80_FR_40271
80 FR 40138 - Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles-Phase 2
80 FR 40138 - Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles-Phase 2
ENVIRONMENTAL PROTECTION AGENCY DEPARTMENT OF TRANSPORTATION National Highway Traffic Safety Administration
Federal Register Volume 80, Issue 133 (July 13, 2015)
Page Range
40138-40765
FR Document
2015-15500
EPA and NHTSA, on behalf of the Department of Transportation, are each proposing rules to establish a comprehensive Phase 2 Heavy- Duty (HD) National Program that will reduce greenhouse gas (GHG) emissions and fuel consumption for new on-road heavy-duty vehicles. This technology-advancing program would phase in over the long-term, beginning in the 2018 model year and culminating in standards for model year 2027, responding to the President's directive on February 18, 2014, to develop new standards that will take us well into the next decade. NHTSA's proposed fuel consumption standards and EPA's proposed carbon dioxide (CO<INF>2</INF>) 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 proposal also includes separate standards for the engines that power combination tractors and vocational vehicles. Certain proposed requirements for control of GHG emissions are exclusive to EPA programs. These include EPA's proposed hydrofluorocarbon standards to control leakage from air conditioning systems in vocational vehicles, and EPA's proposed nitrous oxide (N<INF>2</INF>O) and methane (CH<INF>4</INF>) standards for heavy-duty engines. Additionally, NHTSA is addressing misalignment in the Phase 1 standards between EPA and NHTSA to ensure there are no differences in compliance standards between the agencies. In an effort to promote efficiency, the agencies are also proposing to amend their rules to modify reporting requirements, such as the method by which manufacturers submit pre-model, mid-model, and supplemental reports. EPA's proposed HD Phase 2 GHG emission standards are authorized under the Clean Air Act and NHTSA's proposed HD Phase 2 fuel consumption standards authorized under the Energy Independence and Security Act of 2007. These standards would begin with model year 2018 for trailers under EPA standards and 2021 for all of the other heavy-duty vehicle and engine categories. The agencies estimate that the combined standards would reduce CO<INF>2</INF> emissions by approximately 1 billion metric tons and save 1.8 billion barrels of oil over the life of vehicles and engines sold during the Phase 2 program, providing over $200 billion in net societal benefits. As noted, the proposal also includes certain EPA-specific provisions relating to control of emissions of pollutants other than GHGs. EPA is seeking comment on non- GHG emission standards relating to the use of auxiliary power units installed in tractors. In addition, EPA is proposing to clarify the classification of natural gas engines and other gaseous-fueled heavy- duty engines, and is proposing closed crankcase standards for emissions of all pollutants from natural gas heavy-duty engines. EPA is also proposing 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 proposing to require that rebuilt engines installed in new incomplete vehicles meet the emission standards applicable in the year of assembly, including all applicable standards for criteria pollutants.
Federal Register, Volume 80 Issue 133 (Monday, July 13, 2015)
[Federal Register Volume 80, Number 133 (Monday, July 13, 2015)]
[Proposed Rules]
[Pages 40138-40765]
From the Federal Register Online [www.thefederalregister.org]
[FR Doc No: 2015-15500]
[[Page 40137]]
Vol. 80
Monday,
No. 133
July 13, 2015
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 512, 523, 534, et al.
Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and
Heavy-Duty Engines and Vehicles--Phase 2; Proposed Rule
Federal Register / Vol. 80 , No. 133 / Monday, July 13, 2015 /
Proposed Rules
[[Page 40138]]
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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 512, 523, 534, 535, 537, and 538
[EPA-HQ-OAR-2014-0827; NHTSA-2014-0132; FRL-9927-21-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 Department of
Transportation (DOT) National Highway Traffic Safety Administration
(NHTSA)
ACTION: Proposed rule.
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SUMMARY: EPA and NHTSA, on behalf of the Department of Transportation,
are each proposing rules to establish a comprehensive Phase 2 Heavy-
Duty (HD) National Program that will reduce greenhouse gas (GHG)
emissions and fuel consumption for new on-road heavy-duty vehicles.
This technology-advancing program would phase in over the long-term,
beginning in the 2018 model year and culminating in standards for model
year 2027, responding to the President's directive on February 18,
2014, to develop new standards that will take us well into the next
decade. NHTSA's proposed fuel consumption standards and EPA's proposed
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 proposal also
includes separate standards for the engines that power combination
tractors and vocational vehicles. Certain proposed requirements for
control of GHG emissions are exclusive to EPA programs. These include
EPA's proposed hydrofluorocarbon standards to control leakage from air
conditioning systems in vocational vehicles, and EPA's proposed nitrous
oxide (N2O) and methane (CH4) standards for
heavy-duty engines. Additionally, NHTSA is addressing misalignment in
the Phase 1 standards between EPA and NHTSA to ensure there are no
differences in compliance standards between the agencies. In an effort
to promote efficiency, the agencies are also proposing to amend their
rules to modify reporting requirements, such as the method by which
manufacturers submit pre-model, mid-model, and supplemental reports.
EPA's proposed HD Phase 2 GHG emission standards are authorized under
the Clean Air Act and NHTSA's proposed HD Phase 2 fuel consumption
standards authorized under the Energy Independence and Security Act of
2007. These standards would begin with model year 2018 for trailers
under EPA standards and 2021 for all of the other heavy-duty vehicle
and engine categories. The agencies estimate that the combined
standards would reduce CO2 emissions by approximately 1
billion metric tons and save 1.8 billion barrels of oil over the life
of vehicles and engines sold during the Phase 2 program, providing over
$200 billion in net societal benefits. As noted, the proposal also
includes certain EPA-specific provisions relating to control of
emissions of pollutants other than GHGs. EPA is seeking comment on non-
GHG emission standards relating to the use of auxiliary power units
installed in tractors. In addition, EPA is proposing to clarify the
classification of natural gas engines and other gaseous-fueled heavy-
duty engines, and is proposing closed crankcase standards for emissions
of all pollutants from natural gas heavy-duty engines. EPA is also
proposing 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
proposing to require that rebuilt engines installed in new incomplete
vehicles meet the emission standards applicable in the year of
assembly, including all applicable standards for criteria pollutants.
DATES: Comments on all aspects of this proposal must be received on or
before September 11, 2015. Under the Paperwork Reduction Act (PRA),
comments on the information collection provisions are best assured of
consideration if the Office of Management and Budget (OMB) receives a
copy of your comments on or before August 12, 2015.
EPA and NHTSA will announce the public hearing dates and locations
for this proposal in a supplemental Federal Register document.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2014-0827 (for EPA's docket) and NHTSA-2014-0132 (for NHTSA's
docket) by one of the following methods:
Online: www.regulations.gov: Follow the on-line
instructions for submitting comments.
Email: [email protected].
Mail:
EPA: Air and Radiation Docket and Information Center, Environmental
Protection Agency, Mail code: 28221T, 1200 Pennsylvania Ave. NW.,
Washington, DC 20460.
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.
Hand Delivery:
EPA: EPA Docket Center, EPA WJC West Building, Room 3334, 1301
Constitution Ave. NW., Washington, DC 20460. Such deliveries are only
accepted during the Docket's normal hours of operation, and special
arrangements should be made for deliveries of boxed information.
NHTSA: West Building, Ground Floor, Rm. W12-140, 1200 New Jersey
Avenue SE., Washington, DC 20590, between 9 a.m. and 4 p.m. Eastern
Time, Monday through Friday, except Federal holidays.
Instructions: EPA and NHTSA have established dockets for this
action under Direct your comments to Docket ID No. EPA-HQ-OAR-2014-0827
and/or NHTSA-2014-0132, respectively. See the SUPPLEMENTARY INFORMATION
section on ``Public Participation'' for more information about
submitting written comments.
Docket: All documents in the docket are listed on the
www.regulations.gov Web site. Although listed in the index, some
information is not publicly available, e.g., confidential business
information or other information whose disclosure is restricted by
statute. Certain other material, such as copyrighted material, is not
placed on the Internet and will be publicly available only in hard copy
form. Publicly available docket materials are available either
electronically through 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
[[Page 40139]]
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: For hearing information or to
register, please contact: JoNell Iffland, Office of Transportation and
Air Quality, Assessment and Standards Division (ASD), Environmental
Protection Agency, 2000 Traverwood Drive, Ann Arbor, MI 48105;
Telephone number: (734) 214-4454; Fax number: (734) 214-4816; Email
address: [email protected]. For all other information related to
the rule, please contact: 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 or Analiese Marchesseault, Office of Chief
Counsel, National Highway Traffic Safety Administration, 1200 New
Jersey Avenue SE., Washington, DC 20590. Telephone: (202) 366-2992;
[email protected] or [email protected].
SUPPLEMENTARY INFORMATION:
A. Does this action apply to me?
This proposed action would affect companies that manufacture, sell,
or import into the United States new heavy-duty engines and new Class
2b through 8 trucks, including combination tractors, 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. Proposed regulated categories and entities
include the following:
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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
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. Public Participation
EPA and NHTSA request comment on all aspects of this joint proposed
rule. This section describes how you can participate in this process.
(1) How do I prepare and submit comments?
In this joint proposal, there are many issues common to both EPA's
and NHTSA's proposals. For the convenience of all parties, comments
submitted to the EPA docket will be considered comments submitted to
the NHTSA docket, and vice versa. An exception is that comments
submitted to the NHTSA docket on NHTSA's Draft Environmental Impact
Statement (EIS) will not be considered submitted to the EPA docket.
Therefore, the public only needs to submit comments to either one of
the two agency dockets, although they may submit comments to both if
they so choose. Comments that are submitted for consideration by one
agency should be identified as such, and comments that are submitted
for consideration by both agencies should be identified as such. Absent
such identification, each agency will exercise its best judgment to
determine whether a comment is submitted on its proposal.
Further instructions for submitting comments to either EPA or NHTSA
docket are described below.
EPA: Direct your comments to Docket ID No. EPA-HQ-OAR-2014-0827.
EPA's policy is that all comments received will be included in the
public docket without change and may be made available online at
www.regulations.gov, including any personal information provided,
unless the comment includes information claimed to be Confidential
Business Information (CBI) or other information whose disclosure is
restricted by statute. Do not submit information that you consider to
be CBI or otherwise protected through www.regulations.gov or email. The
www.regulations.gov Web site is an ``anonymous access'' system, which
means EPA will not know your identity or contact information unless you
provide it in the body of your comment. If you send an email comment
directly to EPA without going through www.regulations.gov your email
address will be automatically captured and included as part of the
comment that is placed in the public docket and made available on the
Internet. If you submit an electronic comment, EPA recommends that you
include your
[[Page 40140]]
name and other contact information in the body of your comment and with
any disk or CD-ROM you submit. If EPA cannot read your comment due to
technical difficulties and cannot contact you for clarification, EPA
may not be able to consider your comment. Electronic files should avoid
the use of special characters, any form of encryption, and be free of
any defects or viruses. For additional information about EPA's public
docket visit the EPA Docket Center homepage at http://www.epa.gov/epahome/dockets.htm.
NHTSA: Your comments must be written and in English. To ensure that
your comments are correctly filed in the Docket, please include the
Docket number NHTSA-2014-0132 in your comments. Your comments must not
be more than 15 pages long.\1\ NHTSA established this limit to
encourage you to write your primary comments in a concise fashion.
However, you may attach necessary additional documents to your
comments, and there is no limit on the length of the attachments. If
you are submitting comments electronically as a PDF (Adobe) file, we
ask that the documents submitted be scanned using the Optical Character
Recognition (OCR) process, thus allowing the agencies to search and
copy certain portions of your submissions.\2\ Please note that pursuant
to the Data Quality Act, in order for the substantive data to be relied
upon and used by the agency, it must meet the information quality
standards set forth in the OMB and Department of Transportation (DOT)
Data Quality Act guidelines. Accordingly, we encourage you to consult
the guidelines in preparing your comments. OMB's guidelines may be
accessed at http://www.whitehouse.gov/omb/fedreg/reproducible.html.
DOT's guidelines may be accessed at http://www.dot.gov/dataquality.htm.
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\1\ See 49 CFR 553.21.
\2\ Optical character recognition (OCR) is the process of
converting an image of text, such as a scanned paper document or
electronic fax file, into computer-editable text.
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(2) Tips for Preparing Your Comments
When submitting comments, please remember to:
Identify the rulemaking by docket number and other
identifying information (subject heading, Federal Register date and
page number).
Explain why you agree or disagree, suggest alternatives,
and substitute language for your requested changes.
Describe any assumptions and provide any technical
information and/or data that you used.
If you estimate potential costs or burdens, explain how
you arrived at your estimate in sufficient detail to allow for it to be
reproduced.
Provide specific examples to illustrate your concerns, and
suggest alternatives.
Explain your views as clearly as possible, avoiding the
use of profanity or personal threats.
Make sure to submit your comments by the comment period
deadline identified in the DATES section above.
(3) How can I be sure that my comments were received?
NHTSA: If you submit your comments by mail and wish Docket
Management to notify you upon its receipt of your comments, enclose a
self-addressed, stamped postcard in the envelope containing your
comments. Upon receiving your comments, Docket Management will return
the postcard by mail.
(4) How do I submit confidential business information?
Any confidential business information (CBI) submitted to one of the
agencies will also be available to the other agency. However, as with
all public comments, any CBI information only needs to be submitted to
either one of the agencies' dockets and it will be available to the
other. Following are specific instructions for submitting CBI to either
agency. If you have any questions about CBI or the procedures for
claiming CBI, please consult the persons identified in the FOR FURTHER
INFORMATION CONTACT section.
EPA: Do not submit CBI to EPA through www.regulations.gov or email.
Clearly mark the part or all of the information that you claim to be
CBI. For CBI information in a disk or CD ROM that you mail to EPA, mark
the outside of the disk or CD ROM as CBI and then identify
electronically within the disk or CD ROM the specific information that
is claimed as CBI. Information not marked as CBI will be included in
the public docket without prior notice. In addition to one complete
version of the comment that includes information claimed as CBI, a copy
of the comment that does not contain the information claimed as CBI
must be submitted for inclusion in the public docket. Information so
marked will not be disclosed except in accordance with procedures set
forth in 40 CFR part 2.
NHTSA: If you wish to submit any information under a claim of
confidentiality, you should submit three copies of your complete
submission, including the information you claim to be confidential
business information, to the Chief Counsel, NHTSA, at the address given
above under FOR FURTHER INFORMATION CONTACT. When you send a comment
containing confidential business information, you should include a
cover letter setting forth the information specified in our
confidential business information regulation.\3\
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\3\ See 49 CFR part 512.
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In addition, you should submit a copy from which you have deleted
the claimed confidential business information to the Docket by one of
the methods set forth above.
(5) How can I read the comments submitted by other people?
You may read the materials placed in the docket for this document
(e.g., the comments submitted in response to this document by other
interested persons) at any time by going to http://www.regulations.gov.
Follow the online instructions for accessing the dockets. You may also
read the materials at the EPA Docket Center or NHTSA Docket Management
Facility by going to the street addresses given above under ADDRESSES.
(6) How do I participate in the public hearings?
EPA and NHTSA will announce the public hearing dates and locations
for this proposal in a supplemental Federal Register document. At all
hearings, both agencies will accept comments on the rulemaking, and
NHTSA will also accept comments on the EIS.
If you would like to present testimony at the public hearings, we
ask that you notify EPA and NHTSA contact persons listed in the FOR
FURTHER INFORMATION CONTACT section at least ten days before the
hearing. Once EPA and NHTSA learn how many people have registered to
speak at the public hearing, we will allocate an appropriate amount of
time to each participant. For planning purposes, each speaker should
anticipate speaking for approximately ten minutes, although we may need
to adjust the time for each speaker if there is a large turnout. We
suggest that you bring copies of your statement or other material for
EPA and NHTSA panels. It would also be helpful if you send us a copy of
your statement or other materials before the hearing. To accommodate as
many speakers as possible, we prefer that speakers not use
technological aids (e.g., audio-visuals, computer slideshows). However,
if you plan to do so, you must notify the contact persons in the FOR
FURTHER INFORMATION CONTACT section above. You also must make
arrangements to provide your presentation or any other
[[Page 40141]]
aids to EPA and NHTSA in advance of the hearing in order to facilitate
set-up. In addition, we will reserve a block of time for anyone else in
the audience who wants to give testimony. The agencies will assume that
comments made at the hearings are directed to the proposed rule unless
commenters specifically reference NHTSA's EIS in oral or written
testimony.
The hearing will be held at a site accessible to individuals with
disabilities. Individuals who require accommodations such as sign
language interpreters should contact the persons listed under FOR
FURTHER INFORMATION CONTACT section above no later than ten days before
the date of the hearing.
EPA and NHTSA will conduct the hearing informally, and technical
rules of evidence will not apply. We will arrange for a written
transcript of the hearing and keep the official record of the hearing
open for 30 days to allow you to submit supplementary information. You
may make arrangements for copies of the transcript directly with the
court reporter.
C. Did EPA conduct a peer review before issuing this notice?
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.3, a peer review of updates to the vehicle simulation
model (GEM) for the proposed 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
(from academia and a national laboratory). The peer review report and
the agency's response to the peer review comments are available in
Docket ID No. EPA-HQ-OAR-2014-0827.
D. Executive Summary
(1) Commitment to Greenhouse Gas Emission Reductions and Vehicle Fuel
Efficiency
As part of the Climate Action Plan announced in June 2013,\4\ the
President 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 medium-
and heavy-duty vehicles. More than 70 percent of the oil used in the
United States and 28 percent of GHG emissions come from the
transportation sector, and since 2009 EPA and NHTSA have worked with
industry and states 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 proposed here (referred to as Phase 2) would build on the
light-duty vehicle standards spanning model years 2011 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 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\ The White House, The President's Climate Action Plan (June,
2013). http://www.whitehouse.gov/share/climate-action-plan.
\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. 2014. Inventory of
U.S. Greenhouse Gas Emissions and Sinks: 1990-2012. EPA 430-R-14-
003. Mobile sources emitted 28 percent of all U.S. GHG emissions in
2012. Available at http://www.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2014-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, 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 double by 2025.\7\ This is projected to save consumers
$1.7 trillion at the pump--roughly $8,200 per vehicle for a MY2025
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\ Id.
\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\ 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 Canada, and leaders
from the environmental community, set standards that 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 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, but support--indeed are critical for--United States
leadership to encourage other countries to also achieve meaningful GHG
reductions.
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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 proposal 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 200 meetings with
heavy-duty vehicle and engine manufacturers, technology suppliers,
trucking fleets, truck drivers, dealerships, environmental
organizations, and state agencies. As with the previous light-duty
rules and the heavy-duty Phase 1 rule, the agencies have consulted
[[Page 40142]]
frequently with the California Air Resources Board staff during the
development of this Phase 2 proposal, given California's unique ability
among the states to adopt their own GHG standards for on-highway
engines and vehicles. The agencies look forward to feedback and ongoing
conversation following the release of this proposed rule from all
stakeholders--including through planned public hearings, written
comments, and other opportunities for input.
(2) Overview of Phase 1 Medium- and Heavy-Duty Vehicle Standards
The President's direction to EPA and NHTSA to develop GHG emission
and fuel efficiency standards for MDVs and HDVs resulted in the
agencies' promulgation of the Phase 1 program in 2011, which covers new
trucks and heavy vehicles in model years 2014 to 2018. The Phase 1
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 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 two-thirds of all 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 15 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 20 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.\14\
---------------------------------------------------------------------------
\14\ The proposed Phase 2 program would also include NHTSA
recreational vehicle fuel efficiency standards.
---------------------------------------------------------------------------
Heavy-duty engines. In addition to vehicle types, the
Phase 1 rule has separate standards for heavy-duty engines, to assure
they contribute to the overall vehicle reductions in fuel consumption
and GHG emissions.
The Phase 1 standards are premised on utilization of immediately
available technologies. 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 regulatory subcategories. However, credits are not allowed to be
transferred across subcategories.
The Phase 1 program is projected to save 530 million barrels of oil
and avoid 270 million metric tons of GHG emissions.\15\ At the same
time, the program is projected to produce $50 billion in fuel savings,
and net societal benefits of $49 billion. 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 new technology, and the agencies have seen no evidence of ``pre-
buy'' effects in response to the standards.
---------------------------------------------------------------------------
\15\ 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.
---------------------------------------------------------------------------
(3) Overview of Proposed 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. The
proposed Phase 2 standards carry forward our commitment to meaningful
collaboration with stakeholders and the public, as they build on more
than 200 meetings with manufacturers, suppliers, trucking fleets,
dealerships, state air quality agencies, non-governmental organizations
(NGOs), and other stakeholders to identify and understand the
opportunities and challenges involved with this next level of fuel
saving technology. These meetings have been invaluable to the agencies,
enabling the development of a proposal that appropriately balances all
potential impacts and effectively minimizes the possibility of
unintended consequences.
Phase 2 would include technology-advancing standards that would
phase in over the long-term (through model year 2027) to result in an
ambitious, yet achievable program that would allow manufacturers to
meet standards through a mix of different technologies at reasonable
cost. The Phase 2 standards would 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 would build on and advance
Phase 1 in a number of important ways including: 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 standards for trailers;
further encouraging innovation and providing flexibility; including
vehicles produced by small business manufacturers; 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.
Strengthening standards to account for ongoing
technological advancements. Relative to the baseline as of the end of
Phase 1, the proposed standards (labeled Alternative 3 or the
``preferred alternative'' throughout this proposal) would achieve
vehicle fuel savings of up to 8 percent and 24 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 five years for vocational vehicles, and about three years for
heavy-duty pickups and vans. The agencies are further proposing to
phase in these MY 2027 standards with interim standards for model years
2021 and 2024 (and for certain types of trailers, EPA is proposing
model year 2018 phase-in standards as well).
[[Page 40143]]
In addition to the proposed standards, the agencies are considering
another alternative (Alternative 4), which would achieve the same
performance as the proposed standards 2-3 years earlier, leading to
overall reductions in fuel use and greenhouse gas emissions. The
agencies believe Alternative 4 has the potential to be the maximum
feasible and appropriate alternative; however, based on the evidence
currently before us, EPA and NHTSA have outstanding questions regarding
relative risks and benefits of Alternative 4 due to the timeframe
envisioned by that alternative. The agencies are proposing Alternative
3 based on their analyses and projections, and taking into account the
agencies' respective statutory considerations. The comments that the
agencies receive on this proposal will be instrumental in helping us
determine standards that are appropriate (for EPA) and maximum feasible
(for NHTSA), given the discretion that both agencies have under our
respective statutes. Therefore, the agencies have presented different
options and raised specific questions throughout the proposed rule,
focusing in particular on better understanding the perspectives on the
feasible adoption rates of different technologies, considering
associated costs and necessary lead time.
Setting standards for trailers for the first time. In
addition to retaining the vehicle and engine categories covered in the
Phase 1 program, which include semi tractors, heavy-duty pickup trucks
and work vans, vocational vehicles, and separate standards for heavy-
duty engines, the Phase 2 standards propose fuel efficiency and GHG
emission standards for trailers used in combination with tractors.
Although the agencies are not proposing standards for all trailer
types, the majority of new trailers would be covered.
Encouraging technological innovation while providing
flexibility and options for manufacturers. For each category of HDVs,
the standards would set performance targets that allow manufacturers to
achieve reductions through a mix of different technologies and leave
manufacturers free to choose any means of compliance. For tractors and
vocational vehicles, enhanced test procedures and an expanded and
improved compliance simulation model enable the proposed vehicle
standards to encompass more of the complete vehicle and to account for
engine, transmission and driveline improvements than the Phase 1
program. 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 proposal updates drive cycles and vehicle
configurations to better reflect real world operation. For tractor
standards, for example, different combinations of improvements like
advanced aerodynamics, engine improvements and waste-heat recovery,
automated transmission, and lower rolling resistance tires and
automatic tire inflation can be used to meet standards. Additionally,
the agencies' analyses indicate that this proposal 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 proposing to regulate small business entities under
Phase 2 (notably certain trailer manufacturers), but have conducted
extensive proceedings pursuant to Section 609 of the Regulatory
Flexibility Act, and otherwise have engaged in extensive consultation
with stakeholders, and developed a proposed approach to provide
targeted flexibilities geared toward helping small businesses comply
with the Phase 2 standards. Specifically, the agencies are proposing to
delay all new requirements by one year and simplify certification
requirements for small businesses, and are further proposing additional
specific flexibilities adapted to particular types of trailers.
Summary of the Proposed 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, Based on Analysis Method A \a\ \b\
\c\
------------------------------------------------------------------------
3% 7%
------------------------------------------------------------------------
Fuel Reductions (billion gallons)....... 72-77
GHG Reductions (MMT, CO2eq)............. 974-1034
------------------------------------------------------------------------
Pre-Tax Fuel Savings ($billion)......... 165-175 89-94
Discounted Technology Costs ($billion).. 25-25.4 16.8 -17.1
Value of reduced emissions ($billion)... 70.1-73.7 52.9-55.6
Total Costs ($billion).................. 30.5-31.1 20.0-20.5
Total Benefits ($billion)............... 261-276 156-165
Net Benefits ($billion)................. 231-245 136-144
------------------------------------------------------------------------
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\ Range reflects two reference case assumptions, one that projects
very little improvement in new vehicle fuel efficiency absent new
standards, and the second that projects more significant improvements
in vehicle fuel efficiency absent new standards.
\c\ Benefits and net benefits (including those in the 7% discount rate
column) use the 3 percent average SCC-CO2 value applied only to CO2
emissions; GHG reductions include CO2, CH4, N2O and HFC reductions.
Summary of the Proposed Phase 2 Medium- and Heavy-Duty Vehicle Annual
Fuel and GHG Reductions, Program Costs, Benefits and Net Benefits in
Calendar Years 2035 and 2050, Based on Analysis Method B \a\
------------------------------------------------------------------------
2035 2050
------------------------------------------------------------------------
Fuel Reductions (Billion Gallons)....... 9.3 13.4
GHG Reduction (MMT, CO2eq).............. 127.1 183.4
Vehicle Program Costs (including -$6.0 -$7.1
Maintenance; Billions of 2012$)........
Fuel Savings (Pre-Tax; Billions of $37.2 $57.5
2012$).................................
Benefits (Billions of 2012$)............ $20.5 $32.9
[[Page 40144]]
Net Benefits (Billions of 2012$)........ $51.7 $83.2
------------------------------------------------------------------------
Note:
\a\ Benefits and net benefits use the 3 percent average SCC-CO2 value
applied only to CO2 emissions; GHG reductions include CO2, CH4, N2O
and HFC reductions; values reflect the preferred alternative relative
to the less dynamic baseline (a reference case that projects very
little improvement in new vehicle fuel economy absent new standards.
Summary of the Proposed Phase 2 Medium- and Heavy-Duty Vehicle Program Expected Per-Vehicle Fuel Savings, GHG
Emission Reductions, and Cost for Key Vehicle Categories, Based on Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
MY 2021 MY 2024 MY 2027
----------------------------------------------------------------------------------------------------------------
Maximum Vehicle Fuel Savings and
Tailpipe GHG Reduction (%)
Tractors..................... 13 20 24
Trailers \b\................. 4 6 8
Vocational Vehicles.......... 7 11 16
Pickups/Vans................. 2.5 10 16
Per Vehicle Cost ($) \c\ (%
Increase in Typical Vehicle
Price) \d\
Tractors..................... $6,710 (7%) $9,940 (10%) $11,680 (12%)
Trailers..................... $900 (4%) $1,010 (4%) $1,170 (5%)
Vocational Vehicles.......... $1,150 (2%) $1,770 (3%) $3,380 (5%)
Pickups/Vans................. $520 (1%) $950 (2%) $1,340 (3%)
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Note that the proposed EPA standards for some categories of box trailers begin in model year 2018; values
reflect the preferred alternative relative to the less dynamic baseline (a reference case that projects very
little improvement in new vehicle fuel economy absent new standards.
\b\ All engine costs are included.
\c\ For this table, we use a minimum vehicle price today of $100,000 for tractors, $25,000 for trailers, $70,000
for vocational vehicles and $40,000 for HD pickups/vans.
Payback Periods for MY2027 Vehicles Under the Proposed Standards, Based
on Analysis Method B
[Payback occurs in the year shown; using 7% discounting]
------------------------------------------------------------------------
Proposed
standards
------------------------------------------------------------------------
Tractors/Trailers....................................... 2nd
Vocational Vehicles..................................... 6th
Pickups/Vans............................................ 3rd
------------------------------------------------------------------------
(4) Issues Addressed in This Proposed Rule
This proposed rule contains extensive discussion of the background,
elements, and implications of the proposed Phase 2 program. 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 proposed 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 proposed 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 proposed standards. Sections X, XI, and XII
present the alternatives analyses, consideration of natural gas
vehicles, and the agencies' initial response to recommendations from
the Academy of Sciences. Finally, Sections XIII and XIV discuss the
changes that the proposed Phase 2 rules would have on Phase 1 standards
and other regulatory provisions. In addition to this preamble, the
agencies have also prepared a joint Draft Regulatory Impact Analysis
(DRIA) which is available on our respective Web sites and in the public
docket for this rulemaking which provides additional data, analysis and
discussion of the proposed standards and the alternatives analyzed by
the agencies. We request comment on all aspects of this proposed
rulemaking, including the DRIA.
Table of Contents
A. Does this action apply to me?
B. Public Participation
C. Did EPA conduct a peer review before issuing this notice?
D. Executive Summary
I. Overview
A. Background
B. Summary of Phase 1 Program
C. Summary of the Proposed Phase 2 Standards and Requirements
D. Summary of the Costs and Benefits of the Proposed Rule
E. EPA and NHTSA Statutory Authorities
F. Other Issues
II. Vehicle Simulation, Engine Standards and Test Procedures
A. Introduction and Summary of Phase 1 and Phase 2 Regulatory
Structures
B. Phase 2 Proposed Regulatory Structure
C. Proposed Vehicle Simulation Model--Phase 2 GEM
D. Proposed 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 Proposed Phase 2 Tractor Program
C. Proposed Phase 2 Tractor Standards
D. Feasibility of the Proposed Tractor Standards
E. Proposed Compliance Provisions for Tractors
F. Flexibility Provisions
IV. Trailers
A. Summary of Trailer Consideration in Phase 1
B. The Trailer Industry
C. Proposed Phase 2 Trailer Standards
D. Feasibility of the Proposed Trailer Standards
E. Alternative Standards and Feasibility Considered
F. Trailer Standards: Compliance and Flexibilities
V. Class 2b-8 Vocational Vehicles
A. Summary of Phase 1 Vocational Vehicle Standards
[[Page 40145]]
B. Proposed Phase 2 Standards for Vocational Vehicles
C. Feasibility of the Proposed Vocational Vehicle Standards
D. Alternative Vocational Vehicle Standards Considered
E. Compliance Provisions for Vocational Vehicles
VI. Heavy-Duty Pickups and Vans
A. Introduction and Summary of Phase 1 HD Pickup and Van
Standards
B. Proposed HD Pickup and Van Standards
C. Feasibility of Pickup and Van Standards
D. DOT CAFE Model Analysis of the Regulatory Alternatives for HD
Pickups and Vans
E. 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 Proposed Standards and Alternative 4
C. What are the projected reductions in fuel consumption and GHG
emissions?
VIII. How will this proposed action impact non-GHG emissions and
their associated effects?
A. Emissions Inventory Impacts
B. Health Effects of Non-GHG Pollutants
C. Environmental Effects of Non-GHG Pollutants
D. Air Quality Impacts of Non-GHG Pollutants
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 and in benefits and costs?
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. Agencies' Response to Recommendations From the National Academy
of Sciences
A. Overview
B. Major Findings and Recommendations of the NAS Phase 2 First
Report
XIII. Amendments to Phase 1 Standards
A. EPA Amendments
B. Other Compliance Provisions for NHTSA
XIV. Other Proposed Regulatory Provisions
A. Proposed Amendments Related to Heavy-Duty Highway Engines and
Vehicles
B. Amendments Affecting Gliders 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 Nonroad Diesel Engines in 40 CFR Part
1039
H. Amendments Related to Marine Diesel Engines in 40 CFR Parts
1042 and 1043
I. Amendments Related to Locomotives in 40 CFR Part 1033
J. Miscellaneous EPA Amendments
K. 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
XV. Statutory and Executive Order Reviews
A. Executive Order 12866: Regulatory Planning and Review and
Executive 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
XVI. EPA and NHTSA Statutory Authorities
A. EPA
B. NHTSA
C. List of Subjects
I. Overview
A. Background
This background and summary of the proposed Phase 2 GHG emissions
and fuel efficiency standards includes an overview 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 proposed Phase 2 standards and requirements, a summary
of the costs and benefits of the proposed Phase 2 standards, discussion
of EPA and NHTSA statutory authorities, and other issues.
For purposes of this preamble, 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.\16\ They 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.17 18
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\16\ 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.
\17\ 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.
\18\ 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.
---------------------------------------------------------------------------
Consistent with the President's direction, over the past two years
as we have developed this proposal, 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, drive lines, 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
particular, NHTSA and EPA have consulted on an on-going basis with the
California Air Resources Board (CARB) over the past two years as we
have developed the Phase 2 proposal. In addition, CARB staff and
managers have also participated with EPA and NHTSA in meetings with
[[Page 40146]]
many external stakeholders, in particular with vehicle OEMs and
technology suppliers.\19\
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\19\ Vehicle chassis manufacturers are known in this industry as
original equipment manufacturers or OEMs.
---------------------------------------------------------------------------
NHTSA and EPA staff also participated in a large number of
technical and policy conferences over the past two 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
the proposed 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 included well
over 200 meetings with stakeholders. These meetings and conferences
have been invaluable to the agencies. We believe they have enabled us
to develop this proposal in such a way as to appropriately balance all
of the potential impacts, to minimize the possibility of unintended
consequences, and to ensure that we are requesting comment on a wide
range of issues that can inform the final rule.
(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 tractors one sees on the highway to
the largest pickup trucks and vans, as well as vocational vehicles
covering a 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.\20\ 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.
---------------------------------------------------------------------------
\20\ 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.\21\
---------------------------------------------------------------------------
\21\ 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.
---------------------------------------------------------------------------
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 may span Classes 2b through 8, vary
widely in size, including smaller and larger van trucks, utility
``bucket'' trucks, tank trucks, refuse trucks, urban and over-the-road
buses, fire trucks, flat-bed trucks, and dump trucks, among others. The
annual mileage of these 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 two-thirds 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.
EPA and NHTSA have designed our respective proposed standards in
careful consideration of the diversity and complexity of the heavy-duty
truck industry, as discussed in Section I.B.
(2) Related Regulatory and Non-Regulatory Programs
(a) History of EPA's Heavy-Duty Regulatory Program and Impacts of
Greenhouse Gases on Climate Change
This subsection provides an overview of the history of EPA's heavy-
duty regulatory program and impacts of greenhouse gases on climate
change.
(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
[[Page 40147]]
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 those on-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) 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).\22\ 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.
---------------------------------------------------------------------------
\22\ ``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'').
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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
increases the likelihood of reductions in 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 such
assessments have been released. These assessments 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
[[Page 40148]]
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 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 National
Research Council of the National Academies assessment projected that
concentrations by the end of the century would increase to levels that
the Earth has not experienced for millions of years.\23\ 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.'' \24\ What this means, as stated in another
NRC assessment, is that:
---------------------------------------------------------------------------
\23\ National Research Council, Understanding Earth's Deep Past,
p. 1
\24\ 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.\25\
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\25\ 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 recently released USGCRP ``National Climate Assessment'' \26\
emphasizes that climate change is already happening now and it is
happening in the United States. The assessment documents the increases
in some extreme weather and climate events in recent decades, the
damage and disruption to infrastructure and agriculture, and projects
continued increases in impacts across a wide range of peoples, sectors,
and ecosystems.
---------------------------------------------------------------------------
\26\ 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.\27\
The average concentration in 2013 was 396 parts per million. And the
monthly concentration in April of 2014 was 401 parts per million, the
first time a monthly 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.\28\
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\27\ ftp://aftp.cmdl.noaa.gov/products/trends/co2/co2_annmean_mlo.txt.
\28\ http://www.esrl.noaa.gov/gmd/ccgg/trends/.
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(b) The NHTSA and EPA Light-Duty National GHG and Fuel Economy Program
On May 7, 2010, EPA and NHTSA finalized the first-ever National
Program for light-duty cars and trucks, which set GHG emissions and
fuel economy standards for model years 2012-2016 (see 75 FR 25324).
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).\29\ 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.
---------------------------------------------------------------------------
\29\ 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.
---------------------------------------------------------------------------
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 would 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
last ten years to develop test
[[Page 40149]]
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 program, the agencies drew from this testing and
from the SmartWay experience. In the same way, the agencies benefitted
from SmartWay in developing the proposed Phase 2 trailer program.
(d) 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.\30\ 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, the 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.\31\ The
tractors and trailers 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.
Recently, 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.\32\ 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).\33\ And, recently, California Governor Jerry Brown
established a target of up to 50 percent petroleum reduction by 2030.
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\30\ 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.
\31\ See http://www.arb.ca.gov/msprog/truckstop/trailers/trailers.htm for a summary of CARB's ``Tractor-Trailer Greenhouse
Gas Regulation''.
\32\ See http://www.arb.ca.gov/regact/2013/hdghg2013/hdghg2013.htm for details regarding CARB's adoption of the Phase 1
standards.
\33\ 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 (http://www.epa.gov/region09/cleantech/).
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In addition to California's efforts to reduce GHG emissions that
contribute to climate change, California also faces unique air quality
challenges as compared to many other regions of the United States. Many
areas of the state are classified as non-attainment for both the ozone
and particulate matter National Ambient Air Quality Standards (NAAQS)
with California having the nation's only two ``Extreme'' ozone non-
attainment airsheds (the San Joaquin Valley and South Coast Air
Basins).\34\ By 2016, California must submit to EPA its Clean Air Act
State Implementation Plans (SIPs) that demonstrate how the 2008 ozone
and 2006 PM2.5 NAAQS will be met by Clean Air Act deadlines.
Extreme ozone areas must attain the 2008 ozone NAAQS by no later than
2032 and PM2.5 moderate areas must attain the 2006
PM2.5 standard by 2021 or, if reclassified to serious, by
2025.
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\34\ See http://www.epa.gov/airquality/greenbk/index.html for
more information on EPA's nonattainment designations.
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Heavy-duty vehicles are responsible today for one-third of the
state's oxides of nitrogen (NOX) emissions. California has
estimated that the state's South Coast Air Basin will need nearly a 90
percent reduction in heavy-duty vehicle NOX emissions by
2032 from 2010 levels to attain the 2008 NAAQS for ozone. Additionally,
on November 25, 2014, EPA issued a proposal to strengthen the ozone
NAAQS. If a change to the ozone NAAQS is finalized, California and
other areas of the country will need to identify and implement measures
to reduce NOX as needed to complement Federal emission
reduction measures. While this section is focused on California's
regulatory programs and air quality needs, EPA recognizes that other
states and local areas are concerned about the challenges of reducing
NOX and attaining, as well as maintaining, the ozone NAAQS
(further discussed in Section VIII.D.1 below).
In order to encourage the use of lower NOX emitting new
heavy-duty vehicles in California, in 2013 CARB adopted a voluntary low
NOX emission standard for heavy-duty engines.\35\ In
addition, in 2013 CARB awarded a major new research contract to
Southwest Research Institute to investigate advanced technologies that
could reduce heavy-duty vehicle NOX emissions well below the
current EPA and CARB standards.
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\35\ See http://www.arb.ca.gov/regact/2013/hdghg2013/hdghg2013.htm for a description of the CARB optional reduced
NOX emission standards for on-road heavy-duty engines.
---------------------------------------------------------------------------
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.\36\ 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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\36\ 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
[[Page 40150]]
benefits for the regulated industry if the Federal Phase 2 standards
could result in a single, National Program that would meet the NHTSA
and EPA'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).
Similarly, CARB has expressed support in the past for a Federal
heavy-duty Phase 2 program that would produce significant GHG
reductions both at the Federal level and in California that could
enable CARB to adopt the same standards at the state level. This is
similar to CARB's approach for the Federal heavy-duty Phase 1 program,
and with past EPA criteria pollutant standards for heavy-duty vehicles
and engines. 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), NHTSA and EPA have consulted on an on-going basis with
CARB over the past two years as we have developed the Phase 2 proposal.
The agencies' technical staff have shared information on technology
cost, technology effectiveness, and feasibility with the CARB staff. We
have also received information from CARB on these same topics. EPA and
NHTSA have also shared preliminary results from several of our modeling
exercises with CARB as we examined different potential levels of
stringency for the Phase 2 program. In addition, CARB staff and
managers have also participated with EPA and NHTSA in meetings with
many external stakeholders, in particular with vehicle OEMs and
technology suppliers.
In addition to information on GHG emissions, CARB has also kept EPA
and NHTSA informed of the state's need to consider opportunities for
additional NOX emission reductions from heavy-duty vehicles.
CARB has asked the agencies to consider opportunities in the Heavy-Duty
Phase 2 rulemaking to encourage or incentivize further NOX
emission reductions, in addition to the petroleum and GHG reductions
which would come from the Phase 2 standards. When combined with the
Phase 1 standards, the technologies the agencies are projecting to be
used to meet the proposed GHG emission and fuel efficiency standards
would be expected to reduce NOX emissions by over 450,000
tons in 2050 (see Section VIII).
EPA and NHTSA believe that through this information sharing and
dialog we will enhance 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.
The agencies will continue to seek input from CARB, and from all
stakeholders, throughout this rulemaking.
(e) Environment Canada
On March 13, 2013, Environment Canada (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. Environment Canada 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,
Environment Canada 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.\37\ Environment Canada has also been of great
assistance during the development of this Phase 2 proposal. In
particular, Environment Canada supported aerodynamic testing, and
conducted chassis dynamometer emissions testing.
---------------------------------------------------------------------------
\37\ http://www.ijc.org/en_/Air_Quality__Agreement.
---------------------------------------------------------------------------
(f) Recommendations of the National Academy of Sciences
In April 2010 as mandated by Congress in the Energy Independence
and Security Act of 2007 (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.'' 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:
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
As described in Sections II, IV, and XII, the agencies are
proposing to incorporate many of these recommendations into this
proposed Phase 2 program, especially those 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 GHG mandatory 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 are
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 have 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
[[Page 40151]]
tractors, heavy-duty pickups and vans, and vocational vehicles--based
on the relative degree of homogeneity among trucks within each
category. The Phase 1 rule 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 summarize briefly EPA's final
GHG emission standards and NHTSA's final fuel consumption standards for
the three regulatory categories of heavy-duty vehicles and for the
engines powering vocational vehicles and tractors. See Sections 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 are proposing to base the Phase 2 standards 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 the draft RIA Chapter 4, and other test procedures
are discussed further in the draft RIA Chapter 3. It is important to
note that due to these test procedure changes, the Phase 1 standards
and the proposed Phase 2 standards are not directly comparable in an
absolute sense. In particular, the proposed revisions 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 proposing to
apply 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 agencies intend such changes
to address a broader range of technologies not part of the projected
compliance path for use in Phase 1.
(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 two-thirds, 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 vehicles 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.\38\
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\38\ 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.
---------------------------------------------------------------------------
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, 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. The agencies have verified, through our own
confirmatory testing, that the values inputs into the model by
manufacturers are generally correct. Prior to and after adopting the
Phase 1 standards, the agencies worked with manufacturers to minimize
impacts of this process on their normal business practices.
In addition to the final 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 15 percent of today's GHG
emissions from the heavy-duty vehicle sector.\39\
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\39\ EPA MOVES Model, http://www.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,\40\ 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 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
[[Page 40152]]
have been regulated by EPA for criteria pollutants and also consistent
with the way their light-duty counterpart vehicles are regulated by
NHTSA and EPA. 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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\40\ 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 would be 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.\41\ 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. The phase-in takes
the form of a set of target curves, with increasing stringency in each
MY.
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\41\ As explained in Section XII, EPA is proposing to recodify
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 final EPA standards for
2018 (including a separate standard to control air conditioning system
leakage) 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 and greenhouse gas emissions 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 urban 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 20 percent of the GHG emissions and burn approximately 21
percent of the fuel consumed by today's heavy-duty truck sector.\42\
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\42\ EPA MOVES model, http://www.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 & 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.
Engines used in vocational vehicles are subject to separate Phase 1
engine-based standards. Optional certification paths, for EPA and
NHTSA, are also provided to enhance the flexibilities for vocational
vehicles. Manufacturers producing spark-ignition (or gasoline) cab-
complete or incomplete vehicles weighing over 14,000 lbs GVWR and below
26,001 lbs GVWR have the option to certify to the complete vehicle
standards for heavy-duty pickup trucks and vans rather than using the
separate engine and chassis standards for vocational vehicles.
(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.\43\ 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.
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\43\ 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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The agencies also finalized a regulatory alternative whereby a
manufacturer, for an interim period of the 2014-2016 MYs, would have
the option to comply with a unique standard based on a three percent
reduction from an individual engine model's own 2011 MY baseline
level.\44\
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\44\ See 76 FR 57144.
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[[Page 40153]]
(e) Manufacturers Excluded From the Phase 1 Standards
Phase 1 temporarily 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 defines a
small business by the maximum number of employees; for example, this is
currently 1,000 for heavy-duty vehicle manufacturing and 750 for engine
manufacturing. 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 would apply for small
businesses.
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.
(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 disbenefits from
increased driving accidents, 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.\45\
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\45\ 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 NHTSA's and EPA'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.\46\
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\46\ 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 19
subcategories of vehicles. These subcategories are grouped into 9
averaging sets to provide greater opportunities in leveraging
compliance. For tractors and vocational vehicles, the fleet averaging
sets are Classes 2b through 5, Classes 6 and 7, and Class 8 weight
classes. For engines, the fleet averaging sets are gasoline engines,
light heavy-duty diesel engines, medium heavy-duty diesel engines, and
heavy heavy-duty diesel engines. Complete HD pickups and vans (both
spark-ignition and compression-ignition) are the final fleet averaging
set.
As noted above, the agencies included a restriction on averaging,
banking, and trading of credits between the various regulatory
subcategories by defining three HD vehicle averaging sets: Light heavy-
duty (Classes 2b-5); medium heavy-duty (Class 6-7); and heavy heavy-
duty (Class 8). This allows the use of credits between vehicles within
the same weight class. This means that a Class 8 day cab tractor can
exchange credits with a Class 8 high roof sleeper tractor but not with
a smaller Class 7 tractor. Also, a Class 8 vocational vehicle can
exchange credits with a Class 8 tractor. However, we did not allow
trading between engines and chassis. We similarly allowed for trading
among engine categories only within an averaging set, of which there
are four: Spark-ignition engines, compression-ignition light heavy-duty
engines, compression-ignition medium heavy-duty engines, and
compression-ignition heavy heavy-duty engines.
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.\47\ For the early credits and
advanced technology credits, the agencies adopted a 1.5 x 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 this promising technology,
[[Page 40154]]
the Phase 1 rule does not restrict averaging or trading by averaging
set in this instance.
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\47\ 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.
---------------------------------------------------------------------------
For other vehicle or engine technologies that can reduce
CO2 and fuel consumption, but for which there do not yet
exist established methods for quantifying reductions, 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 need to quantify the reductions in fuel consumption and
CO2 emissions that the technology is expected to achieve,
above and beyond those achieved on the existing test procedures. As
with ABT, the use of innovative technology credits 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 allows
manufacturers to generate credits for such early compliance. The market
appears to be very accepting of the new technology, 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 began. Moreover, manufacturers' compliance plans
are taking advantage of 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 recently 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 Co. v. EPA, 783 F. 3d 1291 (D.C. Cir. 2015), U.S. App.
LEXIS 6780, F.3d (D.C. Cir. April 24, 2015).
C. Summary of the Proposed Phase 2 Standards and Requirements
The agencies are proposing new standards that build on and enhance
existing Phase 1 standards, as well as proposing the first ever
standards for certain trailers used in combination with heavy-duty
tractors. Taken together, the proposed Phase 2 program would comprise a
set of largely technology-advancing standards that would achieve
greater GHG and fuel consumption savings than the Phase 1 program. As
described in more detail in the following sections, the agencies are
proposing these standards because, based on the information available
at this time, we believe they would best match 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 agencies request comment
on all aspects of our feasibility analysis including projections of
feasible market adoption rates and technological effectiveness for each
technology.
The proposed Phase 2 standards would represent a more technology-
forcing \48\ 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 proposing standards for MY 2027
that would likely require manufacturers to make extensive use of these
technologies. For existing technologies and technologies in the final
stages of development, we project that manufacturers would likely apply
them to nearly all vehicles, excluding those specific vehicles with
applications or uses that would 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.
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\48\ In this context, the term ``technology-forcing'' 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.
Technology-forcing standards do not require manufacturers to use any
specific technologies.
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Under Alternative 3, the preferred alternative, the agencies
propose to provide ten years of lead time for manufacturers to meet
these 2027 standards, which the agencies believe is adequate to
implement the technologies industry could use to meet the proposed
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.\49\ Additionally,
even for the more developed technologies, phasing in more stringent
standards over a longer timeframe may help manufacturers to ensure
better reliability of the technology and to develop packages to work in
a wide range of applications. Moving more quickly, however, as in
Alternative 4, would lead to earlier and greater cumulative fuel
savings and greenhouse gas reductions.
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\49\ ``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.
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As discussed later, the agencies are also proposing new standards
in MYs 2018 (trailers only), 2021, and 2024 to ensure 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. Moving more quickly,
however, as in Alternative 4, would lead to earlier and greater
cumulative fuel and greenhouse gas savings.
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
[[Page 40155]]
they did not perform sufficient product development validation, which
led to additional costs for operators when the technologies required
repairs or other resulted in other operational issues in use. Thus, the
issues of costs, lead time, and reliability are intertwined for the
agencies' determination of whether standards are reasonable.
Another important consideration is the possibility of disrupting
the market, such as might happen if we were to adopt standards that
manufacturers respond to by applying a new technology 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
industry stakeholders have informed EPA that the 2007 EPA heavy-duty
engine criteria pollutant standard resulted in this pull-ahead
phenomenon for the Class 8 tractor market. The agencies understand the
potential impact that a pull-ahead 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 proposed program to avoid such disruption. These steps
include the following:
Providing considerable lead time, including two to three
additional years for the preferred alternative compared to Alternative
4
The standards 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 in 2007
Allowing manufacturers to use emissions averaging, banking and
trading to phase in the technology even further
We request comment on the sufficiency of the proposed Phase 2
structure, lead time, and stringency to avoid market disruptions. We
note an important difference, however, between standards for criteria
pollutants, with generally no attendant fuel savings, and the fuel
consumption/GHG emission standards proposed today, which provide
immediate and direct financial benefits to vehicle purchasers, who will
begin saving money on fuel costs as soon as they begin operating the
vehicles. It would seem logical, therefore, that vehicle purchasers
(and manufacturers) would weigh those significant fuel savings against
the potential for increased costs that could result from applying fuel-
saving technologies sooner than they might otherwise choose in the
absence of the standards.
As discussed in the Phase 1 final rule, NHTSA has certain statutory
considerations to take into account when determining feasibility of the
preferred alternative.\50\ The Energy Independence and Security Act
(EISA) states that NHTSA (in consultation with EPA and the Secretary of
Energy) shall develop a commercial medium- and heavy-duty fuel
efficiency program designed ``to achieve the maximum feasible
improvement.'' \51\ 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,\52\
which modify ``feasible'' beyond its plain meaning.
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\50\ 75 FR 57198.
\51\ 49 U.S.C. 32902(k).
\52\ 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.''
\53\
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\53\ 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 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) also allows (although it does not
compel) EPA to adopt technology-forcing standards. Id. at 57130.
Giving due consideration to the agencies' respective statutory
criteria discussed above, the agencies are proposing these technology-
forcing standards for MY 2027. The agencies nevertheless recognize that
there is some uncertainty in projecting costs and effectiveness,
especially for those technologies not yet widely available, but believe
that the thresholds proposed for consideration account for realistic
projections of technological development discussed throughout this
notice and in the draft RIA. The agencies are requesting comment on the
alternatives described in Section X below. These alternatives range
from Alternative 1 (which is a no-action alternative that serves as the
baseline for our cost and benefit analyses) to Alternative 5 (which
includes the most stringent of the alternative standards analyzed by
the agencies). The assessment of these different alternatives considers
the importance of allowing manufacturers sufficient flexibility and
discretion while achieving meaningful fuel consumption and GHG
emissions reductions across vehicle types. The agencies look forward to
receiving comments on questions of feasibility and long-term
projections of costs and effectiveness.
As discussed throughout this document, the agencies believe
Alternative 4 has potential to be the maximum feasible alternative,
however, based on the evidence currently before us, the agencies have
outstanding questions regarding relative risks and
[[Page 40156]]
benefits of that option in the timeframe envisioned. We are seeking
comment on these relative risks and benefits. Alternative 3 is
generally designed to achieve the vehicle levels of fuel consumption
and GHG reduction that Alternative 4 would achieve, but with two to
three years of additional lead-time--i.e., the Alternative 3 standards
would end up in the same place as the Alternative 4 standards, but two
to three years later, meaning that manufacturers could, in theory,
apply new technology at a more gradual pace and with greater
flexibility as discussed above. However, Alternative 4 would lead to
earlier and greater cumulative fuel savings and greenhouse gas
reductions.
In the sections that follow, the agencies have closely examined the
potential feasibility of Alternative 4 for each subcategory. The
agencies may consider establishing final fuel efficiency and GHG
standards in whole or in part in the Alternative 4 timeframe if we deem
them to be maximum feasible and reasonable for NHTSA and EPA,
respectively. The agencies seek comment on the feasibility of
Alternative 4, whether for some or for all segments, including
empirical data on its appropriateness, cost-effectiveness, and
technological feasibility. The agencies also note the possibility of
adoption in MY 2024 of a standard reflecting deployment of some, rather
than all, of the technologies on which Alternative 4 is predicated. It
is also possible that the agencies could adopt some or all of the
proposal (Alternative 3) earlier than MY 2027, but later than MY 2024,
based especially on lead time considerations. Any such choices would
involve a considered weighing of the issues of feasibility of projected
technology penetration rates, associated costs, and necessary lead
time, and would consider the information on available technologies,
their level of performance and costs set out in the administrative
record to this proposal.
Sections II through VI of this notice explain the consideration
that the agencies took into account in considering options and
proposing a preferred alternative based on balancing of the statutory
factors under 42 U.S.C. 7521(a)(1) and (2), and under 49 U.S.C.
32902(k).
(1) Carryover From Phase 1 Program and Proposed Compliance Changes
Phase 2 will carry over many of the compliance approaches developed
for Phase 1, with certain changes as described below. Readers are
referred to the proposed regulatory text for much more detail. Note
that some of these provisions are being carried over with revisions or
additions (such as those needed to address trailers).
(a) Certification
EPA and NHTSA are proposing to apply the same general certification
procedures for Phase 2 as are currently being used for certifying to
the Phase 1 standards. The agencies, however, are proposing changes to
the simulation tool used for the vocational vehicle, tractor and
trailer standards that would allow the simulation tool to more
specifically reflect improvements to transmissions and drivetrains.\54\
Rather than the model using default values for transmissions and
drivetrains, manufacturers would enter measured or tested values as
inputs reflecting performance of their actual transmission and
drivetrain technologies.
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\54\ As described in Section IV, although the proposed trailer
standards were developed using the simulation tool, the agencies are
proposing a compliance structure that does not require trailer
manufacturers to actually use the compliance tool.
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The agencies apply essentially the same process for certifying
tractors and vocational vehicles, and propose largely to apply it to
trailers as well. 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, and
the agencies propose to continue it for Phase 2. Finally, we also
propose to continue certifying HD pickups and vans using the Phase 1
vehicle certification process, which is very similar to the light-duty
vehicle certification process.
EPA and NHTSA are also proposing to clarify 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 and vehicles are in 40 CFR 1036.235 and
1037.235. The SEA provisions are in 40 CFR 1036.301 and 1037.301. The
NHTSA provisions are in 49 CFR 535.9(a). Note that these clarifications
would also apply for Phase 1 engines and vehicles. The agencies welcome
suggestions for alternative approaches that would offer the same degree
of compliance assurance for GHGs and fuel consumption as these programs
offer with respect to EPA's criteria pollutants.
(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. We propose to generally
continue this Phase 1 approach with few revisions for vehicles
regulated in Phase 1. As described in Section IV, we are proposing a
more limited averaging program for trailers. The agencies see the ABT
program as playing an important role in making the proposed 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, and 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.\55\
---------------------------------------------------------------------------
\55\ 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).
---------------------------------------------------------------------------
(i) Carryover of Phase 1 Credits and Credit Life
The agencies propose to continue the five-year credit life
provisions from Phase 1, and are not proposing any
[[Page 40157]]
additional restriction on the use of banked Phase 1 credits in Phase 2.
In other words, Phase 1 credits in MY2019 could be used in Phase 1 or
in Phase 2 in MYs 2021-2024. Although, as we have already noted, the
numerical values of proposed 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). Phase 2 would not change payloads,
production volumes, or useful lives for tractors, medium and heavy
heavy-duty engines, or medium and heavy heavy-duty vocational vehicles.
However, EPA is proposing to change 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 are proposing 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.\56\ The new useful life
implemented for Tier 3 is 150,000 miles or 15 years, whichever occurs
first. This is the same useful life proposed in Phase 2 for HD pickups
and vans, light heavy-duty vocational vehicles, spark-ignited engines,
and light heavy-duty compression-ignition engines.\57\ The numerical
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 proposed 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 proposed changes in useful
life would significantly affect the feasibility of the proposed Phase 2
standards. EPA requests comments on the proposed changes to useful
life. 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 would allow
credits generated in either Phase 1 or early in Phase 2 to be used for
the intended purpose. The agencies believe longer credit life is not
necessary to accomplish this transition. Restrictions on credit life
serve to reduce the likelihood that any manufacturer would 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 believe, subject to
consideration of public comment, 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.
---------------------------------------------------------------------------
\56\ 79 FR 23492, April 28, 2014 and 40 CFR 86.1805-17.
\57\ NHTSA's useful life is based on mileage and years of
duration.
---------------------------------------------------------------------------
Although we are not proposing any additional restrictions on the
use of Phase 1 credits, we are requesting comment on this issue. Early
indications suggest that positive market reception to the Phase 1
technologies could lead to manufacturers accumulating credit surpluses
that could be quite large at the beginning of the proposed Phase 2
program. This appears especially likely for tractors. The agencies are
specifically requesting comment on the likelihood of this happening,
and whether any regulatory changes would be appropriate in response.
For example, should the agencies limit the amount of credits that could
be carried over from Phase1 or limit them to the first year or two of
the Phase 2 program? Also, if we determine that large surpluses are
likely, how should that factor into our decision on the feasibility of
more stringent standards in MY 2021?
(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. 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). We propose to continue
this regime in Phase 2, to retain the existing vehicle and engine
averaging sets, and create new trailer averaging sets. We also propose
to continue the averaging set restrictions from Phase 1 in Phase 2.
These 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 van trailers
Short dry van trailers
Long refrigerated trailers
Short refrigerated trailers
We also propose not to allow 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. We
similarly would 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 restricting trading to within
the same eight classes would 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 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
[[Page 40158]]
categories, and the estimated credit calculations will fairly ensure
the expected fuel consumption and GHG emission reductions.
We continue to believe, subject to consideration of public comment,
that the Phase 1 averaging sets create the most flexibility that is
appropriate without creating an unfair advantage for manufacturers with
erratically integrated portfolios, including engines and vehicles. See
76 FR 57240. The agencies committed in Phase 1 to seek public comment
after credit trading begins with manufacturers certifying in 2014 on
whether broader credit trading is more appropriate in developing the
next phase of HD regulations (76 FR 57128, September 15, 2011). The
2014 model year end of year reports will become available to the
agencies in mid-2015. Therefore, the agencies will provide information
at that point. We welcome comment on averaging set restrictions. The
agencies propose to continue this carry forward provision for phase 2
for the same reasons.
(iii) Credit Deficits
The Phase 1 regulations allow manufacturers to carry-forward
deficits for up to three years without penalty. 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 are much better than required. 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 this time, the agencies believe it is no longer appropriate to
provide extra credit for the technologies identified as advanced
technologies for Phase 1, although we are requesting comment on this
issue. 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(i)). 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 proposed Phase 2 heavy-duty engine and vehicles
standards are premised on the use of some advanced technologies, making
them equivalent to other fuel-saving technologies in this context. We
believe the Phase 2 standards themselves would provide sufficient
incentive to develop them.
We request comment on this issue, especially with respect to
electric vehicle, plug-in hybrid, and fuel cell technologies. Although
the proposed standards are premised on some use of Rankine cycle
engines and hybrid powertrains, none of the proposed standards are
based on projected utilization of the use of the other advanced
technologies. (Note that the most stringent alternative is based on
some use of these technologies). Commenters are encouraged to consider
the recently adopted light-duty program, which includes temporary
incentives for these technologies.
(c) Innovative Technology and Off-Cycle Credits
The agencies propose to largely continue the Phase 1 innovative
technology program but to redesignate it as an off-cycle program for
Phase 2. In other words, beginning in MY 2021 technologies that are not
fully accounted for in the GEM simulation tool, or by compliance
dynamometer testing would be considered ``off-cycle'', including those
technologies that may no longer be considered innovative technologies.
However, we are not proposing to apply this flexibility to trailers
(which were not part of Phase 1) in order to simplify the program for
trailer manufacturers.
The agencies propose to maintain 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. Although, we have not identified specific off-cycle technologies
at this time that should be excluded, we believe it may be 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. Nevertheless, the agencies seek comment on whether off-
cycle technologies in the Phase 2 program should be limited in this
way. In particular, the agencies are concerned that because the
proposed Phase 2 program would be implemented MY 2021 and may extend
beyond 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. Moreover, because we have not identified a single
off-cycle technology that should be excluded by this provision at this
time, we are concerned that this approach may create an unnecessary
hindrance to the off-cycle program.
Manufacturers would be able to carry over an innovative technology
credits from Phase 1 into Phase 2, subject to the same restrictions as
other credits. Manufacturers would also be able to carry over the
improvement factor (not the credit value) of a technology, if certain
criteria were met. The agencies would require documentation for all
off-cycle requests similar to those required by EPA for its light-duty
GHG program.
Additionally, NHTSA would not grant any off-cycle credits for crash
avoidance technologies. NHTSA would also require manufacturers to
consider the safety of off-cycle technologies and would request a
safety assessment from the manufacturer for all off-cycle technologies.
The agencies seek comment on these proposed changes, as well as the
possibility of adopting aspects of the light-duty off-cycle program.
(d) Alternative Fuels
The agencies are proposing to largely continue the Phase 1 approach
for engines and vehicles fueled by fuels other than gasoline and
diesel.\58\ 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. The agencies are, however, proposing a
small change that is described in Section II. Under the proposed
change, we would 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 medium heavy-duty engine or a heavy heavy-duty
engine would be subject to all the emission standards and other
requirements that apply to compression-ignition engines. Note that this
small change in approach would also apply with respect to EPA's
criteria pollutant program.
---------------------------------------------------------------------------
\58\ See Section I. F. (1) (a) for a summary of certain specific
changes we are proposing or considering for natural gas-fueled
engines and vehicles.
---------------------------------------------------------------------------
We are also proposing that the Phase 2 standards apply exclusively
at the
[[Page 40159]]
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. 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.
One consequence of the tailpipe-based approach is that the agencies
are proposing to treat vehicles powered by electricity the same as in
Phase 1. In Phase 1, EPA treated all electric vehicles as having zero
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 not found any all-electric heavy-duty vehicles that
have certified by 2014. As we look to the future, we project very
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 propose a cap for heavy-duty
vehicles because of the small likelihood of significant production of
EV technologies in the Phase 2 timeframe. We welcome comments on this
approach.\59\ Note that we also request comment on upstream emissions
for natural gas in Section XI.
---------------------------------------------------------------------------
\59\ See also Section I. C. (1) (b)(iv) above (soliciting
comment on need for advanced technology incentive credits for heavy
duty EVs).
---------------------------------------------------------------------------
(e) Phase 1 Interim Provisions
EPA adopted several flexibilities for the Phase 1 program (40 CFR
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 proposing not to
apply these provisions to Phase 2. These will generally remain in
effect for the Phase 1 program. In particular, the agencies note that
we do not propose to continue the blanket exemption for small
manufacturers. Instead, the agencies propose to adopt narrower and more
targeted relief.
(f) In-Use Standards
Section 202(a)(1) of the CAA specifies that EPA is to adopt
emissions standards that are applicable for the useful life of the
vehicle and for the engine. EPA finalized in-use standards for the
Phase 1 program whereas NHTSA adopted an approach which does not
include these standards. For the Phase 2 program, EPA will carry-over
its in-use provisions and NHTSA proposes to adopt 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. NHTSA seeks comment on the
appropriateness of seeking civil penalties for failure to comply with
its fuel efficiency standards in these instances. NHTSA would limit
such penalties to situations in which it determined that the vehicle or
engine manufacturer failed to comply with the standards.
(2) Proposed Phase 2 Standards
This section briefly summarizes the proposed Phase 2 standards for
each category and identifies the technologies that the agencies project
would be needed to meet the standards. Given the large number of
different regulatory categories and model years for which separate
standards are being proposed, the actual numerical standards are not
listed. Readers are referred to Sections II through IV for the tables
of proposed standards.
(a) Summary of the Proposed Engine Standards
The agencies are proposing to continue the basic Phase 1 structure
for the Phase 2 engine standards. There would be separate standards and
test cycles for tractor engines, vocational diesel engines, and
vocational gasoline engines. However, as described in Section II, we
are proposing a revised test cycle for tractor engines to better
reflect actual in-use operation.
For diesel engines, the agencies are proposing standards for MY
2027 requiring reduction in CO2 emissions and fuel
consumption of 4.2 percent better than the 2017 baseline.\60\ We are
also proposing standards for MY 2021 and MY 2024, requiring reductions
in CO2 emissions and fuel consumption of 1.5 to 3.7 percent
better than the 2017 baseline. The agencies project that these
reductions would be feasible based on technological changes that would
improve combustion and reduce energy losses. For most of these
improvements, the agencies project manufacturers will begin applying
them to about 50 percent of their heavy-duty engines by 2021, and
ultimately apply them to about 90 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 15 percent of tractor engines would 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. Although we see great potential for waste heat
recovery systems to achieve significant fuel savings and CO2
emission reductions, we are not projecting that the technology could be
available for more wide-spread use in this time frame.
---------------------------------------------------------------------------
\60\ Phase 1 standards for diesel engines will be fully phased-
in by MY 2017.
---------------------------------------------------------------------------
For gasoline vocational engines, we are not proposing new more
stringent engine standards. 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. 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 vocational gasoline engines would
[[Page 40160]]
include the same technology as would be used to meet the pickup and van
chassis standards, and this would result in some real world reductions
in CO2 emissions and fuel consumption. Although it is
difficult at this time to project how much improvement would be
observed during certification testing, it seems likely that these
improvements would reduce measured CO2 emissions and fuel
consumption by about one percent. Therefore, we are requesting comment
on finalizing a Phase 2 standard of 621 g/hp-hr for gasoline engines
(i.e., one percent more stringent than the 2016 Phase 1 standard of 627
g/hp-hr) in MY 2027. We note that the proposed MY 2027 vehicle
standards for gasoline-fueled vocational vehicles are predicated in
part on the use of advanced friction reduction technology with
effectiveness over the GEM cycles of about one percent. We also request
comment on whether not proposing more stringent standards for gasoline
engines would create an incentive for purchasers who would have
otherwise chosen a diesel vehicle to instead choose a gasoline vehicle.
Table I-2--Summary of Phase 1 and Proposed Phase 2 Requirements for Engines in Combination Tractors and
Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Alternative 3-2027 Alternative 4-2024 (also
Phase 1 program (proposed standard) under consideration)
----------------------------------------------------------------------------------------------------------------
Covered in this category......... Engines installed in tractors and vocational chassis.
----------------------------------------------------------------------------------------------------------------
Share of HDV fuel consumption and Combination tractors and vocational vehicles account for approximately 85
GHG emissions. percent of fuel use and GHG emissions in the medium and heavy duty truck
sector.
----------------------------------------------------------------------------------------------------------------
Per vehicle fuel consumption and 5%-9% improvement over MY 4% improvement over MY 2017 for diesel engines.
CO2 improvement. 2010 baseline, depending Note that improvements are captured in complete
vehicle application. vehicle tractor and vocational vehicle standards,
Improvements are in so that engine improvements and the vehicle
addition to improvements improvement shown below are not additive.
from tractor and
vocational vehicle
standards.
----------------------------------------------------------------------------------------------------------------
Form of the standard............. EPA: CO2 grams/horsepower-hour and NHTSA: Gallons of fuel/horsepower-hour.
----------------------------------------------------------------------------------------------------------------
Example technology options Combustion, air handling, Further technology improvements and increased use
available to help manufacturers friction and emissions of all Phase 1 technologies, plus waste heat
meet standards. after-treatment recovery systems for tractor engines (e.g., turbo-
technology improvements. compound and Rankine-cycle).
----------------------------------------------------------------------------------------------------------------
Flexibilities.................... ABT program which allows Same as Phase 1, except no advanced technology
emissions and fuel incentives.
consumption credits to Adjustment factor of 1.36 proposed for credits
be averaged, banked, or carried forward from Phase 1 to Phase 2 for SI
traded (five year credit and LHD CI engines due to proposed change in
life). Manufacturers useful life.
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.
----------------------------------------------------------------------------------------------------------------
(b) Summary of the Proposed Tractor Standards
As explained in Section III, the agencies are proposing to largely
continue the Phase 1 tractor program but to propose new standards. The
tractor standards proposed for MY 2027 would achieve up to 24 percent
lower CO2 emissions and fuel consumption than a 2017 model
year Phase 1 tractor. The agencies project that the proposed 2027
tractor standards could be met through improvements in the:
Engine \61\ (including some use of waste heat recovery
systems)
---------------------------------------------------------------------------
\61\ Although the agencies are proposing separate engine
standards and separate engine certification, engine improvements
would 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' 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. The agencies
are proposing to enhance the GEM vehicle simulation tool to recognize
these technologies, as described in Section II.C.
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 proposed 2021
model year standards for combination tractors and engines would achieve
up to 13 percent lower CO2 emissions and fuel consumption
than a 2017 model year Phase 1 tractor, and the 2024 model year
standards would achieve up to 20 percent lower CO2 emissions
and fuel consumption.
[[Page 40161]]
Table I-3--Summary of Phase 1 and Proposed Phase 2 Requirements for Class 7 and Class 8 Combination Tractors
----------------------------------------------------------------------------------------------------------------
Alternative 4--2024
Phase 1 program Alternative 3--2027 (also under
(proposed standard) consideration)
----------------------------------------------------------------------------------------------------------------
Covered in this category......... Tractors that are designed to pull trailers and move freight.
----------------------------------------------------------------------------------------------------------------
Share of HDV fuel consumption and Combination tractors and their engines account for approximately two thirds
GHG emissions. of fuel use and GHG emissions in the medium and heavy duty truck sector.
----------------------------------------------------------------------------------------------------------------
Per vehicle fuel consumption and 10%-23% improvement over 18%-24% improvement over MY 2017 standards.
CO2 improvement. MY 2010 baseline,
depending on tractor
category. Improvements
are in addition to
improvements from engine
standards.
----------------------------------------------------------------------------------------------------------------
Form of the standard............. EPA: CO2 grams/ton payload mile and NHTSA: Gallons of fuel/1,000 ton payload
mile.
----------------------------------------------------------------------------------------------------------------
Example technology options Aerodynamic drag Further technology improvements and increased use
available to help manufacturers improvements; low of all Phase 1 technologies, plus engine
meet standards. rolling resistance improvements, improved and automated
tires; high strength transmissions and axles, powertrain optimization,
steel and aluminum tire inflation systems, and predictive cruise
weight reduction; control (depending on tractor type).
extended idle reduction;
and speed limiters.
----------------------------------------------------------------------------------------------------------------
Flexibilities.................... ABT program which allows Same as Phase 1, except no extra credits for
emissions and fuel advanced technologies or early certification.
consumption credits to
be averaged, banked, or
traded (five year credit
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 Proposed Trailer Standards
This proposed rule is a set of GHG emission and fuel consumption
standards for manufacturers of new trailers that are used in
combination with tractors that would 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 accomplish these proposed standards. For the most
part, these technologies have already been introduced into the market
to some extent through EPA's voluntary SmartWay program. However,
adoption is still somewhat limited.
The agencies are proposing incremental levels of Phase 2 standards
that would apply 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 would be
mandatory beginning in MY 2018, while NHTSA's fuel consumption
standards would be voluntary beginning in MY 2018, and be mandatory
beginning in MY 2021.
As described in Section XV.D and Chapter 12 of the draft RIA, the
agencies are proposing special provisions to minimize the impacts on
small trailer manufacturers. These provisions have been informed by and
are largely consistent with recommendations coming 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 manufacturers, as well as simplified testing and
compliance requirements. The agencies are also requesting comment on
whether there is a need for additional provisions to address small
business issues.
Table I-4--Summary of Proposed Phase 2 Requirements for Trailers
----------------------------------------------------------------------------------------------------------------
Alternative 4--2024
Phase 1 program Alternative 3--2027 (also under
(proposed standard) consideration)
----------------------------------------------------------------------------------------------------------------
Covered in this category......... Trailers hauled by low, mid, and high roof day and sleeper cab tractors,
except those qualified as logging, mining, stationary or heavy-haul.
----------------------------------------------------------------------------------------------------------------
Share of HDV fuel consumption and Trailers are modeled together with combination tractors and their engines.
GHG emissions. Together, they account for approximately two thirds of fuel use and GHG
emissions in the medium and heavy duty truck sector.
----------------------------------------------------------------------------------------------------------------
Per vehicle fuel consumption and N/A...................... Between 3% and 8% improvement over MY 2017
CO2 improvement. baseline, depending on the trailer type.
----------------------------------------------------------------------------------------------------------------
[[Page 40162]]
Form of the standard............. N/A...................... EPA: CO2 grams/ton payload mile and NHTSA: Gallons/
1,000 ton payload mile.
----------------------------------------------------------------------------------------------------------------
Example technology options N/A...................... Low rolling resistance tires, automatic tire
available to help manufacturers inflation systems, weight reduction for most
meet standards. trailers, aerodynamic improvements such as side
and rear fairings, gap closing devices, and
undercarriage treatment for box-type trailers
(e.g., dry and refrigerated vans).
----------------------------------------------------------------------------------------------------------------
Flexibilities.................... N/A...................... One year delay in implementation for small
businesses, trailer manufacturers may use pre-
approved devices to avoid testing, averaging
program for manufacturers of dry and refrigerated
box trailers.
----------------------------------------------------------------------------------------------------------------
(d) Summary of the Proposed Vocational Vehicle Standards
As explained in Section V, the agencies are proposing to revise the
Phase 1 vocational vehicle program and to propose new standards. These
proposed standards also reflect further sub-categorization from Phase
1, with separate proposed standards based on mode of operation: Urban,
regional, and multi-purpose. The agencies are also proposing
alternative standards for emergency vehicles.
The agencies project that the proposed vocational vehicle standards
could be met through improvements in the engine, transmission,
driveline, lower rolling resistance tires, workday idle reduction
technologies, and weight reduction, plus some application of hybrid
technology. These are described in Section V of this preamble and in
Chapter 2.9 of the draft RIA. These MY 2027 standards would achieve up
to 16 percent lower CO2 emissions and fuel consumption than
MY 2017 Phase 1 standards. The agencies are also proposing revisions to
the compliance regime for vocational vehicles. These include: The
addition of an idle cycle that would be weighted along with the other
drive cycles; and revisions to the vehicle simulation tool to reflect
specific 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 proposing new
standards for MY 2021 and 2024. Based on our analysis, the MY 2021
standards for vocational vehicles would achieve up to 7 percent lower
CO2 emissions and fuel consumption than a MY 2017 Phase 1
vehicle, on average, and the MY 2024 standards would achieve up to 11
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 would be
feasible to apply similar A/C refrigerant leakage standards for
vocational vehicles, beginning with the 2021 model year. The process
for certifying that low leakage components are used would follow the
system currently in place for comparable systems in tractors.
Table I-5--Summary of Phase 1 and Proposed Phase 2 Requirements for Vocational Vehicle Chassis
----------------------------------------------------------------------------------------------------------------
Alternative 4--2024
Phase 1 program Alternative 3--2027 (also under
(proposed standard) consideration)
----------------------------------------------------------------------------------------------------------------
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 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 consumption and Vocational vehicles account for approximately 20 percent of fuel use and GHG
GHG emissions. emissions in the medium and heavy duty truck sector categories.
----------------------------------------------------------------------------------------------------------------
Per vehicle fuel consumption and 2% improvement over MY Up to 16% improvement over MY 2017 standards.
CO2 improvement. 2010 baseline.
Improvements are in
addition to improvements
from engine standards.
----------------------------------------------------------------------------------------------------------------
Form of the standard............. EPA: CO2 grams/ton payload mile and NHTSA: Gallons of fuel/1,000 ton payload
mile.
----------------------------------------------------------------------------------------------------------------
Example technology options Low rolling resistance Further technology improvements and increased use
available to help manufacturers tires. of Phase 1 technologies, plus improved engines,
meet standards. transmissions and axles, powertrain optimization,
weight reduction, hybrids, and workday idle
reduction systems.
----------------------------------------------------------------------------------------------------------------
[[Page 40163]]
Flexibilities.................... ABT program which allows Same as Phase 1, except no advanced technology
emissions and fuel incentives.
consumption credits to
be averaged, banked, or
traded (five year credit
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.
......................... Chassis intended for emergency vehicles have
proposed Phase 2 standards based only on Phase 1
technologies, and may continue to certify using a
simplified Phase 1-style GEM tool. Adjustment
factor of 1.36 proposed for credits carried
forward from Phase 1 to Phase 2 due to proposed
change in useful life.
----------------------------------------------------------------------------------------------------------------
(e) Summary of the Proposed Heavy-Duty Pickup and Van Standards
The agencies are proposing to adopt new Phase 2 GHG emission and
fuel consumption standards for heavy-duty pickups and vans that would
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 strong hybrid powertrain
technology. These proposed standards would commence in MY 2021.
Overall, the proposed standards are 16 percent more stringent by 2027.
Table I-6--Summary of Phase 1 and Proposed Phase 2 Requirements for HD Pickups and Vans
----------------------------------------------------------------------------------------------------------------
Alternative 4--2025
Phase 1 program Alternative 3--2027 (also under
(proposed standard) consideration)
----------------------------------------------------------------------------------------------------------------
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 consumption and HD pickups and vans account for approximately 15% of fuel use and GHG
GHG emissions. emissions in the medium and heavy duty truck sector.
----------------------------------------------------------------------------------------------------------------
Per vehicle fuel consumption and 15% improvement over MY 16% improvement over MY 2018-2020 standards.
CO2 improvement. 2010 baseline for diesel
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. As proposed, the Phase 2 standards would be based
on the same approach.
----------------------------------------------------------------------------------------------------------------
Example technology options Engine improvements, Further technology improvements and increased use
available to help manufacturers transmission of all Phase 1 technologies, plus engine stop-
meet standards. improvements, start, and powertrain hybridization (mild and
aerodynamic drag strong).
improvements, low
rolling resistance
tires, weight reduction,
and improved accessories.
----------------------------------------------------------------------------------------------------------------
[[Page 40164]]
Flexibilities.................... Two optional phase-in Proposed to be same as Phase 1, with phase-in
schedules; ABT program schedule based on year-over-year increase in
which allows emissions stringency. Adjustment factor of 1.25 proposed
and fuel consumption for credits carried forward from Phase 1 to Phase
credits to be averaged, 2 due to proposed change in useful life. Proposed
banked, or traded (five cessation of advanced technology incentives in
year credit life). 2021 and continuation of off-cycle credits.
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.
----------------------------------------------------------------------------------------------------------------
(f) Summary of the Proposed Final Numeric Standards by Regulatory
Subcategory
Table I-7 lists the proposed final (i.e., MY 2027) numeric
standards by regulatory subcategory for tractors, trailers, vocational
vehicles and engines. Note that these are the same final numeric
standards for Alternative 4, but for Alternative 4 these would be
implemented in MY 2024 instead of MY 2027.
Table I-7--Proposed Final (MY 2027) Numeric Standards by Regulatory Subcategory
----------------------------------------------------------------------------------------------------------------
CO2 grams per ton-mile Fuel consumption gallon
(for engines CO2 grams per 1,000 ton-mile (for
Regulatory subcategory per brake horsepower- engines gallons per 100
hour) brake horsepower-hour)
----------------------------------------------------------------------------------------------------------------
Tractors:.....................................................
Class 7 Low Roof Day Cab.................................. 87 8.5462
Class 7 Mid Roof Day Cab.................................. 96 9.4303
Class 7 High Roof Day Cab................................. 96 9.4303
Class 8 Low Roof Day Cab.................................. 70 6.8762
Class 8 Mid Roof Day Cab.................................. 76 7.4656
Class 8 High Roof Day Cab................................. 76 7.4656
Class 8 Low Roof Sleeper Cab.............................. 62 6.0904
Class 8 Mid Roof Sleeper Cab.............................. 69 6.7780
Class 8 High Roof Sleeper Cab............................. 67 6.5815
Trailers:
Long Dry Box Trailer...................................... 77 7.5639
Short Dry Box Trailer..................................... 140 13.7525
Long Refrigerated Box Trailer............................. 80 7.8585
Short Refrigerated Box Trailer............................ 144 14.1454
Vocational Diesel:
LHD Urban................................................. 272 26.7191
LHD Multi-Purpose......................................... 280 27.5049
LHD Regional.............................................. 292 28.6837
MHD Urban................................................. 172 16.8959
MHD Multi-Purpose......................................... 174 17.0923
MHD Regional.............................................. 170 16.6994
HHD Urban................................................. 182 17.8782
HHD Multi-Purpose......................................... 183 17.9764
HHD Regional.............................................. 174 17.0923
Vocational Gasoline:
LHD Urban................................................. 299 33.6446
LHD Multi-Purpose......................................... 308 34.6574
LHD Regional.............................................. 321 36.1202
MHD Urban................................................. 189 21.2670
MHD Multi-Purpose......................................... 191 21.4921
MHD Regional.............................................. 187 21.0420
HHD Urban................................................. 196 22.0547
HHD Multi-Purpose......................................... 198 22.2797
HHD Regional.............................................. 188 21.1545
Diesel Engines:
LHD Vocational............................................ 553 5.4322
MHD Vocational............................................ 553 5.4322
HHD Vocational............................................ 533 5.2358
MHD Tractor............................................... 466 4.5776
[[Page 40165]]
HHD Tractor............................................... 441 4.3320
----------------------------------------------------------------------------------------------------------------
Similar to Phase 1 the agencies are proposing for Phase 2 a set of
continuous equation-based standards for HD pickups and vans. Please
refer to Section 6, subsection B.1, for a description of these
standards, including associated tables and figures.
D. Summary of the Costs and Benefits of the Proposed Rule
This section summarizes the projected costs and benefits of the
proposed NHTSA fuel consumption and EPA GHG emission standards, along
with those of Alternative 4. These projections helped to inform the
agencies' choices among the alternatives considered, along with other
relevant factors, and NHTSA's Draft Environmental Impact Statement
(DEIS). See Sections VII through IX and the Draft RIA for additional
details about these projections.
For this rule, the agencies conducted coordinated and complementary
analyses using 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 complementary
analyses, which we refer to as ``Method A'' and ``Method B.'' In Method
A, 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 was used to project a pathway the industry could use to comply
with each regulatory alternative, along with resultant impacts on per
vehicle costs, and the MOVES model was used to calculate corresponding
changes in total fuel consumption and annual emissions. Additional
calculations were performed to determine corresponding 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 both methods. The agencies concluded that both methods led
the agencies to the same conclusions and the same selection of the
proposed standards. See Section VII for additional discussion of these
two methods.
(1) Reference Case Against Which Costs and Benefits Are Calculated
The No Action Alternative for today's analysis, alternatively
referred to as the ``baseline'' or ``reference case,'' assumes that the
agencies would not issue new rules regarding MD/HD fuel efficiency and
GHG emissions. This is the baseline against which costs and benefits
for the proposed standards are calculated. The reference case assumes
that model year 2018 standards would be extended indefinitely and
without change.
The agencies recognize that if the proposed rule is not adopted,
manufacturers will continue to introduce new heavy-duty vehicles in a
competitive market that responds to a range of factors. Thus
manufacturers might have continued to improve technologies to reduce
heavy-duty vehicle fuel consumption. Thus, as described in Section VII,
both agencies fully analyzed the proposed standards and the regulatory
alternatives against two reference cases. The first case uses a
baseline that projects very little improvement in new vehicles in the
absence of new Phase 2 standards, and the second uses a more dynamic
baseline that projects more significant improvements in vehicle fuel
efficiency. NHTSA considered its primary analysis to be based on the
more 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 chose to analyze these two different baselines because
the agencies recognize that there are a number of factors that create
uncertainty in projecting a baseline against which to compare the
future effects of the proposed 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, and
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, 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
[[Page 40166]]
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. The agencies request comment on which
alternative baseline scenarios would be most appropriate for analysis
in the final rule. Specifically, the agencies request empirical
evidence to support whether the agencies should use for the final rule
the central cases used in this proposal, alternative sensitivity cases
such as those mentioned below, or some other scenarios. See Section
X.A.1of this Preamble and Chapter 11 of the draft 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 draft RIA for a detailed discussion of these
additional scenarios.
(2) Costs and Benefits Projected for the Standards Being Proposed and
Alternative 4
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 draft RIA.
Table I-8 shows benefits and costs for the proposed standards and
Alternative 4 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-8--Lifetime Fuel Savings, GHG Reductions, Benefits, Costs and Net Benefits for Model Years 2018-2029
Vehicles Using Analysis Method A
[Billions of 2012$] \a\ \b\
----------------------------------------------------------------------------------------------------------------
Alternative
-----------------------------------------------------------------------
Category 3 Preferred 4
-----------------------------------------------------------------------
7% Discount rate 3% Discount rate 7% Discount rate 3% Discount rate
----------------------------------------------------------------------------------------------------------------
Fuel Reductions (Billion Gallons)....... 72.2-76.7
81.9-86.7
GHG reductions (MMT CO2 eq)............. 974-1,034
1,102-1,166
-----------------------------------------------------------------------
Vehicle Program: Technology and Indirect 25.0-25.4 16.8-17.1 32.9-34.3 22.5-23.5
Costs, Normal Profit on Additional
Investments............................
Additional Routine Maintenance.......... 1.0-1.1 0.6-0.6 1.0-1.1 0.6-0.7
Congestion, Accidents, and Noise from 4.5-4.7 2.6-2.8 4.7-4.9 2.7-2.8
Increased Vehicle Use..................
-----------------------------------------------------------------------
Total Costs......................... 30.5-31.1 20.0-20.5 38.7-40.8 25.8-27.0
Fuel Savings (valued at pre-tax prices). 165.1-175.1 89.2-94.2 187.4-198.3 102.0-107.5
Savings from Less Frequent Refueling.... 2.9-3.1 1.5-1.6 3.4-3.6 1.8-2.0
Economic Benefits from Additional 14.7-15.1 8.2-8.4 15.0-15.4 8.4-8.6
Vehicle Use............................
Reduced Climate Damages from GHG 32.9-34.9 32.9-34.9 37.3-39.4 37.3-39.4
Emissions \c\..........................
Reduced Health Damages from Non-GHG 37.2-38.8 20-20.7 40.9-42.5 22.1-22.8
Emissions..............................
Increased U.S. Energy Security.......... 8.1-8.9 4.3-4.7 9.3-10.2 5.0-5.5
-----------------------------------------------------------------------
Total Benefits...................... 261-276 156-165 293-309 177-186
-----------------------------------------------------------------------
Net Benefits.................... 231-245 136-144 255-269 151-159
----------------------------------------------------------------------------------------------------------------
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\ 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 CO2 emissions; GHG
reductions include CO2, CH4, N2O 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.
Table I-9 shows benefits and cost from the perspective of reducing
GHG.
[[Page 40167]]
Table I-9--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\
----------------------------------------------------------------------------------------------------------------
Alternative
----------------------------------------------------------------------------------
Category 3 Preferred 4
----------------------------------------------------------------------------------
7% Discount rate 3% Discount rate 7% Discount rate 3% Discount rate
----------------------------------------------------------------------------------------------------------------
Fuel Reductions (Billion 70.2 to 75.8
Gallons).
79.7 to 85.4
GHG reductions (MMT CO2eq)... 960 to 1,040
1,090 to 1,160
----------------------------------------------------------------------------------
Vehicle Program (e.g., -$24.6 to -$25.1 -$16.3 to -$16.6 -$33.1 to -$33.5 -$22.2 to -$22.5
technology and indirect
costs, normal profit on
additional investments).
Additional Routine -$1.1 to -$1.1 -$0.6 to -$0.6 -$1.1 to -$1.1 -$0.6 to -$0.6
Maintenance.
Fuel Savings (valued at pre- $159 to $171 $84.2 to $90.1 $181 to $193 $96.5 to $103
tax prices).
Energy Security.............. $8.5 to $9.3 $4.4 to $4.8 $9.8 to $10.6 $5.2 to $5.6
Congestion, Accidents, and -$4.2 to -$4.3 -$2.4 to -$2.4 -$4.2 to -$4.3 -$2.4 to -$2.4
Noise from Increased Vehicle
Use.
Savings from Less Frequent $2.8 to $3.1 $1.4 to $1.6 $3.3 to $3.6 $1.7 to $1.9
Refueling.
Economic Benefits from $14.8 to $14.9 $8.2 to $8.2 $14.7 to $14.8 $8.1 to $8.1
Additional Vehicle Use.
Benefits from Reduced Non-GHG $37.4 to $39.7 $17.7 to $18.8 $41.2 to $43.5 $19.7 to $20.7
Emissions \c\.
----------------------------------------------------------------------------------
Reduced Climate Damages from $31.6 to $34.0
GHG Emissions \d\.
$35.9 to $38.3
----------------------------------------------------------------------------------
Net Benefits............. $224 to $242 $128 to $138 $248 to $265 $142 to $152
----------------------------------------------------------------------------------------------------------------
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\ 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 $/ton
estimates for calculating benefits.
\d\ Benefits and net benefits use the 3 percent average SCCO2 value applied only to CO2 emissions; GHG
reductions include CO2, CH4 and N2O reductions.
Table I-10 breaks down by vehicle category the benefits and costs
for the proposed standards and Alternative 4 using the Method A
analytical approach. For additional detail on per-vehicle break-downs
of costs and benefits, please see Chapter 10.
Table I-10--Per Vehicle Category Lifetime Fuel Savings, GHG Reductions, Benefits, Costs and Net Benefits for
Model Years 2018-2029 Vehicles Using Analysis Method A (Billions of 2012$), Relative to Baseline 1b \a\
----------------------------------------------------------------------------------------------------------------
Alternative
-----------------------------------------------------------------------
Key costs and benefits by vehicle 3 Preferred 4
category -----------------------------------------------------------------------
7% Discount rate 3% Discount rate 7% Discount rate 3% Discount rate
----------------------------------------------------------------------------------------------------------------
Tractors, Including Engines, and
Trailers:..............................
Fuel Reductions (Billion Gallons)... 56.1
61.6
GHG Reductions (MMT CO2 eq)......... 731.1
803.1
-----------------------------------------------------------------------
Total Costs..................... 15.2 10.0 17.7 11.9
Total Benefits.................. 177.8 105.4 194.2 115.7
Net Benefits.................... 162.6 95.4 176.5 103.9
Vocational Vehicles, Including Engines:
-----------------------------------------------------------------------
Fuel Reductions (Billion Gallons)... 8.3
10.9
GHG Reductions (MMT CO2 eq)......... 107.0
139.8
-----------------------------------------------------------------------
Total Costs..................... 9.5 6.1 12.8 8.4
Total Benefits.................. 27.7 16.0 35.0 20.6
Net Benefits.................... 18.1 9.9 22.1 12.1
HD Pickups and Vans:
-----------------------------------------------------------------------
Fuel Reductions (Billion Gallons)... 7.8
9.3
GHG Reductions (MMT CO2 eq)......... 94.1
112.8
-----------------------------------------------------------------------
Total Costs..................... 5.5 3.7 7.8 5.3
[[Page 40168]]
Total Benefits.................. 23.5 14.1 28.3 17.1
Net Benefits.................... 18.0 10.5 20.4 11.9
----------------------------------------------------------------------------------------------------------------
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.
Table I-11--Per Vehicle Costs Relative to Baseline 1a
----------------------------------------------------------------------------------------------------------------
3 Proposed standards 4
-------------------------------------------------------------------------------
MY 2021 MY 2024 MY 2027 MY 2021 MY 2024
----------------------------------------------------------------------------------------------------------------
Per Vehicle Cost ($) \a\
Tractors.................... $6,710 $9,940 $11,700 $10,200 $12,400
Trailers.................... 900 1,010 1,170 1,080 1,230
Vocational Vehicles......... 1,150 1,770 3,380 1,990 3,590
Pickups/Vans................ 520 950 1,340 1,050 1,730
----------------------------------------------------------------------------------------------------------------
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 (MY2024 for
alternative 4 and MY2027 for the proposed standards) are shown in Table
I-12, and are similar for both Method A and Method B.
Table I-12--Payback Periods for MY2027 Vehicles Under the Proposed
Standards and for MY2024 Vehicles Under Alternative 4 Relative to
Baseline 1a
[Payback occurs in the year shown; using 7% discounting]
------------------------------------------------------------------------
Proposed
standards Alternative 4
------------------------------------------------------------------------
Tractors/Trailers....................... 2nd 2nd
Vocational Vehicles..................... 6th 6th
Pickups/Vans............................ 3rd 4th
------------------------------------------------------------------------
(3) Cost Effectiveness
These proposed 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.\62\ 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 1 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.
---------------------------------------------------------------------------
\62\ 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 the proposed standards in terms of costs per gallon of fuel
conserved. As described in the draft RIA, the agencies also evaluated
the
[[Page 40169]]
proposed standards using the same approaches employed in HD Phase 1.
Together, the agencies have considered the following three ratios of
cost effectiveness:
1. Total costs per gallon of fuel conserved.
2. Technology costs per ton of GHG emissions reduced.
3. Technology costs minus fuel savings per ton of GHG emissions
reduced.
By all three of these measures, the proposed standards would 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, the proposed standards would cost about $30 billion and
conserve about 75 billion gallons of fuel, such that the first measure
of cost effectiveness would be about 40 cents per gallon. Relative to
fuel prices underlying the agencies' analysis, the agencies have
concluded that today's proposed standards would be cost effective.
With respect to the second measure, which is useful for comparisons
to other GHG rules, the proposed standards would have overall $/ton
costs similar to the HD Phase 1 rule. As Chapter 7 of the draft RIA
shows, technology costs by themselves would amount to less than $50 per
metric ton of GHG (CO2 eq) for the entire HD Phase 2
program. This compares well to both the HD Phase 1 rule, which was
estimated to cost about $30 per metric ton of GHG (without fuel
savings), and to the agencies' estimates of the social cost of carbon.
Thus, even without accounting for fuel savings, the proposed standards
would be cost-effective.
The third measure deducts fuel savings from technology costs, which
also is useful for comparisons to other GHG rules. On this basis, net
costs per ton of GHG emissions reduced would be negative under the
proposed standards. This means that the value of the fuel savings would
be greater than the technology costs, and there would be a net cost
saving for vehicle owners. In other words, the technologies would pay
for themselves (indeed, more than pay for themselves) in fuel savings.
In addition, while the net economic benefits (i.e., total benefits
minus total costs) of the proposed standards is not a traditional
measure of their cost-effectiveness, the agencies have concluded that
the total costs of the proposed standards are justified in part by
their significant economic benefits. As discussed in the previous
subsection and in Section IX, this rule would 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 the proposed standards
would result in net economic benefits exceeding $100 billion, making
this a highly beneficial rule.
Our current analysis of Alternative 4 also shows that, if
technologically feasible, it would have similar cost-effectiveness but
with greater net benefits (see Chapter 11 of the draft RIA). For
example, the agencies estimate costs under Alternative 4 could be about
$40 billion and about 85 billion gallons of fuel could be conserved,
such that the first measure of cost effectiveness would be about 47
cents per gallon. However, the agencies considered all of the relevant
factors, not just relative cost-effectiveness, when selecting the
proposed standards from among the alternatives considered. Relative
cost-effectiveness was not a limiting factor for the agencies in
selecting the proposed standards. It is also worth noting that the
proposed standards and the Alternative 4 standards appear very cost
effective, regardless of which reference case is used for the baseline,
such that all of the analyses reinforced the agencies' findings.
E. EPA and NHTSA Statutory Authorities
This section briefly summarizes the respective statutory authority
for EPA and NHTSA to promulgate the Phase 1 and proposed Phase 2
programs. For additional details of the agencies' authority, see
Section XV of this notice as well as the Phase 1 rule.\63\
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\63\ 76 FR 57106--57129, September 15, 2011.
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(1) EPA Authority
Statutory authority for the vehicle controls in this proposal 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(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 proposed 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,
187 L. Ed. 2d 278, 2013 U.S. LEXIS 7380 (U.S., 2013), affirmed in part
and reversed in part on unrelated grounds by Util. Air Regulatory Group
v. EPA, 134 S. Ct. 2427, 189 L. Ed. 2d 372, 2014 U.S. LEXIS 4377 (U.S.,
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 of
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 it authority
under Section 202(a), its testing authority under Section 203 of the
Act, and its enforcement authorities under Section 207 of the Act are
discussed fully in the Phase 1 rule, and need not be repeated here. See
76 FR 57129-57130.
[[Page 40170]]
The proposed rule includes GHG emission and fuel efficiency
standards applicable to trailers--an essential part of the tractor-
trailer motor vehicle. Class 7/8 heavy-duty vehicles are composed of
three major components:--The engine, the cab-chassis (i.e. the
tractor), and the trailer. The fact that the vehicle consists of two
detachable parts does not mean that either of the parts is not a motor
vehicle. The trailer's sole purpose is to serve as the cargo-hauling
part of the vehicle. Without the tractor, the trailer cannot transport
property. The tractor is likewise incomplete without the trailer. The
motor vehicle needs both parts, plus the engine, to accomplish its
intended use. Connected together, a tractor and trailer constitute ``a
self-propelled vehicle designed for transporting . . . property on a
street or highway,'' and thus meet the definition of ``motor vehicle''
under Section 216(2) of the CAA. Thus, as EPA has previously explained,
we interpret our authority to regulate motor vehicles to include
authority to regulate such trailers. See 79 FR 46259 (August 7,
2014).\64\
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\64\ Indeed, an argument that a trailer is not a motor vehicle
because, considered (artificially) as a separate piece of equipment
it is not self-propelled, applies equally to the cab-chassis--the
tractor. No entity has suggested that tractors are not motor
vehicles; nor is such an argument plausible.
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This analysis is consistent with definitions in the Federal
regulations issued under the CAA at 40 CFR 86.1803-01, where a heavy-
duty vehicle ``that has the primary load carrying device or container
attached'' is referred to as a ``[c]omplete heavy-duty vehicle,'' while
a heavy-duty vehicle or truck ``which does not have the primary load
carrying device or container attached'' is referred to as an
``[i]ncomplete heavy- duty vehicle'' or ``[i]ncomplete truck.'' The
trailers that would be covered by this proposal are properly considered
``the primary load carrying device or container'' for the heavy-duty
vehicles to which they become attached for use. Therefore, under these
definitions, such trailers are implicitly part of a ``complete heavy-
duty vehicle,'' and thus part of a ``motor vehicle.''
65 66 67
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\65\ We note further, however, that certain hauled items, for
example a boat, would not be considered to be a trailer under the
proposal. See proposed section 1037.801, proposing to define
``trailer' as being ``designed for cargo and for being drawn by a
tractor.''
\66\ This concept is likewise reflected in the definition of
``tractor'' in the parallel Department of Transportation
regulations: ``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.'' See 49 CFR
571.3.
\67\ EPA's proposed definition of ``vehicle'' in 40 CFR 1037.801
makes clear that an incomplete trailer becomes a vehicle (and thus
subject to the prohibition against introduction into commerce
without a certificate) when it has a frame with axles attached.
Complete trailers are also vehicles.
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The argument that trailers do not themselves emit pollutants and so
are not subject to emission standards is also unfounded. First, the
argument lacks a factual predicate. Trailers indisputably contribute to
the motor vehicle's CO2 emissions by increasing engine load,
and these emissions can be reduced through various means such as
trailer aerodynamic and tire rolling resistance improvements. See
Section IV below. The argument also lacks a legal predicate. Section
202(a)(1) authorizes standards applicable to emissions of air
pollutants ``from'' either the motor vehicle or the engine. There is no
requirement that pollutants be emitted from a specified part of the
motor vehicle or engine. And indeed, the argument proves too much,
since tractors and vocational vehicle chassis likewise contribute to
emissions (including contributing by the same mechanisms that trailers
do) but do not themselves directly emit pollutants. The fact that
Section 202(a)(1) applies explicitly to both motor vehicles and engines
likewise indicates that EPA has unquestionable authority to interpret
pollutant emission caused by the vehicle component to be ``from'' the
motor vehicle and so within its regulatory authority under Section
202(a)(1).\68\
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\68\ This argument applies equally to emissions of criteria
pollutants, whose rate of emission is likewise affected by vehicle
characteristics. It is for this reason that EPA's implementing rules
for criteria pollutants from heavy duty vehicles and engines specify
a test weight for certification testing, since that weight
influences the amount of pollution emission.
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(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
proposed 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 proposed rule would continue 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 notice, 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 notice, NHTSA is currently engaging in this Phase
2 rulemaking action. Therefore, the Phase 1 standards would not remain
in effect at their 2018 or 2019 MY levels indefinitely; they would
remain in effect until the MY Phase 2 standards apply. 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.
(a) Authority To Regulate Trailers
As contemplated in the Phase 1 proposed and final rules, the
agencies are proposing standards for trailers in this 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.
[[Page 40171]]
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. . . .'' 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 GVWRs,
despite demonstrating the ability to exclude MDPVs, it is reasonable to
interpret the provision to include them.
Both commercial medium- and heavy-duty on-highway vehicles and work
trucks, though, must be vehicles in order to be regulated under this
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.
. . .'' NHTSA clearly has authority to regulate trailers under this Act
as vehicles that are drawn and has exercised that authority numerous
times. 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.
Furthermore, the general definition of a vehicle is something used
to transport goods or persons from one location to another. A tractor-
trailer is designed for the purpose of transporting goods. Therefore it
is reasonable to consider all of its 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 definition of vehicle.
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) Authority To Regulate Recreational Vehicles
NHTSA did not regulate recreational vehicles as part of the Phase 1
medium- and heavy-duty fuel consumption standards, although EPA did
regulate them as vocational vehicles for GHG emissions.\69\ In the
Phase 1 proposed rule, NHTSA interpreted ``commercial medium- and heavy
duty'' to mean that recreational vehicles, such as motor homes, were
not to be included within the program because recreational vehicles are
not commercial. Oshkosh Corporation submitted a comment on the agency's
interpretation stating that it did not match the statutory definition
of ``commercial medium- and heavy-duty on-highway vehicle,'' which
defines the phrase by GVWR and on-highway use. In the Phase 1 final
rule NHTSA agreed with Oshkosh Corporation that the agency had
effectively read words into the statutory definition. However, because
recreational vehicles were not proposed in the Phase 1 proposed rule,
they were not within the scope of the rulemaking and were excluded from
NHTSA's standards.\70\ NHTSA expressed that it would address
recreational vehicles in its next rulemaking.
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\69\ EPA did not give special consideration to recreational
vehicles because the CAA applies to heavy-duty motor vehicle
generally.
\70\ Motor homes are still subject to EPA's Phase 1
CO2 standards for vocational vehicles.
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NHTSA is proposing that recreational vehicles be included in the
Phase 2 fuel consumption standards. As discussed above, EISA prescribes
that NHTSA shall set average fuel economy standards for work trucks and
commercial medium-duty or heavy-duty on-highway vehicles. ``Work
truck'' means a vehicle that is rated between 8,500 and 10,000 lbs GVWR
and is not an MDPV. ``Commercial medium- and heavy-duty on-road highway
vehicle'' means an on-highway vehicle with a gross vehicle weight
rating of 10,000 lbs or more.\71\ Based on the definitions in EISA,
recreational vehicles would be regulated as class 2b-8 vocational
vehicles. Excluding recreational vehicles from the NHTSA standards in
Phase 2 could create illogical results, including treating similar
vehicles differently. Moreover, including recreational vehicles under
NHTSA regulations furthers the agencies' goal of one national program,
as EPA regulations already cover recreational vehicles.
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\71\ 49 U.S.C. 32901(a)(7).
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NHTSA is proposing that recreational vehicles be included in the
Phase 2 fuel consumption standards and that early compliance be allowed
for manufacturers who want to certify during the Phase 1 period.\72\
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\72\ NHTSA did not allow early compliance for one RV
manufacturer in MY 2014 that is currently complying EPA's GHG
standards.
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F. Other Issues
In addition to the standards being proposed, this notice discusses
several other issues related to those standards. It also proposes 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) 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: 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
would emit 20 percent less CO2; and a natural gas vehicle
with the same fuel efficiency as a gasoline vehicle would emit 30
percent less CO2. Yet natural gas vehicles consume no
petroleum. In Phase 1, the agencies balanced 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 would 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 benefits of using domestic
natural gas. See 76 FR 57123. We propose to maintain this approach for
Phase 2. Note that EPA is also considering natural gas in a broader
context of life cycle emissions, as described in Section XI.
(b) Alternative Refrigerants
In addition to use of leak-tight components in air conditioning
system
[[Page 40172]]
design, manufacturers could also decrease the global warming impact of
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,\73\
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.\74\ 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.\75\
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 LD 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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\73\ 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://www.epa.gov/ozone/snap/refrigerants/lists/index.html, last accessed on March 5, 2015.
\74\ Listed at 40 CFR part 82, subpart G.
\75\ GWP values cited in this proposal are from the IPCC Fourth
Assessment Report (AR4) unless stated otherwise. Where no GWP is
listed in AR4, GWP values shall be 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 could 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 could
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; \76\
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 would anticipate that HFO-1234yf could 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. EPA has begun, but has not yet completed, our
evaluation of the use of HFO-1234yf in HD vehicles. After EPA has
conducted a full evaluation based on the SNAP program's comparative
risk framework, EPA will list this alternative as either a) acceptable
subject to use conditions or b) unacceptable if the risk of use in HD
A/C systems is determined to be greater than that of the other
currently or potentially available alternatives. EPA is also
considering and evaluating additional refrigerant substitutes for use
in motor vehicle A/C systems under the SNAP program. EPA welcomes
comments related to industry development of HD A/C systems using lower-
GWP refrigerants.
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\76\ 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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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 investment required to transition to
ease over time as alternative refrigerants are adopted across all LD
vehicles and trucks. This may occur 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
manufacturers may wish to also transition their HD vehicles.
Transitioning could be advantageous for a variety of reasons including
platform standardization and company environmental stewardship
policies.
Although manufacturers of HD vehicles may begin to transition to
alternative refrigerants in the future, there is great uncertainty
about when significant adoption of alternative refrigerants for HD
vehicles might begin, on what timeline adoption might become
widespread, and which refrigerants might be involved. Another factor is
that the most likely candidate, HFO-1234yf, remains under evaluation
and has not yet been listed under SNAP. For these reasons, EPA has not
attempted to project any specific hypothetical scenarios of transition
for analytical purposes in this proposed rule.
Because future introduction of and transition to lower-GWP
alternative refrigerants for HD vehicles may occur, EPA is proposing
regulatory provisions that would be in place if and when such
alternatives become available and manufacturers of HD vehicles choose
to use them. These proposed provisions would also have the effect of
easing the burden associated with complying with the lower-leakage
requirements when a lower-GWP refrigerant is used instead of HFC-134a.
These provisions would recognize that leakage of refrigerants would be
relatively less damaging from a climate perspective if one of the
lower-GWP alternatives is used. Specifically, EPA is proposing to allow
a manufacturer to be ``deemed to comply'' with the leakage standard by
using a lower-GWP alternative refrigerant. In order to be ``deemed to
comply'' the vehicle manufacturer would need to use a refrigerant other
than HFC-134a that is listed as an acceptable substitute refrigerant
for heavy-duty A/C systems under SNAP, and defined under the LD GHG
regulations at 40 CFR 86.1867-12(e). The refrigerants currently defined
at 40 CFR 86.1867-12(e), besides HFC-134a, are HFC-152a, HFO-1234yf,
and CO2. If a manufacturer chooses to use a lower-GWP
refrigerant that is listed in the future as acceptable in 40 CFR part
82, subpart G, but that is not identified in 40 CFR 86.1867-12(e), then
the manufacturer could contact EPA about how to appropriately determine
compliance with the leakage standard.
EPA encourages comment on all aspects of our proposed approach to
HD
[[Page 40173]]
vehicle refrigerant leakage and the potential future use of alternative
refrigerants for HD applications. We specifically request comment on
whether there should be additional provisions that could prevent or
discourage manufacturers that transition to an alternative refrigerant
from discontinuing existing, low-leak A/C system components and instead
reverting to higher-leakage components.
Recently, EPA proposed to change the SNAP listing for the
refrigerant HFC-134a from acceptable (subject to use conditions) to
unacceptable for use in A/C systems in new LD vehicles.\77\ EPA expects
to take final action on this proposed change in listing status for HFC-
134a for use in new, light-duty vehicles in 2015. If the final action
changes the status of HFC-134a to unacceptable, it would establish a
future compliance date by which HFC-134a could no longer be used in A/C
systems in newly manufactured LD vehicles; instead, all A/C systems in
new LD vehicles would be required to use HFC-152a, HFO-1234yf,
CO2, or any other alternative listed as acceptable for this
use in the future. The current proposed rule does not address the use
of HFC-134a in heavy-duty vehicles; however, EPA could consider a
change of listing status for HFC-134a use in HD vehicles in the future
if EPA determines that other alternatives are currently or potentially
available that pose lower overall risk to human health and the
environment.
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\77\ See 79 FR 46126, August 6, 2014.
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(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. Sections 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 would 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 IRFA. A copy of
the Panel Report is included in the docket for this proposed rule.
The agencies determined that the proposed Phase 2 regulations could
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 \78\ Assemblers
\78\ Vehicles produced by installing a used engine into a new
chassis are commonly referred to as ``gliders,'' ``glider kits,'' or
``glider vehicles,''
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To minimize these impacts the agencies are proposing certain
regulatory flexibilities--both general and category-specific. In
general, we are proposing to delay new requirements for EPA GHG
emission standards by one year and simplify certification requirements
for small businesses. For the proposed trailers standards, small
businesses would be required to comply with EPA's standards before
NHTSA's fuel efficiency standards would begin. NHTSA does not believe
that providing small businesses trailer manufacturers with an
additional year of delay to comply with those fuel efficiency standards
would provide beneficial flexibility. The agencies are also proposing
the following specific relief:
Trailers: Proposing simpler requirements for non-box
trailers, which are more likely to be manufactured by small businesses;
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.
Glider Vehicle Assemblers: \79\ Exempt existing small
businesses, but limit the small business exemption to a capped level of
annual production (production in excess of the capped amount would be
allowed, but subject to all otherwise applicable requirements including
the Phase 2 standards).
\79\ EPA is proposing to amend its rules applicable to engines
installed in glider kits, a proposal which would affect emission
standards not only for GHGs but for criteria pollutants as well. EPA
is also proposing to clarify its requirements for certification and
revise its definitions for glider manufacturers. NHTSA is also
considering including gliders under its Phase 2 standards.
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These flexibilities are described in more detail in Section XIV and in
the Panel Report. The agencies look forward to comments and to feedback
from the small business community before finalizing the rule and
associated flexibilities to protect small businesses.
(d) Confidentiality of Test Results and GEM Inputs
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 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). For Phase 2, we expect to continue this policy and
thus would not treat any test results or other GEM inputs as CBI after
the introduction into commerce date as identified by the manufacturer.
We request comment on this approach.
We consider this issue to be especially relevant for tire rolling
resistance measurements. Our understanding is that tire manufacturers
typically consider such results as proprietary. However, under EPA's
policy, tire rolling resistance measurements are not considered to be
CBI and can be released to the public after the introduction into
commerce date identified by the manufacturer. We request comment on
whether EPA should release such data on a regular basis to make it
easier for operators to find proper replacement tires for their
vehicles.
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 will be 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
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. EPA has found this provision to work well for
engine manufacturers and is proposing a new provision in 40 CFR
[[Page 40174]]
1037.621 that would provide 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. As conditions of this allowance
manufacturers would 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.
We request comment on this allowance.
(2) Proposed Amendments to Phase 1 Program
The agencies are proposing revisions to test procedures and
compliance provisions used for Phase 1. These changes are described in
Section XII. As a drafting matter, EPA notes that we are proposing to
migrate 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 proposing to amend 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 parties and
also reduce agency administrative burden. More specifically, NHTSA
proposes to change 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
NHTSA and EPA programs. NHTSA is also proposing to remove the
petitioning process for off-road vehicles, clarify requirements for the
documentation needed for submitting innovative technology requests in
accordance with 40 CFR 1037.610 and 49 CFR 535.7, and add further
detail to requirements for submitting credit allocation plans as
specified in 49 CFR 535.9. Finally, NHTSA is adding the same record
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.
(3) Other Proposed Amendments to EPA Regulations
EPA is proposing several amendments to regulations not directly
related to the HD Phase 1 or Phase 2 programs, as detailed in Section
XIII. For these amendments, there would not be corresponding changes in
NHTSA regulations (since there are no such regulations relevant to
those programs). Some of these 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 proposed amendments to nonroad regulations
in addition to the changes proposed only for highway engines and
vehicles.
(a) Standards for Engines Used 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 XIV, EPA is proposing to amend our
regulations to allow only engines that have been certified to meet
current standards to be installed in new glider kits, with two
exceptions. First, engines certified to earlier MY standards that were
identical to the current model year standards may be used. Second, the
small manufacturer allowance described in Section I.F.(1)(c) for glider
vehicles would also apply for the engines used in the exempted glider
kits.
(b) Re-Proposal of 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 this action, EPA is re-proposing most of these amendments
to provide fuller notice and additional opportunity for public comment.
They are discussed in Section XIV.
(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 proposing to make 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
proposing in this rule to adopt 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 proposing to apply all the general
compliance provisions of 40 CFR part 1068 to heavy-duty engines and
vehicles. We propose to also apply 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.
We also request comment on applying the rest of the provisions from 40
CFR part 1068 to highway motorcycles and to all vehicles subject to
standards under 40 CFR part 86, subpart S.
EPA is proposing to update and consolidate the regulations related
to
[[Page 40175]]
formal and informal hearings in 40 CFR part 1068, subpart G. This would
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 proposing to make 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 proposing several changes to our engine testing procedures
specified in 40 CFR part 1065. None of these changes would
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 proposing to amend 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 proposing to make several minor revisions to these regulations.
(4) Other Proposed Amendments to NHTSA Regulations
NHTSA is proposing to amend 49 CFR parts 512 and 537 to allow
manufacturers to submit required compliance data for the Corporate
Average Fuel Economy program electronically, rather than submitting
some reports to NHTSA via paper and CDs and some reports to EPA through
its VERIFY database system. The agencies are coordinating on an
information technology project which will allow manufacturers to submit
pre-model, mid-model and final model year reports through a single
electronic entry point. The agencies anticipate that this would reduce
the reporting burden on manufacturers by up to fifty percent. The
amendments to 49 CFR part 537 would allow reporting to an electronic
database (i.e. EPA's VERIFY system), and the amendments to 49 CFR part
512 would ensure that manufacturer's confidential business information
would be protected through that process. This proposal is discussed
further in Section XIII.
II. Vehicle Simulation, Engine Standards and Test Procedures
A. Introduction and Summary of Phase 1 and Phase 2 Regulatory
Structures
This Section II. A. gives an overview of our vehicle simulation
approach in Phase 1 and our proposed approach for Phase 2; our separate
engine standards for tractor and vocational chassis in Phase 1 and our
proposed separate engine standards in Phase 2; and it describes our
engine and vehicle test procedures that are common among the tractor
and vocational chassis standards. Section II. B. discusses in more
detail how the Phase 2 proposed regulatory structure would approach
vehicle simulation, separate engine standards, and test procedures.
Section II. C. discusses the proposed vehicle simulation computer
program, GEM, in further detail and Section II. D. discusses the
proposed separate engine standards and engine test procedure. See
Sections III through VI for discussions of the proposed test procedures
that are unique for tractors, trailers, vocational chassis, and HD
pickup trucks and vans.
In Phase 1 the agencies adopted a regulatory structure that
included a vehicle simulation procedure for certifying tractors and the
chassis of vocational vehicles. In contrast, the agencies adopted a
full vehicle chassis dynamometer test procedure for certifying complete
heavy-duty pickups and vans. The Phase 1 vehicle simulation procedure
for tractors and vocational chassis requires regulated entities to use
GEM to simulate and certify tractors and vocational vehicle chassis.
This program is provided free of charge for unlimited use and may be
downloaded by anyone from EPA's Web site: http://www.epa.gov/otaq/climate/gem.htm. This computer program mathematically combines vehicle
component test results with other pre-determined vehicle attributes to
determine a vehicle's levels of fuel consumption and CO2
emissions for certification purposes. For Phase 1, the required inputs
to this computer program include, for tractors, 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. The sole input for vocational vehicles, was
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 a
generic engine and powertrain within the computer program, and for
Phase 1 these cannot be changed by a program user.\80\
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\80\ These attributes are recognized in Phase 1 innovative
technology provisions at 40 CFR 1037.610.
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The full vehicle chassis dynamometer test procedure for heavy-duty
pickups and vans substantially mirrors EPA's existing light-duty
vehicle test procedure. EPA also set separate engine so-called cap
standards for methane (CH4) and nitrous oxide
(N2O) (essentially capping current emission levels).
Compliance with the CH4 and N2O standards is
measured by an engine dynamometer test procedure, which EPA based on
our existing heavy-duty engine emissions test procedure with small
adaptations. EPA also set hydro-fluorocarbon refrigerant leakage design
standards for cabin air conditioning systems in tractors, pickups, and
vans, which are evaluated by design rather than a test procedure.
In this action the agencies are proposing a similar regulatory
structure for Phase 2, along with a number of revisions that are
intended to more accurately evaluate vehicle and engine technologies'
impact on real-world fuel efficiency and GHG emissions. Thus, we are
proposing to continue the same certification test regime for heavy duty
pickups and vans, and for the CH4 and N2O)
standards, as well as tractor and pickup and van air conditioning
leakage standards. EPA is also proposing to control vocational vehicle
air conditioning leakage and to use that same certification procedure.
We are proposing to continue the vehicle simulation procedure for
certifying tractors and vocational chassis, and we are proposing a new
regulatory program to regulate some of the trailers hauled by tractors.
The agencies are proposing the use of an equation based on the vehicle
simulation procedure for trailer certification. In addition, we are
proposing a simplified option for trailer certification that would not
require testing to be undertaken by manufacturers to generate inputs
for the equation. We are also proposing to continue separate fuel
consumption and CO2 standards for the engines installed
[[Page 40176]]
in tractors and vocational chassis, and we are proposing to continue to
require a full vehicle chassis dynamometer test procedure for
certifying complete heavy-duty pickups and vans. As described in
Section II.B.(2)(b), the agencies see important advantages to
maintaining separate engines standards, such as improved compliance
assurance and better control during transient engine operation.
The vehicle simulation procedure necessitates some testing of
engines and vehicle components to generate the inputs for the
simulation tool; that is, to generate the inputs to the model which is
used to certify tractors and vocational chassis. For trailers, some
testing may be performed in order to generate values that are input
into the simulation-based compliance equations. In addition to the
testing needed for this purpose for the inputs used in the Phase 1
standards, the agencies are proposing in Phase 2 that manufacturers
conduct additional required and optional engine and vehicle component
tests, and proposing the additional procedures for conducting these
input tests. These include a new required engine test procedure that
provides steady-state engine fuel consumption and CO2 inputs
to represent the actual engine in a vehicle. In addition, we are
seeking comment on a newly developed engine test procedure that
captures transient engine performance for use in the vehicle simulation
computer program. As described in detail in the draft RIA Chapter 4, we
are proposing to require entering attributes that describe the
vehicle's transmission type, and its number of gears and gear ratios.
We are proposing an optional powertrain test procedure that would
provide inputs to override the agencies' simulated engine and
transmission in the vehicle simulation computer program. We are
proposing to require entering attributes that describe the vehicle's
drive axle(s) type and axle ratio. We are also seeking comment on an
optional axle efficiency test procedure that would override the
agencies' simulated axle in the vehicle simulation computer program. To
improve the measurement of aerodynamic components performance, we are
proposing a number of improvements to the aerodynamic coast-down test
procedure and data analysis, and we are seeking comment on a newly
developed constant speed aerodynamic test procedure. We are proposing
that the aerodynamic test procedures for tractors be applicable to
trailers when a regulated entity opts to use the GEM-based compliance
equation. Additional details about all these test procedures are found
in the draft RIA Chapter 3.
We are further proposing to significantly expand the number of
technologies that are recognized in the vehicle simulation computer
program. 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. We are seeking comment on recognizing
additional technologies such as high efficiency glass and low global
warming potential air conditioning refrigerants as post-process
adjustments to the simulation results.
To better reflect real-world operation, we are also proposing to
revise the vehicle simulation computer program's urban (55 mph) and
rural (65 mph) highway duty cycles to include changes in road grade. We
are seeking comment on whether or not these duty cycles should also
simulate driver behavior in response to varying traffic patterns. We
are proposing 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 when the vehicle is not moving. And to better
recognize that vocational vehicle powertrains are configured for
particular applications, we are proposing to further subdivide the
vocational chassis category into three different vehicle speed
categories. This is in addition to the Phase 1 subdivision by three
weight categories. The result is nine proposed vocational vehicle
subcategories for Phase 2. The agencies are also proposing to subdivide
the highest weight class of tractors into two separate categories to
recognize the unique configurations and technology applicability to
``heavy-haul'' tractors.
Even though we are proposing to include engine test results as
inputs into the vehicle simulation computer model, we are also
proposing to continue the Phase 1 separate engine standard regulatory
structure by proposing separate engine fuel consumption and
CO2 standards for engines installed in tractors and
vocational chassis. For these separate engine standards, we are
proposing to continue to use the Phase 1 engine dynamometer test
procedure, which was adapted substantially from EPA's existing heavy-
duty engine emissions test procedure. However, we are proposing to
modify the weighting factors of the tractor engine's 13-point steady-
state duty cycle to better reflect real-world engine operation and to
reflect the trend toward operating engines at lower engine speeds
during tractor cruise speed operation. Further details on the proposed
Phase 2 separate engine standards are provided below in Section II. D.
In today's action EPA is proposing to continue the separate engine cap
standards for methane (CH4) and nitrous oxide
(N2O) emissions.
(1) Phase 1 Vehicle Simulation Computer Program (GEM)
For Phase 1 EPA developed a vehicle simulation computer program
called, ``Greenhouse gas Emissions Model'' or ``GEM.'' GEM was created
for Phase 1 for the exclusive purpose of certifying tractors and
vocational vehicle chassis. GEM is similar in concept to a number of
other commercially available vehicle simulation computer programs. See
76 FR 57116, 57146, and 57156-57157. However, GEM is also unique in a
number of ways.
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. For Phase 1 GEM's vehicle inputs include vehicle
aerodynamics information (for tractors), 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 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 models the vehicle pulling
a standard trailer. For vocational vehicles, Phase 1 GEM includes a
fixed aerodynamic drag coefficient and vehicle frontal area.
GEM uses the same physical principles as many other existing
vehicle simulation models to derive governing equations which describe
driveline components, engine, and vehicle. These equations are then
integrated in time to calculate transient speed and torque. 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; ad 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
[[Page 40177]]
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. This concludes
the vehicle simulation.
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 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. For each regulatory subcategory of tractor and vocational
vehicle (e.g., sleeper cab tractor, day cab tractor, small vocational
vehicle, large vocational vehicle, etc.), GEM applies prescribed
weighting factors to each of the three duty cycles to represent the
fraction of city, urban highway, and rural highway driving that would
be typical of each subcategory. After completing all the cycles, GEM
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 the vehicle complies with
the applicable standards. This other information includes the annual
sales volume of the vehicle (family) simulated in GEM, plus information
on emissions credits that may be generated or used as part of that
vehicle family's certification.
While GEM is similar to other vehicle simulation computer programs,
GEM is also unique in a number of ways. First, GEM was designed
exclusively for regulated entities to certify tractor and vocational
vehicle chassis to the agencies' respective fuel consumption and
CO2 emissions standards. For GEM to be effective for this
purpose, the inputs to GEM include only information related to vehicle
components and attributes that significantly impact vehicle fuel
efficiency and CO2 emissions. For example, these include
vehicle aerodynamics, 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. 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
might be included in other commercially available vehicle simulation
programs for other purposes. Furthermore, the simulated driver behavior
and the duty cycles cannot be changed in the GEM executable program.
This helps to ensure that all vehicles are simulated and certified in
the same way, but this does preclude GEM from being of much use as a
research tool for exploring the effects of driver behavior and of
different duty cycles.
To allow for public comment, GEM 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.
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.81 82 In response to this peer review and comments
from stakeholders, EPA has made changes to GEM. The current version of
GEM is v2.0.1, which is the version applicable for the Phase 1
standards.\83\
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\81\ See 76 FR 57146-57147.
\82\ 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://www.epa.gov/otaq/climate/documents/420r11007.pdf.
\83\ See EPA's Web site at http://www.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).
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(2) Phase 1 Engine Standards and Engine Test Procedure
For Phase 1 the agencies set separate engine fuel consumption and
CO2 standards for engines installed in tractors and
vocational vehicle chassis. EPA also set separate engine cap standards
for methane (CH4) and nitrous oxide (N2O)
emissions. These Phase 1 engine standards are specified in terms of
brake-specific (g/hp-hr) fuel, CO2, CH4 and
N2O emissions limits. For these separate engine standards,
the agencies adopted an engine dynamometer test procedure, which was
built substantially from EPA's existing heavy-duty engine emissions
test procedure. Since the test procedure already specified how to
measure fuel consumption, CO2 and CH4, few
changes were needed to employ the test procedure for purposes of the
Phase 1 standards. For Phase 1 the test procedure was modified to
specify how to measure N2O.
The duty cycles from EPA's existing heavy-duty emissions test
procedure were used in a somewhat unique way for Phase 1. 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) 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 FTP. This
requirement was intended to reflect that tractor engines typically
operate near steady-state conditions versus transient conditions. See
76 FR 57159. The agencies adopted the converse for engines installed in
vocational vehicles. That is, these engines must meet fuel efficiency
and CO2 standards over only the hot-start 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 cold-start and hot-start FTP only and not over
the SET duty cycle. See Section II. D. for details on how we propose to
modify the engine test procedure for Phase 2.
B. Phase 2 Proposed Regulatory Structure
For Phase 2, the agencies are proposing to modify the regulatory
structure used for Phase 1. Note that we are not proposing to apply the
new Phase 2 regulatory structure for compliance with the Phase 1
standards. The structure used to demonstrate compliance with the Phase
1 standards will remain as finalized in the Phase 1 regulation. The
modifications we are proposing are consistent with the agencies' Phase
1 commitments to consider a range of regulatory approaches during the
development of
[[Page 40178]]
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 intended 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 also committed to consider the potential for a regulatory
program for some of the trailers hauled by tractors. After considering
these various approaches, the agencies are proposing a structure in
which regulated tractor and vocational chassis manufacturers would
additionally enter engine and powertrain-related inputs into GEM, which
was not allowed in Phase 1.
For trailer manufacturers, which would be subject to first-time
standards under the proposal, we are also proposing GEM-based
certification. However, we are proposing a simplified structure that
would allow certification without the manufacturers actually running
GEM. More specifically, the agencies have developed a simple equation
that uses the same trailer inputs as GEM to represent the emission
impacts of aerodynamic improvements, tire improvements, and weight
reduction. As described in Chapter 2.10.6 of the draft RIA, these
equations have nearly perfect correlation with GEM so that they can be
used instead of GEM without impacting stringency.
We are proposing both required and optional test procedures to
provide these additional GEM inputs. We are also proposing to
significantly expand the number of technologies recognized in GEM.
Further, we are proposing to modify the GEM duty cycles and to further
subdivide the vocational vehicle subcategory to better represent real-
world vehicle operation. In contrast to these changes, we are proposing
to maintain essentially the same chassis dynamometer test procedure for
certifying complete heavy-duty pickups and vans.
(1) Other Structures Considered
To follow-up on the commitment to consider other approaches, the
agencies spent significant time and resources in evaluating six
different options for demonstrating compliance with the proposed Phase
2 standards. These six options include full vehicle chassis dynamometer
testing, full vehicle simulation, and vehicle simulation in combination
with powertrain testing, engine testing, engine electronic controller
and/or transmission electronic controller 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 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.
Chassis dynamometer testing is used extensively in the development
and certification of light-duty vehicles. It also is used in Phase 1
for complete Class 2b/3 pickups and vans, as well as for 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 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
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 draft RIA Chapter 3, the agencies were only
able to locate 11 heavy-duty chassis test sites. However, 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 proposing
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. First, the agencies
recognize that such testing 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.\84\ 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.\85\ Although the agencies are not
proposing chassis dynamometer certification of tractors and vocational
chassis, we believe such an approach could 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. We request comment on whether or
not a chassis dynamometer test procedure should be required in lieu of
the vehicle simulation approach we are proposing. Note, as discussed in
Section II. C. (4) (b) that we are also proposing a modest complete
tractor heavy-duty chassis dynamometer test program only for monitoring
complete tractor fuel efficiency trends over the implementation
timeframe of the Phase 1 and proposed Phase 2 standards.
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\84\ 03-19034 TASK 2 Report-Paper 03-Class8_hil_DRAFT, September
30, 2013.
\85\ GEM Validation, Technical Research Workshop, San Antonio,
December 10-11, 2014.
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Another option considered for certification involves testing a
vehicle's powertrain in a modified engine dynamometer test facility. In
this case the engine and transmission are installed 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. A key advantage of the powertrain test approach is that it
[[Page 40179]]
directly measures the effectiveness of the engine, the transmission,
and the integration of the two. Engines and transmissions are
particularly challenging to simulate within a computer program like GEM
because engines and transmissions installed in vehicles today are
actively and interactively controlled by their own sophisticated
electronic controls. These controls already contain essentially their
own vehicle simulation programs that GEM would then have to otherwise
simulate.
We believe that the capital investment impact for powertrain
testing on manufacturers could be manageable for those that already
have heavy-duty engine dynamometer test cells. 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 recently completed construction of a new and
specialized heavy heavy-duty powertrain dynamometer facility. EPA also
contracted SwRI to evaluate North America's current capabilities for
powertrain testing in the heavy-duty sector and the cost of installing
a new powertrain cell that would meet agency requirements.\86\ Results
indicated that one supplier currently has 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 $68,972.
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\86\ 03-19034 TASK 2 Report-Paper 03-Class8_hil_DRAFT, September
30, 2013.
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Since the Phase 1 Final Rule, the agencies and other stakeholders
have completed significant new work toward refining the powertrain test
procedure itself. The proposed regulations provide details of the
refined powertrain test procedure. See 40 CFR 1037.550.
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 proposing an approach to define a
powertrain family in 40 CFR 1037.231. We request comment on what key
attributes should be considered when defining a transmission family.
We believe that a combination of a robust powertrain family
definition, a refined powertrain test procedure and a refined GEM could
become an optimal certification path that leverages the accuracy of
powertrain testing along with the versatility of GEM, which alleviates
the need to test a large number of vehicle or powertrain variants. To
balance the potential advantages of this approach with the fact that it
has never been used for vehicle certification in the past, we are
proposing to allow this approach as an optional certification path, as
described in Section II.B.(2)(b). To be clear, we are not proposing to
require powertrain testing at this time, but because this testing would
recognize additional technologies that are not recognized directly in
GEM (even as proposed to be amended), we are factoring its use into our
stringency considerations for vocational chassis. We request comment on
whether the agencies should consider requiring powertrain testing more
broadly.
Another regulatory structure option considered was engine-only
testing over the GEM duty cycles over a range of simulated vehicle
configurations. This approach would use GEM to generate engine duty
cycles by simulating a range of transmissions and other vehicle
variations. These engine duty cycles then would be programmed into a
separate controller of a dynamometer connected to an engine's output
shaft. Unlike the chassis dynamometer or powertrain dynamometer
approaches, which could have significant test facility construction or
modification costs, this approach has little capital investment impact
on manufacturers because the majority already have engine test
facilities to both develop engines and to certify engines to meet both
the non-GHG standards and the Phase 1 fuel efficiency and GHG
standards. The agencies also have been investigating this approach as
an alternative way to generate data that could be used to represent an
engine in GEM. Because this approach captures engine performance under
transient conditions, this approach could be an improvement over our
proposed Phase 2 approach of representing an engine in GEM with only
steady-state operating data. Details of this alternative are described
in draft RIA. Because this approach is new and has never been used for
vehicle development or certification, we are not proposing requiring
its use as part of the Phase 2 certification process. However, we
encourage others to investigate this new approach in detail, and we
request comment on whether or not the agencies should replace our
proposed steady-state operation representation of the engine in GEM
with this alternative approach.
Additional certification options considered included 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. 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 engine-only test procedure, 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 technical challenges, however. The model would
have to become more complex and tailored to each transmission and
controller to make sure that the controller would operate properly when
it is connected to a computer instead of a 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. The vehicle manufacturer would have to be
responsible for connecting the transmission controller to the computer,
which would require a detailed verification process to ensure it is
operating properly. 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.
Finally, the agencies considered full vehicle simulation plus
separate engine standards, which is the proposed
[[Page 40180]]
approach for Phase 2. These are discussed in more detail in the
following sections.
(2) Proposed Regulatory Structure
Under the proposed structure, tractor and vocational chassis
manufacturers would be required to provide engine, transmission, drive
axle(s) and tire radius inputs into GEM. For Phase 1, GEM used 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 proposing to significantly expand GEM to account for a wider range
of technological improvements that would otherwise need to be
recognized through some off-cycle crediting approach. These include
improvements to the driver controller (i.e., the simulation of the
driver), engines, transmissions, and axles. Additional technologies
that would now be recognized in GEM also include 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. The
agencies are also proposing to maintain 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 Full 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 manufacturers to adopt new engine, transmission or axle
technologies because GEM was not configured to recognize these
technologies uniquely. By recognizing such technologies in GEM under
Phase 2, the agencies would be creating a 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
Phase 2 incorporate such an approach.
We anticipate that the proposed Phase 2 approach would create three
new specific regulatory incentives. First, vehicle manufacturers would
have an incentive to use the most efficient engines. Since GEM would no
longer use the agency default engine in simulation manufacturers would
have their own more efficient 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 efficient engines in their vehicles. Second, the
proposed approach would 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 would allow the vehicle
manufactures to use specific transmission, axle, and tire
characteristics as inputs, thus having the ability to directly
recognize many powertrain integration benefits, such as downspeeding,
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 for designing its
vehicle to operate closer to the sweet spot because Phase 1 GEM does
not model the actual engine, transmission, axle, or tire revolutions
per mile. Third, the proposed approach would recognize improvements to
the overall efficiency of the drivetrain including the axle. The
proposed version of GEM would recognize the benefits of different axle
technologies including axle lubricants, and reducing axle losses such
as by enabling three-axle vehicles to deliver power to only one rear
axle through the proposed post-simulation adjustment approach (see
Chapter 4.5 of the Draft RIA).
In addition to providing regulatory incentives to use more fuel
efficient technologies, expanding GEM to recognize engine and other
powertrain component improvements would also provide important
flexibility to vehicle manufacturers. The flexibility to effectively
trade engine and other component improvements against other vehicle
improvements would allow vehicle manufacturers to better optimize their
vehicles to achieve the lowest cost for specific customers. Vehicle
manufacturers could use this flexibility to reduce overall compliance
costs and/or address special applications where certain vehicle
technologies are not practical. The agencies considered in Phase 1
allowing the exchange of emission certification credits generated
relative to the separate brake-specific (g/hp-hr) engine standards and
credits generated relative to the vehicle standards (g/ton-mile).
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
proposed approach for Phase 2 would eliminate these concerns because
engine and other vehicle component improvements would be evaluated
relative to the same vehicle standard in GEM. This also means that
under the proposed 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 propose to continue the separate engine standard
along with recognizing engine performance at the vehicle level. The
agencies acknowledge that maintaining a separate engine standard would
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.
There could be disadvantages to the proposed approach, however. As
is discussed in Section II.B.(2)(b), some of the disadvantages can be
addressed by maintaining separate engine standards, which we are
proposing to do. We request comment on other disadvantages such as
those discussed below.
One disadvantage of the proposed approach is that it would increase
complexity for the vehicle standards. For example, vehicle
manufacturers would be required to conduct additional engine tests and
track additional GEM
[[Page 40181]]
inputs for compliance purposes. However, we believe that most of the
burden associated with this increased complexity would be an infrequent
burden of engine testing and updating information systems to track
these inputs.
Because GEM measures performance over specific duty cycles intended
to represent average operation of vehicles in-use, the proposed
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. 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 would not prevent manufacturers from properly
optimizing vehicles for customer fuel efficiency. First, the impact of
the certification duty cycles would 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 proposed
regulations would 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 would 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. The proposed standards are not intended to be at a stringency
where manufacturers would 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 proposed
standards. Fourth, we are proposing further sub-categorization of the
vocational vehicle segment, tripling the number of subcategories within
this segment from 3 to 9. These 9 subcategories would divide each of
the 3 Phase 1 weight categories into 3 additional vehicle speed
categories. Each of the 3 speed categories would have unique duty cycle
weighting factors to recognize that different vocational chassis are
configured for different vehicle speed applications. Furthermore, we
are proposing 9 unique standards for each of the subcategories. This
further subdivision better recognizes technologies' performance under
the conditions for which the vocational chassis was configured to
operate. This further decreases the potential of the certification duty
cycles to encourage manufacturers to configure vocational chassis
differently than the optimum configuration for specific customers'
applications. Finally, as required by Section 202 (a) (1) and 202 (d)
of the CAA, EPA is proposing specific GHG standards which would have to
be met in-use.
One disadvantage of our proposed full vehicle simulation approach
is the potential requirement for engine manufacturers to disclose
otherwise proprietary information to vehicle manufacturers who install
their engines. Under the proposed approach, vehicle manufacturers would
need to know 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 would need to know details about the engine's performance
that are generally not publicly available--specifically the detailed
fuel consumption of an engine over many steady-state operating points.
We request comment on whether or not such information could be used to
``reverse engineer'' intellectual property related to the proprietary
design of engines, and what steps the agencies could take to address
this.
The agencies also generally request comment on the advantages and
disadvantages of the proposed structure that would require vehicle
manufacturers to provide additional inputs into GEM to represent the
engine, transmission, drive axle(s), and loaded tire radius.
(b) Advantages of Separate Engine Standards
For engines installed in tractors and vocational vehicle chassis,
we are proposing to maintain separate engine standards for fuel
consumption and GHG emissions in Phase 2 for both SI and CI engines.
Moreover, we are proposing new more stringent engine standards for CI
engines. 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 NHTSA
and EPA standards.
First, EPA has a robust compliance program based on 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. If the engines
exceed the standards, they can be required to correct the problem or
perform other remedial actions. Without separate engine standards in
Phase 2, addressing in-use compliance becomes more subjective. Having
clearly defined compliance responsibilities is important to both the
agencies and to the market.
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.
Third, engine fuel consumption can vary significantly between
transient operation and steady-state operation, and we are proposing
only steady-state engine operating data as the required engine input
into GEM for both tractor and vocational chassis certification. Because
vocational vehicles can spend significant operation under transient
engine operation, the separate engine standard for engines installed in
vocational vehicles is a transient test. Therefore, the separate engine
standard for vocational engines provides the only measure of engine
fuel consumption and CO2 emissions under transient
conditions. Without a transient engine test we would not be able to
ensure control of fuel consumption and CO2 emissions under
transient engine conditions.
[[Page 40182]]
It is worth noting that these first three advantages are also
beneficial for the marketplace. In these respects, the separate engine
standards allow each manufacturer to be confident that its competitors
are playing by the same rules. The agencies believe that the absence of
a separate engine standard would leave open the possibility that a
manufacturer might choose to cut corners with respect to in-use
compliance margins, the NOX-CO2 tradeoff, or
transient controls. Concerns that competitors might take advantage of
this can put a manufacturer in a difficult situation. On the other hand
knowing that the agencies are ensuring all manufacturers are complying
fully can eliminate these concerns.
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 reason why efficient engines cannot be used in such vehicles.
However, without separate engine standards, there would be no way to
require them to be efficient.
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 proposing to require 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.
The agencies request comment on the advantages and disadvantages of
the proposal to maintain separate engine standards and to increase the
stringency of the CI engine standards. We would also welcome suggested
alternative approaches that would achieve the same goals. It is
important to emphasize that the agencies see the advantages of separate
engine standards as fundamental to the success of the program and do
not expect to adopt alternative approaches that fall short of these
goals.
Note that commenters opposing separate engine standards should also
be careful distinguish between concerns related to the stringency of
the proposed engine standards, from concerns inherent to any separate
engine standards whatsoever. When meeting with manufacturers prior to
this proposal, the agencies heard many concerns about the potential
problems with separate engines standards that were actually concerns
about separate engine standards that are too stringent. However, we see
these as two different issues. The agencies do recognize that setting
engine standards at a high stringency could increase the cost to comply
with the vehicle standard, if lower-cost vehicle technologies are
available. Additionally, the agencies recognize that setting engine
standards at a high stringency may promote the use of large-
displacement engines, which have inherent heat transfer and efficiency
advantages over smaller displacement engines over the engine test
cycles, though a smaller engine may be more efficient for a given
vehicle application. Thus we encourage commenters supporting the
separate engine standards to address the possibility of unintended
consequences such as these.
C. Proposed Vehicle Simulation Model--Phase 2 GEM 87
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\87\ The specific version of GEM used to develop the proposed
standards, and which we propose to use for compliance purposes is
also known as GEM 3.0.
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For tractors and vocational vehicle chassis, the agencies propose
that manufacturers would be required to meet vehicle-based standards,
and certification to these standards would be facilitated by the
required use of the vehicle simulation computer program called,
``Greenhouse gas Emissions Model'' or ``GEM.'' GEM was created for
Phase 1 for the exclusive purpose of certifying tractors and vocational
chassis. The agencies are proposing to modify GEM and to require
vehicle manufacturers to provide additional inputs into GEM to
represent the engine, transmission, drive axle(s), and loaded tire
radius. For Phase 1, GEM used agency default values for all of these
parameters. Under the proposed approach for Phase 2, vehicle
manufacturers would be able to use these technologies, plus additional
technologies to demonstrate compliance with the applicable standards.
The additional technologies include 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 comply with
the standards.
(1) Description of the Proposed Modifications to GEM
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. 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 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 the
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 proposal GEM has been modified and validated against a set
of experimental data that represents over 130 unique vehicle variants.
EPA believes this new version of GEM is an accurate and cost-effective
alternative to measuring fuel consumption and CO2 over a
chassis dynamometer test procedure. Some of the key proposed
modifications would necessitate required and optional vehicle component
test procedures to generate additional GEM inputs. The results of which
would provide additional inputs into GEM. These include a new required
engine test procedure to provide steady-state engine fuel consumption
and CO2 inputs into GEM. We are also seeking comment on a
newly developed engine test procedure that also captures transient
engine performance for use in GEM. We are proposing to require inputs
that describe the vehicle's transmission type, and its number of gears
and gear ratios. We are proposing an optional powertrain test procedure
that would provide inputs to override
[[Page 40183]]
the agencies' simulated engine and transmission in GEM. We are
proposing to require inputs that describe the vehicle's drive axle(s)
type (e.g., 6x4 or 6x2) and axle ratio. We are also seeking comment on
an optional axle efficiency test procedure to override the agencies'
simulated axle in GEM. We are proposing to significantly expand 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. We are seeking comment on recognizing (outside
of the GEM simulation) additional technologies such as high efficiency
glass and low global warming potential air conditioning refrigerants.
To better reflect real-world operation, we are also proposing to revise
the vehicle simulation computer program's urban and rural highway duty
cycles to include changes in road grade. We are seeking comment on
whether or not these duty cycles should also simulate driver behavior
in response to varying traffic patterns. We are proposing 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 when the vehicle
is not moving. And to better recognize that vocational vehicle
powertrains are configured for particular applications, we are
proposing to further subdivide 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.
This section briefly describes some of the key proposed modifications
to GEM.
(a) Simulating Engines for Vehicle Certification
Before describing the proposed approach for Phase 2, this section
first reviews how engines are simulated for vehicle certification in
Phase 1. 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-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 runs 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, interpolation of
the tables themselves over each of the three different GEM duty cycles
did not have to closely represent how an actual engine might operate
over these three different duty cycles.
In contrast, for Phase 2 we are proposing a new and required
steady-state engine dynamometer test procedure for manufacturers to use
to generate their own engine fuel maps to represent each of their
engine families in GEM. The proposed Phase 2 approach is consistent
with the 2014 NAS Phase 2 First Report recommendation.\88\ To validate
this approach we compared 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 hp) and one engine was tested at two
ratings (6.7 liters at 240 and 300 hp), and other engine with one
rating (15 liters 455 hp) service classes. For each engine and rating
our proposed 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
proposing, 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 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, 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.
---------------------------------------------------------------------------
\88\ 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 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 turbo-charger vane position and other set
points than it is to do so 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. Furthermore, because exhaust
emissions control is more challenging under transient engine operation,
engineering tradeoffs sometimes need to be made between fuel efficiency
and transient emissions control. Special calibrations are typically
also required to control smoke and manage exhaust temperatures during
transient operation for a transient cycle. We are confident that this
low bias in GEM would continue to exist well into the future if we were
to test additional engines. However, with the range of the results that
we have generated so far we are somewhat less confident in proposing a
single numerical value to correct for this effect
[[Page 40184]]
over the ARB Transient duty cycle. Based on the data we have collected
so far, we are conservatively proposing to apply a 5.0 percent
correction factor to GEM's ARB Transient results. Note that adjustment
would be applied internal to GEM, and no manufacturer input or action
would be needed. This means that for GEM fuel consumption and
CO2 emissions results that were generated using the steady-
state engine map representation of an engine in GEM, a 1.05 multiplier
would be applied to only the ARB Transient result. If a manufacturer
chooses to perform the optional powertrain test procedure we are
proposing, then this 1.05 multiplier to the ARB Transient would not
apply (since we know of no bias in that optional powertrain test). For
the same reason, if we were to replace the proposed steady-state engine
map in GEM with the alternative approach detailed in draft RIA, then
this 1.05 multiplier would not apply. We request comment on whether or
not this single value multiplier is an appropriate way to correct
between steady-state and transient engine fuel consumption and
CO2 emissions, specifically over the ARB Transient duty
cycle. We also request comment on the magnitude of the multiplier
itself. For example, for the proposal we have chosen a 1.05 multiplier
correction value because it is conservative but still near the mean
bias we observed. However, for the tests we have conducted on current
technology engines, a 1.05 multiplier would mean that about one half of
these engines would be penalized by powertrain testing (or if we
utilized the alternative engine approach) because the actual measured
transient impact would be slightly higher than 5 percent. While these
tests were performed on current technology powertrains rather than the
kind of optimized powertrains we project for Phase 2, these results
raise still some concerns for us. Because we intend to incentivize
powertrain testing and not penalize it, and because we also encourage
constructive comments on the alternative approach, we also request
comment on increasing the magnitude of this ARB Transient multiplier
toward the higher end of the biases we observed. For example, we
request comment on increasing the proposed multiplier from 1.05 to
1.07, which is close to the 90th percentile of the results we have
collected so far. Using this higher multiplier would imply that only
about 10 percent of engines powertrain tested or tested under the
alternative approach would show worse fuel consumption over the ARB
Transient than its respective representation in a steady-state data
table in GEM. This would mean that the remaining 90 percent of engines
powertrain tested would receive additional credit in GEM. Using 1.07
would essentially guarantee that any powertrain that was significantly
more efficient than current powertrains would receive meaningful credit
for the improvement. However, this value would also provide credits for
many current powertrain designs.
We also request comment as to whether or not there might be certain
vehicle sub-categories or certain small volume vocational chassis,
where using the Phase 1 approach of using a generic engine table might
be more appropriate. We also request comment as to whether or not the
agencies should provide default generic engine maps in GEM for Phase 2
and allow manufacturers to optionally override these generic maps with
their own maps, which would be generated according to our proposed
engine dynamometer steady-state test 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 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 ideal points for maximum fuel efficiency 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 proposing to allow manufacturers to
select one of three types of transmissions to represent the
transmission in the vehicle they are certifying: manual transmission,
automated manual transmission, and automatic transmission. We are
currently in the process of developing a dual-clutch transmission type
in GEM, but we are not proposing to allow its use in Phase 2 at this
time. Because production of heavy-duty dual clutch transmissions has
only begun in the past few months, we do not yet have any experimental
data to validate our GEM simulation of this transmission type.
Therefore, we are requesting comment on whether or not there is
additional data available for such validation. Should such data be
provided in comments, we may finalize GEM for Phase 2 with a fourth
transmission types for dual clutch transmissions. We are also
considering an option to address dual clutch transmissions through a
post-simulation adjustment as discussed in Chapter 4 of the draft RIA.
In the proposed modifications to GEM, the driver behavior and the
three different transmission types are simulated in the same basic
manner as in Phase 1, but each transmission type features a unique
combination of driver behavior and transmission responses that match
both the driver behavior and 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 always in the most
efficient gear for the current vehicle demand, while staying within
certain limits to prevent unrealistically high frequency 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 three 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
draft RIA for a more detailed description of these different simulated
driver behaviors and transmission types.
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.\89\ The advantages of this approach 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 policy disadvantages of
this approach. One disadvantage is that it would require the
[[Page 40185]]
disclosure of proprietary information between competing companies
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 propose requiring 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 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 requiring transmission manufacturers to submit
detailed proprietary shift strategy information to vehicle
manufacturers to input into GEM. This is not unlike Phase 1, where
unique transmission and axle attributes were not recognized at all in
GEM. Instead, the agencies are proposing that vehicle manufacturers
choose from among the three transmission types that the agencies have
already developed, validated, and programmed into GEM. The vehicle
manufacturers would then enter into GEM their particular transmission's
number of gears and gear ratios. The agencies recognize that designing
GEM like this would exclude a potentially significant reduction from
the GEM simulation. However, if a manufacturer chooses to use the
optional powertrain test procedure, then the agencies' transmission
types in GEM would be overridden by the actual data collected during
the powertrain test, which would recognize the actual benefit of the
transmission. Note that the optional powertrain test procedure is only
advantageous to a vehicle manufacturer if an actual transmission is
more efficient and has a superior shift strategy compared to its
respective transmission type simulated in GEM.
---------------------------------------------------------------------------
\89\ 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.
---------------------------------------------------------------------------
(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 we are proposing that the vehicle
manufacturer input into GEM the axle ratio of the primary drive axle.
This input would recognize the intent 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.
We are proposing a fixed axle ratio energy efficiency of 95.5
percent at all speeds and loads, but are requesting comment on whether
this pre-specified efficiency is reasonable. However, we know that this
efficiency actually varies as a function of axle speed and axle input
torque. Therefore, as an exploratory test we have created a modified
version of GEM that has as an input a data table of axle efficiency 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. We have also created a draft axle ratio efficiency test
procedure that requires the use of a dynamometer test facility. This
procedure includes the use of a baseline fuel-efficient synthetic gear
lubricant manufactured by BASF.\90\ This baseline will be used to gauge
improvements in axle design and lubricants. The draft test procedure
includes initial feedback that we have received from axle manufacturers
and our own engineering judgment. Refer to 40 CFR 1037.560 of the Phase
2 proposed regulations, which contain this draft test procedure. This
test procedure could be used to generate the results needed to create
the axle efficiency data table for input into GEM. However, the
agencies have not yet conducted experimental tests of axles using this
draft test procedure so we are reluctant to propose this test procedure
as either mandatory or even optional at this time. Rather we request
comment as to whether or not we should finalize this test procedure and
either require its use or allow its use optionally to determine an axle
efficiency data table as an input to GEM, which would override the
fixed axle efficiency we are proposing at this time. We also request
comment on improving or otherwise refining the test procedure itself.
Note that the agencies believe that allowing the GEM default axle
efficiency to be replaced by manufacturer inputs only makes sense if
the manufacturer inputs is are the results of a specified test
procedure that we could verify by our own independent testing of the
axle.
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\90\ BASF TI/EVO 0137 e, Emgard[supreg] FE 75W-90 Fuel Efficient
Synthetic Gear Lubricant.
---------------------------------------------------------------------------
In addition to proposing to require the primary drive axle ratio
input into GEM (and potentially an option to input an actual axle
efficiency data table), we are also proposing that the vehicle
manufacturer input into GEM whether or not 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 pumping 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 is estimated to be
[[Page 40186]]
2.5 percent.\91\ Therefore, in the proposed Phase 2 version of GEM, if
a manufacturer simulates a 6x2 axle configuration, GEM decreases the
overall GEM result by 2.5 percent. 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. Note that we are not proposing that GEM have an option to
increase the overall GEM result by some percentage by selecting, say, a
6x6 or 8x8 option if the front axle(s) are driven. Because these
configurations are only manufactured for specialized vehicles that
require extra traction for off-road applications, they are very low
volume sales and their increased fuel consumption and CO2
emissions are not significant in comparison to the overall reductions
of the proposed Phase 2 program. Note that 40 CFR 1037.631 (for off-
road vocational vehicles), which is being continued from the Phase 1
program, would likely exempt many of these vehicles from the vehicle
standards.
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\91\ NACFE. Executive Report--6x2 (Dead Axle) Tractors. November
2010. See Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
Instead of directly modeling 6x4 or 6x2 axle configuration, we are
proposing use of a post-simulation adjustment approach discussed in
Chapter 4 of the drat RIA to model benefits of different axle
configuration.
(d) Simulating Accessories for Vehicle Certification
Phase 1 GEM uses a fixed power consumption value to simulate the
fuel consumed for powering accessories such as power steering pumps and
alternators. While the agencies are not proposing any changes to this
approach for Phase 2, we are requesting comment on whether or not we
should allow some manufacturer input to reflect the installation of
accessory components that result in lower accessory loads. For example,
we could consider an accessory load reduction GEM input based on
installing a number of qualifying advanced accessory components that
could be in production during Phase 2. We request comment on
identifying such advanced accessory components, and we request comment
on defining these components in such a way that they can be
unambiguously distinguished from other similar components that do not
decrease accessory loads. We also request comment on how much of a
decrease in accessory load should be programmed into GEM if qualifying
advanced accessory components are installed.
(e) Aerodynamics for Tractor, Vocational Vehicle, and Trailer
Certification
For GEM in Phase 2 the agencies propose to simulate aerodynamic
drag in largely the same manner as in Phase 1. For vocational chassis
we propose to continue to use the same prescribed products of drag
coefficient times vehicle frontal area (Cd*A) that were predefined for
each of the vocational subcategories in Phase 1. For tractors we
propose to continue to use an aerodynamic bin approach similar to the
one that exists in Phase 1 today. This approach requires tractor
manufacturers to conduct a certain amount of coast-down vehicle
testing, although manufacturers have the option to conduct scaled wind
tunnel testing and/or computational fluid dynamics modeling. The
results of these tests determine into which bin a vehicle is assigned.
Then in GEM the aerodynamic drag coefficient for each vehicle in the
same bin is the same. 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. However, for Phase 2 we are proposing new
boundary values for the bins themselves and we are adding two
additional bins in order to recognize further advances in aerodynamic
drag reduction beyond what was recognized in Phase 1. Furthermore,
while Phase 1 GEM used predefined frontal areas for tractors while the
manufacturers input a Cd value, the agencies propose that manufacturers
would use a measured drag area (CdA) value for each tractor
configuration for Phase 2. See 40 CFR 1037.525.
In addition to these proposed changes we are proposing a number of
aerodynamic drag test procedure improvements. One proposed improvement
is to update the so-called standard trailer that is prescribed for use
during aerodynamic drag testing of a tractor--that is, the hypothetical
trailer modeled in GEM to represent a trailer paired with the tractor
in actual use. 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
proposing to modify this standard trailer for tractor testing to make
it more similar to the trailers we would require to be produced during
the Phase 2 timeframe. More specifically, we would prescribe the
installation of aerodynamic trailer skirts (and low rolling resistance
tires as applied in Phase 1) on the reference trailer, as discussed in
further in Section III.E.2. As explained more fully in Sections III and
IV below, 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 also
request comment on whether or not the Phase 2 standard trailer should
include the installation of other aerodynamic devices such as a nose
fairing, an under tray, or a boat tail or trailer tail. Would a
standard trailer including these additional components make the tractor
program better?
Another proposed aerodynamic test procedure improvement is intended
to better account for average wind yaw angle to better reflect the true
impact of aerodynamic features on the in-use fuel consumption and
CO2 emissions of tractors. Refer to the proposed test
procedures in 40 CFR 1037.525 for further details of these aerodynamic
test procedures.
For trailer certification, the agencies are proposing to use GEM in
a different way than GEM is used for tractor certification in Phase 1
and Phase 2. As described in Section IV, the proposed trailer standards
are based on GEM simulation, but trailer manufacturers would not run
GEM for certification. Instead, manufacturers would use a simple
equation to replicate GEM performance from the inputs. As with GEM, the
only technologies recognized by this GEM-based equation for trailer
certification are aerodynamic technologies, tire technologies
(including tire rolling resistance and automatic tire inflation
systems), and some weight reduction technologies. Note that since the
purpose of this equation is to measure 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.
Similar to tractor certification, we propose that trailer
manufacturers may at their option conduct some amount of aerodynamic
testing (e.g., coast-down testing, scale wind tunnel testing,
computational fluid dynamics modeling, or possibly aerodynamic
component testing) and use this information with the equation.\92\ In
this
[[Page 40187]]
case the agencies propose 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 proposed regulations for details on the proposed
reference tractor configuration for trailer test procedures.
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\92\ The agencies project that more than enough aerodynamic
component vendors would take advantage of proposed optional pre-
approval process to make trailer manufacturer testing optional.
---------------------------------------------------------------------------
(f) Tires and Tire Inflation Systems for Truck and Trailer
Certification
For GEM in Phase 1 vehicle 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 are proposing to continue this same approach and the use of ISO
28580, and we propose to expand these requirements to trailer tires as
well. We request comment on whether specific modifications to this test
procedure would improve its accuracy, repeatability or its test lab to
test lab variability.
In addition to tire rolling resistance, we are proposing that for
Phase 2 vehicle manufacturers enter into GEM the tire manufacturer's
specified tire loaded radius 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. We request
comment on whether the proposed test procedure should be modified to
measure the tire's revolutions per distance directly, as opposed to
using the loaded radius to calculate the drive axle rotational speed
from vehicle speed.
For tractors and trailers, we propose to allow manufacturers to
specify whether or not an automatic tire inflation system is installed.
If one is installed, GEM, or in the case of trailers, the equations
based on GEM, would assign a 1 percent decrease in the overall fuel
consumption and CO2 emissions simulation results for
tractors, and a 1.5 percent decrease for trailers. This would be done
through post-simulation adjustments discussed in Chapter 4 of the draft
RIA. In contrast, we are not proposing to assign any decrease in fuel
consumption and CO2 emissions for tire pressure monitoring
systems. We do recognize that some drivers would respond to a warning
indication from a tire pressure monitoring system, but we are unsure
how to assign a fixed decrease in fuel consumption and CO2
emissions for tire pressure monitoring systems. We would estimate that
the value would be less than any value we would assign for an automatic
tire inflation system. We request comment on whether or not we should
assign a fixed decrease in fuel consumption and CO2
emissions for tire pressure monitoring systems, and if so, we request
comment on what would be an appropriate assigned fixed value.
(g) Weight Reduction for Tractor, Vocational Chassis and Trailer
Certification
We propose for Phase 2 that 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 propose to
use these same 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 are proposing a similar part by part weight reduction list
for tractor parts made from thermoplastic material. We are also
proposing 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. This increase would be allocated
partly to the chassis and from the payload using the same allocation as
weight reductions for the given vehicle type. For tractors we are
proposing to 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. Therefore, we propose to use these
ratios for trailers in Phase 2. However, as with the other fuel
consumption and GHG reducing technologies manufacturers use for
compliance, reductions associated with weight reduction would be
calculated using the trailer compliance equation rather than GEM. For
vocational chassis, for which Phase 1 did not address weight reduction,
we propose a 50/50 ratio. In other words, for vocational chassis in GEM
we propose to 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. We request comment on all aspects of applying weight
reductions in GEM, including proposed weight increases for alternate
fuel vehicles and whether a 50/50 ratio is appropriate for vocational
chassis.
(h) GEM Duty Cycles for Tractor, Vocational Chassis and Trailer
Certification
---------------------------------------------------------------------------
\93\ SwRI road grade testing and GEM validation report, 2014.
---------------------------------------------------------------------------
In Phase 1, there are three GEM vehicle duty cycles that
represented 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 propose to use these three
drive cycles in Phase 2, but with some revisions. First the agencies
propose that GEM would 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 of time 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. For Phase 2
the agencies are proposing to enhance 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 present many
opportunities for a transmission to shift gears, and may have the
unintended consequence of enabling underpowered vehicles or excessively
downsped drivetrains to generate credits. The road grade profile
proposed is the same for both the 55 mph and 65 mph duty cycles, and
the profile was based on real over-the-road testing the agencies
directed under an agency-funded contract with Southwest Research
Institute.\93\ See Section III.E for more details on development of the
proposed road grade profile. The agencies are continuing to evaluate
[[Page 40188]]
alternate road grade profiles including actual sections of restricted
access highway with road grades that are statistically similar to the
national road grade profile as well as purely synthetic road grade
profiles.\94\ We request comments on the proposed road grade profile,
and would welcome additional statistical evaluations of this road grade
profile and other road grade profiles for comparison. 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.\95\
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\94\ 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.
\95\ 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.''
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We recognize that even with the proposed road grade profile, GEM
may continue to under predict the number of transmission shifts of
vehicles on restricted access highways if the model simulates constant
speeds. We request comment on other ways in which the proposed 55 mph
and 65 mph duty cycles could be enhanced. For example, we request
comment on whether a more aggressive road grade profile would induce a
more realistic and representative number of transmission gear shifts.
We also request comment on whether we should consider varying the
vehicle target speed over the 55 mph and/or 65 mph duty cycles to
simulate human driver behavior reacting to traffic congestion. This
would increase the number of shifts during the 55 mph and 65 mph duty
cycles, though it may be possible for an equivalent effect to be
achieved by assigning a greater weighting to the transient cycle in the
GEM composite test score.
(i) Workday Idle Operation for Vocational Vehicle Certification
In the Phase 1 program, reduction in idle emissions was recognized
only for sleeper cab tractors, and only with respect to hotelling 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,
the agencies are now proposing to recognize in GEM technologies that
reduce workday idle emissions, such as automatic stop-start systems and
automatic transmissions that shift to neutral at idle. Many vocational
vehicle applications operate on patterns implicating workday idle
cycles, and the agencies are proposing test procedures in GEM to
account specifically for these cycles and potential controls. GEM would
recognize these idle controls in two ways. For technologies like
neutral-idle that address idle that occurs during the transient cycle
(representing the type of operation that would occur when the vehicle
is stopped at a stop light), GEM would interpolate lower fuel rates
from the engine map. For technologies like start-stop and auto-shutdown
that eliminate some of the idle that occurs when a vehicle is stopped
or parked, GEM would assign a value of zero fuel rate for what we are
proposing as an ``idle cycle''. This idle cycle would be weighted along
with the 65 mph, 55 mph, and ARB Transient duty cycles according to the
vocational chassis duty cycle weighting factors that we are proposing
for Phase 2. These weighting factors are different for each of the
three vocational chassis speed categories that we are proposing for
Phase 2. While we are not proposing to apply this idle cycle for
tractors, we do request comment on whether or not we should consider a
applying this idle cycle to certain tractor types, like day cabs that
could experience more significant amounts of time stopped or parked as
part of an urban delivery route. We also request comment on whether or
not start-stop or auto-shutdown technologies are being developed for
tractors; especially for Class 7 and 8 day cabs that could experience
more frequent stops and more time parked for deliveries.
(2) Validation of the Proposed GEM
After making the proposed changes to GEM, the agencies validated
the model in comparison to over 130 vehicle variants, consistent with
the recommendation made by the NAS in their Phase 2-First Report.\96\
As is described in Chapter 4 of the Draft RIA, good agreement was
observed between GEM simulations and test data over a wide range of
vehicles. In general, the model simulations agreed with the 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
this rulemaking. This is because all of the numeric standards proposed
for tractors, trailers and vocational chassis are derived from running
GEM first with Phase 1 ``baseline'' technology packages and then with
various candidate Phase 2 technology packages. The differences between
these GEM results are examined to select stringencies. In other words,
the agencies used the same version of GEM to establish the standards as
was used to evaluate baseline performance for this rulemaking.
Therefore, it is most important that GEM accurately reflects relative
changes in emissions for each added technology. For vehicle
certification purposes it is less important that GEM's absolute value
of the fuel consumption or CO2 emissions are accurate
compared to laboratory testing of the same vehicle. The ultimate
purpose of this new version of GEM will be to evaluate changes or
additions in technology, and compliance is demonstrated on a relative
basis to the numerically 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-1.
Chapter 4.3.2 of the draft RIA shows that relative accuracy is even
better, 2-3 percent.
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\96\ National Academy of Science. ``Reducing the Fuel
Consumption and GHG Emissions of Medium- and Heavy-Duty Vehicles,
Phase Two, First Report.'' 2014. Recommendation1.2.
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[[Page 40189]]
[GRAPHIC] [TIFF OMITTED] TP13JY15.000
In addition to this successful validation against experimental
results, the agencies have also initiated a peer review of the proposed
GEM source code. This peer review has been submitted to Docket # EPA-
HQ-OAR-2014-0827.
(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
slightly before comparing to the standard.\97\ For example, a
manufacturer incorporating a launch-assist mild hybrid that was
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 would be reduced to 285 g/ton-mile.
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\97\ 40 CFR 1036.610, 1036.615, 1037.610, and 1037.615
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For Phase 2, the agencies are proposing to largely continue the
existing Phase 1 innovative technology approach. We are also proposing
to create a parallel option specifically related to innovative
powertrain designs. These proposals are discussed below.
(a) Innovative/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, that 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 are proposing to continue this approach for
technologies and concepts with CO2 emissions and fuel
consumption reduction potential that might not be adequately captured
over the proposed Phase 2 duty cycles or are not proposed inputs to
GEM. Note, however, that the agencies are proposing to refer to these
technologies as off-cycle rather than innovative. See Section I 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 and 6x2 axles both have fixed default values,
recognized through a post-simulation adjustment approach discussed in
Chapter 4 of the draft 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 innovative/off-cycle technology credit
provisions would provide the 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 would not be accounted for in GEM
as we are proposing it because we do not have enough information about
these technologies to assign fixed values to them in GEM. Any credits
for these technologies would 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 are proposing to continue to provide
two
[[Page 40190]]
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 would 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, powerpack 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 prior to collecting any test
data. The agencies are also proposing to continue the second path which
includes a public approval process of any testing method which could
have questionable benefits (i.e., an unknown usage rate for a
technology). Furthermore, the agencies are proposing to modify its
provisions to better clarify the documentation required to be submitted
for approval aligning them with provisions in 40 CFR 86.1869-12, and
NHTSA is separately proposing to prohibit credits from technologies
addressed by any of its crash avoidance safety rulemakings (i.e.,
congestion management systems). We welcome recommendations on how to
improve or streamline the off-cycle technology approval process.
Sections III and V describe tractor and vocational vehicle
technologies, respectively, that the agencies anticipate may qualify
for these off-cycle credit provisions.
(b) Powertrain Testing
The agencies are proposing a powertrain test option to allow for a
robust way 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. Powertrain testing and
certification was included as one of the NAS recommendations in the
Phase 2 -First Report.\98\ Some of these improvements are transient
fuel control, engine and transmission control integration and hybrid
systems. To limit the amount of testing, the powertrain would be
divided into families and powertrains would be tested in a limited
number of simulated vehicles that cover the range of vehicles in which
the powertrain would be installed. The powertrain test results would
then be used to override the engine and transmission simulation portion
of GEM.
---------------------------------------------------------------------------
\98\ National Academy of Science. ``Reducing the Fuel
Consumption and GHG Emissions of Medium- and Heavy-Duty Vehicles,
Phase Two, First Report.'' 2014. Recommendation 1.6. However, the
agencies are not proposing to allow for the use of manufacturer
derived and verified models of the powertrain within GEM.
---------------------------------------------------------------------------
The largest proposed change from the Phase 1 powertrain procedure
is that only the advanced powertrain would need to be tested (as
opposed to the Phase 1 requirement where both the advanced powertrain
and the conventional powertrain had to be tested). This change is
possible because the proposed GEM simulation uses the engine fuel map
and torque curve from the actual engine in the vehicle to be certified.
For the powertrain results to be used broadly across all the vehicles
that the powertrain would go into, a matrix of 8 to 9 tests would be
needed per vehicle cycle. These tests would cover the range of
coefficient of drag, coefficient of rolling resistance, vehicle mass
and axle ratio of the vehicles that the powertrain will be installed
in. The main output of this matrix of tests would be fuel mass as a
function of positive work and average transmission output speed over
average vehicle speed. This matrix of test results would then be used
to calculate the vehicle's CO2 emissions by taking the work
per ton-mile from the GEM simulation and multiplying it by the
interpolated work specific fuel mass from the powertrain test and mass
of CO2 to mass of fuel ratio.
Along with proposing changes to how the powertrain results are
used, the agencies are also proposing changes to the procedures that
describe how to carry out a powertrain test. The changes are to give
additional guidance on controlling the temperature of the powertrains
intake-air, oil, coolant, block, head, transmission, battery, and power
electronics so that they are within their expected ranges for normal
operation. The equations that describe the vehicle model are proposed
to be changed to allow for input of the axle's efficiency, driveline
rotational inertia, as well as the mechanical and electrical accessory
loads.
The determine the positive work and average transmission output
speed over average vehicle speed in GEM for the vehicle that will be
certified, the agencies have defined a generic powertrain for each
vehicle category. The agencies are requesting comment on if the generic
powertrains should be modified according to specific aspects of the
actual powertrain. For example using the engine's rated power to scale
the generic engine's torque curve. Similarly, the transmission gear
ratios could be scaled by the axle ratio of the drive axle, to make
sure the generic engine is operated in GEM at the correct engine speed.
(4) Production Vehicle Testing for Comparison to GEM
The agencies are is proposing to require tractor and vocational
vehicle manufacturers to annually chassis test 5 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 would
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 proposing to not apply compliance liability to such
testing. Rather, this testing would 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 would 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 would continue
evaluate in-use compliance by verifying GEM inputs and testing in-use
engines.
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. By proposing
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 is proposing to
structure this pilot-scale program to minimize the costs. First, we are
proposing that this chassis testing would not need to comply with the
same requirements as would apply for official certification testing.
This would allow testing to be performed in developmental test cells
with simple portable analyzers. Second, since the proposed program
would require only 5 tests per year, manufacturers without
[[Page 40191]]
their own chassis testing facility would be able to contract with a
third party to perform the testing. Finally, EPA proposes to apply this
testing to only those manufacturers with annual production in excess of
20,000 vehicles.
We request comment on this proposed testing requirement. Commenters
are encouraged to suggest alternate approaches that could achieve the
assurance that the projected emissions reductions would occur in actual
use.
(5) Use of GEM in Establishing Proposed Numerical Standards
Just like in Phase 1, the agencies are proposing specific numerical
standards against which tractors and vocational vehicles would be
evaluated using GEM (We propose that trailers use a simplified
equation-based approach that was derived from GEM). Although the
proposed standards are performance-based standards, which do not
specifically require the use of any particular technologies, the
agencies established the proposed standards by evaluating specific
vehicle technology packages using a prepublication version of the Phase
2 GEM. This prepublication version was an intermediate version of the
GEM source code, rather than the executable file version of GEM, which
is being docketed for this proposal and is available on EPA's GEM Web
page. Both the GEM source code and the GEM executable file are
generally functionally equivalent.
The agencies determined the proposed numerical standards
essentially by evaluating certain specific technology packages
representing the packages we are projecting to be feasible in the Phase
2 time frame. For each technology package, GEM was used determine a
cycle-weighted g/ton-mile emission rate and a gal/1,000 ton-mile fuel
consumption rate. These GEM results were then essentially averaged
together, weighted by the adoption rates the agencies are projecting
for each technology package and for each model year of standards.
Consider as an oversimplified example of two technology packages for
Class 8 low-roof sleepers cabs: one package that resulted in 60 g/ton-
mile and a second that resulted in 80 g/ton-mile. If we project that
the first package could be applied to 50 percent of the Class 8 low-
roof sleeper cab fleet in MY 2027, and that the rest of the fleet could
do no better than the second technology package, then we would set the
fleet average standard at 70 g/ton-mile (0.5 [middot] 60 + 0.5 [middot]
80 = 70).
Formal external peer review and expert external user review was
then conducted on the version of the GEM source code that was used to
calculate the numerical values of the proposed standards. It was
discovered via these external review processes that the GEM source code
contained some minor software ``bugs.'' These bugs were then corrected
by EPA and the Phase 2 proposed GEM executable file was derived from
this corrected version of the GEM source code. Moreover, we expect to
also receive technical comments during the comment period that could
potentially identify additional GEM software bugs, which would lead EPA
to make additional changes to GEM before the Final Rule. Nevertheless,
EPA has repeated the analysis described above using the corrected
version of the GEM source code that was used to create the proposed GEM
executable file. The results of this analysis are available in the
docket to this proposal.\99\
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\99\ See Memorandum to the Docket ``Numerical Standards for
Tractors, Trailers, and Vocational Vehicles Based on the June 2015
GEM Executable Code.
---------------------------------------------------------------------------
Thus, even without the agencies making any changes in our
projections of technology effectiveness or market adoption rates, it is
likely that further revisions to GEM could result in us finalizing
different numerical values for the standards. It is important to note
that the agencies would not necessarily consider such GEM-based
numerical changes by themselves to be changes in the stringency of the
standards. Rather, we believe that stringency is more appropriately
evaluated in technological terms; namely, by evaluating technology
effectiveness and the market adoption rates of technologies.
Nevertheless, the agencies will docket any updates and supporting
information in a timely manner.
D. Proposed Engine Test Procedures and Engine Standards
For the most part, the proposed Phase 2 engine standards are a
continuation of the Phase 1 program, but with more stringent standards
for compression-ignition engines. Nevertheless, the agencies are
proposing important changes related to the test procedures and
compliance provisions. These changes are described below.
As already discussed in Section II.B. the agencies are proposing a
regulatory structure in which engine technologies are evaluated using
engine-specific test procedures as well using GEM, which is vehicle-
based. We are proposing separate standards for each procedure. The
proposed engine standards described in Section II.D.(2) and the
proposed vehicle standards described in Sections III and V are based on
the same engine technology, which is described in Section II.D.(2). We
request comment on whether the engine and vehicle standards should be
based on the same projected technology. As described below, while the
agencies projected the same engine technology for engine standards and
for vehicle standards, we separately projected the technology that
would be appropriate for:
Gasoline vocational engines and vehicles
Diesel vocational engines and vehicles
Tractor engines and vehicles
Before addressing the engine standards and engine technology in
Section II.D.(2), the agencies describe the test procedures that would
be used to evaluate these technologies in Section II.D.(1) below. We
believe that without first understanding the test procedures, the
numerical engine standards would not have the proper context.
(1) Engine Test Procedures
The Phase 1 engine standards relied on the engine test procedures
specified in 40 CFR part 1065. These procedures were previously used by
EPA to regulate criteria pollutants such as NOX and PM, and
few changes were needed to employ them for purposes of the Phase 1
standards. The agencies are proposing significant changes to two areas
for Phase 2: (1) cycle weighting; and (2) GEM inputs. (Note that EPA is
also proposing some minor changes to the basic part 1065 test
procedures, as described in Section XIII).
The diesel (i.e., compression-ignition) engine test procedure
relies on two separate engine test cycles. The first is the Heavy-duty
Federal Test Procedure (Heavy-duty FTP) that includes transient
operation typified by frequent accelerations and decelerations, similar
to urban or suburban driving. The second is the Supplemental Engine
Test (SET) which includes 13 steady-state test points. The SET was
adopted by EPA to address highway cruise operation and other nominally
steady-state operation. However, it is important to note that it was
intended as a supplemental test cycle and not necessarily to replicate
precisely any specific in-use operation.
The gasoline (i.e., spark-ignition) engine test procedure relies on
a single engine test cycle: a gasoline version of Heavy-duty FTP. The
agencies are not proposing changes to the gasoline engine test
procedures.
It is worth noting that EPA sees great value in using the same test
procedures for measuring GHG emissions as is used
[[Page 40192]]
for measuring criteria pollutants. From the manufacturers' perspective,
using the same procedures minimizes their test burden. However, EPA
sees additional benefits. First, as already noted in Section(b),
requiring engine manufacturers to comply with both NOX and
CO2 standards using the same test procedures discourages
alternate calibrations that would trade NOX emissions
against fuel consumption depending how the engine or vehicle is tested.
Second, this approach leverages the work that went into developing the
criteria pollutant cycles. Taken together, these factors support our
decision to continue to rely on the 40 CFR part 1065 test procedures
with only minor adjustments, such as those described in Section
II.D.(1)(a). Nevertheless, EPA would consider more substantial changes
if they were necessary to incentivize meaningful technology changes,
similar to the changes being made to GEM for Phase 2 to address
additional technologies.
(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 often called the ``A speed'', the intermediate speed is often
called the ``B speed'', and the high speed is often called the ``C
speed.'' As is shown in Table II-1, the SET 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
Total A Speed........................................... 23
Total B Speed........................................... 39
Total C Speed........................................... 23
------------------------------------------------------------------------
The C speed is typically in the range of 1800 rpm for current HHD
engine designs. However, it is becoming less common for engines to
operate often in such a high speed in real world driving condition, and
especially not during cruise vehicle speed between 55 and 65 mph. The
agencies receive confidential business information from a few vehicle
manufacturers that support this observation. Thus, although the current
SET represents highway operation better than the FTP cycle, it is not
an ideal cycle to represent future highway operation. Furthermore,
given the recent trend configure drivetrains to operate engines at
speeds down to a range of 1150-1200 rpm at vehicle speed of 65mph. This
trend would make the typical highway engine speeds even further away
from C speed.
To address this issue, the agencies are proposing new weighting
factors for the Phase 2 GHG and fuel consumption standards. The
proposed new SET mode weightings move most of C weighting to ``A''
speed, as shown in Table II-2. It would also slightly reduce the
weighting factor on the idle speed.
The agencies request comment on the proposed reweighting.
Table II-2--Proposed SET Modes Weighting Factor in Phase 2
------------------------------------------------------------------------
Proposed
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
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) Measuring GEM Engine Inputs
Although GEM does not apply directly to engine certification,
implementing the Phase 2 GEM would impact engine manufacturers. To
recognize the contribution of the engine in GEM the engine fuel map,
full load torque curve and motoring torque curve have to be input into
GEM. To insure the robustness of each of those inputs, a standard
procedure has to be followed. Both the full load and motoring torque
curve procedures are already defined in 40 CFR part 1065 for engine
testing. However, the fuel mapping procedure being proposed would be
new. The agencies have compared the proposed procedure against other
accepted engine mapping procedures with a number of engines at various
labs including EPA's NVFEL, Southwest Research Institute sponsored by
the agencies, and Environment Canada's laboratory.\100\ The proposed
procedure was selected because it proved to be accurate and repeatable,
while limiting the test burden to create the fuel map. This proposed
provision is consistent with NAS's recommendation (3.8).
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\100\ US EPA, ``Technical Research Workshop supporting EPA and
NHTSA Phase 2 Standards for MD/HD Greenhouse Gas and Fuel
Efficiency-- December 10 and 11, 2014,'' http://www.epa.gov/otaq/climate/regs-heavy-duty.htm.
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One important consideration is the need to correct measured fuel
consumption rates for the carbon and energy content of the test fuel.
For engine tests, we propose to continue the Phase 1 approach, which is
specified in 40 CFR 1036.530. We propose a similar approach to GEM fuel
maps in Phase 2.
The agencies are proposing that engine manufacturers must certify
fuel maps as part of their certification to the engine standards, and
that they be required to provide those maps to vehicle manufacturers
beginning with MY 2020.\101\ The one exception to this requirement
would be for cases in which the engine manufacturer certifies based on
powertrain testing, as described in Section (c). In such cases, engine
manufacturers would not be required to also certify the otherwise
applicable fuel maps. We are not proposing that vehicle manufacturers
be allowed to develop their own fuel maps for engines they do not
manufacture.
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\101\ Current normal vehicle manufacturing processes generally
result in many vehicles being produced with prior model year
engines. For example, we expect that some MY 2021 vehicles will be
produced with MY 2020 engines. Thus, we are proposing to require
engine manufacturers to begin providing fuel maps in 2020 so that
vehicle manufacturers could run GEM to certify MY 2021 vehicles with
MY 2020 engines.
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The current engine test procedures also require the development of
regeneration emission rate and frequency factors to account for the
emission changes for criteria pollutants during a regeneration event.
In Phase 1, the agencies adopted provisions to exclude CO2
emissions and fuel consumption due to regeneration. However, for Phase
2, we propose to include CO2 emissions and fuel consumption
due to regeneration over the FTP and RMC cycles as determined using the
infrequently regenerating aftertreatment devices (IRAF) provisions in
40 CFR 1065.680. We do not believe this would significantly impact the
stringency of the proposed standards
[[Page 40193]]
because manufacturers have already made great progress in reducing the
impact of regeneration emissions since 2007. Nevertheless, we believe
it would be prudent to begin accounting for regeneration emissions to
discourage manufacturers from adopting compliance strategies that would
reverse this trend. We request comment on this requirement.
We are not proposing, however, to include fuel consumption due to
regeneration in the creation of the fuel map used in GEM for vehicle
compliance. We believe that the proposed requirements for the duty-
cycle standards, along with market forces that already exist, would
create sufficient incentives to reduce fuel consumption during
regeneration over the entire fuel map.
(c) Engine Test Procedures for Replicating Powertrain Tests
As described in Section II.B.(2)(b), the agencies are proposing a
powertrain test option to quantify the benefits of CO2
reducing powertrain technologies. These powertrain test results would
then be used to override the engine and transmission simulation portion
of GEM. The agencies are proposing to require 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. Subsequent engine testing would be conducted using the normal
part 1065 engine test procedures, and g/hp-hr CO2 results
would be compared to the levels the manufacturer reported during
certification. Such testing would apply for both confirmatory and
selective enforcement audit testing.
Under the proposed regulations, engine manufacturers certifying
powertrain performance (instead of or in addition to the multi-point
fuel maps) would be held responsible for powertrain test results. If
the engine manufacturer does not certify powertrain performance and
instead certifies only the multi-point fuel maps, it would held
responsible for fuel map performance rather than the powertrain test
results. Engine manufacturers certifying both would be responsible for
both.
(d) CO2 From Urea SCR Systems
For diesel engines utilizing urea SCR emission control systems for
NOX reduction, the agencies are proposing to allow
correction of the final engine fuel map and powertrain duty cycle
CO2 emission results to account for the contribution of
CO2 from the urea injected into the exhaust. This urea could
contribute up to 1 percent of the total CO2 emissions from
the engine. Since current urea production methods use gaseous
CO2 captured from the atmosphere (along with
NH3), CO2 from urea consumption does not
represent a net carbon emission. This adjustment is necessary so that
fuel maps developed from CO2 measurements would be
consistent with fuel maps from direct measurements of fuel flow rates.
Thus, we are only proposing to allow 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 would be voluntary for manufacturers,
and expect that some manufacturers may determine that the correction is
too small to be of concern. The agencies will use this correction with
any engines for which the engine manufacturer applied the correction
for its fuel maps during certification.
We are not proposing this correction for engine test results with
respect to the engine CO2 standards. Both the Phase 1
standards and the proposed 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. We
request comment on whether it would be appropriate to allow this
correction for the Phase 2 engine CO2 standards, but also
adjust the standards to reflect the correction. At this time, we
believe that reducing the numerical value of the CO2
standards by 1 g/hp-hr would make the standards consistent with
measurement that are corrected for CO2 from urea. However,
we also request comment on the appropriateness of applying a 2 g/hp-hr
adjustment should we determine it would better reflect the urea
contribution for current engines.
(e) Potential Alternative Certification Approach
In Section II.B.(2)(b), we explained that although GEM does not
apply directly to engine certification, implementing the Phase 2 GEM
would impact engine manufacturers by requiring that they measure engine
fuel maps. In Section II.B.(2), the agencies noted that some
stakeholders may have concerns about the proposed regulatory structure
that would require engine manufacturers to provide detailed fuel
consumption maps for GEM. Given such concerns, the agencies are
requesting comment on an approach that could mitigate the concerns by
allowing both vehicle and engine to use the same driving cycles for
certification. The detailed description of this alternative
certification approach can be seen in the draft RIA. We are requesting
comment on allowing this approach as an option, or as a replacement to
the proposed approach. Commenters supporting this approach should
address possible impacts on the stringency of the proposed standards.
This approach utilizes GEM with a default engine fuel map pre-
defined by the agency to run a number of pre-defined vehicle
configurations over three certification cycles. Engine torque and speed
profile would be obtained from the simulations, and would be used to
specify engine dynamometer commands for engine testing. The results of
this testing would be a CO2 map as function of the
integrated work and the ratio of averaged engine speed (N) to averaged
vehicle speed (V) defined as (N/V) over each certification cycle. In
vehicle certification, vehicle manufacturers would run GEM with the to-
be-certified vehicle configuration and the agency default engine fuel
map separately for each GEM cycle. Applying the total work and N/V
resulted from the GEM simulations to the CO2 map obtained
from engine tests would determine CO2 consumption for
vehicle certification. For engine certification, we are considering
allowing the engine to be certified based on one of the points
conducted during engine alternative CO2 map tests mentioned
above rather than based on the FTP and SET cycle testing.
(2) Proposed Engine Standards for CO2 and Fuel Consumption
We are proposing to maintain 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), but we are proposing changes to how
these standards would apply to natural gas fueled engines. As discussed
in Section II.B.(2)(b), the agencies see important advantages to
maintaining separate engines standards, such as improved compliance
assurance and better control during transient engine operation.
Phase 1 also applied different test cycles depending on whether the
engine is used for tractors, vocational vehicles, or both, and we
propose to continue this as well.\102\ We assume that CO2 at
the
[[Page 40194]]
end of Phase 1 is the baseline of Phase 2. Table II-3 shows the Phase 1
CO2 standards for diesel engines, which serve as the
baseline for our analysis of the proposed Phase 2 standards.
---------------------------------------------------------------------------
\102\ Engine classification is set forth in 40 CFR 1036.801.
Spark-ignition means relating to a gasoline-fueled engine or any
other type of engine with a spark plug (or other sparking device)
and with operating characteristics similar to the Otto combustion
cycle. However, engines that meet the definition of spark-ignition
per 1036.801, but are regulated as diesel engines under 40 CFR part
86 (for criteria pollutants) are treated as compression-ignition
engines for GHG standards. Compression-ignition means relating to a
type of reciprocating, internal-combustion engine that is not a
spark-ignition engine, however, engines that meet the definition of
compression-ignition per 1036.801, but are regulated as Otto-cycle
engines under 40 CFR part 86 are treated as spark-ignition engines
for GHG standards.
Table II-3--Phase 2 Baseline CO2 Performance
(g/bhp-hr)
----------------------------------------------------------------------------------------------------------------
LHDD-FTP MHDD-FTP HHDD-FTP MHDD-SET HHDD-SET
----------------------------------------------------------------------------------------------------------------
576 576 555 487 460
----------------------------------------------------------------------------------------------------------------
The gasoline engine baseline CO2 is 627 (g/bhp-hr). The
agencies used the baseline engine to assess the potential of the
technologies described in the following sections. As described below,
the agencies are proposing new compression-ignition engine standards
for Phase 2 that would require additional reductions in CO2
emissions and fuel consumption beyond the baseline. However, as also
described below in Section II.B.(2)(b), we are not proposing more
stringent CO2 or fuel consumption standards for new heavy-
duty gasoline engines. Note, however, that we are projecting some small
improvement in gasoline engine performance that would be recognized
over the vehicle cycles.
For heavy-heavy-duty diesel engines to be installed in Class 7 and
8 combination tractors, the agencies are proposing the standards shown
in Table II-4.\103\ The proposed MY 2027 standards for engines
installed in tractors would require engine manufacturers to achieve, on
average, a 4.2 percent reduction in fuel consumption and CO2
emissions beyond the Phase 1 standard. We propose to adopt interim
engine standards in MY 2021 and MY 2024 that would require diesel
engine manufacturers to achieve, on average, 1.5 percent and 3.7
percent reductions in fuel consumption and CO2 emissions,
respectively.
---------------------------------------------------------------------------
\103\ The agencies note that the CO2 and fuel
consumption standards for Class 7 and 8 combination tractors do not
cover gasoline or LHDD engines, as those are not used in Class 7 and
8 combination tractors.
Table II-4--Proposed Phase 2 Heavy-Duty Tractor Engine Standards for Engines\104\ Over the SET Cycle
----------------------------------------------------------------------------------------------------------------
Medium heavy- Heavy heavy-
Model year Standard duty diesel duty diesel
----------------------------------------------------------------------------------------------------------------
2021-2023.................................. CO2 (g/bhp-hr)..................... 479 453
Fuel Consumption (gallon/100 bhp- 4.7053 4.4499
hr).
2024-2026.................................. CO2 (g/bhp-hr)..................... 469 443
Fuel Consumption (gallon/100 bhp- 4.6071 4.3517
hr).
2027 and Later............................. CO2 (g/bhp-hr)..................... 466 441
Fuel Consumption (gallon/100 bhp- 4.5776 4.3320
hr).
----------------------------------------------------------------------------------------------------------------
Forcompression-ignition engines fitted into vocational vehicles,
the agencies are proposing MY 2027 standards that would require engine
manufacturers to achieve, on average, a 4.0 percent reduction in fuel
consumption and CO2 emissions beyond the Phase 1 standard.
We propose to adopt interim engine standards in MY 2021 and MY 2024
that would require diesel engine manufacturers to achieve, on average,
2.0 percent and 3.5 percent reductions in fuel consumption and
CO2 emissions, respectively.
---------------------------------------------------------------------------
\104\ Tractor engine standards apply to all engines, without
regard to the engine-cycle classification.
---------------------------------------------------------------------------
Table II-5 presents the CO2 and fuel consumption
standards the agencies propose for compression-ignition engines to be
installed in vocational vehicles. The first set of standards would take
effect with MY 2021, and the second set would take effect with MY 2024.
Table II-5--Proposed Vocational Diesel Engine Standards Over the Heavy-Duty FTP Cycle
----------------------------------------------------------------------------------------------------------------
Light heavy- Medium heavy- Heavy heavy-
Model year Standard duty diesel duty diesel duty diesel
----------------------------------------------------------------------------------------------------------------
2021-2023.......................... CO2 Standard (g/bhp-hr).... 565 565 544
Fuel Consumption Standard 5.5501 5.5501 5.3438
(gallon/100 bhp-hr).
2024-2026.......................... CO2 Standard (g/bhp-hr).... 556 556 536
Fuel Consumption (gallon/ 5.4617 5.4617 5.2652
100 bhp-hr).
2027 and Later..................... CO2 Standard (g/bhp-hr).... 553 553 533
Fuel Consumption (gallon/ 5.4322 5.4322 5.2358
100 bhp-hr).
----------------------------------------------------------------------------------------------------------------
Although both EPA and NHTSA are proposing to begin the Phase 2
engine standards, EPA considered proposing Phase 2 standards that would
begin before MY 2021--that is with less lead time. NHTSA is required by
statute to
[[Page 40195]]
provide four models years of lead time, while EPA is required only to
provide lead time ``necessary to permit the development and application
of the requisite technology'' (CAA Section 202(a)(2)). However, as
noted in Section I, lead time cannot be separated for other relevant
factors such as costs, reliability, and stringency. Proposing these
standards before 2021 could increase the risk of reliability issues in
the early years. Given the limited number of engine models that each
manufacturer produces, managing that many new standards would be
problematic (i.e., new Phase 1 standards in 2017, new Phase 2 EPA
standards in 2018, 2019, or 2020, new standards in 2021, 2024, and
again in 2027). Considering these challenges, EPA determined that
earlier model year standards would not be appropriate, especially given
the value of harmonizing the NHTSA and EPA standards.
(a) Feasibility of the Diesel (Compression-Ignition) Engine Standards
In this section, the agencies discuss our assessment of the
feasibility of the proposed engine standards and the extent to which
they would conform to our respective statutory authority and
responsibilities. More details on the technologies discussed here can
be found in the Draft RIA Chapter 2.3. The feasibility of these
technologies is further discussed in draft RIA Chapter 2.7 for tractor
and vocational vehicle engines. Note also, that the agencies are
considering adopting engine standards with less lead time, and may do
so in the Final Rules. These standards are discussed in Section (e).
Based on the technology analysis described below, the agencies can
project a technology path exists to allow manufacturers to meet the
proposed final Phase 2 standards by 2027, as well as meeting the
intermediate 2021 and 2024 standards. The agencies also project that
manufacturers would be able to meet these standards at a reasonable
cost and without adverse impacts on in-use reliability. Note that the
agencies are still evaluating whether these same standards could be met
sooner, as was analyzed in Alternative 4.
In general, engine performance for CO2 emissions and
fuel consumption can be improved by improving combustion and reducing
energy losses. More specifically, the agencies have identified the
following key areas where fuel efficiency can be improved:
Combustion optimization
Turbocharging system
Engine friction and other parasitic losses
Exhaust aftertreatment
Engine breathing system
Engine downsizing
Waste heat recovery
Transient control for vocational engines only
The agencies are proposing to phase-in the standards from 2021
through 2027 so that manufacturers could gradually introduce these
technologies. For most of these improvements, the agencies project
manufacturers could begin applying them 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 and 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 proposed phase-in schedule would allow
manufacturers to complete these normal processes. As described in
Section (e), the agencies are also requesting comment on whether
manufacturers could complete these development steps more quickly so
that they could meet these standards sooner.
Based on our technology assessment described below, the proposed
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 interim standards would be feasible.
Because this analysis considers reductions from engines meeting the
Phase 1 standards, it assumes manufacturers would continue to include
the same compliance margins as Phase 1. In other words, a manufacturer
currently declaring FCLs 10 g/hp-hr above its measured emission rates
(in order to account for production and test-to-test variability) would
continue to do the same in Phase 2. We request comment on this
assumption.
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.\105\ The engine technologies are discussed
in more detail below. Readers are encouraged to see the draft RIA
Chapter 2 for additional details (and underlying references) about our
feasibility analysis.
---------------------------------------------------------------------------
\105\ 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 would be possible after 2018. For example,
improvements to fuel injection systems would 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 would 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
these technologies, although it would 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 would 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 would reduce
emission over the FTP cycle, and during in-use operation, they would
not reduce emissions over the SET cycle. Thus the agencies are
projecting model based control reductions only for vocational engines.
Although this control concept is not currently available, we project
model based controls achieving a 2 percent improvement in transient
emissions could be in production for some engine models by 2021. By
2027, we project over one-third of all vocational diesel engines would
incorporate model-based controls.
(ii) Turbocharging System
Many advanced turbocharger technologies can be potentially added
[[Page 40196]]
into production in the time frame between 2021 and 2027, and some of
them are already in production, such as mechanical or electric turbo-
compound, more efficient variable geometry turbine, and Detroit
Diesel's patented asymmetric turbocharger. A turbo compound system
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 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 see a fuel efficiency improvement. Light load factor vehicles
can expect little or no benefit. Volvo reports two to four percent fuel
consumption improvement in line haul applications, which could be in
production even by 2020.
(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 valvetrain, and at the piston-cylinder interface.
Taken together such losses represent a large 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 would be possible for some engines by 2021 and all engines by
2027. These reductions would be possible due to improvements in bearing
materials, lubricants, and new accessory designs such as variable-speed
pumps.
(iv) Aftertreatment Optimization
All diesel engines manufacturers are already using diesel
particulate filter (DPF) to reduce particulate matter (PM) and
selective catalytic reduction (SCR) to reduce NOX emissions.
The agencies see two areas in which improved aftertreatment 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. Second, improved designs could reduce
backpressure on the engine to lower pumping losses. The agencies
project the combined impact of such improvements could be 0.6 percent
or more.
(v) Engine Breathing System
Various high efficiency air handling (for both intake air and
exhaust) processes 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 would likely include higher efficiency EGR systems and
intercoolers that reduce frictional pressure loss 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 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.
(vi) Engine Downsizing
Proper sizing of an engine is an important component of optimizing
a vehicle for best fuel consumption. This Phase 2 rule would improve
overall vehicle efficiency, which would result in a drop in the vehicle
power demand for most operation. This drop moves the vehicle operating
points down to a lower load zone, which can move the engine away from
the sweet spot. Engine downsizing combined with engine downspeeding can
allow the engine to move back to higher loads and lower speed zone,
thus achieving slightly better fuel economy 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 normalized based
on the full torque curve. Thus the current engine test is not the best
way to measure the true effectiveness of engine downsizing.
Nevertheless, we project that some small benefit would be measured over
the engine test cycles--perhaps up to a one-quarter percent improvement
in fuel consumption. Note that a bigger benefit would be observed
during GEM simulation, better reflecting real world improvements. This
is factored into the vehicle standards. Thus, the agencies see no
reason to fundamentally revise the engine test procedure at this time.
(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 the waste heat in the
exhaust into usable mechanical power than is used to compress the
intake air. Manufacturers have also been working to use 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 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.
Prior to the Phase 1 Final Rule, the NAS estimated the potential
for WHR to reduce fuel consumption by up to 10 percent.\106\ However,
the agencies do not believe such levels would 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. The agencies believe it is likely a
commercially-viable WHR capable of reducing fuel consumption by over
three percent would be available in the 2021 to 2024 time frame. Cost
and complexity may remain high enough to limit the use of such systems
in this time frame. Moreover, packaging constraints and transient
response challenges would limit the application of WHR systems to line-
haul tractors. Refer to RIA Chapter 2 for a detailed description of
these systems and their applicability. The agencies project that WHR
recovery could be used on 1 percent of all tractor engines by 2021, on
5 percent by 2024, and 15 percent by 2027.
---------------------------------------------------------------------------
\106\ See 2010 NAS Report, page 57.
---------------------------------------------------------------------------
The net cost and effectiveness of future WHR systems would depend
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 would increase the overall cooling system heat rejection
requirement and likely require larger radiators. This could have
negative impacts on cooling fan power
[[Page 40197]]
needs and vehicle aerodynamics. Limited engine compartment space under
hood could leave insufficient room for additional radiator size
increasing. On the other hand, WHR systems that extract heat from the
engine coolant, could actually improve overall cooling.
(viii) Technology Packages for Diesel Engines Installed in Tractors
Typical technology packaged for diesel engines installed in
tractors basically includes most technologies mentioned above, which
includes combustion optimization, turbocharging system, engine friction
and other parasitic losses, exhaust aftertreatment, engine breathing
system, and engine downsizing. Depending on the technology maturity of
WHR and market demands, a small number of tractors could install waste
heat recovery device with Rankine cycle technology. During the
stringency development, the agencies received strong support from
various stakeholders, where they graciously provided many confidential
business information (CBI) including both technology reduction
potentials and estimated market penetrations. Combining those CBI data
with the agencies' engineering judgment, Table II-4 lists those
potential technologies together with the agencies' estimated market
penetration for tractor engine. Those reduction values shown as ``SET
reduction'' are relative to Phase 1 engine, which is shown in Table II-
6. It should be pointed out that the stringency in Table II-6 are
developed based on the proposed SET reweighting factors l shown in
Table II-2. The agencies welcome comment on the market penetration
rates listed below.
Table II-6--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...................... 1.8 5 10 10
WHR (Rankine cycle)............................. 3.6 1 5 15
Parasitic/Friction (Cyl Kits, pumps, FIE), 1.4 45 95 100
lubrication....................................
Aftertreatment (lower dP)....................... 0.6 45 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
Weighted reduction (%).......................... .............. 1.5 3.7 4.2
----------------------------------------------------------------------------------------------------------------
(ix) Technology Packages for Diesel Engines Installed in Vocational
Vehicles
For compression-ignition engines fitted into vocational vehicles,
the agencies are proposing MY 2021 standards that would require engine
manufacturers to achieve, on average, a 2.0 percent reduction in fuel
consumption and CO2 emissions beyond the baseline that is
the Phase 1 standard. Beginning in MY 2024, the agencies are proposing
engine standards that would require diesel engine manufacturers to
achieve, on average, a 3.5 percent reduction in fuel consumption and
CO2 emissions beyond the Phase 1 baseline standards for all
diesel engines including LHD, MHD, and HHD. The agencies are proposing
these standards based on the performance of reduced parasitics and
friction, improved aftertreatment, combustion optimization,
superchargers with VGT and bypass, model-based controls, improved EGR
cooling/transport, and variable valve timing (only in LHD and MHD
engines). The percent reduction for the MY2021, MY2024, and MY2027
standards is based on the combination of technology effectiveness and
market adoption rate projected.
Most of the potential engine related technologies discussed
previously can be applied here. However, neither the waste heat
technologies with the Rankine cycle concept nor turbo-compound would be
applied into vocational sector due to the inefficient use of waste heat
energy with duty cycles and applications with more transient operation
than highway operation. Given the projected cost and complexity of such
systems, we believe that for the Phase 2 time frame manufacturers will
focus their development work on tractor applications (which would have
better payback for operators) rather than vocational applications. In
addition, the benefits due to engine downsizing, which can be seen in
tractor engines, may not be clearly seen in vocational sector, again
because this control technology produces few benefits in transient
operation.
One of the most effective technologies for vocational engines is
the optimization of transient control. It would be expected that more
advanced transient control including different levels of model based
control and neural network control package could provide substantial
benefits in vocational engines due to the extensive transient operation
of these vehicles. For this technology, the use of the FTP cycle would
drive engine manufacturers to invest more in transient control to
improve engine efficiency. Other effective technologies would be
parasitic/friction reduction, as well as improvements to combustion,
air handling systems, turbochargers, and aftertreatment systems. Table
II-7 below lists those potential technologies together with the
agencies' projected market penetration for vocational engines. Again,
similar to tractor engine, the technology reduction and market
penetration are estimated by combining the CBI data together with the
agencies' engineering judgment. Those reduction values shown as ``FTP
reduction'' are relative to a Phase 2 baseline engine, which is shown
in Table II-3. The weighted reductions combine the emission reduction
values weighted by the market penetration of each technology).
[[Page 40198]]
Table II-7--Projected Vocational Engine Technologies and Reduction
----------------------------------------------------------------------------------------------------------------
GHG emissions Market Market Market
Technology reduction 2020- penetration penetration penetration
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 50 90 100
Improved AT..................................... 0.5 50 90 100
Combustion Optimization......................... 1.0 50 90 100
Weighted reduction (%)-L/M/HHD.................. .............. 2.0 3.5 4.0
----------------------------------------------------------------------------------------------------------------
(x) Summary of the Agencies' Analysis of the Feasibility of the
Proposed Diesel Engine Standards
The proposed HD Phase 2 standards are based on adoption rates for
technologies that the agencies regard, subject to consideration of
public comment, as the maximum feasible for purposes of EISA Section
32902(k) and appropriate under CAA Section 202(a) for the reasons given
above. The agencies believe these technologies can be adopted at the
estimated rates for these standards within the lead time provided, as
discussed in draft RIA Chapter 2. 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.
As described in Section II.D.(2)(d) below, the cost of the proposed
standards is estimated to range from $270 to $1,698 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 would be significantly larger than these costs, and the
emission reductions would 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 proposed phase-in 2021 and
2024 MY standards are less stringent and less costly than the proposed
2027 MY standards. Given that the agencies believe the proposed
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), the proposed standards
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
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. The number of such
incomplete SI-powered vehicles is small compared to the number of
completes. 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. The resulting market structure
leads manufacturers of heavy-duty SI engines to have little market
incentive to develop separate technology for vocational engines that
are engine-certified. Moreover, the agencies have not identified a
single SI engine technology that we believe belongs on engine-certified
vocational engines that we do not also project to be used on complete
heavy-duty pickups and vans.
In light of this market structure, when the agencies considered the
feasibility of more stringent Phase 2 standards for SI vocational
engines, we identified the following key questions:
1. Will there be technologies available that could reduce in-use
emissions from vocational SI engines?
2. Would these technologies be applied to complete vehicles and
carried-over to engine certified engines without a new standard?
3. Would these technologies be applied to meet the vehicle-based
standards described in Section V?
4. What are the drawbacks associated with setting a technology-
forcing Phase 2 standard for SI engines?
With respect to the first and second questions, as noted in Chapter
2.6 of the draft RIA, the agencies have identified improved lubricants,
friction reduction, and cylinder deactivation as technologies that
could potentially reduce in-use emissions from vocational engines; and
the agencies have further determined that to the extent these
technologies would be viable for complete vehicles, they would also be
applied to engine-certified engines. Nevertheless, significant
uncertainty remains about how much benefit would be provided by these
technologies. It is possible that the combined impact of these
technologies would be one percent or less. With respect to the third
question, we believe that to the extent these technologies are viable
and effective, they would be applied to meet the vehicle-based
standards for vocational vehicles.
At this time, it appears the fourth question regarding drawbacks is
the most important. The agencies could propose a technology forcing
standard for vocational SI engines based on a projection of each of
these technologies being effective for these engines. However, as
already noted in Section I, the agencies see value in setting the
standards at levels that would not require every projected technology
to work as projected. Effectively requiring technologies to match our
current projections would create the risk that the standards would not
be feasible if even a single one of technologies failed to match our
projections. This risk is amplified for SI engines because of the very
limited product offerings, which provide far fewer opportunities for
averaging than exist for CI engines. Given the relatively small
improvement projected, and the likelihood that most or all of this
improvement would result anyway from the complete pickup and van
standards and the vocational vehicle-based standards, we do not believe
such risk is justified or needed. The approach the agencies are
proposing accomplishes the same objective without the attendant
[[Page 40199]]
potential risk. With this approach, the Phase 1 SI engine standard for
these engines would remain in place, and engine improvements would be
reflected in the stringency of the vehicle standard for the vehicle in
which the engine would be installed. Nevertheless, we request comment
on the merits of adopting a more stringent SI engine standard in the
2024 to 2027 time frame, including comment on technologies, adoption
rates, and effectiveness over the engine cycle that could support
adoption of a more stringent standard. Please see Section V.C of this
preamble for a description of the SI engine technologies that have been
considered in developing the proposed vocational vehicle standards.
Please see Section VI.C of this preamble for a description of the SI
engine technologies that have been considered in developing the
proposed HD pickup truck and van standards.
(c) Engine Improvements Projected for Vehicles over the GEM Duty Cycles
Because we are proposing that tractor and vocational vehicle
manufacturers represent their vehicles' actual engines in GEM for
vehicle certification, the agencies aligned our engine technology
effectiveness assessments for both the separate engine standards and
the tractor and vocational vehicle standards for each of the regulatory
alternatives considered. This was an important step because we are
proposing to recognize the same engine technologies in both the
separate engine standards and the vehicle standards, which 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 and 65 mph steady-state vehicle cycles and the
ARB Transient vehicle cycle. Note that we are also proposing a new
workday idle cycle for vocational vehicles. Each of these duty cycles
emphasizes different engine operating points; therefore, they can each
recognize certain technologies differently.
Our first step in aligning our engine technology assessment at both
the engine and vehicle levels was to start with an analysis of how we
project each technology to impact performance at each of the 13
individual test points of the SET steady-state engine duty cycle. For
example, engine friction reduction technology would be expected to have
the greatest impact at the highest engine speeds, where frictional
energy losses are the greatest. 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 synergies and dis-synergies with respect to engine
efficiency at each of these test points. See RIA Chapter 2 for further
details.
Next we estimated unique brake-specific fuel consumption values for
each of the 13 SET test points for two hypothetical MY2018 tractor
engines that would be compliant with the Phase 1 standards. These were
a 15 liter displacement 455 horsepower engine and an 11 liter 350
horsepower engine. We then added technologies to these engines that we
determined were feasible for MY2021, MY2024, and MY 2027, and we
determined unique improvements at each of the 13 SET points. We then
calculated composite SET values for these hypothetical engines and
determined the SET improvements that we could use to propose more
stringent separate tractor engine standards for MY2021, MY2024, and MY
2027.
To align our engine technology analysis for vehicles to the SET
engine analysis described above, we then fit a surface equation through
each engine's SET points versus engine speed and load to approximate
their analogous fuel maps that would represent these same engines in
GEM. Because the 13 SET test points do not fully cover an engine's wide
range of possible operation, we also determined improvements for an
additional 6 points of engine operation to improve the creation of GEM
fuel maps for these engines. Then for each of these 8 tractor engines
(two each for MY2018, MY2021, MY2024, and MY2027) we ran GEM
simulations to represent low-, mid-, and high-roof sleeper cabs and
low-, mid-, and high-roof day cabs. Class 8 tractors were assumed for
the 455 horsepower engine and Class 7 tractors (day cabs only) were
assumed for the 350 horsepower engine. Each GEM simulation calculated
results for the 55 mph, 65 mph, and ARB Transient cycles, as well as
the composite GEM value associated with each of the tractor types.
After factoring in our Alternative 3 projected market penetrations of
the engine technologies, we then compared the percent improvements that
the same sets of engine technology caused over the separate engines'
SET composites and the various vehicles' GEM composites. Compared to
their respective MY2018 baseline engines, the two engines of different
horsepower showed the same percent improvements. All of the tractor cab
types showed nearly the same relative improvements too. For example,
for the MY2021 Alternative 3 engine technology package in a high roof
sleeper tractor, the SET engine composites showed a 1.5 percent
improvement and the GEM composites a 1.6 percent improvement. For the
MY2024 Alternative 3 engine technology packages, the SET engine
composites showed a 3.7 percent improvement and the GEM composites a
3.7 percent improvement. For MY2027 Alternative 3 engine technology
packages, the SET engine composites showed a 4.2 percent improvement
and the GEM composites a 4.2 percent improvement. We therefore
concluded that tractor engine technologies will improve engines and
tractors proportionally, even though the separate engine and vehicle
certification test procedures have different duty cycles.
We then repeated this same process for the FTP engine transient
cycle and the GEM vocational vehicle types. For the vocational engine
analysis we investigated four engines: 15 liter displacement engine at
455 horsepower rating, 11 liter displacement engine at 345 horsepower
rating, a 7 liter displacement engine at a 200 horsepower rating and a
270 horsepower rating. These engines were then used in GEM over the
light-heavy, medium-heavy, and heavy-heavy vocational vehicle
configurations. Because the technologies were assumed to impact each
point of the FTP in the same way, the results for all engines and
vehicles were 2.0 percent improvement in MY2021, 3.5 percent
improvement in MY2024, and 4.0 percent improvement in MY2027.
Therefore, we arrived at the same conclusion that vocational vehicle
engine technologies are recognized at the same percent improvement over
the FTP as the GEM cycles. We request comment on our approach to arrive
at this conclusion.
(d) Engine Technology Package Costs for Tractor and Vocational Engines
(and Vehicles)
As described in Chapters 2 and 7 of the draft RIA, the agencies
estimated costs for each of the engines technologies discussed here.
All costs
[[Page 40200]]
are presented relative to engines projected to comply with the model
year 2017 standards--i.e., relative to our baseline engines. Note that
we are not presenting any costs for gasoline engines (SI engines)
because we are not proposing to change the standards.
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 proposed standards is achieved
generally by installing new parts and systems purchased from a
supplier. In such a case, the supplier is conducting the bulk of the
research and development on the new parts and systems and including
those costs in the purchase price paid by the original equipment
manufacturer. The indirect costs incurred by the original equipment
manufacturer need not include much cost to cover research and
development since the bulk of that effort is already done. For the MHD
and HHD diesel engine segment, however, the agencies believe 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 draft RIA Chapter 2.
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-8 through Table II-11. 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-12 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-8--Proposed MY2021 Tractor Diesel Engine Component Costs
Inclusive of Indirect Cost Markups and Adoption Rates (2012$)
------------------------------------------------------------------------
Medium HD Heavy HD
------------------------------------------------------------------------
Aftertreatment system (improved $7 $7
effectiveness SCR, dosing, DPF)........
Valve Actuation......................... 82 82
Cylinder Head (flow optimized, increased 3 3
firing pressure, improved thermal
management)............................
Turbocharger (improved efficiency)...... 9 9
Turbo Compounding....................... 50 50
EGR Cooler (improved efficiency)........ 2 2
Water Pump (optimized, variable vane, 43 43
variable speed)........................
Oil Pump (optimized).................... 2 2
Fuel Pump (higher working pressure, 2 2
increased efficiency, improved pressure
regulation)............................
Fuel Rail (higher working pressure)..... 5 5
Fuel Injector (optimized, improved 5 5
multiple event control, higher working
pressure)..............................
Piston (reduced friction skirt, ring and 1 1
pin)...................................
Valvetrain (reduced friction, roller 39 39
tappet)................................
Waste Heat Recovery..................... 105 105
``Right sized'' engine.................. -40 -40
-------------------------------
Total............................... 314 314
------------------------------------------------------------------------
Note: ``Right sized'' diesel engine is a smaller, less costly engine
than the engine it replaces.
Table II-9--Proposed MY2024 Tractor Diesel Engine Component Costs
Inclusive of Indirect Cost Markups and Adoption Rates (2012$)
------------------------------------------------------------------------
Medium HD Heavy HD
------------------------------------------------------------------------
Aftertreatment system (improved $14 $14
effectiveness SCR, dosing, DPF)........
Valve Actuation......................... 166 166
Cylinder Head (flow optimized, increased 6 6
firing pressure, improved thermal
management)............................
Turbocharger (improved efficiency)...... 17 17
Turbo Compounding....................... 92 92
EGR Cooler (improved efficiency)........ 3 3
Water Pump (optimized, variable vane, 84 84
variable speed)........................
Oil Pump (optimized).................... 4 4
Fuel Pump (higher working pressure, 4 4
increased efficiency, improved pressure
regulation)............................
Fuel Rail (higher working pressure)..... 9 9
Fuel Injector (optimized, improved 10 10
multiple event control, higher working
pressure)..............................
Piston (reduced friction skirt, ring and 3 3
pin)...................................
Valvetrain (reduced friction, roller 75 75
tappet)................................
[[Page 40201]]
Waste Heat Recovery..................... 502 502
``Right sized'' engine.................. -85 -85
-------------------------------
Total............................... 904 904
------------------------------------------------------------------------
Note: ``Right sized'' diesel engine is a smaller, less costly engine
than the engine it replaces.
Table II-10--Proposed MY2027 Tractor Diesel Engine Component Costs
Inclusive of Indirect Cost Markups and Adoption Rates (2012$)
------------------------------------------------------------------------
Medium HD Heavy HD
------------------------------------------------------------------------
Aftertreatment system (improved $14 $14
effectiveness SCR, dosing, DPF)........
Valve Actuation......................... 169 169
Cylinder Head (flow optimized, increased 6 6
firing pressure, improved thermal
management)............................
Turbocharger (improved efficiency)...... 17 17
Turbo Compounding....................... 87 87
EGR Cooler (improved efficiency)........ 3 3
Water Pump (optimized, variable vane, 84 84
variable speed)........................
Oil Pump (optimized).................... 4 4
Fuel Pump (higher working pressure, 4 4
increased efficiency, improved pressure
regulation)............................
Fuel Rail (higher working pressure)..... 9 9
Fuel Injector (optimized, improved 10 10
multiple event control, higher working
pressure)..............................
Piston (reduced friction skirt, ring and 3 3
pin)...................................
Valvetrain (reduced friction, roller 75 75
tappet)................................
Waste Heat Recovery..................... 1,340 1,340
``Right sized'' engine.................. -127 -127
-------------------------------
Total................................... 1,698 1,698
------------------------------------------------------------------------
Note: ``Right sized'' diesel engine is a smaller, less costly engine
than the engine it replaces.
(ii) Vocational Diesel Engine Package Costs
Table II-11--Proposed MY2021 Vocational Diesel Engine Component Costs Inclusive of Indirect Cost Markups and
Adoption Rates (2012$)
----------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
----------------------------------------------------------------------------------------------------------------
Aftertreatment system (improved effectiveness SCR, dosing, DPF). $8 $8 $8
Valve Actuation................................................. 91 91 91
Cylinder Head (flow optimized, increased firing pressure, 6 3 3
improved thermal management)...................................
Turbocharger (improved efficiency).............................. 10 10 10
EGR Cooler (improved efficiency)................................ 2 2 2
Water Pump (optimized, variable vane, variable speed)........... 57 57 57
Oil Pump (optimized)............................................ 3 3 3
Fuel Pump (higher working pressure, increased efficiency, 3 3 3
improved pressure regulation)..................................
Fuel Rail (higher working pressure)............................. 7 6 6
Fuel Injector (optimized, improved multiple event control, 8 6 6
higher working pressure).......................................
Piston (reduced friction skirt, ring and pin)................... 1 1 1
Valvetrain (reduced friction, roller tappet).................... 69 52 52
Model Based Controls............................................ 28 28 28
-----------------------------------------------
Total....................................................... 293 270 270
----------------------------------------------------------------------------------------------------------------
Table II-12--Proposed MY2024 Vocational Diesel Engine Component Costs Inclusive of Indirect Cost Markups and
Adoption Rates (2012$)
----------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
----------------------------------------------------------------------------------------------------------------
Aftertreatment system (improved effectiveness SCR, dosing, DPF). $13 $13 $13
Valve Actuation................................................. 157 157 157
Cylinder Head (flow optimized, increased firing pressure, 10 6 6
improved thermal management)...................................
Turbocharger (improved efficiency).............................. 16 16 16
EGR Cooler (improved efficiency)................................ 3 3 3
Water Pump (optimized, variable vane, variable speed)........... 79 79 79
Oil Pump (optimized)............................................ 4 4 4
[[Page 40202]]
Fuel Pump (higher working pressure, increased efficiency, 4 4 4
improved pressure regulation)..................................
Fuel Rail (higher working pressure)............................. 10 9 9
Fuel Injector (optimized, improved multiple event control, 13 10 10
higher working pressure).......................................
Piston (reduced friction skirt, ring and pin)................... 2 2 2
Valvetrain (reduced friction, roller tappet).................... 95 71 71
Model Based Controls............................................ 31 31 31
-----------------------------------------------
Total....................................................... 437 405 405
----------------------------------------------------------------------------------------------------------------
Table II-13--Proposed MY2027 Vocational Diesel Engine Component Costs Inclusive of Indirect Cost Markups and
Adoption Rates (2012$)
----------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
----------------------------------------------------------------------------------------------------------------
Aftertreatment system (improved effectiveness SCR, dosing, DPF). $14 $14 $14
Valve Actuation................................................. 169 169 169
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)........... 84 84 84
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)................... 3 3 3
Valvetrain (reduced friction, roller tappet).................... 100 75 75
Model Based Controls............................................ 39 39 39
-----------------------------------------------
Total....................................................... 471 437 437
----------------------------------------------------------------------------------------------------------------
(e) Feasibility of Phasing In the CO2 and Fuel Consumption
Standards Sooner
The agencies are requesting comment on accelerated standards for
diesel engines that would achieve the same reductions as the proposed
standards, but with less lead time. Table II-14 and Table II-15 below
show a technology path that the agencies project could be used to
achieve the reductions that would be required within the lead time
allowed by the alternative standards. As discussed in Sections I and X,
the agencies are proposing to fully phase in these standards through
2027. The agencies believe that standards that fully phase in through
2024 have the potential to be the maximum feasible and appropriate
option. However, based on the evidence currently before the agencies,
we have outstanding questions (for which we are seeking comment)
regarding relative risks and benefits of that option in the timeframe
envisioned. Commenters are encouraged to address how technologies could
develop if a shorter lead time is selected. In particular, we request
comment on the likelihood that WHR systems would be available for
tractor engines in this time frame, and that WHR systems would achieve
the projected level of reduction and the necessary reliability. We also
request comment on whether it would be possible to apply the model
based controls described in Section II.D.(2) (a)(i) to this many
vocational engines in this time frame.
Table II-14--Projected Tractor Engine Technologies and Reduction for Alternative 4 Standards
----------------------------------------------------------------------------------------------------------------
Market Market
%-Improvements beyond Phase 1, 2018 engine as baseline SET reduction penetration MY penetration MY
(%) 2021 (%) 2024 (%)
----------------------------------------------------------------------------------------------------------------
Turbo compound.................................................. 1.82 5 10
WHR (Rankine cycle)............................................. 3.58 4 15
Parasitics/Friction (Cyl Kits, pumps, FIE), lubrication......... 1.41 60 100
Aftertreatment.................................................. 0.61 60 100
Exhaust Manifold Turbo Efficiency EGR Cooler VVT................ 1.14 60 100
Combustion/FI/Control........................................... 1.11 60 100
Downsizing...................................................... 0.29 20 30
-------------------------------
Market Penetration Weighted Package............................................. 2.1 4.2
----------------------------------------------------------------------------------------------------------------
[[Page 40203]]
Table II-15--Projected Vocational Engine Technologies and Reduction for More Stringent Alternative Standards
----------------------------------------------------------------------------------------------------------------
Market Market
%-Improvements beyond Phase 1, 2018 engine as baseline FTP reduction penetration MY penetration MY
(%) 2021 (%) 2024 (%)
----------------------------------------------------------------------------------------------------------------
Model based control............................................. 2 30 40
Parasitics/Friction............................................. 1.5 70 100
EGR/Air/VVT/Turbo............................................... 1 70 100
Improved AT..................................................... 0.5 70 100
Combustion Optimization......................................... 1 70 100
Weighted reduction (%)-L/MHD/HHD................................ .............. 2.5 4.0
----------------------------------------------------------------------------------------------------------------
The projected HDD engine package costs for both tractors and
vocational engines in MYs 2021 and 2024 under Alternative 4 are shown
in Table II-16. Note that, while the technology application rates in
MY2024 under Alternative 4 are essentially identical to those for
MY2027 under the proposal, the costs are about 5 to 11 percent higher
under Alternative 4 due to learning effects and markup changes that are
estimated to have occurred by MY2027 under Alternative 3. Note also
that the agencies did not include any additional costs for accelerating
technology development or to address potential in-use durability
issues. We request comment on whether such costs would occur if we
finalized this alternative. We also request comment on what steps could
be taken to mitigate such costs.
Table II-16--Expected Package Costs for HD Diesel Engines under Alternative 4 (2012$) \a\
----------------------------------------------------------------------------------------------------------------
LHDD MHDD HHDD
Model year MHDD tractor HHDD tractor vocational vocational vocational
----------------------------------------------------------------------------------------------------------------
2021............................ $656 $656 $372 $345 $345
2024............................ 1,885 1,885 493 457 457
----------------------------------------------------------------------------------------------------------------
Note:
\a\ Costs presented here include application rates.
The agencies' analysis shows that, in the absence of additional
costs for accelerating technology development or to address potential
in-use durability issues, the costs associated with Alternative 4 would
be very similar to those we project for the proposed standards.
Alternative 4 would also have similar payback times and cost-
effectiveness. In other words, Alternative 4 would achieve some
additional reductions for model years 2021 through 2026, with roughly
proportional additional costs unless there were additional costs for
accelerating development or for in-use durability issues. (Note that
reductions and costs for MY 2027 and later would be equivalent for
Alternative 4 and the proposed standards). In order to help make this
assessment, we request comment on the following issues: whether
manufacturers could meet these standards with three years less lead
time, what additional expenses would be incurred to meet these
standards with less lead time, and how reliable would the engines be if
the manufacturers had to bring them to market three years earlier.
(3) Proposed EPA Engine Standards for N2O
EPA is proposing to adopt the MY 2021 N2O engine
standards that were originally proposed for Phase 1. The proposed level
for Phase 2 would be 0.05 g/hp-hr with a default deterioration factor
of 0.01 g/hp-hr, which we believe is technologically feasible because a
number of engines meet this level today. This level of stringency is
consistent with the agency's Phase 1 approach to set ``cap'' standards
for N2O. EPA finalized Phase 1 standards for N2O
as engine-based standards at 0.10 g/hp-hr and a 0.02 g/hp-hr default
deterioration factor because the agency believes that emissions of this
GHG are technologically related solely to the engine, fuel, and
emissions aftertreatment systems, and the agency is not aware of any
influence of vehicle-based technologies on these emissions. We continue
to believe this approach is appropriate, but we believe that more
stringent standards are appropriate to ensure that N2O
emissions do not increase in the future. Note that NHTSA did not adopt
standards for N2O because these emissions do not impact fuel
consumption in a significant way, and is not proposing such standards
for Phase 2 for the same reason.
We are proposing this change at no additional cost and no
additional benefit because manufacturers are generally meeting the
proposed standard today. The purpose of this standard is to prevent
increases in N2O emissions absent this proposed increase in
stringency. We request comment on whether or not we should be
considering additional costs for compliance. Similarly, we request
comment on whether or not we should assume N2O increases in
our ``No Action'' regulatory Alternatives 1a and 1b described in
Section X.
Although N2O is emitted in very small amounts, it can
have a very significant impact on the climate. The global warming
potential (GWP) of one molecule of N2O is 298 times that of
one molecule CO2. Because N2O and CO2
coincidentally have the same molar mass, this means that one gram of
N2O would have the same impact on the climate as 298 grams
of CO2. To further put this into perspective, the difference
between the proposed N2O standard (and deterioration factor)
and the current Phase 1 standard is 0.40 g/hp-hr of N2O
emissions. This is equivalent to 11.92 g/hp-hr CO2. Over the
same certification test cycle (i.e. EPA's HD FTP) the Phase 1 engine
CO2 emissions standard ranges from 460 to 576 g/hp-hr,
depending on the service class of the engine. Therefore, absent today's
proposed action, engine N2O increases equivalent to 2.1 to
2.6 percent of the Phase 1 CO2 standard could occur.
We are proposing this lower cap because we have determined that
[[Page 40204]]
manufacturers generally are meeting this level today but in the future
could increase N2O emissions up to the current Phase 1 cap
standard. Because we do not believe any manufacturer would need to do
anything more than recalibrate their SCR systems to comply, the lead
time being provided would be sufficient. This section later describes
why manufacturers may increase N2O emissions from SCR-
equipped compression-ignition engines in the absence of a lower
N2O cap standard. We request comment on this. We also note
that, as described in Section XI, EPA does not believe there is a
similar opportunity to lower the pickup and van N2O standard
because it was set at a more stringent level in Phase 1.
(a) N2O Formation
N2O formation in modern diesel engines is a by-product
of the SCR process. It is dependent on the SCR catalyst type, the
NO2 to NOX ratio, the level of NOX
reduction required, and the concentration of the reactants in the
system (NH3 to NOX ratio).
Two current engine/aftertreatment designs are driving
N2O emission higher. The first is an increase in engine out
NOX, which puts a higher NOX reduction burden on
the SCR NOX emission control system. The second is an
increase in NO2 formation from the diesel oxidation catalyst
(DOC) located upstream of the passive catalyzed diesel particulate
filter (CDPF). This increase in NO2 serves two functions:
Improving passive CDPF regeneration and optimization of faster SCR
reaction.\107\
---------------------------------------------------------------------------
\107\ Hallstrom, K., Voss, K., and Shah, S., ``The Formation of
N2O on the SCR Catalyst in a Heavy Duty US 2010 Emission
Control System'', SAE Technical Paper 2013-01-2463.
---------------------------------------------------------------------------
There are multiple mechanisms through which N2O can form
in an SCR system:
1. Low temperature formation of N2O over the DOC prior
to the SCR catalyst.
2. Low temperature formation of NH4NO3 with
subsequent decomposition as exhaust temperatures increase, leading to
conversion to N2O over the SCR catalyst.
3. Formation of N2O from NO2 over the SCR
catalyst at NO2 to NO ratios greater than 1:1.
N2O formation increases significantly at 300 to 350 [deg]C.
4. Formation of N2O from NH3 via partial
oxidation over the ammonia slip catalyst.
5. High-temperature N2O formation over the SCR catalyst
due to NH3 oxidation facilitated by high SCR catalyst
surface coverage of NH3.
Thus, as discussed below, control of N2O formation
requires precise optimization of SCR controls including thermal
management and dosing rates, as well as catalyst composition.
(b) N2O Emission Reduction
Through on-engine and reactor bench experiments, this same work
showed that the key to reducing N2O emissions lies in
intelligent emission control system design and operation, namely:
1. Selecting the appropriate DOC and/or CDPF catalyst loadings to
maintain NO2 to NO ratios at or below 1:1.
2. Avoiding high catalyst surface coverage of NH3 though
urea dosing management when the system is in the ideal N2O
formation window.
3. Utilizing thermal management to push the SCR inlet temperature
outside of the N2O low-temperature formation window.
EPA believes that reducing the standard from 0.1 g/hp-hr to 0.05 g/
hp-hr is feasible because most engines have emission rates that would
meet this standard today and the others could meet it with minor
calibration changes at no additional cost. Numerous studies have shown
that diesel engine technologies can be fine-tuned to meet the current
NOX and proposed N2O standards while still
providing passive CDPF regeneration even with earlier generations of
SCR systems. Currently model year 2014 systems have already moved on to
newer generation systems in which the combined CDPF and SCR functions
have been further optimized. The result of this is 18 of 24 engines in
the EPA 2014 certification database emitting N2O at less
than half of the 2014 standard, and thus below the proposed
standard.\108\ Given the discussions in the literature, there are still
additional calibration steps that can be taken to further reduce
N2O emissions for the higher emitters to afford an adequate
compliance margin and room to account for deterioration, without having
an adverse effect on criteria pollutant emissions.
---------------------------------------------------------------------------
\108\ http://www.epa.gov/otaq/crttst.htm.
---------------------------------------------------------------------------
[[Page 40205]]
[GRAPHIC] [TIFF OMITTED] TP13JY15.001
It is important to note, however, that there is a trade off when
trying to optimize SCR systems to achieve peak NOX reduction
efficiencies. When transitioning from a <93 percent efficient MY 2011
system to a 98 percent efficient system of the future, lowering the
N2O cap to 0.05 g/hp-hr would put constraints on the
techniques that can be applied to improve efficiency. If system
designers push the NH3 to NOX ratio higher to try
and achieve the maximum possible NOX reduction, it could
increase N2O emissions. If EPA were to adopt a very low
NOX standard (e.g., 0.02 g/hp-hr) over existing test cycles,
some reductions would be needed throughout the hot portion of the cycle
(although most of the reductions would have to come from the cold start
portion of the test cycle). Thermal management would need to play a key
role, and reducing catalyst light-off time would move the SCR catalyst
through the ammonium nitrate formation and decomposition thermal range
quicker, thus lowering N2O emissions. An increase in the
NH3 to NOX ratio could also further reduce
NOX emissions; however this would also adversely affect
NH3 slip and N2O formation. The inability of
NH3 slip catalysts to handle the increased NH3
load and the EPA NH3 slip limit of 10 ppm would guard
against this NH3 to NOX ratio increase, and thus
subsequent N2O increase.
In summary, EPA believes that engine manufacturers would be able to
respond with highly efficient NOX reducing systems that can
meet the proposed lower N2O cap of 0.05 g/hp-hr with no
additional cost or lead time. When optimizing SCR systems for better
NOX reduction efficiency, that optimization includes
lowering the emissions of undesirable side reactions, including those
that form N2O.
(4) EPA Engine Standards for Methane
EPA is proposing 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 aftertreatment
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 CH4 (or N2O) because these
emissions do not impact fuel consumption in a significant way, and is
not proposing CH4 standards for Phase 2 either.
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 allow us to adopt more
stringent standards at this time. We request comment on this.
(5) Compliance Provisions and Flexibilities for Engine Standards
The agencies are proposing to continue 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 are not proposing to offer any special credits to engine
manufacturers. Except for early credits and advanced technology
credits, the agencies propose to retain all Phase 1 credit
flexibilities and limitations to continue for use in the Phase 2
program.
As discussed below, EPA is proposing to change the useful life for
LHD
[[Page 40206]]
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 would maintain their value in the transition from
Phase 1 to Phase 2, NHTSA and EPA propose an 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 proposed 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. See Sections V and VI for additional discussion of
similar adjustments of vehicle-based credits.
(b) Request for Comment on Changing Global Warming Potential Values in
the Credit Program for CH4 and N2O
The Phase 1 rule included a compliance alternative allowing 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 manufacturers
to average and bank pollutant emissions to comply with the methane and
nitrous oxide requirements after adjusting the CO2 emission
credits based on the relative GHG equivalents. To establish the GHG
equivalents used by the CO2 credits program, the Phase 1
rule incorporated the IPCC Fourth Assessment Report global warming
potential (GWP) values of 25 for CH4 and 298 for
N2O, which are assessed over a 100 year lifetime.
Since the Phase 1 rule was finalized, a new IPCC report has been
released (the Fifth Assessment Report), with new GWP estimates. This is
prompting us to look again at the relative CO2 equivalency
of methane and nitrous oxide and to seek comment on whether the methane
and nitrous oxide GWPs used to establish the GHG equivalency value for
the CO2 Credit program should be updated to those
established by IPCC in its Fifth Assessment Report. The Fifth
Assessment Report provides four 100 year GWPs for methane ranging from
28 to 36 and two 100 year GWPs for nitrous oxide, either 265 or 298.
Therefore, we not only request comment on whether to update the GWP for
methane and nitrous oxide to that of the Fifth Assessment Report, but
also on which value to use from this report.
(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 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 proposing
to change this for Phase 2, but request comment on whether this
allowance is still necessary.
We note that in Phase 1, we applied these standards to only certain
engine configurations in each engine family (often called the parent
rating). We welcome comment on whether the agencies should set Phase 2
CO2 and fuel consumption standards for the other ratings
(often called the child ratings) within an engine family. We are not
proposing specific engine standards for child ratings in Phase 2
because we are proposing to include the actual engine's fuel map in the
vehicle certification. We believe this approach appropriately addresses
our concern that manufacturers control CO2 emissions and
fuel consumption from all in-use engine configurations within an engine
family.
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 described in Section V, EPA is
proposing that the Phase 2 GHG standards for vocational vehicles at or
below 19,500 lbs GVWR apply over the same useful life of 150,000 miles
or 15 years. To be consistent with that proposed change, we are also
proposing that the Phase 2 GHG standards for engines used in vocational
vehicles at or below 19,500 lbs GVWR apply over the same useful life of
150,000 miles or 15 years. NHTSA proposes to use the same useful life
values as EPA for all vocational vehicles.
We are proposing to continue 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 would still be required to meet the standards in actual use
without regard to whether the manufacturer used the assigned DFs. This
allowance is being 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 advance or off-cycle technologies). Upon
request, we could allow the assigned DF for CO2 emissions
from engines including advance 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.
We are also requesting comment on how to apply DFs to low level
measurements where test-to-test variability may be larger than the
actual deterioration rates being measured, such as might occur with
N2O. Should we allow statistical analysis to be used to
identifying trends rather than basing the DF on the highest measured
value? How would we allow this where emission deterioration is not
linear, such as saw-tooth deterioration related to maintenance or other
offsetting emission effects causing emissions to peak before the end of
the useful life? Finally, EPA requests comment on whether a similar
allowance would be appropriate for criteria pollutants as well.
(d) Alternate CO2 Standards
In the Phase 1 rulemaking, the agencies proposed provisions to
allow 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 proposing a similar flexibility in this
rulemaking. We also request comment on whether this allowance should be
eliminated for Phase 1 engines.
[[Page 40207]]
(e) Proposed Approach to Standards and Compliance Provisions for
Natural Gas Engines
EPA is also proposing certain clarifying changes to its rules
regarding classification of natural gas engines. This proposal 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 our nonroad programs, in which we divide
engines into compression-ignition and spark-ignition technologies based
only on the operating characteristics of the engines.\109\ However, the
Phase 1 rule included a provision allowing us to continue with the
historic approach on an interim basis.
---------------------------------------------------------------------------
\109\ 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 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 would be used in applications mostly served by
diesel engines today. We are therefore proposing 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. Under the proposed clarifying
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. 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.
Table II-17 describes the provisions that would apply differently
for compression-ignition and spark-ignition engines:
Table II-17--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, paragraph Appendix I,
(f)(2) cycle; divide paragraph
by 1.12 to de- (f)(1) cycle.
normalize.
Ramped-modal test (SET)....... yes................... no.
NTE standards................. yes................... no.
Smoke standard................ yes................... no.
Manufacturer-run in-use yes................... no.
testing.
ABT--pollutants............... NOX, PM............... NOX, NMHC.
ABT-- transient conversion 6.5................... 6.3.
factor.
ABT--averaging set............ Separate averaging One averaging
sets for light, set for all SI
medium, and heavy engines.
HDDE.
Useful life................... 110,000 miles for 110,000 miles
light HDDE.
185,000 miles for
medium HDDE..
435,000 miles for
heavy HDDE..
Warranty...................... 50,000 miles for light 50,000 miles.
HDDE.
100,000 miles for
medium HDDE..
100,000 miles for
heavy HDDE..
Detailed AECD description..... yes................... no.
Test engine selection......... highest injected fuel most likely to
volume. exceed emission
standards.
------------------------------------------------------------------------
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 would
change from compression-ignition to spark-ignition under the proposed
clarified approach. Nonetheless, because these proposed standards
implicate rules for criteria pollutants (as well as GHGs), the
provisions of CAA section 202(a)(3)(C) apply (for the criteria
pollutants), notably the requirement of four years lead time. We are
therefore proposing to continue to apply the existing interim provision
through model year 2020.\110\
[[Page 40208]]
Starting in model year 2021, all the provisions would apply as
described above. Manufacturers would 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.
---------------------------------------------------------------------------
\110\ 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
emission discussed in the following subsection.
---------------------------------------------------------------------------
We are also proposing that these provisions would 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 19,500 lbs GVWR, EPA believes any
alternative-fueled vehicles in this weight range would be competing
primarily with diesel vehicles and should be subject to the same
requirements as them. We request comment on all aspects of classifying
natural-gas and other engines for purposes of applying emission
standards. See Sections XI and XII for additional discussion of natural
gas fueled engines.
(f) Crankcase Emissions From Natural Gas Engines
EPA is proposing one fuel-specific provision for natural gas
engines, likewise applicable to all pollutant emissions, both GHGs and
criteria pollutant emissions. Note that we are also proposing other
vehicle-level emissions controls for the natural gas storage tanks and
refueling connections. These are presented in Section XIII.
EPA is proposing 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. This has 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
aftercooler heat exchangers. In contrast, historically EPA has mandated
closed crankcase technology on all gasoline fueled engines and all
natural gas spark-ignition engines.\111\ The inherently low PM
emissions from these engines posed no technical barrier to a closed
crankcase mandate. Because natural gas-fueled compression ignition
engines also have inherently low PM emissions, there is no
technological limitation that would prevent manufacturers from closing
the crankcase and recirculating all crankcase gases into a natural gas-
fueled compression ignition engine's air intake. We are requesting
comment on the costs and effectiveness of technologies that we have
identified to comply with these provisions. In addition, EPA is
proposing that this revised standard not take effect until the 2021
model year, consistent with the requirement of section 202(a)(3)(C) to
provide four years lead time.
---------------------------------------------------------------------------
\111\ See 40 CFR 86.008-10(c).
---------------------------------------------------------------------------
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 two-thirds, due to their large payloads,
their high annual miles traveled, and their major role in national
freight transport.\112\ These vehicles consist of a cab and engine
(tractor or combination tractor) and a trailer.\113\ In general,
reducing GHG emissions and fuel consumption for these vehicles would
involve improvements to all aspects of the vehicle.
---------------------------------------------------------------------------
\112\ 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.
\113\ ``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 proposed
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
proposing 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.
[[Page 40209]]
[GRAPHIC] [TIFF OMITTED] TP13JY15.002
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.
---------------------------------------------------------------------------
\114\ 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 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.\115\ 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.
---------------------------------------------------------------------------
\115\ Manufacturers may voluntarily opt-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 would 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,
[[Page 40210]]
a simulation tool is the preferred approach for HD tractor compliance
because of the extremely large number of vehicle configurations.\116\
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.
---------------------------------------------------------------------------
\116\ 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, 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.
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 Proposed Phase 2 Tractor Program
The proposed HD Phase 2 program is similar in many respects to the
Phase 1 approach. The agencies are proposing to maintain 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. The one area where the agencies are
proposing to change 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 propose to include the
powertrain as part of the technology basis for the tractor and
vocational vehicle standards in Phase 2, we are proposing to classify a
certain set of these vocational tractors as heavy-haul tractors and
subject 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.\117\
---------------------------------------------------------------------------
\117\ See 76 FR 57138 for Phase 1 discussion. See 40 CFR
1037.801 for proposed Phase 2 heavy-haul tractor regulatory
definition.
---------------------------------------------------------------------------
The agencies propose to also retain much of the certification and
compliance structure developed in Phase 1 but to simplify end of the
year reporting. The agencies propose that the Phase 2 tractor
CO2 emissions and fuel consumption standards, as in Phase 1,
be aligned.\118\ The agencies also propose to continue to have separate
engine and vehicle standards to drive technology improvements in both
areas. The reasoning behind the proposal to maintain separate standards
is discussed above in Section II.B.2. As in Phase 1, the agencies
propose to certify tractors using the GEM simulation tool and to
require manufacturers to 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 proposed 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.
The agencies required two reports for the initial program to help
manufacturers become familiar with the reporting process. For the Phase
2 program, the agencies propose that manufacturers would only be
required to submit one end of the year report, which would simplify
reporting.
---------------------------------------------------------------------------
\118\ 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 proposed 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 proposed HD Phase 2 standards seek additional
reductions through increased use of existing technologies and the
development and deployment of more advanced technologies. To evaluate
the effectiveness of a more comprehensive set of technologies, the
agencies propose several additional inputs to GEM. The proposed 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 would now be required. Manufacturers would
conduct component testing to obtain the values for these technologies
(should they choose to use them), which testing values would then be
input into the GEM simulation tool. See Section III.D.2 below. To
effectively assess performance of the technologies, the agencies also
propose to change some aspects of the drive cycle used in certification
through the addition of road grade. To reflect the existing trailer
market, the agencies are proposing to refine the aerodynamic test
procedure for high roof cabs by adding some aerodynamic improving
devices to the reference trailer (used for determining the relative
aerodynamic performance of the tractor). The agencies also propose to
change the aerodynamic certification test procedure to capture
aerodynamic improvement of trailers and the impact of wind on tractor
aerodynamic performance. The agencies are also proposing to change some
of the interim provisions developed in Phase 1 to reflect the maturity
of the program and
[[Page 40211]]
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. Proposed Phase 2 Tractor Standards
EPA is proposing CO2 standards and NHTSA is proposing
fuel consumption standards for new Class 7 and 8 combination tractors.
In addition, EPA is proposing to maintain the HFC standards for the air
conditioning systems that were adopted in Phase 1. EPA is also seeking
comment on new standards to further control emissions of particulate
matter (PM) from auxiliary power units (APU) installed in tractors that
would prevent an unintended consequence of increasing PM emissions from
tractors during long duration idling.
This section describes in detail the proposed standards. In
addition to describing the proposed alternative (``Alternative 3''), in
Section III.D.2.f we also detail another alternative (``Alternative
4''). Alternative 4 provides less lead time than the proposed set of
standards but may provide more net benefits in the form of greater
emission and fuel consumption reductions (with somewhat higher costs)
in the early years of the program. The agencies believe Alternative 4
has the potential to be maximum feasible and appropriate as discussed
later in this section.
The agencies welcome comment on all aspects of the proposed
standards and the alternative standards described in Section III.D.2.f.
Commenters are encouraged to address all aspects of feasibility
analysis, including costs, the likelihood of developing the technology
to achieve sufficient relaibility within the proposed and alternative
lead-times, and the extent to which the market could utilize the
technology. It would be helpful if comments addressed these issues
separately for each type of technology.
(1) Proposed Fuel Consumption and CO2 Standards
The proposed fuel consumption and CO2 standards for the
tractor cab are shown below in Table III-1. These proposed standards
would achieve reductions of up to 24 percent compared to the 2017 model
year baseline level when fully phased in beginning in the 2027 MY.\119\
The proposed 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 propose to require any Class 7 tractor,
regardless of cab configuration, meet the standards described as
``Class 7 Day Cab.'' We welcome comment on this proposed approach.
---------------------------------------------------------------------------
\119\ 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 draft RIA Chapter 2, indicate
that these proposed standards, if finalized, would be maximum feasible
(within the meaning of 49 U.S.C. Section 32902 (k)) and would be
appropriate under each agency's respective statutory authorities. The
agencies solicit comment on all aspects of these analyses.
Table III-1--Proposed Phase 2 Heavy-Duty Combination Tractor EPA Emissions Standards (g CO2/ton-mile) and NHTSA
Fuel Consumption Standards (gal/1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Day cab Sleeper cab
-----------------------------------------------
Class 7 Class 8 Class 8
----------------------------------------------------------------------------------------------------------------
2021 Model Year CO2 Grams per Ton-Mile..........................................................................
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 97 78 70
Mid Roof........................................................ 107 84 78
High Roof....................................................... 109 86 77
----------------------------------------------------------------------------------------------------------------
2021 Model Year Gallons of Fuel per 1,000 Ton-Mile..............................................................
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 9.5285 7.6621 6.8762
Mid Roof........................................................ 10.5108 8.2515 7.6621
High Roof....................................................... 10.7073 8.4479 7.5639
----------------------------------------------------------------------------------------------------------------
2024 Model Year CO2 Grams per Ton-Mile..........................................................................
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 90 72 64
Mid Roof........................................................ 100 78 71
High Roof....................................................... 101 79 70
----------------------------------------------------------------------------------------------------------------
2024 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile....................................................
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 8.8409 7.0727 6.2868
Mid Roof........................................................ 9.8232 7.6621 6.9745
High Roof....................................................... 9.9214 7.7603 6.8762
----------------------------------------------------------------------------------------------------------------
2027 Model Year CO2 Grams per Ton-Mile..........................................................................
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 87 70 62
Mid Roof........................................................ 96 76 69
High Roof....................................................... 96 76 67
----------------------------------------------------------------------------------------------------------------
2027 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile....................................................
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 8.5462 6.8762 6.0904
Mid Roof........................................................ 9.4303 7.4656 6.7780
[[Page 40212]]
High Roof....................................................... 9.4303 7.4656 6.5815
----------------------------------------------------------------------------------------------------------------
It should be noted that the proposed HD Phase 2 CO2 and
fuel consumptions standards are not directly comparable to the Phase 1
standards. This is because the agencies are proposing several test
procedure changes to more accurately reflect real world operation of
tractors. These changes will result in the following differences.
First, the same vehicle evaluated using the proposed 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 proposed changes in the evaluation of aerodynamics. In the real
world, vehicles are exposed to wind 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-trailers, the agencies are proposing to input
into Phase 2 GEM the 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 proposed 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 proposing 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 proposed
CO2 and fuel consumption standards, and have identified
means of achieving the proposed standards that are technically feasible
in the lead time afforded, economically practicable and cost-effective.
EPA and NHTSA present the estimated costs and benefits of the proposed
standards in Section III.D.2. In developing the proposed standards for
Class 7 and 8 tractors, the agencies have evaluated the following:
the current levels of emissions and fuel consumption
the kinds 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 proposed 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 draft RIA Chapter 2.4. 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 proposed Class 7 and 8 combination tractor
standards in draft RIA Chapter 2.8 and 2.12, explaining as well the
basis for the agencies' proposed stringency level.
As explained below in Section III.D, EPA and NHTSA have determined
that there would 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 proposing for Phase 2 that manufacturers may 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 24 percent reduction
in CO2 emissions and fuel consumption over a 2017 model year
baseline tractor, as detailed in Section III.D.2. In considering the
feasibility of vehicles to comply with the proposed 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. 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 height. In the case of aerodynamic components, we
project no change in performance through the regulatory life of the
vehicle since there is essentially no change in their physical form as
vehicles age. Similarly, weight reduction elements such as aluminum
wheels are (evidently) not projected to increase in mass through time,
and hence, we can conclude will not deteriorate with regard to
CO2 performance in-use. Given all of these considerations,
the agencies are confident in projecting that the tractor standards
being proposed today would be technically feasible throughout the
regulatory useful life of the program.
(2) Proposed Non-CO2 GHG Standards for Tractors
EPA is also proposing standards to control non-CO2 GHG
emissions from Class 7 and 8 combination tractors.
(a) N2O and CH4 Emissions
The proposed heavy-duty engine standards for both N2O
and CH4 as well as details of the proposed standards are
included in the discussion in Section II.D.3 and II.D.4. No additional
controls for N2O or CH4 emissions beyond those in
the proposed HD Phase 2 engine standards are being considered 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
[[Page 40213]]
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
proposes to address HFC emissions by 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.
In addition, there currently are not any low GWP refrigerants approved
for the heavy-duty vehicle sector. Without an alternative refrigerant
approved for this sector, it is challenging to demonstrate feasibility
to reduce the amount of leakage allowed under the HFC leakage standard.
Please see Section I.F(1)(b) for a discussion related to alternative
refrigerants.
(3) PM Emissions From APUs
Auxiliary power units (APUs) can be used in lieu of operating the
main engine during extended idle operations to provide climate control
and power to the driver. APUs can reduce fuel consumption,
NOX, HC, CH4, and CO2 emissions when
compared to main engine idling.\120\ 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. Therefore, EPA is seeking comment on the need
and appropriateness to further reduce PM emissions from APUs.
---------------------------------------------------------------------------
\120\ 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.
---------------------------------------------------------------------------
EPA conducted an analysis evaluating the potential impact on PM
emissions due to an increase in APU adoption rates using MOVES. In this
analysis, EPA assumed that these APUs emit criteria pollutants at the
level of the EPA standard for this type of non-road diesel engines.
Under this assumption, an APU would emit 1.8 grams PM per hour,
assuming an extended idle load demand of 4.5 kW (6 hp).\121\ However, a
2010 model year or newer tractor that uses its main engine to idle
emits approximately 0.35 grams PM per hour.\122\ The results from these
MOVES runs are shown below in Table III-2. These results show that an
increase in use of APUs could lead to an overall increase in PM
emissions if left uncontrolled. Column three labeled ``Proposed 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.
---------------------------------------------------------------------------
\121\ Tier 4, less-than-8 kW nonroad compression-ignition engine
exhaust emissions standards assumed for APUs: http://www.epa.gov/otaq/standards/nonroad/nonroadci.htm.
\122\ U.S. EPA. MOVES2014 Reports. Last accessed on May 1, 2015
at http://www.epa.gov/otaq/models/moves/moves-reports.htm.
Table III-2--Projected Impact of Increased Adoption of APUs in
Phase 2
------------------------------------------------------------------------
Proposed program
Baseline HD vehicle PM2.5\a\ emission
CY PM2.5 emissions impact without
(tons) further PM control
(tons)
------------------------------------------------------------------------
2035.......................... 21,452 1,631
2050.......................... 24,675 2,257
------------------------------------------------------------------------
Note:
\a\ Positive numbers mean emissions would increase from baseline to
control case. PM2.5 from tire wear and brake wear are included.
Since January 1, 2008, California ARB has prohibited the idling of
sleeper cab tractors during periods of sleep and rest.\123\ The
regulations apply additional requirements to diesel-fueled APUs on
tractors equipped with 2007 model year or newer 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.\124\ Currently ARB includes 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.
---------------------------------------------------------------------------
\123\ 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.
\124\ California Air Resources Board. Sec. 2485(c)(3)(A)(1).
---------------------------------------------------------------------------
EPA conducted an evaluation of the impact of potentially requiring
further PM control from APUs nationwide. As shown in Table III-2, EPA
projects that the HD Phase 2 program as proposed (without additional PM
controls) would increase PM2.5 emissions by 1,631 tons in
2035 and 2,257 tons in 2050. The annual impact of a program to further
control PM could lead to a reduction of PM2.5 emissions
nationwide by 3,084 tons in 2035 and by 4,344 tons in 2050, as shown in
Table III-3 the column labeled ``Net Impact on National
PM2.5 Emission with Further PM Control of APUs (tons).''
[[Page 40214]]
Table III-3--Projected Impact of Further Control on PM2.5 Emissions \a\
----------------------------------------------------------------------------------------------------------------
Proposed HD phase 2 Proposed HD Phase 2 Net impact on
Baseline national program national Program National national PM2.5
CY heavy-duty vehicle PM2.5 Emissions PM2.5 emissions emission with
PM2.5 emissions without Further PM with further pm further PM control
(tons) Control (tons) control (tons) of APUs (tons)
----------------------------------------------------------------------------------------------------------------
2035........................ 21,452 23,083 19,999 -3,084
2050........................ 24,675 26,932 22,588 -4,344
----------------------------------------------------------------------------------------------------------------
Note:
\a\ PM2.5 from tire wear and brake wear are included.
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.\125\ The costs
of a DPF for an APU that provides less than 25 horsepower would be less
than the projected cost of a 150 HP engine because the filter volume is
in general proportional to the engine-out emissions and exhaust flow
rate. Proventia is charging customers $2,240 for electronically heated
DPF.\126\ EPA welcomes comments on cost estimates associated with DPF
systems for APUs.
---------------------------------------------------------------------------
\125\ 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.
\126\ Proventia. Tripac Filter Kits. Last accessed on October
21, 2014 at http://www.proventiafilters.com/purchase.html.
---------------------------------------------------------------------------
EPA requests comments on the technical feasibility of diesel
particulate filters ability to reduce PM emissions by 85 percent from
non-road engines used to power APUs. EPA also requests comments on
whether the technology costs outlined above are accurate, and if so, if
projected reductions are appropriate taking into account cost, noise,
safety, and energy factors. See CAA section 213(a)(4).
(4) Proposed Exclusions From the Phase 2 Tractor Standards
As noted above, in Phase 1, the agencies adopted provisions to
allow tractor manufacturers to reclassify certain tractors as
vocational vehicles.\127\ The agencies propose in Phase 2 to continue
to allow manufacturers to exclude certain vocational-types of tractors
from the combination tractor standards and instead be subject to the
vocational vehicle standards. However, the agencies propose to set
unique standards for tractors used in heavy haul applications in Phase
2. Details regarding the proposed heavy-haul standards are included
below in Section II.D.3.
---------------------------------------------------------------------------
\127\ See 40 CFR 1037.630.
---------------------------------------------------------------------------
During the development of Phase 1, the agencies received multiple
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 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. Consistent with the agencies' approach in Phase 1, the
agencies agree 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.\128\ A vehicle determined by the manufacturer to be a HHD
vocational tractor would 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 would be regulated as a MHD vocational vehicle. Specifically,
the agencies are proposing to change the provisions in EPA's 40 CFR
1037.630 and NHTSA's regulation at 49 CFR 523.2 and only allow the
following two types of vocational tractors to be eligible for
reclassification by the manufacturer:
---------------------------------------------------------------------------
\128\ 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.
---------------------------------------------------------------------------
(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.\129\
---------------------------------------------------------------------------
\129\ See existing 40 CFR 1037.630(a)(1)(i) through (iii).
---------------------------------------------------------------------------
Because the difference between some vocational tractors and line-
haul tractors is potentially somewhat subjective, we are also proposing
to continue to limit the use of this provision to a rolling three year
sales limit of 21,000 vocational tractors per manufacturer consistent
with past production volumes of such vehicles. We propose 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 volumetric 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
welcome comment on whether the proposed sales volume limit is set at an
appropriate level looking into the future.
Also in Phase 1, EPA determined that manufacturers that met the
small business criteria specified in 13 CFR 121.201 for ``Heavy Duty
Truck Manufacturing'' were not subject to the greenhouse gas emissions
standards of 40 CFR 1037.106.\130\ The regulations required that
qualifying manufacturers must notify the Designated Compliance Officer
each model year before introducing the vehicles into commerce. The
manufacturers are also required to label the vehicles to identify them
as excluded vehicles. EPA and NHTSA are seeking comments on eliminating
this provision for tractor manufacturers in the Phase 2 program. The
agencies are aware of two second stage manufacturers building custom
sleeper cab tractors. 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.\131\ Or the
[[Page 40215]]
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. We welcome comments on
these considerations.
---------------------------------------------------------------------------
\130\ See 40 CFR 1037.150(c).
\131\ 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.
---------------------------------------------------------------------------
EPA is proposing to not exempt glider kits from the Phase 2 GHG
emission standards.\132\ Gliders and glider kits are exempt from
NHTSA's Phase 1 fuel consumption standards. For EPA purposes, the
CO2 provisions of Phase 1 exempted gliders and glider kits
produced by small businesses but did not include such a blanket
exemption for other glider kits.\133\ Thus, some gliders and glider
kits are already subject to the requirement to obtain a vehicle
certificate prior to introduction into commerce as a new vehicle.
However, the agencies believe glider manufacturers may not understand
how these regulations apply to them, resulting in a number of
uncertified vehicles.
---------------------------------------------------------------------------
\132\ Glider vehicles are new vehicles produced to accept
rebuilt engines (or other used engines) along with used axles and/or
transmissions. The common commercial term ``glider kit'' is used
here primarily to refer to an assemblage of parts into which the
used/rebuilt engine is installed.
\133\ Rebuilt engines used in glider vehicles are subject to EPA
criteria pollutant emission standards applicable for the model year
of the engine. See 40 CFR 86.004-40 for requirements that apply for
engine rebuilding. Under existing regulations, engines that remain
in their certified configuration after rebuilding may continue to be
used.
---------------------------------------------------------------------------
EPA is concerned about adverse economic impacts on small businesses
that assemble glider kits and glider vehicles. Therefore, EPA is
proposing an option that would grandfather existing small businesses,
but cap annual production based on their recent sales. EPA requests
comment on whether any special provisions would be needed to
accommodate glider kits. See Section XIV for additional discussion of
the proposed requirements for glider vehicles.
Similarly, NHTSA is considering including glider vehicles under its
Phase 2 program. The agencies request comment on their respective
considerations.
We believe that the agencies potentially having different policies
for glider kits and glider vehicles under the Phase 2 program would not
result in problematic disharmony between the NHTSA and EPA programs,
because of the small number of vehicles that would be involved. EPA
believes that its proposed changes would result in the glider market
returning to the pre-2007 levels, in which fewer than 1,000 glider
vehicles would be produced in most years. Only non-exempt glider
vehicles would 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 would be few enough not to
result in any meaningful disharmony between the two agencies.
With regard to NHTSA's safety authority over gliders, the agency
notes that it has become increasingly aware of potential noncompliance
with its regulations applicable to gliders. NHTSA has learned of
manufacturers who 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 consider amending 49 CFR
571.7(e) and related regulations as necessary. NHTSA believes
manufacturers may not be using this regulation as originally intended.
(5) In-Use Standards
Section 202(a)(1) of the CAA specifies that EPA is to propose
emissions standards that are applicable for the useful life of the
vehicle. The in-use Phase 2 standards that EPA is proposing would apply
to individual vehicles and engines, just as EPA adopted for Phase 1.
NHTSA is also proposing to use the same useful life mileage and years
as EPA for Phase 2.
EPA is also not proposing any changes to provisions requiring 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-4. 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 propose no changes to the
regulations describing compliance with GHG pollutants with regards to
deterioration. See 40 CFR 1037.241. We welcome comments that highlight
a need to change this approach.
Table III-4--Tractor Useful Life Periods
------------------------------------------------------------------------
Years Miles
------------------------------------------------------------------------
Class 7 Tractors.................................. 10 185,000
Class 8 Tractors.................................. 10 435,000
------------------------------------------------------------------------
D. Feasibility of the Proposed Tractor Standards
This section describes the agencies' technical feasibility and cost
analysis in greater detail. Further detail on all of these technologies
can be found in the draft 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 proposing to
continue the Phase 1 provisions that treat vocational tractors as
vocational vehicles instead of as combination tractors, as noted in
Section III.C. The focus of this section is on the feasibility of the
proposed 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. The primary sources of information were the
Southwest Research Institute evaluation of heavy-duty vehicle fuel
efficiency and costs for NHTSA,\134\ the Department of Energy's
SuperTruck Program,\135\ 2010 National Academy of Sciences report of
Technologies and Approaches to Reducing the Fuel Consumption of Medium-
and Heavy-Duty Vehicles,\136\ TIAX's assessment of technologies to
support the NAS panel report,\137\ 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),\138\ and the technology cost analysis
conducted by ICF for EPA.\139\
[[Page 40216]]
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\134\ 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.
\135\ U.S. Department of Energy. SuperTruck Initiative.
Information available at http://energy.gov/eere/vehicles/vehicle-technologies-office.
\136\ 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.
\137\ TIAX, LLC. ``Assessment of Fuel Economy Technologies for
Medium- and Heavy-Duty Vehicles,'' Final Report to National Academy
of Sciences, November 19, 2009.
\138\ NESCCAF, ICCT, Southwest Research Institute, and TIAX.
Reducing Heavy-Duty Long Haul Combination Truck Fuel Consumption and
CO2 Emissions. October 2009.
\139\ ICF International. ``Investigation of Costs for Strategies
to Reduce Greenhouse Gas Emissions for Heavy-Duty On-Road
Vehicles.'' July 2010. Docket Number EPA-HQ-OAR-2010-0162-0283.
---------------------------------------------------------------------------
(1) What technologies did the agencies consider to reduce the
CO2 emissions and fuel consumption of combination tractors?
Manufacturers can reduce CO2 emissions and fuel
consumption of combination tractors through use of many technologies,
including engine, drivetrain, aerodynamic, tire, extended idle, and
weight reduction technologies. The agencies' determination of the
feasibility of the proposed HD Phase 2 standards is based on our
projection of the use of these technologies and an 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 proposed standards on their use for the model years
covered by this proposal, for various reasons discussed below.
In this section we discuss generally the tractor and engine
technologies that the agencies considered to improve performance of
heavy-duty tractors, while Section III.D.2 discusses the baseline
tractor definition and technology packages the agencies used to
determine the proposed standard levels.
Engine technologies: As discussed in Section II.D above, there are
several engine technologies that can reduce fuel consumption of heavy-
duty tractors. These technologies include friction reduction,
combustion system optimization, and Rankine cycle. These engine
technologies would impact the Phase 2 vehicle results because the
agencies propose that the manufacturers enter a fuel map into GEM.
Aerodynamic technologies: There are opportunities to reduce
aerodynamic drag from the tractor, 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 vehicles that achieve a 50 percent improvement
in freight efficiency. This SuperTruck program has led to significant
advancements in the aerodynamics of combination tractor-trailers. The
manufacturers' SuperTruck demonstration vehicles are achieving
approximately 7 percent freight efficiency improvements over a 2010 MY
baseline vehicle due to improvements in tractor aerodynamics.\140\ The
2010 NAS Report on heavy-duty trucks found that aerodynamic
improvements which yield 3 to 4 percent fuel consumption reduction or 6
to 8 percent reduction in Cd values, beyond technologies used in
today's SmartWay trucks are achievable.\141\
---------------------------------------------------------------------------
\140\ Daimler Truck North America. SuperTruck Program Vehicle
Project Review. June 19, 2014.
\141\ See TIAX, Note 137, Page 4-40.
---------------------------------------------------------------------------
Lower Rolling Resistance Tires: A tire's rolling resistance results
from the tread compound material, the architecture and materials of the
casing, tread design, the tire manufacturing process, and its operating
conditions (surface, inflation pressure, speed, temperature, etc.).
Differences in rolling resistance of up to 50 percent have been
identified for tires designed to equip the same vehicle. Since 2007,
SmartWay designated tractors have had steer tires with rolling
resistance coefficients of less than 6.6 kg/metric ton for the steer
tire and less than 7.0 kg/metric ton for the drive tire.\142\ 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 lowest rolling resistance value submitted for
2014MY GHG and fuel efficiency certification was 4.3 and 5.0 kg/metric
ton for the steer and drive tires respectively.\143\
---------------------------------------------------------------------------
\142\ Ibid.
\143\ Memo to Docket. Coefficient of Rolling Resistance
Certification Data. See Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
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 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 proposed for Phase
2, one-third of the weight reduction would 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 agencies propose 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.\144\ 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.
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\144\ 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.''
---------------------------------------------------------------------------
Extended Idle Reduction: Auxiliary power units (APU), fuel operated
heaters, battery supplied air conditioning, and thermal storage systems
are among the technologies available today to reduce main engine
extended idling from sleeper cabs. Each of these technologies reduces
fuel consumption during idling from a truck without this equipment (the
baseline) from approximately 0.8 gallons per hour (main engine idling
fuel consumption rate) to approximately 0.2 gallons per hour for an
APU.\145\ EPA and NHTSA agree with the TIAX assessment that a 5 percent
reduction in overall fuel consumption reduction is achievable.\146\
---------------------------------------------------------------------------
\145\ See the draft RIA Chapter 2.4.8 for details.
\146\ See the 2010 NAS Report, Note 136, above, at 128.
---------------------------------------------------------------------------
[[Page 40217]]
Idle Reduction: 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. To
recognize idle reduction technologies that reduce workday idling, the
agencies have developed a new idle-only duty cycle that is proposed to
be used in GEM. As discussed above in Section II.D, this new proposed
certification test cycle would measure the amount of fuel saved and
CO2 emissions reduced by two primary types of technologies:
Neutral idle and stop-start. The proposed rules apply this test cycle
only to vocational vehicles because these types of vehicles spend more
time at idle than tractors. However, the agencies request comment on
whether we should extend this vocational vehicle idle reduction
approach to day cab tractors. Neutral idle would only be available for
tractors using torque-converter automatic transmissions, and stop-start
would be available for any tractor. Unlike the fixed numerical value in
GEM for automatic engine shutdown systems to reduce overnight idling of
combination tractors, this new idle reduction approach would result in
different numerical values depending on user inputs. The required
inputs and other details about this cycle, as it would apply to
vocational vehicles, are described in the draft RIA Chapter 3. If we
extended this approach to day cab tractors, we could set a fixed GEM
composite cycle weighting factor at a value representative of the time
spent at idle for a typical day cab tractor, possibly five percent.
Under this approach, tractor manufacturers would be able to select GEM
inputs that identify the presence of workday idle reduction
technologies, and GEM would calculate the associated benefit due to
these technologies, using this new idle-only cycle as described in the
draft RIA Chapter 3.
The agencies have also received a letter from the California Air
Resources Board requesting consideration of credits for reducing solar
loads. Solar reflective paints and solar control glazing technologies
are briefly discussed in draft RIA Chapter 2.4.9.3. The agencies
request comment on the Air Resources Board's letter and
recommendations.\147\
---------------------------------------------------------------------------
\147\ 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.
---------------------------------------------------------------------------
Vehicle Speed Limiters: Fuel consumption and GHG emissions increase
proportional to the square of vehicle speed. Therefore, lowering
vehicle speeds can significantly reduce fuel consumption and GHG
emissions. A vehicle speed limiter (VSL), which limits the vehicle's
maximum speed, is 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).
Downsized Engines and 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 BMEP 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, 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.
Transmission: 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.\148\ However, as also noted in the report and in
the supporting TIAX report, the improvement is very dependent on the
driver of the truck, such that reductions ranged from 0 to 8
percent.\149\ Well-trained drivers would be expected to perform as well
or even better than an automatic transmission since the driver can see
the road ahead and anticipate a changing stoplight or other road
condition that neither an automatic nor automated manual transmission
can anticipate. However, poorly-trained drivers that shift too
frequently or not frequently enough to maintain optimum engine
operating conditions could be expected to realize improved in-use fuel
consumption by switching from a manual transmission to an automatic or
automated manual transmission. As transmissions continue to evolve, we
are now seeing in the European heavy-duty vehicle market the addition
of dual clutch transmissions (DCT). DCTs operate similar to AMTs, but
with two clutches so that the transmission can maintain engine speed
during a shift which improves fuel efficiency. We believe there may be
real benefits in reduced fuel consumption and GHG emissions through the
adoption of dual clutch, automatic or automated manual transmission
technology.
---------------------------------------------------------------------------
\148\ 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.
\149\ See TIAX, Note 137, above at 4-70.
---------------------------------------------------------------------------
Low Friction Transmission, Axle, and Wheel Bearing Lubricants: The
2010 NAS report assessed low friction lubricants for the drivetrain as
providing a 1 percent improvement in fuel consumption based on fleet
testing.\150\ 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.\151\ The light-duty 2012-16 MY vehicle rule and the
pickup truck portion of this program estimate that low friction
lubricants can have an effectiveness value between 0 and 1 percent
compared to traditional lubricants.
---------------------------------------------------------------------------
\150\ See the 2010 NAS Report, Note 136, page 67.
\151\ 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.
---------------------------------------------------------------------------
Drivetrain: 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
[[Page 40218]]
a 6x4 configuration.\152\ 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 1 and 3 percent.\153\ 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.
---------------------------------------------------------------------------
\152\ North American Council for Freight Efficiency.
''Confidence Findings on the Potential of 6x2 Axles.'' 2014. Page
16.
\153\ 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.
---------------------------------------------------------------------------
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 coming from improved water pump efficiency.\154\ 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 single operating point on the engine map, and therefore the overall
expected reduction of these technologies is less than the single point
result.
---------------------------------------------------------------------------
\154\ See the draft RIA Chapter 2.4 for details.
---------------------------------------------------------------------------
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 propose to provide a 2 percent reduction in fuel
consumption and CO2 emissions for vehicles configured with
intelligent controls, such as predictive cruise control.
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 reduced 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.\155\ Generally, a 10 psi reduction in
overall tire inflation results in about a 1 percent reduction in fuel
economy.\156\ To achieve the intended fuel efficiency benefits of low
rolling resistance tires, it is critical that tires are maintained at
the proper inflation pressure.
---------------------------------------------------------------------------
\155\ Bridgestone Tires. Real Questions, Real Answers. http://www.bridgestonetrucktires.com/us_eng/real/magazines/ra_special-edit_4/ra_special4_fuel-tires.asp.
\156\ ``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.\157\ A 2011 FMCSA study estimated
underinflation 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
underinflation.\158\ A recent study by The North American Council on
Freight Efficiency, found that adoption 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.\159\ These automatic tire
inflation systems monitor tire pressure and also automatically keep
tires inflated to a specific level. The agencies propose to provide a 1
percent CO2 and fuel consumption reduction value for
tractors with automatic tire inflation systems installed.
---------------------------------------------------------------------------
\157\ 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.
\158\ TMC Future Truck Committee Presentation ``FMCSA Tire
Pressure Monitoring Field Operational Test Results,'' February 8,
2011.
\159\ North American Council for Freight Efficiency, ``Tire
Pressure Systems,'' 2013.
---------------------------------------------------------------------------
Tire pressure monitoring systems 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 are not proposing to provide a reduction value for tire
pressure monitoring systems. We request comment on this approach and
seek data from those that support a reduction value be assigned to tire
pressure monitoring systems.
Hybrid: Hybrid powertrain development in Class 7 and 8 tractors has
been limited to a few manufacturer demonstration vehicles to date. One
of the key benefit opportunities for fuel consumption reduction with
hybrids is less fuel consumption when a vehicle is idling, but the
standard is already premised on use of extended idle reduction so use
of hybrid technology would duplicate many of the same emission
reductions attributable to extended idle reduction. NAS estimated that
hybrid systems would cost approximately $25,000 per tractor in the 2015
through the 2020 time frame and provide a potential fuel consumption
reduction of 10 percent, of which 6 percent is idle reduction which can
be achieved (less expensively) through the use of other idle reduction
technologies.\160\ The limited reduction potential outside of idle
reduction for Class 8 sleeper cab tractors is due to the mostly highway
operation and limited start-stop operation. Due to the high cost and
limited benefit during the model years at issue in this action (as well
as issues regarding sufficiency of lead time (see Section III.D.2
below), the agencies are not including hybrids in assessing standard
stringency (or as an input to GEM).
---------------------------------------------------------------------------
\160\ See the 2010 NAS Report, Note 136, page 128.
---------------------------------------------------------------------------
Management: The 2010 NAS report noted many operational
opportunities to reduce fuel consumption, such as driver training and
route optimization. The agencies have included discussion of several of
these strategies in draft RIA Chapter 2, but are not using these
approaches or technologies in the standard setting process. The
agencies are looking to other resources, such as EPA's SmartWay
Transport Partnership and regulations that could potentially be
promulgated by the Federal Highway Administration and the Federal Motor
Carrier Safety Administration, to continue to encourage the development
and utilization of these approaches.
[[Page 40219]]
(2) 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 the proposed standards.
The agencies propose Phase 2 standards that project 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. As discussed in Section II.D, the agencies assume the
proposed 2027 MY engines would achieve an additional 4 percent
improvement over Phase 1 engines and we project would include 15
percent of waste heat recovery (WHR) and many other advanced engine
technologies. In addition, we are proposing standards that project
improvements to nearly all of today's transmissions, incorporation of
extended idle reduction technologies on 90 percent of sleeper cabs, and
significant adoption of other types of technologies such as predictive
cruise control and automatic tire inflation systems.
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 idle shutdown technologies and not on the broader energy
storage and recovery systems necessary to achieve reductions over
typical vehicle drive cycles. The proposed standards reflect the
potential for idle shutdown technologies through GEM. 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 tractor fuel efficiency and to greenhouse
gas emission reductions. However, due to the high cost, limited benefit
during highway driving, and lacking any existing systems or
manufacturing base, we cannot conclude with certainty, absent
additional information, that such technology would be available for
tractors in the 2021-2027 timeframe. However the agencies welcome
comment from industry and others on their projected timeline for
deployment of hybrid powertrains for tractor applications.
(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. The specific attributes of each
tractor subcategory are listed below in Table III-5. Using these
values, the agencies assessed the CO2 emissions and fuel
consumption performance of the proposed baseline tractors using the
proposed version of Phase 2 GEM. The results of these simulations are
shown below in Table III-6.
As noted earlier, the Phase 1 2017 model year tractor standards and
the baseline 2017 model year tractor results 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 proposed 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
proposed 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.
Finally, the agencies assessed the current level of automatic engine
shutdown and idle reduction technologies used by the tractor
manufacturers to comply with the 2014 model year CO2 and
fuel consumption standards. To date, the manufacturers are meeting the
2014 model year standards without the use of this technology.
Therefore, in this proposal the agencies reverted back to the baseline
APU adoption rate of 30 percent, the value used in the Phase 1
baseline.
[[Page 40220]]
Table III-5--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 2017 MY 2017 MY
Engine 350 Engine 350 Engine 350 Engine 455 Engine 455 Engine 455 15L Engine 15L Engine 15L Engine
HP HP HP HP HP HP 455 HP 455 HP 455 HP
----------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m\2\)
----------------------------------------------------------------------------------------------------------------
5.00 6.40 6.42 5.00 6.40 6.42 4.95 6.35 6.22
----------------------------------------------------------------------------------------------------------------
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 Adoption Rate
----------------------------------------------------------------------------------------------------------------
N/A N/A N/A N/A N/A N/A 30% 30% 30%
----------------------------------------------------------------------------------------------------------------
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 = 3.70
----------------------------------------------------------------------------------------------------------------
Table III-6--Class 7 and 8 Tractor Baseline CO2 Emissions and Fuel Consumption
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
--------------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
--------------------------------------------------------------------------------------------------
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 (grams CO2/ton-mile)............................. 107 118 121 86 93 95 79 87 88
Fuel Consumption (gal/1,000 ton-mile)................ 10.5 11.6 11.9 8.4 9.1 9.3 7.8 8.5 8.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
The fuel consumption and CO2 emissions in the 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 more dynamic baseline, was developed to
estimate the effect of market pressures and non-regulatory government
initiatives to improve tractor fuel consumption. The more 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 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 \161\ 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 more 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-6. 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-5 is 6.22
(m\2\) in 2018. In 2028, the CdA of a high roof sleeper cab would be
assumed to still be 6.22 m\2\ in the 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 draft RIA Chapter 11.
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\161\ U.S. Department of Energy. ``SuperTruck Making Leaps in
Fuel Efficiency.'' 2014. Last accessed on May 10, 2015 at http://energy.gov/eere/articles/supertruck-making-leaps-fuel-efficiency.
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[[Page 40221]]
(b) Tractor Technology Packages
The agencies' assessment of the proposed technology effectiveness
was developed through the use of the GEM in coordination with modeling
conducted by Southwest Research Institute. The agencies developed the
proposed standards through a three-step process, similar to the
approach used in Phase 1. First, the agencies developed technology
performance characteristics for each technology, as described below.
Each technology is associated with an input parameter which in turn
would be used as an input to the Phase 2 GEM simulation tool and its
effectiveness thereby modeled. The performance levels for the range of
Class 7 and 8 tractor aerodynamic packages and vehicle technologies are
described below in Table III-7. Second, the agencies combined the
technology performance levels with a projected technology adoption rate
to determine the GEM inputs used to set the stringency of the proposed
standards. Third, the agencies input these parameters into Phase 2 GEM
and used the output to determine the proposed CO2 emissions
and fuel consumption levels. All percentage improvements noted below
are over the 2017 baseline tractor.
(i) Engine Improvements
There are several technologies that could be used to improve the
efficiency of diesel engines used in tractors. Details of the engine
technologies, adoption rates, and overall fuel consumption and
CO2 emission reductions are included in Section II.D. The
proposed heavy-duty tractor engine standards would lead to a 1.5
percent reduction in 2021MY, a 3.5 percent reduction in 2024MY, and a 4
percent reduction in 2027MY. These reductions would show up in the fuel
map used in GEM.
(ii) Aerodynamics
The 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. A more complete description of these aerodynamic packages
is included in Chapter 2 of the draft RIA. In general, the proposed 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.
(iii) Tire Rolling Resistance
The proposed rolling resistance coefficient target for Phase 2 was
developed from SmartWay's tire testing to develop the SmartWay
certification, testing a selection of tractor tires as part of the
Phase 1 and Phase 2 programs, and from 2014 MY certification data. 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 are 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. The Level 3 values represent 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. 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
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 baseline, 60 percent Level 1 and 10 percent Level
2. Finally, the low roof day cab 2017MY standard can be met with a
weighted average rolling resistance consisting of 40 percent baseline,
50 percent Level 1, and 10 percent Level 2.
(iv) Idle Reduction
The benefits for the extended idle reductions were developed from
literature, SmartWay work, and the 2010 NAS report. Additional details
regarding the comments and calculations are included in draft RIA
Section 2.4.
(v) Transmission
The benefits for automated manual, automatic, and dual clutch
transmissions were developed from literature and from simulation
modeling conducted by Southwest Research Institute. The benefit of
these transmissions is proposed to be set to a two percent improvement
over a manual transmission due to the automation of the gear shifting.
(vi) Drivetrain
The reduction in friction due to low viscosity axle lubricants is
set to 0.5 percent. 6x4 and 4x2 axle configurations lead to a 2.5
percent improvement in vehicle efficiency. Downspeeding would be as
demonstrated through the Phase 2 GEM inputs of transmission gear ratio,
drive axle ratio, and tire diameter. Downspeeding is projected to
improve the fuel consumption by 1.8 percent.
(vii) Accessories and Other Technologies
Compared to 2017MY 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 1 percent over the 2017MY baseline.
Based on literature information, intelligent controls such as
predictive cruise control will reduce CO2 emissions by 2
percent while automatic tire inflation systems improve fuel consumption
by 1 percent by keeping tire rolling resistance to its optimum based on
inflation pressure.
(viii) Weight Reduction
The weight reductions were developed from tire manufacturer
information, the Aluminum Association, the Department of Energy, SABIC
and TIAX, as discussed above in Section II.B.3.e.
(ix) Vehicle Speed Limiter
The agencies did not consider the availability of vehicle speed
limiter technology in setting the Phase 1 stringency levels, and again
did not consider the availability of the technology in developing
regulatory alternatives for Phase 2. However, as described in more
detail above, speed limiters could be an effective means for achieving
compliance, if employed on a voluntary basis.
(x) Summary of Technology Performance
Table III-7 describes the performance levels for the range of Class
7 and 8 tractor vehicle technologies.
[[Page 40222]]
Table III-7--Proposed 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 11L 11L 15L 15L 15L 15L 15L 15L
Engine Engine Engine Engine Engine Engine Engine Engine Engine
350 HP 350 HP 350 HP 455 HP 455 HP 455 HP 455 HP 455 HP 455 HP
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m\2\)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I................................................ 5.3 6.7 7.6 5.3 6.7 7.6 5.3 6.7 7.4
Bin II............................................... 4.8 6.2 7.1 4.8 6.2 7.1 4.8 6.2 6.9
Bin III.............................................. 4.3 5.7 6.5 4.3 5.7 6.5 4.3 5.7 6.3
Bin IV............................................... 4.0 5.4 5.8 4.0 5.4 5.8 4.0 5.4 5.6
Bin V................................................ N/A N/A 5.3 N/A N/A 5.3 N/A N/A 5.1
Bin VI............................................... N/A N/A 4.9 N/A N/A 4.9 N/A N/A 4.7
Bin VII.............................................. N/A N/A 4.5 N/A N/A 4.5 N/A N/A 4.3
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.............................................. 4.3 4.3 4.3 4.3 4.3 4.3 4.3 4.3 4.3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base................................................. 8.2 8.2 8.2 8.2 8.2 8.2 8.2 8.2 8.2
Level 1.............................................. 7.0 7.0 7.0 7.0 7.0 7.0 7.0 7.0 7.0
Level 2.............................................. 6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0
Level 3.............................................. 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Idle Reduction (% reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
APU.................................................. N/A N/A N/A N/A N/A N/A 5% 5% 5%
Other................................................ N/A N/A N/A N/A N/A N/A 7% 7% 7%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Type (% 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Driveline (% reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Lubricant....................................... 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5%
6x2 or 4x2 Axle...................................... 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5
Downspeed............................................ 1.8 1.8 1.8 1.8 1.8 1.8 1.8 1.8 1.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements (% reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
A/C.................................................. 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 1 1 1 1 1 1 1 1
--------------------------------------------------------------------------------------------------------------------------------------------------------
(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. 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 proposed HD Phase 2 standards, NHTSA and EPA established technology
[[Page 40223]]
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. 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. This second type of constraint was applied to the
aerodynamic, tire, powertrain, and vehicle speed limiter technologies.
Table III-8 and Table III-10, specify the adoption rates that EPA
and NHTSA used to develop the proposed standards. The agencies welcome
comments on these adoption rates.
NHTSA and EPA believe that within each of these individual vehicle
categories there are particular applications where the use of the
identified technologies would be either ineffective or not technically
feasible. For example, the agencies are not predicating the proposed
standards on the use of full aerodynamic vehicle treatments on 100
percent of tractors because we know that in many applications (for
example gravel truck engaged in local aggregate delivery) the added
weight of the aerodynamic technologies will increase fuel consumption
and hence CO2 emissions to a greater degree than the
reduction that would be accomplished from the more aerodynamic nature
of the tractor.
(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 are proposing the most aggressive aerodynamic
technology application to this regulatory subcategory. All of the major
manufacturers today offer at least one SmartWay sleeper cab tractor
model, which is represented as Bin III aerodynamic performance. The
proposed aerodynamic adoption rate for Class 8 high roof sleeper cabs
in 2027 (i.e., the degree of technology adoption on which the
stringency of the proposed standard is premised) consists of 20 percent
of Bin IV, 35 percent Bin V, 20 percent Bin VI, and 5 percent Bin VII
reflecting our assessment of the fraction of tractors in this segment
that could successfully apply these aerodynamic packages with this
amount of lead time. 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 changes required for Bin IV and
better performance reflect the kinds of improvements projected in the
Department of Energy's SuperTruck program. That program assumes that
such systems can be demonstrated on vehicles by 2017. In this case, the
agencies are projecting that truck manufacturers would be able to begin
implementing these aerodynamic technologies as early as 2021 MY on a
limited scale. 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 aerodynamic adoption rates used to develop the proposed
standards for the other tractor regulatory categories are less
aggressive than for the Class 8 sleeper cab high roof. 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 which require
on/off-road capability and other truck functions which restrict the
type of aerodynamic equipment applicable. We also recognize that these
types of trucks spend less time at highway speeds where aerodynamic
technologies have the greatest benefit. The 2002 VIUS data ranks trucks
by major use.\162\ The heavy trucks usage indicates that up to 35
percent of the trucks may be used in on/off-road applications or
heavier applications. The uses include construction (16 percent),
agriculture (12 percent), waste management (5 percent), and mining (2
percent). Therefore, the agencies analyzed the technologies to evaluate
the potential restrictions that would prevent 100 percent adoption of
more advanced aerodynamic technologies for all of the tractor
regulatory subcategories.
---------------------------------------------------------------------------
\162\ U.S. Department of Energy. Transportation Energy Data
Book, Edition 28-2009. Table 5.7.
---------------------------------------------------------------------------
As discussed in Section III.C.2, the agencies propose to increase
the number of aerodynamic bins for low and mid roof tractors from the
two levels adopted in Phase 1 to four levels in Phase 2. The agencies
propose to increase 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.
(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.
(iii) Weight Reduction Technology Adoption Rate
Unlike in HD Phase 1, the agencies propose setting the 2021 through
2027 model year tractor standards without using weight reduction as a
technology to demonstrate the feasibility. However, as described in
Section III.C.2 below, the agencies are proposing 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. 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 would
cost $2,050 (2012$) in 2021MY, but offers a 0.3 percent reduction in
fuel consumption and CO2 emissions.
(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
[[Page 40224]]
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 indicate that idle
technologies are sometimes installed in the factory, but it is also a
common practice to have the units installed after the sale of the
truck. We would like to continue to incentivize this practice and to do
so in a manner that the emission reductions associated with idle
reduction technology occur in use. Therefore, as adopted in Phase 1, we
are allowing only idle emission reduction technologies which include an
automatic engine shutoff (AES) with some override provisions.\163\
However, we welcome comment on other approaches that would
appropriately quantify the reductions that would be experienced in the
real world.
---------------------------------------------------------------------------
\163\ The agencies are proposing to continue the HD Phase 1 AES
override provisions included in 40 CFR 1037.660(b) for driver
safety.
---------------------------------------------------------------------------
We propose an overall 90 percent adoption rate for this technology
for Class 8 sleeper cabs. The agencies are unaware of reasons why AES
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.
The agencies are interested in extending the idle reduction
benefits beyond Class 8 sleepers, to day cabs. 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.\164\ Idling may
occur during the delivery process, queuing at loading docks or border
crossings, during power take off operations, or to provide comfort
during the work day. However, the study provided only ``rough
estimates'' of the idle time and energy use for these vehicles. The
agencies are not able to appropriately develop a baseline of workday
idling for day cabs and identify the percent of this idling which could
be reduced through the use of AES. We welcome comment and data on
quantifying the effectiveness of AES on day cabs.
---------------------------------------------------------------------------
\164\ Gaines, L., A. Vyas, J. Anderson. Estimation of Fuel Use
by Idling Commercial Trucks. January 2006.
---------------------------------------------------------------------------
(v) Vehicle Speed Limiter Adoption Rate
As adopted in Phase 1, we propose to continue the approach where
vehicle speed limiters may be used as a technology to meet the proposed
standard. In setting the proposed standard, however, we assumed a zero
percent adoption rate of vehicle speed limiters. Although we believe
vehicle speed limiters are a simple, easy to implement, and inexpensive
technology, we want to leave the use of vehicles speed limiters to the
truck purchaser. Since truck fleets purchase tractors today with owner-
set vehicle speed limiters, we considered not including VSLs in our
compliance model. However, we have concluded that we should allow the
use of VSLs that cannot be overridden by the operator as a means of
compliance for vehicle manufacturers that wish to offer it and truck
purchasers that wish to purchase the technology. In doing so, we are
providing another means of meeting that standard that can lower
compliance cost and provide a more optimal vehicle solution for some
truck fleets 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 55 mph for this vehicle at the request of the
customer. The resulting tractor would be optimized for its intended
application and would be fully compliant with our program all at a
lower cost to the ultimate tractor purchaser.\165\
---------------------------------------------------------------------------
\165\ Ibid.
The agencies note that because a VSL value can be input into
GEM, its benefits can be directly assessed with the model and off
cycle credit applications therefore are not necessary even though
the proposed standard is not based on performance of VSLs (i.e. VSL
is an on-cycle technology).
---------------------------------------------------------------------------
As in Phase 1, we have chosen not to base the proposed standards on
performance of VSLs because of concerns about how to set a realistic
adoption rate that avoids unintended adverse impacts. Although we
expect there would 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 would result
in similar benefits to overall efficiency or how many customers would
be willing to accept a tamper-proof VSL setting. As discussed in
Section III.E.2.f below, we welcome comment on suggestions to modify
the tamper-proof requirement while maintaining assurance that the speed
limiter is used in-use throughout the life of the vehicle. We are not
able at this time to quantify the potential loss in utility due to the
use of VSLs, but we welcome comment on whether the use of a VSL would
require a fleet to deploy additional tractors. Absent this information,
we cannot make a determination regarding the reasonableness of setting
a standard based on a particular VSL level. Therefore, the agencies are
not premising the proposed standards on use of VSL, and instead would
continue to rely on the industry to select VSL when circumstances are
appropriate for its use. The agencies have not included either the cost
or benefit due to VSLs in analysis of the proposed program's costs and
benefits, therefore it remains a significant flexibility for
manufacturers to choose.
(vi) Summary of the Adoption Rates Used To Determine the Proposed
Standards
Table III-8 through Table III-10 provide the adoption rates of each
technology broken down by weight class, cab configuration, and roof
height.
[[Page 40225]]
Table III-8--Technology Adoption Rates for Class 7 and 8 Tractors for Determining the Proposed 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
% % % % % % % % %
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021 MY Engine Technology Package
--------------------------------------------------------------------------------------------------------------------------------------------------------
100 100 100 100 100 100 100 100 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I................................................ 0 0 0 0 0 0 0 0 0
Bin II............................................... 75 75 0 75 75 0 75 75 0
Bin III.............................................. 25 25 40 25 25 40 25 25 40
Bin IV............................................... 0 0 35 0 0 35 0 0 35
Bin V................................................ N/A N/A 20 N/A N/A 20 N/A N/A 20
Bin VI............................................... N/A N/A 5 N/A N/A 5 N/A N/A 5
Bin VII.............................................. N/A N/A 0 N/A N/A 0 N/A N/A 0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base................................................. 5 5 5 5 5 5 5 5 5
Level 1.............................................. 60 60 60 60 60 60 60 60 60
Level 2.............................................. 25 25 25 25 25 25 25 25 25
Level 3.............................................. 10 10 10 10 10 10 10 10 10
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base................................................. 5 5 5 5 5 5 5 5 5
Level 1.............................................. 60 60 60 60 60 60 60 60 60
Level 2.............................................. 25 25 25 25 25 25 25 25 25
Level 3.............................................. 10 10 10 10 10 10 10 10 10
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
APU.................................................. N/A N/A N/A N/A N/A N/A 80 80 80
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Type
--------------------------------------------------------------------------------------------------------------------------------------------------------
Manual............................................... 45 45 45 45 45 45 45 45 45
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Driveline
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Lubricant....................................... 20 20 20 20 20 20 20 20 20
6x2 or 4x2 Axle...................................... ......... ......... ......... 10 10 20 10 10 20
Downspeed............................................ 20 20 20 20 20 20 20 20 20
Accessory Improvements
--------------------------------------------------------------------------------------------------------------------------------------------------------
A/C.................................................. 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 40226]]
Table III-9--Technology Adoption Rates for Class 7 and 8 Tractors for Determining the Proposed 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
% % % % % % % % %
--------------------------------------------------------------------------------------------------------------------------------------------------------
2024 MY Engine Technology Package
--------------------------------------------------------------------------------------------------------------------------------------------------------
100 100 100 100 100 100 100 100 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I................................................ 0 0 0 0 0 0 0 0 0
Bin II............................................... 60 60 0 60 60 0 60 60 0
Bin III.............................................. 38 38 30 38 38 30 38 38 30
Bin IV............................................... 2 2 30 2 2 30 2 2 30
Bin V................................................ N/A N/A 25 N/A N/A 25 N/A N/A 25
Bin VI............................................... N/A N/A 13 N/A N/A 13 N/A N/A 13
Bin VII.............................................. N/A N/A 2 N/A N/A 2 N/A N/A 2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base................................................. 5 5 5 5 5 5 5 5 5
Level 1.............................................. 50 50 50 50 50 50 50 50 50
Level 2.............................................. 30 30 30 30 30 30 30 30 30
Level 3.............................................. 15 15 15 15 15 15 15 15 15
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base................................................. 5 5 5 5 5 5 5 5 5
Level 1.............................................. 50 50 50 50 50 50 50 50 50
Level 2.............................................. 30 30 30 30 30 30 30 30 30
Level 3.............................................. 15 15 15 15 15 15 15 15 15
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
APU.................................................. N/A N/A N/A N/A N/A N/A 90 90 90
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Type
--------------------------------------------------------------------------------------------------------------------------------------------------------
Manual............................................... 20 20 20 20 20 20 20 20 20
AMT.................................................. 50 50 50 50 50 50 50 50 50
Auto................................................. 20 20 20 20 20 20 20 20 20
Dual Clutch.......................................... 10 10 10 10 10 10 10 10 10
--------------------------------------------------------------------------------------------------------------------------------------------------------
Driveline
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Lubricant....................................... 40 40 40 40 40 40 40 40 40
6x2 or 4x2 Axle...................................... ......... ......... ......... 20 20 60 20 20 60
Downspeed............................................ 40 40 40 40 40 40 40 40 40
Direct Drive......................................... 50 50 50 50 50 50 50 50 50
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements
--------------------------------------------------------------------------------------------------------------------------------------------------------
A/C.................................................. 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...................... 40 40 40 40 40 40 40 40 40
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 40227]]
Table III-10--Technology Adoption Rates for Class 7 and 8 Tractors for Determining the Proposed 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
% % % % % % % % %
--------------------------------------------------------------------------------------------------------------------------------------------------------
2027 MY Engine Technology Package
--------------------------------------------------------------------------------------------------------------------------------------------------------
100 100 100 100 100 100 100 100 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I................................................ 0 0 0 0 0 0 0 0 0
Bin II............................................... 50 50 0 50 50 0 50 50 0
Bin III.............................................. 40 40 20 40 40 20 40 40 20
Bin IV............................................... 10 10 20 10 10 20 10 10 20
Bin V................................................ N/A N/A 35 N/A N/A 35 N/A N/A 35
Bin VI............................................... N/A N/A 20 N/A N/A 20 N/A N/A 20
Bin VII.............................................. N/A N/A 5 N/A N/A 5 N/A N/A 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base................................................. 5 5 5 5 5 5 5 5 5
Level 1.............................................. 20 20 20 20 20 20 20 20 20
Level 2.............................................. 50 50 50 50 50 50 50 50 50
Level 3.............................................. 25 25 25 25 25 25 25 25 25
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base................................................. 5 5 5 5 5 5 5 5 5
Level 1.............................................. 20 20 20 20 20 20 20 20 20
Level 2.............................................. 50 50 50 50 50 50 50 50 50
Level 3.............................................. 25 25 25 25 25 25 25 25 25
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
APU.................................................. N/A N/A N/A N/A N/A N/A 90 90 90
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Type
--------------------------------------------------------------------------------------------------------------------------------------------------------
Manual............................................... 10 10 10 10 10 10 10 10 10
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Driveline
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Lubricant....................................... 40 40 40 40 40 40 40 40 40
6x2 Axle............................................. ......... ......... ......... 20 20 60 20 20 60
Downspeed............................................ 60 60 60 60 60 60 60 60 60
Direct Drive......................................... 50 50 50 50 50 50 50 50 50
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements
--------------------------------------------------------------------------------------------------------------------------------------------------------
A/C.................................................. 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...................... 40 40 40 40 40 40 40 40 40
--------------------------------------------------------------------------------------------------------------------------------------------------------
(d) Derivation of the Proposed Tractor Standards
The agencies used the technology effectiveness inputs and
technology adoption rates to develop GEM inputs to derive the proposed
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 proposed level of
stringency, but manufacturers would be free to use any combination of
technology to meet the standards, and with 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
proposed CdA value for a 2021MY Class 8 Sleeper Cab High Roof scenario
case was
[[Page 40228]]
derived as 40 percent times 6.3 plus 35 percent times 5.6 plus 20
percent times 5.1 plus 5 percent times 4.7, which is equal to a CdA of
5.74 m\2\. Similar calculations were made for tire rolling resistance,
transmission types, idle reduction, and other technologies. To account
for the proposed engine standards and engine technologies, the agencies
assumed a compliant engine fuel map in GEM.\166\ The agencies then ran
GEM with a single set of vehicle inputs, as shown in Table III-11, to
derive the proposed standards for each subcategory. Additional detail
is provided in the draft RIA Chapter 2.
---------------------------------------------------------------------------
\166\ See Section II.D above explaining the derivation of the
proposed engine standards.
Table III-11--GEM Inputs for the Proposed 2021MY 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
----------------------------------------------------------------------------------------------------------------
2021MY 11L 2021MY 11L 2021MY 11L 2021MY 15L 2021MY 15L 2021MY 15L 2021MY 15L 2021MY 15L 2021MY 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 (CdA in m\2\)
----------------------------------------------------------------------------------------------------------------
4.68 6.08 5.94 4.68 6.08 5.94 4.68 6.08 5.74
----------------------------------------------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
6.2 6.2 6.2 6.2 6.2 6.2 6.2 6.2 6.2
----------------------------------------------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
6.6 6.6 6.6 6.6 6.6 6.6 6.6 6.6 6.6
----------------------------------------------------------------------------------------------------------------
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 Automated 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 = 3.55
----------------------------------------------------------------------------------------------------------------
6x2 Axle Weighted Effectiveness
----------------------------------------------------------------------------------------------------------------
N/A N/A N/A 0.3% 0.3% 0.5% 0.3% 0.3% 0.5%
----------------------------------------------------------------------------------------------------------------
Low Friction Axle Lubrication = 0.1%
----------------------------------------------------------------------------------------------------------------
Transmission benefit = 1.1%
----------------------------------------------------------------------------------------------------------------
Predictive Cruise Control = 0.4%
----------------------------------------------------------------------------------------------------------------
Accessory Improvements = 0.1%
----------------------------------------------------------------------------------------------------------------
Air Conditioner Efficiency Improvements = 0.1%
----------------------------------------------------------------------------------------------------------------
Automatic Tire Inflation Systems = 0.2%
----------------------------------------------------------------------------------------------------------------
Weight Reduction = 0 lbs
----------------------------------------------------------------------------------------------------------------
[[Page 40229]]
Table III-12--GEM Inputs for the Proposed 2024MY 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
----------------------------------------------------------------------------------------------------------------
2024MY 11L 2024MY 11L 2024MY 11L 2024MY 15L 2024MY 15L 2024MY 15L 2024MY 15L 2024MY 15L 2024MY 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 (CdA in m\2\)
----------------------------------------------------------------------------------------------------------------
4.59 5.99 5.74 4.59 5.99 5.74 4.59 5.99 5.54
----------------------------------------------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9
Drive Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
6.2 6.2 6.2 6.2 6.2 6.2 6.2 6.2 6.2
----------------------------------------------------------------------------------------------------------------
Extended Idle Reduction Weighted Effectiveness
----------------------------------------------------------------------------------------------------------------
N/A N/A N/A N/A N/A N/A 3% 3% 3%
----------------------------------------------------------------------------------------------------------------
Transmission = 10 speed Automated 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
----------------------------------------------------------------------------------------------------------------
6x2 Axle Weighted Effectiveness
----------------------------------------------------------------------------------------------------------------
N/A N/A N/A 0.5% 0.5% 1.5% 0.5% 0.5% 1.5%
----------------------------------------------------------------------------------------------------------------
Low Friction Axle Lubrication = 0.2%
----------------------------------------------------------------------------------------------------------------
Transmission benefit = 1.6%
----------------------------------------------------------------------------------------------------------------
Predictive Cruise Control = 0.8%
----------------------------------------------------------------------------------------------------------------
Accessory Improvements = 0.2%
----------------------------------------------------------------------------------------------------------------
Air Conditioner Efficiency Improvements = 0.1%
----------------------------------------------------------------------------------------------------------------
Automatic Tire Inflation Systems = 0.4%
----------------------------------------------------------------------------------------------------------------
Weight Reduction = 0 lbs
----------------------------------------------------------------------------------------------------------------
Direct Drive Weighted Efficiency = 1% for sleeper cabs; 0.8% for day cabs
----------------------------------------------------------------------------------------------------------------
Table III-13--GEM Inputs for the Proposed 2027MY 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
----------------------------------------------------------------------------------------------------------------
2027MY 11L 2027MY 11L 2027MY 11L 2027MY 15L 2027MY 15L 2027MY 15L 2027MY 15L 2027MY 15L 2027MY 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 (CdA in m\2\)
----------------------------------------------------------------------------------------------------------------
4.52 5.92 5.52 4.52 5.92 5.52 4.52 5.92 5.32
----------------------------------------------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
5.6 5.6 5.6 5.6 5.6 5.6 5.6 5.6 5.6
----------------------------------------------------------------------------------------------------------------
[[Page 40230]]
Drive Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9
----------------------------------------------------------------------------------------------------------------
Extended Idle Reduction Weighted Effectiveness
----------------------------------------------------------------------------------------------------------------
N/A N/A N/A N/A N/A N/A 3% 3% 3%
----------------------------------------------------------------------------------------------------------------
Transmission = 10 speed Automated 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 = 3.2
----------------------------------------------------------------------------------------------------------------
6x2 Axle Weighted Effectiveness
----------------------------------------------------------------------------------------------------------------
N/A N/A N/A 0.5% 0.5% 1.5% 0.5% 0.5% 1.5%
----------------------------------------------------------------------------------------------------------------
Low Friction Axle Lubrication = 0.2%
----------------------------------------------------------------------------------------------------------------
Transmission benefit = 1.8%
----------------------------------------------------------------------------------------------------------------
Predictive Cruise Control = 0.8%
----------------------------------------------------------------------------------------------------------------
Accessory Improvements = 0.3%
----------------------------------------------------------------------------------------------------------------
Air Conditioner Efficiency Improvements = 0.2%
----------------------------------------------------------------------------------------------------------------
Automatic Tire Inflation Systems = 0.4%
----------------------------------------------------------------------------------------------------------------
Weight Reduction = 0 lbs
----------------------------------------------------------------------------------------------------------------
Direct Drive Weighted Efficiency = 1% for sleeper cabs; 0.8% for day cabs
----------------------------------------------------------------------------------------------------------------
The proposed level of the 2027 model year standards, in addition to
the phase-in standards in model years 2021 and 2024 for each
subcategory is included in Table III-14.
Table III-14--Proposed 2021, 2024, and 2027 Model Year Tractor Standards
----------------------------------------------------------------------------------------------------------------
Day cab Sleeper Cab
-----------------------------------------------
Class 7 Class 8 Class 8
----------------------------------------------------------------------------------------------------------------
2021 Model Year CO2 Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 97 78 70
Mid Roof........................................................ 107 84 78
High Roof....................................................... 109 86 77
----------------------------------------------------------------------------------------------------------------
2021 Model Year Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 9.5285 7.6621 6.8762
Mid Roof........................................................ 10.5108 8.2515 7.6621
High Roof....................................................... 10.7073 8.4479 7.5639
----------------------------------------------------------------------------------------------------------------
2024 Model Year CO2 Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 90 72 64
Mid Roof........................................................ 100 78 71
High Roof....................................................... 101 79 70
----------------------------------------------------------------------------------------------------------------
2024 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 8.8409 7.0727 6.2868
Mid Roof........................................................ 9.8232 7.6621 6.9745
High Roof....................................................... 9.9214 7.7603 6.8762
----------------------------------------------------------------------------------------------------------------
[[Page 40231]]
2027 Model Year CO2 Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 87 70 62
Mid Roof........................................................ 96 76 69
High Roof....................................................... 96 76 67
----------------------------------------------------------------------------------------------------------------
2027 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................................ 8.5462 6.8762 6.0904
Mid Roof........................................................ 9.4303 7.4656 6.7780
High Roof....................................................... 9.4303 7.4656 6.5815
----------------------------------------------------------------------------------------------------------------
A summary of the draft 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 draft RIA
Chapter 2.12. We welcome comments on the technology costs.
Table III-15--Class 7 and 8 Tractor Technology Incremental Costs in the 2021 Model Year \a\ \b\ Preferred
Alternative vs. the Less Dynamic Baseline
[2012$ per vehicle]
----------------------------------------------------------------------------------------------------------------
Class 7 Class 8
----------------------------------------------------------------------------
Day cab Day cab Sleeper cab
----------------------------------------------------------------------------
Low/mid Low/mid
roof High roof roof High roof Low roof Mid roof High roof
----------------------------------------------------------------------------------------------------------------
Engine \c\......................... $314 $314 $314 $314 $314 $314 $314
Aerodynamics....................... 687 511 687 511 656 656 535
Tires.............................. 49 9 81 15 59 59 15
Tire inflation system.............. 180 180 180 180 180 180 180
Transmission....................... 3,969 3,969 3,969 3,969 3,969 3,969 3,969
Axle & axle lubes.................. 50 50 70 90 70 70 90
Idle reduction with APU............ 0 0 0 0 2,449 2,449 2,449
Air conditioning................... 45 45 45 45 45 45 45
Other vehicle technologies......... 174 174 174 174 174 174 174
----------------------------------------------------------------------------
Total.......................... 5,468 5,252 5,520 5,298 7,916 7,916 7,771
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2021 model year and are incremental to the costs of a tractor meeting the Phase 1
standards. These costs include indirect costs via markups along with learning impacts. For a description of
the markups and learning impacts considered in this analysis and how it impacts technology costs for other
years, refer to Chapter 2 of the draft RIA (see draft RIA 2.12).
\b\ Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the
average cost expected for each of the indicated tractor classes. To see the actual estimated technology costs
exclusive of adoption rates, refer to Chapter 2 of the draft RIA (see draft RIA 2.12 in particular).
\c\ Engine costs are for a heavy HD diesel engine meant for a combination tractor. The engine costs in this
table are equal to the engine costs associated with the separate engine standard because both include the same
set of engine technologies (see Section II.D.2.d.i).
Table III-16--Class 7 and 8 Tractor Technology Incremental Costs in the 2024 Model Year \a\ \b\ Preferred
Alternative vs. the Less Dynamic Baseline
[2012$ per vehicle]
----------------------------------------------------------------------------------------------------------------
Class 7 Class 8
----------------------------------------------------------------------------
Day cab Day cab Sleeper cab
----------------------------------------------------------------------------
Low/mid Low/mid
roof High roof roof High roof Low roof Mid roof High roof
----------------------------------------------------------------------------------------------------------------
Engine \c\......................... $904 $904 $904 $904 $904 $904 $904
Aerodynamics....................... 744 684 744 684 712 712 723
Tires.............................. 47 11 78 18 58 58 18
Tire inflation system.............. 330 330 330 330 330 330 330
Transmission....................... 5,883 5,883 5,883 5,883 5,883 5,883 5,883
Axle & axle lubes.................. 92 92 128 200 128 128 200
Idle reduction with APU............ 0 0 0 0 2,687 2,687 2,687
Air conditioning................... 82 82 82 82 82 82 82
[[Page 40232]]
Other vehicle technologies......... 318 318 318 318 318 318 318
----------------------------------------------------------------------------
Total.......................... 8,400 8,304 8,467 8,419 11,102 11,102 11,145
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2024 model year and are incremental to the costs of a tractor meeting the Phase 1
standards. These costs include indirect costs via markups along with learning impacts. For a description of
the markups and learning impacts considered in this analysis and how it impacts technology costs for other
years, refer to Chapter 2 of the draft RIA (see draft RIA 2.12).
\b\ Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the
average cost expected for each of the indicated tractor classes. To see the actual estimated technology costs
exclusive of adoption rates, refer to Chapter 2 of the draft RIA (see draft RIA 2.12).
\c\ Engine costs are for a heavy HD diesel engine meant for a combination tractor. The engine costs in this
table are equal to the engine costs associated with the separate engine standard because both include the same
set of engine technologies (see Section II.D.2.d.i).
Table III-17--Class 7 and 8 Tractor Technology Incremental Costs in the 2027 Model Year \a\ \b\ Preferred
Alternative vs. the Less Dynamic Baseline
[2012$ per vehicle]
----------------------------------------------------------------------------------------------------------------
Class 7 Class 8
----------------------------------------------------------------------------
Day cab Day cab Sleeper cab
----------------------------------------------------------------------------
Low/mid Low/mid
roof High roof roof High roof Low roof Mid roof High roof
----------------------------------------------------------------------------------------------------------------
Engine \c\......................... $1,698 $1,698 $1,698 $1,698 $1,698 $1,698 $1,698
Aerodynamics....................... 771 765 771 765 733 733 802
Tires.............................. 45 10 75 17 56 56 17
Tire inflation system.............. 314 314 314 314 314 314 314
Transmission....................... 6,797 6,797 6,797 6,797 6,797 6,797 6,797
Axle & axle lubes.................. 97 97 131 200 131 131 200
Idle reduction with APU............ 0 0 0 0 2,596 2,596 2,596
Air conditioning................... 117 117 117 117 117 117 117
Other vehicle technologies......... 302 302 302 302 302 302 302
----------------------------------------------------------------------------
Total.......................... 10,140 10,099 10,204 10,209 12,744 12,744 12,842
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2027 model year and are incremental to the costs of a 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 draft RIA (see draft 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 draft RIA (see draft 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).
(i) Proposed Heavy-Haul Tractor Standards
For Phase 2, the agencies propose to add a tenth subcategory to the
tractor category for heavy-haul tractors. The agencies recognize the
need for manufacturers to build these types of vehicles for specific
applications and believe the appropriate way to prevent penalizing
these vehicles is to set separate standards recognizing a heavy-haul
vehicle's unique needs, such as requiring a higher horsepower engine or
different transmissions. The agencies are proposing 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 proposed tractor standards and are
included as manufacturer inputs in GEM. This means that the agencies
can adopt a standard reflecting 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 technology at certification.
The typical tractor is designed with a Gross Combined Weight Rating
(GCWR) of approximately 80,000 lbs due to the effective weight limit on
the federal highway system, except in states with preexisting higher
weight limits. The agencies propose to consider tractors with a GCWR
over 120,000 lbs as heavy-haul tractors. Based on comments received
during the development of HD Phase 1 (76 FR 57136-57138) and because we
are not proposing a sales limit for heavy-haul like we have for the
vocational tractors, the agencies also believe 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 would include
[[Page 40233]]
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 welcome 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.
The agencies propose that heavy-haul tractors demonstrate
compliance with the proposed 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 propose that GEM simulates the heavy-
haul tractors with a payload of 43 tons and a total tractor, trailer,
and payload weight of 118,500 lbs. In addition, we propose that the
engines installed in heavy-haul tractors meet the proposed tractor
engine standards included in 40 CFR 1036.108. We welcome comments on
these proposed specifications.
The agencies recognize that certain technologies used to determine
the stringency of the proposed 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 would 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 are not considering the use of
aerodynamic technologies in the development of the proposed Phase 2
heavy-haul tractor standards. Moreover, because aerodynamics would not
play a role in the heavy-haul standards, the agencies propose 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.\167\ We welcome comment on this approach.
---------------------------------------------------------------------------
\167\ Since aerodynamic improvements are not part of the
technology package, the agencies likewise are not proposing any bin
structure for the heavy-haul tractor subcategory.
---------------------------------------------------------------------------
Certain powertrain and drivetrain components are also impacted
during the design of a heavy-haul tractor, 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.
Downsped 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.
The agencies used the following heavy-haul tractor inputs for
developing the proposed 2021, 2024, and 2027 MY standards, as shown in
Table III-18 and Table III-19.
Table III-18--Application Rates for Proposed Heavy-Haul Tractor
Standards
------------------------------------------------------------------------
Heavy-Haul Tractor Application Rates
-------------------------------------------------------------------------
2021MY 2024MY 2027MY
--------------------------------------
Engine 2021 MY 15L 2024 MY 15L 2027 MY 15L
Engine with Engine with Engine with
600 HP (%) 600 HP (%) 600 HP (%)
------------------------------------------------------------------------
Aerodynamics--0%
------------------------------------------------------------------------
Steer Tires
------------------------------------------------------------------------
Phase 1 Baseline................. 5 5 5
Level I.......................... 60 50 20
Level 2.......................... 25 30 50
Level 3.......................... 10 15 25
------------------------------------------------------------------------
Drive Tires
------------------------------------------------------------------------
Phase 1 Baseline................. 5 5 5
Level I.......................... 60 50 20
Level 2.......................... 25 30 50
Level 3.......................... 10 15 25
------------------------------------------------------------------------
Transmission
------------------------------------------------------------------------
AMT.............................. 40 50 50
Automatic........................ 10 20 30
DCT.............................. 5 10 10
------------------------------------------------------------------------
Other Technologies
------------------------------------------------------------------------
6x2 Axle......................... 0 0 0
Low Friction Axle Lubrication.... 20 40 40
Predictive Cruise Control........ 20 40 40
Accessory Improvements........... 10 20 30
Air Conditioner Efficiency 10 20 30
Improvements....................
Automatic Tire Inflation Systems. 20 40 40
[[Page 40234]]
Weight Reduction................. 0 0 0
------------------------------------------------------------------------
Table III-19--GEM Inputs for Proposed 2021, 2024 and 2027 MY Heavy-Haul Tractor Standards
----------------------------------------------------------------------------------------------------------------
Heavy-haul tractor
-----------------------------------------------------------------------------------------------------------------
Baseline 2021MY 2024MY 2027MY
----------------------------------------------------------------------------------------------------------------
Engine = 2017 MY 15L Engine with 600 Engine = 2021 MY 15L Engine = 2024 MY 15L Engine = 2027 MY 15L
HP. Engine with 600 HP. Engine with 600 HP. Engine with 600 HP
----------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m\2\) = 5.00
----------------------------------------------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton) = Steer Tires (CRR in kg/ Steer Tires (CRR in kg/ Steer Tires (CRR in kg/
7.0. metric ton) = 6.2. metric ton) = 6.0. metric ton) = 5.8.
Drive Tires (CRR in kg/metric ton) = Drive Tires (CRR in kg/ Drive Tires (CRR in kg/ Drive Tires (CRR in kg/
7.4. metric ton) = 6.6. metric ton) = 6.4. metric ton) = 6.2.
Transmission = 13 speed Manual Transmission = 13 speed Transmission = 13 speed Transmission = 13 speed
Transmission, Gear Ratios = 12.29, Automated Manual Automated Manual Automated Manual
8.51, 6.05, 4.38, 3.20, 2.29, 1.95, Transmission, Gear Transmission, Gear Transmission, Gear
1.62, 1.38, 1.17, 1.00, 0.86, 0.73. Ratios = 12.29, 8.51, Ratios = 12.29, 8.51, Ratios = 12.29, 8.51,
6.05, 4.38, 3.20, 6.05, 4.38, 3.20, 6.05, 4.38, 3.20,
2.29, 1.95, 1.62, 2.29, 1.95, 1.62, 2.29, 1.95, 1.62,
1.38, 1.17, 1.00, 1.38, 1.17, 1.00, 1.38, 1.17, 1.00,
0.86, 0.73. 0.86, 0.73. 0.86, 0.73.
Drive axle Ratio = 3.55.............. Drive axle Ratio = 3.55 Drive axle Ratio = 3.55 Drive axle Ratio =
3.55.
N/A.................................. 6x2 Axle Weighted 6x2 Axle Weighted 6x2 Axle Weighted
Effectiveness = 0%. Effectiveness = 0%. Effectiveness = 0%.
N/A.................................. Low Friction Axle Low Friction Axle Low Friction Axle
Lubrication = 0.1%. Lubrication = 0.2%. Lubrication = 0.2%.
N/A.................................. AMT benefit = 1.1%..... AMT benefit = 1.8%..... AMT benefit = 1.8%.
N/A.................................. Predictive Cruise Predictive Cruise Predictive Cruise
Control = 0.4%. Control = 0.8%. Control = 0.8%.
N/A.................................. Accessory Improvements Accessory Improvements Accessory Improvements
= 0.1%. = 0.2%. = 0.3%.
N/A.................................. Air Conditioner Air Conditioner Air Conditioner
Efficiency Efficiency Efficiency
Improvements = 0.1%. Improvements = 0.1%. Improvements = 0.2%.
N/A.................................. Automatic Tire Automatic Tire Automatic Tire
Inflation Systems = Inflation Systems = Inflation Systems =
0.2%. 0.4%. 0.4%.
N/A.................................. Weight Reduction = 0 Weight Reduction = 0 Weight Reduction = 0
lbs. lbs. lbs.
----------------------------------------------------------------------------------------------------------------
The baseline 2017 MY heavy-haul tractor would emit 57 grams of
CO2 per ton-mile and consume 5.6 gallons of fuel per 1,000
ton-mile. The agencies propose the heavy-haul standards shown in Table
III-20. We welcome comment on the heavy-haul tractor technology path
and standards proposed by the agencies.
Table III-20--Proposed Heavy-Haul Tractor Standards
------------------------------------------------------------------------
Heavy-haul tractor
--------------------------------------
2021 MY 2024 MY 2027 MY
------------------------------------------------------------------------
Grams of CO2 per Ton-Mile 54 52 51
Standard........................
Gallons of Fuel per 1,000 Ton- 5.3045 5.1081 5.010
Mile............................
------------------------------------------------------------------------
The technology costs associated with the proposed heavy-haul
tractor standards are shown below in Table III-21. We welcome comment
on the technology costs.
[[Page 40235]]
Table III-21--Heavy-Haul Tractor Technology Incremental Costs in the
2021, 2024, and 2027 Model Year \a\ \b\ Preferred Alternative vs. the
Less Dynamic Baseline
[2012$ per vehicle]
------------------------------------------------------------------------
2021 MY 2024 MY 2027 MY
------------------------------------------------------------------------
Engine \c\....................... $314 $904 $1,698
Tires............................ 81 78 75
Tire inflation system............ 180 330 314
Transmission..................... 3,969 5,883 6,797
Axle & axle lubes................ 70 128 200
Air conditioning................. 45 82 117
Other vehicle technologies....... 174 318 302
Total........................ 4,833 7,723 9,503
------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the specified model year and are incremental to
the costs of a 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 draft RIA (see draft 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 draft RIA (see draft RIA 2.12 in particular).
\c\ Engine costs are for a heavy HD diesel engine meant for a
combination tractor.
(e) Consistency of the Proposed Tractor Standards With the Agencies'
Legal Authority
The proposed HD Phase 2 standards are based on adoption rates for
technologies that the agencies regard, subject to consideration of
public comment, 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.2(b) through (d) above; see also draft RIA
Chapter 2.4. The agencies believe these technologies can be adopted at
the estimated rates for these standards within the lead time provided,
as discussed in draft RIA Chapter 2. 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 would 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
proposed 2027 MY standards is projected to range between $10,000 and
$13,000 (much or all of this would be mitigated by the fuel savings
during the first two years of ownership). The agencies note that while
the projected costs are significantly greater than the costs projected
for Phase 1, we still consider that cost to be reasonable, especially
given the relatively short payback period. In this regard the agencies
note that the estimated payback period for tractors of less than two
years \168\ 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.\169\ 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.\170\ 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
proposal is technology-forcing (especially with respect to aerodynamic
and tire rolling resistance 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 $20 in 2030, and we estimate the cost per gallon of
avoided fuel consumption to be about $0.25 per gallon, which compares
favorably with the levels of cost effectiveness the agencies found to
be reasonable for light duty trucks.171 172 See 77 FR 62922.
The proposed phase-in 2021 and 2024 MY standards are less stringent and
less costly than the proposed 2027 MY standards. For these reasons, and
because the agencies have carefully considered lead time, EPA believes
they are also reasonable under Section 202(a) of the CAA. Given that
the agencies believe the proposed standards are technically 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), the proposed standards 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).
---------------------------------------------------------------------------
\168\ See Draft RIA Chapter 7.1.3.
\169\ 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.
\170\ North American Council for Freight Efficiency. Barriers to
Increased Adoption of Fuel Efficiency Technologies in Freight
Trucking. July 2013. Page 24.
\171\ See Draft RIA Chapter 7.1.4.
\172\ 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 would be negative
under the proposed standards.
---------------------------------------------------------------------------
Based on the information before the agencies, we currently believe
that Alternative 3 would be maximum feasible and reasonable for the
tractor segment for the model years in question. The agencies believe
Alternative 4 has potential to be the maximum feasible and reasonable
alternative; however, based on the evidence currently before us, EPA
and NHTSA have outstanding questions regarding relative risks and
benefits of Alternative 4 due to the timeframe envisioned by the
alternative. Alternative 3 is generally designed to achieve the levels
of fuel consumption and GHG reduction that Alternative 4 would achieve,
but with several years of
[[Page 40236]]
additional lead-time--i.e., the Alternative 3 standards would end up in
the same place as the Alternative 4 standards, but several years later,
meaning that manufacturers could, in theory, apply new technology at a
more gradual pace and with greater flexibility. However, Alternative 4
would provide earlier GHG benefits compared to Alternative 3.
(f) 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-22.
Table III-22--Summary of Alternatives Considered for the Proposed
Rulemaking
------------------------------------------------------------------------
------------------------------------------------------------------------
Alternative 1..................... No action alternative
Alternative 2..................... Less Stringent than the Proposed
Alternative applying off-the-shelf
technologies.
Alternative 3 (Proposed Proposed Alternative fully phased-in
Alternative). by 2027 MY.
Alternative 4..................... Alternative that pulls ahead the
proposed 2027 MY standards to 2024
MY.
Alternative 5..................... Alternative based on very high
market adoption of advanced
technologies.
------------------------------------------------------------------------
When evaluating the alternatives, it is necessary to evaluate the
impact of a proposed 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. The purchaser often has
uncertainty in 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 selected the proposed standards over the more
stringent alternatives based on considering the relevant statutory
factors. In 2027, the proposed standards achieve up to a 24 percent
reduction in CO2 emissions and fuel consumption compared to
a Phase 1 tractor at a per vehicle cost of approximately $13,000.
Alternative 4 achieves the same percent reduction in CO2
emissions and fuel consumption compared to a Phase 1 tractor, but three
years earlier, at a per vehicle cost of approximately $14,000. The
alternative standards are projected to result in more emission and fuel
consumption reductions from the heavy-duty tractors built in model
years 2021 through 2026.\173\ We project the proposed standards to be
achievable within known design cycles, and we believe these standards
would allow different paths to compliance in addition to the one we
outline and cost here.
---------------------------------------------------------------------------
\173\ See Tables III-14 and III-27.
---------------------------------------------------------------------------
The agencies solicit comment on all of these issues and again note
the possibility of adopting, in a final action, standards that are more
accelerated than those proposed in Alternative 3. The agencies are also
assuming that both the proposed standards and Alternative 4 could be
accomplished with all changes being made during manufacturers' normal
product design cycles. However, we note 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.
The agencies are especially interested in seeking detailed comments
on Alternative 4. Therefore, we are including the details of the
Alternative 4 analysis below. The adoption rates considered for the
2021 and 2024 MY standards developed for Alternative 4 are shown below
in Table III-23 and Table III-24. The inputs to GEM used to develop the
Alternative 4 CO2 and fuel consumption standards are shown
below in Table III-25 and Table III-26. The standards associated with
Alternative 4 are shown below in Table III-27. Commenters are
encouraged to address all aspects of feasibility analysis, including
costs, the likelihood of developing the technology to achieve
sufficient relaibility within the proposed lead time, and the extent to
which the market could utilize the technology.
(g) Derivation of Alternative 4 Tractor Standards
The adoption rates considered for the 2021 and 2024 MY standards
developed for Alternative 4 are shown below in Table III-23 and Table
III-24. The inputs to GEM used to develop the Alternative 4
CO2 and fuel consumption standards are shown below in Table
III-25 and Table III-26. The standards associated with Alternative 4
are shown below in Table III-27. Commenters are encouraged to address
all aspects of feasibility analysis, including costs, the likelihood of
developing the technology to achieve sufficient relaibility within the
lead time.
[[Page 40237]]
Table III-23--Alternative 4 Adoption Rates for 2021 MY
--------------------------------------------------------------------------------------------------------------------------------------------------------
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
(%) (%) (%) (%) (%) (%) (%) (%) (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Alternative 4 2021MY Engine Technology Package
--------------------------------------------------------------------------------------------------------------------------------------------------------
100 100 100 100 100 100 100 100 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I.............................. 0 0 0 0 0 0 0 0 0
Bin II............................. 65 65 0 65 65 0 65 65 0
Bin III............................ 30 30 35 30 30 35 30 30 35
Bin IV............................. 5 5 30 5 5 30 5 5 30
Bin V.............................. N/A N/A 25 N/A N/A 25 N/A N/A 25
Bin VI............................. N/A N/A 10 N/A N/A 10 N/A N/A 10
Bin VII............................ N/A N/A 0 N/A N/A 0 N/A N/A 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............................ 45 45 45 45 45 45 45 45 45
Level 3............................ 15 15 15 15 15 15 15 15 15
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 5 5 5 5 5 5 5 5 5
Level 1............................ 35 35 35 35 35 35 35 35 35
Level 2............................ 45 45 45 45 45 45 45 45 45
Level 3............................ 15 15 15 15 15 15 15 15 15
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
APU................................ N/A N/A N/A N/A N/A N/A 80 80 80
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Type
--------------------------------------------------------------------------------------------------------------------------------------------------------
Manual............................. 25 25 25 25 25 25 25 25 25
AMT................................ 40 40 40 40 40 40 40 40 40
Auto............................... 30 30 30 30 30 30 30 30 30
Dual Clutch........................ 5 5 5 5 5 5 5 5 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Driveline
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Lubricant..................... 20 20 20 20 20 20 20 20 20
6x2 Axle........................... ........... ........... ........... 10 10 20 10 10 30
Downspeed.......................... 30 30 30 30 30 30 30 30 30
Direct Drive....................... 50 50 50 50 50 50 50 50 50
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements
--------------------------------------------------------------------------------------------------------------------------------------------------------
A/C................................ 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.......... 30 30 30 30 30 30 30 30 30
--------------------------------------------------------------------------------------------------------------------------------------------------------
Automated Tire Inflation System.... 30 30 30 30 30 30 30 30 30
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 40238]]
Table III-24--Alternative 4 Adoption Rates for 2024 MY
--------------------------------------------------------------------------------------------------------------------------------------------------------
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
(%) (%) (%) (%) (%) (%) (%) (%) (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Alternative 4 2024MY Engine Technology Package
--------------------------------------------------------------------------------------------------------------------------------------------------------
100 100 100 100 100 100 100 100 100
Aerodynamics
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I.............................. 0 0 0 0 0 0 0 0 0
Bin II............................. 50 50 0 50 50 0 50 50 0
Bin III............................ 40 40 20 40 40 20 40 40 20
Bin IV............................. 10 10 20 10 10 20 10 10 20
Bin V.............................. N/A N/A 35 N/A N/A 35 N/A N/A 35
Bin VI............................. N/A N/A 20 N/A N/A 20 N/A N/A 20
Bin VII............................ N/A N/A 5 N/A N/A 5 N/A N/A 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 5 5 5 5 5 5 5 5 5
Level 1............................ 20 20 20 20 20 20 20 20 20
Level 2............................ 50 50 50 50 50 50 50 50 50
Level 3............................ 25 25 25 25 25 25 25 25 25
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 5 5 5 5 5 5 5 5 5
Level 1............................ 20 20 20 20 20 20 20 20 20
Level 2............................ 50 50 50 50 50 50 50 50 50
Level 3............................ 25 25 25 25 25 25 25 25 25
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
APU................................ N/A N/A N/A N/A N/A N/A 90 90 90
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Type
--------------------------------------------------------------------------------------------------------------------------------------------------------
Manual............................. 10 10 10 10 10 10 10 10 10
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Driveline
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Lubricant..................... 40 40 40 40 40 40 40 40 40
6x2 Axle........................... ........... ........... ........... 20 20 60 20 20 60
Downspeed.......................... 60 60 60 60 60 60 60 60 60
Direct Drive....................... 50 50 50 50 50 50 50 50 50
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements
--------------------------------------------------------------------------------------------------------------------------------------------------------
A/C................................ 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.... 40 40 40 40 40 40 40 40 40
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 40239]]
Table III-25--Alternative 4 GEM Inputs for 2021MY
----------------------------------------------------------------------------------------------------------------
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 11L 2021MY 11L 2021MY 11L 2021MY 15L 2021MY 15L 2021MY 15L 2021MY 15L 2021MY 15L 2021MY 15L
Engine 350 Engine 350 Engine 350 Engine 455 Engine 455 Engine 455 Engine 455 Engine 455 Engine 455
HP--2% HP--2% HP--2% HP--2% HP--2% HP--2% HP--2% HP--2% HP--2%
reduction reduction reduction reduction reduction reduction reduction reduction reduction
----------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m\2\)
----------------------------------------------------------------------------------------------------------------
4.61 6.01 5.83 4.61 6.01 5.83 4.61 6.01 5.63
----------------------------------------------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9
----------------------------------------------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
6.2 6.2 6.2 6.2 6.2 6.2 6.2 6.2 6.2
----------------------------------------------------------------------------------------------------------------
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 Automated 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 = 3.45
----------------------------------------------------------------------------------------------------------------
6x2 Axle Weighted Effectiveness
----------------------------------------------------------------------------------------------------------------
N/A N/A N/A 0.3% 0.3% 0.8% 0.3% 0.3% 0.8%
----------------------------------------------------------------------------------------------------------------
Low Friction Axle Lubrication = 0.1%
----------------------------------------------------------------------------------------------------------------
Transmission benefit = 1.5%
----------------------------------------------------------------------------------------------------------------
Predictive Cruise Control = 0.6%
----------------------------------------------------------------------------------------------------------------
Accessory Improvements = 0.2%
----------------------------------------------------------------------------------------------------------------
Air Conditioner Efficiency Improvements = 0.1%
----------------------------------------------------------------------------------------------------------------
Automatic Tire Inflation Systems = 0.3%
----------------------------------------------------------------------------------------------------------------
Weight Reduction = 0 lbs
----------------------------------------------------------------------------------------------------------------
Direct Drive Weighted Efficiency = 1% for sleeper cabs; 0.8% for day cabs
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Table III-26--Alternative 4 GEM Inputs for 2024MY
----------------------------------------------------------------------------------------------------------------
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 11L 2021MY 11L 2021MY 11L 2021MY 15L 2021MY 15L 2021MY 15L 2021MY 15L 2021MY 15L 2021MY 15L
Engine 350 Engine 350 Engine 350 Engine 455 Engine 455 Engine 455 Engine 455 Engine 455 Engine 455
HP--4% HP--4% HP--4% HP--4% HP--4% HP--4% HP--4% HP--4% HP--4%
reduction reduction reduction reduction reduction reduction reduction reduction reduction
----------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m\2\)
----------------------------------------------------------------------------------------------------------------
4.52 5.92 5.52 4.52 5.92 5.52 4.52 5.92 5.32
----------------------------------------------------------------------------------------------------------------
[[Page 40240]]
Steer Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
5.6 5.6 5.6 5.6 5.6 5.6 5.6 5.6 5.6
----------------------------------------------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9
----------------------------------------------------------------------------------------------------------------
Extended Idle Reduction Weighted Effectiveness
----------------------------------------------------------------------------------------------------------------
N/A N/A N/A N/A N/A N/A 3% 3% 3%
----------------------------------------------------------------------------------------------------------------
Transmission = 10 speed Automated 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 = 3.2
----------------------------------------------------------------------------------------------------------------
6x2 Axle Weighted Effectiveness
----------------------------------------------------------------------------------------------------------------
N/A N/A N/A 0.5% 0.5% 1.5% 0.5% 0.5% 1.5%
----------------------------------------------------------------------------------------------------------------
Low Friction Axle Lubrication = 0.2%
----------------------------------------------------------------------------------------------------------------
Transmission benefit = 1.8%
----------------------------------------------------------------------------------------------------------------
Predictive Cruise Control = 0.8%
----------------------------------------------------------------------------------------------------------------
Accessory Improvements = 0.3%
----------------------------------------------------------------------------------------------------------------
Air Conditioner Efficiency Improvements = 0.2%
----------------------------------------------------------------------------------------------------------------
Automatic Tire Inflation Systems = 0.4%
----------------------------------------------------------------------------------------------------------------
Weight Reduction = 0 lbs
----------------------------------------------------------------------------------------------------------------
Direct Drive Weighted Efficiency = 1% for sleeper cabs; 0.8% for day cabs
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Table III-27--Tractor Standards Associated with Alternative 4
------------------------------------------------------------------------
Day cab Sleeper cab
------------------------------------------------------------------------
Class 7 Class 8 Class 8
------------------------------------------------------------------------
2021 Model Year CO2 Grams per Ton-Mile
------------------------------------------------------------------------
Low Roof......................... 92 74 66
Mid Roof......................... 102 81 74
High Roof........................ 104 82 73
------------------------------------------------------------------------
2021 Model Year Gallons of Fuel per 1,000 Ton-Mile
------------------------------------------------------------------------
Low Roof......................... 9.0373 7.2692 6.4833
Mid Roof......................... 10.0196 7.9568 7.2692
High Roof........................ 10.2161 8.0550 7.1709
------------------------------------------------------------------------
2024 Model Year CO2 Grams per Ton-Mile
------------------------------------------------------------------------
Low Roof......................... 87 70 62
Mid Roof......................... 96 76 69
High Roof........................ 96 76 67
------------------------------------------------------------------------
2024 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile
------------------------------------------------------------------------
Low Roof......................... 8.5462 6.8762 6.0904
Mid Roof......................... 9.4303 7.4656 6.7780
High Roof........................ 9.4303 7.4656 6.5815
------------------------------------------------------------------------
[[Page 40241]]
The technology costs of achieving the reductions projected in
Alternative 4 are included below in Table III-28 and Table III-29.
Table III-28-Class 7 and 8 Tractor Technology Incremental Costs in the 2021 Model Year Alternative 4 vs. the Less Dynamic Baseline \a\ \b\
(2012$ per vehicle)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
------------------------------------------------------------------------------------------
Low/mid Low/mid
roof High roof roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\................................................... $656 $656 $656 $656 $656 $656 $656
Aerodynamics................................................. 769 632 769 632 740 740 665
Tires........................................................ 50 11 83 18 61 61 18
Tire inflation system........................................ 271 271 271 271 271 271 271
Transmission................................................. 6,794 6,794 6,794 6,794 6,794 6,794 6,794
Axle & axle lubes............................................ 56 56 75 95 75 75 115
Idle reduction with APU...................................... 0 0 0 0 2,449 2,449 2,449
Air conditioning............................................. 90 90 90 90 90 90 90
Other vehicle technologies................................... 261 261 261 261 261 261 261
------------------------------------------------------------------------------------------
Total.................................................... 8,946 8,769 8,999 8,816 11,397 11,397 11,318
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2021 model year and are incremental to the costs of a 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 draft RIA (see draft 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 draft RIA (see draft
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.e).
Table III-29-Class 7 and 8 Tractor Technology Incremental Costs in the 2024 Model Year Alternative 4 vs. the Less Dynamic Baseline \a\ \b\
(2012$ per vehicle)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
------------------------------------------------------------------------------------------
Low/mid Low/mid
roof High roof roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\................................................... $1,885 $1,885 $1,885 $1,885 $1,885 $1,885 $1,885
Aerodynamics................................................. 805 935 805 935 773 773 997
Tires........................................................ 50 14 83 23 63 63 23
Tire inflation system........................................ 330 330 330 330 330 330 330
Transmission................................................. 7,143 7,143 7,143 7,143 7,143 7,143 7,143
Axle & axle lubes............................................ 102 102 138 210 138 138 210
Idle reduction with APU...................................... 0 0 0 0 2,687 2,687 2,687
Air conditioning............................................. 123 123 123 123 123 123 123
Other vehicle technologies................................... 318 318 318 318 318 318 318
------------------------------------------------------------------------------------------
Total.................................................... 10,757 10,851 10,826 10,968 13,461 13,461 13,717
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2024 model year and are incremental to the costs of a 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 draft RIA (see draft 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 draft RIA (see draft
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.e).
E. Proposed 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 propose to carry over many aspects of the Phase 1
compliance approach, but are proposing 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 regulatory structure considerations for Phase 2 are discussed
in more detail above in Section II. We welcome comment on all aspects
of the
[[Page 40242]]
compliance program including where we are not proposing any changes.
(a) Application and Certification Process
For the Phase 2 proposed rule, the agencies are proposing to keep
many aspects of the HD Phase 1 tractor compliance program. For example,
the agencies propose to 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 proposed fuel
efficiency and CO2 standards. Another aspect that we propose
to carry over is the overall compliance approach.
In Phase 1 and as proposed in Phase 2, the general compliance
process in terms of the pre-model year, during the model year, and post
model year activities remain unchanged. The manufacturers would
continue to be required to apply for certification through a single
source, EPA, with limited sets of data and GEM results (see 40 CFR
1037.205). EPA would 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
proposing a similar process for allowing credits for off-cycle
technologies that are not measured by the GEM simulation tool (see
Section I.B.v. for a more detailed discussion of off-cycle requests).
During the model year, the manufacturers would continue to generate
certification data and conduct GEM runs on each of the vehicle
configurations it builds. After the model year ends, the manufacturers
would 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 would jointly coordinate on any enforcement action required.
(b) Compliance Requirements
The agencies are also proposing not to change the following
provisions:
Useful life of tractors (40 CFR 1037.105(e) and 1037.106(e))
although added for NHTSA in Phase 2 (40 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)
(c) Drive Cycles 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 propose to maintain the existing drive cycles and
weighting. For sleeper cabs, the 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 cab results 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 40 CFR 1037.510(c)). One key
difference in the proposed drive cycles is the addition of grade,
discussed below in Section III.E.2.
The 55 mph and 65 mph drive cycles used in GEM assume constant
speed operation at nominal vehicle speeds 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.
The agencies therefore request 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. We also request data from fleet
operators or others that may track vehicle speed operation of heavy-
duty tractors.
(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 are proposing to carry
over the total weight of the tractor-trailer combination used in GEM
for Phase 1. The agencies developed the proposed tractor curb weight
inputs for Phase 2 from actual tractor weights measured in two of EPA's
Phase 1 test programs. The proposed 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.\174\
---------------------------------------------------------------------------
\174\ ICF International. Investigation of Costs for Strategies
to Reduce Greenhouse Gas Emissions for Heavy-Duty On-road Vehicles.
July 2010. Pages 4-15. Docket Number EPA-HQ-OAR-2010-0162-0044.
---------------------------------------------------------------------------
There 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 is full
before the weight limit is reached), and 30 percent are ``weighed out''
(operating weight equal 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).\175\
---------------------------------------------------------------------------
\175\ 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.\176\ 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
[[Page 40243]]
these data, the agencies are proposing 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. The agencies propose 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 proposed 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.''
---------------------------------------------------------------------------
\176\ 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.
---------------------------------------------------------------------------
Details of the proposed individual weight inputs by regulatory
category, as shown in Table III-30, are included in draft RIA Chapter
3. We welcome comment or new data to support changes to the tractor
weights, or refinements to the heavy-haul tractor, trailer, and payload
weights.
Table III-30--Proposed Combination Tractor Weight Inputs
----------------------------------------------------------------------------------------------------------------
Regulatory Tractor tare Trailer weight Total weight
Model type subcategory weight (lbs) (lbs) Payload (lbs) (lbs)
----------------------------------------------------------------------------------------------------------------
Class 8...................... Sleeper Cab 19,000 13,500 38,000 70,500
High 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 17,100 10,000 38,000 65,100
Roof.
Class 8...................... Day Cab Low 17,000 10,500 38,000 65,500
Roof.
Class 7...................... Day Cab High 11,500 13,500 25,000 50,000
Roof.
Class 7...................... Day Cab Mid 11,100 10,000 25,000 46,100
Roof.
Class 7...................... Day Cab Low 11,000 10,500 25,000 46,500
Roof.
Class 8...................... Heavy-Haul..... 19,000 13,500 86,000 118,500
----------------------------------------------------------------------------------------------------------------
(e) Tire Testing
In Phase 1, the 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 propose to carry over
the Phase 1 testing provisions for tire rolling resistance into Phase
2. We welcome comments regarding the proposed tire testing provisions.
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 (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 would
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 propose to allow the use of either Smithers or STL
laboratories for determining the tire rolling resistance value.
However, we welcome 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.
(2) Key Differences in HD Phase 2 Compliance Provisions
We welcome comment on all aspects of the compliance program for
which we are proposing changes.
(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
propose to continue this general approach in HD Phase 2, but make
several enhancements to the aerodynamic assessment of tractors. As
discussed below in this section, we propose some modifications to the
aerodynamic test procedures--the addition of wind averaged yaw 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.
(i) 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 and a procedure to align results from other
aerodynamic test procedures with the reference method.
The agencies adopted in Phase 1 an enhanced 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 test methods
to the reference method results using Falt-aero (see 40 CFR 1037.525).
Manufacturers are able to use any aerodynamic evaluation method in
demonstrating a vehicle's aerodynamic performance as long as the method
is aligned to the reference method. The agencies propose to continue to
use this alignment method
[[Page 40244]]
approach to maintain the testing flexibility that manufacturers have
today. However, the agencies propose to increase the rigor in
determining the Falt-aero for Phase 2. Beginning in 2021 MY, we propose
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
propose 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 propose 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 welcome comment on the burden associated with this
proposed change to conduct up to six coastdown tests per year per
manufacturer.
Based on feedback received during the development of Phase 1, we
understand that there is interest from some manufacturers to change the
reference method in Phase 2 from coastdown to constant speed testing.
EPA has 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 draft 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 propose to continue to use the enhanced coastdown
procedure for the reference method in Phase 2.\177\ However, we welcome
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 welcome comments on and suggested
revisions to the constant speed test procedure specifications set forth
in Chapter 3.2.2.2 of the draft RIA and 40 CFR 1037.533. If we
determine that it is appropriate to make the change, then the
aerodynamic bins in the final rule would be adjusted to take into
account the difference in absolute CdA values due to the change in
method.
---------------------------------------------------------------------------
\177\ Southwest Research Institute. ``Heavy Duty Class 8 Truck
Coastdown and Constant Speed Testing.'' April 2015.
---------------------------------------------------------------------------
The agencies are also considering refinements to the computational
fluid dynamics modeling method to determine the aerodynamic performance
of tractors. 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.\178\ The agencies welcome
comment on the proposed revisions.
---------------------------------------------------------------------------
\178\ 40 CFR 1037.531 ``Computational fluid dynamics (CFD)''.
---------------------------------------------------------------------------
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.\179\ In
addition, we are proposing 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 proposing to sunset the provision in 40 CFR 1037.150(k) at the
end of the Phase 1 program (after the 2020 model year). We request
comment on whether or not we should factor in a test variability
compliance margin into the aerodynamic test procedure, and therefore
request data on aerodynamic test variability.
---------------------------------------------------------------------------
\179\ Southwest Research Institute. ``Heavy Duty Class 8 Truck
Coastdown and Constant Speed Testing.'' April 2015.
---------------------------------------------------------------------------
(ii) Wind Averaged Drag
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.\180\ As noted in the NAS report, the wind
average drag coefficient is about 15 percent higher than the zero
degree coefficient of drag.\181\ 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.\182\ 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.
---------------------------------------------------------------------------
\180\ See 2010 NAS Report, page 95
\181\ See 2010 NAS Report, Finding 2-4 on page 39. Also see 2014
NAS Report, Recommendation 3.5.
\182\ 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
could potentially impact the overall technology effectiveness or change
the kinds of technology decisions made by the tractor manufacturers in
developing equipment to meet our proposed HD Phase 2 standards.
Therefore, we are proposing aerodynamic test procedures that take into
account the wind averaged drag performance of tractors. The agencies
propose 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 propose that beginning in 2021 MY, the manufacturers
would be required 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. We welcome data
evaluating the consistency of wind averaged drag measurements between
wind tunnel, CFD, and other potential methods such as constant speed or
coastdown. The agencies propose that manufacturers would use the
following equation to make the necessary adjustments to a coastdown
result to obtain the CdAwad value:
CdAwad = CdAzero,coastdown +
(CdAwad,wind tunnel-CdAzero,wind tunnel) *
Falt-aero
If the manufacturer has a wind averaged CdA value from either a
wind tunnel or CFD, then we propose they
[[Page 40245]]
would use the following equation to obtain the CdAwad value:
CdAwad = CdAwad,wind tunnel or CFD *
Falt-aero
We welcome comment on whether the wind averaged drag should be
determined using a full yaw sweep as specified in Appendix A of the
Society of Automotive Engineers (SAE) recommended practice number J1252
``SAE Wind Tunnel Test Procedure for Trucks and Buses'' (e.g., zero
degree yaw and a six other yaw angles at increments of 3 degrees or
greater) or a subset of specific angles as currently allowed in the
Phase 1 regulations.\183\
---------------------------------------------------------------------------
\183\ Proposed 40 CFR 1037.525(d)(2); ``Yaw Sweep Corrections''.
---------------------------------------------------------------------------
To reduce the testing burden the agencies propose 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. Details regarding the determination of the
offset are included in the draft RIA Chapter 3.2. We propose the
manufacturers would use the following equation if they had a zero yaw
coastdown value and choose not to conduct wind averaged measurements.
CdAwad = CdAzero,coastdown + 0.80
In addition, we propose the manufacturers would use the following
equation if they had a zero yaw wind tunnel or CFD value and choose not
to conduct wind averaged measurements.
CdAwad = (CdAzero,wind tunnel or CFD *
Falt-aero)+0.80
We welcome comments on all aspects of the proposed wind averaged
drag provisions.
(iii) Standard Trailer Definition
Similar to the approach the agencies adopted in Phase 1, NHTSA and
EPA are proposing provisions such that the tractor performance in GEM
is judged assuming the tractor is pulling a standardized trailer.\184\
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 would intuit: tractor-trailer pairings
are almost always optimized. EPA conducted an evaluation of over 4,000
tractor-trailer combinations using live traffic cameras in 2010.\185\
The results showed that approximately 95 percent of the tractors were
matched with the standard trailer specified (high roof tractor with box
trailer, mid roof tractor with tanker trailer, and low roof with
flatbed trailer). Therefore, the agencies propose that Phase 2 GEM
continue to use a predefined typical trailer defined in Phase 1 in
assessing overall performance for test purposes. As such, the high roof
tractors would be paired with a standard box trailer; the mid roof
tractors would be paired with a tanker trailer; and the low roof
tractors would be paired with a flatbed trailer.
---------------------------------------------------------------------------
\184\ See 40 CFR 1037.501(g).
\185\ See Memo to Docket, Amy Kopin. ``Truck and Trailer Roof
Match Analysis.'' August 2010.
---------------------------------------------------------------------------
However, the agencies are proposing to change the definition of the
standard box 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 \186\ and EPA's SmartWay
Transport Partnership. The standard box 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.187 188 As the agencies look towards the proposed
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. Therefore,
we are proposing that the standard box trailer in Phase 2--the trailer
assumed during the certification process to be paired with a high roof
tractor--be updated to include a trailer skirt starting in 2021 model
year. Even though the agencies are proposing new box trailer standards
beginning in 2018 MY, we are not proposing 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 need to revise the Phase
1 tractor standards. The details of the trailer skirt definition are
included in 40 CFR 1037.501(g)(1).
---------------------------------------------------------------------------
\186\ 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.
\187\ 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.
\188\ Frost & Sullivan, ``Strategic Analysis of North American
Semi-trailer Advanced Technology Market'', Feb 2013.
---------------------------------------------------------------------------
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 the draft 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 8 percent improvement in coefficient of drag area.
This off-set was used during the development of the Phase 2 aerodynamic
bins.
We seek comment on our proposed HD Phase 2 standard trailer
configuration. We also welcome comments on suggestions on alternative
ways to define the standard trailer, such as developing a certified
computer aided drawing (CAD) model.
(iv) Aerodynamic Bins
The agencies are proposing 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. The agencies
proposed 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, 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 proposed 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
[[Page 40246]]
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
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. These two new
bins would further segment the Phase 1 aerodynamic Bin V to recognize
the difference in advanced aerodynamic technologies and designs.
In both HD Phase 1 and as proposed by the agencies in 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 which
capitalize on a generally aerodynamic shape and avoid classic features
which increase drag. High roof tractors within Bin III build on the
basic aerodynamics of Bin II tractors with added components to reduce
drag in the most significant areas on the tractor, such as integral
roof fairings, side extending gap reducers, fuel tank fairings, and
streamlined grill/hood/mirrors/bumpers, similar to 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 propose 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 would move high roof tractors from a Bin III to Bins IV
through VII include features such as gap reducers and integral roof
fairings which would 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 are
proposing 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 aerodynamic
technologies in their compliance plan. We propose that low and mid roof
tractors may determine the aerodynamic bin based on the aerodynamic bin
of an equivalent high roof tractor, as shown below in Table III-31.
Table III-31--Proposed 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 I
Bin III Bin II
Bin IV Bin II
Bin V Bin III
Bin VI Bin III
Bin VII Bin IV
------------------------------------------------------------------------
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 proposed high roof bins are
included in Draft RIA Chapter 3.2.8. The proposed high roof tractor
bins are defined in Table III-32. The proposed revisions to the low and
mid roof tractor bins reflect the addition of two new aerodynamic bins
and are listed in Table III-33.
Table III-32--Proposed 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............................ >=7.5 >=7.5 >=7.3
Bin II........................... 6.8-7.4 6.8-7.4 6.6-7.2
Bin III.......................... 6.2-6.7 6.2-6.7 6.0-6.5
Bin IV........................... 5.6-6.1 5.6-6.1 5.4-5.9
Bin V............................ 5.1-5.5 5.1-5.5 4.9-5.3
Bin VI........................... 4.7-5.0 4.7-5.0 4.5-4.8
Bin VII.......................... <=4.6 <=4.6 <=4.4
------------------------------------------------------------------------
[[Page 40247]]
Aerodynamic Input to GEM (CdAwad in m\2\)
------------------------------------------------------------------------
Bin I............................ 7.6 7.6 7.4
Bin II........................... 7.1 7.1 6.9
Bin III.......................... 6.5 6.5 6.3
Bin IV........................... 5.8 5.8 5.6
Bin V............................ 5.3 5.3 5.1
Bin VI........................... 4.9 4.9 4.7
Bin VII.......................... 4.5 4.5 4.3
------------------------------------------------------------------------
Table III-33--Proposed 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............................. >=5.1 >=6.5 >=5.1 >=6.5 >=5.1 >=6.5
Bin II............................ 4.6-5.0 6.0-6.4 4.6-5.0 6.0-6.4 4.6-5.0 6.0-6.4
Bin III........................... 4.2-4.5 5.6-5.9 4.2-4.5 5.6-5.9 4.2-4.5 5.6-5.9
Bin IV............................ <=4.1 <=5.5 <=4.1 <=5.5 <=4.1 <=5.5
----------------------------------------------------------------------------------------------------------------
Aerodynamic Input to GEM (CdA in m\2\)
----------------------------------------------------------------------------------------------------------------
Bin I............................. 5.3 6.7 5.3 6.7 5.3 6.7
Bin II............................ 4.8 6.2 4.8 6.2 4.8 6.2
Bin III........................... 4.3 5.7 4.3 5.7 4.3 5.7
Bin IV............................ 4.0 5.4 4.0 5.4 4.0 5.4
----------------------------------------------------------------------------------------------------------------
(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.\189\ 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.\190\ 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 shows 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.\191\
---------------------------------------------------------------------------
\189\ 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.
\190\ Ibid.
\191\ Reinhart, T. (2015). Commercial Medium- and Heavy-Duty
(MD/HD) Truck Fuel Efficiency Technology Study--Report #2.
Washington, DC: National Highway Traffic Safety Administration.
Table III-34--Fuel Consumption Relative to Road Grade
------------------------------------------------------------------------
Average fuel Average fuel
Type of terrain economy (miles per consumption
gallon) (gallons per mile)
------------------------------------------------------------------------
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
------------------------------------------------------------------------
[[Page 40248]]
In Phase 1, the agencies did not include road grade. However, we
believe it is important to propose including 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 would be consistent with the NAS recommendation in the
2014 Phase 2 First Report.\192\
---------------------------------------------------------------------------
\192\ 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 have partnered to support a
project aimed at evaluating, refining and/or developing the appropriate
road grade profiles for the 55 mph and 65 mph highway cruise duty
cycles that would be used in the certification of heavy-duty vehicles
to the Phase 2 GHG emission and fuel efficiency standards. The National
Renewable Energy Laboratory (NREL) was contracted to do this work and
has since developed two pairs of candidate, activity-weighted road
grade profiles representative of U.S. limited-access highways. To this
end, NREL used high-accuracy road grade data and county-specific
vehicle miles traveled data. One pair of the profiles is representative
of the nation's limited-access highways with 55 and 60 mph speed
limits, and another is representative of such highways with speed
limits of 65 to 75 mph. The profiles are distance-based and cover a
maximum distance of 12 and 15 miles, respectively. A report documenting
this NREL work is in the public docket for these proposed rules, and
comments are requested on the recommendations therein.\193\ In addition
to NREL work, the agencies have independently developed yet another
candidate road grade profile for use in the 55 mph and 65 mph highway
cruise duty cycles. 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 memorandum to the docket.\194\ The agencies have
evaluated all of the candidate road grade profiles and have prepared
possible alternative tractor standards based on these profiles. The
agencies request comment on this analysis, which is available in a
memorandum to the docket.\195\
---------------------------------------------------------------------------
\193\ 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.
\194\ Memorandum dated April 2015 on Possible Tractor, Trailer,
and Vocational Vehicle Standards Derived from Alternative Road Grade
Profiles.
\195\ Ibid.
---------------------------------------------------------------------------
For the proposal, the agencies developed an interim road grade
profile for development of the proposed standards. The agencies are
proposing the inclusion of an interim road grade profile, as shown
below in Figure III-2, 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.\196\ The minimum grade
in the interim cycle is -2.1 percent and the maximum grade is 2.4
percent. The cycle spends 30 percent of the distance in grades of +/-
0.5 percent. Overall, the cycle spends approximately 50 percent of the
time in relatively flat terrain with road gradients of less than 1
percent.
---------------------------------------------------------------------------
\196\ 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://www.epa.gov/otaq/climate/regs-heavy-duty.htm.
---------------------------------------------------------------------------
The agencies believe the interim cycle has sufficient
representativeness based on a comparison to data from the Department of
Transportation used in the development of the light-duty Federal Test
Procedure cycle (FTP), which found approximately 55 percent of the
vehicle miles traveled were on road gradients of less than 1
percent.\197\ Consequently, we expect that road grade profiles
developed by NREL and by the agencies will not differ significantly
from the interim profile proposed here. The agencies request data from
fleet operators or others that have real world grade profile data.
---------------------------------------------------------------------------
\197\ U.S. EPA. FTP Preliminary Report. May 14, 1993. Table 5-1,
page 76. EPA-420-R-93-007.
[GRAPHIC] [TIFF OMITTED] TP13JY15.003
(c) 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 propose carrying 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
[[Page 40249]]
the proposed (or alternative) standards, can still be recognized in GEM
up to a point. In addition, the agencies propose to add additional
thermoplastic components to the weight reduction table, as shown below
in Table III-35. The thermoplastic component weight reduction values
were developed in coordination with SABIC, a thermoplastic component
supplier. Also, in Phase 2, we are proposing 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.\198\ We propose including the values
listed in Table III-36 and make them available upon promulgation of the
final Phase 2 rules (i.e., available even under Phase 1). We welcome
comments on all aspects of weight reduction.
---------------------------------------------------------------------------
\198\ North American Council for Freight Efficiency.
``Confidence Findings on the Potential of 6x2 Axles.'' 2014. Page
16.
Table III-35--Proposed Phase 2 Weight Reduction Technologies for Tractors
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Weight reduction technology Weight reduction
(lb per tire/wheel)
----------------------------------------------------------------------------------------------------------------
Single Wide Drive Tire with..................... Steel Wheel............................ 84
Aluminum Wheel......................... 139
Light Weight Aluminum Wheel............ 147
Steer Tire or Dual Wide Drive Tire with......... High Strength Steel Wheel.............. 8
Aluminum Wheel......................... 21
Light Weight Aluminum Wheel............ 30
----------------------------------------------------------------------------------------------------------------
Aluminum High strength Thermoplastic
weight steel weight weight
Weight reduction technologies 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 11 ...............
Brake Drums--Non Drive (per 2)............................... 60 8 ...............
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 ...............
Driveshaft (per vehicle)..................................... 20 5 ...............
Transmission/Clutch Shift Levers (per vehicle)............... 20 4 ...............
----------------------------------------------------------------------------------------------------------------
Table III-36--Proposed Phase 2 Weight Reduction Values for Other
Components
------------------------------------------------------------------------
Weight reduction
Weight reduction technology (lb)
------------------------------------------------------------------------
6x2 axle configuration in tractors................ 300
4x2 axle configuration in Class 8 tractors........ 300
Tractor engine with displacement less than 14.0L.. \199\300
CI Liquified Natural Gas tractor.................. \200\ \201\-600
SI Compressed Natural Gas tractor................. -525
[[Page 40250]]
CI Compressed Natural Gas tractor................. -900
------------------------------------------------------------------------
(d) GEM Inputs
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\199\ 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.
\200\ National Energy Policy Institute. ``What Set of Conditions
Would Make the Business Case to Convert Heavy Trucks to Natural
Gas?--A Case Study.'' May 1, 2012. Last accessed on December 15,
2014 at http://www.tagnaturalgasinfo.com/uploads/1/2/2/3/12232668/natural_gas_for_heavy_trucks.pdf.
\201\ Westport presentation (2013). Last accessed on December
15, 2014 at http://www.westport.com/file_library/files/webinar/2013-06-19_CNGandLNG.pdf.
---------------------------------------------------------------------------
The agencies propose 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, and
Vehicle Speed Limiter.
As discussed above in Section II.C and III.D, there are several
additional inputs that are proposed for Phase 2. The new GEM inputs
proposed for Phase 2 include the following:
Engine information including manufacturer, model,
combustion type, fuel type, family name, and calibration identification
Engine fuel map,
Engine full-load torque curve,
Engine motoring curve,
Transmission information including manufacturer and model
Transmission type,
Transmission gear ratios,
Drive axle ratio,
Loaded tire radius for drive tires, and
Other technology inputs.
The agencies welcome comments on the inclusion of these proposed
technologies into GEM in Phase 2.
(e) Vehicle Speed Limiters and Extended Idle 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); 42 U.S.C. 7522(a)(3)(A)) of vehicle speed limiters and
extended idle reduction technologies would prohibit 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 are not proposing to change
those provisions (see 40 CFR 1037.640). However, as we develop Phase 2,
we understand 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 welcome 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 42 U.S.C. 7522(a)(3)(A). We request comment on potential
approaches which would enable 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 which also provides the
vehicle owner/fleet the flexibility they many 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 which is currently
limited to the directly regulated truck manufacturers. VSLs and
extended idle systems were two example technologies that fleets and
individual owners can order for a new build truck, and that from the
fleet's perspective the truck manufacturers receive emission credits
for. The agencies do not have a specific proposal or a position on the
request from the American Trucking Association and its members, but we
request 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.
(f) 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 proposed emission control systems for greenhouse gas
emissions in Phase 2 has increased significantly. For example, the
engine, transmission, drive axle ratio, accessories, tire radius, wind
averaged drag, predictive cruise control, and automatic tire inflation
system 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 as proposed 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 proposes 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 may finalize requirements to maintain
some label content to facilitate a limited visual inspection of key
vehicle parameters that can be readily observed. Such requirements may
be very similar to the labeling requirements from the Phase 1
rulemaking, though we would want to more carefully consider the list of
technologies that would allow for the most effective inspection. We
request comment on an appropriate list of candidate technologies that
would properly balance the need to limit label content with the
interest in providing the most useful information for inspectors to
confirm that vehicles have been properly built. We are not proposing to
modify the existing emission control labels for tractors certified for
MYs 2014-2020 (Phase 1) CO2 standards.
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
[[Page 40251]]
on a same-day basis, or within 24 hours of a request at most. We
request comment on any practical limitations in promptly providing this
information. We also request comment on approaches that would minimize
burden for manufacturers to respond to requests for vehicle build
information and would expedite an authorized compliance inspector's
visual inspection. For example, 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 would 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 request
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 may consider initiating a separate rulemaking effort to
propose and request comment on implementing such an approach.
(g) 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 propose 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 are accordingly
proposing to eliminate the end of year report, which represents a
preliminary set of ABT figures for the preceding year. We welcome
comment on this proposed revision.
(h) Special Compliance Provisions
In Phase 2, the agencies propose to consider 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 proposes 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)). In Phase 2, we no longer see the need to prohibit the
use of vocational engines in tractors because the performance of the
engine would be appropriately reflected in GEM. We welcome comment on
removing this prohibition.
The agencies also propose 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 is
proposing to remove its off-road petitioning process in 49 CFR 535.8
and EPA is proposing to add requirements for informal approvals in 40
CFR 1037.610.
(i) 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 proposes that the manufacturers conduct annual
chassis dynamometer testing of three sleeper cabs tractor and two day
cab tractor and provide the data and the GEM result from each of these
two tractor configurations to EPA (see 40 CFR 1037.665). We request
comment on the costs and efficacy of this data submission requirement.
We emphasize that this program would not be used for compliance or
enforcement purposes.
F. Flexibility Provisions
EPA and NHTSA are proposing 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 which generated the credit.
The agencies are also proposing to remove or modify 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 propose to carry-over
the Phase 1 ABT provisions for tractors into Phase 2.
The agencies propose to continue 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. Although we are not proposing any additional restrictions on
the use of Phase 1 credits, we are requesting comment on this issue.
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 proposed Phase 2
program. This appears especially likely for tractors. The agencies are
specifically requesting comment on the likelihood of this happening,
and whether any regulatory changes would be appropriate. For example,
should the agencies limit the amount of credits than could be carried
[[Page 40252]]
over from Phase 1 or limit them to the first year or two of the Phase 2
program? Also, if we determine that large surpluses are likely, how
should that factor into our decision on the feasibility of more
stringent standards in MY 2021?
We welcome comments on these proposed flexibilities and are
interested in information that may indicate doing as proposed could
distort the heavy-duty vehicle market.
(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
propose to largely continue, but redesignate the Phase 1 innovative
technology program as part of the off-cycle program for Phase 2. In
other words, beginning in 2021 MY all technologies that are not fully
accounted for in the GEM simulation tool, or by compliance dynamometer
testing could be considered off-cycle, including those technologies
that may have been considered innovative technologies in Phase 1 of the
program. The agencies propose 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. For additional information on the
treatment of off-cycle technologies see Section I.C.1.c.
The agencies are proposing a split process for handling off-cycle
technologies in Phase 2. First, there is a set of predefined off-cycle
technologies that are entering the market today, but could be fully-
recognized in our proposed HD Phase 2 certification procedures.
Examples of such technologies include predictive cruise control, 6x2
axles, axle lubricants, automated tire inflation systems, and air
conditioning efficiency improvements. For these technologies, the
agencies propose to define the effectiveness value of these
technologies similar to the approach taken in the MY2017-2025 light-
duty rule (see 77 FR 62832-62840 (October 15, 2012)). These default
effectiveness values could be used as valid inputs to Phase 2 GEM. The
proposed effectiveness value of each technology is discussed above in
Section III.D.2.
The agencies also recognize that there are emerging technologies
today that are being developed, but would not be accounted for in the
GEM inputs, therefore would be considered off-cycle. These technologies
could include systems such as efficient steering systems, cooling fan
optimization, and further tractor-trailer integration. These off-cycle
technologies could include known, commercialized technologies if they
are not yet widely utilized in a particular heavy-duty sector
subcategory. Any credits for these technologies would 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.
The agencies propose that the approval for Phase 1 innovative
technology credits (approved prior to 2021 MY) would 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 would not be required to request new approval for any
innovative credits carried into the off-cycle program, but would have
to demonstrate the new cycle does not account for these improvements
beginning in the 2021 MY. 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. The agencies also
seek comments on whether off-cycle technologies in the Phase 2 program
should be limited by infrequent common use and by what model years, if
any. We also seek comments on an appropriate penetration rate for a
technology not to be considered in common use.
As in Phase 1, the agencies are proposing to 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 proposed 40 CFR 1037.610
and 49 CFR 535.7. The first path would not require a public approval
process of the test method. A manufacturer could 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 would be required to be approved
prior to collecting any test data. The agencies are also proposing to
continue 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
proposing to modify their provisions to clarify what documentation must
be submitted for approval, which would align them with provisions in 40
CFR 86.1869-12. NHTSA and EPA are also proposing to prohibit credits
from technologies addressed by any of NHTSA's crash avoidance safety
rulemakings (i.e., congestion management systems). See 77 FR 62733
(discussing similar issues in the context of the light-duty fuel
economy and greenhouse gas reduction standards). We welcome
recommendations on how to improve or streamline the off-cycle
technology approval process.
(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 would
thus apply for trailers regulated in Phase 2. EPA is proposing to
continue this provision and requests comment on it.
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 would 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
[[Page 40253]]
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 42 U.S.C. 7522(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 that the modifications would not
cause the vehicle to exceed any applicable standard.
(4) Other Interim Provisions
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 2016 and 2017 model years. In discussion 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 XIV.A.1 for a discussion of
regulatory changes proposed to reduce the non-GHG certification burden
for engines paired with hybrid powertrain systems.
(5) Phase 1 Flexibilities Not Proposed for Phase 2
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(i)). 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 proposed 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 proposed
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. Therefore, we propose to not provide
advanced technology credits in Phase 2 for any technology, but we
welcome comments on the need for such incentive.
Also in Phase 1, the agencies adopted early credits 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 are not proposing 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 would displace
the need for early credits.
IV. Trailers
As mentioned in Section III, trailers pulled by Class 7 and 8
tractors (together considered ``tractor-trailers'') account for
approximately two-thirds 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 (1) and
(2) above.
The agencies are proposing standards for trailers specifically
designed to be drawn by Class 7 and 8 tractors when coupled to the
tractor's fifth wheel. The agencies are not proposing standards for
trailers designed to be drawn by vehicles other than tractors, and
those that are coupled to vehicles with pintle hooks or hitches instead
of a fifth wheel. These proposed standards are expressed as
CO2 and fuel consumption standards, and would apply to each
trailer with respect to the emissions and fuel consumption that would
be expected for a specific standard type of tractor pulling such a
trailer. Note that this approach is discussed in more detail later.
Nevertheless, EPA and NHTSA believe it is appropriate to establish
standards for trailers separately from tractors because they are
separately manufactured by distinct companies; the agencies are not
aware of any manufacturers that currently assemble both the finished
tractor and the trailer.
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). We chose
not to regulate trailers at that time, primarily because of the lack of
a proposed test procedure, as well as the technical and policy issues
at that time. The agencies also noted the large number of small
businesses in this industry, the possibility that regulations would
substantially impact these small businesses, and the agencies'
consequent obligations under the Small Business Regulatory Enforcement
Fairness Act.\202\ However, the agencies did indicate the potential
CO2 and fuel consumption benefits of including trailers in
the program and we committed to consider establishing standards for
trailers in future rulemakings.
---------------------------------------------------------------------------
\202\ The Regulatory Flexibility Act (RFA), as amended by the
Small Business Regulatory Enforcement Fairness Act (SBREFA),
requires agencies to account for economic impacts of all rules that
may have a significant impact on a substantial number of small
businesses and in addition contains provisions specially applicable
to EPA requiring a multi-agency pre-proposal process involving
outreach and consultation with representatives of potentially
affected small businesses. See http://www.epa.gov/rfa/ for more
information. Note that for this Phase 2 proposal, EPA has completed
a Small Business Advocacy Review panel process that included small
trailer manufacturers, as discussed in XIV.C below.
---------------------------------------------------------------------------
In the Phase 1 proposal, the agencies solicited general comments on
controlling CO2 emissions and fuel consumption through
future trailer regulations (see 75 FR 74345-74351). Although we neither
proposed nor finalized trailer regulations at that time, the agencies
have considered those comments in developing this proposal. This notice
proposes 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
intend for 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.
B. The Trailer Industry
(1) Industry Characterization
The trailer industry encompasses a wide variety of trailer
applications and designs. Among these are box trailers (dry vans and
refrigerated vans of all sizes) and ``non-box'' trailers, including
platform (sometimes called ``flatbed''), tanker, 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
(called ``highway trailers'' for purposes of this proposed rule). A
relatively small number of trailers are designed for dedicated use in
logging and mining operations or for use in
[[Page 40254]]
applications that we expect would involve little or no time on paved
roadways. A more detailed description of the characteristics that
distinguish these trailers is included in Section IV.C.(5).
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 trailers 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 trailer 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.
Non-box trailers are uniquely designed to transport a specific type
of freight. Platform trailers carry cargo that may not be easily
contained within or loaded and unloaded into a box trailer, such as
large, nonuniform equipment or machine components. Tank trailers are
often pressure-tight 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, automobile hauler, livestock
trailers, construction and heavy-hauling trailers.
Chapter 1 of the Draft RIA includes a more thorough
characterization of the trailer industry. The agencies have considered
the variety of trailer designs and applications in developing the
proposed CO2 emissions and fuel consumption standards for
trailers.
(2) Historical Context for Proposed Trailer Provisions
(a) SmartWay Program
EPA's voluntary SmartWay Transport Partnership program encourages
businesses to take actions that reduce fuel consumption and
CO2 emissions while cutting costs. See Section I.A.2.f
above. SmartWay staff work with the shipping, logistics, and carrier
communities to identify low carbon strategies and technologies across
their transportation supply chains. It is a voluntary, fleet-targeted
program that provides an objective ranking of a fleet's freight
efficiency relative to its competitors. SmartWay Partners commit to
adopting fuel-saving practices and technologies relative to a baseline
year as well as tracking their progress.
EPA's SmartWay program has accelerated the availability and market
penetration of advanced, fuel efficient technologies and operational
practices. In conjunction with the SmartWay Partners 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
and low rolling resistance tires and maintains a list of verified
technologies on its Web site. The trailer aerodynamic technologies
verified are grouped in bins that represent one percent, four percent,
or five percent fuel savings relative to a typical long-haul tractor-
trailer at 65-mph cruise conditions. Historically, use of verified
aerodynamic devices totaling at least five percent fuel savings, along
with verified tires, qualifies a 53-foot dry van trailer for the
``SmartWay Trailer'' designation. In 2014, EPA expanded the program to
qualify trailers as ``SmartWay Elite'' if they use verified tires and
aerodynamic equipment providing nine percent or greater fuel savings.
The 2014 updates also expanded the SmartWay-designated trailer
eligibility to include 53-foot refrigerated van trailers in addition to
53-foot dry van trailers.
The SmartWay Technology Program continues to improve the technical
quality of data that EPA and stakeholders need for verification. EPA
bases its SmartWay verifications on common industry test methods using
SmartWay-specified testing protocols. Historically, SmartWay's
aerodynamic equipment verification was performed using the SAE J1321
test procedure, which measures fuel consumption as the test vehicle
drives laps around a test track. Under SmartWay's 2014 updates, EPA
expanded its trailer designation and equipment verification programs to
allow additional testing options. The updates included a new, more
stringent 2014 track test protocol based on SAE's 2012 update to its
SAE J1321 test method,\203\ as well as protocols for wind tunnel,
coastdown, and possibly computational fluid dynamics (CFD) approaches.
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 \204\ methods), EPA's own testing and research, and lessons
learned from years of implementing technology verification programs.
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.\205\
---------------------------------------------------------------------------
\203\ SAE International, Fuel Consumption Test Procedure--Type
II. SAE Standard J1321. Revised 2012-02-06. Available at: http://standards.sae.org/j1321_201202/.
\204\ 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/.
\205\ 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.
---------------------------------------------------------------------------
SmartWay 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-trailer. SmartWay-verified trailer
tires achieve a CRR of 5.1 kg/metric ton or less on the
ISO28580 test method. 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.
Over the last decade, SmartWay partners have demonstrated
measureable fuel consumption benefits by adding aerodynamic features
and low rolling resistance tires to their 53-foot dry van trailers. To
date, SmartWay has verified over 70 technologies, including nine
packages from five manufacturers that have received the Elite
designation. The SmartWay Transport 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 in the HD
vehicle technology industry, have 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
[[Page 40255]]
that reduce CO2 emissions and fuel consumption.
(b) 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 foot or longer dry and
refrigerated box trailers that operate in California.\206\ 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 trailers
or to retrofit trailers with SmartWay-verified technologies. 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.\207\
---------------------------------------------------------------------------
\206\ Recently, 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.
\207\ 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).
---------------------------------------------------------------------------
(c) 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 will continue to be required to meet current safety
regulations for the trailers they produce. We welcome any comments on
additional regulations that are not included and particularly those
that may be incompatible with the regulations outlined in this
proposal.
FMVSS Nos. 223 and 224 \208\ 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. The agencies request comment on any issues associated with
installing potential boat tails or other rear aerodynamic fairings that
would be more effective than current designs, given the current
definition of trailer rear extremity in FMVSS 223.
---------------------------------------------------------------------------
\208\ 49 CFR 571.223, 224.
Table IV--1 Current NHTSA Statutes and Regulations Related to Trailers
------------------------------------------------------------------------
Reference Title
------------------------------------------------------------------------
49 CFR 565............................. Vehicle Identification Number
(VIN) Requirements.
49 CFR 566............................. Manufacturer Identification.
49 CFR 567............................. Certification.
49 CFR 568............................. Vehicles Manufactured in Two or
More Stages.
49 CFR 569............................. Regrooved Tires.
49 CFR 571............................. Federal Motor Vehicle Safety
Standards.
49 CFR 573............................. Defect and Noncompliance
Responsibility and Reports.
49 CFR 574............................. Tire Identification and
Recordkeeping.
49 CFR 575............................. Consumer Information.
49 CFR 576............................. Record Retention.
------------------------------------------------------------------------
(d) 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.\209\ 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.\210\
EPA and NHTSA do not anticipate any conflicts between FHWA's
regulations and those proposed in this rulemaking.
---------------------------------------------------------------------------
\209\ 23 CFR 658.9.
\210\ 23 CFR part 658.
---------------------------------------------------------------------------
(3) Agencies' Outreach in Developing This Proposal
In developing this proposed rule, EPA and NHTSA staff met and
consulted with a wide range of organizations that have an interest in
trailer regulations. Staff from both agencies met representatives of
the Truck Trailer Manufacturers Association, the National Trailer
Dealers Association, and the American Trucking Association, including
their Fuel Efficiency Advisory Committee and their Technology and
Maintenance Council. We also met with and visited the facilities of
several individual trailer manufacturers, trailer aerodynamic device
manufacturing companies, and trailer tire manufacturers, as well as
visited an aerodynamic wind tunnel test facility and two independent
tire testing facilities. The agencies consulted with representatives
from California Air Resources Board, the International Council on Clean
Transportation, the North American Council for Freight Efficiency, and
several environmental NGOs.
In addition to these informal meetings, and as noted above, EPA
also conducted several outreach meetings with representatives from
small business trailer manufacturers as required under section 609(b)
of the Regulatory Flexibility Act (RFA) and amended by the Small
Business Regulatory Enforcement Fairness Act of 1996 (SBREFA). EPA
convened a Small Business Advocacy Review (SBAR) Panel, and additional
information regarding the findings and recommendations of the Panel are
available in Section XIV below and in the Panel's final report.\211\
EPA worked with NHTSA to propose flexibilities in response to EPA's
SBAR Panel (as outlined in Section IV. F(6)(f) with more detail
provided in Chapter 12 of the draft RIA). We welcome comments from all
entities and the public to all aspects of this proposal.
---------------------------------------------------------------------------
\211\ 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, January 15, 2015.
---------------------------------------------------------------------------
C. Proposed Phase 2 Trailer Standards
This proposed rule proposes, for the first time, a set of
CO2 emission and fuel consumption standards for
manufacturers of new trailers that would phase in over a period of nine
years and continue to reduce CO2 emissions and fuel
consumption in the years to follow. The proposed 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 are proposing trailer standards that we believe well
implement our respective statutory obligations. The agencies believe
that a proposed set of standards with similar stringencies, but less
lead-time (referred to as ``Alternative 4'' and discussed in more
detail later) has the potential to be the maximum feasible alternative
within the meaning of section 32902 (k) of EISA, and appropriate under
EPA's CAA authority (sections 202 (a)(1) and (2)). However, based on
the evidence
[[Page 40256]]
currently before us, EPA and NHTSA have outstanding questions regarding
relative risks and benefits of Alternative 4 due to the timeframe
envisioned by that alternative. The proposed alternative (referred to
as ``Alternative 3'' and discussed in more detail later) is generally
designed to achieve the levels of fuel consumption and GHG reduction
that Alternative 4 would achieve, but with several years of additional
lead-time. Put another way, the Alternative 3 standards would result in
the same stringency as the Alternative 4 standards, but several years
later, meaning that manufacturers could, in theory apply new technology
at a more gradual pace and with greater flexibility. Additional lead-
time will also provide for a more gradual implementation of full
compliance program, which could be especially helpful for this newly-
regulated trailer industry. It is possible that the agencies could
adopt, in full or in part, stringencies from Alternative 4 in the final
rule. The agencies seek comment on the lead-time and market penetration
in these alternatives.
The agencies are not proposing standards for CO2
emissions and fuel consumption from the transport refrigeration units
(TRUs) used on refrigerated box trailers. Additionally, EPA is not
proposing standards for hydrofluorocarbon (HFC) emissions from TRUs.
See Section IV.C.(4)
It is worth noting that the proposed standards for box trailers are
based in part on the expectation that the proposed program would allow
emissions averaging. However, as discussed in Section IV.F. below,
given the specific structure and competitive nature of the trailer
industry, we request comment on the advantages and disadvantages of
implementing the proposed standards without an averaging program.
Commenters addressing the stringency of the proposed standards are
encouraged to address stringency in the context of compliance programs
with and without averaging.
(1) Trailer Designs Covered by This Proposed Rule
As described previously, the trailer industry produces many
different trailer designs for many different applications. The agencies
are proposing standards for a majority of these trailers. Note that
these proposed regulations apply to trailers designed for being drawn
by a tractor when coupled to the tractor's fifth wheel. As described in
detail in Section IV.C below, the agencies are proposing standards that
would phase in between MY 2018 and 2027; the NHTSA standards would be
voluntary until MY 2021. The proposed standards would apply to most
types of trailers. For most box trailers, these standards would be
based on the use of various technologies to improve aerodynamic
performance, and on improved tire efficiency through low rolling
resistance tires and use of automatic tire inflation (ATI) systems. As
discussed below, the agencies have identified some trailers with
characteristics that limit the aerodynamics that can be applied, and
are proposing reduced the stringencies for those trailer types. As
described in Sections IV.D.(1)(d) and (2)(d) below, although
manufacturers can reduce trailer weight to reduce fuel costs by
reducing trailer weight, these standards are not predicated on weight
reduction for the industry.
The most comprehensive set of proposed requirements would apply to
long box trailers, which include refrigerated and non-refrigerated
(dry) vans. Long box trailers are the largest trailer category and are
typically paired with high roof cab tractors that have high annual
vehicle miles traveled (VMT) and high average speeds, and therefore
offer the greatest potential for CO2 and fuel consumption
reductions. Many of the aerodynamic and tire technologies considered
for long box trailers in this proposal are similar to those used in
EPA's SmartWay program and required by California's Heavy-Duty
Greenhouse Gas Emission Reduction Regulation. Many manufacturers and
operators of box trailers have experience with these CO2-
and fuel consumption-reducing technologies. In addition to SmartWay
partners and those fleets affected by the California regulation, many
operators also seek such technologies in response to high fuel prices
and the prospect of improved fuel efficiency. As a result, more data
about the performance of these technologies exist for long box trailers
than for other trailer types. Short box vans do not have the benefit of
programs such as SmartWay to provide an incentive for development of
and a reliable evaluation and promotion of CO2- and fuel
consumption-reducing technologies for their trailers. In addition,
short box trailers are more frequently used in short-haul and urban
operations, which may limit the potential effectiveness of these
technologies. As such, EPA is proposing less stringent requirements for
manufacturers of short box trailers.
Some trailer designs include features that can affect the
practicality or the effectiveness of devices that manufacturers may
consider to lower their CO2 emissions and fuel consumption.
We are proposing to recognize box trailers that are restricted from
using aerodynamic devices in one location on the trailer as ``partial-
aero'' box trailers.\212\ The proposed standards for these trailers are
based on the proposed standards for full-aero box-trailers, but would
be less stringent than when the program is fully phased in.
---------------------------------------------------------------------------
\212\ Examples of types of work-performing components,
equipment, or designs that the agencies might consider as warranting
recognition as partial-aero or non-aero trailers include side or end
lift gates, belly boxes, pull-out platforms or steps for side door
access, and drop-deck designs. See 40 CFR 1037.107 and 49 CFR
535.5(e).
---------------------------------------------------------------------------
We propose that box trailers that have work-performing devices in
two locations such that they inhibit the use of all practical
aerodynamic devices be considered ``non-aero'' box trailers in this
proposal. The proposed standards for non-aero box trailers are
predicated on the use of tire technologies--lower rolling resistance
tires and ATI. We are proposing similar standards for non-box trailers
(including applications such as dump trailers and agricultural trailers
that are designed to be used both on and off the highway).
We are proposing to completely exclude several types of trailers
from this trailer program. These excluded trailers would include those
designed for dedicated in-field operations related to logging and
mining. In addition, we are proposing to exclude heavy-haul trailers
and trailers the primary function of which is performed while they are
stationary. For all of these excluded trailers, manufacturers would not
have any regulatory requirements under this program, and would not be
subject to the proposed trailer compliance requirements. We seek
comment on the appropriateness of excluding these types of trailers
from the proposed trailer program and whether other trailer designs
should be excluded. Section IV. C. (5) discusses these trailer types we
propose to exclude and the physical characteristics that would define
these trailers.
In summary, the agencies are proposing separate standards for ten
trailer subcategories:
--Long box (longer than 50 feet \213\) dry vans
---------------------------------------------------------------------------
\213\ Most long trailers are 53 feet in length; we are proposing
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.
---------------------------------------------------------------------------
--Long box (longer than 50 feet) refrigerated vans
--Short box (50 feet and shorter) dry vans
--Short box (50 feet and shorter) refrigerated vans
--Partial-aero long box dry vans
--Partial-aero long box refrigerated vans
--Partial-aero short box dry vans
[[Page 40257]]
--Partial-aero short box refrigerated vans
--Non-aero box vans (all lengths of dry and refrigerated vans)
--Non-box trailers (tanker, platform, container chassis, and all other
types of highway trailers that are not box trailers)
As discussed in the next section, partial-aero box trailers would
have the same standards as their corresponding full-aero trailers in
the early phase-in years, and would have separate, less stringent
standards as the program is fully implemented. Section IV. C. (5)
introduces these proposed partial-aero trailer standards and Section
IV. D. describes the technologies that could be applied to meet these
proposed standards.
(2) Proposed Fuel Consumption and CO2 Standards
As described in previously, it is the combination of the tractor
and the trailer that form the useful vehicle, and trailer designs
substantially affect the CO2 emissions and diesel fuel
consumption of the tractors pulling them. Note that although the
agencies are proposing 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) in relation to
``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.
The agencies project that these proposed standards, when fully
implemented in MY (model year) 2027, would achieve fuel consumption and
CO2 emissions reductions of three to eight percent,
depending on trailer subcategory. These projected reductions assume a
degree of technology adoption into the future absent the proposed
program and are evaluated on a weighted drive cycle (see Section IV. D.
(3) . We expect that the MY 2027 standards would be met with high-
performing aerodynamic and tire technologies largely available in the
marketplace today. With a lead-time of more than 10 years, the agencies
believe that both trailer construction and bolt-on CO2- and
fuel consumption-reducing technologies will advance well beyond the
performance of their current counterparts that exist today. A
description of technologies that the agencies considered for this
proposal is provided in Section IV. D.
The agencies designed this proposed 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 proposing progressively more stringent standards in three-
year stages leading up to the MY 2027.\214\ The agencies are proposing
several options to reduce compliance burden (see Section IV. F.) in the
early years as the industry gains experience with the program. EPA is
proposing to initiate its program in 2018 with modest standards for
long box dry and refrigerated vans that can be met with common
SmartWay-verified aerodynamic and tire technologies. In this early
stage, we expect that manufacturers of the other trailer subcategories
would meet those standards by using tire technologies only. Standards
that we propose for the next stages, which we propose to begin in MY
2021, MY 2024, and MY 2027, would gradually increase in stringency for
each subcategory, including the introduction of standards for shorter
box vans that we expect would be met by applying both aerodynamic and
tire technologies. NHTSA's regulations would be voluntary until MY 2021
as described in Section IV. C. (3).
---------------------------------------------------------------------------
\214\ These stages are consistent with NHTSA's stability
requirements under EISA.
---------------------------------------------------------------------------
Table IV-2 below presents the CO2 and fuel consumption
phase-in standards, beginning in MY 2018 that the agencies are
proposing for trailers. 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. Partial-aero
trailers would be subject to the same standards as their corresponding
``full aero'' trailers for MY 2018 through MY 2026. In MY 2027 and the
years to follow, partial-aero trailers would continue to meet the
standards for MY 2024.
The agencies are not proposing CO2 or fuel consumption
standards predicated on aerodynamic improvements for non-box trailers
or non-aero box vans at any stage of this proposed program. Instead, we
are proposing design standards that would require manufacturers of
these trailers to adopt specific tire technologies and thus to comply
without aerodynamic devices. We believe that this approach would
significantly limit the compliance burden for these manufacturers and
request comment on this provision.\215\
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\215\ The agencies are not proposing provisions to allow
averaging for non-box trailers, non-aero box trailers, or partial-
aero box trailers, and this reduced flexibility would likely have
the effect of requiring compliant tire technologies to be used.
Table IV-2--Proposed Trailer CO2 and Fuel Consumption Standards for Box Trailers
----------------------------------------------------------------------------------------------------------------
Subcategory Dry van Refrigerated van
Model year ---------------------------------------------------------------------------------
Length Long Short Long Short
----------------------------------------------------------------------------------------------------------------
2018-2020..................... EPA Standard.... 83 144 84 147
(CO2 Grams per
Ton-Mile).
Voluntary NHTSA 8.1532 14.1454 8.2515 14.4401
Standard.
(Gallons per
1,000 Ton-Mile).
2021-2023..................... EPA Standard.... 81 142 82 146
(CO2 Grams per
Ton-Mile).
NHTSA Standard.. 7.9568 13.9489 8.0550 14.3418
(Gallons per
1,000 Ton-Mile).
2024-2026..................... EPA Standard.... 79 141 81 144
(CO2 Grams per
Ton-Mile).
NHTSA Standard.. 7.7603 13.8507 7.9568 14.1454
(Gallons per
1,000 Ton-Mile).
2027 +........................ EPA Standard.... 77 140 80 144
(CO2 Grams per
Ton-Mile).
NHTSA Standard.. 7.5639 13.7525 7.8585 14.1454
(Gallons per
1,000 Ton-Mile).
----------------------------------------------------------------------------------------------------------------
[[Page 40258]]
Differences in the numerical values of these standards among
trailer subcategories are due to differences in the tractor-trailer
characteristics, as well as differences in the default payloads, in the
vehicle simulation model we used to develop the proposed standards (as
described in Section IV. D. (3) (a) below). Lower numerical values in
Table IV-2 do not necessarily indicate more stringent standards. For
instance, the proposed standards for dry and refrigerated vans of the
same length have the same stringency through MY 2026, but the standards
recognize differences in trailer weight and aerodynamic performance due
to the TRU on refrigerated vans. Trailers of the same type but
different length differ in weight as well as in the number of axles
(and tires), tractor type, payload and aerodynamic performance. Section
IV. D. and Chapter 2.10 of the draft RIA provide more details on the
characteristics of the tractor-trailer vehicles, with various
technologies, that are the basis for these standards.
In developing the proposed standards for trailers, the agencies
evaluated the current level of CO2 emissions and fuel
consumption, the types and availability of technologies that could be
applied to reduce CO2 and fuel consumption, and the current
adoption rates of these technologies. Additionally, we considered the
necessary lead-time and associated costs to the industry to meet these
standards, as well as the fuel savings to the consumer and magnitude of
CO2 and fuel savings that we project would be achieved as a
result of these proposed standards. As discussed in more detail later
in this preamble and in Chapter 2.10 of the draft RIA, the analyses of
trailer aerodynamic and tire technologies that the agencies have
conducted appear to show that these proposed standards would be the
maximum feasible and appropriate in the lead-time provided under each
agency's respective statutory authorities. We ask that any comments
related to stringency include data whenever possible indicating the
potential effectiveness and cost of adding such devices to these
vehicles.
The agencies request comment on all aspects of these proposed
standards, including trailers to be covered and the proposed 50-foot
demarcation between ``long'' and ``short'' box vans, the proposed
phase-in schedule, and the stringency of the standards in relation to
their cost, CO2 and fuel consumption reductions, and on the
proposed compliance provisions, as discussed in Section IV. F.
In addition to these proposed trailer standards, the agencies
considered standards both less stringent and more stringent than the
proposed standards. We specifically request comment on a set of
accelerated standards that we considered, as presented in Section IV.
E. This set of standards is predicated on performance and penetration
rates of the same technologies as the proposed standards, but would
reach full implementation three years sooner.
(3) Lead-Time Considerations
As mentioned earlier, although the agencies did not include
standards for trailers in Phase 1, box trailer 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 long box trailers have some experience installing
these aerodynamic and tire technologies for customers. This experience
impacts how much lead-time is necessary from a technological
perspective. EPA is proposing CO2 emission standards for
long box trailers for MY 2018 that represent stringency levels similar
to those used for SmartWay verification and required for the California
regulation, and thus could be met by adopting off-the-shelf aerodynamic
and tire technologies available today. The NHTSA program from 2018
through 2020 would be voluntary.
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 these technologies for their trailers and
therefore have less experience with these technologies. As such, EPA is
proposing less stringent requirements for manufacturers of other
highway trailer subcategories beginning in MY 2018. We expect these
manufacturers of short box trailers would adopt some aerodynamic and
tire technologies, and manufacturers of other trailers would adopt tire
technologies only, as a means of achieving the proposed standards. Some
manufacturers of trailers other than long boxes may not yet have direct
experience with these technologies, but the technologies they would
need are fairly simple and can be incorporated into trailer production
lines without significant process changes. Also, the NHTSA program for
these trailers would be voluntary until MY 2021.
The agencies believe that the burdens of installing and marketing
these technologies would not be limiting factors in determining
necessary lead-time for manufacturers of these trailers. Instead, we
expect that the proposed first-time compliance and, in some cases,
performance testing requirements, would be the more challenging
obstacles for this newly regulated industry. For these reasons, we are
proposing that these standards phase in over a period of nine years,
with flexibilities that would minimize the compliance and testing
burdens in the early years of the proposed program (see Section IV.
F.).
As mentioned previously, EPA is proposing modest standards and
several compliance options that would allow it to begin its program for
MY 2018. However, EISA requires four model years of lead-time for fuel
consumption standards, regardless of the stringency level or
availability of flexibilities. Therefore, NHTSA's proposed fuel
consumption requirements would not become 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
would need to stay in the program for all succeeding model years.\216\
---------------------------------------------------------------------------
\216\ NHTSA adopted a similar voluntary approach in the first
years of Phase 1 (see 76 FR 57106).
---------------------------------------------------------------------------
The agencies believe that the expected period of seven years or
more between the issuing of the final rules and full implementation of
the program would provide sufficient lead-time for all affected trailer
manufacturers to adopt CO2- and fuel consumption-reducing
technologies or design trailers to meet the proposed standards.
(4) Non-CO2 GHG Emissions from Trailers
In addition to the impact of trailer design on the CO2
emissions of tractor-trailer vehicles, the agencies recognize 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. We do not
currently believe that HFC leakage is likely to become a major problem
in the near future, and we are not proposing provisions addressing
refrigerant leakage of trailer-related HFCs in this proposed
rulemaking. TRUs differ from the other source categories where EPA has
adopted (or proposed) to apply HFC leakage requirements (i.e., air
conditioning). We believe trailer owners have a strong incentive to
limit refrigerant leakage in order to maintain the operability of the
trailer's refrigeration unit and avoid financial liability for damage
to perishable freight due to a failure to maintain the agreed-
[[Page 40259]]
upon temperature and humidity conditions. In addition, refrigerated van
units represent a relatively small fraction of new trailers.
Nevertheless, we request comment on this issue, including any data on
typical TRU charge capacity, the frequency of HFC refrigerant leakage
from these units across the fleet, the magnitude of unaddressed leakage
from individual units, and how potential EPA regulations might address
this leakage issue.
(5) Exclusions and Less-Stringent Standards
All trailers built before January 1, 2018 are excluded from the
Phase 2 trailer program, and from 40 CFR part 1037 and 49 CFR part 535
in general (see 40 CFR 1037.5(g) and 49 CFR 535.3(e)). Furthermore, the
proposed regulations do not apply to trailers designed to be drawn by
vehicles other than tractors, and those that are coupled to vehicles
with pintle hooks or hitches instead of a fifth wheel. As stated
previously, we are proposing that non-box trailers that are designed
for dedicated use with in-field operations related to logging and
mining be completely excluded from this Phase 2 trailer program. The
agencies believe that the operational capabilities of trailers designed
for these purposes could be compromised by the use of aerodynamic
devices or tires with lower rolling resistance. Additionally, the
agencies are proposing to exclude trailers designed for heavy-haul
applications and those that are not intended for highway use, as
follows:
--Trailers shorter than 35 feet in length with three axles, and all
trailers with four or more axles (including any lift axles)
--Trailers designed to operate at low speeds such that they are
unsuitable for normal highway operation
--Trailers designed to perform their primary function while stationary
--Trailers intended for temporary or permanent residence, office space,
or other work space, such as campers, mobile homes, and carnival
trailers
--Trailers designed to transport livestock
--Incomplete trailers that are sold to a secondary manufacturer for
modification to serve a purpose other than transporting freight, such
as for offices or storage \217\
---------------------------------------------------------------------------
\217\ Secondary manufacturers who purchase incomplete trailers
and complete their construction to serve as trailers are subject to
the requirements of 40 CFR 1037.620.
Where the criteria for exclusion identified above may be unclear
for specific trailer models, manufacturers would be encouraged to ask
the agencies to make a determination before production begins. The
agencies seek comments on these and any other trailer characteristics
that might make the trailers incompatible with highway use or would
restrict their typical operating speeds.
Because the agencies are proposing that these trailers be excluded
from the program, we are not proposing to require manufacturers to
report to the agencies about these excluded trailers. We seek comments
on whether, in lieu of the exclusion of trailers from the program, the
agencies should instead exempt these trailers from the standards, but
still require reporting to the agencies in order to verify that a
manufacturer qualifies for an exemption. In that case, exempt trailers
would have some regulatory requirements (e.g., reporting); again,
excluded trailers would have no regulatory requirements under this
proposal. All other trailers would remain covered by the proposed
standards.
As described earlier, the proposed program is based on the
expectation that manufacturers would be able to apply aerodynamic
devices and tire technologies to the vast majority of box trailers, and
these standards would be relatively stringent. We propose to categorize
trailers with functional components or work-performing equipment, and
trailers with certain design elements, that could partially interfere
with the installation or the effectiveness of some aerodynamic
technologies, as ``partial-aero'' box trailers. For example, some
trailer equipment by their placement or their need for operator access
might not be compatible with current designs of trailer skirts, but a
boat tail could be effective on that trailer in the early years of the
program. Similarly, a rear lift gate or roll-up rear door might not be
compatible with a current boat tail design, but skirts could be
effective. The proposed requirements for these trailers would the same
as their full-aero counterparts until MY 2027, at which time they would
continue to be subject to the MY 2024 standards. See 40 CFR 1037.107.
For trailers for which no aerodynamic devices are practical, the
agencies are proposing design standards requiring LRR tires and ATI
systems. Trailers for which neither skirt/under-body devices nor rear-
end devices would be likely to be feasible fall into two categories:
non-box trailers and non-aero box trailers. We believe that there is
limited availability of aerodynamic technologies for non-box trailers
(for example, platform (flatbed) trailers, tank trailers, and container
chassis trailers). Also, for container chassis trailers, operational
considerations, such as stacking of the chassis trailers, impede
introduction of aerodynamic technologies. In addition, manufacturers of
these trailer types have little or no experience with aerodynamic
technologies designed for their products. Non-aero box trailers,
defined as those with equipment or design features that would preclude
both skirt/under-body and rear-end aerodynamic technologies (e.g., a
trailer with both a pull-out platform for side access and a rear lift
gate), would be subject to the same tire-only design standards as would
non-box trailers, based exclusively on the performance of tire and ATI
technologies.\218\
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\218\ The agencies are not aware of work-performing equipment
that would prevent the use of gap-reducing trailer devices on dry
vans of any length; thus dry vans with side and rear equipment could
qualify as ``non-aero'' trailers, even if the manufacturer could
install a gap-reducing device.
---------------------------------------------------------------------------
We recognize that the shortest short box vans (i.e., less than 35
feet) are often pulled in tandem. Since these trailers make up the
majority of trailers in the short box van subcategories, we are not
proposing standards for short box dry and refrigerated vans based on
the use of rear devices. Thus, work-performing features on the rear of
the trailer (e.g., lift gates) would not impact a trailer's ability to
meet the full-aero short-box trailer standards. As a result, we are
proposing that all short box vans only be categorized as partial-aero
vans if they have work-performing side features (e.g., belly boxes). We
expect that partial-aero short dry van trailers would be able to adopt
front-side devices that would achieve the reduced standards.
Furthermore, some short box trailers that are not operated in tandem,
such as 40- or 48-foot trailers, could also be able to adopt rear-side
devices and achieve even greater reductions.
Refrigerated short box vans are a special case in that they have
TRUs that limit the ability to apply aerodynamic technologies to the
front side of the trailers. Because of this, we are proposing to
classify the shortest refrigerated box vans (shorter than 35 feet) as
non-aero trailers if they are designed with work-performing side
features. Since these trailers may be pulled in tandem and since they
cannot adopt front-side aerodynamic devices, we propose that they meet
standards predicated on tire technologies only. Short box refrigerated
trailers 35 feet and longer would only qualify for non-aero standards
if they have work-
[[Page 40260]]
performing devices on both the side and rear of the trailer. See 40 CFR
1037.107.
We request comment on these proposed provisions for excluding some
trailers from the program, including speed restrictions and physical
characteristics that would generally make them incompatible for highway
use. We also request comment on the proposed approach of applying less-
stringent standards to non-box, non-aero box, and partial-aero box
trailers.
(6) In-Use Standards
Consistent with Section 202(a)(1) of the CAA, EPA is proposing that
the emissions standards apply for the useful life of the trailers.
NHTSA also proposes to adopt EPA's useful life requirements for
trailers 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. Aerodynamic devices available today,
including trailer skirts, rear fairings, under-body devices, and gap-
reducing fairings, are designed to maintain their physical integrity
for the life of the trailer. In the absence of failures like
detachment, breakage, or misalignment, we expect that the aerodynamic
performance of the devices will not degrade appreciably over time and
that the projected CO2 and fuel consumption reductions will
continue for the life of the vehicle with no special maintenance
requirements. Because of this, EPA does not see a benefit to
establishing separate standards that would apply in-use for trailers.
EPA and NHTSA are proposing a regulatory useful life value for trailers
of 10 years, and thus the certification standards would apply in-use
for that period of time.\219\ See Section IV. F. (5) (a) for a
discussion of other factors related to trailer useful life.
---------------------------------------------------------------------------
\219\ EPA may perform in-use testing of any vehicle subject to
the standards of this part, including trailers. For example, we may
test trailers to verify drag areas or other GEM inputs.
---------------------------------------------------------------------------
D. Feasibility of the Proposed Trailer Standards
As discussed below, the agencies' initial determination, subject to
consideration of public comment, is 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. We summarize our analyses in this section, and describe
them in more detail in the Draft RIA (Chapter 2.10).
Our analysis of the feasibility of the proposed CO2 and
fuel consumption standards is based on technology cost and
effectiveness values collected from several sources. Our assessment of
the proposed trailer program is based on information from:
--Southwest Research Institute evaluation of heavy-duty vehicle fuel
efficiency and costs for NHTSA,\220\
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\220\ 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.
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--2010 National Academy of Sciences report of Technologies and
Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty
Vehicles,\221\
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\221\ 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.
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--TIAX's assessment of technologies to support the NAS panel
report,\222\
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\222\ 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-duty
long haul combination tractors (the NESCCAF/ICCT study),\223\
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\223\ 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,\224\ and
---------------------------------------------------------------------------
\224\ 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 inflation technologies, and weight reduction through
component substitution. 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 standards, but rather demonstrated one
example of how compliance could reasonably occur, taking into account
cost of the standards (including costs of compliance testing and
certification), and needed lead time. We are proposing that full-aero
box trailer manufacturers have additional flexibility in meeting the
standards through averaging. The less complex standards proposed for
partial- and non-aero box and non-box trailers would still provide a
degree of technology choices that would meet their standards.
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. We then combined these technologies into packages of
increasing effectiveness in reducing CO2 and fuel
consumption and projected reasonable rates at which the evaluated
technologies and packages could be adopted across the trailer industry.
More details regarding our analysis can be found in Chapter 2.10.4.1 of
the draft RIA.
The agencies developed the proposed 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. We evaluated these standards with
respect to the cost of these technologies, the emission reductions and
fuel consumption improvements achieved, and the lead-time needed to
deploy the technology at a given adoption rate.
Unlike the other sectors covered by this Phase 2 rulemaking,
trailer manufacturers do not have experience certifying under the Phase
1 program. Moreover, a large fraction of the trailer industry is
composed of small businesses and very few of the largest trailer
manufacturers have the same resources available as manufacturers in the
other heavy-duty sectors. The standards have been developed with this
in mind, and we are confident the proposed standards can be achieved by
manufacturers who lack prior experience implementing such standards.
(1) Available Technologies
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. In this section
we outline the general trailer technologies that the agencies
considered in evaluating the feasibility of the proposed standards.
(a) Aerodynamic Drag Reduction
Historically, the primary goal when designing the shape of box
trailers has been to maximize usable internal cargo volume, while
complying with regulatory size limits and minimizing construction
costs. This led to standard box trailers being rectangular. This basic
shape creates significant aerodynamic
[[Page 40261]]
drag and makes box trailers strong candidates for aerodynamic
improvements. Current bolt-on aerodynamic technologies for box trailers
are designed to create a smooth transition of airflow from the tractor,
around the trailer, and beyond the trailer.
Table IV-3 lists general aerodynamic technologies that the EPA
SmartWay program has evaluated for use on box trailers and a
description of their intended impact. Several versions of each of these
technologies are commercially available and have seen increased
adoption over the past decade. Performance of these devices varies
based on their design, their location and orientation on the trailer,
and the vehicle speed. More information regarding the agencies' initial
assessment of these devices, including incremental costs is discussed
in Chapter 2.10 of the draft RIA.
Table IV-3--Aerodynamic Technologies for Box Trailers
------------------------------------------------------------------------
Example Intended impact on
Location on trailer technologies aerodynamics
------------------------------------------------------------------------
Front........................... Front fairings and Reduce cross-flow
gap-reducing through gap and
fairings. smoothly
transition
airflow from
tractor to the
trailer.
Rear............................ Rear fairings, Reduce pressure
boat tails and drag induced by
flow diffusers. the trailer wake.
Underside....................... Side fairings and Manage flow of air
skirts, and under the trailer
underbody devices. to reduce
turbulence,
eddies and wake.
------------------------------------------------------------------------
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 in lengths different than 53 feet and some fleets have
opted to add trailer skirts to their refrigerated vans and 28-foot
trailers (often called ``pups''). In addition, some side skirts have
been adapted for non-box trailers (e.g., tankers, platforms, and
container chassis), and have shown potential for large reductions in
drag. At this time, however, non-box trailer aerodynamic devices are
not widely available, with many still at the prototype stage. The
agencies encourage commenters to provide more information and data
related to the effectiveness of technologies applied to trailers other
than 53-foot dry and refrigerated vans.
``Boat tail'' devices, applied to the rear of a trailer, 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. The
agencies request comment on whether we should require that trailer
manufacturers using such devices for compliance with the proposed
standards only use designs that automatically deploy when the vehicle
is in motion.
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 prohibits the use of current gap-reducers. Similarly, drop deck
dry vans have lowered floors between the landing gear and the trailer
axles that limit the ability to use side skirts. The agencies
considered the availability and limitations of aerodynamic technologies
for each trailer type evaluated in our feasibility analysis of the
proposed and alternative standards.
(b) Tire Rolling Resistance
On a typical Class 8 long-haul tractor-trailer, over 40 percent of
the total energy loss from tires is attributed to rolling resistance
from the trailer tires.\225\ Trailer tire rolling resistance values
collected by the agencies for Phase 1 indicate that the average
coefficient of rolling resistance (CRR) for new trailer
tires was 6.0 kg/ton. This value was applied for the standard trailer
used for tractor compliance in the Phase 1 tractor program. For Phase
2, the agencies consider all trailer tires with CRR values
below 6.0 kg/ton to be ``lower rolling resistance'' (LRR) tires. For
reference, a trailer tire that qualifies as a SmartWay-verified tire
must meet a CRR value of 5.1 kg/ton, a 15 percent
CRR reduction from the trailer tire identified in Phase 1.
Our research of rolling resistance indicates an additional
CRR reduction of 15 percent or more from the SmartWay
verification threshold is possible with tires that are available in the
commercial market today.
---------------------------------------------------------------------------
\225\ ``Tires & Truck Fuel Economy: A New Perspective'', The
Tire Topic Magazine, Special Edition Four, 2008, Bridgestone
Firestone, North American Tire, LLC. Available online: http://www.trucktires.com/bridgestone/us_eng/brochures/pdf/08-Tires_and_Truck_Fuel_Economy.pdf.
---------------------------------------------------------------------------
For this proposal, the agencies are proposing to use the same
rolling resistance baseline value of 6.0 kg/ton for all trailer
subcategories. We request comment on the appropriateness of 6.0 kg/ton
as the proposed CRR threshold for all regulated trailers.
Specifically, the agencies would like more information on current
adoption rates of and CRR values for models of LRR tires
currently in use on short box trailers and the various non-box
trailers.
Similar to the case of tractor tires, LRR tires are available as
either dual or as single wide-based tires for trailers. Single wide-
based tires achieve CRR values that are similar to their
dual counterparts, but have an added benefit of weight reduction, which
can be an attractive option for trailers that frequently maximize cargo
weight. See Section IV.D.1.d below.
(c) Tire Pressure Systems
The inflation pressure of tires also impacts the rolling
resistance. Tractor-trailers operating with all tires under-inflated by
10 psi have been shown to increase fuel consumed by up to 1
percent.\226\ Tires can gradually lose pressure from small punctures,
leaky valves or simply diffusion through the tire casing. Changes in
ambient temperature can also have an effect on tire pressure. Trailers
that remain unused for long periods of time between hauls may
experience any of these conditions. A 2003 FMCSA report found that
nearly 1 in 5 trailers had at least 1 tire under-inflated by 20 psi or
more. If drivers or fleets are not diligent about checking and
attending to under-inflated tires, the trailer may have much higher
rolling resistance and much higher CO2 emissions and fuel
consumption.
---------------------------------------------------------------------------
\226\ ``Tire Pressure Systems--Confidence Report''. North
American Council for Freight Efficiency. 2013. Available online:
http://nacfe.org/wp-content/uploads/2014/01/TPS-Detailed-Confidence-Report1.pdf.
---------------------------------------------------------------------------
Tire pressure monitoring (TPM) and automatic tire inflation (ATI)
systems are designed to address under-inflated tires. Both systems
alert drivers if a tire's pressure drops below its set point. TPM
systems are simpler and merely monitor tire pressure. Thus, they
require user-interaction to re inflate to the appropriate pressure.
Today's ATI systems, on the other hand, typically
[[Page 40262]]
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, ATI systems have the added
benefit of maintaining enough pressure to allow the driver to get to a
safe stopping area. The agencies believe TPM systems cannot
sufficiently guarantee the proper inflation of tires due to the
inherent user-interaction required. Therefore, ATI systems are the only
pressure systems the agencies are proposing to recognize in Phase 2.
Benefits of ATI systems in individual trailers vary depending on
the base level of maintenance already performed by the driver or fleet,
as well as the number of miles the trailer travels. Trailers that are
well maintained or that travel fewer miles will experience less
benefits from ATI systems compared to trailers that often drive with
poorly inflated tires or log many miles. The agencies believe ATI
systems can provide a CO2 and fuel consumption benefit to
most trailers. With ATI use, trailers that have lower annual vehicle
miles traveled (VMT) due to long periods between uses would be less
susceptible to low tire pressures when they resume activity. Trailers
with high annual VMT would experience the fuel savings associated with
consistent tire pressures. Automatic tire inflation systems could
provide a CO2 and fuel consumption savings of 0.5-2.0
percent, depending on the degree of under-inflation in the trailer
system. See Section IV.D.3.d below for discussion of our estimates of
these factors, as well as estimates of the degree of adoption of ATI
systems prior to and at various points in the phase-in of the proposed
program.
The use of ATI systems can result in cost savings beyond reducing
fuel costs. For example, drivers and fleets that diligently maintain
their tires would spend less time and money to inspect each tire. A
2011 FMCSA 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.\227\
---------------------------------------------------------------------------
\227\ TMC Future Truck Committee Presentation ``FMCSA Tire
Pressure Monitoring Field Operational Test Results,'' February 8,
2011.
---------------------------------------------------------------------------
(d) Weight Reduction
Reduction in trailer tare (i.e., empty) weight can lead to fuel
efficiency reductions in two ways. For applications where payload is
not limited by weight restrictions, the overall weight of the tractor
and trailer would be reduced and would lead to improved fuel
efficiency. For applications where payload is limited by weight
restrictions, the lower trailer weight would allow additional payload
to be transported during the truck's trip, so emissions and fuel
consumption on a ton-mile basis would decrease. There are weight
reduction opportunities for trailers in both the structural components
and in the wheels/tires. Material substitution (e.g., replacing steel
with aluminum or lighter-weight composites) is feasible for components
such as roof bows, side and corner posts, cross members, floor joists,
floors, and van sidewalls. Similar material substitution is feasible
for wheels (e.g., substituting aluminum for steel). Weight can also be
reduced through the use of single wide-based tires replacing two dual
tires.
Lower weight is a desired trailer attribute for many customers, and
most trailer manufacturers offer options that reduce weight to some
degree. Some of these manufacturers, especially box van makers, market
trailers with lower-weight major components, such as light-weight
composite van sidewalls or aluminum floors, especially to customers
that expect to frequently reach regulatory weight limits (i.e., ``weigh
out'') and are willing to pay a premium for the ability to increase
cargo weight without exceeding overall vehicle weight. Alternatively,
manufacturers that primarily design trailers for customers that do not
have weight limit concerns (i.e., their payloads frequently fill the
available trailer cargo space before the weight limit is reached, or
``cube out''), or for customers that have smaller budgets, may continue
to design trailers based on traditional, heavier materials, such as
wood and steel.
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 would be appropriate or
fair across the industry to apply overall weight reductions toward
compliance. However, the agencies do believe it would be appropriate to
allow a manufacturer to account for weight reductions that involve
substituting very specific, traditionally heavier components with
lower-weight options that are not currently widely adopted in the
industry. We discuss how we apply weight reduction in developing the
standards in Section IV. D. (2)(d) below.
(2) Technological Basis of the Standards
The analysis below presents one possible set of technology designs
by which trailer manufacturers could reasonably achieve the goals of
the program on average. 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 proposed program.
Much of our analysis is performed for box trailers, which have the
most stringent proposed standards. As mentioned previously, we have
separate standards for short and long box vans, and a trailer length of
50 feet is proposed as the cut-point to distinguish the two length
categories. For the purpose of this analysis, long trailers are
represented by 53-foot vans and short trailers are represented by
single, 28-foot (``pup'') vans. These trailer lengths make up the
largest fraction of the vans in the two categories. The agencies
recognize that many 28-foot short vans are operated in tandem. However,
these trailers are sold individually, and require a ``dolly'', often
sold by a separate manufacturer, to connect the trailers for tandem
operation.
In addition, the other trailer types considered short vans in this
proposal (e.g., 40-foot and 48-foot) typically operate as single
trailers. To minimize complexity, we are proposing that 28-foot
trailers represent all short refrigerated and dry vans for both
compliance and for this feasibility analysis. This means that
manufacturers would not need to perform tests (or report device
manufacturers' test data) of the performance of devices for each
trailer length in the short van category. Although this approach would
provide a conservative estimate of actual CO2 emissions and
fuel consumption reductions for the short van category, the agencies
believe that the need to avoid an overly complex compliance program
justifies this approach. We request comment on this approach to
evaluating short box trailers.
(a) Aerodynamic Packages
In order to evaluate performance and cost of the aerodynamic
technologies discussed in the previous section, 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 technologies based on EPA's
aerodynamic testing. The agencies recognize that there are other
technology options that have similar performance. We chose the
technologies presented here based on their current adoption rates and
effectiveness in reducing CO2 and fuel consumption.
[[Page 40263]]
Bin I represents a base trailer with no aerodynamic technologies
added. There is no cost associated with this bin. Bin II achieves small
reductions in CO2 and fuel consumption. This bin includes a
gap reducing fairing added to a long dry van or a skirt added to a solo
short dry van.\228\ Bin III includes devices that would achieve
SmartWay's verification threshold of four percent at cruise speeds.
Some basic skirts and boat tails would achieve these levels of
reductions for long box trailers. A gap reducer and a basic skirt on a
short dry van would meet this level of performance. Bin IV technologies
are more effective, single aerodynamic devices for long box trailers,
including advanced skirts or boat tails, that achieve larger reductions
in drag than the technologies in Bin III. The combination of an
advanced skirt and gap reducer on a short dry van are also expected to
achieve this bin.
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\228\ The agencies recognize that many 28-foot pup trailers are
often operated in tandem. However, we are regulating and evaluating
short dry vans as solo trailers since they are sold individually and
the short box regulatory subcategories also include trailer sizes
not often operated in tandem (e.g., 40-foot and 48-foot trailers).
---------------------------------------------------------------------------
Bin V levels of performance were not observed in EPA's aerodynamic
testing for short box trailers. It is possible that a gap reducer,
skirt, and boat tail could achieve this performance, but boat tails are
not feasible for 28-foot trailers operated in tandem unless the trailer
is located in the rear position. For this analysis, the agencies only
evaluated solo pup trailers and, therefore, did not evaluate any
technologies for short box trailers beyond Bin IV. For this proposed
rulemaking, we believe a Bin V level of performance can be achieved for
long box trailers by either highly effective single devices or by
applying a combination of basic boat tails and skirts. We do not
currently have data for a single aerodynamic device that fits this bin
and we evaluated it as a combination of a basic tail and skirt. Bin VI
combines advanced skirts and boat tail technologies on long box
trailers. This bin is expected to include many technologies that
qualify for SmartWay's ``Elite'' designation.
Bin VII represents an optimized system of technologies that work
together to synergistically address each of the main areas of drag and
achieves aerodynamic improvements greater than SmartWay's ``Elite''
designation. We are representing Bin VII with a gap reducer, and
advanced tail and skirt. Bin VIII is designed to represent aerodynamic
technologies that may become available in the future, including
aerodynamic devices yet to be designed or approaches that would
incorporate changes to the construction of trailer bodies. We have not
analyzed this final bin in terms of effectiveness or cost, but are
including it to account for future advancements in trailer
aerodynamics.
For this proposal, aerodynamic performance is evaluated using a
vehicle's aerodynamic drag area, CDA. EPA collected
aerodynamic test data for several tractor-trailer configurations,
including 53-foot dry vans and 28-foot dry van trailers with many of
these technology packages. The agencies developed bins, somewhat
similar to the aerodynamic bins in the Phase 1 and proposed Phase 2
tractor programs, based on results from our test program. However,
unlike the tractor program, we grouped the technologies by changes in
CDA (or ``delta CDA'') rather than by absolute
values. In other words, each bin would comprise aerodynamic
technologies that provide similar improvements in drag. 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 trailer manufacturers
are familiar.
Table IV-4 illustrates the bin structure that the agencies are
proposing as the basis for compliance. The table shows example
technology packages that might be included in each bin based on EPA's
testing of 53-foot dry vans and solo 28-foot dry vans. The agencies
believe these bins apply to other box trailers (refrigerated vans and
lengths other than 28 and 53 feet), which will be described in more
detail in Section IV.D.3.b. These bins cover a wide enough range of
delta CDAs to account for the uncertainty seen in EPA's
aerodynamic testing program due to procedure variability, the use of
different test methods, or different models of tractors, trailers and
devices. A more detailed description of the development of these bins
can be found in the draft RIA, Chapter 2.10. We welcome comments and
additional data that may support or suggest changes to these bins.
Table IV-4--Technology Bins Used To Evaluate Trailer Benefits and Costs
----------------------------------------------------------------------------------------------------------------
Example technologies
Bin Delta CdA Average delta ---------------------------------------------
CDA 53-foot dry van 28-foot dry van
----------------------------------------------------------------------------------------------------------------
Bin I............................. < 0.09 0.0 No Aero Devices...... No Aero Devices.
Bin II............................ 0.10-0.19 0.1 Gap Reducer.......... Skirt.
Bin III........................... 0.20-0.39 0.3 Basic Skirt or Basic Skirt + Gap Reducer.
Tail.
Bin IV............................ 0.40-0.59 0.5 Advanced Skirt or Adv. Skirt + Gap
Tail. Reducer.
Bin V............................. 0.60-0.79 0.7 Basic Combinations...
Bin VI............................ 0.80-1.19 1.0 Advanced Combinations .....................
(including SmartWay
Elite).
Bin VII........................... 1.20-1.59 1.4 Optimized .....................
Combinations.
Bin VIII.......................... > 1.6 1.8 Changes to Trailer .....................
Construction.
----------------------------------------------------------------------------------------------------------------
Note: A blank cell indicates a zero or NA value in this table.
The agencies used EPA's Greenhouse gas Emissions Model (GEM)
vehicle simulation tool to conduct this analysis. See Section F.1 below
for more about GEM. Within GEM, the aerodynamic performance of each
trailer subcategory is evaluated by subtracting the delta
CDA shown in Table IV-4 from the CDA value
representing a specific standard tractor pulling a zero-technology
trailer. The agencies chose to model the zero-technology long box dry
van using a CDA value of 6.2 m\2\ (the average
CDA from EPA's coastdown testing). For long box refrigerated
vans, a two percent reduction in CDA was assumed to account
for the aerodynamic benefit of the TRU at the front of the trailer.
Short box dry vans also received a two percent lower CDA
value compared to its 53-foot counterpart, consistent with the
reduction observed in EPA's wind tunnel testing. The CDA
value assigned to the refrigerated short box vans was an
[[Page 40264]]
additional two percent lower than the short box dry van. Non-aero box
trailers are modeled as short box dry vans. The trailer subcategories
that have design standards (i.e., non-box and non-aero box trailers) do
not have numerical standards to meet, but they were evaluated in this
feasibility analysis in order to quantify the benefits of including
them in the program. Non-aero box trailers are modeled as short dry
vans. Non-box trailers, which are modeled as flatbed trailers, were
assigned a drag area of 4.9 m\2\, as was done in the Phase 1 tractor
program for low roof day cabs. Table IV-5 illustrates the Bin I drag
areas (CDA) associated with each trailer subcategory.
Table IV-5--Baseline CDA Values Associated With Aerodynamic Bin I
[Zero trailer technologies]
------------------------------------------------------------------------
Trailer subcategory Dry van
------------------------------------------------------------------------
Long Dry Van............................................ 6.2
Short Dry Van........................................... 6.1
Long Ref. Van........................................... 6.1
Short Ref. Van.......................................... 6.0
Non-Aero Box............................................ 6.1
Non-Box................................................. 4.9
------------------------------------------------------------------------
(b) Tire Rolling Resistance
Similar to the proposed Phase 2 tractor and vocational vehicle
programs, the agencies are proposing a tire program based on adoption
of lower rolling resistance tires. 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) indicates about 35 percent of box
trailers sold today have SmartWay tires.\229\ While some trailers
continue to be sold with tires of higher rolling resistances, the
agencies believe most box trailer tires currently achieve the Phase 1
trailer tire CRR of 6.0 kg/ton or better.
---------------------------------------------------------------------------
\229\ Truck Trailer Manufacturers Association letter to EPA.
Received on October 16, 2014. Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
The agencies evaluated two levels of tire performance for this
proposal 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 would achieve an
additional eight percent reduction in rolling resistance (a 22 percent
reduction from the baseline tire), 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.
The agencies evaluated these three tire rolling resistance levels,
summarized in Table IV-6, in the feasibility analysis of the following
sections. GEM simulations that apply Level 1 and 2 tires result in
CO2 and fuel consumption reductions of two and three percent
from the baseline tire, respectively. It should be noted that these
levels are for the feasibility analysis only. For compliance,
manufacturers would have the option to use tires with any rolling
resistance and would not be limited to these TRRLs.
Table IV-6--Summary of Trailer Tire Rolling Resistance Levels Evaluated
------------------------------------------------------------------------
CRR (kg/
Tire rolling resistance level ton)
------------------------------------------------------------------------
Baseline..................................................... 6.0
Level 1...................................................... 5.1
Level 2...................................................... 4.7
------------------------------------------------------------------------
(c) Automatic Tire Inflation Systems
NHTSA and EPA recognize the role of proper tire inflation in
maintaining optimum tire rolling resistance during normal trailer
operation. For this proposal, rather than require performance testing
of ATI systems, the agencies are proposing to recognize the benefits of
ATI systems with a single default reduction for manufacturers that
incorporate ATI systems into their trailer designs. Based on
information available today, we believe that there is a narrow range of
performance among technologies available and among systems in typical
use. We propose to assign a 1.5 percent reduction in CO2 and
fuel consumption for all trailers that implement ATI systems, based on
information available today.\230\ We believe the use of these systems
can consistently ensure that tire pressure and tire rolling resistance
are maintained. We selected the levels of the proposed trailer
standards with the expectation that a high rate of adoption of ATI
systems would occur across all on-highway trailers and during all years
of the phase-in of the program. See Section IV.D.3.d below for
discussion of our estimates of these factors, as well as estimates of
the degree of adoption of ATI systems prior to and at various points in
the phase-in of the proposed program. The informal survey of members
from the Truck Trailer Manufacturers Association (TTMA) indicates about
40 percent of box trailers sold today have ATI systems.\231\
---------------------------------------------------------------------------
\230\ See the Chapter 2.10.2.3 of the draft RIA.
\231\ Truck Trailer Manufacturers Association letter to EPA.
Received on October 16, 2014. Docket EPA-HQ-OAR-2014-0827
---------------------------------------------------------------------------
(d) Weight Reduction
The agencies are proposing compliance provisions that would limit
the weight-reduction options to the substitution of specified
components that can be clearly isolated from the trailer as a whole.
For this proposal, the agencies have identified several conventional
components with available lighter-weight substitutes (e.g.,
substituting conventional dual tires mounted on steel wheels with wide-
based single tires mounted on aluminum wheels). We are proposing values
for the associated weight-related savings that would be applied with
these substitutions for compliance. The proposed component
substitutions and their associated weight savings are presented in the
draft RIA, Chapter 2.10.2.4 and in proposed 40 CFR 1037.515. 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.
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 EPA's GEM vehicle simulation tool, it
is assumed that one-third of the weight reduction will be applied to
the payload. For tractor-trailers simulated in GEM, it takes a weight
reduction of nearly 1,000 lbs before a one percent fuel savings is
achieved. The component substitutions identified by the agencies result
in weight reductions of less than 500 lbs, yet can cost over $1,000.
The agencies believe that few trailer manufacturers would apply weight
reduction solely as a means of achieving reduced fuel consumption and
CO2 emissions. Therefore, we are proposing standards that
could be met without reducing weight--that is, the compliance path set
[[Page 40265]]
out by the agencies for the proposed standards does not include weight
reduction. However, we are proposing to offer weight reduction as an
option for box trailer manufacturers who wish to apply it to some of
their trailers as part of their compliance strategy.
The agencies have identified 11 common trailer components that have
lighter weight options available (see 40 CFR 1037.515)
232 233 234 235 Manufacturers that adopt these technologies
would sum the associated weight reductions and apply those values in
GEM. As mentioned previously, we are restricting the weight reduction
options to those listed in 40 CFR 1037.515. We are requesting comment
on the appropriateness of the specified weight reductions from
component substitution. In addition, we seek weight and cost data
regarding additional components that could be offered as specific
weight reduction options. The agencies request that any such components
be applicable to most box trailers, and that the reduced weight option
not currently be in common use.
---------------------------------------------------------------------------
\232\ 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.
\233\ ``Weight Reduction: A Glance at Clean Freight
Strategies'', EPA SmartWay. EPA420F09-043. Available at: http://permanent.access.thefederalregister.org/gpo38937/EPA420F09-043.pdf.
\234\ Memorandum dated June 2015 regarding confidential weight
reduction information obtained during SBREFA Panel. Docket EPA-HQ-
OAR-2014-0827.
\235\ Randall Scheps, Aluminum Association, ``The Aluminum
Advantage: Exploring Commercial Vehicles Applications,'' presented
in Ann Arbor, Michigan, June 18, 2009.
---------------------------------------------------------------------------
(3) Effectiveness, Adoption Rates, and Costs of Technologies for the
Proposed 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 rates are then used to
derive the proposed standards.
(a) Zero-Technology Baseline Tractor-Trailer Vehicles
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
model being certified. The proposed trailer program has separate
standards for each trailer subcategory, and a unique tractor-trailer
vehicle was chosen to represent each subcategory for compliance. In the
Phase 2 update to GEM, each trailer subcategory is modeled as a
particular trailer being pulled by a standard tractor depending on the
physical characteristics and use pattern of the trailer. Table IV-7
highlights the relevant vehicle characteristics for the zero-technology
baseline of each subcategory. 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 Bin I values shown
previously in Table IV-5. Weight reduction and ATI systems are not
applied in these baselines. Chapter 2.10 of the draft RIA provides a
detailed description of the development of these baseline tractor-
trailers.
The agencies chose to consistently model a Class 8 tractor across
all trailer subcategories. We recognize that Class 7 tractors are
sometimes used in certain applications. However, we believe Class 8
tractors are more widely available, which will make it easier for
trailer manufacturers to obtain a qualified tractor if they choose to
perform trailer testing. We request comment on the use of Class 8
tractors as part of the tractor-trailer vehicles used in the compliance
simulation as well as performance testing. We ask that commenters
include data, where available, related to the current use and
availability of Class 7 and 8 tractors with respect to the trailer
types in each trailer subcategory.
Table IV--7 Characteristics of the Zero-Technology Baseline Tractor-Trailer Vehicles
--------------------------------------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------------------------------------------------------
Dry van
Refrigerated van Non-aero box Non-box
-----------------------------------------------------------------------------------------------------------------------
Trailer Length.................. Long.............. Short............. Long.............. Short............. All Lengths....... All Lengths
Tractor Class................... Class 8........... Class 8........... Class 8........... Class 8........... Class 8........... Class 8
Tractor Cab Type................ Sleeper........... Day............... Sleeper........... Day............... Day............... Day
Tractor Roof Height............. High.............. High.............. High.............. High.............. High.............. Low
Engine.......................... 2018 MY 15L,...... 2018 MY 15L,...... 2018 MY 15L,...... 2018 MY 15L,...... 2018 MY 15L,...... 2018 MY 15L,
455 HP............ 455 HP............ 455 HP............ 455 HP............ 455 HP............ 455 HP
Frontal Area (m\2\)............. 10.4.............. 10.4.............. 10.4.............. 10.4.............. 10.4.............. 6.9
Drag Area, CDA (m\2\)........... 6.2............... 6.1............... 6.1............... 6.0............... 6.1............... 4.9
Steer Tire RR (kg/ton).......... 6.54.............. 6.54.............. 6.54.............. 6.54.............. 6.54.............. 6.54
Drive Tire RR (kg/ton).......... 6.92.............. 6.92.............. 6.92.............. 6.92.............. 6.92.............. 6.92
Trailer Tire RR (kg/ton)........ 6.00.............. 6.00.............. 6.00.............. 6.00.............. 6.00.............. 6.00
Total Weight (kg)............... 31,978............ 21,028............ 33,778............ 22,828............ 21,028............ 29,710
Payload (tons).................. 19................ 10................ 19................ 10................ 10................ 19
ATI System Use.................. 0................. 0................. 0................. 0................. 0................. 0
Weight Reduction (lb)........... 0................. 0................. 0................. 0................. 0................. 0
Drive Cycle Weightings.......... .................. .................. .................. .................. .................. ..................
65-MPH Cruise................... 86%............... 64%............... 86%............... 64%............... 64%............... 64%
55-MPH Cruise................... 9%................ 17%............... 9%................ 17%............... 17%............... 17%
Transient Driving............... 5%................ 19%............... 5%................ 19%............... 19%............... 19%
--------------------------------------------------------------------------------------------------------------------------------------------------------
(b) Effectiveness of Technologies
The agencies are proposing to recognize trailer improvements via
four performance parameters: aerodynamic drag reduction, tire rolling
resistance reduction, the adoption of ATI systems, and by substituting
specific weight-reducing components. Table IV-8 summarizes the
performance levels for each of these parameters based on the technology
characteristics outlined in Section IV. D. (2) .
[[Page 40266]]
Table IV--8 Performance Parameters for the Proposed Trailer Program
------------------------------------------------------------------------
------------------------------------------------------------------------
Aerodynamics (Delta CDA, m\2\):
Bin I................................... 0.0.
Bin II.................................. 0.1.
Bin III................................. 0.3.
Bin IV.................................. 0.5.
Bin V................................... 0.7.
Bin VI.................................. 1.0.
Bin VII................................. 1.4.
Bin VIII................................ 1.8.
Tire Rolling Resistance (CRR, kg/ton):
Tire Baseline........................... 6.0.
Tire Level 1............................ 5.1.
Tire Level 2............................ 4.7.
Tire Inflation System (% reduction):
ATI System.............................. 1.5.
Weight Reduction (lbs):
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-9 shows the agencies' estimates of the
effectiveness of each parameter for the four box trailer subcategories.
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 lbs). The table shows that aerodynamic
improvements offer the largest potential for CO2 emissions
and fuel consumption reductions, making them relatively effective
technologies.
Table IV-9--Effectiveness (Percent CO2 and Fuel Savings From Baseline) of Technologies for the Proposed 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....................... 0.3............. -2 -2 -2 -2
Bin IV........................ 0.5............. -3 -4 -3 -3
Bin V......................... 0.7............. -5 -5 -5 -5
Bin VI........................ 1.0............. -7 -7 -7 -7
Bin VII....................... 1.4............. -10 -10 -9 -10
Bin VIII...................... 1.8............. -13 -13 -12 -12
----------------------------------------------------------------------------------------------------------------
Tire Rolling Resistance CRR (kg/ton).... Dry van
Refrigerated van
---------------------------------------------------------------
Long Short Long Short
----------------------------------------------------------------------------------------------------------------
Baseline...................... 6.0............. 0 0 0 0
Level 1....................... 5.1............. -2 -1 -2 -1
Level 2....................... 4.7............. -3 -2 -3 -2
----------------------------------------------------------------------------------------------------------------
Weight Reduction Weight (lb)..... Dry van
Refrigerated van
---------------------------------------------------------------
Long Short Long Short
----------------------------------------------------------------------------------------------------------------
Baseline...................... 0.0............. 0.0 0.0 0.0 0.0
Al. Dual Wheels............... 168............. -0.2 -0.3 -0.2 -0.3
Upper Coupler................. 280............. -0.3 -1 -0.3 -1
Suspension.................... 430............. -0.5 -1 -0.5 -1
Al. Single Wide............... 556............. -1 -1 -1 -1
----------------------------------------------------------------------------------------------------------------
(c) Reference Tractor-Trailer To Evaluate Benefits and Costs
In order to evaluate the benefits and costs of the proposed
standards, it is necessary to establish a reference point for
comparison. As mentioned previously, the technologies described in
Section IV. D. (2) 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 this
proposal, the agencies identified reference case tractor-trailers for
each trailer subcategory based on the technology adoption rates we
project would exist if this proposed trailer program was not
implemented.
We project that by 2018, absent further California regulation,
EPA's SmartWay program and these research programs will result in about
20 percent of 53-foot dry and refrigerated vans adopting basic
SmartWay-level aerodynamic technologies (meeting SmartWay's four
percent verification level and Bin III from Table IV-5), 30 percent
adopting more advanced aerodynamic technologies at the five percent
SmartWay-verification level (Bin IV from Table IV-5) and five percent
adding combinations of technologies (Bin V).236 237 238 In
addition, we project half of these 53' box trailers will be equipped
with SmartWay-verified tires (i.e., 5.1 kg/ton or better) and ATI
systems as well. The agencies project that market forces will drive an
additional one percent increase in adoption of the advanced SmartWay
and tire technologies each year through 2027. For analytical purposes,
the agencies assumed manufacturers of the shorter box trailers and
other trailer
[[Page 40267]]
subcategories would not adopt these technologies in the timeframe
considered and a zero-technology baseline is assumed. We are not
assuming weight reduction for any of the trailer subcategories in the
reference cases. Table IV-10 summarizes the reference case trailers for
each trailer subcategory.
---------------------------------------------------------------------------
\236\ Truck Trailer Manufacturers Association letter to EPA.
Received on October 16, 2014. Docket EPA-HQ-OAR-2014-0827.
\237\ 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.
\238\ Frost & Sullivan, ``Strategic Analysis of North American
Semi-trailer Advanced Technology Market'', Feb 2013.
Table IV-10--Projected Adoption Rates and Average Performance Parameters for the Less Dynamic Reference Case
Trailers
----------------------------------------------------------------------------------------------------------------
Technology Long box dry & refrigerated vans Short box, non-
------------------------------------------------------------------------------------------------- aero box, &
non-box
trailers
Model Year 2018 2021 2024 2027 ---------------
2018-2027
----------------------------------------------------------------------------------------------------------------
Aerodynamics:
Bin I....................... 45% 41% 38% 35% 100%
Bin II...................... .............. .............. .............. .............. ..............
Bin III..................... 20 20 20 20 ..............
Bin IV...................... 30 34 37 40 ..............
Bin V....................... 5 5 5 5 ..............
Bin VI...................... .............. .............. .............. .............. ..............
Bin VII..................... .............. .............. .............. .............. ..............
Bin VIII.................... .............. .............. .............. .............. ..............
Average Delta CDA (m\2\) 0.2 0.3 0.3 0.3 0.0
\a\....................
Tire Rolling Resistance:
Baseline tires.............. 50 47 43 40 100
Level 1 tires............... 50 53 57 60 ..............
Level 2 tires............... .............. .............. .............. .............. ..............
Average CRR (kg/ton) \a\ 5.55 5.52 5.49 5.46 6.0
Tire Inflation:
ATI......................... 50 53 57 60 0
Average % Reduction \a\. 0.8 0.8 0.9 0.9 0.0
Weight Reduction (lbs):
Weight \b\.................. .............. .............. .............. .............. ..............
----------------------------------------------------------------------------------------------------------------
Notes: A blank cell indicates a zero value.
\a\ Combines adoption rates with performance levels shown in Table IV-8.
\b\ Weight reduction was not projected for the reference case trailers.
Also shown in Table IV-10 are average aerodynamic performance
(delta CDA), average tire rolling resistance
(CRR), and average reductions due to use of ATI and weight
reduction for each stage of the proposed program. These values indicate
the performance of theoretical average tractor-trailers that the
agencies project will be in use if no federal regulations were in place
for trailer CO2 and fuel consumption. The average tractor-
trailer vehicles serve as reference cases for each trailer subcategory.
The agencies provide a detailed description of the development of these
reference case vehicles in Chapter 2.10 in the draft RIA.
Because the agencies cannot be certain about future trends, we also
considered a second reference case. This more dynamic reference case
reflects the possibility that absent a Phase 2 regulation, there will
be continuing adoption of technologies in the trailer market after 2027
that reduce fuel consumption and CO2 emissions. This case
assumes the research funded and conducted by the federal government,
industry, academia and other organizations will, after 2027, result the
adoption of some technologies beyond the levels required to comply with
existing regulatory and voluntary programs. One example of such
research is the Department of Energy Super Truck 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.\239\ This
reference case assumes that by 2040, 75 percent of new trailers will be
equipped with SmartWay-verified aerodynamic devices, low rolling
resistance tires, and ATI systems. Table IV-11 shows the agencies'
projected adoption rates of technologies in the more dynamic reference
case.
---------------------------------------------------------------------------
\239\ Daimler Truck North America. SuperTruck Program Vehicle
Project Review. June 19, 2014. Docket EPA-HQ-OAR-2014-0827.
Table IV-11--Projected Adoption Rates and Average Performance Parameters for the More Dynamic Reference Case
--------------------------------------------------------------------------------------------------------------------------------------------------------
Technology Long box dry & refrigerated vans Short box, non-
----------------------------------------------------------------------------------------------------------------------------------------- aero box, &
non-box
trailers
Model year 2018 2021 2024 2027 2040 ---------------
2018-2027
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics:
Bin I............................................... 45% 41% 38% 35% 20% 100%
Bin II.............................................. .............. .............. .............. .............. .............. ..............
Bin III............................................. 20 20 20 20 20 ..............
[[Page 40268]]
Bin IV.............................................. 30 34 37 40 55 ..............
Bin V............................................... 5 5 5 5 5 ..............
Bin VI.............................................. .............. .............. .............. .............. .............. ..............
Bin VII............................................. .............. .............. .............. .............. .............. ..............
Bin VIII............................................ .............. .............. .............. .............. .............. ..............
Average Delta C DA (m\2\) \a\................... 0.2 0.3 0.3 0.3 0.4 0.0
Tire Rolling Resistance:
Baseline tires...................................... 50 47 43 40 25 100
Level 1 tires....................................... 50 53 57 60 75 ..............
Level 2 tires....................................... .............. .............. .............. .............. .............. ..............
Average CRR (kg/ton) \a\........................ 5.6 5.5 5.5 5.5 5.3 6.0
Tire Inflation:
ATI..................................................... 50 53 57 60 75 0
Average % Reduction \a\......................... 0.8 0.8 0.9 0.9 1.1 0.0
Weight Reduction (lbs):
Weight \b\.......................................... .............. .............. .............. .............. .............. ..............
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes: A blank cell indicates a zero value.
\a\ Combines adoption rates with performance levels shown in Table IV-8.
\b\ Weight reduction was not projected for the reference case trailers.
The agencies applied the vehicle attributes from Table IV-7 and the
average performance values from Table IV-10 in the proposed Phase 2 GEM
vehicle simulation to calculate the CO2 emissions and fuel
consumption performance of the reference tractor-trailers. The results
of these simulations are shown in Table IV-12. We used these
CO2 and fuel consumption values to calculate the relative
benefits of the proposed standards. 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) as seen in Table IV-7 and discussed further in the Chapter
2.10.3. The alternative reference case shown in Table IV-11 impacts the
long-term projections of benefits beyond 2027, which are analyzed in
Chapters 5-7 of the draft RIA.
Table IV-12--CO2 Emissions and Fuel Consumption Results for the Reference Tractor-Trailers
----------------------------------------------------------------------------------------------------------------
Dry van Refrigerated van
Length ---------------------------------------------------------------
Long Short Long Short
----------------------------------------------------------------------------------------------------------------
CO2 Emissions (g/ton-mile)...................... 85 147 87 151
Fuel Consumption (gal/1000 ton-miles)........... 8.3497 14.4401 8.5462 14.8330
----------------------------------------------------------------------------------------------------------------
(d) Projected Technology Adoption Rates for the Proposed Standards
As described in Section IV. E., the agencies evaluated several
alternatives for the proposed trailer program. Based on our analysis,
and current information, the agencies are proposing the alternative we
believe reflects the agencies' respective statutory authorities. The
agencies are also considering an accelerated alternative with less lead
time, requiring the same incremental stringencies for the proposed
program, but becoming effective three years earlier. The agencies
believe this alternative has the potential to be the maximum feasible
alternative. However, based on the evidence currently before us, EPA
and NHTSA have outstanding questions regarding relative risks and
benefits of Alternative 4 due to the timeframe envisioned by that
alternative. EPA and NHTSA are seriously considering this accelerated
alternative in whole or in part for the trailer segment. In other
words, the agencies could determine that less lead-time is maximum
feasible in the final rule. We request comment on these two
alternatives, including the proposed lead-times.
Table IV-13 and Table IV-14 present a set of assumed adoption rates
for aerodynamic, tire, and ATI technologies that a manufacturer could
apply to meet the proposed standards. These adoption rates begin with
60 percent of long box trailers achieving current SmartWay level
aerodynamics (Bin IV) and progress to 90 percent achieving SmartWay
Elite (Bin VI) or better over the following nine years. The adoption
rates for short box trailers assume adoption of single aero devices in
MY 2021 and combinations of devices by MY 2027. 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 would continue to innovate skirt, under-body, rear, and
gap-reducing devices and combinations to achieve improved aerodynamic
performance on these shorter trailers. The assumed adoption rates for
aerodynamic technologies for both long and short refrigerated vans are
slightly less than for dry vans, reflecting the more limited number of
aerodynamic options due to the presence of their TRUs.
The gradual increase in assumed adoption of aerodynamic
technologies
[[Page 40269]]
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-period, their adoption on the scale of
the proposed program would likely take time. The adoption rates we are
assuming in the interim years--and the standards that we developed from
these rates--represent steady and yet reasonable improvement in average
aerodynamic performance.
The agencies project that nearly all box trailers will adopt tire
technologies to comply with the standards and the agencies projected
consistent adoption rates across all lengths of dry and refrigerated
vans, with more advanced (Level 2) low-rolling resistance tires assumed
to replace Level 1 tire models in the 2024 time frame, as Level 2-type
tires become more available and fleet experience with these tires
develops. 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 a compliance pathway, as discussed
in Section IV.D.1.d above.
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 manufacturers are not
limited to aerodynamic and tire technologies, since these are
performance-based standards, and manufacturers would not be constrained
to adopt any particular way to demonstrate compliance. Certain types of
weight reduction, for example, may be used as a compliance pathway, as
discussed in Section IV.D.1.d above.
Similar to our analyses of the reference cases, the agencies
derived a single set of performance parameters for each subcategory by
weighting the performance levels included in Table IV-8 by the
corresponding adoption rates. These performance parameters represent an
average compliant vehicle for each trailer subcategory and we present
these values in the tables. The 2024 MY adoption rates would continue
to apply for the partial-aero box trailers in 2027 and later model
years.
Table IV-13--Projected Adoption Rates and Average Performance Parameters for Long Box Trailers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Technology Long box dry vans Long box refrigerated vans
--------------------------------------------------------------------------------------------------------------------------------------------------------
Model year 2018 2021 2024 2027 2018 2021 2024 2027
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamic Technologies:
Bin I....................................................... 5% ......... ......... ......... 5% ......... ......... .........
Bin II...................................................... ......... ......... ......... ......... ......... ......... ......... .........
Bin III..................................................... 30% 5% ......... ......... 30% 5% ......... .........
Bin IV...................................................... 60% 55% 25% ......... 60% 55% 25% .........
Bin V....................................................... 5% 10% 10% 10% 5% 10% 10% 20%
Bin VI...................................................... ......... 30% 65% 50% ......... 30% 65% 60%
Bin VII..................................................... ......... ......... ......... 40% ......... ......... ......... 20%
Bin VIII.................................................... ......... ......... ......... ......... ......... ......... ......... .........
Average Delta CDA (m\2\) \a\............................ 0.4 0.7 0.8 1.1 0.4 0.7 0.8 1.0
Trailer Tire Rolling Resistance:
Baseline tires.............................................. 15% 5% 5% 5% 15% 5% 5% 5%
Level 1 tires............................................... 85% 95% ......... ......... 85% 95% ......... .........
Level 2 tires............................................... ......... ......... 95% 95% ......... ......... 95% 95%
Average CRR (kg/ton) \a\................................ 5.2 5.1 4.8 4.8 5.2 5.1 4.8 4.8
Tire Inflation System:
ATI......................................................... 85 95 95 95 85 95 95 95
Average ATI Reduction (%) \a\........................... 1.3% 1.4% 1.4% 1.4% 1.3% 1.4% 1.4% 1.4%
Weight Reduction (lbs):
Weight \b\.................................................. ......... ......... ......... ......... ......... ......... ......... .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes: A blank cell indicates a zero value.
\a\ Combines projected adoption rates with performance levels shown in Table IV-8.
\b\ This set of proposed adoption rates did not apply any assumed weight reduction to meet the proposed standards for these trailers.
Table IV-14--Projected Adoption Rates and Average Performance Parameters for Short Box Trailers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Technology Short box dry vans Short box refrigerated vans
--------------------------------------------------------------------------------------------------------------------------------------------------------
Model year 2018 2021 2024 2027 2018 2021 2024 2027
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamic Technologies: \a\
Bin I....................................................... 100% 5% ......... ......... 100% 5% ......... .........
Bin II...................................................... ......... 95% 70% 30% ......... 95% 70% 55%
Bin III..................................................... ......... ......... 30% 60% ......... ......... 30% 40%
Bin IV...................................................... ......... ......... ......... 10% ......... ......... ......... 5%
Bin V....................................................... ......... ......... ......... ......... ......... ......... ......... .........
Bin VI...................................................... ......... ......... ......... ......... ......... ......... ......... .........
Bin VII..................................................... ......... ......... ......... ......... ......... ......... ......... .........
Bin VIII.................................................... ......... ......... ......... ......... ......... ......... ......... .........
Average Delta CDA (m\2\) \b\............................ 0.4 0.7 0.8 1.1 0.4 0.7 0.8 1.0
Trailer Tire Rolling Resistance:
Baseline tires.............................................. 15% 5% 5% 5% 15% 5% 5% 5%
Level 1 tires............................................... 85% 95% ......... ......... 85% 95% ......... .........
Level 2 tires............................................... ......... ......... 95% 95% ......... ......... 95% 95%
Average CRR (kg/ton) \b\................................ 5.2 5.1 4.8 4.8 5.2 5.1 4.8 4.8
[[Page 40270]]
Tire Inflation System:
ATI............................................................. 85% 95% 95% 95% 85% 95% 95% 95%
Average ATI Reduction (%) \c\........................... 1.3% 1.4% 1.4% 1.4% 1.3% 1.4% 1.4% 1.4%
Weight Reduction (lbs):
Weight \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-8.
\c\ This set of proposed adoption rates did not apply any assumed weight reduction to meet the proposed standards for these trailers.
Non-aero box trailers, with two or more work-related special
components, and non-box trailers are not shown in the tables above. We
are proposing that manufacturers of these trailers meet design-based
(i.e., technology-based) standards, instead of performance-based
standards that would apply to other trailers. That is, manufacturers of
these trailers would not need to use aerodynamic technologies, but they
would need to use appropriate lower rolling resistance tires and ATI
systems, based on our assessments of the typical CO2 and
fuel consumption performance of this equipment (see Section IV.2.c).
Thus, we are projecting 100 percent adoption rates of these
technologies at each stage of the program. Compared to manufacturers
that needed aerodynamic technologies to comply, the approach for non-
aero box trailers and non-box trailers would result 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. F.). The agencies are proposing these design standards in
two stages. In 2018, the proposed standards would require manufacturers
to use tires meeting a rolling resistance of Level 1 or better and to
install ATI systems on all non-box and non-aero box trailers. In 2024,
the proposed standards would require manufacturers to use LRR tires at
a Level 2 or better, and to still install ATI systems. We seek comment
on all aspects of this design-based standards concept. We also seek
comment on providing manufacturers with the option of adopting Level 2
tires in the early years of the program (MY 2018-2023) and avoiding the
use of ATI systems if they chose.
Table IV-15--Projected Adoption Rates and Average Performance Parameters for Non-Aero Box and Non-Box Trailers
----------------------------------------------------------------------------------------------------------------
Technology Non-aero box & non-box trailers
----------------------------------------------------------------------------------------------------------------
Model year 2018 2021 2024 2027
----------------------------------------------------------------------------------------------------------------
Aerodynamic Technologies:
Bin I....................................... 100% 100% 100% 100%
Bin II...................................... .............. .............. .............. ..............
Bin III..................................... .............. .............. .............. ..............
Bin IV...................................... .............. .............. .............. ..............
Bin V....................................... .............. .............. .............. ..............
Bin VI...................................... .............. .............. .............. ..............
Bin VII..................................... .............. .............. .............. ..............
Bin VIII.................................... .............. .............. .............. ..............
Average Delta CDA (m\2\) \a\............ 0.0 0.0 0.0 0.0
Trailer Tire Rolling Resistance:
Baseline tires.............................. .............. .............. .............. ..............
Level 1 tires............................... 100% 100% .............. ..............
Level 2 tires............................... .............. .............. 100% 100%
Average CRR (kg/ton) \a\................ 5.1 5.1 4.7 4.7
Tire Inflation System:
ATI......................................... 100% 100% 100% 100%
Average ATI Reduction (%) \a\........... 1.5% 1.5% 1.5% 1.5%
Weight Reduction (lbs):
Weight \b\.................................. .............. .............. .............. ..............
----------------------------------------------------------------------------------------------------------------
Notes: A blank cell indicates a zero value.
\a\ Combines projected adoption rates with performance levels shown in Table IV-8.
\b\ This set of adoption rates did not apply weight reduction to meet the proposed standards for these trailers.
We request comment and any data related to our projections of
technology adoption rates. The following section (d) explains how the
agencies combined these adoption rates with the performance values
shown previously to calculate the proposed standards.
(e) Derivation of the Proposed Standards
The average performance parameters from Table IV-14, and Table IV-
15 were applied as input values to the GEM vehicle simulation to derive
the
[[Page 40271]]
proposed HD Phase 2 fuel consumption and CO2 emissions
standards for each subcategory of trailers. The proposed standards are
shown in Table IV-16. The proposed standards for partial-aero trailers,
which are not explicitly shown in Table IV-16, would be the same as
their full-aero counterparts through MY 2026. In MY 2027 and later,
partial aero trailers would continue to meet the MY 2024 standards.
Over the four stages of the proposed rule, box trailers longer than
50 feet would, on average, reduce their CO2 emissions and
fuel consumption by two percent, four percent, seven percent and eight
percent compared to their reference cases. Box trailers 50-feet and
shorter would achieve reductions of two percent, three percent and four
percent compared to their reference cases. The tire technologies used
on non-box and non-aero box trailers would provide reductions of two
percent in the first two stages and achieve three percent by 2027.
Table IV-16--Proposed Standards for Box Trailers
----------------------------------------------------------------------------------------------------------------
Subcategory Dry van Refrigerated van
Model year ---------------------------------------------------------------------------------
Length Long Short Long Short
----------------------------------------------------------------------------------------------------------------
2018--2020.................... EPA Standard 83 144 84 147
(CO2 Grams per
Ton-Mile).
Voluntary NHTSA 8.1532 14.1454 8.2515 14.4401
Standard
(Gallons per
1,000 Ton-Mile).
2021--2023.................... EPA Standard 81 142 82 146
(CO2 Grams per
Ton-Mile).
NHTSA Standard 7.9568 13.9489 8.0550 14.3418
(Gallons per
1,000 Ton-Mile).
2024--2026.................... EPA Standard 79 141 81 144
(CO2 Grams per
Ton-Mile).
NHTSA Standard 7.7603 13.8507 7.9568 14.1454
(Gallons per
1,000 Ton-Mile).
2027 +........................ EPA Standard 77 140 80 144
(CO2 Grams per
Ton-Mile).
NHTSA Standard 7.5639 13.7525 7.8585 14.1454
(Gallons per
1,000 Ton-Mile).
----------------------------------------------------------------------------------------------------------------
It should be noted that the proposed standards are based on highway
cruise cycles that include road grade to better reflect real world
driving and to help recognize engine and driveline technologies. See
Section III.E. The agencies have evaluated some alternate road grade
profiles recommended by the National Renewable Energy Laboratory (NREL)
and have prepared possible alternative trailer vehicle standards based
on these profiles. The agencies request comment on this analysis, which
is available in a memorandum to the docket.\240\
---------------------------------------------------------------------------
\240\ Memorandum dated May 2015 on Analysis of Possible Tractor,
Trailer, and Vocational Vehicle Standards Based on Alternative Road
Grade Profiles. Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
(f) Technology Costs for the Proposed Standards
The agencies evaluated the technology costs for 53-foot dry and
refrigerated vans and 28-foot dry vans, which we believe are
representative of the majority of trailers in the 50-foot and longer
and shorter than 50-foot categories, respectively. We identified costs
for each technology package evaluated and projected the costs for each
year of the program. A summary of the technology costs is included in
Table IV-17 through Table IV-20 for MYs 2018 through 2027, with
additional details available in the draft RIA Chapter 2.12. Costs shown
in the following tables are for the specific model year indicated and
are incremental to the average reference case 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. Note
that these costs do not represent actual costs for the individual
components because some fraction of the component costs has been
subtracted to reflect some use of these components in the reference
case. For more on the estimated technology costs exclusive of adoption
rates, refer to Chapter 2.12 of the draft 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 draft RIA. We welcome
comment on the technology costs, markups, and learning impacts.
Table IV-17--Trailer Technology Incremental Costs in the 2018 Model Year
[2012$]
----------------------------------------------------------------------------------------------------------------
53-foot
53-foot dry refrigerated 28-foot dry Non-aero &
van van van non-box
----------------------------------------------------------------------------------------------------------------
Aerodynamics.................................... $285 $285 $0 $0
Tires........................................... 65 65 78 185
Tire inflation system........................... 239 239 435 683
---------------------------------------------------------------
Total....................................... 588 588 514 868
----------------------------------------------------------------------------------------------------------------
[[Page 40272]]
Table IV-18--Trailer Technology Incremental Costs in the 2021 Model Year
[2012$]
----------------------------------------------------------------------------------------------------------------
53-foot
53-foot dry refrigerated 28-foot dry Non-aero &
van van van non-box
----------------------------------------------------------------------------------------------------------------
Aerodynamics.................................... $602 $602 $468 $0
Tires........................................... 65 65 79 175
Tire inflation system........................... 234 234 426 632
---------------------------------------------------------------
Total....................................... 901 901 974 807
----------------------------------------------------------------------------------------------------------------
Table IV-19--Trailer Technology Incremental Costs in the 2024 Model Year
[2012$]
----------------------------------------------------------------------------------------------------------------
53-foot
53-foot dry refrigerated 28-foot dry Non-aero &
van van van non-box
----------------------------------------------------------------------------------------------------------------
Aerodynamics.................................... $836 $836 $608 $0
Tires........................................... 61 61 76 160
Tire inflation system........................... 220 220 412 578
---------------------------------------------------------------
Total....................................... 1,116 1,116 1,097 739
----------------------------------------------------------------------------------------------------------------
Table IV-20--Trailer Technology Incremental Costs in the 2027 Model Year
[2012$]
----------------------------------------------------------------------------------------------------------------
53-foot
53-foot dry refrigerated 28-foot dry Non-aero &
van van van non-box
----------------------------------------------------------------------------------------------------------------
Aerodynamics.................................... $1,163 $1,034 $788 $0
Tires........................................... 54 54 74 155
Tire inflation system........................... 192 192 391 549
---------------------------------------------------------------
Total....................................... 1,409 1,280 1,253 704
----------------------------------------------------------------------------------------------------------------
(4) Consistency of the Proposed Trailer Standards With the Agencies'
Legal Authority
The agencies' initial determination, subject to consideration of
public comment, is 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' proposed decisions on the stringency and timing of the
proposed 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 would be
subject to first-time emission control and fuel consumption regulation
under the proposed standards. These manufacturers are in many cases
small businesses, with limited resources to master the mechanics of
regulatory compliance. Thus, the agencies' proposal seeks to provide a
reasonable time for trailer manufacturers to become familiar with the
requirements and the proposed new compliance regime, given the unique
circumstances of the industry and the compliance flexibilities and
optional compliance mechanisms specially adapted for this industry
segment that we are proposing.
The stringency of the standard is predicated on more widespread
deployment of aerodynamic and tire technologies that are already in
commercial use. The availability, feasibility, and level of
effectiveness of these technologies are well-documented. Thus the
agencies do not believe that there is any issue of technological
feasibility of the proposed standards. Among the issues reflected in
the agencies' proposal are considerations of cost and sufficiency of
lead-time--including lead-time not only to deploy technological
improvements, but also this industry sector to assimilate for the first
time the compliance mechanisms of the proposed rule.
The highest cost shown in Table IV-20 is associated with the long
dry vans. We project that the average cost per trailer to meet the
proposed MY 2027 standards for these trailers would 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. This trend is consistent with the expected average control
costs for Phase 2 tractors, which are also less than 10 percent of
typical tractor costs (see Section III).
The agencies believe these technologies can be adopted at the rates
the standards are predicated on within the proposed lead-time, as
discussed above in Section IV.C.(3). Moreover, we project that most
owners would rapidly recover the initial cost of these technologies due
to the associated fuel savings, usually in less than two years, as
shown in the payback analysis in Section IX. This payback period is
generally considered reasonable in the
[[Page 40273]]
trailer industry for investments that reduce fuel consumption.\241\
---------------------------------------------------------------------------
\241\ 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.
---------------------------------------------------------------------------
Overall, as discussed above in IV.D.3.c in the context of our
assumed technology adoption rates, the gradual increase in stringency
of the proposed trailer program over the phase-in period recognizes two
important factors that the agencies carefully considered in developing
this proposed rule. One factor is that assumed adoption of technologies
many of the aerodynamic technologies that box trailer manufacturers
would likely choose are available today and clearly technologically
feasible throughout the phase-period. At the same time, we recognize
that the adoption of these technologies across the industry scale
envisioned by the proposed program would likely take time. The
standards we are proposing in the interim years represent steady
improvement in average aerodynamic performance toward the final MY 2027
standards.
E. Alternative Standards and Feasibility Considered
As discussed in Section X, the agencies evaluated several different
regulatory alternatives representing different levels of stringency for
the Phase 2 program. The results of the analysis of these proposed
alternatives are discussed below in Section X of the preamble. The
agencies believe each alternative is feasible from a technical
standpoint. However, each successive alternative increases costs and
complexity of compliance for the manufacturers, which can be a
prohibitive burden on the large number of small businesses in the
industry. Table IV-21 provides a summary of the alternatives considered
in this proposal.
Table IV-21--Summary of Alternatives Considered for the Proposed
Rulemaking
------------------------------------------------------------------------
------------------------------------------------------------------------
Alternative 1........................ No action alternative.
Alternative 2........................ Expand the use of aerodynamic and
tire technologies at SmartWay
levels to all 53-foot box
trailers.
Alternative 3 (Proposed Alternative). Adoption of advanced aerodynamic
and tire technologies on all box
trailers.
Adoption of tire technologies on
non-box trailers.
Alternative 4........................ Same technology and application
assumptions as Alternative 3
with an accelerated introduction
schedule.
Alternative 5........................ Aggressive adoption of advance
aerodynamic and tire
technologies for all box
trailers.
Adoption of aerodynamic and tire
technologies for some tank,
flatbed, and container chassis
trailers.
Adoption of tire technologies for
the remaining non-box trailers.
------------------------------------------------------------------------
While we welcome comment on any of these alternatives, we are
specifically requesting comment on Alternative 4 for the trailer
program identified as Alternative 4 above and in Section X. The same
general technology effectiveness values were considered and much of the
feasibility analysis was the same in this alternative and in the
proposed alternative, but Alternative 4 applies the adoption rates of
higher-performing aerodynamic technologies from Alternative 3 at
earlier stages for box trailers. This accelerated alternative achieves
the same final fuel consumption and CO2 reductions as our
proposed alternative three years in advance. The following sections
detail the adoption rates, reductions and costs projected for this
alternative.
(1) Effectiveness, Adoption Rates, and Technology Costs for Alternative
4
Alternative 4 includes the same trailer subcategories and same
trailer technologies as the proposed alternative. Therefore, the zero-
technology baseline trailers (Table IV-7), reference case trailers
(Table IV-10) and performance levels (Table IV-8) described in Section
IV. D. apply for this analysis as well. The following sections describe
the adoption rates of this accelerated alternative and the associated
benefits and costs.
(a) Projected Technology Adoption Rates for Alternative 4
The adoption rates and average performance parameters projected by
the agencies for Alternative 4 are shown in Table IV-22 and Table IV-
23. Adoption rates for non-aero box and non-box trailers remain
unchanged from the proposed standards and they are not repeated in this
section. From the tables, it can be seen that the 2018 MY aerodynamic
technology adoption rates and the tire technology adoption rates for
all model years are identical to those presented previously for the
proposed standards. The aerodynamic projections for MY 2021 and MY 2024
in this accelerated alternative are the same as those projected for MY
2024 and MY 2027 of the proposed standards, but are applied three years
earlier. In this alternative, the 2021 MY adoption rates would continue
to apply for the partial-aero box trailers in 2024 and later model
years.
Table IV-22--Adoption Rates and Average Performance Parameters for the Long Box Trailers in Alternative 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Technology Long box dry vans Long box refrigerated vans
--------------------------------------------------------------------------------------------------------------------------------------------------------
Model year 2018 2021 2024 2018 2021 2024
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamic Technologies: \a\
Bin I............................................... 5% .............. .............. 5% .............. ..............
Bin II.............................................. .............. .............. .............. .............. .............. ..............
Bin III............................................. 30% .............. .............. 30% .............. ..............
Bin IV.............................................. 60% 25% .............. 60% 25% ..............
Bin V............................................... 5% 10% 10% 5% 10% 20%
Bin VI.............................................. .............. 65% 50% .............. 65% 60%
[[Page 40274]]
Bin VII............................................. .............. .............. 40% .............. .............. 20%
Bin VIII............................................ .............. .............. .............. .............. .............. ..............
Average Delta CDA (m2) a........................ 0.4 0.8 1.1 0.4 0.8 1.0
Trailer Tire Rolling Resistance:
Baseline tires...................................... 15 5 5 15 5 5
Level 1 tires....................................... 85 95 .............. 85 95 ..............
Level 2 tires....................................... .............. .............. 95 .............. .............. 95
Average CRR (kg/ton) a.......................... 5.2 5.1 4.8 5.2 5.1 4.8
Tire Inflation System:
ATI................................................. 85% 95% 95% 85% 95% 95%
Average ATI Reduction (%)a...................... 1.3% 1.4% 1.4% 1.3% 1.4% 1.4%
Weight Reduction (lbs):
Weight b............................................ .............. .............. .............. .............. .............. ..............
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes: A blank cell indicates a zero value.
a Combines adoption rates with performance levels shown in Table IV-8.
b This set of adoption rates did not apply weight reduction to meet the proposed standards for these trailers.
Table IV-23--Adoption Rates and Average Performance Parameters for the Short Box Trailers in Alternative 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Technology Short box dry vans Short box refrigerated vans
--------------------------------------------------------------------------------------------------------------------------------------------------------
Model Year 2018 2021 2024 2018 2021 2024
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamic Technologies a
Bin I............................................... 100% .............. .............. 100% .............. ..............
Bin II.............................................. .............. 70% 30% .............. 70% 55%
Bin III............................................. .............. 30% 60% .............. 30% 40%
Bin IV.............................................. .............. .............. 10% .............. .............. 5%
Bin V............................................... .............. .............. .............. .............. .............. ..............
Bin VI.............................................. .............. .............. .............. .............. .............. ..............
Bin VII............................................. .............. .............. .............. .............. .............. ..............
Bin VIII............................................ .............. .............. .............. .............. .............. ..............
Average Delta CDA (m2) b........................ 0.4 0.8 1.1 0.4 0.8 1.0
Trailer Tire Rolling Resistance:
Baseline tires...................................... 15% 5% 5% 15% 5% 5%
Level 1 tires....................................... 85% 95% .............. 85% 95% ..............
Level 2 tires....................................... .............. .............. 95% .............. .............. 95%
Average CRR (kg/ton) b.......................... 5.2 5.1 4.8 5.2 5.1 4.8
Tire Inflation System:
ATI................................................. 85% 95% 95% 85% 95% 95%
Average ATI Reduction (%) b..................... 1.3% 1.4% 1.4% 1.3% 1.4% 1.4%
Weight Reduction (lbs):
Weight c............................................ .............. .............. .............. .............. .............. ..............
--------------------------------------------------------------------------------------------------------------------------------------------------------
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 adoption rates with performance levels shown in Table IV-8.
c This set of adoption rates did not apply weight reduction to meet the proposed standards for these trailers.
(b) Derivation of the Standards for Alternative 4
Similar to the proposed standards of Section IV. D. (3) (d), the
agencies applied the technology performance values from Table IV-22 and
Table IV-23 as GEM inputs to derive the proposed standards for each
subcategory.
Table IV-24 shows the resulting standards for Alternative 4. Over
the three phases of the alternative, box trailers longer than 50 feet
would, on average, reduce their CO2 emissions and fuel
consumption by two percent, six percent and eight percent. Box trailers
50-foot and shorter would achieve reductions of two percent, three
percent, and four percent compared to the reference case. Partial-aero
box trailers would continue to be subject to the 2021 MY standards for
MY 2024 and later. The non-aero box and non-box trailers would meet the
same standards as shown in the proposed Alternative 3 and achieve the
same two and three percent benefits as shown in the proposed
alternative.
[[Page 40275]]
Table IV-24--Trailer CO2 and Fuel Consumption Standards for Box Trailers in Alternative 4
----------------------------------------------------------------------------------------------------------------
Subcategory Dry van Refrigerated van
Model year ---------------------------------------------------------------------------------
Length Long Short Long Short
----------------------------------------------------------------------------------------------------------------
2018-2020..................... EPA Standard.... 83 144 84 147
(CO2 Grams per
Ton-Mile).
Voluntary NHTSA 8.1532 14.1454 8.2515 14.4401
Standard.
(Gallons per
1,000 Ton-Mile).
2021-2023..................... EPA Standard.... 80 142 81 145
(CO2 Grams per
Ton-Mile).
NHTSA Standard.. 7.8585 13.9489 7.9568 14.2436
(Gallons per
1,000 Ton-Mile).
2024+......................... EPA Standard.... 77 140 80 144
(CO2 Grams per
Ton-Mile).
NHTSA Standard.. 7.5639 13.7525 7.8585 14.1454
(Gallons per
1,000 Ton-Mile).
----------------------------------------------------------------------------------------------------------------
(c) Costs Associated With Alternative 4
A summary of the technology costs is included in Table IV-25 to
Table IV-27for MYs 2018, 2021 and 2024, with additional details
available in the draft RIA Chapter 2.12. Costs shown in the following
tables are for the specific model year indicated and are incremental to
the average reference case costs, which includes some level of adoption
of these technologies as shown in Table IV-10. Therefore, the
technology costs in the following tables reflect the average cost
expected for each of the indicated trailer classes. Note that these
costs do not represent actual costs for the individual components
because some fraction of the component costs has been subtracted to
reflect some use of these components in the reference case. For more on
the estimated technology costs exclusive of adoption rates, refer to
Chapter 2.12 of the draft 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 it impacts technology costs for other years, refer to
the draft RIA.
Table IV-25--Trailer Technology Incremental Costs in the 2018 Model Year for Alternative 4
[2012$]
----------------------------------------------------------------------------------------------------------------
53-foot
53-foot dry refrigerated 28-foot dry Non-aero & non-
van van van box
----------------------------------------------------------------------------------------------------------------
Aerodynamics.................................... $285 $285 $0 $0
Tires........................................... 65 65 78 185
Tire inflation system........................... 239 239 435 683
---------------------------------------------------------------
Total....................................... 588 588 514 868
----------------------------------------------------------------------------------------------------------------
Table IV-26--Trailer Technology Incremental Costs in the 2021 Model Year for Alternative 4
[2012$]
----------------------------------------------------------------------------------------------------------------
53-foot
53-foot dry refrigerated 28-foot dry Non-aero & non-
van van van box
----------------------------------------------------------------------------------------------------------------
Aerodynamics.................................... $908 $908 $641 $0
Tires........................................... 65 65 79 175
Tire inflation system........................... 234 234 426 632
---------------------------------------------------------------
Total....................................... 1,207 1,207 1,146 807
----------------------------------------------------------------------------------------------------------------
Table IV-27--Trailer Technology Incremental Costs in the 2024 Model Year for Alternative 4
[2012$]
----------------------------------------------------------------------------------------------------------------
53-foot
53-foot dry refrigerated 28-foot dry Non-aero & non-
van van van box
----------------------------------------------------------------------------------------------------------------
Aerodynamics.................................... 1,223 1,090 816 0
Tires........................................... 61 61 76 160
Tire inflation system........................... 220 220 412 578
---------------------------------------------------------------
Total....................................... 1,504 1,371 1,304 739
----------------------------------------------------------------------------------------------------------------
[[Page 40276]]
The agencies believe Alternative 4 has the potential to be the
maximum feasible and appropriate alternative. However, based on the
evidence currently before us, EPA and NHTSA have outstanding questions
regarding relative risks and benefits of Alternative 4 due to the
timeframe envisioned by that alternative. As discussed earlier, the
ability for manufacturers in this industry to broadly take the
necessary technical steps while becoming familiar with first-time
regulatory responsibilities may be significantly limited with three
fewer years of lead-time. As reinforced in the SBAR Panel Report, this
challenge would not be equal across the industry, often falling more
heavily on smaller trailer manufacturers.
The agencies request comment on the feasibility and costs for
trailer manufacturers to achieve the Alternative 4 standards by
applying advanced aerodynamic technologies with three years less lead-
time than Alternative 3 would provide. The agencies also request
comment on particular burdens that these aggressive adoption rates
could have on small business trailer manufacturers.
F. Trailer Standards: Compliance and Flexibilities
Under the proposed structure, trailer manufacturers would be
required to obtain a certificate of conformity from EPA before
introducing into commerce new trailers subject to the proposed new
trailer CO2 and fuel consumption standards. See CAA section
206(a). The certification process the agencies are proposing for
trailer manufacturers is very similar in its basic structure to the
process for the tractor program. This structure involves pre-
certification activities, the certification application and its
approval, and end-of-year reporting.
In this section, the agencies first describe how we developed
compliance equations based on the GEM vehicle simulation tool and the
general certification process, followed by a discussion of the proposed
test procedures for measuring the performance of tires and aerodynamic
technologies and how manufacturers would apply test results toward
compliance and certification. The section closes with discussions of
several other proposed certification and compliance provisions as well
as proposed provisions to provide manufacturers with compliance
flexibility.
(1) Trailer Compliance Using a GEM-Based Equation
The agencies are committed to introducing a compliance program for
trailer manufacturers that is straightforward, technically robust,
transparent, and that minimizes new administrative burdens on the
industry. As described earlier in this section and in Chapter 4 of the
draft 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 proposed Phase 2 tractor and vocational vehicle
programs, the proposed trailer program uses GEM in evaluating emissions
and fuel consumption in developing the proposed standards. However,
unlike the tractor and vocational vehicle programs, we are not
proposing to 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, but without running the model.
For the proposed trailer program, the trailer characteristics that
a manufacturer would supply to the equation are aerodynamic
improvements (i.e., a change in the aerodynamic drag area, delta
CDA), tire rolling resistance (i.e., coefficient of rolling
resistance, CRR), the presence of an automatic tire
inflation (ATI) system, and the use of light-weight components from a
pre-determined list. The use of the equation would quantify the overall
performance of the trailer in terms of CO2 emissions and
fuel consumption on a per ton-mile basis.
Chapter 2.10.6 of the draft RIA provides a full a description of
the development and evaluation of the equation proposed for trailer
compliance. Equation IV-1 is a single linear regression curve that can
be used for all box trailers in this proposal. Unique constant values,
C1 through C4, are applied for each of the
trailer subcategories as shown in Table IV-28. Constant C5
is equal to 0.985 for any trailer that installs an ATI system
(accounting for the 1.5 percent reduction given for use of ATI) or 1.0
for trailers without ATI systems. This equation was found to accurately
reproduce the results of GEM for each of the four box van subcategories
and the agencies are proposing that trailer manufacturers use Equation
IV-1 when calculating CO2 for compliance. Manufacturers
would 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.
y = [C1 + C2[middot](TRRL) +
C3[middot]([Delta]CDA) +
C4[middot](WR)][middot]C5 (IV-1)
Table IV-28--Constants for GEM-Based Trailer Compliance Equation
----------------------------------------------------------------------------------------------------------------
Trailer subcategory C1 C2 C3 C4
----------------------------------------------------------------------------------------------------------------
Long Dry Van.................................... 77.4 1.7 -6.1 -0.001
Long Refrigerated Van........................... 78.3 1.8 -6.0 -0.001
Short Dry Van................................... 134.0 2.2 -10.5 -0.003
Short Refrigerated Van.......................... 136.3 2.4 -10.3 -0.003
----------------------------------------------------------------------------------------------------------------
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. These long and short van
constants are based on GEM-simulated tractors pulling 53-foot and solo
28-foot trailers, respectively. As a result, we are proposing that
aerodynamic testing to obtain a trailer's performance parameters for
Equation IV-1 be performed using consistent trailer sizes (i.e., all
lengths of short vans be tested as a solo 28-foot van, and all lengths
of long vans be tested as a 53-foot van). More information about
aerodynamic testing is provided in Section IV. F. (3).
(2) General Certification Process
Under the proposed process for certification, trailer manufacturers
would be required to apply to EPA for certification and would provide
performance test data (see 40 CFR 1037.205) in their applications.\242\
A
[[Page 40277]]
staff member from EPA's Compliance Division (in the Office of
Transportation and Air Quality) would be assigned to each trailer
manufacturer to help them through the compliance process. Although not
required, we recommend that manufacturers arrange to meet with the
agencies to discuss compliance plans and obtain any preliminary
approvals (e.g., appropriate test methods) before applying for
certification.
---------------------------------------------------------------------------
\242\ As with the tractor program, manufacturers would submit
their applications to EPA, which would then share them with NHTSA.
Obtaining an approved certificate of conformity from EPA is the
first step in complying with the NHTSA program.
---------------------------------------------------------------------------
Trailer manufacturers would submit their applications through the
EPA VERIFY electronic database, and EPA would issue certificates based
on the information provided. At the end of the model year, trailer
manufacturers would submit an end-of-year report to the agencies to
complete their annual obligations.
The proposed EPA certification provisions also contain provisions
for applying to the NHTSA program. EPA and NHTSA would coordinate on
any enforcement action required.
(a) Preliminary Considerations for Compliance
Prior to submitting an application for a certificate, a
manufacturer would choose the technologies they plan to offer their
customers, obtain performance information for these technologies, and
identify any trailers in their production line that qualify for
exclusion from the program.\243\ Manufacturers that choose to perform
aerodynamic or tire testing would obtain approval of test methods and
perform preliminary testing as needed. During this time, the
manufacturer would 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 would all be subject to
the same standard and covered by a single certificate.
---------------------------------------------------------------------------
\243\ 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.
---------------------------------------------------------------------------
At its simplest, the program would allow all products in each of
the trailer subcategories to be certified as separate families. That
is, long box dry vans, short box dry vans, long refrigerated vans,
short refrigerated vans, non-box trailers, partial-aero trailers (long
and short box, dry and refrigerated vans), and non-aero trailers, could
each be certified as separate trailer families. If a manufacturer
chooses this approach, all products within a family would need to meet
or do better than the standards for that trailer subcategory. This is
not to say that, for example, every long box dry van model would need
to have identical technologies like skirts, tires, and tire inflation
systems, but that every model in that family would need to have a
combination of technologies that had performance representative of
testing demonstrated for that family. (Because the manufacturer would
not be using averaging provisions, a trailer that ``over-complied''
could not offset a trailer that did not meet that family's emission
limit).
If a trailer manufacturer wishes to take advantage of the proposed
averaging provisions, it could divide the trailer models in each of the
standard box trailer categories (i.e., not including the non-box
trailer or non-aero box trailer categories\244\) into subfamilies. Each
subfamily could be a grouping of trailers that have with similar
performance levels, even if they use different technologies. We call
the performance levels for each subfamily as ``Family Emission Limits''
(FELs). A long box dry van manufacturer could choose, for example, to
create two or more subfamilies in its long box dry van family. Trailers
in one or more of these subfamilies could be allowed to under-comply
with the standard (e.g., if the manufacturer chose not to apply ATI or
chose tires with higher rolling resistance levels) as long as the
performance of the other subfamilies over-comply with the standard
(e.g., if the manufacturer applied higher-performing skirts) such that
the average of all of the subfamilies' FELs met or did better than the
stringency for that family on a production-weighted basis. Section
IV.F.6.a below further discusses how the proposed averaging program
would function for any such trailer subfamilies.
---------------------------------------------------------------------------
\244\ The agencies are proposing that manufacturers implement
100 percent of their non-box and special purpose box trailers with
automatic tire inflation systems and tires meeting the specified
rolling resistance levels. As a result, averaging provisions do not
apply to these trailer subcategories.
---------------------------------------------------------------------------
b) 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., 2018 through 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. It must also include a description of
the emission controls that a manufacturer intends to offer. These
emission controls could include aerodynamic features, tire models, tire
inflation 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.F.5 for more
information).
The manufacturer would also provide a summary of the plans to
comply with the standard. This information would include a description
of the trailer family and subfamilies (if applicable) covered by the
certificate and projected sales of its products. Manufacturers that do
not participate in averaging would include information on the lowest
level of CO2 and fuel consumption performance offered in the
trailer family. Manufacturers that choose to average within their
families would include performance information for the projected
highest production trailer configuration, as well as the lowest and the
highest performing configurations within that trailer family.
(c) End-of-Year Obligations
After the end of each year, all manufacturers would 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, manufacturers
participating in the averaging program would submit an end-of-year
report containing both emissions and fuel consumption information for
both agencies. This report would include the year's final compliance
data (as calculated using the compliance equation) and actual sales in
order to demonstrate that the trailers either met the standards for
that year or that the manufacturer generated a deficit to be reconciled
within the next three years under the averaging provisions (see 40 CFR
1037.730, 40 CFR 1037.745, and 49 CFR 535.7). All certifying
manufacturers would need to maintain records of all the data and
information required to be supplied to EPA and NHTSA for eight years.
(3) Trailer Certification Test Protocols
The Clean Air Act specifies that compliance with emission standards
for motor vehicles be demonstrated using emission test data (see CAA
section 206(a) and (b)). The Act does not require the use of specific
technologies or designs. The agencies are proposing that the compliance
equation shown in
[[Page 40278]]
Section IV. F. (1) function as the official ``test procedure'' for
quantifying CO2 and fuel consumption performance for trailer
compliance and certification (as opposed to GEM, which serves this
function in the tractor and vocational vehicle programs). Manufacturers
would insert performance information from the trailer technologies
applied into the equation in order to calculate their impact on overall
trailer performance. The agencies are proposing to assign performance
levels to ATI systems and specific weight reduction values to pre-
determined component substitutions. Aerodynamic and tire rolling
resistance performance would be obtained by the trailer manufacturers.
The following sections describe the approved performance tests for tire
rolling resistance and aerodynamic drag. Non-box and non-aero box
trailers have tire requirements only. Manufacturers of these trailers
will only need to obtain results from the tire performance tests. Long
and short box trailers are expected to use aerodynamic and tire
technologies to meet the proposed standards and will need to obtain
test results from both procedures. See generally proposed 40 CFR part
1037, subpart F, for full description of the proposed performance
tests, and see in particular proposed 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 coefficient into GEM and
the agencies adopted the provisions in ISO 28580:2009(E) \245\ to
determine the rolling resistance of tires. As described in 40 CFR
1037.520(c), this measured value, expressed as CRR, is
required to be the result of at least three repeat measurements of
three different tires of a given design, giving a total of at least
nine data points. Manufacturers specify a CRR value for GEM
that may not be lower than the average of these nine results. Tire
rolling resistance may be determined by either the vehicle or tire
manufacturer. In the latter case, the tire manufacturer would provide a
signed statement confirming that it conducted testing in accordance
with this part.
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\245\ See http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_detail.htm?csnumber=44770.
---------------------------------------------------------------------------
Similar to the tractor program, we propose to extend the Phase 1
testing provisions for tire rolling resistance to apply to the Phase 2
box trailer program, only without requiring the use of GEM. The average
rolling resistance value obtained from this test would be used to
specify the tire rolling resistance level (TRRL) for the trailer tires
in the compliance equation. Based on the current practice for tractors,
we expect the trailer manufacturers to obtain these data from tire
manufacturers. We welcome comments regarding the proposed tire testing
provisions as they relate to the proposed trailer program.
For non-box trailers, the agencies are proposing to use the same
test methods to evaluate tires, but are proposing to apply a single
threshold standard instead of inputting the rolling resistance value
into the GEM equation. Manufacturers of non-box trailers would comply
with the rolling resistance standard by using tires with rolling
resistance below the threshold. From the perspective of the trailer
manufacturer, this would be equivalent to a design standard for the
trailers, even though the standard would be expressed as a performance
standard for the tires.
The agencies are considering adopting a program for tire
manufacturers similar to the provision described in Section IV. F. (3)
(b)(iv) for aerodynamic device manufacturers. For aerodynamic devices,
the agencies are proposing to allow device manufacturers to seek
preliminary approval of the performance of their devices. Device
manufacturers would perform the required testing of their device and
submit the performance results directly to EPA. We are requesting
comment on a similar provision for tires. Tire manufacturers could
submit their test data directly to EPA to show they meet the rolling
resistance requirements, and trailer manufacturers that choose to use
approved tires would merely indicate that in their the certification
applications.
EPA is also considering adopting regulatory text addressing
obligations for tire manufacturers. We note that CAA section 207(c)(1)
requires ``the manufacturer'' to remedy certain in-use problems and
does not limit this responsibility to certificate holders. The remedy
process is generally called recall, and the regulations for this
process are in 40 CFR part 1068, subpart F. In the case of in-use
problems with trailer tires, EPA is requesting comment on adding
regulatory text that would explicitly apply these provisions to tire
manufacturers. In other words, if EPA determines that tires on
certified trailers do not conform to the regulations in actual use,
should EPA require the tire manufacturer to recall and replace the
nonconforming tires? \246\
---------------------------------------------------------------------------
\246\ EPA is considering such a requirement for trailer tire
manufacturers, but not at this time for manufacturers of other
heavy-duty vehicle components. This is because, for the trailer
sector, we believe that the small business trailer manufacturers
that make up a large fraction of companies in this industry could be
uniquely challenged if they needed to recall trailers to replace
tires.
---------------------------------------------------------------------------
(b) Trailer Aerodynamic Performance Testing
Our proposed trailer aerodynamic test procedures are based on the
current and proposed tractor procedures for testing aerodynamic control
devices, including coastdown, constant speed, wind tunnel, and
computational fluid dynamics (CFD) modeling. The purpose of the tests
is to establish an estimate of the aerodynamic drag experienced by a
tractor-trailer vehicle in real-world operation. In the tractor
program, the resulting CdA value represents the aerodynamic drag of a
tested tractor assumed to be pulling a specified standard trailer. In
the proposed trailer program, the CDA value used in the
compliance equation would represent the tested trailer pulled by a
standard tractor.
To minimize the number of tests required, the agencies are
proposing that devices for long trailers be evaluated based on 53-foot
trailers, and that devices for short trailers be evaluated based on 28-
foot trailers. Details of the test procedures can be found in 40 CFR
1037.525 and a discussion of EPA's aerodynamic testing program as it
relates to the proposed trailer program are provided in the draft RIA
Chapter 3.2. The following sections outline the testing requirements
proposed for the long term trailer program, as well as simpler testing
provisions that would apply in the nearer term.
(i) A to B Testing for Trailer Aerodynamic Performance
A key difference between the proposed tractor and trailer programs
is that while the tractor procedures provide a direct measurement of an
absolute CDA value for each tractor model, the agencies
expect a majority of the aerodynamic improvements for trailers will be
accomplished by adding bolt-on technologies. As a result, we are
proposing to evaluate the aerodynamic improvements for trailers by
measuring a change in CDA (delta CDA) relative to
a baseline. Specifically, we propose that the trailer tests be
performed as ``A to B'' tests, comparing the aerodynamic performance of
a tractor-trailer without a trailer aerodynamic device to one with the
device installed. See Draft RIA Chapter 2.10 for more information on
this approach.
As mentioned in Section IV. F. (1) that is consistent with the
compliance
[[Page 40279]]
equations. See 40 CFR 1037.525 and 49 CFR 535.6. We believe that most
trailers longer than 50 feet with comparable technologies would perform
similarly in aerodynamic testing. We also recognize that devices used
on some lengths of trailers in the short-van category may perform
differently than those devices perform when used on a representative
28-foot test trailer.
The agencies are proposing that manufacturers have some flexibility
in the devices (or packages of devices) that they use with box vans
that have lengths different than those of the trailers on which the
devices/packages were tested (i.e., trailers not 53 or 28 feet long).
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 use longer or shorter side skirts than those tested on 53-
or 28-foot trailers. No additional testing would be required in order
to validate the appropriateness of using the alternate devices on these
trailers.
On average, we believe that testing of a device on a 28-foot test
trailer would provide a conservative evaluation of the performance of
that device on other lengths of short box trailers. We believe that the
proposed compliance approach would effectively represent the
performance of such devices on the majority of short van trailers, yet
would limit the number of trailers a manufacturer would need to track
and evaluate. We request comment, including data where possible, on
additional approaches that could be used to address this issue of
varying performance for devices across the range of short van lengths.
Commenters supporting an allowance or requirement to test devices on
short van trailers of other lengths than 28 feet are encouraged to also
address how the agencies should consider such a provision in setting
the levels of the standards, as well as how any additional compliance
complexity would be justified.
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 van trailers.
However, as discussed in Chapter 2.10 of the draft 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 differences in tractor design
are canceled-out, which allows a variety of standard tractors to be
used 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 essence, an A to B test is a set of tests: one test of a
baseline tractor-trailer with zero trailer aerodynamic technologies
(A), and one test that includes the aerodynamic devices to be tested
(B). However, because an A test would relate to a B test only with
respect to the test method and the test trailer length, one A test
could be used for many different B tests. This type of testing would
result in a delta CDA value instead of an absolute
CDA value. For the trailer program, the vehicle
configuration in the A test would include a standard tractor that meets
specified characteristics,\247\ and a manufacturer's baseline trailer
with no aerodynamic improvements. The entity conducting the testing
(e.g., the trailer manufacturer or the trailer aerodynamic device
manufacturer, as discussed below) would perform the test for this
configuration according to the procedures in 40 CFR 1037.525 and repeat
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 device would be the difference between
the CDA values obtained in the A and B tests.
---------------------------------------------------------------------------
\247\ As explained in Section IV. F. (3) (b)(ii), the standard
tractor in GEM consists of a high roof sleeper cab for box trailers
longer than 50 feet and a high roof day cab for box trailers 50 feet
and shorter.
---------------------------------------------------------------------------
In the event that a trailer manufacturer makes major changes to the
aerodynamic design of its trailer in lieu of installing add-on devices,
trailer manufacturers would use the same baseline trailer for the A
configuration as would be used for bolt-on features. In both cases, the
baseline trailer would be a manufacturer's standard box trailer. Thus,
the manufacturer of a redesigned trailer would get full credit for any
aerodynamic improvements it made. We request comment on this issue. In
addition, we request comment on how the program could handle a
situation in which a manufacturer made aerodynamic design changes to a
trailer between 28 and 50 feet, which as proposed could only be
compared to a 28-foot standard trailer.
The agencies are proposing to determine the delta CDA
for trailer aerodynamics using the zero-yaw (or head-on wind) values.
The agencies are not proposing a reference method (i.e., the coastdown
procedure in the tractor program). Instead, we are proposing to allow
manufacturers to perform any of the proposed test procedures to
establish a delta CDA. Since the proposed coastdown and
constant speed procedures include wind restrictions, we are proposing
to only accept the zero-yaw values from aerodynamic evaluation
techniques that are capable of measuring drag at multiple yaw angles
(e.g., wind tunnels and CFD) to allow cross-method comparison and
certification. The agencies welcome comment on the pros and cons of
exclusive use of zero-yaw data from trailer aerodynamic compliance
testing. We recognize that the benefits of aerodynamic devices can be
higher when measured considering wind from other yaw angles. We request
comment on the possibility of allowing manufacturers to use wind-
averaged results for compliance if they choose to test using procedures
that provide wind-averaged values. Chapter 2.10 of the draft RIA
compares zero-yaw and wind-averaged results from EPA's wind tunnel
testing. We request that commenters provide test data to support any
preference for compliance test results. We also request comments on
strategies that could be used to maintain consistency with other
methods that cannot provide wind-averaged results.
(ii) Standard Tractor for Aerodynamic Testing in the Proposed Trailer
Program
We propose that the proposed compliance equation, based on GEM, be
used to determine compliance with the trailer standards. Our discussion
of the feasibility of our proposed standards (Section IV. D. (3) (a))
includes a description of the tractor-trailer vehicle used in GEM. We
recognize the impact of the tractor and want to maintain consistency
with GEM, but for the trailer program it is not necessary to address
all aspects (e.g., the engine) of the tractor, because, as explained
above, the impact of many of its features will be canceled-out with the
use of an A to B test strategy. However, some aerodynamic design
features of the tractor can influence the performance of trailer
aerodynamic technologies and we want to ensure a level of consistency
between tests of different trailer manufacturers.
The agencies believe the A to B test strategy would reduce 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
[[Page 40280]]
would instead identify key characteristics of a standard tractor. EPA's
trailer testing program investigated the impact of tractor aerodynamics
on the performance of trailer aerodynamic technologies, as mentioned in
Chapter 2.10 of the draft RIA. In order to maintain a minimal level of
performance, we are proposing that tractors used in trailer aerodynamic
tests meet Phase 2 Bin III or better tractor requirements (see Section
III.D.). 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. The standard
tractor for long-box trailers is a Class 8 high-roof sleeper cab. The
standard tractor for short box trailers is a Class 8 high roof day cab.
Trailer manufacturers are free to choose any standard tractor that
meets these criteria in their aerodynamic performance testing. See 40
CFR 1037.501.
(iii) Bins for Aerodynamic Performance
As mentioned in Section IV. D. (1) (a), the agencies are proposing
aerodynamic bins to account for testing variability and to provide
consistency in the performance values used for compliance. These bins
were developed in terms of delta CDA ranges, and designed 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 differences in test method, tractor models,
trailer models and device models.
As discussed in Chapter 2.10 of the draft RIA, measured drag
coefficients and drag areas vary depending on the test method used. In
general, values measured using wind tunnels and CFD tend to be lower
than values measured using the coastdown method. The Phase 1 and
proposed 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
(called ``Falt,aero'') to apply to any of the alternative
test methods. For simplicity, the agencies are not proposing a similar
approach for trailers. We believe that the size of the bins and the use
of change in CDA (as opposed to absolute values) would
minimize the significance of this variability. However, we recognize
that this could be a problem in instances where a manufacturer using a
method other than coastdown produces a trailer with performance near
the upper end of a bin. In such cases, it is possible that adjusting
for methodological differences using a Falt,aero would allow
the manufacturer to achieve a more stringent bin.
We request comment on the proposed approach for evaluating
performance of trailers and establishing bins for trailer compliance.
We specifically request that commenters address the need for an
aerodynamic reference test for trailer performance or additional
strategies for normalizing test methods. For example, would it be
appropriate to allow all manufacturers using wind tunnel or CFD methods
to apply an assigned Falt,aero of 1.10, or another value, to
their results?
Table IV-29--Aerodynamic Bins Used To Determine Inputs for Trailer
Certification
------------------------------------------------------------------------
Average
delta CDA
Delta CDA measured in testing Bin input for
gem
------------------------------------------------------------------------
0.09............................... Bin I................. 0.0
0.10-0.19.......................... Bin II................ 0.1
0.20-0.39.......................... Bin III............... 0.3
0.40-0.59.......................... Bin IV................ 0.5
0.60-0.79.......................... Bin V................. 0.7
0.80-1.19.......................... Bin VI................ 1.0
1.20-1.59.......................... Bin VII............... 1.4
[gteqt] 1.6........................ Bin VIII.............. 1.8
------------------------------------------------------------------------
A manufacturer that wished to perform testing would first identify
a standard tractor (according to 40 CFR 1037.525) and a representative
baseline trailer with no aerodynamic features, then perform the A to B
tests with and without aerodynamic devices and obtain a delta
CDA value. The manufacturer would use Table IV-29 to
determine the appropriate bin based on their delta CDA. Each
bin has a corresponding average delta CDA value which is the
value manufacturers insert into the compliance equation.
(iv) Aerodynamic Device Testing Alternative
The agencies recognize that much of the trailer manufacturing
industry may have little experience with aerodynamic performance
testing. As such, we are proposing an alternative compliance option
that we believe will minimize the testing burden for trailer
manufacturers, meet the requirements of the Clean Air Act and of EISA,
and provide reasonable assurance that the anticipated CO2
and fuel consumption benefits of the program will be realized in real-
world operation.
The agencies are proposing to allow 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 in Section IV. F. (3) (b)(i). Device
manufacturers would perform the required A to B testing of their
device(s) on a trailer that meets the requirements specified in 40 CFR
1037.211 and 1037.525 and submit the performance results, in terms of
delta CDA, directly to EPA.\248\ Trailer manufacturers could
then choose to use these devices and apply their performance levels in
the certification application for their trailer families. This approach
would provide 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 proposed testing alternative is consistent with recommendations of
the SBAR Panel. The Panel Report is summarized below in Section XV.D.
---------------------------------------------------------------------------
\248\ Note that in the event a device manufacturer chooses to
submit such 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.
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If trailer manufacturers wish to use multiple devices with pre-
approved test data, the proposed program provides a process for
combining the effects of multiple devices to determine an appropriate
delta CDA value for compliance. More specifically, such
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.\249\ This
discounting would acknowledge the complex interactions among individual
aerodynamic devices and would provide a conservative value for the
impact of the combined devices. 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:
---------------------------------------------------------------------------
\249\ A trailer manufacturer would need to use good engineering
judgement 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\
In addition, the agencies believe that discounting the delta
CDA values of individually-tested devices used as a
combination would provide a modest incentive for trailer or device
manufacturers to test and get EPA pre-approval of the combination as an
aerodynamic system for compliance. We propose that device manufacturers
be
[[Page 40281]]
allowed to test and receive EPA pre-approval for combinations of
devices, and that trailer manufacturers that wish to use those specific
combinations be allowed to use the results from the tests of the
combined devices.
The agencies note that many of the largest box trailer
manufacturers are already performing aerodynamic test procedures to
some extent, and the agencies expect other box trailer manufacturers
will increasingly be capable of performing these tests as the program
progresses.
The proposed alternative 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 would 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 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. The process to obtain approval is outlined in the
proposed 40 CFR 1037.211.
(4) Use of the Compliance Equation for Trailer Compliance
The agencies are proposing standards for non-box and non-aero box
trailers requiring the use of tires with rolling resistance levels at
or below a threshold, and on ATI systems. As part of their
certification application, manufacturers of these trailers would submit
their tire rolling resistance levels and a description of their ATI
system(s) to EPA. As long as the trailer manufacturer certifies that
they will install the appropriate tires and ATI systems on all of their
trailers, the agencies do not believe it is necessary to require these
trailer manufacturers to use the equation and report the results of the
model to the agencies to demonstrate compliance.
Box trailer manufacturers who apply more than tire technologies to
meet the standards would use the compliance equation to combine the
effects of these technologies and quantify the overall performance of
the vehicle to demonstrate compliance. Trailer manufacturers would
obtain delta CDA and tire rolling resistance values from
testing (either from their own testing or testing performed by another
entity as described previously) and note if they installed a qualifying
automatic tire inflation system or made a component substitution that
qualifies for weight reduction. Manufacturers would directly apply the
delta CDA and TRRL values into the equation, which would
also recognize the use of an ATI system, applying a 1.5 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 trailers
would sum the weight reductions assigned to each component and enter
that total into the equation. The equation would also account for the
use of weight-reducing components, 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.
For this proposal, we are requiring that the equation be used if
the manufacturer is to take advantage of the agencies' proposed
averaging provisions. Prior to submitting a certificate application,
manufacturers would decide which technologies to make available for
their customers and use the equation to determine the range performance
of the packages they will offer. 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
sold. As described in Section IV.F.2.c above, at the end of the year,
manufacturers would submit two reports. One report would include their
production volumes for each configuration. The second report, required
for manufacturers using averaging, would summarize the families and
subfamilies, and CO2 emissions and fuel consumption results
from the equation for all of the trailer configurations they
build.\250\
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\250\ We are not proposing to allow manufacturers to ``bank''
credits to the following year if a manufacturer over-complies on
average for a given model year. We are proposing to allow
manufacturers to generate temporary deficits if they under-comply on
average. These deficits would need to be resolved within three model
years. See Section IV.F.7.a below and 40 CFR 1037.250, 40 CFR
1037.730, and 49 CFR 535.7.
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Box trailer manufacturers that do not participate in averaging
would also use the compliance equation to ensure that all of the
trailer configurations they offer would meet the standard for the given
model year. These calculations using the equation could be performed by
the manufacturer prior to submitting a certificate application, but it
is not necessary for the manufacturer to continue to calculate
emissions and fuel consumption throughout the model year unless a new
technology package is offered. These manufacturers would submit a
single end-of-year report that would include their production volumes
and confirmation that all of their trailers applied the technology
packages outlined in their application.
(5) 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 also proposes to adopt EPA's useful life requirements
for trailers 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. Based on our own research and discussions
with trailer manufacturers, EPA and NHTSA are proposing a regulatory
useful life value for trailers of 10 years. This useful life represents
the average duration of the initial use of trailers, before they are
moved into less rigorous (e.g., limited use or storage) duty. We note
that the useful life value is 10 years for other heavy-duty vehicles.
However, unlike the other vehicles, we are not proposing to set a mile
value for trailers because we do not require odometers for trailers.
Thus, we propose that trailer manufacturers be responsible for
meeting the CO2 emissions and fuel consumption standards for
10 years after the trailer is produced. We believe that manufacturers
would be able to demonstrate at certification that their trailers will
comply for the useful life of the trailers without durability testing.
The aerodynamic technologies that we expect manufacturers to use to
comply with the proposed 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. See also Section
IV.C.6 above describing why we are not proposing separate in-use
standards.
Regarding 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
[[Page 40282]]
performance of their trailer for its useful life, we are proposing to
require that trailer manufacturers supply adequate information in the
owner's manual to allow the trailer owner to purchase replacement tires
meeting or exceeding the rolling resistance performance of the original
equipment tires. We believe that the favorable fuel consumption benefit
of continued use of LRR tires would generally result in proper
replacements throughout the 10-year useful life. Finally, we are
requiring that ATI systems remain effective for at least the 10 year
useful life, although some servicing may be necessary. See the
maintenance discussion in Section IV.D.4.e.
(b) Emission Control Labels
Historically, EPA-certified vehicles are required to have a
permanent emission control label affixed to the vehicle. The label
facilitates the identification of the vehicle as a certified vehicle.
For the trailer program, EPA proposes that the labels include the same
basic information as we are proposing to require for tractor labels.
For trailers, this information would include 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 proposed Phase 2 label for tractors
would not include emission control system identifiers (as previously
required for tractors in the Phase 1 program in 40 CFR 1037.135(c)(6)),
we are proposing that these identifiers be included in the trailer
labels. As for tractors, we would require manufacturers to maintain
records that would allow us to verify that an individual trailer was in
its certified configuration.
(c) Warranty
Section 207 of the CAA requires manufacturers to warrant their
products to be free from defects that would otherwise cause non-
compliance with emission standards. For purposes of the proposed
trailer program, EPA would require trailer manufacturers to warrant all
components that form the basis of the certification to the
CO2 emission standards. The emission-related warranty would
cover all aerodynamic devices, lower rolling resistance tires,
automatic tire inflation systems, and other components that may be
included in the certification application.
The trailer manufacturer would need to warrant that these
components and systems are designed to remain functional for the
warranty period. Based on the historical practice of requiring
emissions warranties to apply for half of the useful life, we propose
that the warranty period for trailers be 5 years for everything except
tires. For trailer tires, we propose to apply a warranty period of 1
year. Manufacturers could offer a more generous warranty if they chose;
however the emissions related warranty may not be shorter than any
other warranty offered without charge for the vehicle. If aftermarket
components were installed (unrelated to emissions performance) that
offer a longer warranty, this would not impact emission related
warranty obligations of the vehicle manufacturer. NHTSA is not
proposing any warranty requirements relating to its trailer fuel
consumption program.
At the time of certification, manufacturers would need to supply a
copy of the warranty statement that they would supply to the end
customer. This document would outline what is covered under the GHG
emissions related warranty as well as the duration of coverage.
Customers would also 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
maintenance schedules to keep their product in compliance with emission
standards throughout the useful life of the vehicle (CAA section 207).
For trailers, such maintenance could include fairing adjustments or
service to ATI systems. However, EPA believes that any such maintenance
is likely to be performed by operators to maintain the fuel savings of
the components, and we are not proposing that trailer manufacturers be
required submit a maintenance schedule for these components as part of
its application for certification.
Since low rolling resistance tires are key emission control
components under this program, and will likely require replacement at
multiple points within the life of a vehicle, it is important to
clarify how tires would 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 propose to
hold trailer manufacturers responsible for the actions of operators. We
do not see this as problematic because we believe that trailer
operators have a genuine financial motivation for ensuring their
vehicles are as fuel efficient as possible, which includes purchasing
LRR replacement tires. Therefore, as mentioned in Section IV.F.5.a
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, we are
proposing to require that trailer manufacturers supply adequate
information in the owner's manual to allow the trailer owner to
purchase tires meeting or exceeding the rolling resistance performance
of the original equipment tires. We would require that these
instructions be submitted to EPA as part of the application for
certification.
(e) Post-Useful Life Modifications
Under 40 CFR part 1037, EPA generally prohibits for any person from
removing or rendering inoperative any emission control device installed
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. EPA is
proposing for this section to apply trailers, since it applies to all
vehicles subject to 40 CFR part 1037, and requests comment on it.
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. In the case of trailers, this
essentially requires a trailer owner 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. Thus, this provision does not
provide a blanket allowance for modifications after the useful life.
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 are presumed to
violate 42 U.S.C. 7522(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 would not cause the vehicle to exceed any
applicable standard.
(6) Flexibilities
The trailer program that the agencies are proposing incorporates a
number of provisions that would have the effect of providing
flexibility and easing the compliance burden on trailer manufacturers
while maintaining the
[[Page 40283]]
expected CO2 and fuel consumption benefits of the program.
Among these is the basic approach we used in setting the proposed
standards, including the staged phase-in of the standards, which would
gradually increase the CO2 and fuel consumption reductions
that manufacturers would need to achieve over time as they also
increase their experience with the program. As described in the general
certification discussion above (Section IV.F.2), another proposed
provision would allow trailer manufacturers to designate broad trailer
families that would aggregate several models with similar technologies
or performance, thus potentially limiting the number of families and
the associated family-level compliance requirements.
In addition to these provisions inherent to the proposed trailer
program, the agencies are proposing additional options for
certification that we believe would be very valuable to many trailer
manufacturers. One of these is the proposed process for component
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. See Section IV.F.4 above.
(a) Proposed Averaging Provisions
The agencies are also proposing a limited averaging program as a
part of the trailer compliance process for box trailers. This program
would be similar to the Phase 1 averaging program for other sectors,
but would be narrower in scope to reflect the unique competitive
aspects of the trailer market. The trailer manufacturing industry is
very competitive, and manufacturers must be highly responsive to their
customers' diverse demands. Compared to other industry sectors, this
reality can limit the value of the flexibility that averaging could
provide to trailer manufacturers, since 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. In
addition, the majority of trailer manufacturers have very few basic
trailer models to offer, potentially putting them at a competitive
disadvantage to the small number of larger companies that would be in a
position to meet market demands that the smaller companies could not.
For example, 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.
Although we recognize that there might be potential negative
impacts on at least some trailer manufacturers of an averaging program,
we believe that there may be overall value to such a program. We
propose that full-aero box trailer manufacturers may optionally comply
with their standards on average for a trailer family in any given model
year. We are not proposing to allow partial-aero box trailers to
average. Instead, all trailers in partial-aero families would need to
meet the standard for that subcategory. We are proposing to allow a
trailer manufacturer to combine partial-aero box trailers with the
corresponding full-aero trailer family and reduce the number of
certification applications required. We expect this to be particularly
beneficial to manufacturers in the early years of the program, when
these two trailer categories have identical standards. Although this
option should reduce the compliance paperwork, the partial-aero
trailers would not be able to adopt enough technologies to meet the
full-aero standards in the later years, and manufacturers would have
the option of creating a separate family for these trailers.
Additionally, we are proposing to allow refrigerated trailers to
combine with the dry vans of the same length and meet the dry van
standards and to allow short box vans to combine with their long box
counterparts to meet the long box standards.
Unlike averaging programs in other sectors, including those in this
Phase 2 program, we propose that averaging be limited to a single model
year, and manufacturer not be allowed to ``bank'' credits generated
from over-compliance in one year for use in a future year. In other
words, a manufacturer that produces some trailers in a family that
perform better than required by the applicable standard would be
allowed to produce a number of trailers that do not meet the standards,
provided the average of the trailers it produces in any given model
year is at or below the standards. A trailer family performing better
than the standard would not be allowed to bank credits for a future
model year.\251\ However, as a temporary recourse for unexpected
challenges in a given model year, we propose that manufacturers be
allowed to generate a deficit that would be resolved within the next
three model years, and to allow the manufacturer to use credits they
generate from over-compliance in subsequent years to address deficits
from prior model years. As discussed below, we are not proposing this
allowance for non-box trailers or non-aero trailers.
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\251\ Section IV.F.2 describes the process of identifying
trailer families and sub-families based on basic trailer
characteristics. Section 1037.710 of the proposed regulations
describes the provisions for establishing subfamilies within a
trailer family and the Family Emission Limits that would be averaged
among the subfamilies.
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We recognize that at each stage of the program, there may be a
small fraction of trailer applications for which the trailer
manufacturers cannot easily apply all of the aerodynamic and tire
technologies. Thus the proposed dry and refrigerated van standards are
designed in the form of family average performance, meaning that each
trailer manufacturer would comply on average across the trailer
families it produces within each subcategory category (or family). The
proposed program would allow a manufacturer, for example, to comply
without full adoption of aerodynamic devices across 100 percent of its
box trailer production in a trailer family, as long as it also produced
a sufficient number of trailers within that family that performed
better than the standard, such that the overall production-weighted
CO2 and fuel consumption results of the trailer models in
that family complied with the appropriate standard.
In addition to the flexibility created by averaging, the proposed
box trailer standards themselves are not predicated on a set adoption
rate of any one technology. Manufacturers would be free under the
proposed averaging program to choose to apply the appropriate number
and type of technologies that met their customers' needs and the level
of performance required within a particular trailer family. The
proposed rules in general do not mandate inclusion of any particular
technology or other means of emission control. The agencies believe
that, ordinarily, averaging would create an incentive for manufacturers
to promote high-performing technologies for some customers, beyond the
requirements for that given year, in order to provide other customers
with trailers with fewer aerodynamic technologies.
The agencies also recognize, however, that an averaging program
would inherently require a higher degree of data management, record
keeping, and reporting than one without averaging. Recognizing that
this could impose burdens, especially on small business manufacturers,
the agencies are proposing that the averaging provisions be optional; a
box trailer manufacturer could choose whether to use averaging
[[Page 40284]]
for any or all of its standard box trailer subcategories (families), or
to forego averaging and simply meet the standards with 100 percent of
the production within each family. Also, unlike some other regulated
motor vehicle sectors, we are not proposing that credits from over-
compliance be able to be ``banked'' for use in a later model year, or
to be ``traded'' among trailer manufacturers, since they would
exacerbate the competitive issues, especially for small manufacturers,
as discussed immediately below. However, we are proposing to apply to
trailers the provisions of Phase 1 for tractors that allow for the
generation of a compliance deficit that could be resolved over several
years. Thus, a manufacturer that chose to use averaging, but by the end
of the production year found that a trailer family's CO2 and
fuel consumption values did not reach that year's standards, could
carry a ``deficit'' that would need to be resolved by the third year
following.
The availability of averaging options also has the potential to be
a disadvantage to some companies in a competitive market that is highly
customer-driven. During the SBREFA process, several manufacturers
expressed concern about their ability to manage their credit balances
in a highly competitive market. Many believe that they would have
little ability to essentially force their customers to purchase the
technology, especially if other manufacturers that had credits were
able to sell trailers without the technology. We see this as especially
problematic for non-box trailers, which are much more likely to be
produced by small businesses, and for which customers may have less
interest in fuel savings technologies since they are less often used
long-haul applications than are box trailers. For these reasons, we are
proposing averaging only for dry and refrigerated vans.
The agencies understand that averaging is unfamiliar to many
trailer manufacturers and other stakeholders. We have drafted a
supplementary document that includes example scenarios to illustrate
the concept of averaging for a hypothetical box trailer
manufacturer.\252\ Example adoption rates are provided for a standard
compliance strategy (no averaging) and a strategy using the proposed
averaging provisions.
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\252\ Memorandum dated March 2015 on Example Compliance
Scenarios for the Proposed GHG Phase 2 Trailer Program. Docket EPA-
HQ-OAR-2014-0827.
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One value of averaging that the agencies have historically cited in
several other motor vehicle regulatory programs is that the
availability of averaging provisions made it possible for the agencies
to propose and enact more stringent standards than would otherwise have
been appropriate, recognizing that the expected flexibility of
averaging provisions would ease the path to compliance by the more
challenged members of the industry. In the case of trailer
manufacturers, however, our decisions on the proposed stringency of the
standards is essentially independent of the presence or absence of
averaging, since, as discussed above, averaging provisions may have
relatively less value to manufacturers in this customer-driven industry
and we did not speculate about much or how little it might be used.
We also request comment on whether the burden of managing an
averaging program could be more trouble than the flexibility is worth.
In the event that averaging were not allowed, the agencies would need
to require that all trailers meeting specified characteristics meet a
minimum stringency level without averaging. If we were to finalize such
non-averaging standards, manufacturers would still be allowed to select
the appropriate technology package that best achieved their emission
performance level, but they would not have the ability to accommodate
customers that may request trailers that perform less well on an
individual trailer basis.
It is also worth noting that the agencies are not proposing to
allow any generation of early credits before MY 2018. It is clear to us
that small businesses would be less prepared to begin complying early
than larger businesses, and that allowing large manufacturers to
generate early credits that could be used later could put small
businesses at a competitive disadvantage. It does not appear to us that
there would be a sufficient broader programmatic benefit from early
credits to justify such an adverse impact on small businesses.
We request comment on this proposed averaging option, including
whether the program should allow credit and deficit banking and credit
trading, as well as on any other potential provisions that could
provide compliance flexibility for trailer manufacturers while
achieving the goals of the overall program. Comments supporting
averaging, banking, or trading should explain how these provisions
would be valuable for trailer manufactures across the industry,
including how the provisions would maintain a ``level playing field.''
(b) Proposed SmartWay-Based Certification
Since many manufacturers have some experience with the SmartWay
program, the agencies are proposing a gradual transition to the
proposed approach that recognizes the parallel SmartWay Technology
Program. The agencies expect aerodynamic device manufacturers to
continue to submit test data to SmartWay for verification. Device
manufacturers that also wish to have their technology available for
trailer manufacturers to use in the Phase 2 program could, in parallel,
submit their test data to EPA for pre-approval for Phase 2 (see Section
IV.F.4). The information obtained by EPA from the device manufacturers
would include the technology name, a description of its proper
installation procedure, and its corresponding delta CDA
derived from the approved test procedures. Any manufacturers that
attained SmartWay verification prior to January 1, 2018 would be
eligible to submit their previous data to EPA's Compliance Division for
pre-approval, provided their test results come from 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. The agencies request comment on
whether we should pre-approve devices tested using SAE J1321 and also
seek comment on an appropriate means of converting from the fuel
consumption results of that test to the delta CDA values
required for trailer compliance.
Beginning on January 1, 2018, EPA would require that device
manufacturers that wish to seek approval of new technologies for
trailer certification use one of the approved test methods for Phase 2
(i.e., coastdown, constant speed, wind tunnel or CFD) and the test
procedures found in 40 CFR 1037.525. Technologies that were pre-
approved using SmartWay's 2014 Protocols would maintain their approved
status until CY 2021. After January 1, 2021, we are proposing that all
pre-approved aerodynamic trailer technologies be tested using the Phase
2 test procedures.
(c) Off-Cycle Technologies
The Phase 1 and proposed Phase 2 programs for tractors include
provisions for manufacturers to request the use of off cycle
technologies that are not recognized in GEM or were not in common use
before MY 2010. In the
[[Page 40285]]
case of trailers, the agencies are not aware of any technologies that
could improve CO2 and fuel consumption performance that
would not be captured in the test protocols as proposed. We are
therefore not proposing a process to evaluate off-cycle trailer
technologies.
(d) 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 flexibilities proposed.\253\ 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 standards compared
to other entities. Thus, as discussed below, we are proposing several
regulatory flexibility provisions for small trailer manufacturers that
we believe would reduce the burden on them while achieving the goals of
the program.
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\253\ Additional information regarding the findings and
recommendations of the Panel are available in Section XIV, Chapter
11 of the draft 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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We believe that the small business regulatory flexibilities
discussed below and in Section XV.C could provide these entities with
reduced compliance requirements and/or additional time to accumulate
capital internally or to secure capital financing from lenders, and to
acquire additional engineering and testing resources.
The agencies designed many of the proposed program elements and
flexibility provisions available to all trailer manufacturers with the
large fraction of small business trailer manufacturers in mind. We
believe the option to choose pre-approved aerodynamic devices would
significantly reduce the compliance burden and eliminate the
requirement for all manufacturers to perform testing.
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 would not be able to generate the same volume of credits as
large manufacturers. The agencies are proposing not to include banking
and trading provisions in any part of the program, and are limiting the
option to average to manufacturers of dry and refrigerated box
trailers. Since a majority of non-box trailer manufacturers are small
businesses, we believe a requirement of specific tire technologies for
all non-box trailers would create the most uniformity in requirements
among manufacturers and would reduce the compliance burden by
eliminating the use of the compliance equation.
In addition to the provisions offered to trailer manufacturers of
all sizes, the agencies are proposing or requesting comment on several
additional provisions designed specifically to ease compliance burdens
on small trailer manufacturers. For all small business trailer
manufacturers, the agencies propose a one-year delay in the beginning
of implementation of the program, until MY 2019. We believe (subject to
consideration of public comment) that this would allow small businesses
additional needed lead-time to make the proper staffing adjustments and
process changes, and possibly add new infrastructure to meet the
requirements. We also request comment about where there may be
circumstances in later stages of the program, when the stringency of
the standards increase in MY 2021 and 2024, when a similar 1-year delay
in implementation could be warranted for small trailer manufacturers.
As mentioned previously, we are proposing to offer averaging
provisions for manufacturers of dry and refrigerated box trailers only.
We recognize that the small box trailer manufacturers may not be able
to fully take advantage of averaging and may be at a competitive
disadvantage with larger manufacturers with larger sales volumes and
more diverse product lines. We request comment on additional provisions
that could ease the potential harm to and/or incentivize small business
participation in an averaging program.
The agencies also request comment on provisions for small
manufacturers that might face a situation where the technologies needed
for compliance are unavailable. This could be a particular concern for
small business non-box and non-aero box trailers that require the use
of LRR tires and ATI systems. We request that trailer manufacturers as
well as tire and aerodynamic technology manufacturers provide
information regarding the current projected availability of the
technologies that trailer manufacturers can use to meet our proposed
standards.
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 20 percent of the GHG emissions and
burn approximately 21 percent of the fuel consumed by today's heavy-
duty truck sector.\254\
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\254\ See Memorandum to the Docket ``Runspecs and Model Inputs
for MOVES for HD GHG Phase 2 Emissions Modeling'' Docket Number EPA-
HQ-OAR-2014-0827. See also EPA's MOVES Web page at http://www.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 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.
[[Page 40286]]
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.\255\
In that same year, 74 percent of final stage manufacturers produced
less than 500 units.
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\255\ 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 would
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 would lead 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) would 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 would be 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.\256\
---------------------------------------------------------------------------
\256\ See 2013 ICCT Barriers Report at Note 241, above.
---------------------------------------------------------------------------
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 propose to apply the Phase 2 vocational
vehicle standards at the chassis manufacturer level.\257\
---------------------------------------------------------------------------
\257\ See 76 FR 57120.
---------------------------------------------------------------------------
The Phase 1 regulations prohibit the introduction into commerce of
any heavy-duty vehicle without a valid certificate or exemption. 40 CFR
1037.620, redesignated as 40 CFR 1037.622 in the proposed rule, allows
for a temporary exemption for the chassis manufacturer if it produces
the chassis for a secondary manufacturer that holds a certificate.
Further discussion of temporary exemptions and possible obligations of
secondary manufacturers can be found in Section V. E.
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.\258\ 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 propose to retain the vocational tractor
definition, and to allow vocational tractors to certify over any of the
proposed vocational vehicle duty cycles, following the same decision-
tree as other vocational chassis. Vocational tractors would continue to
satisfy the proposed engine standard and vocational vehicle GEM-based
standard, rather than the proposed tractor standard.
---------------------------------------------------------------------------
\258\ See EPA's regulation at 40 CFR 1037.630 and NHTSA's
regulation at 49 CFR 523.2.
---------------------------------------------------------------------------
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
within the same averaging set to comply on average. 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.\259\
---------------------------------------------------------------------------
\259\ 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).
---------------------------------------------------------------------------
B. Proposed Phase 2 Standards for Vocational Vehicles
The agencies have held dozens of meetings with manufacturers,
suppliers, non-governmental organizations (NGOs), and other
stakeholders to identify and understand the opportunities and
challenges involved with regulating vocational vehicles. These meetings
have helped us to better understand the performance demands of the
customers, the fuel-saving and GHG reducing technologies that are being
investigated, as well as some challenges that are being encountered. In
addition, we updated our industry characterization to better understand
the vocational vehicle manufacturing process, including the component
suppliers and body builders.\260\ We believe these information
exchanges have enabled us to develop this proposal with an appropriate
balance of
[[Page 40287]]
reasonably achievable goals and a reasonably small risk of unintended
consequences.
---------------------------------------------------------------------------
\260\ September 2013, Heavy Duty Vocational Vehicle Industry
Characterization, EPA Contract No. EP-C-12-011.
---------------------------------------------------------------------------
(1) Proposed Subcategories and Test Cycles
The proposed Phase 2 vocational vehicle standards are based on the
performance of a wider array of control technologies than the Phase 1
rules. In particular, the agencies are proposing to recognize detailed
characteristics of powertrains and drivelines in the proposed Phase 2
vocational vehicle standards. 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
would 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
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 be as low as 3.1:1
(delivery vehicle) and as high as 9.8:1 (transit bus).\261\ 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 and recognize
that the agencies cannot use a one-size-fits-all approach. A detailed
list of the technologies the agencies project could be adopted to meet
the proposed vocational vehicle standards is described in Section V.C,
and in the draft RIA Chapter 2. The agencies have determined that these
technologies perform differently depending on the drivelines and
driving patterns, further supporting the need to subcategorize this
segment.
---------------------------------------------------------------------------
\261\ 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
---------------------------------------------------------------------------
For these reasons, the agencies are proposing to create additional
subcategories of vocational vehicles in Phase 2. By creating additional
subcategories we would essentially be setting separate baselines and
separate numerical performance standards for different groups of
vocational vehicle chassis over different test cycles. This would
enable the technologies that perform best at highway speeds and those
that perform best in urban driving to each to be fully recognized over
appropriate test cycles, while avoiding the unintended consequence of
forcing vocational vehicles that are designed to serve in a wide
variety of applications to be measured against a single baseline. The
attributes we believe could define these chassis groups are described
below.
The agencies are proposing to split groups of chassis into
subcategories based generally on vehicle use patterns in which the
CO2 emissions and fuel consumption standards vary as a
consequence. Compliance with these standards would be demonstrated
through test cycles reflecting these use patterns, to best assure that
actual in-use benefits occur. An ideal test cycle is one in which the
performance improvements achieved by the adopted technologies are
recognized over the cycle. As described in Section V.C and in the draft
RIA Chapter 2.9, the agencies have found that most of the technologies
considered do perform differently under different driving conditions.
For example, the effectiveness of lower tire rolling resistance is
different depending on the degree of highway or transient driving, but
the differences are very small compared to the difference in
effectiveness for a hybrid drivetrain under different driving
conditions. The agencies have found that the measurable changes in
performance of a majority of the technologies are significant enough to
merit creation of different subcategories with different test cycles.
Idle reduction technology is one type of technology that is
particularly duty-cycle dependent. The composite test cycle for
vocational vehicles in Phase 1 includes a 42 percent weighting on the
ARB Transient test cycle, which comprises nearly 17 percent of idle
time. However, no single idle event in this test cycle is longer than
36 seconds, which may not be enough time to adequately recognize the
benefits of some idle reduction technologies.\262\ For Phase 2, the
agencies propose to recognize this important fuel saving technology by
evaluating workday idle reduction technologies through a new idle-only
cycle as described in the draft RIA Chapter 3.
---------------------------------------------------------------------------
\262\ However, as noted above, emission improvements due to
workday idle technology can be recognized under Phase 1 as an
innovative credit under 40 CFR 1037.610 and 49 CFR 535.7.
---------------------------------------------------------------------------
The agencies are proposing three different composite test cycles
for vocational vehicles in Phase 2: Regional, Multi-Purpose, and Urban.
The agencies believe these three cycles balance the competing pressures
to recognize the varying performance of technologies, serve the varying
needs of customers, and maintain reasonable regulatory simplicity.
Table V-1 below presents the nine proposed subcategories of vocational
vehicles: Three weight class groupings, each with three composite duty
cycles. Each of these proposed composite duty cycles has a different
weighting of the new idle cycle, the highway cruise cycles, and the ARB
Transient cycle, as shown in Table V-2. The CALSTART HD Truck Fuel
Economy Task Group met in June 2013 to discuss vocational vehicle
segmentation, and suggested an approach very similar to this. The task
group generally supported a limited number of duty cycles that would be
sufficient to cover the basic applications while allowing new
technology to demonstrate its worth. They recognized that a few
meaningful duty cycles could ``bound'' how vocational vehicles are
generally used, while recognizing that this approach would not
perfectly match how every vocational vehicle is actually used. Their
recommendations included three vocational vehicle duty-cycle-based
subcategories: Urban, Regional, and Work Site. A detailed discussion of
the CALSTART recommendations, as well as reasoning why the agencies
selected the proposed composite cycle weightings can be found in the
draft RIA Chapter 2. Continuing the averaging scheme from Phase 1, each
manufacturer would be able to average within each vehicle weight class.
[[Page 40288]]
Table V-1--Proposed Regulatory Subcategories for Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-duty class 2b- Medium heavy-duty class 6-
Weight class 5 7 Heavy heavy-duty class 8
----------------------------------------------------------------------------------------------------------------
Duty Cycle.................. Regional.................. Regional.................. Regional.
Multi-Purpose............. Multi-Purpose............. Multi-Purpose.
Urban..................... Urban..................... Urban.
----------------------------------------------------------------------------------------------------------------
Table V-2--Proposed Composite Test Cycle Weightings (in Percent) for Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
55 mph cruise 65 mph cruise
ARB transient with road with road Idle
grade \a\ grade \a\
----------------------------------------------------------------------------------------------------------------
Regional........................................ 50 28 22 10
Multi-Purpose................................... 82 15 3 15
Urban........................................... 94 6 0 20
----------------------------------------------------------------------------------------------------------------
Note:
\a\ As described in Section III.E.2.b, the agencies are proposing to add road grade to the highway cruise test
cycles.
The agencies are proposing criteria for determining the
applicability of these subcategories. This is not as straightforward an
exercise as with tractors, where attributes such as cab type are
obvious physical properties that indicate reasonably well how a vehicle
is intended to be used. The agencies have identified the final drive
ratio of a vocational vehicle as a possible attribute that may indicate
how the vehicle is intended to be used. As described in Section
V.E.(1)(d), we expect that most vocational chassis could be assigned to
a duty cycle by estimating the percent of maximum engine test speed
that is achieved over highway cruise cycles, by use of an equation that
relates engine speed to vehicle speed. To simplify this assignment
process, the agencies propose that a vocational chassis would be
presumed to certify using the Multi-Purpose duty cycle unless some
criteria were met that indicated either the Regional or Urban cycle
would be more appropriate. Those criteria could include the objective
calculation described in Section V.E., or a mix of physical attributes
and knowledge of intended use. The agencies are also proposing that
chassis manufacturers would be able to request a different duty cycle.
We understand that even within certain vocational vehicle types,
vehicle use varies significantly. By employing the agencies'
recommended assignment process, it is our expectation that a delivery
truck and a dump truck could both be certified over the same duty cycle
while still yielding accurate technology effectiveness, if they had
similar chassis and driveline characteristics. Further, while intended
service class may help a manufacturer decide how to classify some
vehicles, we do not believe that intended service class would be a
sufficient indicator by itself. An example of this is the refuse
service class. A neighborhood collection refuse truck would not need to
be assigned to the same subcategory as a roll-off refuse straight/dump
truck that makes daily highway trips to a landfill.
The agencies request comment on the method for assigning vocational
chassis to regulatory subcategories. We believe the proposed approach
is aligned with the objective to allow manufacturers to certify their
chassis over appropriate duty cycles, while maintaining the ability of
the market to offer a variety of products to meet customer demand.
(2) Alternative Approach to Subcategorization
The U.S. Department of Energy and EPA are partnering to support a
project aimed at evaluating, refining and/or developing duty cycles for
tractors and vocational vehicles to be used in the certification of
heavy-duty vehicles to GHG emission standards. This project is underway
at the National Renewable Energy Laboratory (NREL) and includes a task
to develop alternative subcategorization options for vocational
vehicles, along with new drive cycles and/or cycle composite
weightings. NREL is continuing to collate available vehicle activity
data and vehicle characteristics, and the public is invited to submit
information to the docket in support of this work to identify possible
alternative GEM test cycles and segmentation options for vocational
vehicles. Preliminary work under this project indicates that two or
three test cycles may adequately represent most vocational vehicles.
Depending on how many distinct vehicle driving patterns can be
identified with correlation to vehicle attributes, the agencies may
finalize a vocational subcategorization approach that includes as few
as two or as many as five composite GEM duty cycles. It is also
possible that some test cycles may not apply to all subcategories. It
is further possible that the approach to assignment of vocational
chassis to subcategories in the final rules may be based on different
attributes than those proposed, including different engine and
driveline characteristics and different indicators of vehicle purpose.
Preliminary work from NREL indicates that in-use drive cycles may
include more idle operation for all types of vocational vehicles than
is represented by the currently proposed GEM test cycles. Depending on
comments and additional information received during the comment period,
it may be within the agencies' discretion to adopt one or more
alternative vocational vehicle test cycles, or re-weight the current
test cycles, to better represent real world driving and better reflect
performance of the technology packages.
(3) Proposed GHG and Fuel Consumption Standards for Vocational Vehicles
EPA is proposing CO2 standards and NHTSA is proposing
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 proposing test procedures so that engine performance
would 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 proposing to establish HFC leakage
standards for air conditioning systems in vocational vehicles, as
described
[[Page 40289]]
below and in the draft RIA Chapters 2 and 5.
This section describes the standards and implementation dates that
the agencies are proposing for the nine subcategories of vocational
vehicles. The agencies have performed a technology analysis to
determine the level of standards that we believe would be available at
reasonable cost, and would be cost-effective, technologically feasible,
and appropriate in the lead time provided. More details of this
analysis are described in the draft RIA Chapter 2. This analysis
considered the following for each of the proposed 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 would 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 proposal described here and throughout the rulemaking documents
is the preferred alternative, referred to as Alternative 3 in Section X
and the draft RIA Chapter 11. However, the agencies are seriously
considering another alternative for all segments, including vocational
vehicles, referred to as Alternative 4. The agencies believe that
Alternative 4 has the potential to be the maximum feasible and
reasonable alternative. However, based on the evidence currently before
the agencies, EPA and NHTSA have outstanding questions regarding
relative risks and benefits of Alternative 4 due to the time frame
envisioned by that alternative. Alternative 4 is predicated on the same
general market adoption rates of the same technologies as the proposal,
but would provide three years less lead time than the proposal. Details
of Alternative 4 are presented in Section V.D, Section X, and in the
draft RIA Chapter 11.
The agencies seek comment on the feasibility of Alternative 4 for
vocational vehicles, including empirical data on its appropriateness,
cost-effectiveness, and technological feasibility. It would be helpful
if comments addressed these issues separately for each type of
technology.
Additional information and feedback could further inform our
assumptions and, by extension, our analysis of feasibility. The
agencies believe it is possible that it could be within the agencies'
discretion to determine in the final rules that Alternative 4 could be
maximum feasible and appropriate under CAA section 202(a)(1) and (2).
If the agencies receive relevant information supporting the feasibility
of Alternative 4, or regarding technology pathways different than those
in Alternatives 3 and 4, the agencies may consider establishing final
fuel consumption and GHG emission standards at levels that provide more
overall reductions than what we are proposing if we deem them to be
maximum feasible and reasonable for NHTSA and EPA, respectively.
(a) Proposed Fuel Consumption and CO2 Standards
The agencies are proposing standards that would 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 proposed Phase 2 program would progress
in three-year stages with an intermediate set of standards in MY 2024
and would 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 would be projected to achieve improvements of 16
percent in MY 2027 over the MY 2017 baseline, as described below and in
the draft RIA Chapter 2. The agencies project up to 13 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 would ensure steady
progress toward the MY 2027 standards, with improvements in MY 2021 of
up to seven percent and improvements in MY 2024 of up to 11 percent
over the MY 2017 baseline vehicles, as shown in Table V-3.
The agencies' analyses, as discussed in this preamble and in the
draft RIA Chapter 2, show that the proposed standards would be
appropriate under each agency's respective statutory authority.
Table V-3--Projected Vocational Vehicle CO2 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 7 6
SI Engine............... 5 5 4
2024.................................. CI Engine............... 11 11 10
SI Engine............... 7 7 7
2027.................................. CI Engine............... 16 16 16
SI Engine............... 12 13 12
----------------------------------------------------------------------------------------------------------------
Based on our analysis and research, the agencies believe 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. In developing the proposed standards, the agencies
have evaluated 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 examining the possibilities of vehicle
improvements, the agencies are basing the proposed standards on the
performance of workday idle reduction technologies, improved
transmissions
[[Page 40290]]
including hybrid powertrains, axle technologies, weight reduction, and
further tire rolling resistance improvements. The EPA-only air
conditioning standard is based on leakage improvements.
The agencies' evaluation indicates that some of the above vehicle
technologies are commercially available today, though often in limited
volumes. Other technologies would 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, EPA is not proposing standards predicated on performance of
these technologies until MY 2021.\263\ The agencies consider 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 would
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 we anticipate
that the Phase 1 standards will continue to apply in model years 2018
to 2020.
---------------------------------------------------------------------------
\263\ NHTSA is unable to adopt mandatory amended standards in
those model years since there would be less than the statutorily-
prescribed amount of lead time available. 49 U.S.C. 32902(k)(3)(A).
---------------------------------------------------------------------------
Vehicle technologies that we believe will become available in the
near term include improved axle lubrication and 6x2 axles. Vehicle
technologies that we understand would benefit from even more
development time 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 would be expected to take
to reduce fuel consumption and emissions to achieve the standards, and
believe that the standards would be technologically feasible throughout
the regulatory useful life of the program. EPA and NHTSA estimated
vehicle package costs are found in Section V.C.(2).
Table V-4 and Table V-5 present EPA's proposed CO2
standards and NHTSA's proposed 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 would be 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 would be measured in units of
grams CO2 per ton-mile and the NHTSA standards would be 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 would assign 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 numerical
values of the proposed standards for each weight class group.
EPA's proposed vocational vehicle CO2 standards and
NHTSA's proposed 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. The
standards for vehicles powered by CI engines also reflect that in MY
2024, the separate engine standard would be more stringent, so the
vehicle standard keeps pace with the engine standard.
EPA's proposed vocational vehicle CO2 standards and
NHTSA's proposed 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 in the basis for the previous stages of the
Phase 2 standards. The proposed MY 2027 standards for vocational
vehicles powered by CI engines reflect additional engine technologies
consistent with those on which the separate proposed MY 2027 CI engine
standard is based. The proposed MY 2027 standards for vocational
vehicles powered by SI engines reflect improvements due to additional
engine friction reduction technology, which is not among the
technologies on which the separate SI engine standard is based.
The proposed standards are based on highway cruise cycles that
include road grade, to better reflect real world driving and to help
recognize engine and driveline technologies. See Section III.E. The
agencies have evaluated some alternate road grade profiles, including
several recommended by NREL and two developed independently by the
agencies, and have prepared possible alternative vocational vehicle
standards based on these profiles. The agencies request comment on this
analysis, which is available in a memorandum to the docket.\264\
---------------------------------------------------------------------------
\264\ See Memorandum dated May 2015 on Possible Tractor,
Trailer, and Vocational Vehicle Standards Derived from Alternative
Road Grade Profiles.
---------------------------------------------------------------------------
As described in Section I, the agencies are proposing to continue
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 that belong to the same weight class group and have
the same regulatory useful life.
Table V-4--Proposed EPA CO2 Standards for MY 2021 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-
Duty cycle duty class 2b- Medium heavy- Heavy heavy-
5 duty class 6-7 duty class 8
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with CI Engine Effective MY 2021 (gram CO2/ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 296 188 198
Multi-Purpose................................................... 305 190 200
Regional........................................................ 318 186 189
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with SI Engine Effective MY 2021 (gram CO2/ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 320 203 214
[[Page 40291]]
Multi-Purpose................................................... 329 205 216
Regional........................................................ 343 201 204
----------------------------------------------------------------------------------------------------------------
Table V-5--Proposed NHTSA Fuel Consumption Standards for MY 2021 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-
Duty cycle duty class 2b- Medium heavy- Heavy heavy-
5 duty class 6-7 duty class 8
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with CI Engine Effective MY 2021 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 29.0766 18.4676 19.4499
Multi-Purpose................................................... 29.9607 18.6640 19.6464
Regional........................................................ 31.2377 18.2711 18.5658
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with SI Engine Effective MY 2021 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 36.0077 22.8424 24.0801
Multi-Purpose................................................... 37.0204 23.0674 24.3052
Regional........................................................ 38.5957 22.6173 22.9549
----------------------------------------------------------------------------------------------------------------
Table V-6--Proposed EPA CO2 Standards for MY 2024 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-
Duty cycle duty class 2b- Medium heavy- Heavy heavy-
5 duty class 6-7 duty class 8
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with CI Engine Effective MY 2024 (gram CO2/ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 284 179 190
Multi-Purpose................................................... 292 181 192
Regional........................................................ 304 178 182
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with SI Engine Effective MY 2024 (gram CO2/ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 312 197 208
Multi-Purpose................................................... 321 199 210
Regional........................................................ 334 196 199
----------------------------------------------------------------------------------------------------------------
Table V-7--Proposed NHTSA Fuel Consumption Standards for MY 2024 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-
Duty cycle duty class 2b- Medium heavy- Heavy heavy-
5 duty class 6-7 duty class 8
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with CI Engine Effective MY 2024 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 27.8978 17.5835 18.6640
Multi-Purpose................................................... 28.6837 17.7800 18.8605
Regional........................................................ 29.8625 17.4853 17.8782
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with SI Engine Effective MY 2024 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 35.1075 22.1672 23.4050
Multi-Purpose................................................... 36.1202 22.3923 23.6300
Regional........................................................ 37.5830 22.0547 22.3923
----------------------------------------------------------------------------------------------------------------
Table V-8--Proposed EPA CO2 Standards for MY 2027 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-
Duty cycle duty class 2b- Medium heavy- Heavy heavy-
5 duty class 6-7 duty class 8
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with CI Engine Effective MY 2027 (gram CO2/ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 272 172 182
Multi-Purpose................................................... 280 174 183
[[Page 40292]]
Regional........................................................ 292 170 174
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with SI Engine Effective MY 2027 (gram CO2/ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 299 189 196
Multi-Purpose................................................... 308 191 198
Regional........................................................ 321 187 188
----------------------------------------------------------------------------------------------------------------
Table V-9--Proposed NHTSA Fuel Consumption Standards for MY 2027 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-
Duty cycle duty class 2b- Medium heavy- Heavy heavy-
5 duty class 6-7 duty class 8
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with CI Engine Effective MY 2027 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 26.7191 16.8959 17.8782
Multi-Purpose................................................... 27.5049 17.0923 17.9764
Regional........................................................ 28.6837 16.6994 17.0923
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with SI Engine Effective MY 2027 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 33.6446 21.2670 22.0547
Multi-Purpose................................................... 34.6574 21.4921 22.2797
Regional........................................................ 36.1202 21.0420 21.1545
----------------------------------------------------------------------------------------------------------------
As with the other regulatory categories of heavy-duty vehicles,
NHTSA and EPA are are proposing standards that apply to Class 2b-8
vocational vehicles at the time of production, and EPA is proposing
standards for a specified period of time in use (e.g., throughout the
regulatory useful life of the vehicle). The derivation of the standards
for these vehicles, as well as details about the proposed provisions
for certification and implementation of these standards, are discussed
in more detail later in this notice and in the draft RIA.
(b) Proposed 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 proposing revisions to our regulations that would
resolve the issues identified in Phase 1, in what we believe is a
practical and feasible manner, as described below in Section V.E.
For the above reasons, in Phase 2, EPA now believes that it is
reasonable to propose 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 would follow the system
in place currently for comparable systems in tractors. In the case
where a chassis manufacturer would rely on a second stage manufacturer
to install a compliant air conditioning system, the chassis
manufacturer must follow the proposed delegated assembly provisions
described below in Section V.E.
(4) Proposed Exemptions and Exclusions
(a) Proposed Standards for Emergency Vehicles
Emergency vehicles are covered by the Phase 1 program at the same
level of stringency as any other vocational vehicle. In discussions
with representatives of the Fire Apparatus Manufacturers Association,
the agencies have learned that chassis manufacturers of fire apparatus
are currently able to obtain compliant engines and tires with the
coefficient of rolling resistance allowing compliance with the Phase 1
standards. The agencies are proposing in Phase 2 to allow emergency
vehicles to meet less stringent standards than other vocational
vehicles. There are two reasons for doing so. First, as the level of
complexity of Phase 2 would increase with the need for additional
technologies aimed to improve driveline efficiency, the compliance
burden would be disproportionately high for a company that manufactures
small volumes of specialized chassis. The ability of such a company to
benefit from averaging would be limited, as would be the ability to
spread compliance costs across many vehicles. The second and more
important reason is that emergency vehicles, which are necessarily
built for high levels of performance and reliability, would likely
sacrifice some levels of function to attain the proposed Phase 2
standards. For example, vehicles with large engines, high-torque
powertrains, and tires designed with deep tread would likely be
deficit-producing vehicles if manufacturers needed to certify an
emergency vehicle family to the primary proposed standards.
In the MY 2017-2025 light-duty rule, the agencies adopted an
exclusion for emergency and police vehicles from GHG and fuel economy
standards.\265\ As described in that rule, the unique features of
purpose-built emergency vehicles, such as high rolling resistance
[[Page 40293]]
tires, reinforced suspensions, and special calibrations of engines and
transmissions, have the effect of raising their GHG emissions. The
agencies determined in that rule that an exemption was appropriate
because the technological feasibility issues for emergency vehicles
went beyond those of other high-performance vehicles, and vehicles with
these performance characteristics must continue to be made available in
the market. The agencies do not believe that non-emergency vocational
vehicles are designed for the severe duty cycles that are experienced
by emergency vehicles, and therefore do not face the same potential
constraints in terms of vehicle design and the application of
technology.
---------------------------------------------------------------------------
\265\ See 77 FR 62653, October 12, 2012.
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In conducting an independent technological feasibility assessment
for heavy-duty emergency vehicles, the agencies believe that some GHG
and fuel saving technologies could reasonably be applied without
compromising vehicle utility. However, these vehicles are designed,
built, and operated so differently than other vocational vehicles that
we believe keeping them in the same averaging sets as other vocational
vehicles in Phase 2 would not be appropriate and thus a separate
standard (evaluated from a baseline specific to these vehicles) is
warranted.
Our feasibility analysis and the available tire data indicate that
emergency vehicle manufacturers can reasonably continue to apply tires
with the Phase 1 level tire CRR performance, in the Phase 2 program. We
have also learned that a variety of vehicle-level technologies are
being developed specifically for emergency vehicles, to maintain on-
board electronics without excessive idling. Modern fire apparatus and
ambulances typically have multiple computers and other electronic
devices on-board, each of which requires power and continues to draw
electricity when the vehicle is parked and the crew is responding to an
emergency, which could take several hours. Most on-board batteries and
alternators are not capable of sustaining these power demands for any
length of time, so emergency vehicles must either operate in a high-
idle mode or adopt one of several possible technologies that can assist
with electrical load management. Some of these technologies can enable
an emergency vehicle to shut down the main engine and drastically
reduce idle emissions.\266\ NHTSA and EPA have not based the proposed
emergency vehicle standards on use of idle reduction technologies
because we do not believe the regular neutral idle and stop-start
technologies we project for other vocational vehicles could apply
equally to emergency vehicles, and we do not have enough information
about this subset of idle reduction technologies that is designed for
extended electrical load management to either estimate an effectiveness
value or determine an appropriate market adoption rate. The agencies
request comment on whether we should include any market adoption rate
of idle reduction technologies for emergency vehicles, as part of the
basis for the Phase 2 emergency vocational vehicle standard.
---------------------------------------------------------------------------
\266\ See ``How to solar power a fire truck or ambulance,''
available at http://www.firerescue1.com/fire-products/apparatus-accessories/articles/1934440-How-to-solar-power-a-fire-truck-or-ambulance/, accessed November 2014.
---------------------------------------------------------------------------
To address both the technical feasibility and the compliance
burden, the agencies are proposing less stringent standards that also
have a simplified compliance method. Because the potential trade-offs
between performance and fuel efficiency apply equally to any emergency
vehicle manufacturer, the agencies propose that these less stringent
standards would apply for commercial chassis manufacturers of emergency
vehicles, as well as for custom chassis manufacturers. The standard for
vehicles identified at the time of certification as being intended for
emergency service would be predicated solely on the continued use of
lower rolling resistance tires, at the Phase 2 baseline level (i.e.
compliant with Phase 1).\267\
---------------------------------------------------------------------------
\267\ See 40 CFR 86.1803-01 for the applicable definition of
emergency vehicle.
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With respect to standards for engines used in these emergency
vehicles, based on what we have learned from discussions with engine
manufacturers, we understand that engines designed for heavy-duty
emergency vehicles are generally higher-emitting than other engines.
However, if we maintain a separate engine standard and regulatory
flexibility such as ABT, fire apparatus manufacturers would be able to
obtain engines that, on average, meet the proposed Phase 2 engine
standards. The agencies further recognize that the proposed engine map
inputs to GEM in the primary program would pose a difficulty for
emergency vehicle manufacturers. If we required engine-specific inputs
then these manufacturers would have to apply extra vehicle technologies
to compensate for the necessary but higher-emitting engine. The
agencies are therefore not proposing to recognize engine performance as
part of the vehicle standard for emergency vehicles. Manufacturers of
these vehicles would be expected to install an engine that is certified
to the applicable separate Phase 2 engine standard. However, under the
simplified compliance method we are proposing, emergency vehicle
manufacturers would not follow the otherwise applicable Phase 2
proposed approach of entering an engine map in GEM. Instead a Phase 1
style GEM interface would be made available, where an EPA default
engine specified by rule would be simulated in GEM. The agencies
request comments on the merits of using an equation-based compliance
approach for emergency vehicle manufacturers, similar to the approach
proposed for trailer manufacturers and described in Section IV.F.
This approach is consistent with the approach recommended by the
Small Business Advocacy Review Panel, which believed it would be
feasible for small emergency vehicle manufacturers to install a Phase
2-compliant engine, but recommended a simplified certification approach
to reduce the number of required GEM inputs. Consistent with the
recommendations of this panel, the agencies are asking for comments on
whether there would be enough fuel consumption and CO2
emissions benefits achieved by use of LRR tires in emergency vehicles
to justify requiring small business emergency chassis manufacturers to
adopt them.
We expect some commercial chassis manufacturers that serve the
emergency vehicle market may have the ability to meet the proposed
Phase 2 standards of our primary program when including emergency
vehicles in their averaging sets. Even so, we are proposing that they
have the option to comply with the less stringent standards, because
there are fewer opportunities to improve fuel efficiency on emergency
vehicles, which (as noted) are designed for high levels of performance
and severe duty. The agencies expect that this compliance path would be
most needed by custom chassis manufacturers who serve the emergency
vehicle market. Custom chassis manufacturers typically offer a narrow
range of products with low sales volumes. Therefore, fleet averaging
would provide a lower level of compliance flexibility, and there would
be less opportunity to spread the costs of developing advanced
technologies across a large number of vehicles. Further, many custom
chassis manufacturers do not qualify as small entities under the SBA
regulations. Thus, the agencies believe that existence of program-wide
ABT does not vitiate
[[Page 40294]]
the need to propose alternative, less stringent standards for emergency
vehicles.
Table V-10 below presents the proposed numerical standards to which
an emergency vehicle chassis would be certified under this provision.
Emergency vehicles certified to these proposed emergency vehicle
standards would be ineligible to generate credits. The proposed
standards shown below were derived by building a model of three
baseline vehicles (LHD, MHD, HHD) using attributes similar to those
developed for the primary program as assigned to the Urban drive cycle
subcategories. By modeling a 2021-compliant engine and tires with CRR
of 7.7, the MY 2021 standards were derived using GEM. Details of these
configurations are provided in the draft RIA Chapter 2.
Table V-10--Proposed Standards for Class 2b-8 Emergency Vehicles for MY 2021 and Later
----------------------------------------------------------------------------------------------------------------
Light heavy-
Implementation year duty class 2b- Medium heavy- Heavy heavy-
5 duty class 6-7 duty class 8
----------------------------------------------------------------------------------------------------------------
Proposed EPA Emergency Vehicle Standard (gram CO2/ton-mile)
----------------------------------------------------------------------------------------------------------------
MY2021.......................................................... 312 195 215
----------------------------------------------------------------------------------------------------------------
Proposed NHTSA Emergency Vehicle Standard (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
MY2021.......................................................... 30.6483 19.1552 21.1198
----------------------------------------------------------------------------------------------------------------
The agencies have estimated the costs of vocational vehicle
technology packages, as presented below in Table V-20 to Table V-22.
The technologies on which the proposed emergency vehicle standards are
based include engines, LRR tires, and leak-tight air conditioning
systems. Using the estimated costs of those technologies as presented,
the agencies estimate that the average cost for a heavy heavy-duty or
medium-heavy-duty emergency vehicle to meet the proposed emergency
vehicle standards would be approximately $463 in MY 2027, and the
average cost for a light heavy-duty emergency vehicle would be
approximately $497 in MY 2027. To derive these estimates, the agencies
have combined the $7 cost of LRR tires that is presented in Table V-20
with the engine and air conditioning costs presented in Table V-22. The
agencies are not aware of any emergency vehicle manufacturer that
produces engines, thus most of these costs would be borne by engine
manufacturers. While some of the added engine costs may be passed on to
emergency vehicle manufacturers and vehicle owners/operators, the
overall costs of these technologies are on the order of the Phase 1
vocational vehicle program costs, which are highly cost-effective.
To ensure that only emergency vehicle chassis would be able to
certify to these less stringent standards, the agencies propose that
manufacturers identify vehicles using the definition at 40 CFR 86.1803-
01, which for Phase 2 purposes would be an ambulance or a fire truck.
Manufacturers have informed us that it is feasible to identify such
vehicles using sales codes or the presence of specialty attributes. The
agencies request comment on the merits and drawbacks of 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.
According to the International Council on Clean Transportation
(ICCT), less than one percent of all new heavy-duty truck registrations
from 2003 to 2007 were emergency vehicles.\268\ On average, the ICCT's
data suggest that approximately 5,700 new emergency vehicles are sold
in the U.S. each year; about 0.8 percent of the 3.4 million new heavy-
duty trucks registered between 2003 and 2007. According to the Fire
Apparatus Manufacturers Association, the annual VMT of the newest
emergency vehicles ranges from approximately 2,000 to 8,000 miles, as
documented in their 2004 Fire Apparatus Duty Cycle White Paper.\269\
Because there are relatively few of these vehicles and they travel a
relatively small number of miles, the agencies believe that setting
less stringent GHG and fuel consumptions standards for these vehicles
would not detract from the greater benefits of this rulemaking, and
such separate standards are warranted in any case.
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\268\ ICCT, May 2009, ``Heavy-Duty Vehicle Market Analysis:
Vehicle Characteristics & Fuel Use, Manufacturer Market Shares.''
\269\ 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.
---------------------------------------------------------------------------
(b) Possible Standards for Other Custom Chassis Manufacturers
The agencies request comment on extending the above simplified
compliance procedure and less stringent Phase 2 standards to other
custom chassis manufacturers--those who offer 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. Custom chassis
manufacturers that are not small businesses must comply with the Phase
1 standards and are generally doing so, by installing tires with the
required coefficient of rolling resistance. We are aware of a handful
of U.S. chassis manufacturers serving the recreational vehicle and bus
markets who we believe would have a disproportionate compliance burden,
should we require compliance with the primary proposed Phase 2
standards.
According to the MOVES model forecast, there will be approximately
1,000 commercial intercity coach buses, 5,000 transit buses, 40,000
school buses, and 90,000 recreational vehicles manufactured new for MY
2018.\270\ In each of these markets, specialty chassis manufacturers
compete with large vertically integrated manufacturers. We request
comment on the merits of offering less stringent standards to small
volume chassis manufacturers, and seek comment as well as to other
factors the agencies should consider to ensure this
[[Page 40295]]
approach would not have unintended consequences for businesses
competing in the vocational vehicle market.
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\270\ 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.
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If the agencies were to adopt less stringent standards for custom
non-emergency chassis manufacturers, we would expect to limit this by
setting a maximum number of eligible vocational chassis annually for
each such manufacturer. The agencies request comment on an appropriate
sales volume to qualify for these possible standards, and also request
comment as to whether the sales volume thresholds should be different
for different markets. We further request comment on whether it would
adversely affect business competitiveness if custom chassis
manufacturers were held to a different standard than commercial chassis
manufacturers, and whether the agencies should consider allowing
commercial chassis manufacturers competing in these markets to sell a
limited number of chassis certified to a less stringent standard.
As an alternative approach, the agencies request comment on
providing custom chassis manufacturers with additional lead time to
comply. For example, we could allow such manufacturers an additional
one or two years to meet each level of the primary proposed vocational
vehicle standards.
If the agencies pursued the approach of less stringent standards,
we would likely adopt a simplified compliance procedure similar to the
one proposed for emergency vehicles. Custom chassis manufacturers would
not follow the otherwise applicable Phase 2 proposed approach of
entering an engine map in GEM. Instead, a Phase 1 style GEM interface
would be made available, where an EPA default engine specified by rule
would be simulated in GEM. The vehicle-level standard would be
predicated on a simpler set of technologies than the primary proposed
Phase 2 standard, most likely lower rolling resistance tires and idle
reduction. Because these would not be emergency vehicles, we believe
the performance of these vehicles would not be compromised by requiring
improvement in tire CRR beyond that of the Phase 1 level. The agencies
request comment on whether we should develop separate standards for
different vehicle types such as recreational vehicles and buses.
The Small Business Advocacy Review Panel recommended that EPA seek
comment on how to design a small business vocational vehicle exemption
by means of a custom chassis volume exemption and what sales volume
would be an appropriate threshold. The agencies seek comments on all
aspects of an approach for custom vocational vehicle chassis
manufacturers that would enable us to adopt a final Phase 2 program
that would be consistent with the recommendations of the panel.
(c) Off-Road and Low-Speed Vocational Vehicle Exemptions
The agencies are proposing to continue the exemptions in Phase 1
for off-road and low-speed vocational vehicles, with revision. See
generally 76 FR 57175. These provisions currently apply 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. 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. In Phase 1, this typically means not needing to
install tires with a lower coefficient of rolling resistance. Because
manufacturers choosing to exempt vehicles (but not engines) based on
the criteria for heavy-duty off road vehicles at 40 CFR 1037.631 and 49
CFR 523.2 will for the first time provide a description to the agencies
of how they meet the qualifications for this exemption in their end-of-
the year reports in the spring of 2015, we do not have information
beyond what we knew at the time of the Phase 1 rules regarding how
broadly this provision is being used. Nonetheless, we are proposing to
discontinue the criterion for exemption based solely on use of tires
with maximum speed rating at or below 55 mph. The agencies are
concerned that tires are so easily replaced that this would be an
unreliable way to identify vehicles that truly need special
consideration. We are proposing to retain the qualifying criteria
related to design and use of the vehicle. We invite comments on the
proposed revisions to the qualifying criteria in the regulations,
including whether the rated speed of the tires should be retained, and
whether vehicles intended to be covered by this provision have
characteristics that are captured by the proposed criteria.
C. Feasibility of the Proposed Vocational Vehicle Standards
This section describes the agencies' technological feasibility and
cost analysis in greater detail. Further detail on all of these
technologies can be found in the draft 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. The focus of this section is on the feasibility of
the proposed standards for non-emergency vocational vehicles. Further,
the agencies project that these technology packages would also be
feasible for vocational tractors. With typical driving patterns having
limited operation at highway speeds, vocational tractors would
appropriately be classified as vocational vehicles, with proposed
standards that would not be predicated on the performance of
aerodynamic devices. The agencies propose to allow vocational tractors
to follow the same subcategory assignment process as other vocational
vehicles. For example, a beverage tractor intended for local delivery
routes may have a driving pattern that is reasonably represented by the
proposed Urban test cycle. The agencies request comment on whether
vocational tractors would be deficit-generating vehicles if certified
as vocational vehicles, where performance would be measured against the
proposed vocational vehicle baseline configurations. For example, if a
tractor were designed with a higher power engine to carry a heavier
payload than presumed in the GEM baseline for that subcategory, would
GEM return a value that poorly represents the real world performance of
that vehicle, and if so, would that merit a different certification
approach for vocational tractors?
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,\271\ the 2010 National Academy of
Sciences report of Technologies and Approaches to Reducing the Fuel
Consumption of Medium- and Heavy-Duty Vehicles,\272\ TIAX's assessment
of technologies to support the NAS panel report,\273\ the technology
cost analysis conducted by
[[Page 40296]]
ICF for EPA,\274\ and the 2009 report from Argonne National Laboratory
on Evaluation of Fuel Consumption Potential of Medium and Heavy Duty
Vehicles through Modeling and Simulation.\275\
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\271\ Reinhart, T, 2015. Commercial Medium- and Heavy-Duty (MD/
HD) Truck Fuel Efficiency Technology Study--Reports #1 and #2.
Washington, DC: National Highway Traffic Safety Administration; 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.
\272\ See NAS Report, Note 136, above.
\273\ See TIAX 2009, Note 137, above.
\274\ See ICF 2010, Note 139, above.
\275\ 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 proposed Phase 2 vocational
vehicle standards, the agencies evaluated a suite of technologies,
including workday idle reduction, improved tire rolling resistance,
improved transmissions, improved axles, 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 proposed 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 proposed standards,
regardless of whether the vehicle is powered by a CI or SI engine. With
the exception of the MY 2027 proposed standards, the analysis below
does not distinguish between vehicles with different types of engines.
The resulting proposed vehicle standards do reflect the differences
arising from the performance of different types of engines over the GEM
cycles.
(a) Vehicle Technologies Considered in Standard-Setting
The agencies note that the effectiveness values estimated for the
technologies may represent average values, and 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 0.5 percent for low
friction axle lubricants, each vehicle could have a unique
effectiveness estimate depending on the baseline axle's oil viscosity
rating. For purposes of this proposed rulemaking, NHTSA and EPA believe
that employing average values for technology effectiveness estimates is
an appropriate way of recognizing the potential variation in the
specific benefits that individual manufacturers (and individual
vehicles) might obtain from adding a given technology. There may be
real world effectiveness that exceeds or falls short of the average,
but on-balance the agencies believe this is the most practicable
approach for determining the wide ranging effectiveness of technologies
in the diverse vocational vehicle arena.
(i) Transmissions
Transmission improvements present a significant opportunity for
reducing fuel consumption and CO2 emissions from vocational
vehicles. Transmission efficiency is important for many vocational
vehicles as their duty cycles involve high percentages of driving under
transient operation. The three categories of transmission improvements
the agencies considered for Phase 2 are driveline optimization,
architectural improvements, and hybrid powertrain systems.
The agencies believe an effective way to derive efficiency
improvements from a transmission is by optimizing it with the engine
and other driveline components to balance both performance needs and
fuel savings. However, many vocational vehicles today are not operating
with such optimized systems. Because customers are able to specify
their preferred components in a highly customized build process, many
vocational vehicles are assembled with components that were designed
more for compatibility than for optimization. To some extent,
vertically integrated manufacturers are able to optimize their
drivelines. However, this is not widespread in the vocational vehicle
sector, resulting primarily, from the multi-stage manufacture process.
The agencies project transmission and driveline optimization will yield
a substantial proportion of vocational vehicle fuel efficiency and GHG
emissions reduction improvements for Phase 2. On average, we anticipate
that efficiency improvements of about five percent can be achieved from
optimization, or deep integration of drivelines. However, we are not
assigning a fixed level of improvement; rather we have developed a test
procedure, the powertrain test, for manufacturers to use to obtain
improvement factors representative of their systems. See Section V.E
and the draft RIA Chapter 3 for a discussion of this proposed test
procedure. Depending on the test cycle and level of integration, the
agencies believe improvement factors greater than ten percent above the
baseline vehicle performance could be achieved. To obtain such benefits
across more of the vocational vehicle fleet, the agencies believe there
is opportunity for manufacturers to form strategic partnerships and to
explore commercial pathways to deeper driveline integration. For
example, one partnership of an engine manufacturer and a transmission
manufacturer has led to development of driveline components that
deliver improved fuel efficiency based on optimization that could not
be realized without sharing of critical data.\276\
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\276\ See Cummins-Eaton partnership at http://smartadvantagepowertrain.com/
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The agencies project other related transmission technologies would
be recognized over the powertrain test along with driveline
optimization. These include improved mechanical gear efficiency, more
sophisticated shift strategies, more aggressive torque converter
lockups, transmission friction reduction, and reduced parasitic losses,
as described in the 2009 TIAX report at 4.5.2. Each of these attributes
would be simulated in GEM using default values, unless the powertrain
test were utilized by the certifying manufacturer. The draft RIA
Chapter 4 explains each parameter that would be set as a fixed value in
GEM. The expected benefits of improved gear efficiency, shift logic,
and torque converter lockup are included in the total projected
effectiveness of optimized conventional transmissions using the
powertrain test.
Transmission efficiency could also be improved in the time frame of
the proposed rules by changes in the architecture of conventional
transmissions. Most vocational vehicles currently use torque converter
automatic transmissions (AT), especially in Classes 2b-6. According to
the 2009 TIAX report, approximately 70 percent of Class 3-6 box and
bucket trucks use AT, and all refuse trucks, urban buses, and motor
coaches use AT.\277\ Automatic transmissions offer acceleration
benefits over drive cycles with frequent stops, which can enhance
productivity. However, with the diversity of vocational vehicles and
drive cycles, other kinds of transmission architectures can meet
customer needs, including automated manual transmissions (AMT) and even
some manual transmissions (MT).\278\
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\277\ See TIAX 2009, Note 137, above.
\278\ 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).
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One type of architectural improvement the agencies project will be
developed by manufacturers of all transmission architectures is
increased number of gears. The benefit of adding
[[Page 40297]]
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.\279\ Although the
agencies estimate the improvement could on average be about two percent
for the adding of two gears in the range where significant vehicle
operation occurs, we are not assigning a fixed improvement based solely
on number of transmission gears. Manufacturers would enter the number
of gears and gear ratios into GEM and the model would simulate the
efficiency benefit over the applicable test cycle. Because a public
version of proposed GEM is being released with these proposed rules,
stakeholders are free to use this tool to explore the effectiveness of
different numbers of gears and gear ratios over the proposed test
cycles. The agencies request comment on all aspects of the GEM tool,
including how it models transmissions and shifting strategies. More
details on GEM are available in the draft RIA Chapter 4.
---------------------------------------------------------------------------
\279\ See TIAX 2009, Note 137, Table 4-48.
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Other architectural changes that the agencies project will offer
efficiency improvements include improved automated manual transmissions
(AMT) and introduction of dual clutch transmissions (DCT). Newer
versions of AMT are showing significant improvements in reliability,
such that the current generation of transmissions with this
architecture is more likely to retain resale value and win customer
acceptance than early models.\280\ The agencies believe AMT generally
compare favorably to manual transmissions in fuel efficiency, and while
the degree of improvement is highly driver-dependent, it can be two
percent or greater, depending on the drive cycle. See Section III for
additional discussion of AMT. The agencies are not assigning fixed
average performance levels to compare an AMT with a traditional
automatic transmission. Although the lack of a torque converter offers
AMT an efficiency advantage in one respect, the lag in power during
shifts is a disadvantage. For Phase 2, the agencies have developed
validated models of both AMT and AT, as described in the draft RIA
Chapter 4. Manufacturers installing AMT or AT would enter the relevant
inputs to GEM and the simulation would calculate the performance. Dual
clutch transmissions (DCT) designed for medium heavy-duty vocational
vehicles are already in production, and could reasonably be expected to
be adapted for other weight classes of vocational vehicles during the
time frame of Phase 2.\281\ Based on supplier conversations,
manufacturers intend to match varying DCT designs with the diverse
needs of the heavy-duty market. The agencies do not yet have a
validated DCT model in GEM, and we are not assigning a fixed
performance level for DCT, though we expect the per-vehicle fuel
efficiency improvement due to switching from automatic to DCT to be in
the range of three percent over the GEM vocational vehicle test cycles.
Selection of transmission architecture type (Manual, AMT, AT, DCT)
would be made by manufacturers at the time of certification, and GEM
would either use this input information to simulate that transmission
using algorithms as described in the draft RIA Chapter 4, or fixed
improvements may be assigned. The agencies are assigning fixed levels
of improvement that vary by test cycle in GEM for AMT when replacing a
manual, which for vocational vehicles would be in the HHD Regional
subcategory. If a manufacturer elected not to conduct powertrain
testing to obtain specific improvements for use of a DCT, GEM would
simulate a DCT as if it were an AMT, with no fixed assigned benefit.
The draft RIA at Chapter 2.9 describes the projected effectiveness of
each type of transmission improvement for each vocational vehicle test
cycle.
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\280\ See NACFE Confidence Report: Electronically Controlled
Transmissions, at http://www.truckingefficiency.org/powertrain/automated-manual-transmissions (January 2015). See also http://www.overdriveonline.com/auto-vs-manual-transmission-autos-finding-solid-ground-by-sharing-data-with-engines/ (accessed November 2014).
\281\ See Eaton Announcement September 2014, available at http://www.ttnews.com/articles/lmtbase.aspx?storyid=2969&t=Eaton-Unveils-Medium-Duty-Procision-Transmission.
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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 proposed vocational vehicle standards are predicated.
We project a variety of mild and strong hybrid systems, with a wide
range of effectiveness. Mild hybrid systems that offer an engine stop-
start feature are discussed below under workday idle reduction. For
hybrid powertrains, we are estimating a 22 to 25 percent fuel
efficiency improvement over the powertrain test, depending on the duty
cycle in GEM for the applicable subcategory. The agencies obtained
these estimates by projecting a 27 percent effectiveness over the ARB
Transient cycle, and zero percent over the constant-speed highway
cruise cycles. With the proposed cycle weightings, this calculates to a
25 percent improvement over the Urban cycle, and 22 percent over the
Multi-Purpose cycle. According to the NREL Final Evaluation of UPS
Diesel Hybrid-Electric Delivery Vans, the improvement of a hybrid over
a conventional diesel in gallons per ton-mile on a chassis dynamometer
over the NYC Composite test cycle was 28 percent.\282\ NREL
characterizes the NYC Composite cycle as more aggressive than most of
the observed field data points from the study, and may represent an
ideal hybrid cycle in terms of low average speed, high stops per mile,
and high kinetic intensity. NREL noted that most of the observed field
data points were reasonably represented by the HTUF4 cycle, over which
the chassis dynamometer results showed a 31 percent improvement in
gallons per ton-mile. In units of grams CO2 per mile, NREL
reported these test results as 22 percent improvement over the NYC
Composite cycle and 26 percent improvement over the HTUF4 cycle. Based
on these results, and the fact that any improvement from strong hybrids
in Phase 2 would not be simulated in GEM, but rather would be evaluated
using the powertrain test, the agencies deemed it reasonable to
estimate a conservative 27 percent effectiveness over the ARB Transient
in setting the stringency of the proposed standards.
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\282\ Lammert, M., Walkowivz, K., NREL, Eighteen-Month Final
Evaluation of UPS Second Generation Diesel Hybrid-Electric Delivery
Vans, September 2012, NREL/TP-5400-55658.
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The Phase 1 standards were not predicated on any adoption of hybrid
powertrains in the vocational vehicle sector. Because the first
implementation year of Phase 1 came just three years after
promulgation, there was insufficient lead time for development and
deployment of the technology.\283\ In addition, our proposed Phase 2
[[Page 40298]]
vocational vehicle GEM test cycles are expected to better recognize
hybrid technology effectiveness than the Phase 1 hybrid test cycle,
especially in the Urban subcategory. Further, our Phase 2 cost analysis
shows that hybrid systems designed for LHD and MHD vocational vehicles
would cost less than the costs we were projecting in Phase 1. The
agencies believe the Phase 2 rulemaking timeframes would offer
sufficient lead time to develop, demonstrate, and conduct reliability
testing for technologies that are still maturing, including these
hybrid technologies.
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\283\ In addition to concerns over adequacy of lead time, the
agencies described concerns over ``modest'' emission reductions. See
76 FR 57234. Even so, in Phase 1 the agencies adopted provisions for
hybrids to generate advanced technology credits.
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Several types of vocational vehicles are well suited for hybrid
powertrains, and are among the early adopters of this technology.
Vehicles such as utility or bucket trucks, delivery vehicles, refuse
haulers, and buses have operational usage patterns with either a
significant amount of stop-and-go activity or spend a large portion of
their operating hours idling the main engine to operate a PTO unit.
The industry is currently developing many variations of hybrid
powertrain systems. There are a few hybrid systems in the market today
and several more under development. In addition, energy storage systems
are improving.\284\ Heavy-duty customers are getting used to these
systems with the number of demonstration products on the road. Even so,
some manufacturers may be uncertain how much investment to make in this
technology without clear signals about future market demand. A list of
hybrid manufacturers and their products intended for the vocational
market is provided in the draft RIA Chapter 2.9.
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\284\ Green Fleet Magazine, The Latest Developments in EV
Battery Technology, November 2013, available at http://www.greenfleetmagazine.com/article/story/2013/12/the-latest-developments-in-ev-battery-technology-grn/page/1.aspx.
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Some low cost products on the simple end of the hybrid spectrum are
available that minimize battery demand through the use of
ultracapacitors or only provide power assist at low speeds. Our
regulations define a hybrid system as one that has the capacity for
energy storage.\285\ In the light-duty GHG program a mild hybrid is
defined as including an integrated starter generator, a high-voltage
battery (above 12v), and a capacity to recover at least 15 percent of
the braking energy. In such systems some accessories are usually
electrified. Strong hybrids are typically referred to as those that
have larger energy recovery and storage capacity, defined at 65 percent
braking energy recovery in the light-duty GHG program. Although
integration of a strong hybrid system may enable installation of a
downsized engine in some cases, the agencies have not projected any
vocational engine downsizing for any hybrid systems as part of our
Phase 2 technology assessment. This is in part to be conservative in
our cost estimates, and in part because in some applications a smaller
engine may not be acceptable if it would risk that performance could be
sacrificed during some portion of a work day. Depending on the drive
cycle and units of measurement, strong hybrids developed to date have
seen fuel consumption and CO2 emissions reductions between
20 and 50 percent in the field.\286\
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\285\ EPA's and NHTSA's regulations define a hybrid vehicle as
one that ``includes energy storage features . . . in addition to an
internal combustion engine or other engine using consumable chemical
fuel. . . .'' at 40 CFR 1037.801 and 49 CFR 535.4.
\286\ Van Amburg, Bill, CALSTART, Status Report: Alternative
Fuels and High-Efficiency Vehicles, Presentation to National
Association of Fleet Administrators (NAFA) 2014 Institute and Expo,
April 8, 2014.
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The agencies are working to reduce barriers related to hybrid
vehicle certification. In Phase 1, there is a significant test burden
associated with demonstrating the GHG and fuel efficiency performance
of vehicles with hybrid powertrain systems. Manufacturers must obtain a
conventional vehicle that is identical to the hybrid vehicle in every
way except the transmission, test both, and compare the results.\287\
In Phase 2, the agencies are proposing that manufacturers would conduct
powertrain testing on the hybrid system, and the results of that
testing would become inputs to GEM for simulation of the non-powertrain
features of the hybrid vehicle, removing a significant test burden.
---------------------------------------------------------------------------
\287\ See test procedures at 40 CFR 1037.555.
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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
XIV.A.1 for a discussion of regulatory changes proposed to reduce the
non-GHG certification burden for engines paired with hybrid powertrain
systems. The agencies have also received a letter from the California
Air Resources Board requesting consideration of supplemental
NOX testing of hybrids. The agencies request comment on the
Air Resources Board's letter and recommendations.\288\
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\288\ 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.
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(ii) Axles
The agencies are considering two axle technologies for the
vocational vehicle sector. The first is advanced low friction axle
lubricants. Under contract with NHTSA, SwRI tested improved driveline
lubrication and found measurable improvements by switching from current
mainstream products to newer formulations focusing on modified
viscometric effects.\289\ Synthetic lubricant formulations can offer
superior thermal and oxidative stability compared to petroleum or
mineral based lubricants. The agencies believe that a 0.5 percent
improvement in vocational vehicle efficiency (as for tractors) is
achievable through the application of low friction axle lubricants, and
have included that value as a fixed value in GEM. Beyond the use of
different lubricant formulations, some axle manufacturers are offering
products that achieve efficiency improvements by varying the
lubrication levels with vehicle speed, reducing churning losses. The
agencies request comment on whether we could accept these systems as
qualifying for a fixed GEM improvement value. If a manufacturer wishes
to demonstrate the benefit of a specific axle technology, an off-cycle
technology credit would be necessary. To support such an application,
manufacturers could conduct a rear axle efficiency test, as described
in the draft RIA Chapter 3.8. Proposed regulations for this test
procedure can be found at 40 CFR 1037.560. Our estimated axle
lubricating costs do not include operational costs such as refreshing
lubricants on a periodic basis. Based on supplier information, it is
likely that some advanced lubricants may 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.
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\289\ 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 (the 2015 NHTSA Technology Study). For axle
improvements see T-270 Delivery Truck Vehicle Technology Results.
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The second axle technology the agencies are considering is a design
that enables one of the rear axles to disconnect or otherwise behave as
if it's a non-driven axle, on vehicles with two rear (drive) axles,
commonly referred to as a 6x2 configuration. The agencies have
considered two types of 6x2 configurations for vocational vehicles:
[[Page 40299]]
Those that are engaged full time on a vehicle, and those that may be
engaged only during some types of vehicle operation, such as only when
operating at highway cruise speeds. Some early versions of 6x2
technology offered by manufacturers were not accepted by vehicle
owners. When the second drive axle is no longer powered, traction may
be sacrificed in some cases. Vehicles with earlier versions of this
technology have seen reduced residual values in the secondary market.
Over the model years covered by the Phase 2 rules, the agencies expect
the market to offer significantly improved versions of this technology,
with traction control maintained at lower speeds and efficiency gains
at highway cruise speeds.\290\ Further information about this
technology is provided in the feasibility of the tractor standards,
Section III, as well as in draft RIA Chapter 2.4.
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\290\ NACFE, Confidence Findings on the Potential of 6x2 Axles,
available at http://nacfe.org/wp-content/uploads/2014/01/Trucking-Efficiency-6x2-Confidence-Report-FINAL-011314.pdf, January 2014
(downloaded November 2014).
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The efficiency benefit of a 6x2 axle configuration can be duty-
cycle dependent. In many instances, vocational vehicles need to operate
off-highway, such as at a construction site delivering materials or
dumping at a refuse collection facility. In these cases, vehicles with
two drive axles may need the full tractive benefit of both drive axles.
The part-time 6x2 axle technology is not expected to measurably improve
a vehicle's efficiency for vehicles whose normal duty cycle involves
performing significant off-highway work, but the agencies do expect
this technology to be recognized over a highway cruise cycle.
Some vocational vehicles in the HHD Regional subcategory may see a
6x2 axle configuration as a reasonable option for improving fuel
efficiency. As in Phase 1, our vehicle simulation model assumes that
only HHD vehicles have two rear axles, so only these could be
recognized for adopting this technology. Further, the agencies don't
believe the Multipurpose and Urban subcategories include a significant
enough highway cycle weighting in the composite cycle for vehicles that
operate in this manner to experience a benefit from adopting this
technology. The agencies project this can achieve 2 percent benefit at
highway cruise; \291\ thus, we propose to assign a fixed value in GEM
for part-time 6x2 technology of 2.5 percent over the highway cruise
cycles, where the specific improvement would be calculated according to
the composite weighting of the applicable vocational vehicle test
cycle. We request comment on the best way to recognize this technology
in Phase 2, either through a GEM calculation or a fixed assigned value,
for vocational vehicles.
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\291\ See 2015 NHTSA Technology Study, Note 289, T-700 Class 8
Tractor-Trailer Vehicle Technology Results.
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(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.\292\ There is a wide range of rolling resistance of tires
used on vocational vehicles today. This is in part due to the fact that
the competitive pressure to improve rolling resistance of vocational
vehicle tires has been less than that found in the line haul tire
market. In addition, the drive cycles typical for these applications
often lead vocational vehicle buyers to value tire traction and
durability more heavily than rolling resistance. The agencies
acknowledge there can be tradeoffs when designing a tire for reduced
rolling resistance. These tradeoffs can include characteristics such as
wear resistance, cost and scuff resistance. However, based on input
from tire suppliers, the agencies expect that the LRR tires that will
be available in the Phase 2 timeframe will not compromise performance
parameters such as traction, handling, wear, retreadability, or
structural durability.
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\292\ See Argonne National Laboratory 2009 report, Note 275,
page 91.
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After the Phase 1 rules were promulgated, NHTSA and EPA conducted
supplemental tire testing. Other data that have become available to the
agencies since Phase 1 include pre-certification data provided to
manufacturers by tire suppliers in preparation for MY 2014 vehicle
certification.\293\ The agencies categorized the data by tire position
and vehicle application, so that we have a representation of the
variety of LRR vocational vehicle tires that are available in the
market for the drive position, steer and all-position tires, as well as
wide base singles in all positions. Based on our data set that includes
results from multiple laboratories, drive tires that are intended for
vocational vehicles have an average CRR of 7.8, and steer and all-
position tires that are intended for vocational vehicles have an
average CRR of 6.7. The results also indicate that there are a variety
of wide based single tires that are intended for vocational vehicles,
with an average CRR of 6.6. Each of these data sets shows several
models of commercial tires are available at levels of CRR ranging
generally from 20 percent worse than average to 20 percent better than
average. Further details are presented in the draft RIA Chapter 2.
---------------------------------------------------------------------------
\293\ See memorandum dated May 2015 on Vocational Vehicle Tire
Rolling Resistance Test Data Evaluation.
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According to the 2015 NHTSA Technology Study, vocational vehicles
are likely to see the most benefits from reduced tire rolling
resistance when they are driving at 55 mph.\294\ This report also found
an influence of vehicle weight on the benefits of LRR tires. The study
found that both vocational vehicles tested had greater benefits of LRR
tires at 100 percent payload than when empty. Also, the T270 delivery
box truck that was 4,000 lbs heavier when fully loaded saw slightly
greater efficiency gains from LRR tires than the F650 flatbed tow truck
over the same cycles. At higher speeds, aerodynamic drag grows, which
reduces the rolling resistance share of total vehicle power demand. In
highly transient cycles, the power required to accelerate the vehicle
inertia overshadows the rolling resistance power demand. In simulation,
GEM represents vocational vehicles with fixed vehicle weights, payloads
and aerodynamic coefficients. Thus, the benefit of LRR tires will be
reflected in GEM differently for vehicles of different weight classes.
There will also be further differences arising from the different test
cycles. Based on preliminary simulations, it appears the vehicles in
GEM most likely to see the greatest fuel efficiency gains from use of
LRR tires are those in the MHD weight classes tested over the Regional
or Multipurpose duty cycles, where one percent efficiency improvement
could be achieved by reducing CRR by four to five percent. Those seeing
the least benefit from LRR tires would likely be Class 8 vehicles
tested over the Urban or Multipurpose cycles, where one percent
efficiency improvement could be achieved by reducing CRR by seven to
eight percent.
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\294\ See 2015 NHTSA Technology Study, Note 289, T-270 Delivery
Truck Vehicle Technology Results
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The agencies propose to continue the light truck (LT) tire CRR
adjustment factor that was adopted in Phase 1. 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. After promulgation of the Phase 1 rules, the agencies conducted
additional tire CRR testing on a variety of LT tires, most of which
were designated as all-
[[Page 40300]]
position tires. In addition, manufacturers have submitted to the
agencies pre-certification data that include CRR values provided by
tire suppliers. For the small subset of newer test tires that were
designated as steer tires, the average CRR was 7.8 kg/ton. For the
subset of newer test tires that were designated as drive tires, the
average CRR was 8.6 kg/ton. However all-position tires had an average
CRR of 8.9 kg/ton.\295\ Therefore, for LT vocational vehicle tires, we
propose to continue allowing the measured CRR values to be multiplied
by a 0.87 adjustment factor before entering the values in the GEM for
compliance, because this additional testing has not revealed compelling
information that a change is needed. We request comment on whether the
adjustment factor should be retained, as well as data on which to base
a possible update of its numerical value.
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\295\ See tire memorandum, Note 293.
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As described above in V. B. (4) (c), the agencies are proposing to
continue the Phase 1 off-road and low speed exemptions in Phase 2, with
the proposed revision of discontinuing the option to qualify for this
exemption solely if the vehicle is fitted with tires that have a
maximum speed rating at or below 55 mph. The agencies welcome comments
on this revision.
(iv) Workday Idle Reduction
The Phase 2 idle reduction technologies considered for vocational
vehicles are those that reduce workday idling, unlike the overnight
idling of combination tractors. There are many potential technologies.
The agencies in particular evaluated neutral idle and stop-start
technologies, and the proposed standards are predicated on projected
amounts of penetrations of these technologies, described in Section V.
C. (2) . While neutral idle is necessarily a transmission technology,
stop-start could range from an engine technology to one that would be
installed by a secondary manufacturer under a delegated assembly
agreement.
The agencies are aware that for a vocational vehicle's engine to
turn off during workday driving conditions, there must be a reserve
source of energy to maintain functions such as power steering, cabin
heat, and transmission pressure, among others. Stop-start systems can
be viewed as having a place on the low-cost end of the hybridization
continuum. As described in Section V. C. (2) and in the draft RIA
Chapter 2.9, the agencies are including the cost of energy storage
sufficient to maintain critical onboard systems and restart the engine
as part of the cost of vocational vehicle stop-start packages. The
technologies to capture this energy could include a system of
photovoltaic cells on the roof of a box truck, or regenerative braking.
The technologies to store the captured energy could include a battery
or a hydraulic pressure bladder. More discussion of stop-start
technologies is found in the draft RIA Chapter 2.4.
The agencies intend for the technologies that would qualify to be
recognized in GEM as stop-start to be broadly defined, including those
that may be installed at different stages in the manufacturing process.
The agencies request comment on an appropriate definition of stop-start
technologies for vocational vehicles.
The agencies are also proposing a certification test cycle that
measures the amount of fuel saved and CO2 reduced by these
two primary types of idle reduction technologies: neutral idle and
stop-start. Vocational vehicles frequently also idle while cargo is
loaded or unloaded, and while operating a PTO such as compacting
garbage or operating a bucket. In these rules, the agencies are
proposing that the Regional duty cycle have ten percent idle, the
Multi-purpose cycle have 15 percent idle, and the Urban cycle have 20
percent idle. These estimates are based on publically available data
published by NREL.\296\ To bolster this information, EPA entered into
an interagency agreement with NREL to characterize workday idle among
vocational vehicles. One task of this agreement is to estimate the
nationally representative fraction of idle operation for vocational
vehicles for each proposed regulatory subcategory including a
distinction between idling while driving or stopping in gear, and
idling while parked. The preliminary range of total daily idle
operation per vehicle indicated by this work is about 18 percent to 33
percent when combining the data from all available vehicles. The
agencies request comment regarding the nature of vocational workday
idle operation, including how much of it is in traffic and how much is
while the vehicle is parked. Depending on comments and additional
information received during the comment period, it may be within the
agencies' discretion to adopt different final test cycles, or re-weight
the current test cycles, to better represent real world driving and
better reflect performance of the technology packages. An analysis of
possible vocational vehicle standards derived from alternate
characterizations of idle operation has been prepared by the agencies,
and is available for review in the public docket for this
rulemaking.\297\
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\296\ See NREL data at http://www.nrel.gov/vehiclesandfuels/fleettest/research_fleet_dna.html.
\297\ See memorandum dated May 2015 on Analysis of Possible
Vocational Vehicle Standards Based on Alternative Idle Cycle
Weightings.
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Based on GEM simulations using the currently proposed vocational
vehicle test cycles, the agencies estimate neutral idle for automatic
transmissions to provide fuel efficiency improvements ranging from one
percent to nearly four percent, depending on the regulatory
subcategory. The agencies estimate stop-start to provide fuel
efficiency improvements ranging from 0.5 percent to nearly seven
percent, depending on the regulatory subcategory. Because of the higher
idle weighting factor in the Urban test cycle, vehicles certified in
these subcategories would derive the greatest benefit from applying
idle reduction technologies.
Although the primary program would not simulate vocational vehicles
over a test cycle that includes PTO operation, the agencies are
proposing to continue, with revisions, the hybrid-PTO test option that
was in Phase 1. See 76 FR 57247 and 40 CFR 1037.525 (proposed to be
redesignated as 40 CFR 1037.540). Recall that we are proposing to
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. Based on stakeholder
input, chassis manufacturers are expected to know whether a vehicle's
transmission is PTO-enabled. However, that is very different from
knowing whether a PTO will actually be installed and how it 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. 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 would otherwise apply to that vehicle. In addition, the
delegated assembly provisions would apply. See Section V.E for a
description of the delegated assembly provisions. See draft RIA Chapter
3 for a discussion of the proposed revisions to the PTO test cycle.
[[Page 40301]]
The agencies have reason to believe there may be a NOX
co-benefit to stop-start idle reduction technologies, e-PTO, and
possibly also to neutral idle. For this to be true, the benefits of
reduced fuel consumption and retained aftertreatment temperature would
have to outweigh any extra emissions due to re-starts. In the draft RIA
Chapter 2.9, there is a more detailed discussion of the relationship
between idle reduction and NOX co-benefits. The agencies
request comments and relevant test data that can help inform this
issue.
(v) Weight Reduction
The agencies believe there is opportunity for weight reduction in
some vocational vehicles. 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 for long haul tractors and trailers.
On a city duty cycle, 89 percent of the vehicle's road load is weight
dependent, compared to 38 percent on a steady-state 55 mph duty
cycle.\298\ The 2015 NHTSA Technology Study found that weight reduction
provides a greater fuel efficiency benefit for vehicles driving under
transient conditions than for those operating under constant speeds. In
simulation, the study found that the two Class 6 trucks improved fuel
efficiency by over two percent on the ARB transient cycle by removing
1,100 lbs. Further, SwRI observed that the improvements due to weight
reduction behaved linearly.\299\ The proposed menu of components
available for a vocational vehicle weight credit in GEM is presented in
Section V.E and in the draft RIA Chapter 2.9. It includes fewer options
than for tractors, but the agencies believe there are a number of
feasible material substitution choices at the chassis level, which
could add up to weight savings on the order of a few hundred lbs. The
agencies project that refuse trucks, construction vehicles, and weight-
limited regional delivery vehicles could reasonably apply material
substitution for weight reduction. We do not expect this to be broadly
applicable across many types of vocational vehicles. Based on the
assumed payload in GEM, and depending on the vocational vehicle
subcategory, the agencies believe a reduction of 200 lbs may offer a
fuel efficiency improvement of approximately 1 to 2 percent.
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\298\ Helms 2003 as referenced in TIAX 2009.
\299\ See 2015 NHTSA Technology Study, Note 289, T-270 Delivery
Truck Vehicle Technology Results and Vehicle Performance in the F-
650 Truck.
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Without more specific data on which to base our assumptions, the
agencies are proposing to allocate 50 percent of any mass reduction to
increased payload, and 50 percent to reduce the chassis weight. We
considered the data on which the tractor weight allocation (1/3:2/3) is
based, but determined this would not be valid for vocational vehicles,
as the underlying data pertained only to long haul tractor-trailers.
The agencies propose that 50 percent of weight removed from vocational
vehicle chassis would be added back as additional payload in GEM. This
suggests an equal likelihood that a vehicle would be reducing weight
for benefits of being lighter, or reducing weight to carry more
payload. The agencies welcome data that could better inform the
fraction of weight reduced for vocational vehicles that is added back
as payload.
The agencies request comment on whether the HD Phase 2 program
should recognize that weight reduction of rotating components provides
an enhanced fuel efficiency benefit over weight reduction on static
components. In theory, as components such as brake rotors, brake drums,
wheels, tires, crankshafts, camshafts, and piston assemblies become
lighter, the power consumption to rotate the masses would be directly
proportional to the mass decrease. Using physical properties of a
rotating component such as a wheel, it is relatively straightforward to
calculate an equivalent mass. However, we do not have enough
information to derive industry average values for equivalent mass, nor
have we evaluated the best way for GEM to account for this.
(vi) HFC Refrigerant From Cabin Air Conditioning (A/C) Systems
Manufacturers can reduce direct A/C leakage emissions by utilizing
leak-tight components. EPA's proposed HFC direct emission leakage
standard would be independent of the CO2 vehicle standard.
Manufacturers could 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.
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. EPA is proposing in
Phase 2 to extend the HFC leakage standard that exists due to Phase 1
requirements to all vocational vehicles. Beginning in the 2021 model
year, EPA proposes that vocational vehicle air conditioning systems
with a refrigerant capacity of greater than 733 grams 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 believes this proposed approach of having a leak rate
standard for lower capacity systems and a percent leakage per year
standard for higher capacity systems would 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.
EPA believes that reducing A/C system leakage is both highly cost-
effective and technologically feasible. The availability of low leakage
components is being driven by the air conditioning program in the
light-duty GHG rule which 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.\300\ 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' can be used in place of the value
normally used for an o-ring fitting, when 100 percent helium leak
testing is performed on those fittings. The agencies request comment on
other
[[Page 40302]]
possible improvements in the design of air conditioning systems that
EPA could recognize for the purposes of compliance with this proposed
standard. For example, should the agency recognize electrified
compressors as having a zero leak rate, and should we allow vehicles
fitted with electrified compressors to use a simplified version of the
compliance reporting form? Please see Section I.F.1 (b) of this
preamble for a description of proposed program-wide revisions to EPA's
HFC leakage standards that would address air conditioning systems
designed for alternative refrigerants.
---------------------------------------------------------------------------
\300\ Team 1-Refrigerant Leakage Reduction: Final Report to
Sponsors, SAE, 2007.
---------------------------------------------------------------------------
The HFC control costs presented in the draft RIA Chapter 2.9 and
2.12 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 proposed
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 proposing to predicate
the vocational vehicle standards on different diesel engine technology
packages than those presumed for compliance with the separate diesel
engine standards. However, for the proposed MY 2027 vocational vehicle
standards, the agencies are predicating the SI-powered vocational
vehicle standards on a gasoline engine technology package that includes
additional friction reduction beyond that presumed for compliance with
the MY 2016 gasoline engine standard. Chapter 2 of the draft RIA
provides more details on each of the technologies that can be applied
to both gasoline and diesel engines.
The vehicle-level standards would vary depending on whether the
engines powering those vehicles are compression-ignition or spark-
ignition.\301\ In Phase 1, this was not the case because GEM used a
default engine that was the same for every vehicle configuration,
regardless of the actual engine being installed. As described above in
Section II, the Phase 2 vehicle certification tool, GEM, would require
manufacturers to enter specific engine performance data, where
emissions and fuel consumption profiles would differ significantly
depending on the engine's architecture.\302\
---------------------------------------------------------------------------
\301\ Specifically, EPA is proposing CO2,
N2O, and CH4 emission standards for new heavy-
duty engines over an EPA specified useful life period (See Section
II).
\302\ See Section II.D.5 for an explanation of which engine
architecture would need to meet which standard.
---------------------------------------------------------------------------
As explained in Section II.A.2, engines would continue to be
certified over the FTP test cycle. The FTP test cycle that is
applicable for bare vocational engines is very different than the
proposed 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 draft RIA Chapter 3. A consequence of
recognizing engine performance at the vehicle level would be that
further engine improvements (i.e. improvements measureable by duty
cycles that more precisely represent driving patterns for specific
subcategories of vocational vehicles) could be evaluated as possible
components of a technical basis for a vocational vehicle standard.\303\
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 proposed standard
stringency).
---------------------------------------------------------------------------
\303\ As noted in 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.
---------------------------------------------------------------------------
One CI engine technology that might be recognized over a vehicle
highway cruise cycle would be waste heat recovery (WHR). However, the
agencies do not consider this to be a feasible technology for
vocational engines. As described in Section II of this preamble and
Chapter 2.3 of the draft RIA, there currently are no commercially
available WHR systems for diesel engines, although most engine
manufacturers are exploring this technology. While it would be possible
to capture excess heat from a vocational engine operating at highway
speeds, many vocational vehicles spend insufficient time at highway
speeds to generate enough excess heat to make this technology
worthwhile. As explained in Section II.D, the agencies are projecting a
very small adoption rate of WHR even in the tractor engine market.
Because the research is currently being conducted to apply this
technology for tractors, it is logical that future research may reveal
ways to adapt this technology for those vocational engines that are
intended for on-highway applications. The agencies do not believe this
technology will be developed to the point of commercial readiness for
vocational vehicles in the time frame of these proposed rules.
The agencies assessed three SI engine technologies for possible
inclusion in the vocational vehicle technology packages: cylinder
deactivation, variable valve timing, and advanced friction reduction.
These might be recognized over the proposed vocational vehicle test
cycles in GEM through use of the proposed engine mapping procedures. To
the extent either cylinder deactivation or variable valve timing would
be adopted for complete heavy-duty pickups and vans, they would be
recognized over the complete chassis test specified for that segment
and possibly over the GEM highway cruise cycles, however the aggressive
bare engine FTP test is unlikely to put the engine into operating modes
that activate either of those technologies. Based on stakeholder input,
the agencies project that the SI engines certified over the FTP and
fitted into vocational vehicles would most likely be designed as
overhead valve engines, for which the only kind of VVT available is
dual cam phasing.\304\ Dual cam phasing is already included at 100
percent adoption rate in the feasibility and stringency of the MY 2016
bare engine standard. If manufacturers choose to fit vocational
vehicles with coaxial camshaft SI engines, additional VVT options would
be feasible and could be recognized over the vocational vehicle test
cycles. Based on stakeholder input, the agencies project that some SI
engines certified over the FTP and fitted into vocational vehicles may
be designed with cylinder deactivation by MY 2021. However, the
agencies do not have enough information at this time to quantify the
potential fuel efficiency improvements over the vocational vehicle test
cycles for engines with cylinder deactivation or various designs
implementing VVT. Therefore we are not proposing to predicate the SI-
powered vocational vehicle standards on use of these technologies.
---------------------------------------------------------------------------
\304\ See preamble Section VI.C.5.(a) under Coupled Cam Phasing.
---------------------------------------------------------------------------
In Section II.D, the agencies explain why we are not proposing a
more stringent separate SI vocational engine standard in Phase 2 based
on additional engine technologies beyond those assumed for the Phase 1
MY 2016 standard. The agencies are instead proposing to include
adoption and performance of advanced engine friction reduction
technology as a basis for the
[[Page 40303]]
proposed SI-powered vocational vehicle standards. Based on Volpe model
results presented in preamble Section VI, the agencies project that
manufacturers of some SI engines for complete HD pickups would apply
advanced friction reduction. Level 2 engine friction reduction is
listed in Table VI-3, and costs are presented in the draft RIA Chapter
2.12. We expect some engines with this technology would be engine-
certified and sold for use in vocational vehicles. We are projecting an
overall effectiveness of 0.6 percent improvement over the GEM cycles
for this technology, calculated using a per-vehicle effectiveness of
1.1 percent and a vocational vehicle adoption rate of 56 percent. We
request comment on the merits of setting a SI-based vocational vehicle
standard predicated on adoption of SI engine technologies.
(c) Technologies the Agencies Assessed but Did Not Use in Standard-
Setting
(i) Aerodynamics
The Argonne National lab work shows that aerodynamics has less of
an impact on vocational vehicle energy losses than do engines or
tires.\305\ Further, when a vehicle spends significant time at slower
speeds, the disbenefit of the added weight of the aero devices
diminishes the benefit obtained when driving at high speeds. In
addition, the aerodynamic performance of a complete vehicle is
significantly influenced by the body of the vehicle. As noted above,
the agencies are not proposing to regulate body builders for the
reasons discussed in Phase 1.
---------------------------------------------------------------------------
\305\ See Argonne National Laboratory 2009 report, Note 275,
above.
---------------------------------------------------------------------------
The NAS 2010 report estimated a one percent fuel efficiency
improvement could be achieved from a full aerodynamic package on a box
truck with an average speed of 30 mph.\306\ Both from the NAS 2010
report and from experiences of EPA's SmartWay team, the agencies expect
the potential benefits of aerodynamics at an average speed of 60 mph
would be diminished by 50 percent or more when average speeds are
closer to 40 mph. The proposed Regional composite duty cycle in GEM for
vocational vehicles (the test cycle with the most highway weighting)
has a weighted average speed of 39 mph.
---------------------------------------------------------------------------
\306\ See Table 5-10 of the NAS 2010 report, Note 136.
---------------------------------------------------------------------------
The 2015 NHTDA Technology Study simulated a Class 6 box truck with
a coefficient of aerodynamic drag that had been improved by 15 percent.
Over transient test cycles, this produced a one percent fuel efficiency
benefit, though this produced results of approximately seven percent
improvement over the 55 mph and eight percent over the 65 mph cycle.
SwRI conducted coastdown testing to determine the baseline
CDA of the truck, of 5.0.\307\ However, it is unknown what
aerodynamic technologies could be applied to yield a 15 percent
improvement in CDA. Using these simulation results and the
proposed Regional cycle weightings of 22 percent at 65 mph and 28
percent at 55 mph, the agencies estimate the fuel efficiency benefit of
improving the CdA of a Class 6 box truck by 15 percent could be
approximately four percent. This assumes no penalty for carrying the
weight of the aerodynamic devices while operating under transient
driving conditions.
---------------------------------------------------------------------------
\307\ See 2015 NHTSA Technology Study, Note 289, Appendix C.
---------------------------------------------------------------------------
Because we do not have information on specific technologies that
could be applied to vocational vehicles to yield a 15 percent
improvement in CdA, or their costs, we are not basing any of the
proposed standards for vocational vehicles on aerodynamic improvements.
Nonetheless, we are working with CARB to incorporate into GEM some data
from testing that is being conducted by CARB through NREL. A test plan
is underway to assess the fuel efficiency benefit of three different
devices to improve the aerodynamic performance of a Class 6 box truck
and one device on a Class 4 box truck. The agencies request comment on
allowing a manufacturer to obtain an improved GEM result by certifying
that a final vehicle configuration will closely match one of the
configurations on which this testing was conducted, where the
improvement would be based on installation of specific aerodynamic
devices for which we have pre-defined effectiveness through this
testing program. The amount of improvement would be set by EPA and
NHTSA based on NREL's test results. This credit provision would apply
only to vocational vehicles certified over the Regional duty cycle.
Manufacturers wishing to receive credit for other aerodynamic
technologies or on other vehicle configurations would be able to seek
credit for it as an off-cycle technology. See Section V.E, for a
description of regulatory flexibilities such as off-cycle technology
credits.
A description of vehicles and aerodynamic technologies that could
be eligible for this option, as well as a description of the testing
conducted to obtain the assigned GEM improvements due to these
technologies, can be found in a memorandum to the docket.\308\ The
agencies seek comment on this potential approach to providing credits
for aerodynamic aids to vocational box trucks.
---------------------------------------------------------------------------
\308\ See May 2015 memorandum to the docket titled Vocational
Vehicle Aerodynamic Testing Program.
---------------------------------------------------------------------------
(ii) Full Electric Trucks
Some heavy-duty vehicles can be powered exclusively by electric
motors. Electric motors are efficient and able to produce high torque,
giving e-trucks strong driving characteristics, particularly in stop-
and-go or urban driving situations, and are well-suited for moving
heavy loads. Electric motors also offer the ability to operate with
very low noise, an advantage in certain applications. Currently, e-
trucks have some disadvantages over conventional vehicles, primarily in
cost, weight and range. Components are relatively expensive, and
storing electricity using currently available technology is expensive,
bulky, and heavy.
The West Coast Collaborative, a public-private partnership, has
estimated the incremental costs for electric Class 3-6 trucks in the
Los Angeles, CA, area.\309\ Compared to a conventional diesel, the WCC
estimates a BEV system would cost between $70,000 and $90,000 more than
a conventional diesel system. The CalHEAT Technology Roadmap includes
an estimate that the incremental cost for a fully-electric medium- or
heavy- duty vehicle would be between $50,000 and $100,000. This roadmap
report also presents several actions that must be taken by
manufacturers and others, before heavy-duty e-trucks can reach what
they call Stage 3 Deployment.\310\
---------------------------------------------------------------------------
\309\ See http://westcoastcollaborative.org/files/sector-fleets/WCC-LA-BEVBusinessCase2011-08-15.pdf.
\310\ Silver, Fred, and Brotherton, Tom. (CalHEAT) Research and
Market Transformation Roadmap to 2020 for Medium- and Heavy-Duty
Trucks. California Energy Commission, June 2013.
---------------------------------------------------------------------------
Early adopters of electric drivetrain technology are medium-heavy-
duty vocational vehicles that are not weight-limited and have drive
cycles where they don't need to go far from a central garage. Examples
include Frito-Lay. CalHEAT has published results of a comprehensive
performance evaluation of three battery electric truck models using
information and data from in-use data collection, on road testing and
chassis dynamometer testing.\311\
---------------------------------------------------------------------------
\311\ Gallo, Jean-Baptiste, and Jasna Tomic (CalHEAT). 2013.
Battery Electric Parcel Delivery Truck Testing and Demonstration.
California Energy Commission.
---------------------------------------------------------------------------
[[Page 40304]]
Given the high 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 proposed rules.
For this reason, the agencies have not based the proposed Phase 2
standards on adoption of full-electric vocational vehicles. 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 Section V.E and in
EPA's regulations at 40 CFR 1037.150 and NHTSA's regulations at 49 CFR
535.8.
(iii) Electrified Accessories
Accessories that are traditionally gear- or belt-driven by a
vehicle's engine can be optimized and/or converted to electric power.
Examples include the engine water pump, oil pump, fuel injection pump,
air compressor, power-steering pump, cooling fans, and the vehicle's
air-conditioning system. Optimization and improved pressure regulation
may significantly reduce the parasitic load of the water, air and fuel
pumps. Electrification may result in a reduction in power demand,
because electrically-powered accessories (such as the air compressor or
power steering) operate only when needed if they are electrically
powered, but they impose a parasitic demand all the time if they are
engine-driven. In other cases, such as cooling fans or an engine's
water pump, electric power allows the accessory to run at speeds
independent of engine speed, which can reduce power consumption.
Electrification of accessories can individually improve fuel
consumption, regardless of whether the drivetrain is a strong hybrid.
The TIAX study used 2 to 4 percent fuel consumption improvement for
accessory electrification, with the understanding that electrification
of accessories will have more effect in short haul/urban applications
and less benefit in line-haul applications.\312\
---------------------------------------------------------------------------
\312\ TIAX 2009, Note 137, pp. 3-5.
---------------------------------------------------------------------------
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.
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. However, the agencies have not
developed a pre-defined credit-generating option for manufacturers to
directly receive credit in GEM for electrified accessories on
vocational vehicles. Manufacturers wishing to conduct independent
testing may apply for off-cycle credits derived from electrified
accessories.
(iv) E-PTO
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 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. The
agencies are proposing to continue the hybrid-PTO test option that was
available in Phase 1, with a few revisions. See the proposed
regulations at 40 CFR 1037.540. The current test procedure is a charge-
sustaining procedure, meaning the test is not complete until the energy
storage system is depleted and brought back to its original state of
charge. The agencies request comment and data 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. For the
reasons described above in Section V.C.1.a.iv, the agencies are not
basing the proposed vocational vehicle standards on use of electrified
PTO or hybrid PTO technology. Manufacturers wishing to conduct testing
as specified may apply for off-cycle credits derived from e-PTO or
hybrid PTO technologies.
(2) Projected Vehicle Technology Package Effectiveness and Cost
(a) Baseline Vocational Engine and Vehicle Performance
The proposed baseline vocational vehicle configurations for each of
the nine proposed regulatory subcategories are described in draft RIA
Chapter 2.9 and Chapter 4.4. The agencies propose to set the baseline
rolling resistance coefficient for the 2017 vocational vehicle fleet at
7.7 kg/metric ton, which assumes 100 percent of tires meet the Phase 1
standard.
In the agencies' proposed baseline configurations, we include
torque converter automatics with five forward gears in eight of the
nine subcategories. In the Regional HHD subcategory, the baseline
includes a manual transmission with ten forward gears. No additional
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, increased 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 draft RIA Chapter 2.12. Chapter 2.12.8
presents the adoption rates for tires on vocational vehicles with
different levels of rolling resistance, including the 100 percent
adoption 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. Details of the vehicle configurations, including
reasons why they are reasonably included as baseline technologies, are
discussed in the draft RIA Chapter 2.9.
The agencies note that the baseline performance derived for the
proposed rules varies between regulatory subcategories--as noted above,
this is the reason the agencies are proposing the further
subcategories. 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 request comment on whether the proposed
configurations adequately represent a reasonable range of vocational
chassis configurations likely
[[Page 40305]]
to be manufactured in the implementation years of the Phase 2 program.
We especially are interested in comments regarding the following
driveline parameters: Transmission gear ratios, axle ratios, and tire
radii.
The baseline engine fuel consumption represents improvements beyond
currently available engines to achieve the efficiency of what the
agencies believe would be a 2017 model year diesel engine, as described
in the draft RIA Chapter 2. Using the values for compression-ignition
engines, the baseline performance of vocational vehicles is shown in
Table V-11.
Different types of diesel engines are used in vocational vehicles,
depending on the application. They fall into the categories of Light,
Medium, and Heavy Heavy-duty Diesel engines. The Light Heavy-duty
Diesel engines typically range between 4.7 and 6.7 liters displacement.
The Medium Heavy-duty Diesel engines typically have some overlap in
displacement with the Light Heavy-duty Diesel engines and range between
6.7 and 9.3 liters. The Heavy Heavy-duty Diesel engines typically are
represented by engines between 10.8 and 16 liters. 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 draft RIA. These
four engine models have been employed in setting the vocational vehicle
baselines, as described in the draft RIA Chapter 2.9.
Table V-11--Baseline Vocational Vehicle Performance With CI Engines
----------------------------------------------------------------------------------------------------------------
Light heavy-
Duty cycle duty class 2b- Medium heavy- Heavy heavy-
5 duty class 6-7 duty class 8
----------------------------------------------------------------------------------------------------------------
Baseline Emissions Performance in CO[bdi2] gram/ton-mile
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 316 201 212
Multi-Purpose................................................... 325 203 214
Regional........................................................ 339 199 203
----------------------------------------------------------------------------------------------------------------
Baseline Fuel Efficiency Performance in gallon per 1,000 ton-mile
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 31.0413 19.7446 20.8251
Multi-Purpose................................................... 31.9253 19.9411 21.0216
Regional........................................................ 33.3006 19.5481 19.9411
----------------------------------------------------------------------------------------------------------------
The agencies intend to develop a model in GEM of a MY 2016-
compliant gasoline engine, but we have been unable to obtain sufficient
information to complete this process. The agencies request 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. In lieu of a SI engine map, the agencies have applied
a correction factor to the GEM CI vocational simulation results, to
approximate the baseline performance of a SI-powered vocational
vehicle. The SI-powered vocational vehicle baseline performance shown
in Table V-12 was calculated from applying an adjustment factor to the
respective CI-powered vocational vehicle baseline values. This CI to SI
baseline adjustment factor is derived from the Phase 1 HD pickup and
van stringency curves, as described in the draft RIA Chapter 2.9.1. The
correction factor approach is not the agencies' preferred approach, as
it has many drawbacks. One key drawback with this approach is that it
does not account for the fact that SI engines operate very differently
than CI engines at idle. Our current model includes information on CI
engine idle performance, and assumes transmissions and torque
converters appropriate for CI engines. We expect these driveline
parameters would be very different for SI powered vehicles, which would
affect performance over all the GEM duty cycles.
The baseline performance levels for HHD vocational vehicles powered
by SI engines were derived using the same procedures described above
for the MHD and LHD vehicles, adjusting the performance of the HHD CI
powered vocational vehicles by the same degree as for the other
vehicles. However, we expect that any gasoline Class 8 vocational
vehicle would be powered by a MHD SI engine, as there are no HHD
gasoline engines on the market. Further, we expect that if we were to
develop an engine map for use in simulating heavier SI vocational
vehicles in GEM, we could establish a more representative baseline
performance level by calculating the work done by the MHD engine to
move the heavier vehicle over the test cycles. The agencies request
comments on the merits of developing separate baseline levels and
numerical standards for HHD vocational vehicles powered by SI engines,
including any benefits that could be obtained by addressing this
unlikely occurrence and other ways in which the agencies could avoid
the instance of an orphaned SI vocational vehicle. Commenters who favor
separate numerical standards are encouraged to submit information
related to appropriate default vehicle characteristics such as weight
and payload. Depending on comments, the agencies could choose to
require all Class 8 vocational vehicles to certify to the standards for
CI powered HHD vocational vehicles, or we could require SI powered
Class 8 vocational vehicles to certify to the MHD standards for SI
vocational vehicles.
Table V-12--Baseline Vocational Vehicle Performance With SI Engines
----------------------------------------------------------------------------------------------------------------
Light heavy-duty Medium heavy-duty Heavy heavy-duty
Duty cycle Class 2b-5 Class 6-7 Class 8
----------------------------------------------------------------------------------------------------------------
Baseline Emissions Performance in CO[bdi2] gram/ton-mile
----------------------------------------------------------------------------------------------------------------
Urban............................................ 334 213 224
[[Page 40306]]
Multi-Purpose.................................... 344 215 226
Regional......................................... 358 211 214
----------------------------------------------------------------------------------------------------------------
Baseline Fuel Efficiency Performance in gallon per 1,000 ton-mile
----------------------------------------------------------------------------------------------------------------
Urban............................................ 37.5830 23.9676 25.2054
Multi-Purpose.................................... 38.7082 24.1926 25.4304
Regional......................................... 40.2836 23.7425 24.0801
----------------------------------------------------------------------------------------------------------------
(b) Technology Packages for Derivation of Proposed Standards
Prior to developing the numerical values for the proposed
standards, the agencies projected the mix of new technologies and
technology improvements that would be feasible within the proposed 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. The standards being proposed reflect the
technology projected for each service class. Where a technology
performs differently over different test cycles, these differences are
reflected to some extent in the derivation of the stringency of the
proposed standard. However, the proposed standard stringency does
reflect, to some extent, the ability of manufacturers to utilize
credits. For example, we project that hybrid vehicles would generally
be certified in the Urban subcategory and would generate emission
credits that would most likely be used in the other subcategories
within the weight class group.\313\
---------------------------------------------------------------------------
\313\ See averaging sets at 40 CFR 1037.740.
---------------------------------------------------------------------------
As part of the derivation of the numerical standards, we performed
a benchmarking analysis to inform our development of standards that
would have roughly equivalent stringency among the duty-cycle-based
subcategories within each weight class group. To do this, the agencies
assessed the performance of broadly applicable technologies, such as
low rolling resistance tires, on each of the selected baseline vehicles
over each of the duty cycles. We then evaluated how much improvement
could be achieved over the various duty cycles for a vehicle that
incorporated all the broadly applicable technologies, but which did not
include a hybrid powertrain. We simulated neutral idle for benchmarked
vehicles for MY 2021 and MY 2024, and simulated stop-start idle
reduction on the benchmarked MY 2027 vehicles. From this, we learned
that a vehicle with neutral idle and a deeply integrated conventional
powertrain, with moderately low rolling resistance tires and some
weight reduction could easily meet the proposed standards in the early
implementation years of the program, in any weight class or duty cycle.
We also learned how the effectiveness of tire rolling resistance and
weight reduction vary in GEM (i.e. and therefore likely in actual
operation) across the different subcategories. We also found that a
vehicle with a deeply integrated conventional powertrain, tires with
even lower CRR, some weight reduction, and stop-start idle reduction
could achieve the MY 2027 proposed standards. However, our technology
feasibility does not presume that 100 percent of vocational vehicles
can reasonably apply deep powertrain integration, nor do we project 100
percent adoption of LRR tires or weight reduction.
The technologies assumed for the benchmarked vehicles are
summarized in Table V-13, Table V-14, and Table V-15. Note that the
agencies are not projecting that these are the vehicles that would
actually be produced. Rather, these theoretical vehicles are being
evaluated to compare the relative stringency of the standards for each
subcategory.
Table V-13--GEM Inputs for Benchmarked MY 2021 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Class 2b-5 Class 6-7 Class 8
----------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
----------------------------------------------------------------------------------------------------------------
Transmission
----------------------------------------------------------------------------------------------------------------
100% Deep Transmission Integration for 7% Urban, 6% Multipurpose, 5% Regional
----------------------------------------------------------------------------------------------------------------
5s AT 5s AT 5s AT 5s AT 5s AT 5s AT 5s AT 5s AT 10s AMT
----------------------------------------------------------------------------------------------------------------
[[Page 40307]]
CI Engine \a\
----------------------------------------------------------------------------------------------------------------
2021 MY 7L, 22021 MY 7L, 270 hp Engine
2021 MY 11L, 345 hp 2021 MY 15L
Engine 455hp
Engine
----------------------------------------------------------------------------------------------------------------
100% Idle Reduction = Neutral Idle
----------------------------------------------------------------------------------------------------------------
100% improved axle lubrication: 0.5%
----------------------------------------------------------------------------------------------------------------
100% Steer Tires with CRR 6.9 kg/metric ton
----------------------------------------------------------------------------------------------------------------
100% Drive Tires with CRR 7.3 kg/metric ton
----------------------------------------------------------------------------------------------------------------
Weight Reduction 200 lb
----------------------------------------------------------------------------------------------------------------
Note:
\a\ SI engines were not simulated in GEM.
Table V-14--GEM Inputs for Benchmarked MY 2024 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Class 2b-5 Class 6-7 Class 8
----------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
----------------------------------------------------------------------------------------------------------------
Transmission
----------------------------------------------------------------------------------------------------------------
100% Deep Transmission Integration for 7% Urban, 6% Multipurpose, 5% Regional
----------------------------------------------------------------------------------------------------------------
5s AT 5s AT 5s AT 5s AT 5s AT 5s AT 5s AT 5s AT 10s AMT
----------------------------------------------------------------------------------------------------------------
CI Engine \a\
----------------------------------------------------------------------------------------------------------------
2024 MY 7L, 22024 MY 7L, 270 hp Engine
2024 MY 11L, 345 hp 2024 MY 15L
Engine 455hp
Engine
----------------------------------------------------------------------------------------------------------------
100% Idle Reduction = Neutral Idle
----------------------------------------------------------------------------------------------------------------
100% improved axle lubrication: 0.5%
----------------------------------------------------------------------------------------------------------------
100% Steer Tires with CRR 6.7 kg/metric ton
----------------------------------------------------------------------------------------------------------------
100% Drive Tires with CRR 7.1 kg/metric ton
----------------------------------------------------------------------------------------------------------------
Weight Reduction 200 lb
----------------------------------------------------------------------------------------------------------------
Note:
\a\ SI engines were not simulated in GEM.
Table V-15--GEM Inputs for Benchmarked MY 2027 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Class 2b-5 Class 6-7 Class 8
----------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
----------------------------------------------------------------------------------------------------------------
Transmission
----------------------------------------------------------------------------------------------------------------
100% Deep Transmission Integration for 7% Urban, 6% Multipurpose, 5% Regional
----------------------------------------------------------------------------------------------------------------
5s AT 5s AT 5s AT 5s AT 5s AT 5s AT 5s AT 5s AT 10s AMT
----------------------------------------------------------------------------------------------------------------
[[Page 40308]]
CI Engine \a\
----------------------------------------------------------------------------------------------------------------
2027 MY 7L, 22027 MY 7L, 270 hp Engine
2027 MY 11L, 345 hp 2027 MY 15L
Engine 455hp
Engine
----------------------------------------------------------------------------------------------------------------
100% Idle Reduction = Stop-Start
----------------------------------------------------------------------------------------------------------------
100% Steer Tires with CRR 6.4 kg/metric ton
----------------------------------------------------------------------------------------------------------------
100% Drive Tires with CRR 7.0 kg/metric ton
----------------------------------------------------------------------------------------------------------------
Weight Reduction 200 lb
----------------------------------------------------------------------------------------------------------------
Note:
\a\ SI engines were not simulated in GEM.
Next we identified the best performing baseline vehicle in each
weight class group (one for HHD, one for MHD and one for LHD) and
normalized the baseline GEM results to the performance of that vehicle.
A complete description of this normalization process is found in the
draft RIA Chapter 2. We then applied our actual projected technology
adoption rates, including hybrid powertrains and stop-start idle
reduction, to normalized-benchmarked vehicles in each of the nine
subcategories. The proposed standards then were calculated by
multiplying the normalized baseline vehicle GEM result by an average
percent improvement for each weight class group. For example, the GEM
results from applying the projected technology mix for MY 2021 MHD CI
vocational vehicles were a 5 percent improvement in the Regional MHD
subcategory, 7 percent improvement in the MHD Multipurpose subcategory,
and 8 percent improvement in the MHD Urban subcategory. To achieve
standards with equivalent stringency, we multiplied each normalized
baseline vehicle's GEM performance by the numerical average of those
simulated improvements, 6.6 percent. Without comparable stringency
across the subcategories, manufacturers could have an incentive to
select a subcategory strategically to have a less stringent standard,
rather than to certify vehicles in the subcategory that best matches
the vehicles' expected use patterns. By setting the standards at the
same percent reduction from each weight class group of normalized-
benchmarked vehicles, we would expect to minimize any incentive for a
manufacturer to certify a vocational vehicle in an inappropriate
subcategory.
We request comment on using this approach to normalize the
standards. Commenters are encouraged to address both the approach in
general and the specific technology assumed for the benchmark vehicles.
We are aware that in this approach, some of the projected
technology packages would not provide a direct path to compliance for
manufacturers, such as in the example above of the MHD Regional
vehicle. Using the technologies adopted at projected rates, it would
fall short of the standard by 1.5 percent. The agencies believe that
the Phase 2 program has enough regulatory flexibility (averaging,
banking, and trading provisions in particular) to enable such a vehicle
to be certified.
In the package descriptions that follow, individual technology
costs are not presented, rather these can be found in the draft RIA
Chapter 2.9 and 2.12. Section V. C. (2) (d) includes the costs
estimated for packages of technologies the agencies project would
enable vocational vehicles to meet the proposed Phase 2 standards.
(i) Transmission Packages
The agencies project that 30 percent of vocational vehicles would
have one or more of the transmission technologies identified above in
this section applied by MY 2021, increasing to nearly 60 percent by MY
2024 and over 80 percent by MY 2027. Most of this increase is due to a
projected increase in adoption of technologies that represent deep
driveline integration. The agencies project an adoption rate of 15
percent in MY 2021 and 30 percent in MY 2024 for manufacturers using
the powertrain test to be recognized for non-hardware upgrades such as
gear efficiencies, shift strategies, and torque converter lockups, as
well as other technologies that enable driveline optimization. Due to
the relatively high efficiency gains available from driveline
optimization for relatively low costs, the agencies are projecting a 70
percent application rate of driveline optimization by MY 2027 across
all subcategories. We do not have information about the extent to which
integration may be deterred by barriers to information-sharing between
component suppliers. Therefore we are projecting that major
manufacturers would work to overcome these barriers, integrate and
optimize their drivelines, and use the powertrain test on all eligible
configurations, while smaller manufacturers may not adopt these
technologies at all, or not to a degree that they would find value in
this optional test procedure.
For the technology of adding two gears, we are predicating the
proposed MY 2021 standard on a five percent adoption rate, except zero
in the HHD Regional subcategory, which is modeled with a 10-speed
transmission. This adoption rate is projected to essentially remain at
this level throughout the program, with an increase to ten percent only
for two subcategories (Regional LHD and MHD) in MY 2027. This is
because the manufacturers most likely to develop 8-speed transmissions
are those that are also developing transmissions for HD pickups and
vans, and the GEM-certified vocational market share among those
manufacturers is relatively small.
The HHD Regional subcategory is the only one where we assume a
manual transmission in the baseline configuration. For these vehicles,
the agencies project upgrades to electronic transmissions such as
either AMT, DCT, or automatic, at collective adoption rates of 51
percent in MY 2021, 68 percent in MY 2024, and five percent in MY 2027.
The decrease in MY 2027 reflects a projection that a greater number of
deeply integrated HHD powertrains would be used by MY 2027 (one
consequence being that fewer HHD
[[Page 40309]]
powertrains would be directly simulated in GEM in that year). The
larger numbers in the phase-in years reflect powertrains that have been
automated or electrified but not deeply integrated. The agencies have
been careful to account for the cost of both electrifying and deeply
integrating the MY 2027 powertrains. In draft RIA Chapter 11, the
technology adoption rates for the HHD Regional subcategory presented in
Table 11-42, Table 11-45, and Table 11-48 account for the assumption
that a manual transmission cannot be deeply integrated, so there must
also be an automation upgrade. These tables are inputs to the agencies'
cost analysis, thus the costs of both upgrading and integrating HHD
powertrains are included. The adoption rates of the upgraded but not
integrated transmission architectures represent a projection of three
percent of all vocational vehicles in MY 2021 and four percent in MY
2024. This is based on an estimate that seven percent of the vocational
vehicles would be in the HHD Regional subcategory. For more information
about the assumptions that were made about the populations of vehicles
in different subcategories, see the agencies' inventory estimates in
draft RIA Chapter 5.
In the eight subcategories in which automatic transmissions are the
base technology, the agencies project that five percent would upgrade
to a dual clutch transmission in MY 2021. This projection increases to
15 percent in MY 2024 and decreases in MY 2027 to ten percent for two
subcategories (Regional LHD and MHD) and five percent for the remaining
6 subcategories. The low projected adoption rates of DCT reflect the
fact that this is a relatively new technology for the heavy-duty
sector, and it is likely that broader market acceptance would be
achieved once fleets have gained experience with the technology.
Similar to the pattern described for the HHD Regional subcategory, the
decrease in MY 2027 reflects a projection of greater use of deeply
integrated powertrains.
In setting the proposed standard stringency, we have projected that
hybrids on vehicles certified in the Multipurpose subcategories would
achieve on average 22 percent improvement, and those in the Urban
subcategories would see a 25 percent improvement. We have also
projected zero hybrid adoption rate by vehicles in the Regional
subcategories, expecting that the benefit of hybrids for those vehicles
would be too low to merit use of that type of technology. However,
there is no fixed hybrid value assigned in GEM and the actual
improvement over the applicable test cycle would be determined by
powertrain testing. By the full implementation year of MY 2027, the
agencies are projecting an overall vocational vehicle adoption rate of
ten percent hybrids, which we estimate would be 18 percent of vehicles
certified in the Multi-Purpose and Urban subcategories. We are
projecting a low adoption rate in the early years of the Phase 2
program, just four percent in these subcategories in MY 2021, and seven
percent in MY 2024 for vehicles certified in the Multi-Purpose and
Urban subcategories. 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 four percent overall in MY
2024.
Considering the combination of the above technologies and adoption
rates, we project the CO2 and fuel efficiency improvements
for all transmission upgrades to be approximately seven percent on a
fleet basis by MY 2027. One subcategory in which we are projecting a
very large advanced transmission adoption rate is the HHD Regional
subcategory, in which we are projecting 75 percent of the transmissions
would be either automated or automatic (upgraded from a manual) with 70
percent of those also being deeply integrated by MY 2027. By
comparison, the agencies are projecting that HHD day cab tractors would
have 90 percent adoption of automated or automatic transmissions by MY
2027. Although we are not prepared to predict what fraction of these
would be upgraded in the absence of Phase 2, the draft RIA Chapter 2.9
explains why the agencies are confident that durable transmissions will
be widely available in the Phase 2 time frame to support manufacture of
HHD vocational vehicles.
If the above technologies do not reach the expected level of market
adoption, the vocational vehicle Phase 2 program has several other
technology options that manufacturers could choose to meet the proposed
standards.
(ii) Axle Packages
The agencies project that 75 percent of vocational vehicles in all
subcategories would adopt advanced axle lubricant formulations in all
implementation years of the Phase 2 program. Fuel efficient lubricant
formulations are widespread across the heavy-duty market, though
advanced synthetic formulations are currently less popular.\314\ Axle
lubricants with improved viscosity and efficiency-enhancing performance
are projected to 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 request comment on
information regarding any vocational vehicle applications for which use
of advanced lubricants would not be feasible.
---------------------------------------------------------------------------
\314\ Based on conversations with axle suppliers.
---------------------------------------------------------------------------
The agencies estimate that 45 percent of HHD Regional vocational
vehicles would adopt either full time or 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 slightly higher adoption rate of
60 percent combined for both full and part time 6x2 axle technologies
in MY 2024 and MY 2027. Based on our estimates of vehicle populations,
this is about four percent of all vocational vehicles.
(iii) Tire Packages
The agencies estimate that the per-vehicle average level of rolling
resistance from vocational vehicle tires could be reduced by 11 percent
by full implementation of the Phase 2 program in MY 2027, based on the
tire development achievements expected over the next decade. This is
estimated by weighting the projected improvements of steer tires and
drive tires using an assumed axle load distribution of 30 percent on
the steer tires and 70 percent on the drive tires, as explained in the
draft RIA Chapter 2.9. The projected adoption rates and expected
improvements in CRR are presented in Table V-16. By applying the
assumed axle load distribution, the average vehicle CRR improvements
projected for the proposed MY 2021 standards would be four percent,
which we project would achieve up to one percent reduction in fuel use
and CO2 emissions, depending on the vehicle subcategory.
Using that same method, the agencies estimate the average vehicle CRR
in MY 2024 would be seven percent, yielding reductions in fuel use and
CO2 emissions of between one and two percent, depending on
the vehicle subcategory.
The agencies understand that the vocational vehicle segment has
access to
[[Page 40310]]
a large variety of tires, including some that are designed for
tractors, some that are designed for HD pickups and vans, and some with
multiple use designations. In spite of the likely availability of LRR
tires during the Phase 2 program, the projected adoption rates are
intended to be conservative. 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 least
rolling resistance) only where it makes sense given these vehicles'
differing purposes and applications.
Table V-16--Projected LRR Tire Adoption Rates
----------------------------------------------------------------------------------------------------------------
Level of rolling MY 2021 MY 2024 MY 2027
Tire position resistance adoption rate adoption rate adoption rate
----------------------------------------------------------------------------------------------------------------
Drive............................... Baseline CRR (7.7)..... 50 20 10
Steer............................... Baseline CRR (7.7)..... 20 10 0
Drive............................... 5% Lower CRR (7.3)..... 50 50 25
Steer............................... 10% Lower CRR (6.9).... 80 30 20
Drive............................... 10% Lower CRR (6.9).... 0 30 50
Steer............................... 15% Lower CRR (6.5).... 0 60 30
Drive............................... 15% Lower CRR (6.5).... 0 0 15
Steer............................... 20% Lower CRR (6.2).... 0 0 50
Drive............................... Average Improvement in 3% 6% 9%
CRR.
Steer............................... Average Improvement in 8% 12% 17%
CRR.
----------------------------------------------------------------------------------------------------------------
For comparison purposes, the reader may note that these levels of
tire CRR generally correspond with levels of tire CRR projected for
tractors built for the Phase 1 standards. For example, the baseline
level CRR for vocational tires is very similar to the baseline tractor
steer tire CRR. Vocational vehicle tires with 10 percent better CRR
have a similar CRR level as tractor tires of Drive Level 1. Vocational
vehicle tires with 15 percent better CRR have a similar CRR level as
tractor tires of Steer Level 1. Vocational vehicle tires with 20
percent better CRR have a similar CRR level as tractor tires of Drive
Level 2, as described in Section III.D.2.
(iv) Idle Reduction Packages
In this proposal, we are projecting a progression of idle reduction
technology development that begins with 70 percent adoption rate of
neutral idle for the MY 2021 standards, which by MY 2027 is replaced by
a 70 percent adoption rate of stop-start idle reduction technology.
Although it is possible that a vehicle could have both neutral idle and
stop-start, we are only considering emissions reductions for vehicles
with one or the other of these technologies. Also, as the program
phases in, we do not see a reduction in the projected adoption rate of
neutral idle to be a concern in terms of stranded investment, because
it is a very low cost technology that could be an enabler for stop-
start systems in some cases.
We are not projecting any adoption of neutral idle for the HHD
Regional subcategory, because any vehicle with a manual transmission
must shift to neutral when stopped to avoid stalling the engine, so
that vehicles in the HHD Regional subcategory would already essentially
be idling in neutral and no additional technology would be needed to
achieve this. A similar case can be made for any vocational vehicle
with an automated manual transmission, since these share inherently
similar architectures with manuals. The agencies are not projecting an
adoption rate of 85 percent neutral idle until MY 2024, because it may
take some additional development time to apply this technology 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 development time as well as some work to
enable two-way communication between engines and transmissions.
We are projecting a five percent adoption rate of stop-start in the
six MHD and LHD subcategories for MY 2021 and zero for the HHD
vehicles, because this technology is still developing for vocational
vehicles and is most likely to be feasible in the early years of Phase
2 for vehicles with lower power demands and lower engine inertia.
Stopping a heavy-duty engine is not challenging. The real challenge is
designing a robust system that can deliver multiple smooth restarts
daily without loss of function while the engine is off. Many current
light-duty products offer this feature, and some heavy-duty
manufacturers are exploring this.\315\ The agencies are projecting an
adoption rate of 15 percent stop-start across all subcategories in the
intermediate year of MY 2024. The agencies are projecting this
technology to have a relatively high adoption rate (70 percent as
stated above) by MY 2027 because we see it being technically feasible
on the majority of vocational vehicles, and especially effective on
those with the most time at idle in their workday operation. Although
we are not prepared to predict what fraction of vehicles would adopt
stop-start in the absence of Phase 2, the draft RIA Chapter 2.9
explains why the agencies are confident that this technology, which is
on the entry-level side of the hybrid and electrification spectrum,
will be widely available in the Phase 2 time frame.
---------------------------------------------------------------------------
\315\ See Ford announcement December 2013, https://
media.ford.com/content/fordmedia/fna/us/en/news/2013/12/12/70-
percent-of-ford-lineup-to-have-auto-start-stop-by-2017--fuel-.html.
See also Allison-Cummins announcement July 2014, http://www.oemoffhighway.com/press_release/12000208/allison-stop-start?utm_source=OOH+Industry+News+eNL&utm_medium=email&utm_campaign=RCL140723006.
---------------------------------------------------------------------------
Based on these projected adoption rates and the effectiveness
values described above in this section, we expect overall GHG and fuel
consumption reductions from workday idle on vocational vehicles to be
approximately three percent in MY 2027.
(v) Weight Reduction Packages
As described in the draft RIA Chapter 2.12, weight reduction is a
relatively costly technology, at approximately $3 to $4 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 weight reduction
would most likely be used for vocational vehicles in the refuse and
construction service classes, as well as some regional delivery
vehicles. The agencies are
[[Page 40311]]
predicating the proposed standards on an adoption rate of five to eight
percent, depending on the subcategory, in MY 2027, with slightly lower
adoption rates in MY 2021 and MY 2024.
For this technology package, NHTSA and EPA project manufacturers
would use material substitution in the amount of 200 lbs. An example of
how this weight could be reduced would be a complete set of aluminum
wheels for a Class 8 vocational vehicle, or an aluminum transmission
case plus high strength steel wheels, frame rails, and suspension
brackets on a MHD or LHD vocational vehicle. The agencies have limited
information about how popular the use of aluminum components is in the
vocational vehicle sector. We request comments with information on
whether any lightweight vocational vehicle components are in such
widespread use that we should exclude them from the list of components
for which a GEM improvement value would be available.
(c) GEM Inputs for Derivation of Proposed Vocational Vehicle Standards
To derive the stringency of the proposed vocational vehicle
standards, the agencies developed a suite of fuel consumption maps for
use with the GEM: One set of maps that represent engines meeting the
proposed MY 2021 vocational diesel engine standards, a second set of
maps representing engines meeting the proposed MY 2024 vocational
diesel engine standards, and a third set of maps representing engines
meeting the proposed MY 2027 vocational diesel engine standards.\316\
By incorporating the engine technology packages projected to be adopted
to meet the proposed Phase 2 vocational CI engine standards, the
agencies employed GEM engine models in deriving the stringency of the
proposed Phase 2 CI-powered vocational vehicle standards. As noted
above, because the agencies did not have enough information to develop
a robust GEM-based gasoline engine fuel map, the stringency of the
proposed SI-powered vocational vehicle standards is derived as an
adjustment from the CI-powered vocational vehicle standards. See the
draft RIA Chapter 2.9 for more details about this adjustment process.
---------------------------------------------------------------------------
\316\ See Section II.D.2 of this preamble for the derivation of
the engine standards.
---------------------------------------------------------------------------
Depending on the particular technology, either the effectiveness
was assigned by the agencies using an accepted average value, or the
GEM tool was used to assess the proposed technology effectiveness, as
discussed above. The agencies derived a scenario vehicle for each
subcategory using the adoption rate and assigned or modeled improvement
values of transmission, axle, and idle reduction technologies. For
example, the MY 2021 CRR values for each subcategory scenario case were
derived as follows: For steer tires--20 percent times 7.7 plus 80
percent times 6.9 yields an average CRR of 7.1 kg/metric ton; and for
drive tires--50 percent times 7.7 plus 50 percent times 7.3 yields an
average CRR of 7.5 kg/metric ton. Similar calculations were done for
weight reduction, transmission improvements, and axle improvements. The
set of tire CRR, idle reduction, weight reduction, engine and
transmission input parameters that was modeled in GEM in support of the
proposed MY 2021 vocational vehicle standards is shown in Table V-17.
The agencies derived the level of the proposed MY 2024 standards by
using the tire, weight reduction, engine and transmission GEM inputs
shown in Table V-18, below. The agencies derived the level of the
proposed MY 2027 standards by using the tire, weight reduction, engine
and transmission GEM inputs shown in Table V-19, below. As post-
processing, the respective adoption rates and assigned improvement
values of transmission, axle, and idle reduction technologies were
calculated for each subcategory.
The agencies have not directly transferred the GEM results from
these inputs as the proposed standards. Rather, the proposed standards
are the result of the normalizing and benchmarking analysis described
above. The proposed standards are presented in Table V-4 through Table
V-9. Additional detail is provided in the RIA Chapter 2.9.
Table V-17--GEM Inputs Used To Derive Proposed 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
----------------------------------------------------------------------------------------------------------------
CI Engine \a\
----------------------------------------------------------------------------------------------------------------
2021 MY 7L, 200 hp E2021 MY 7L,
2021 MY 11L, 2021 MY 15L
200 hp Engine270 hp Engine
345 hp Engine 455hp
Engine
----------------------------------------------------------------------------------------------------------------
Transmission (improvement factor)
----------------------------------------------------------------------------------------------------------------
0.023 0.021 0.008 0.023 0.021 0.009 0.023 0.022 0.022
----------------------------------------------------------------------------------------------------------------
Axle (improvement factor)
----------------------------------------------------------------------------------------------------------------
0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.012
----------------------------------------------------------------------------------------------------------------
Stop-Start (adoption rate)
----------------------------------------------------------------------------------------------------------------
5% 5% 5% 5% 5% 5% 0% 0% 0%
----------------------------------------------------------------------------------------------------------------
Neutral Idle (adoption rate)
----------------------------------------------------------------------------------------------------------------
70% 70% 70% 70% 70% 70% 70% 70% 0%
----------------------------------------------------------------------------------------------------------------
Steer Tires (CRR kg/metric ton)
----------------------------------------------------------------------------------------------------------------
7.1 7.1 7.1 7.1 7.1 7.1 7.1 7.1 7.1
----------------------------------------------------------------------------------------------------------------
[[Page 40312]]
Drive Tires (CRR kg/metric ton)
----------------------------------------------------------------------------------------------------------------
7.5 7.5 7.5 7.5 7.5 7.5 7.5 7.5 7.5
----------------------------------------------------------------------------------------------------------------
Weight Reduction (lb)
----------------------------------------------------------------------------------------------------------------
8 8 14 8 8 12 8 8 10
----------------------------------------------------------------------------------------------------------------
Note:
\a\ SI engines were not simulated in GEM, rather a gas/diesel adjustment factor was applied to the results.
Table V-18--GEM Inputs Used To Derive Proposed 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
----------------------------------------------------------------------------------------------------------------
CI Engine\a\
----------------------------------------------------------------------------------------------------------------
2024 MY 7L, 2024 MY 11L,
2024 MY 15L, 2024 MY 15L
270 hp Engine345 hp Engine
455hp Engine 455hp
Engine
----------------------------------------------------------------------------------------------------------------
Transmission (improvement factor)
----------------------------------------------------------------------------------------------------------------
0.045 0.04 0.017 0.045 0.041 0.018 0.045 0.042 0.035
----------------------------------------------------------------------------------------------------------------
Axle (improvement factor)
----------------------------------------------------------------------------------------------------------------
0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.014
----------------------------------------------------------------------------------------------------------------
Stop-Start (adoption rate)
----------------------------------------------------------------------------------------------------------------
15% 15% 15% 15% 15% 15% 15% 15% 15%
----------------------------------------------------------------------------------------------------------------
Neutral Idle (adoption rate)
----------------------------------------------------------------------------------------------------------------
85% 85% 85% 85% 85% 85% 85% 85% 0%
----------------------------------------------------------------------------------------------------------------
Steer Tires (CRR kg/metric ton)
----------------------------------------------------------------------------------------------------------------
6.8 6.8 6.8 6.8 6.8 6.8 6.8 6.8 6.8
----------------------------------------------------------------------------------------------------------------
Drive Tires (CRR kg/metric ton)
----------------------------------------------------------------------------------------------------------------
7.3 7.3 7.3 7.3 7.3 7.3 7.3 7.3 7.3
----------------------------------------------------------------------------------------------------------------
Weight Reduction (lb)
----------------------------------------------------------------------------------------------------------------
8 8 14 8 8 12 8 8 10
----------------------------------------------------------------------------------------------------------------
Note:
\a\ SI engines were not simulated in GEM, rather a gas/diesel adjustment factor was applied to the results.
Table V-19--GEM Inputs Used To Derive Proposed 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
----------------------------------------------------------------------------------------------------------------
CI Engine \a\
----------------------------------------------------------------------------------------------------------------
2027 MY 7L, 2027 MY 7L,
2027 MY 11L, 2027 MY 15L
200 hp Engine270 hp Engine
345 hp Engine 455hp
Engine
----------------------------------------------------------------------------------------------------------------
Transmission (improvement factor)
----------------------------------------------------------------------------------------------------------------
0.096 0.085 0.034 0.096 0.088 0.037 0.097 0.089 0.036
----------------------------------------------------------------------------------------------------------------
Axle (improvement factor)
----------------------------------------------------------------------------------------------------------------
0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.014
----------------------------------------------------------------------------------------------------------------
[[Page 40313]]
Stop-Start (adoption rate)
----------------------------------------------------------------------------------------------------------------
75% 70% 70% 75% 70% 70% 70% 70% 70%
----------------------------------------------------------------------------------------------------------------
Neutral Idle (adoption rate)
----------------------------------------------------------------------------------------------------------------
25% 30% 30% 25% 30% 30% 30% 30% 0%
----------------------------------------------------------------------------------------------------------------
Steer Tires (CRR kg/metric ton)
----------------------------------------------------------------------------------------------------------------
6.4 6.4 6.4 6.4 6.4 6.4 6.4 6.4 6.4
----------------------------------------------------------------------------------------------------------------
Drive Tires (CRR kg/metric ton)
----------------------------------------------------------------------------------------------------------------
7.0 7.0 7.0 7.0 7.0 7.0 7.0 7.0 7.0
----------------------------------------------------------------------------------------------------------------
Weight Reduction (lb)
----------------------------------------------------------------------------------------------------------------
10 10 16 10 10 14 10 10 12
----------------------------------------------------------------------------------------------------------------
Note:
\a\ SI engines were not simulated in GEM, rather a gas/diesel adjustment factor was applied to the results.
(d) Technology Package Costs
The agencies have estimated the costs of the technologies that
could be used to comply with the proposed standards. The estimated
costs are shown in Table V-20 for MY2021, in Table V-21 for MY2024, and
Table V-22 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-20, in MY 2021
these range from approximately $600 for MHD and LHD Regional vehicles,
up to $3,400 for HHD Regional vehicles. Those two lower-cost packages
reflect zero hybrids, and the higher-cost package reflects significant
adoption of automated transmissions. In the draft RIA Chapter 2.13.2,
the agencies present vocational vehicle technology package costs
differentiated by MOVES vehicle type. For example, intercity buses are
estimated to have an average package cost of $2,900 and gasoline motor
homes are estimated to have an average package cost of $450 in MY 2021.
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 draft RIA
Chapter 2.12. For example, Chapter 2.12.7 describes why a complex
technology such as hybridization is estimated to range between $15,000
and $40,000 per vehicle for vocational vehicles in MY 2021. The engine
costs listed represent the cost of an average package of diesel engine
technologies as set out in Section II. Individual technology adoption
rates for engine packages are described in Section II.D. The details
behind all these costs are presented in draft RIA Chapter 2.12,
including the markups and learning effects applied and how the costs
shown here are weighted to generate an overall cost for the vocational
segment. We welcome comments on our technology cost assessments.
[[Page 40314]]
Table V-20--Vocational Vehicle Technology Incremental Costs for the Proposal in the 2021 Model Year\a\ \b\
[2012$]
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
--------------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\...................................................... $293 $293 $293 $270 $270 $270 $270 $270 $270
Tires........................................................... 7 7 7 7 7 7 7 7 7
Transmission.................................................... 81 81 81 81 81 81 81 81 2,852
Axle related.................................................... 99 99 99 99 99 99 148 148 219
Weight Reduction................................................ 27 27 48 27 27 41 27 27 34
Idle reduction.................................................. 49 49 49 51 51 51 6 6 0
Electrification & hybridization................................. 547 547 0 861 861 0 1,437 1,437 0
Air Conditioning \d\............................................ 22 22 22 22 22 22 22 22 22
-------------------------------------------------------------------------------------------------------------------------------
Total....................................................... 1,125 1,125 598 1,418 1,418 571 1,998 1,998 3,404
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
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 draft RIA (see draft
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 vehicle classes. To see the actual
estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft 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 no additional costs beyond Phase 1 for gasoline vocational engines.
\d\ EPA's air conditioning standards are presented in Section V.C above.
[[Page 40315]]
The estimated fleet average vocational vehicle package costs are
shown in Table V-21 for MY 2024. As shown, these range from
approximately $800 for MHD and LHD Regional vehicles, up to $4,800 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 draft RIA Chapter 2.12. For example,
Chapter 2.12.7 presents MY 2024 hybridization costs that range from
$13,000 to $33,000 per vehicle for vocational vehicles. The engine
costs listed represent the average costs associated with the proposed
MY 2024 vocational diesel engine standard described in Section II.D.
[[Page 40316]]
Table V-21--Vocational Vehicle Technology Incremental Costs for the Proposal in the 2024 Model Year\a\ \b\
[2012$]
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
--------------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\...................................................... $437 $437 $437 $405 $405 $405 $405 $405 $405
Tires........................................................... 17 17 17 17 17 17 23 23 23
Transmission.................................................... 123 123 123 123 123 123 123 123 3,915
Axle related.................................................... 90 90 90 90 90 90 136 136 224
Weight Reduction................................................ 24 24 43 24 24 37 24 24 30
Idle reduction.................................................. 119 119 119 125 125 125 224 224 217
Electrification & hybridization................................. 906 906 0 1,423 1,423 0 2,377 2,377 0
Air Conditioning \d\............................................ 20 20 20 20 20 20 20 20 20
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Total....................................................... 1,737 1,737 849 2,228 2,228 817 3,332 3,332 4,834
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
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 draft RIA (see draft
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 vehicle classes. To see the actual
estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft 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 no additional costs beyond Phase 1 for gasoline vocational engines.
\d\ EPA's air conditioning standards are presented in Section V.C above.
[[Page 40317]]
The estimated fleet average vocational vehicle package costs are
shown in Table V-22 for MY 2027. As shown, these range from
approximately $1,400 for MHD and LHD Regional vehicles, up to $7,400
for HHD Urban and Multipurpose vehicles. These two subcategories are
projected to have the higher-cost packages in MY 2027 due to an
estimated 18 percent adoption of HHD hybrids, which are estimated to
cost $31,000 per vehicle in MY 2027, as shown in Chapter 2.12.7 of the
draft RIA. These per-vehicle technology package costs were averaged
using our projections of vehicle populations in the nine regulatory
subcategories and do not correspond to the MOVES vehicle types. The
engine costs shown represent the average costs associated with the
proposed MY 2027 vocational diesel engine standard described in Section
II.D. For gasoline vocational vehicles, the agencies are projecting
adoption of Level 2 engine friction reduction with an estimated $68
added to the average SI vocational vehicle package cost in MY 2027,
which represents about 56 percent of those vehicles upgrading beyond
Level 1 engine friction reduction. Further details on how these SI
vocational vehicle costs were estimated are provided in the draft RIA
Chapter 2.9.
Purchase prices of vocational vehicles can range from $60,000 for a
stake-bed landscape truck to over $400,000 for some transit buses. The
costs of the vocational vehicle standards can be put into perspective
by considering package costs estimated using MOVES vehicle types along
with typical prices for those vehicles. For example, a package cost of
$4,000 on a $60,000 short haul straight truck would represent an
incremental increase of about six percent of the vehicle purchase
price. Similarly, a package cost of $7,000 on a $200,000 refuse truck
would represent an incremental increase of less than four percent of
the vehicle purchase price. The vocational vehicle industry
characterization report in the docket includes additional examples of
vehicle prices for a variety of vocational applications.\317\
---------------------------------------------------------------------------
\317\ See industry characterization, Note 260, above.
[[Page 40318]]
Table V-22--Vocational Vehicle Technology Incremental Costs for the Proposal in the 2027 Model Year\a\ \b\
[2012$]
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
--------------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\...................................................... $471 $471 $471 $437 $437 $437 $437 $437 $437
Tires........................................................... 20 20 20 20 20 20 29 29 29
Transmission.................................................... 244 244 267 244 244 267 244 244 2,986
Axle related.................................................... 86 86 86 86 86 86 129 129 215
Weight Reduction................................................ 29 29 46 29 29 40 29 29 35
Idle reduction.................................................. 498 499 499 526 526 526 964 964 962
Electrification & hybridization................................. 2,122 2,122 0 3,336 3,336 0 5,571 5,571 0
Air Conditioning \d\............................................ 19 19 19 19 19 19 19 19 19
-------------------------------------------------------------------------------------------------------------------------------
Total....................................................... 3,489 3,490 1,407 4,696 4,696 1,395 7,422 7,422 4,682
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
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 draft RIA (see draft
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 vehicle classes. To see the actual
estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft 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 no additional costs beyond Phase 1 for gasoline vocational engines.
\d\ EPA's air conditioning standards are presented in Section V.C above.
[[Page 40319]]
(3) Consistency of the Proposed Vocational Vehicle Standards With the
Agencies' Legal Authority
NHTSA and EPA project the proposed standards to be achievable
within known design cycles, and we believe these standards, although
technology-forcing, would allow many different paths to compliance in
addition to the example outlined in this section. The proposed
standards are predicated on manufacturers implementing technologies
that we expect will be available in the time frame of these proposed
rules, although in some instances these technologies are still under
development or not widely deployed in the current vocational vehicle
fleet. Under the proposal, manufacturers would need to apply a range of
technologies to their vocational chassis, which the agencies believe
would be consistent with the agencies' respective statutory
authorities. We are projecting that most vehicles could adopt certain
of the technologies. For example, we project a 70 to 75 percent
application rate for stop-start idle reduction and advanced axle
lubrication. However, for other technologies, such as strong hybrids
and weight reduction, we are projecting adoption rates of ten percent
or less overall, with individual subcategories having adoption rates
greater or less than this. The proposed standards offer manufacturers
the flexibility to apply the technologies that make sense for their
business and customer needs.
As discussed above, average per-vehicle costs associated with the
proposed 2027 MY standards are projected to be generally less than six
percent of the overall price of a new vehicle. The cost-effectiveness
of these proposed 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, which the agencies
have found to be highly cost effective.\318\ In addition, the
vocational vehicle standards are clearly effective from a net benefits
perspective (see draft RIA Chapter 11.2). Therefore, the agencies
regard the cost of the proposed standards as reasonable.
---------------------------------------------------------------------------
\318\ See Chapter 5.3 of the final RIA for the MY 2017-2025
Light-Duty GHG Rule, available at http://www.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, would be recovered within five years or less due to
the associated fuel savings, as shown in the payback analysis included
in Section IX and in the draft RIA Chapter 7.1. Specifically, in Table
7-30 of the draft RIA Chapter 7.1.3, 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 shown, the vocational vehicle type with the
shortest payback would be 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 fifth year or sooner.
The agencies note further that although the proposal is technology-
forcing (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 proposed standards are
technically feasible within the lead time provided, are cost effective
while accounting for the fuel savings (see draft 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 proposed standards thus 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). The agencies believe that the
proposed standards are consistent with their respective authorities.
Based on the information currently before the agencies, we believe that
the preferred alternative would be maximum feasible and reasonable for
the vocational segment with a progression of standards reaching full
implementation in MY 2027.
Nevertheless, as discussed in Section I. A. (1) and in Section X
(Alternatives), the agencies seek comment on the feasibility of
Alternative 4, which the agencies may determine is maximum feasible and
reasonable depending on comments and information received during the
comment period. This alternative is discussed in detail below because
it may be possible for manufacturers to accelerate product development
cycles enough to reach the required levels by the 2024 model year.
Thus, the agencies may conclude in the final rules that Alternative 4,
or some elements of this alternative, would be maximum feasible and
appropriate under CAA section 202 (a)(1) and (2), depending on
information and comments received. The agencies seek comments to assist
us in making that determination.
D. Alternative Vocational Vehicle Standards Considered
The agencies have analyzed vocational vehicle standards other than
the proposed standards. These alternatives, listed in Table III-22, are
described in detail in Section X of this preamble and the draft RIA
Chapter 11.
Table V-23--Summary of Alternatives Considered for the Proposed
Rulemaking
------------------------------------------------------------------------
------------------------------------------------------------------------
Alternative 1.......................... No action alternative
Alternative 2.......................... Less stringent than the
proposed alternative, applying
off-the-shelf technologies
Alternative 3 (Proposed Alternative)... Proposed alternative fully
phased-in by MY 2027
Alternative 4.......................... Same stringency as proposed
alternative, except phasing in
faster, by MY 2024
Alternative 5.......................... More stringent alternative,
based on higher adoption rates
of advanced technologies
------------------------------------------------------------------------
NHTSA and EPA are considering an Alternative 4 that achieves the
same level of stringency as the preferred alternative, except it would
provide less lead time, reaching its most stringent level three years
earlier than the
[[Page 40320]]
preferred alternative, that is in MY 2024. The agencies project that
the same selection of technology options would be available to
manufacturers regardless of what alternative is chosen. The preferred
alternative would allow greater lead time to manufacturers to select
and develop technologies for their vehicles.
The agencies have outstanding questions regarding relative risks
and benefits of Alternative 4 due to the time frame envisioned by that
alternative. If the agencies receive relevant information supporting
the feasibility of Alternative 4, the agencies may consider
establishing vocational vehicle standards that provide more overall
reductions than what we are proposing if we deem them to be maximum
feasible and reasonable for NHTSA and EPA, respectively. See the draft
RIA Chapter 11.2.2 for a summary of costs and benefits that compares
the proposed Phase 2 vocational vehicle program with the costs and
benefits of other vocational vehicle alternatives considered.
In the paragraphs that follow, the agencies present the derivation
of the Alternative 4 vocational vehicle standards. For currently
developing technologies where we project an adoption rate that could
present potential risks or challenges, we seek comment on the cost and
effectiveness of such technology. Further, the agencies seek comment on
the potential for adoption of developing technologies into the
vocational vehicle fleet, as well as the extent to which the more
accelerated alternative vocational vehicle standards may depend on such
technology.
(1) Adoption Rates for Derivation of Alternative 4 Vocational Vehicle
Standards
In developing the Alternative 4 standards, the agencies are
projecting a set of technology packages in MY 2024 that is identical to
those projected for the final phase-in year of the preferred
alternative. Because these are the same for each subcategory, the GEM
inputs modeled to derive the level of the MY 2024 Alternative 4
standards can be found in Table V-19, which presents the GEM inputs
used to derive the level of the MY 2027 proposed standards. In the
package descriptions below, the agencies outline technology-specific
adoption rates in MY 2021 for Alternative 4 and offer insights on what
market conditions could enable reaching adoption rates that would
achieve the full implementation levels of stringency with less lead
time.
For transmissions including hybrids, the agencies project for
Alternative 4 that 50 percent of vocational vehicles would have one or
more of the transmission technologies identified above in this section
applied by MY 2021. This includes 25 percent deeply integrated
conventional transmissions that would be recognized over the powertrain
test, 10 percent DCT, 11 percent adding two gears (except zero for HHD
Regional), and nine percent hybrids for vehicles certified in the
Multi-Purpose and Urban subcategories, which we estimate would be five
percent overall. In this alternative, the agencies project 21 percent
of the vocational vehicles with manual transmissions in the HHD
Regional subcategory would upgrade to either an AMT, DCT, or automatic
transmission. The increased projection of driveline integration would
mean that more manufacturers would need to overcome data-sharing
barriers. In this alternative, we project that manufacturers would need
to conduct additional research and development to achieve overall
application of five percent hybrids. In the draft RIA Chapter 7.1, the
agencies have estimated costs for this additional accelerated research.
Comments are requested on the expected costs to accelerate hybrid
development to meet the projected adoption rates of this alternative.
For advanced axle lubricants, the agencies are projecting the same
75 percent adoption rate in MY 2021 as in the proposed program. For
part time or full time 6x2 axles, the agencies project the HHD Regional
vocational vehicles could apply this at the 60 percent adoption rate in
MY 2021, where this level wouldn't be reached until MY 2024 in the
proposed program. One action that could enable this to be achieved is
if information on the reliability of these systems were to be
disseminated to more fleet owners by trustworthy sources.
For lower rolling resistance tires in this alternative, the
agencies project the same adoption rates of LRR tires as in the
proposed program for MY 2021, because we don't expect tire suppliers
would be able to make greater improvements for the models that are
fitted on vocational vehicles in that time frame. The tire research
that is being conducted currently is focused on models for tractors and
trailers, and we project further improved LRR tires would not be
commercially available for vocational vehicles in the early
implementation years of Phase 2.
For the adoption rate of LRR tires in MY 2024 to reach the level
projected for MY 2027 in the proposed program, tire suppliers could
promote their most efficient products to vocational vehicle
manufacturers to achieve equivalent improvements with less lead time.
Depending on how tire manufacturers focus their research and product
development, it is possible that more of the LRR tire advancements
being applied for tractors and trailers could be applied to vocational
vehicles. To see the specific projected adoption rates of different
levels of LRR tires for Alternative 4, see columns three and five of
Table V-16 above.
For workday idle technologies, the agencies project an adoption
rate of 12 percent stop-start in the six MHD and LHD subcategories for
MY 2021 and zero for the HHD vehicles, on the expectation that
manufacturers would have fewer challenges in the short term in bringing
this technology to market for vehicles with lower power demands and
lower engine inertia. In this alternative, the agencies project the
overall workday idle adoption rate would approach 100 percent, such
that any vehicle without stop-start (except HHD Regional) would apply
neutral idle in MY 2021. These adoption raters consider a more
aggressive investment by manufacturers in developing these
technologies. Estimates of research and development costs for this
alternative are presented in the draft RIA Chapter 7.1.
For weight reduction, in this alternative, the agencies project the
same adoption rates of a 200-lb lightweighting package as in the
proposal for each subcategory in MY 2021, which is four to seven
percent. Table V-24 shows the GEM inputs used to derive the level of
the Alternative 4 MY 2021 standards.
[[Page 40321]]
Table V--24--GEM Inputs Used To Derive Alternative 4 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Alternative 4 CI Engine a
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021 MY 7L, 200 hp Engine 2021 MY 7L, 270 hp Engine
2021 MY 11L, 345 hp 2021 MY
Engine 15L 455hp
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission (improvement factor)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0.045................................................... 0.04 0.014 0.045 0.041 0.015 0.045 0.041 0.018
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle (improvement factor)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0.004................................................... 0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.015
--------------------------------------------------------------------------------------------------------------------------------------------------------
Stop-Start (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
12%..................................................... 12% 12% 12% 12% 12% 0% 0% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Neutral Idle (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
88%..................................................... 88% 88% 88% 88% 88% 90% 90% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
7.1..................................................... 7.1 7.1 7.1 7.1 7.1 7.1 7.1 7.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
7.5..................................................... 7.5 7.5 7.5 7.5 7.5 7.5 7.5 7.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Weight Reduction (lb)
--------------------------------------------------------------------------------------------------------------------------------------------------------
8....................................................... 8 14 8 8 12 8 8 10
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ SI engines were not simulated in GEM, rather a gas/diesel adjustment factor was applied to the results.
(2) Possible Alternative 4 Standards
Because the MY 2024 Alternative 4 standards are the same as the
proposed standards for MY 2027 for each subcategory, these numerical
standards can be found in Table V-8 and Table V-9, which present EPA's
and NHTSA's proposed MY 2027 standards, respectively. Table V-25 and
Table V-26 present the Alternative 4 vocational vehicle standards for
the initial year of MY 2021. These represent incremental improvements
over the MY 2017 baseline of six to seven percent for SI-powered
vocational vehicles and nine percent for CI-powered vocational
vehicles.
Table V-25--Alternative 4 EPA CO2 Standards for MY2021 Class 2\b\-8
Vocational Vehicles
------------------------------------------------------------------------
Light heavy- Medium Heavy heavy-
Duty cycle duty Class heavy-duty duty Class
2b-5 Class 6-7 8
------------------------------------------------------------------------
Alternative EPA Standard for Vehicle with CI Engine Effective MY2021
(gram CO2/ton-mile)
------------------------------------------------------------------------
Urban............................ 288 183 193
Multi-Purpose.................... 297 185 196
Regional......................... 309 181 185
------------------------------------------------------------------------
Alternative EPA Standard for Vehicle with SI Engine Effective MY2021
(gram CO2/ton-mile)
------------------------------------------------------------------------
Urban............................ 313 199 210
Multi-Purpose.................... 323 201 212
Regional......................... 336 197 201
------------------------------------------------------------------------
[[Page 40322]]
Table V-26--Alternative 4 NHTSA Fuel Consumption Standards for MY2021 Class 2\b\-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-duty Medium heavy-duty Heavy heavy-duty
Duty cycle Class 2b-5 Class 6-7 Class 8
----------------------------------------------------------------------------------------------------------------
Alternative NHTSA Standard for Vehicle with CI Engine Effective MY 2021 (Fuel Consumption gallon per 1,000 ton-
mile)
----------------------------------------------------------------------------------------------------------------
Urban............................................ 28.2908 17.9764 18.9587
Multi-Purpose.................................... 29.1749 18.1729 19.2534
Regional......................................... 30.3536 17.7800 18.1729
----------------------------------------------------------------------------------------------------------------
Alternative NHTSA Standard for Vehicle with SI Engine Effective MY 2021 (Fuel Consumption gallon per 1,000 ton-
mile)
----------------------------------------------------------------------------------------------------------------
Urban............................................ 35.2200 22.3923 23.6300
Multi-Purpose.................................... 36.3452 22.6173 23.8551
Regional......................................... 37.8080 22.1672 22.6173
----------------------------------------------------------------------------------------------------------------
(3) Costs Associated With Alternative 4 Standards
The agencies have estimated the costs of the technologies expected
to be used to comply with the Alternative 4 standards, as shown in
Table V-27 for MY2021. 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-27, in MY 2021
these range from approximately $800 for MHD and LHD Regional vehicles,
to $4,300 for HHD Urban and Multipurpose vehicles. Those two
subcategories are projected to have the higher-cost packages in MY 2021
due to an estimated 9 percent adoption of HHD hybrids, which are
estimated to cost $40,000 per vehicle in MY 2021, as shown in Chapter
2.12.7 of the draft RIA. For more specific information about the
agencies' estimates of per-vehicle costs, please see the draft RIA
Chapter 2.12. The engine costs listed represent the cost of an average
package of diesel engine technologies with Alternative 4 adoption rates
described in Section II.D.2(e). The details behind all these costs are
presented in draft RIA Chapter 2.12, including the markups and learning
effects applied and how the costs shown here are weighted to generate
an overall cost for the vocational segment.
Table V-27--Vocational Vehicle Technology Incremental Costs for Alternative 4 Standards in the 2021 Model Year \a\ \b\
(2012$)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
--------------------------------------------------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\........................................... $372 $372 $372 $345 $345 $345 $345 $345 $345
Tires................................................ 7 7 7 7 7 7 7 7 7
Transmission......................................... 148 148 148 148 148 148 148 148 2,042
Axle related......................................... 99 99 99 99 99 99 148 148 243
Weight Reduction..................................... 27 27 48 27 27 41 27 27 34
Idle reduction....................................... 110 110 110 116 116 116 8 8 0
Electrification & hybridization...................... 1,384 1,384 0 2,175 2,175 0 3,633 3,633 0
Air Conditioning \d\................................. 22 22 22 22 22 22 22 22 22
--------------------------------------------------------------------------------------------------
Total............................................ 2,169 2,169 805 2,938 2,938 777 4,337 4,337 2,693
--------------------------------------------------------------------------------------------------------------------------------------------------------
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 draft RIA (see draft 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 vehicle classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft 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 no additional costs beyond Phase 1 for gasoline vocational
engines.
\d\ EPA's air conditioning standards are presented in Section V.C above.
The estimated costs of the technologies expected to be used to
comply with the Alternative 4 standards for MY2024 are shown in Table
V-28. As shown, these range from approximately $1,500 for MHD and LHD
Regional vehicles to $7,900 for HHD Urban and Multipurpose vehicles.
These two subcategories are projected to have the higher-cost packages
in MY 2024 due to an estimated 18 percent adoption of HHD hybrids,
which are estimated to cost $33,000 per vehicle in MY 2024, as shown in
Chapter 2.12.7 of the draft RIA. The engine costs listed represent the
cost of an average package of diesel engine technologies with
Alternative 4 adoption rates described in Section II.D.2(e). For
gasoline vocational vehicles, the agencies are projecting adoption of
Level 2 engine friction reduction with an estimated $74 added to the
average SI vocational vehicle package cost in MY 2024, which represents
about 56 percent of those vehicles upgrading beyond Level 1 engine
friction reduction. Further
[[Page 40323]]
details on how these SI vocational vehicle costs were estimated are
provided in the draft RIA Chapter 2.9.
Table V-28--Vocational Vehicle Technology Incremental Costs for Alternative 4 Standards in the 2024 Model Year \a\
(2012$)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
--------------------------------------------------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\........................................... $493 $493 $493 $457 $457 $457 $457 $457 $457
Tires................................................ 26 26 26 26 26 26 40 40 40
Transmission......................................... 256 256 280 256 256 280 256 256 3,123
Axle related......................................... 90 90 90 90 90 90 136 136 224
Weight Reduction..................................... 30 30 49 30 30 43 30 30 37
Idle reduction....................................... 561 524 524 592 553 553 1,014 1,014 1,011
Electrification & hybridization...................... 2,264 2,264 0 3,559 3,559 0 5,943 5,943 0
Air Conditioning \d\................................. 20 20 20 20 20 20 20 20 20
--------------------------------------------------------------------------------------------------
Total............................................ 3,741 3,704 1,482 5,030 4,992 1,469 7,895 7,895 4,912
--------------------------------------------------------------------------------------------------------------------------------------------------------
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 draft RIA (see draft 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 vehicle classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft RIA (see RIA 2.9
in particular).
\c\ Engine costs shown are for a light HD, medium HD or heavy HD diesel engine. For gasoline-powered vocational vehicles we are projecting $74 of
additional engine-based costs beyond Phase 1.
\d\ EPA's air conditioning standards are presented in Section V.C above.
E. Compliance Provisions for Vocational Vehicles
We welcome comment on all aspects of the compliance program,
including those where we would adopt a provision without change in
Phase 2.
(1) Application and Certification Process
The agencies propose to continue to use GEM to determine compliance
with the proposed vehicle fuel efficiency and CO2 standards.
Because the agencies are proposing to modify GEM to recognize inputs in
addition to those recognized under Phase 1, there is a consequent
proposed requirement that manufacturers or component suppliers conduct
component testing to generate those input values. See Section II for
details of engine testing and GEM inputs for engines.
As described above in Section I, the agencies propose to 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 would be required to be
submitted by manufacturers is set forth in 40 CFR 1037.205, 49 CFR
537.6, and 49 CFR 537.7. EPA would continue to issue certificates upon
approval based on information submitted through the VERIFY database
(see 40 CFR 1037.255). End of year reports would 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 are proposed for Phase 2. In addition to the
steer and drive tire CRR, the proposed inputs include the following:
Engine fuel map,
Engine full-load torque curve,
Engine motoring curve,
Transmission type,
Transmission gear ratios,
Drive axle ratio,
Loaded tire radius for drive and steer tires,
Idle Reduction,
Weight Reduction, and
Other pre-defined off-cycle technologies.
(i) Driveline Inputs
As with tractors, for each engine family, an engine fuel map, full
load torque curve, and motoring curve would be generated by engine
manufacturers as inputs to GEM. The test procedures for the torque and
motoring curves are found in proposed 40 CFR part 1065. Section
II.D.1.b describes these proposed procedures as well as the proposed
new procedure for generating the engine fuel map. Also similar to
tractors, transmission specifications would be input to GEM. Any number
of gears could be entered with a numerical ratio for each, and
transmission type would be selectable as either a Manual, Automated
Manual, Automatic, or Dual Clutch transmission.
As part of the driveline information needed to run GEM, drive axle
ratio would be a user input. If a configuration has a two-speed axle,
the agencies propose that a manufacturer may enter the ratio that is
expected to be engaged most often. We request comment on whether the
agencies should allow this choice. Two-speed axles are typically
specified for heavy-haul vocational vehicles, where the higher
numerical ratio axle would be engaged during transient driving
conditions and to deliver performance needed on work sites, while the
lower numerical ratio axle would be engaged during highway driving. The
agencies request comment on whether we should require GEM to be run
twice, once with each axle ratio, where the output over the highway
cycles would be used from the run with the lower axle ratio, and the
output over the transient cycle would be used from the run with the
higher axle ratio.
Tire size would be a new input to GEM that is necessary for the
model to simulate the performance of the vehicle.
[[Page 40324]]
The draft 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 could also vary based on load and inflation levels, air
temperature, and tread depth. The agencies request comment on aspects
of measuring and reporting tire size that could be specified by rule,
to avoid any unnecessary compliance burden of the Phase 2 program.
(ii) Idle Reduction Inputs
Based on user inputs derived from engine testing described in
Section II and draft RIA Chapter 3, GEM would 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 defined in 40 CFR 1065.510(f)(4) for
variable speed engines) for use in the CO2 emission
calculation in 40 CFR 1037.510(b). The proposed regulations at 40 CFR
part 1065 specify that that there must be two consecutive reference
zero load idle points to establish periods of zero load idle for
purposes of calculating total work over an engine test cycle. These two
idle points from the engine test would be used in GEM for purposes of
calculating emissions during vehicle idling over the vocational vehicle
test cycles.
The agencies welcome comments on the inclusion of these
technologies into GEM in Phase 2.
(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
propose to apply relevant weights from the tractor lookup table to
vocational vehicles. As noted above, the agencies are proposing to
recognize weight reduction by allocating one half of the weight
reduction to payload in the denominator, while one half of the weight
reduction would be subtracted from the overall weight of the vehicle in
GEM.
To adapt the tractor table for vocational vehicles, the agencies
propose to add lookup values for vehicles in lower weight classes. We
believe it is appropriate to also recognize the weight reduction
associated with 6x2 axles.\319\ Components available for vocational
vehicle manufacturers to select for weight reduction are shown below in
Table V-29, below. We are also proposing 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. These are
shown as negative values in Table V-29 to indicate that GEM would
internally compute these values in an inverse manner as would be
computed for a weight reduction, for which the GEM input is a positive
numerical value. We welcome comments on all aspects of weight reduction
approaches and potential weight increases as a byproduct of technology
application.
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\319\ See NACFE Confidence Findings on the Potential of 6x2
Axles, Note 152 above.
Table V--29 Proposed 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.......... 8 8
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.......... 5.5 11
Clutch Housing............................ Aluminum..................... 34 40
Clutch Housing............................ High Strength Steel.......... 9 10
Suspension Brackets, Hangers.............. Aluminum..................... 67 100
Suspension Brackets, Hangers.............. High Strength Steel.......... 20 30
Transmission Case......................... Aluminum..................... 45 50
Transmission Case......................... High Strength Steel.......... 11 12
Crossmember--Cab.......................... Aluminum..................... 10 14 15
Crossmember--Cab.......................... High Strength Steel.......... 2 4 5
Crossmember--Non-Suspension............... Aluminum..................... 15 18 21
Crossmember--Non-Suspension............... High Strength Steel.......... 5 6 7
Crossmember--Suspension................... Aluminum..................... 15 20 25
Crossmember--Suspension................... High Strength Steel.......... 4 5 6
Driveshaft................................ Aluminum..................... 12 40 50
Driveshaft................................ High Strength Steel.......... 5 10 12
Frame Rails............................... Aluminum..................... 120 300 440
Frame Rails............................... High Strength Steel.......... 24 40 87
Wheels--Dual.............................. Aluminum..................... 126 126 210
Wheels--Dual.............................. High Strength Steel.......... 48 48 80
Wheels--Dual.............................. Lightweight Aluminum......... 180 180 300
Wheels--Wide Base Single.................. Aluminum..................... 278 278 556
Wheels--Wide Base Single.................. High Strength Steel.......... 168 168 336
Wheels--Wide Base Single.................. Lightweight Aluminum......... 294 294 588
[[Page 40325]]
Permanent 6x2 Axle Configuration.......... Multi........................ N/A N/A 300
CI Liquified Natural Gas Vocational Multi........................ \320\ \321\ -600
Vehicle.
SI Compressed Natural Gas Vocational Multi........................ -525
Vehicle.
CI Compressed Natural Gas Vocational Multi........................ -900
Vehicle.
----------------------------------------------------------------------------------------------------------------
(b) Test Procedures
Powertrain families aredefined in Section II.C.3.b, and powertrain
test procedures are discussed in the draft RIA Chapter 3. The agencies
propose that the results from testing a powertrain configuration using
the matrix of tests described in draft RIA Chapter 3.6 could be applied
broadly across all vocational vehicles in which that powertrain would
be installed.
---------------------------------------------------------------------------
\320\ See National Energy Policy Institute (2012), Note 200
above.
\321\ See Westport presentation (2013), Note 201, above.
---------------------------------------------------------------------------
As in Phase 1, the rolling resistance of each tire would 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 would input the CRR values for
the drive and steer tires separately into the GEM. For vocational
vehicles in Phase 2, the agencies propose that the vehicle load would
be distributed 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 would be
incorporated into the overall vehicle compliance value.
(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 proposing would apply to individual vehicles and
engines at production and in use. NHTSA is not proposing in-use
standards for vehicles and 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 is proposing to continue the Phase 1 approach to adjustment
factors and deterioration factors. 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 request comment on
whether any changes to the DF process are needed.
As with engine certification, a manufacturer must provide evidence
of compliance through the regulatory useful life of the vehicle.
Factors influencing vehicle-level GHG performance over the life of the
vehicle fall into two basic categories: Vehicle attributes and
maintenance items. Each category merits different treatment from the
perspective of assessing useful life compliance, as each has varying
degrees of manufacturer versus owner/operator responsibility.
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
are proposing to follow a design-based approach that would 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. In this proposal, the only maintenance costs we
have quantified are those for tire replacement, as described in Section
IX.C.3 and the draft RIA Chapter 7.1. The agencies invite comments with
information related to maintenance costs that the agencies should
quantify for the final rules.
For current non-hybrid technologies, if the vehicle remains in its
original certified condition throughout its useful life, it is not
believed that GHG emissions would increase as a result of service
accumulation. As in Phase 1, the agencies propose allowing 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. The vehicle manufacturer would be primarily responsible for
providing engineering analysis demonstrating that vehicle attributes
will last for the full useful life of the vehicle. We anticipate this
demonstration would show that components are constructed of
sufficiently robust materials and design practices so as not to become
dysfunctional under normal operating conditions.
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
[[Page 40326]]
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.
EPA and NHTSA are therefore proposing that the Phase 2 GHG and fuel
consumption standards for vocational vehicles at or below 19,500 lbs
GVWR apply over the same useful life of 150,000 miles or 15 years. 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 is proposing to 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 requests comment on this approach, including the
proposed values and the overall process envisioned for achieving the
long-term goal of adopting harmonized useful-life specifications for
criteria and GHG standards that properly represent the manufacturers'
obligation to meet emission standards over the expected service life of
the vehicles. EPA may also revisit the useful-life values that apply
for medium heavy-duty vehicles and heavy heavy-duty vehicles.
One technology option for vocational vehicle manufacturers to
reduce GHG emissions is to use a smaller engine, perhaps in conjunction
with a hybrid powertrain. This could lead to a situation where the
engine and the vehicle are subject to emission standards over different
useful-life periods. For example, an urban bus (heavy heavy-duty
vehicle), might be able to use a medium heavy-duty engine, or even a
light heavy-duty engine. While such a mismatch in useful life values
could be confusing, we don't believe it poses any particular policy
problem that we need to address. EPA requests comment on the
possibility of mismatched engine and vehicle useful-life values and on
any possible implications this may have for manufacturers' ability to
design, certify, produce, and sell their engines and vehicles.
(d) Assigning Vehicles to Test Cycles
The agencies propose the following logic for deciding which chassis
configurations would be assigned to each of the three proposed
vocational duty cycles and thus regulatory subcategories:
A vehicle would be certified over the Multipurpose Duty
Cycle, unless one of the following conditions warrants certifying over
either the Regional or Urban cycle.
If the vehicle is powered by a CI engine, use the Regional
Duty Cycle if the resulting value from the calculation described in
Equation V-1 is less than 75 percent.
If the vehicle is powered by a SI engine, use the Regional
Duty Cycle if the resulting value from the calculation described in
Equation V-1 is less than 45 percent.
[GRAPHIC] [TIFF OMITTED] TP13JY15.004
Where:
CutpointRegional is the percent of maximum engine test
speed that is achieved at a vehicle speed of 65 mph,
SLR is the static loaded tire radius entered into GEM as specified
in the regulations,
Axle ratio is the drive axle ratio that entered into GEM as
specified in the regulations,
Trans ratio is the ratio of the top transmission gear that is not
permanently locked out,
fntest is the maximum engine test speed as defined at 40
CFR 1065.610, and C is a constant equal to:
[GRAPHIC] [TIFF OMITTED] TP13JY15.005
If a vehicle is powered by a CI engine, use the Urban Duty
Cycle if the resulting value from the calculation described in Equation
V-2 is greater than 90 percent.
If a vehicle is powered by a SI engine, use the Urban Duty
Cycle if the resulting value from the calculation described in Equation
V-2 is greater than 50 percent.
[GRAPHIC] [TIFF OMITTED] TP13JY15.006
[[Page 40327]]
Where:
CutpointUrban is the percent of maximum engine test speed
that is achieved at a vehicle speed of 55 mph,
SLR is the static loaded tire radius entered into GEM as specified
in the regulations,
Axle ratio is the drive axle ratio that is entered into GEM as
specified in the regulations,
Trans ratio is the ratio of the top transmission gear that is not
permanently locked out,
fntest is the maximum engine test speed as defined at 40
CFR 1065.610, and C is a constant equal to:
[GRAPHIC] [TIFF OMITTED] TP13JY15.007
The agencies ran GEM with many vocational vehicle configurations to
develop a data set with which we could assess appropriate cutpoints for
the above equations. The configurations varied primarily by the engine
model, fuel type, and axle ratio. See the draft RIA Chapter 2.9.2 for
further details on the assessment process for these proposed cutpoints.
The agencies realize that there are vocational vehicles for which
the above logic may not result in an appropriate assignment of test
cycle. Therefore we are proposing an exception that would enable any
vehicle with a hybrid drivetrain to certify over the Urban test cycle.
Further, we are proposing that the following vehicles must be certified
using the Regional cycle: intercity coach buses, recreational vehicles,
and vehicles whose engine is exclusively certified over the SET. We are
also proposing to allow manufacturers to request a different duty
cycle. We request comment on this approach, and whether we should allow
manufacturers to have complete freedom to select a test cycle without
any need for EPA or NHTSA approval.
(2) Other Compliance Provisions
(a) 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
vocational vehicles that included several items. The Phase 1 vocational
vehicle label must include the manufacturer, vehicle identifier such as
the Vehicle Identification Number, vehicle family, regulatory
subcategory, date of manufacture, compliance statements, and emission
control system identifiers (see 40 CFR 1037.135). In Phase 1, the
vocational vehicle emission control system identifier is tire rolling
resistance, plus any innovative and advanced technologies.
The number of proposed emission control systems for greenhouse gas
emissions in Phase 2 has increased significantly. For example, the
engine, transmission, axle configuration, tire radius, and idle
reduction system are control systems that can be evaluated on-cycle in
Phase 2 (i.e. these technologies' performance can now be input to GEM),
but could not be evaluated in Phase 1. Due to the complexity in
determining greenhouse gas emissions as proposed 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 proposes 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 vocational vehicles
certified to the primary Phase 2 standards. However, the agencies may
finalize requirements to maintain some label content to facilitate a
limited visual inspection of key vehicle parameters that can be readily
observed. Such requirements may be very similar to the labeling
requirements from the Phase 1 rulemaking, though we would want to more
carefully consider the list of technologies that would allow for the
most effective inspection. We request comment on an appropriate list of
candidate technologies that would properly balance the need to limit
label content with the interest in providing the most useful
information for inspectors to confirm that vehicles have been properly
built. EPA is not proposing to modify the existing emission control
labels for vocational vehicles certified for MYs 2014-2020 (Phase 1)
CO2 standards.
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. We request comment on
any practical limitations in promptly providing this information. We
also request comment on approaches that would minimize burden for
manufacturers to respond to requests for vehicle build information and
would expedite an authorized compliance inspector's visual inspection.
For example, 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 would 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 request 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 may consider initiating a separate
rulemaking effort to propose and request comment on implementing such
an approach.
(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 propose to simplify
reporting such that
[[Page 40328]]
manufacturers would only be required to submit one end of the year
report 120 days after the end of the model year with the potential to
obtain approval for a delay up to 30 days. We welcome comment on this
proposed revision.
(c) Delegated Assembly
The proposed 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 many 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 when sold to the ultimate user. In Phase
1, the only vehicle technology available for certified vocational
vehicles was LRR tires. Because these are generally installed by the
chassis manufacturer, there would have been no need to rely on a second
stage manufacturer for purposes of certification.
In Phase 2, the agencies are considering 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 has adopted ``delegated assembly''
provisions for engines at 40 CFR 1068.261 to describe how manufacturers
can share compliance responsibilities through these cooperative
assembly procedures.
We are proposing to take a similar approach for vehicle-based GHG
standards in 40 CFR part 1037. The delegated assembly provisions as
proposed for GHG standards are focused on add-on features to reduce
aerodynamic drag, and on air conditioning systems. This may occur, for
example, if the certifying manufacturer sells a cab-complete chassis to
a secondary vehicle manufacturer, which in turn installs a box with the
appropriate aerodynamic accessories to reduce drag losses. To the
extent certifying manufacturers rely on secondary vehicle manufacturers
to bring the vehicle into a certified configuration, the following
provisions would apply:
The certifying manufacturer would describe their approach
to delegated assembly in the application for certification.
The certifying manufacturer would create installation
instructions to describe how the secondary vehicle manufacturer would
bring the vehicle into a certified configuration.
The certifying manufacturer would 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).
The delegated assembly provisions are most relevant to vocational
vehicles, but we are not proposing to limit these provisions to
vocational vehicles. Similarly, we expect that aerodynamic devices and
air conditioning systems are the most likely technologies for which
delegated assembly is appropriate, but we are not proposing to limit
the use of delegated assembly to these technologies.
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 obligated to comply with all of the regulations.
The draft regulations at 40 CFR 1037.621 describe further detailed
provisions related to delegated assembly. We request comment on all
aspects of these provisions. In particular, we request comment on how
the procedures should be applied more broadly or more narrowly for
specific technologies. We also request comment on any further
modifications that should be made to the delegated assembly provisions
to reflect the nature of manufacturing relationships or technologies
that are specific to greenhouse gas standards for heavy-duty highway
vehicles.
(d) Demonstrating Compliance With Proposed HFC Leakage Standards
EPA is proposing 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
would 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 would then
be calculated as this score divided by the system refrigerant capacity.
Consistent with the light-duty rule and the Phase 1 program for
other HD vehicles, EPA is proposing a requirement that vocational
chassis manufacturers 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 believes 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.
Consistent with HD GHG Phase 1, EPA is not proposing a specific in-
use standard for leakage, as neither test procedures nor facilities
exist to measure refrigerant leakage from a vehicle's air conditioning
system. However, consistent with the HD Phase 1 program and the light-
duty rule, where we propose to require that manufacturers attest to the
durability of components and systems used to meet the CO2
standards (see 75 FR 25689), we
[[Page 40329]]
propose to require 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 is proposing to not exempt glider vehicles from the Phase 2 GHG
emission and fuel consumption standards.\322\ Gliders and glider kits
are exempt from NHTSA's Phase 1 fuel consumption standards. EPA's
interim provisions of Phase 1 exempted glider vehicles produced by
small businesses from the Phase 1 CO2 emission standards but
did not include such a blanket exemption for other glider
vehicles.\323\ Thus, some glider vehicles are already subject to the
requirement to obtain a vehicle certificate prior to introduction into
commerce as a new vehicle. However, the agencies believe glider
manufacturers may not understand how these regulations apply to them,
resulting in a number of uncertified vehicles.
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\322\ Glider vehicles are new vehicles produced to accept
rebuilt engines (or other used engines) along with used axles and/or
transmissions. The common term ``glider kit'' is used here primarily
to refer to an assemblage of parts into which the used/rebuilt
engine is installed.
\323\ Rebuilt engines used in glider vehicles are subject to EPA
criteria pollutant emission standards applicable for the model year
of the engine. See 40 CFR 86.004-40 for requirements that apply for
engine rebuilding. Under existing regulations, engines that remain
in their certified configuration after rebuilding may continue to be
used.
---------------------------------------------------------------------------
EPA is concerned about adverse economic impacts on small businesses
that assemble glider kits and glider vehicles. Therefore, EPA is
proposing a new provision that would grandfather existing small
businesses, but cap annual production based on recent sales. This
approach is consistent with the approach recommended by the Small
Business Advocacy Review Panel, which believed there should be an
allowance to produce some glider vehicles for legitimate purposes. EPA
requests comment on whether any special provisions would be needed to
accommodate glider vehicles. See Section XIV.B for additional
discussion of the proposed requirements for glider vehicles.
Similarly, NHTSA is considering including gliders under its Phase 2
program. The agencies request comment on their respective
considerations. We believe that the agencies potentially having
different policies for glider kits and glider vehicles under the Phase
2 program would not result in problematic disharmony between the NHTSA
and EPA programs, because of the small number of vehicles that would be
involved. EPA believes that its proposed changes would result in the
glider market returning to the pre-2007 levels, in which fewer than
1,000 glider vehicles would be produced in most years. Given that a
large fraction of these vehicles would be exempted from EPA regulations
because they would be produced by qualifying small businesses, they
would thus, in practice, be treated the same under EPA and NHTSA
regulations. Only non-exempt glider vehicles would 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 would be few enough not to result in any meaningful
disharmony between the two agencies.
With regard to NHTSA's safety authority over gliders, the agency
notes that it has become increasingly aware of potential noncompliance
with its regulations applicable to gliders. NHTSA has learned of
manufacturers who 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 consider amending 49 CFR
571.7(e) and related regulations as necessary in the future. NHTSA
believes manufacturers may not be using this regulation as originally
intended.
(3) Proposed Compliance Flexibility Provisions
EPA and NHTSA are proposing three flexibility provisions
specifically for vocational vehicle manufacturers in Phase 2. These are
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 optional
chassis certification. The agencies are also proposing to remove or
modify several Phase 1 interim provisions, as described below. Program-
wide compliance flexibilities are discussed in Section I.B.3 to I.C.1.
(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 propose to carry-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 propose
that chassis manufacturers may 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 proposed Phase 2 approach would continue this. The only
difference is that in Phase 2, there would be different numerical
standards set for the SI-powered and CI-powered vehicles, but that
would not need to 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. E. (1) (c), EPA and NHTSA are proposing to
change the 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
proposing 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 would
maintain their value in the transition from Phase 1 to Phase 2, NHTSA
and EPA propose 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.\324\ Without this adjustment factor the
proposed 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 proposed adjustment would result in a loss of
program benefits because
[[Page 40330]]
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
smoothing the transition to the new Phase 2 standards. The agencies
believe that effectively discounting carry-forward credits from Phase 1
to Phase 2 would be unnecessary and could negatively impact the
feasibility of the proposed Phase 2 standards. EPA and NHTSA request
comment on all aspects of the averaging, banking, and trading program.
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\324\ See 40 CFR 1037.150(s) 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. 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
propose to largely continue the Phase 1 innovative technology program
but to redesignate it as an off-cycle program for Phase 2. The agencies
propose to maintain 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.
The agencies recognize that there are emerging technologies today
that are being developed, but would not be accounted for in the GEM
tool, and therefore would be considered off-cycle. These technologies
could include systems such as electrified accessories, air conditioning
system efficiency, and aerodynamics for vocational vehicles beyond
those tested and pre-approved in the HD Phase 2 program. Such off-cycle
technologies could include known, commercialized technologies if they
are not yet widely utilized in a particular heavy-duty sector
subcategory. Any credits for these technologies would 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 are proposing to 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 would not require a public approval
process of the test method. A manufacturer could 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 would be required to be approved
prior to collecting any test data. The agencies are also proposing to
continue 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
proposing to modify their provisions to clarify what documentation must
be submitted for approval, which would align them with provisions in 40
CFR 86.1869-12. NHTSA is separately proposing to prohibit 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 welcome recommendations on how to improve or
streamline the off-cycle technology approval process.
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 are proposed to be
recognized in our HD Phase 2 certification procedures as pre-defined
technologies, and would not be considered off-cycle. Examples of such
technologies for vocational vehicles include 6x2 axles and axle
lubricants. These default effectiveness values would be used as valid
inputs to GEM. The projected effectiveness of each vocational vehicle
technology is discussed in the draft RIA Chapter 2.9.
The agencies propose that the approval for Phase 1 innovative
technology credits (approved prior to 2021 MY) would 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 would not be required to request new approval for any
innovative credits carried into the off-cycle program, but would have
to demonstrate the new cycle does not account for these improvements
beginning in the 2021 MY. 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. The agencies also
seek comments on whether off-cycle technologies in the Phase 2 program
should be limited by infrequent common use and by what model years, if
any. We also seek comments on an appropriate penetration rate for a
technology not to be considered in common use.
(c) Optional Chassis Certification
In Phase 2, the agencies are proposing to continue the Phase 1
provisions allowing the optional chassis certification of vehicles over
14,000 lbs GVWR. In Phase 1 the agencies allowed manufacturers the
option to choose to comply with heavy-duty pickup or van standards, for
incomplete vehicles that were identical to those on complete pickup
truck or van counterparts, with respect to most components that affect
GHG emissions and fuel consumption, such as engines, cabs, frames,
transmissions, axles, and wheels. The incomplete vehicles would
typically be produced as cab-complete vehicles. For example, a
manufacturer could certify under this allowance an incomplete pickup
truck that includes the cab, but not the bed. The Phase 1 program also
includes provisions that allow manufacturers to include some Class 4
and Class 5 vehicles in averaging sets subject to the chassis-based HD
pickup and van standards, rather than the vocational vehicle
program.\325\
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\325\ See 76 FR 57259-57260, September 15, 2011 and 78 FR 36374,
June 17, 2013.
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This optional chassis certification of vehicles over 14,000 lbs
applies for greenhouse gas emission standards in Phase 1, but not for
criteria pollutant emission standards. We revisited this issue in the
recent Tier 3 final rule, where we revised the regulation to allow this
same flexibility relative to exhaust emission standards for criteria
pollutants. However, EPA is now seeking comment on the proper approach
for certifying vehicles above 14,000 lbs GVWR, because there are
lingering questions about how best to align the certification processes
for GHG emissions and for criteria pollutants. The agencies are
requesting comment on several issues on this topic, including whether
there should be an upper weight limit to this allowance. See Section
XIV.A.2 for the issues on which the agencies seek comment with respect
to chassis and engine certification for GHG and criteria pollutants for
vehicles opting into the HD pickup and van program.
[[Page 40331]]
(d) Phase 1 Flexibilities Not Proposed for Phase 2
As described above in Section I, the agencies are not proposing to
provide advanced technology credits in Phase 2. These technologies had
been defined in Phase 1 as hybrid powertrains, Rankine cycle engines,
all-electric vehicles, and fuel cell vehicles (see 40 CFR 1037.150(i)),
at a 1.5 credit value with the purpose 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. Our
feasibility assessment for the proposed Phase 2 vocational vehicle
standards includes a projection of the use of hybrid powertrains as
described earlier in this section; therefore the agencies believe it
would no longer be appropriate to provide extra credit for this
technology. As noted above, waste heat recovery is not projected to be
utilized for vocational vehicles within the time frame of Phase 2.
While the agencies are not proposing to premise the Phase 2 vocational
vehicle standards on fuel cells or electric vehicles, we expect that
any vehicle certified with this technology would provide such a large
credit to a manufacturer that an additional incentive credit would not
be necessary. We welcome comments on the need for such incentives,
including information on why an incentive for specific technologies in
this time frame may be warranted, recognizing that the incentive would
result in reduced benefits in terms of CO2 emissions and
fuel use due to the Phase 2 program.
The agencies are not proposing to extend early credits to
manufacturers who comply early with Phase 2 standards, because the ABT
program from Phase 1 will be available to manufacturers and this
displaces the need for early credits (see 40 CFR 1037.150(a)). Please
see the more complete discussion of this above in Section I.
Another Phase 1 interim flexibility that the agencies are not
proposing to continue in Phase 2 is the flexibility known as the
``loose engine'' provision, whereby SI engines sold to chassis
manufacturers and intended for use in vocational vehicles need not meet
the separate SI engine standard (see preamble Section II and draft RIA
Chapter 2.6), and instead may be averaged with the manufacturer's HD
pickup and van fleet. We believe the benefits this particular
flexibility offers for manufacturers in the interim between Phase 1 and
Phase 2 would diminish considerably in Phase 2. The agencies are
proposing a Phase 2 SI engine standard that is no more stringent than
the MY 2016 SI engine standard adopted in Phase 1, while the proposed
Phase 2 standards for the HD pickup and van fleet would be
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 was that they be
engine certified while the vehicle would be GEM certified under the GHG
rules. In Phase 2 the agencies propose to continue this as the
certification path for such engines intended for vocational vehicles.
See the draft RIA Chapter 2.6 for further discussion of the separate
engine standard for SI engines intended for vocational vehicles.
(e) Other Phase 1 Interim Provisions
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. In discussion 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 proposed to reduce the non-GHG certification burden for engines
paired with hybrid powertrain systems.
Also in Phase 1, EPA adopted provisions that reinforced the fact
that we were setting GHG emissions from the tailpipe of heavy-duty
vehicles. Therefore, we treated all electric vehicles as having zero
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 ignoring upstream emissions from the charging
of heavy-duty battery-electric vehicles. In our assessment, we have
observed that the few all-electric heavy-duty vocational vehicles that
have been certified are being produced in very small volumes in MY2014.
As we look to the future, we project very limited adoption of electric
vocational vehicles into the market; therefore, we believe that this
provision is still appropriate. Unlike the MY2012-2016 light-duty rule,
which adopted a cap whereby upstream emissions would be counted after a
certain volume of sales (see 75 FR 25434-25436), we believe there is no
need to propose a cap for vocational vehicles because of the infrequent
projected use of EV technologies in the Phase 2 timeframe. In Phase 2,
we propose to continue to deem electric vehicles as having zero
CO2, CH4, and N2O emissions as well as
zero fuel consumption. We welcome comments on this approach.
VI. Heavy-Duty Pickups and Vans
A. Introduction and 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 proposing to retain most elements from the structure of
the program established in the Phase 1 rule for the Phase 2 program
while proposing more stringent Phase 2 standards for MY 2027, phased in
over MYs 2021-2027, that would require additional GHG reductions and
fuel consumption improvements. The MY 2027 standards would remain in
place unless and until amended by the agencies.
Heavy-duty vehicles with GVWR between 8,501 and 10,000 lb 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 proposing
additional requirements for MDPVs in this rulemaking. Heavy-duty
vehicles with GVWR between 10,001 and 14,000 lb are classified as Class
3 motor vehicles. Class 2b and Class 3 heavy-duty vehicles together
emit about 15 percent of today's GHG emissions from the heavy-duty
vehicle sector.
About 90 percent of HD pickups and vans are \3/4\-ton and 1-ton
pickup trucks, 12- and 15-passenger vans, and large work vans that are
sold by vehicle manufacturers as complete vehicles, with no secondary
manufacturer making substantial modifications prior to registration and
use. Most of these vehicles are produced by companies with major light-
duty markets in the
[[Page 40332]]
United States, primarily Ford, General Motors, and 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).\326\
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\326\ 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).
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For the light-duty GHG and fuel economy \327\ 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).\328\ 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).\329\ For HD pickups and vans, the agencies also
set standards based on vehicle attributes, 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 for 4-wheel drive vehicles. See
generally 76 FR 57161-57162.
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\327\ 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.
\328\ EISA requires CAFE standards for passenger cars and light
trucks to be attribute-based; See 49 U.S.C. 32902(b)(3)(A).
\329\ The NAS 2010 report likewise recommended standards
recognizing the work function of HD vehicles. See 76 FR 57161.
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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.\330\ The agencies established separate curves for
diesel and gasoline HD pickups and vans. The agencies are proposing to
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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\330\ 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 are also provided in
the regulations at 40 CFR 1037.104 (which is proposed to be
redesignated as 40 CFR 86.1819-14).
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\331\ 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).
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[[Page 40333]]
[GRAPHIC] [TIFF OMITTED] TP13JY15.008
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
[[Page 40334]]
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. 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
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. Proposed HD Pickup and Van Standards
As described in this section, NHTSA and EPA are proposing more
stringent MY 2027 and later Phase 2 standards that would be phased in
over model years 2021-2027. The agencies are proposing 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. The agencies have analyzed several alternatives which are
discussed in this section below and in Section X. In particular, we are
requesting comment not only on the proposed standards but also
particularly on the Alternative 4 standard which would result in
approximately the same Phase 2 program stringency increase of about 16
percent compared to Phase 1 but would do so two years earlier, in MY
2025 rather than in MY 2027. The Alternative 4 phase in from 2021-2025
would be based on a year-over-year increase in stringency of 3.5
percent, as discussed below. While we believe the proposed preferred
alternative is feasible in the time frame of this rule, and that
Alternative 4 could potentially be feasible, the two phase-in schedules
differ in the required adoption rate of advanced technologies for
certain high volume vehicle segments. The agencies' analysis
essentially shows that the additional lead-time provided by the
preferred alternative would allow manufacturers to more fully utilize
lower cost technologies thereby reducing the adoption rate of more
advanced higher cost technologies such as strong hybrids. As discussed
in more detail in C.8 below, both of the considered phase-ins 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 Alternative 3 would allow
manufacturers more flexibility to fully utilize these non-hybrid
technologies to reduce the number of hybrids needed compared to
Alternative 4. Alternative 4 would additionally require significant
penetration of strong hybridization. We request comments, additional
information, data, and feedback to determine the extent to which such
adoption would be realistic within the MY 2025 timeframe.
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
[[Page 40335]]
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. and D below and Section 2 of the Draft 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.C and D and
Section X also discuss the selection of the proposed 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 in the Phase 1 rule. EPA is proposing to 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 proposing in-use standards for these vehicles in Phase 2.
All of the proposed standards for these HD pickups and vans 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 subset of these
incomplete vehicles, often called cab-chassis vehicles, are sold by the
vehicle manufacturers in configurations with complete cabs and 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 for HD pickups and vans), rather than the
vocational vehicle program.\332\ The agencies are proposing to continue
allowing such incomplete vehicles the option of certifying under either
the heavy duty pickup and van standards or the standards for vocational
vehicles.
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\332\ See 76 FR 57259-57260, September 15, 2011 and 78 FR 36374,
June 17, 2013.
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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 not proposing to retain the loose engine
provisions for Phase 2. These program elements are discussed above in
Section V.E. on vocational vehicles and XIV.A.2 on engines.
NHTSA and EPA request comment on all aspects of the proposed HD
pickup and van standards and program elements described below and the
alternatives discussed in Section X.
(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 propose to
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 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 was also consistent with NAS recommendations and
there was consensus in the public comments on the Phase 1 proposal
supporting this approach. For all of these reasons, the agencies
continue to believe that establishing chassis-based standards for Class
2b and 3 complete vehicles is appropriate for Phase 2.
(a) Work-Based Attributes
In developing the Phase 1 HD rulemaking, the agencies emphasized
creating a program structure that would achieve reductions in fuel
consumption and GHGs based on how vehicles are used and on the work
they perform in the real world. 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 lb 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,
[[Page 40336]]
only the higher curb weight caused by any heavier truck components
would play a role in affecting measured test results. However towing
capacity can be a significant factor to consider because HD pickup
truck towing capacities can be quite large, with a correspondingly
large effect on 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, 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 lb 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 the comments we received on the Phase 1 rule.
The agencies are proposing to continue using the work factor attribute
for the Phase 2 standards and request comments on continuing this
approach.
Recognizing that towing is not reflected in the certification test
for these vehicles, however, the agencies are requesting comment with
respect to the treatment of towing in the work factor, especially for
diesel vehicles. More specifically, does using the existing work factor
equation create an inappropriate incentive for manufacturers to provide
more towing capability than needed for some operators, or a
disincentive for manufacturers to develop vehicles with intermediate
capability. In other words, does it encourage ``surplus'' towing
capability that has no value to vehicle owners and operators? We
recognize that some owners and operators do actually use their vehicles
to tow very heavy loads, and that some owners and operators who rarely
use their vehicles to tow heavy loads nonetheless prefer to own
vehicles capable of doing so. However, others may never tow such heavy
loads and purchase their vehicles for other reasons, such as cargo
capacity or off-road capability. Some of these less demanding (in terms
of towing) users may choose to purchase gasoline-powered vehicles that
are typically less expensive and have lower GCWR values, an indicator
of towing capability. However, others could prefer a diesel engine more
powerful than today's gasoline engines but less powerful than the
typical diesel engines found in 2b and 3 pickups today. In this
context, the agencies are considering (but have not yet evaluated) four
possible changes to the work factor and how it is applied. First, the
agencies are considering revising the work factor to weight payload by
80 percent and towing by 20 percent. Second, we are considering capping
the amount of towing that could be credited in the work factor. For
example, the work factors for all vehicles with towing ratings above
15,000 lbs could be calculated based on a towing rating of 15,000 lbs.
It is important to be clear that such a provision would not limit the
towing capability manufacturers could provide, but would only impact
the extent to which the work factor would ``reward'' towing capability.
Third, the agencies are considering changing the shape of the standard
curve for diesel vehicles to become more flat at very high work
factors. A flatter curve would mean that vehicles with very high work
factors would be more similar to vehicles with lower work factors than
is the case for the proposed curve. Thus, conceptually, flattening the
curves at the high end might be appropriate if we were to determine
that these high work factor vehicles actually operate in a manner more
like the vehicles with lower work factors. For example, when not towing
and when not hauling a full payload, heavy-duty pickup trucks with very
different work factors may actually be performing the same amount of
work. Finally, we are considering having different work factor formulas
for pickups and vans, and are also further considering whether any of
other changes should be applied differently to pickups than to vans. We
welcome comments on both the extent to which surplus towing may be an
issue and whether any of the potential changes discussed above would be
appropriate. Commenters supporting such changes are encouraged to also
address any potential accompanying changes. For example, if we reweight
the work factor, would other changes to the coefficients defining the
target curves be important to ensure that standards remain at the
maximum feasible levels. (Commenters should, however, recognize that
average requirements will, in any event, depend on fleet mix, and the
agencies expect to update estimates of future fleet mix before issuing
a final rule).
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 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 proposing Phase 2 standards based on analysis
performed to determine the appropriate HD pickup and van Phase 2
standards and the most appropriate phase in of those standards. This
analysis, described below and in the Draft RIA, considered:
Projections of future U.S. sales for HD pickup 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 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
the levels of technology that are projected to be added to the
analysis fleet through MY2030 considering
[[Page 40337]]
further improvements needed in order to achieve compliance with
standards defining each regulatory (action) alternative for Phase 2.
Based on this analysis, EPA is proposing CO2 attribute-
based target standards shown in Figure VI-3 and Figure VI-4, and NHTSA
is proposing 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 tables, these standards would
be phased in year-by-year commencing in MY 2021. The agencies are not
proposing to change the standards for 2018-2020 and therefore the
standards would remain stable 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 consistent with the EISA requirements. For
MYs 2021-2027, the agencies are proposing annual reductions in the
standards as the primary phase-in of the Phase 2 standards. The
proposed standards become 16 percent more stringent overall between MY
2020 and MY 2027. This approach to the Phase 2 standards as a whole can
be considered a phase-in or implementation schedule of the proposed MY
2027 standards (which, as noted, would apply thereafter unless and
until amended).
For EPA, Section 202(a) 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.
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). Consistent with
these authorities, the agencies are proposing more stringent standards
beginning with MY 2021 that consider the level of technology we predict
can be applied to new vehicles in the 2021 MY. EPA believes the
proposed Phase 2 standards are consistent with CAA requirements
regarding lead-time, reasonable cost, and feasibility, and safety.
NHTSA believes the proposed 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 redesigns
differs among manufacturers. To provide lead time needed to accommodate
these longer redesign cycles, the proposed Phase 2 GHG standards would
not reach their highest stringency until 2027. Although the proposed
standards would become more stringent over time between MYs 2021 and
2027, the agencies expect manufacturers will likely strive to 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, banking, and trading provisions) to help balance compliance
costs over time (including by allowing needed changes to align with
redesign schedules). The agencies are proposing to provide stable
standards in MYs 2019-2020 in order to provide necessary lead time for
Phase 2. However, for some manufacturers, the transition to the Phase 2
standards may begin earlier (e.g., as soon as MY 2017) depending on
their vehicle redesign cycles. Although standards are not proposed to
change in MYs 2019-2020, manufacturers may introduce additional
technologies in order to carry forward corresponding improvements and
perhaps generate credits under the 5 year credit carry-forward
provisions established in Phase 1 and proposed to continue for Phase 2.
Sections VI.C. and D below provides additional discussion of vehicle
redesign cycles and the feasibility of the proposed standards.
While it is unlikely that there is a phase-in approach that would
equally fit with all manufacturers' unique product redesign schedules,
the agencies recognize that there are other ways the Phase 2 standards
could be phased in and request comments on other possible approaches.
One alternative approach would be to phase in the standards in a few
step changes, for example in MYs 2021, 2024 and 2027. 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 proposed approach.
Among the factors the agencies would consider in assessing a different
phase-in than that proposed would be impacts on lead time, feasibility,
cost, CO2 reductions and fuel consumption improvements. The
agencies request that commenters consider all of these factors in their
recommendations on phase-in.
As in Phase 1, the proposed Phase 2 standards would be met on a
production-weighted fleet average basis. No individual vehicle would
have to meet a particular fleet average standard. Nor would all
manufacturers have to meet numerically identical fleet average
requirement. Rather, each manufacturer would 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, would provide significant additional compliance flexibility in
implementing the standards. It is important to note, however, that
while the standards would differ numerically from manufacturer to
manufacturer, effective stringency should be essentially the same for
each manufacturer.
Also, as with the Phase 1 standards, the agencies are proposing
separate Phase 2 targets for gasoline-fueled (and any other Otto-cycle)
vehicles and diesel-fueled (and any other diesel-cycle) vehicles. The
targets would be used to determine the production-weighted 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 above-proposed stringency increase for Phase 2 applies equally to
the separate gasoline and diesel targets. 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 analysis suggests limited
potential for such optimization, especially considering uncertainties
involved with manufacturers' future fleet mix. The agencies have thus
maintained the equivalent rates of stringency increase. The agencies
invite comment on this element.
[[Page 40338]]
[GRAPHIC] [TIFF OMITTED] TP13JY15.009
[[Page 40339]]
Described mathematically, EPA's and NHTSA's proposed 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 lb if the vehicle is equipped with 4wd, otherwise equals 0
lb.
Towing Capacity = GCWR (lb) - GVWR (lb)
Coefficients a, b, c, and d are taken from Table VI-2.
Table VI-2--Proposed 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 MY2018 only.
As noted above, the standards are not proposed to change from the
final Phase 1 standards for MYs 2018-2020. The MY 2018-2020 standards
are shown in the Figures and tables above for reference.
NHTSA and EPA have also analyzed regulatory alternatives to the
proposed standards, as discussed in Sections VI.C and D and Section X.
below. The agencies request comments on all of the alternatives
analyzed for the proposal, but request comments on Alternative 4 in
particular. The agencies believe Alternative 4 has the potential to be
the maximum feasible alternative; however, based on the evidence
currently before us, EPA and NHTSA have outstanding questions regarding
relative risks and benefits of Alternative 4 due to the timeframe
envisioned by that alternative. Alternative 4 would provide less lead
time for the complete phase-in of the proposed Phase 2 standards based
on an annual improvement of 3.5 percent per year in MYs 2021-2025
compared to the proposed Alternative 3 per year improvement of 2.5
percent in MYs 2021-2027. The CO2 and fuel consumption
attribute-based target standards for the Alternative 4 phase-in are
shown in Figure VI-5 and Figure VI-6 below. As the target curves for
Alternative 4 show in comparison to the target curves shown above for
the proposed Alternative 3, the final Phase 2 standards would result in
essentially the same level of stringency under either alternative.
However, the Phase 2 standards would be fully implemented two years
earlier, in MY 2025, under Alternative 4. The agencies are seriously
considering whether this Alternative 4 (i.e., the proposed standards
but with two years less lead-time) would be realistic and feasible, as
described in Sections VI.C and D, Section X, and in the Draft RIA
Chapter 11. Alternative 4 is predicated on shortened lead time that
would result in accelerated and in some cases higher adoption rates of
the same technologies on which the proposed Alternative 3 is
predicated. The agencies request 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.
[[Page 40340]]
[GRAPHIC] [TIFF OMITTED] TP13JY15.010
As with Phase 1 standards, to calculate a manufacturer's HD pickup
and van fleet average standard, the agencies are proposing that
separate target curves be used for gasoline and diesel vehicles. The
agencies' proposed
[[Page 40341]]
standards 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. These target reductions are based on the agencies' assessment
of the feasibility of incorporating technologies (which differ for
gasoline and diesel powertrains) in the 2021-2027 model years, and on
the differences in relative efficiency in the current gasoline and
diesel vehicles.
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
proposed separate fuel type standards are appropriate in the timeframe
of this rule to protect for the availability of both gasoline and
diesel engines and will result in roughly equivalent redesign burdens
for engines of both fuel types as evidenced by feasibility and cost
analysis in RIA Chapter 10. The agencies request comment on the level
of stringency of the proposed standards, the continued separate targets
for gasoline and diesel HD pickups and vans, and the continued use of
the work-based attribute approach described above.
The proposed 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 proposing to change 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 not proposing to change these testing
protocols. The vehicles would continue to be tested using the same
heavy-duty chassis test procedures currently used by EPA for measuring
criteria pollutant emissions from these vehicles, but with the addition
of the highway fuel economy test cycle (HFET). These test procedures
are used by manufacturers for certification and emissions compliance
demonstrations and by the agencies for compliance verification and
enforcement. Although the highway cycle driving pattern is identical to
that of the light-duty test, other test parameters for running the
HFET, such as test vehicle loaded weight, are identical to those used
in running the current EPA Federal Test Procedure for complete heavy-
duty vehicles. Please see Section II.C (2) of the Phase 1 preamble (76
FR 57166) for a discussion of how HD pickups and vans would be tested.
One item that the agencies are considering to change is how
vehicles are categorized into test weight bins. 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, all
vehicles having a calculated test weight basis of 11,251 to 11,750 lbs
would be tested 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 do recognize that the
test weight bins allow for some reduction in testing burden as many
vehicles can be grouped together under a single test. For Phase 2, the
agencies seek comment on whether the test weight bins should be changed
in order to allow for more realistic testing of HD pickups and vans and
better capture of the improvements due to mass reduction. Some example
changes could include reducing the five hundred pound interval between
bins to smaller intervals similar to those allowed for vehicles tested
below 5,500 lbs. test weight, or allowing any test weight value that is
not fixed to a particular test weight bin. The latter scenario would
still allow some grouping of vehicles to reduce test burden, and the
agencies also seek comment on how vehicles would be grouped and how the
test weight of this group of vehicles should be selected.
We further seek comment as to whether there may be a more
appropriate method such as allowing analytical adjustment of the
CO2 levels and fuel consumption within a vehicle weight
class to more precisely account for the individual vehicle models
performance. For example, could an equation like the one specified in
40 CFR 1037.104(g) for analytically adjusting CO2 emissions
be used (note that this is proposed to be redesignated as 40 CFR
86.1819-14(g)). The agencies are specifically considering an approach
in which vehicles are tested in the same way with the same test
weights, but manufacturers have the option to either accept the
emission results as provided under the current regulations, or choose
to adjust the emissions based on the actual test weight basis (actual
curb plus
[[Page 40342]]
half payload) instead of the equivalent test weight for the 500 test
weight interval. Should the agencies finalize this as an option,
manufacturers choosing to adjust their emissions would be required to
do so for all of their vehicles, and not just for those with test
weights below the midpoint of the range.
(3) Fleet Average Standards
NHTSA and EPA are proposing to retain 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. Each manufacturer would 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) 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 fleet average standard with which the manufacturer must comply
would continue to be based on its final production figures for the
model year, and thus a final assessment of compliance would occur after
production for the model year 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 would demonstrate a level of performance
for vehicles in the test group, and make a good faith demonstration
that its fleet, regrouped by unique vehicle configurations within each
model type, is expected to comply with its fleet average standard when
the model year is over. EPA 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. 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
is proposing to 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 is not proposing 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 would be subject to recall to correct the
noncompliance. NHTSA also proposes to adopt 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 seeks comment on the appropriateness of
seeking civil penalties for failure to comply with its fuel efficiency
standards in these instances. NHTSA would 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, EPA proposes that the in-use Phase 2 standards for
HD pickups and vans be established by adding an adjustment factor to
the full useful life emissions used to calculate the GHG fleet average.
EPA proposes that each model's in-use CO2 standard be the
model-specific level used in calculating the fleet average, plus 10
percent. No adverse comments were received on this provision during the
Phase 1 rulemaking. 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.
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.\333\ The new useful life
implemented for Tier 3 is 150,000 miles or 15 years, whichever occurs
first. EPA and NHTSA propose that the useful life for GHG emissions and
fuel consumption also be updated to 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.
With the relatively flat deterioration generally associated with
CO2 and fuel consumption and the proposed in-use standard
adjustment factor discussed above, the agencies do not believe the
proposed change in useful life would significantly affect the
feasibility of the proposed Phase 2 standards.\334\ The agencies
requests comments on the proposed change to useful life.
---------------------------------------------------------------------------
\333\ 79 FR 23492, April 28, 2014 and 40 CFR 86.1805-17.
\334\ As discussed below in Section VI.D.1., EPA and NHTSA are
proposing an adjustment factor of 1.25 for banked credits that are
carried over from Phase 1 to Phase 2. The useful life is factored
into the credits calculation and without the adjustment factor the
change in useful life would effectively result in a discount of
those carry-over credits.
---------------------------------------------------------------------------
(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 emissions 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
[[Page 40343]]
from current levels, i.e., a no-backsliding standard. EPA is not
proposing to change 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 1.25 g/mile
CO2, which is much less than 1 percent of the overall GHG
emissions of most HD pickups and vans.\335\ 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.
We note that we are not aware of any new technologies that would allow
us to adopt more stringent CH4 and N2O standards
at this time. The CH4 standard remains an important backstop
to prevent future increases in CH4 emissions.
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\335\ N2O has a GWP of 298 and CH4 has a
GWP of 25 according to the IPCC AR4.
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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, currently
being revaluated 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.
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 standards into CO2eq to determine
the amount of CO2 credits required. For example, a
manufacturer would use 25 Mg of positive CO2 credits to
offset 1 Mg of negative CH4 credits or use 298 Mg of
positive CO2 credits to offset 1 Mg of negative
N2O credits.\336\ 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. EPA proposes to maintain these provisions for Phase 2 as
they provide important flexibility without reducing the overall GHG
benefits of the program.
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\336\ N2O has a GWP of 298 and CH4 has a
GWP of 25 according to the IPCC AR4.
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EPA is requesting comment on updating GWPs used in the calculation
of credits discussed above. Please see the full discussion of this
issue and request for comments provided in Sections II.D and XI.D.
(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.\337\ 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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\337\ The U.S. EPA has reclamation requirements for refrigerants
in place under Title VI of the Clean Air Act.
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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.3, EPA is proposing to extend 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 Phase 1 preamble (76 FR 57194-57195)
for further discussion of the A/C leakage standard.
In addition to use of leak-tight components in air conditioning
system design, manufacturers could also decrease the global warming
impact of 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). The potential
use of alternative refrigerants in HD vehicles and EPA's proposed
revisions to 40 CFR 1037.115 so that use
[[Page 40344]]
of certain lower GWP refrigerants would cause an air conditioning
system in a HD vehicle to be deemed to comply with the low leakage
standard is discussed in Section I.F. above.
In addition to direct emissions from refrigerant leakage, air
conditioning systems also create indirect exhaust emissions due to the
extra load on the vehicle's engine to provide power to the air
conditioning system. These indirect emissions are in the form of the
additional CO2 emitted from the engine when A/C is being
used due to the added loads. Unlike direct emissions which tend to be a
set annual leak rate not directly tied to usage, indirect emissions are
fully a function of A/C usage. These indirect CO2 emissions
are associated with air conditioner efficiency, since (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. This continues to be the
case. For this reason, EPA is not proposing to establish standards for
A/C efficiency for Phase 2.
NHTSA and EPA request comments on all aspects of the proposed HD
pickup and van standards and program elements described in this
section.
C. Feasibility of Pickup and Van Standards
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.''
\338\ 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 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.
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\338\ 49 U.S.C. 32902(k)(2).
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As part of the feasibility analysis of potential standards for HD
pickups and vans, the agencies have applied DOT'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.\339\ The agencies used this model
to determine the range of stringencies that might be achievable through
the use of technology that is projected to be available in the Phase 2
time frame. From these runs, the agencies identified the stringency
level that would be technology-forcing (i.e. reflect levels of
stringency based on performance of merging as well as currently
available control technologies), but 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.
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\339\ The CAFE model has been under ongoing development,
application, review, and refinement since 2002. In five rulemakings
subject to public review and comment, DOT has used the model to
estimate the potential impacts of new CAFE standards. The model has
also been subject to formal review outside the rulemaking process,
and DOT anticipates comments on the model in mid-2015 as part of a
broader report under development by the National Academy of Sciences
(NAS). The model, underlying source code, inputs, and outputs are
available at NHTSA's Web site, and some outside organizations are
making use of the model. The agency anticipates that stakeholders
will have comments on recent model changes made to accommodate
standards for HD pickups and vans.
---------------------------------------------------------------------------
As noted in Section I and discussed further below, the analysis
considers two reference cases for HD pickups and vans, 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 whereas
EPA considered both reference cases. 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 would not lead to a different
conclusion regarding the appropriateness of the proposed standards. As
such, the use of different reference cases corroborates the results of
the overall analysis.
The proposed 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, 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
proposed program would afford manufacturers substantial flexibility to
satisfy the proposed 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.
We decided to propose a phased implementation schedule that would
be appropriate to accommodate manufacturers' redesign workload and
product schedules, especially in light of this sector's limited product
offerings \340\ and long product cycles. We did not estimate the cost
of implementing the proposed 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 proposing, 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
[[Page 40345]]
the opportunity to achieve meaningful and cost-effective early
reductions not requiring a major product redesign.
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\340\ Manufacturers generally have only one pickup platform and
one van platform in this segment.
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The agencies believe that Alternative 4 has the potential to be the
maximum feasible alternative, however, the agencies are uncertain that
the potential technologies and market penetration rates included in
Alternative 4 are currently technologically feasible. Alternative 4
would ultimately reach the same levels of stringency as Alternative 3,
but would do so with less lead time. This could require the application
of a somewhat different (and possibly broader) application of the
projected technologies depending on product redesign cycles. We expect,
in fact, that some of these technologies may well prove feasible and
cost-effective in this timeframe, and may even become technologies of
choice for individual manufacturers.
Additionally, Alternative 3 provides two more years of phase-in
than Alternative 4, which eases compliance burden by having more
vehicle redesigns and lower stringency during the phase-in period.
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,
overcompliance, credit carry-forward and carry-back, and redesigning
vehicles more frequently. Each of these will increase technology costs
to the manufacturers and vehicle purchasers, and early redesigns will
significantly increases capital costs and product development costs.
Also, the longer phase-in time for Alternative 3 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.
Alternative 4 is projected to be met using a significantly higher
degree of hybridization including the use of more strong hybrids,
compared to the proposed preferred Alternative 3. In order to comply
with a 3.5 percent per year increase in stringency over MYs 2021-2025,
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 Alternative 3 to achieve the
proposed final 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. Alternative 4
is also projected to result in higher costs and risks than the proposed
Alternative 3 due to the projected higher technology adoption rates
with the additional emission reductions and fuel savings predominately
occurring only during the program phase-in period. The agencies'
analysis is discussed in detail below.
In some cases, 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. The agencies believe it is
technologically feasible to apply hybridization to HD pickups and vans
in the lead time provided. However, strong hybrids present challenges
in this market segment compared to light-duty where there are several
strong hybrids already available. The agencies do 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, we believe that hybrid electric technology could provide
significant GHG and fuel consumption benefits, but we 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, the analysis does not project that engines would
be down-sized in conjunction with hybridization for HD pickups and vans
due to the importance pickup trucks buyers place on engine horsepower
and torque necessary to meet towing objectives. 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 facilitates much of a hybrid's benefit.
Due to these considerations, the agencies have conducted a
sensitivity analysis that is based on the use of no strong hybrids. The
results of the analysis are also discussed below. The analysis
indicates that there would be a technology pathway that would allow
manufacturers to meet both the proposed preferred Alternatives 3 and
Alternative 4 without the use of strong hybrids. However, the analysis
indicates that costs would be higher and the cost effectiveness would
be lower under the no strong hybrid approach, especially for
Alternative 4, which provides less lead time to manufacturers.
We also considered proposing less stringent standards under which
manufacturers could comply by deploying a more limited set of
technologies. However, our assessment concluded with a high degree of
confidence that the technologies on which the proposed standards are
premised would 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.
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 proposed standards. For the most part,
these technologies have not yet been applied to HD pickups and vans,
even on a limited basis. We are 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 \341\ 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
draft RIA provides a detailed description of the CAFE Model and the
analysis performed for the proposal.
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\341\ 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.
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(1) Regulatory Alternatives Considered by the Agencies
As discussed above, the agencies are proposing standards defined by
fuel consumption and GHG targets that continue through model year 2020
unchanged from model year 2018, and then increase in stringency at an
annual rate of 2.5 percent through model year 2027. In addition to this
regulatory alternative, the agencies also considered a no-action
alternative under which standards remain unchanged after model year
2018, as well as three other alternatives, defined by annual stringency
increases of 2.0 percent, 3.5 percent, and 4.0 percent during 2021-
2025. For each of the ``action alternatives'' (i.e., those involving
stringency increases beyond the no-
[[Page 40346]]
action alternative), the annual 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 Table VI-3.
Table VI-3 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
------------------------------------------------------------------------
(2) DOT CAFE Model
DOT developed the CAFE model in 2002 to support the 2003 issuance
of CAFE standards for MYs 2005-2007 light trucks. DOT 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.
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 these rules, the agencies conducted coordinated and
complementary analyses using 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 complementary
analyses, which we refer to as ``Method A'' and ``Method B''. In Method
A, 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 was used to project a pathway the industry could use to comply
with each regulatory alternative, along with resultant impacts on per
vehicle costs, and the MOVES model was used to calculate corresponding
changes in total fuel consumption and annual emissions. Additional
calculations were performed to determine corresponding 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 both methods. The agencies concluded that both methods led
the agencies to the same conclusions and the same selection of the
proposed standards. See Section VII for additional discussion of these
two methods.
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. The file used for this
analysis was created from 2014 manufacturer compliance reports for the
base sales and technology information, and a future fleet projection
created from a combination of data from a sales forecast that the
agencies purchased from IHS Automotive and total volumes class 2b and 3
fleet volumes from 2014 AEO Reference Case. A complete description of
the future fleet is available in Draft RIA Chapter 10.
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.
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
[[Page 40347]]
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 would help
toward compliance with specified standards or would 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.
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 predefined 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. Given the long redesign cycle
used in this analysis and the understanding with respect to where the
different manufacturers are in that cycle, the agencies have initially
determined that the full implementation of the proposed standards would
be feasible and appropriate by the 2027 model year.
This analysis reflects 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.
Inclusion of technologies not included in prior analyses.
Changes to enable more explicit accounting for shared
vehicle platforms and adoption and ``inheritance'' of major engine
changes.
Expansion of the Monte Carlo simulation procedures used to
perform probabilistic uncertainty analysis.
In addition to the inputs summarized above, the agencies' 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 HD segments are discussed below
in Section IX. Others more specific to the analysis of HD pickups and
vans are listed as follows, with additional details in section D:
Vehicle survival and mileage accumulation
VMT rebound
On-road ``gap'' in fuel consumption
Fleet population profile
Past fuel consumption levels
Long-term fuel consumption levels
Payback period
Coefficients for fatality calculations
Compliance credits carried-forward
Emission factors for non-CO2 emissions
Refueling time benefits
External Costs of travel
Ownership and operating costs
The CAFE model and its modifications for this rulemaking are
described in more detail in Section VI. below as well as the Draft RIA
Chapter 10.
(3) How Did the Agencies Develop the Analysis Fleet
In order to more accurately estimate the impacts of potential
standards, the agencies are estimating the composition of the future
vehicle fleet. Projections of the future vehicle fleet are also done
for both vocational vehicles and tractors. The procedure for pickups
and vans is more detailed, though, in order to show the differences for
each manufacturer in the segment. 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 fleet of Class 2b and 3 vehicles. This aspect of the analysis
fleet helps to keep the CAFE model from adding technologies to vehicles
that already have these technologies, which would 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 would exist in MYs 2019-
2030. The CAFE model considers the actual redesign years of each
vehicle platform for each manufacturer. Due to credit banking, some
manufacturers may not need to add technology to comply with the
standards until later model years, which may be after the rulemaking
period. Therefore, it is necessary to run the model until all of the
vehicle technology changes have stabilized.
Most of the information about the vehicles that make up the 2014
analysis fleet was gathered from the 2014 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. Updated data were provided by Chrysler and GM. 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
[[Page 40348]]
time because by now all MY2014 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, the agencies augmented this information
with publicly-available data that include more complete technology
descriptions, e.g. for specific engines and transmissions.
The analysis fleet also requires projections of sales volumes for
the years of the rulemaking analysis. The agencies relied on the MY
2014 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 MY 2014. For all future model years, we combine the
manufacturer submissions with sales projections from the 2014 Annual
Energy Outlook Reference Case and IHS Automotive to determine model
variant level sales volumes in future years.
For more detail on how the analysis fleet and sales volume
projections were developed, please see Section D below as well as the
draft RIA Chapter 10.
(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 proposed
action. However, we are considering and seek comment on advanced
technology credits to encourage the development of such technologies,
as discussed below in Section VI.E.
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 depends on several factors including initial
purchase price, fuel operating costs, durability, towing capability and
payload capacity amongst other reasons. As discussed in IV.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, we are proposing separate
standards for gasoline and diesel vehicles and in the context of our
technology discussion for heavy-duty pickups and vans, we are treating
gasoline and diesel engines separately so each has a set of baseline
technologies. We discuss performance improvements in terms of changes
to those baseline engines. Our cost and inventory estimates contained
elsewhere reflect the current fleet baseline with an appropriate mix of
gasoline and diesel engines. Note that we are not basing the proposed
standards on a targeted switch in the mix of diesel and gasoline
vehicles. We believe our proposed standards require similar levels of
technology development and cost for both diesel and gasoline vehicles.
Hence the proposed program is not intended to force, nor discourage,
changes in a manufacturer's fleet mix between gasoline and diesel
vehicles. Types of engine technologies that improve fuel efficiency and
reduce CO2 emissions include the following:
Low-friction lubricants--Low viscosity and advanced low
friction lubricant oils are now available with improved performance and
better lubrication. If manufacturers choose to make use of these
lubricants, they would need to make engine changes and possibly conduct
durability testing to accommodate the low-friction lubricants.
Reduction of engine friction losses--Can be achieved
through low-tension piston rings, roller cam followers, improved
material coatings, more optimal thermal management, piston surface
treatments, and other improvements in the design of engine components
and subsystems that improve engine operation.
Reduction of engine parasitic demand--Mechanical engine
load reduction can be achieved by variable-displacement oil pumps,
higher-efficiency direct injection fuel pumps, and variable speed/
displacement coolant pumps.
Cylinder deactivation--Deactivates the intake and exhaust
valves and prevents fuel injection into some cylinders during light-
load operation. The engine runs temporarily as though it were a smaller
engine which substantially reduces pumping losses.
Variable valve timing--Alters the timing of the intake
valve, exhaust valve, or both, primarily to reduce pumping losses,
increase specific power, and control residual gases.
Variable valve lift--Alters the intake valve lift in order
to reduce pumping losses and more efficiently ingest air.
Stoichiometric gasoline direct-injection technology--
Injects fuel at high pressure directly into the combustion chamber to
improve cooling of the air/fuel charge within the cylinder, which
allows for higher compression ratios and increased thermodynamic
efficiency.
Cooled exhaust gas recirculation--Technology that
conceptually involves utilizing EGR as a charge diluent for controlling
combustion temperatures and cooling the EGR prior to its introduction
to the combustion system.
Turbocharging and downsizing--Technology
approach that conceptually involves decreasing the displacement and
cylinder count to improve efficiency when not demanding regular high
loads and adding a turbocharger to recover any loss to the original
larger engine peak operating power. This technology was limited in this
analysis to vehicles that are not expected to operate at high trailer
towing levels and instead are more akin to duty cycles of light duty
(i.e. V6 vans).
Lean-burn combustion--Concept that gasoline
engines that are normally stoichiometric mainly for emission reasons
can run lean over a range of
[[Page 40349]]
operating conditions and utilize diesel like aftertreatment systems to
control NOX. For this analysis, we determined that the modal
operation nature of this technology to currently only be beneficial at
light loads would not be appropriate for a heavy duty application
purchased specifically for its high work and load capability.
Diesel engine improvements and diesel aftertreatment
improvements--Improved turbocharger, EGR systems, and advanced timing
can provide more efficient combustion and, hence, lower fuel
consumption. Aftertreatment systems are a relatively new technology on
diesel vehicles and, as such, improvements are expected in coming years
that allow the effectiveness of these systems to improve while reducing
the fuel and reductant demands of current systems.
Types of transmission technologies considered include:
Eight-speed automatic transmissions--The gear span, gear
ratios, and control system are optimized for a broader range of
efficient engine operating conditions.
High efficiency transmission--Significant reduction of
internal parasitic losses such as pumps gear bands, etc.
Driveline friction reduction--Reduction in the driveline
friction from improvements to bearings, seals and other machining
tolerances in the axles and transfer cases.
Secondary axle disconnect--Disconnecting of some rotating
components in the front axle on 4wd vehicles when the secondary axle is
not needed for traction.
Types of vehicle technologies considered include:
Low-rolling-resistance tires--Have characteristics that
reduce frictional losses associated with the energy dissipated in the
deformation of the tires under load, therefore improving fuel
efficiency and reducing CO2 emissions.
Aerodynamic drag reduction--is achieved by changing
vehicle shape or reducing frontal area, including skirts, air dams,
underbody covers, and more aerodynamic side view mirrors.
Mass reduction and material substitution--Mass reduction
encompasses a variety of techniques ranging from improved design and
better component integration to application of lighter and higher-
strength materials. Mass reduction is further compounded by reductions
in engine power and ancillary systems (transmission, steering, brakes,
suspension, etc.). The agencies recognize there is a range of diversity
and complexity for mass reduction and material substitution
technologies and there are many techniques that automotive suppliers
and manufacturers are using to achieve the levels of this technology
that the agencies have modeled in our analysis for this program.
Types of electrification/accessory and hybrid technologies
considered include:
Electric power steering--Are electrically-assisted
steering systems that have advantages over traditional hydraulic power
steering because it replaces a continuously operated hydraulic pump,
thereby reducing parasitic losses from the accessory drive.
Improved accessories--May include high efficiency
alternators, electrically driven (i.e., on-demand) water pumps and
cooling fans. This excludes other electrical accessories such as
electric oil pumps and electrically driven air conditioner compressors.
Mild hybrid--A small, engine-driven (through a belt or
other mechanism) electric motor/generator/battery combination to enable
features such as start-stop, energy recovery, and launch assist.
Strong hybrid--A powerful electric motor/generator/battery
system coupled to the powertrain to enable features such as start-stop,
and significant levels of launch assist, electric operation, and brake
energy recovery. For HD pickups and vans, the engine coupled with the
strong hybrid system would remain unchanged in power and torque to
ensure vehicle performance at all times, even if the hybrid battery is
depleted.
Air Conditioner Systems--These technologies include
improved hoses, connectors and seals for leakage control. They also
include improved compressors, expansion valves, heat exchangers and the
control of these components for the purposes of improving tailpipe
CO2 emissions as a result of A/C use.\342\
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\342\ See Draft RIA Chapter 2.3 for more detailed technology
descriptions.
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(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 proposal.
For costs, the agencies reconsidered both the direct (or ``piece'')
costs and indirect costs of individual components of technologies. For
the direct costs, the agencies followed a bill of materials (BOM)
approach employed by 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.\343\
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\343\ 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.
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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 (see Section IX.B.1.e of this
preamble), 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 2.12 of the Draft RIA.
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
[[Page 40350]]
lb. The adjustments were made on an individual technology basis by
assessing the specific impact of the added load on each technology when
compared to the use of the technology on a light-duty vehicle. The
agencies also considered other sources such as the 2010 NAS Report,
recent CAFE compliance data, and confidential manufacturer estimates of
technology effectiveness. 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 proposed 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 following contains a description of technologies the agencies
considered in the analysis for this proposal.
(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 would be required to ensure that durability
is not compromised. The shift to lower viscosity and lower friction
lubricants will also improve the effectiveness of valvetrain
technologies such as cylinder deactivation, which rely on a minimum oil
temperature (viscosity) for operation.
(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.\344\ 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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\344\ ``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).
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(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.\345\ For
overhead valve engines, which have only one camshaft to actuate both
inlet and exhaust valves, couple cam phasing is the only variable valve
timing implementation option available and requires only one cam
phaser.\346\
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\345\ 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.
\346\ 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
[[Page 40351]]
within the deactivated cylinders is simply compressed and expanded as
an air spring, with reduced friction and heat losses. The active
cylinders combust at almost double the load required if all of the
cylinders were operating. Pumping losses are significantly reduced as
long as the engine is operated in this ``part-cylinder'' mode.
Cylinder deactivation control strategy relies on setting maximum
manifold absolute pressures or predicted torque within a range in which
it can deactivate the cylinders. Noise and vibration issues reduce the
operating range to which cylinder deactivation is allowed, although
manufacturers are exploring vehicle changes that enable increasing the
amount of time that cylinder deactivation might be suitable. Some
manufacturers may choose to adopt active engine mounts and/or active
noise cancellations systems to address Noise Vibration and Harshness
(NVH) concerns and to allow a greater operating range of activation.
Cylinder deactivation has seen a recent resurgence thanks to better
valvetrain designs and engine controls. General Motors and Chrysler
Group have incorporated cylinder deactivation across a substantial
portion of their V8-powered lineups.
(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.
Several manufacturers have recently introduced vehicles with SGDI
engines, including GM and Ford and have announced their plans to
increase dramatically the number of SGDI engines in their portfolios.
(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 we 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
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.
(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
[[Page 40352]]
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 proposed rule, consistent with the proposal, would
use a dual-loop system with both high and low pressure EGR loops and
dual EGR coolers. The engines would 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.
(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.\347\ 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.
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\347\ 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.
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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 proposed 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 the proposal.
(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- and 8-speed automatics have entered
production.
(ii) High Efficiency Transmission
For this proposal, 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.
(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
[[Page 40353]]
carry heavy payloads, so larger vehicles with towing capacity present a
challenge, as these vehicles have high cooling fan loads.\348\ 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.
---------------------------------------------------------------------------
\348\ In the CAFE model, improved accessories refers solely to
improved engine cooling. However, EPA has included a high efficiency
alternator in this category, as well as improvements to the cooling
system.
---------------------------------------------------------------------------
The agencies considered whether to include electric oil pump
technology for the rulemaking. Because it is necessary to operate the
oil pump any time the engine is running, electric oil pump technology
has insignificant effect on efficiency. Therefore, the agencies decided
to not include electric oil pump technology.
(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 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.
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, 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,\349\ there are two key
strategies for primary mass reduction: (1) Changing the design to use
less material; (2) substituting lighter materials for heavier
materials.
---------------------------------------------------------------------------
\349\ 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 \350\ 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
[[Page 40354]]
often used in combination with applying new materials.
---------------------------------------------------------------------------
\350\ 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
unsprung 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.
Ford's MY 2015 F-150 is one example of a light duty manufacturer
who has begun producing high volume vehicles with a significant amount
of mass reduction identified, specifically 250 to 750 lb per vehicle
\351\. The vehicle is an aluminum intensive design and includes 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 \352\ states that state that the MY 2015 F-150 contains 1080 lbs
of aluminum with at least half of this being aluminum sheet and
extrusions for body and closures. Ford engine range for its light duty
truck fleet includes a 2.7L EcoBoost V-6. It is possible that the
strategy of aluminum body panels will be applied to the heavy duty F-
250 and F-350 versions when they are redesigned.\353\
---------------------------------------------------------------------------
\351\ ``2008/9 Blueprint for Sustainability,'' Ford Motor
Company. Available at: http://www.ford.com/go/sustainability (last
accessed February 8, 2010).
\352\ ``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).
\353\ http://www.foxnews.com/leisure/2014/09/30/ford-confirms-increased-aluminum-use-on-next-gen-super-duty-pickups/.
---------------------------------------------------------------------------
EPA recently 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.'' \354\ Results contain a cost curve for
various mass reduction percentages with the main solution being
evaluated for a 21.4 percent (511 kg/1124 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 511 kg, or 20 percent, were from secondary mass reduction.
Information on this study is summarized in SAE paper 2015-01-0559. DOT
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 by early 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.
---------------------------------------------------------------------------
\354\ ``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 also contracted with
FEV North America, Inc. to perform a scaling study in order to evaluate
the technologies identified for the light-duty truck would be
applicable for a heavy-duty pickup truck, in this study a Silverado
2500, a Mercedes Sprinter and a Renault Master. This report is
currently being drafted and will be peer reviewed and finalized between
the proposed rule and the final rule making. The specific results will
be presented in the final rulemaking (FRM) and may be used to update
assumptions of mass reduction for the FRM.
The RIA for this rulemaking shows that mass reduction is assumed to
be part of the strategy for compliance for HD pickups and vans. The
assumptions of mass reduction for HD pickups and vans as used in this
analysis were taken from the recent light-duty fuel economy/GHG
rulemaking for light-duty pickup trucks, though they may be updated for
the FRM based upon the on-going EPA and NHTSA lightweighting studies as
well as other information received in the interim. 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 would include: Increased tire inflation pressure,
material changes, and tire construction with less hysteresis, geometry
changes (e.g., reduced aspect ratios), and reduction in sidewall and
tread deflection. These changes would generally be accompanied with
[[Page 40355]]
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 would include
revised front and rear fascias, modified front air dams and rear
valances, addition of rear deck lips and underbody panels, and lower
aerodynamic drag exterior mirrors.
(6) What Are the Projected Technology Effectiveness Values and Costs
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.
To achieve the levels of the proposed standards for gasoline and
diesel powered heavy-duty vehicles, a combination of the technologies
previously discussed would 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 would be expected, the available test
data show that some vehicle models would not need the full complement
of available technologies to achieve the proposed standards.
Furthermore, many technologies can be further improved (e.g.,
aerodynamic improvements) from today's best levels, and so allow for
compliance without needing to apply a technology that a manufacturer
might deem less desirable.
Technology costs for HD 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 of the Draft 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 MY2021 (2012$)
------------------------------------------------------------------------
Technology Gasoline Diesel
------------------------------------------------------------------------
Engine changes to accommodate low friction $6 $6
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 diesel..... N/A 0
8s automatic transmission (increment to 6s 457 457
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 1)..... 51 51
Passive plus Active aerodynamic improvements 230 230
(aero2)......................................
Electric (or electro/hydraulic) power steering 151 151
Mass reduction (10% on a 6500 lb vehicle)..... 318 318
Driveline friction reduction.................. 139 139
Stop-start (no regenerative braking).......... 539 539
Mild HEV...................................... 2,730 2,730
Strong HEV without inclusion of any engine 6,779 6,779
changes......................................
------------------------------------------------------------------------
Note:
\a\ Cost to downsize from a V8 OHC to a V6 OHC engine with twin turbos.
As noted 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
[[Page 40356]]
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\
Technology FC savings (%) --------------------------------------
2021 2025 2027
----------------------------------------------------------------------------------------------------------------
Improved Lubricants and Engine Friction Reduction....... 1.60 24 24 23
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 \c\...................... 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\ 8 speed automatic transmission costs include costs for high efficiency gearbox and aggressive shift logic
whereas those costs were kept separate in prior analyses.
(7) Summary of Alternatives Analysis
The major outputs of the CAFE model analysis are summarized in
Table VI-6 and Table VI-7 below for the flat and dynamic baselines,
respectively. For a more detailed analysis of the alternatives, please
refer to Section D below as well as the draft RIA.
Table VI-6--Summary of HD Pickup and Van Alternatives' Analysis--Method A Using the Flat Baseline \a\
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Standard 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........................................ 19.05 20.58 20.58 21.14
Achieved........................................ 19.12 20.58 20.83 21.32
----------------------------------------------------------------------------------------------------------------
[[Page 40357]]
Average Fuel Consumption (gallons/100 mi.)
----------------------------------------------------------------------------------------------------------------
Required........................................ 5.25 4.86 4.86 4.73
Achieved........................................ 5.23 4.86 4.80 4.69
----------------------------------------------------------------------------------------------------------------
Average Greenhouse Gas Emissions (g/mi)
----------------------------------------------------------------------------------------------------------------
Required........................................ 495 458 458 446
Achieved........................................ 493 458 453 442
----------------------------------------------------------------------------------------------------------------
Incremental Technology Cost (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Average ($/vehicle) \b\......................... 700 1,324 1,804 2,135
Payback period (m) \b\.......................... 24 26 34 36
Total ($m).................................. 529 1,001 1,363 1,614
----------------------------------------------------------------------------------------------------------------
Benefit-Cost Summary, MYs 2021-2030 ($billion) \c\
----------------------------------------------------------------------------------------------------------------
Fuel Savings (bil. gal.)........................ 6.1 10.1 11.9 13.3
CO2 Reduction (mmt)............................. 73 118 139 155
Total Social Cost........................... 3.3 5.6 8.7 10.2
Total Social Benefit........................ 18.4 29.0 34.4 37.9
Net Social Benefit.......................... 15.1 23.4 25.7 27.7
----------------------------------------------------------------------------------------------------------------
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\ Values also used in Method B.
\c\ At a 3% discount rate.
Table VI-7--Summary of HD Pickup and Van Alternatives' Analysis--Method A Using the Dynamic Baseline \a\
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Standard 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
----------------------------------------------------------------------------------------------------------------
Incremental Technology Cost (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Average ($/vehicle) \b\......................... 578 1,348 1,655 2,080
Payback period (m) \b\.......................... 25 31 34 38
Total ($m).................................. 437 1,019 1,251 1,572
----------------------------------------------------------------------------------------------------------------
Benefit-Cost Summary, MYs 2021-2030 ($billion) \c\
----------------------------------------------------------------------------------------------------------------
Fuel Savings (bil. gal.)........................ 5.0 8.9 10.5 11.9
CO2 Reduction (mmt)............................. 59 104 122 139
Total Social Cost........................... 3.3 6.8 9.5 13.0
Total Social Benefit........................ 14.3 23.6 28.2 32.8
Net Social Benefit.......................... 11.0 16.8 18.7 19.8
----------------------------------------------------------------------------------------------------------------
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\ Values also used in Method B.
\c\ At a 3% discount rate.
[[Page 40358]]
In general, the proposed standards are projected to cause
manufacturers to produce HD pickups and vans that are lighter, more
aerodynamic, and more technologically complex across all the
alternatives, while social benefits continue to increase across all
alternatives. As shown, there is a major difference between the
relatively small improvements in required fuel consumption 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 dependence of the challenge and on the stringency).
Despite the fact that the required average fuel consumption level only
changes by 3 percent between Alternative 4 and Alternative 5, average
technology cost increases by more than 25 percent.
Note further that the difference in estimated costs, effectiveness,
degree of technology penetration required, and overall benefits do not
vary significantly under either the flat or dynamic baseline
assumptions. The agencies view these results as corroborative of the
basic reasonableness of the approach proposed.
(8) Consistency of the Proposed Standards With the Agencies' Respective
Legal Authorities
Based on the information currently before the agencies, we believe
that Alternative 3 would be maximum feasible and appropriate for this
segment for the model years in question. EPA believes this reflects 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). NHTSA believes this proposal is
maximum feasible under EISA. The agencies have projected a compliance
path for the proposed standards showing aggressive implementation of
technologies that the agencies consider to be available in the time
frame of these rules. 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 proposal also is premised on less aggressive
penetration of particular advanced technologies, including strong
hybrid electric vehicles.
We project the proposed standards to be achievable within known
design cycles, and we believe these standards would allow different
paths to compliance in addition to the one we outline and cost here. As
discussed below and throughout this analysis, our proposal places a
higher value on maintaining functionality and capability of vehicles
designed for work (versus light-duty), and on the assurance of in use
reliability and market acceptance of new technology, particularly in
initial model years of the program. Nevertheless, it may be possible to
have additional adoption rates of the technologies than we project so
that further reductions could be available at reasonable cost and cost-
effectiveness.
Alternative 4 is also discussed in detail below because the
agencies believe it has the potential to be the maximum feasible
alternative, and otherwise appropriate. The agencies could decide to
adopt Alternative 4, in whole or in part, in the final rule. In
particular, the agencies believe Alternative 4, which would achieve the
same stringency as the proposed standards with two years less lead
time, merits serious consideration. However, the agencies are uncertain
whether the projected technologies and market penetration rates that
could be necessary to meet the stringencies would be practicable within
the lead time provided in Alternative 4. The proposed standards are
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 and with greater
flexibility. The agencies seek comment on these alternatives, including
their corresponding lead times.
Alternative 4 is based on a year-over-year increase in stringency
of 3.5 percent in MYs 2021-2025 whereas the proposed preferred
Alternative 3 is based on a 2.5 percent year-over-year increase in
stringency in MY 2021-2027. The agencies project 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 Alternative 3. Alternative 3 would 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 the agencies' primary analysis that includes the use
of strong hybrids manufacturers are estimated to deploy strong hybrids
in approximately 8 percent of new vehicles (in MY2027) under
Alternative 3, 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 MY2027 under Alternative 4,
but are not necessary under Alternative 3. 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. While the 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 take less cost-effective means to comply with the
standards compared with the proposed alternative 3 phase-in period of
MY 2021-2027. For example, the model predicts that some manufacturers
would not implement any amount of strong hybrids on their vans during
the 2021-2025 timeframe and instead would implement less effective
technologies such as mild hybrids at higher rates than what would
otherwise have been required if they had implemented a small percentage
of strong hybrids. Whereas for Alternative 3, the longer, shallower
phase-in of the standards 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.
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 would be a real possibility that a manufacturer who followed the
exact technology path we project would not meet their target because a
technology performed slightly differently in their application. NHTSA
has explored this uncertainty, among others, in the uncertainty
analysis described in Section D below.
As discussed above, the proposed Alternative 3 standards and the
Alternative 4 standards are based on the application of the
technologies described in this section. These technologies are
projected to be available within the lead time provided under
Alternative 3--i.e., by MY 2027,
[[Page 40359]]
as discussed in Draft RIA Chapter 2.6. The proposed standards and
Alternative 4 would require a relatively aggressive implementation
schedule of most of these technologies during the program phase-in.
Heavy-duty pickups and vans would need to have a combination of many
individual technologies to achieve the proposed standards. The proposed
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 \355\ and have questionable customer acceptance in a large
portion of this segment dedicated to towing.\356\
---------------------------------------------------------------------------
\355\ 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.
\356\ 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.
---------------------------------------------------------------------------
Table VI-8 below shows that the agencies' analysis estimates that
the most cost-effective way to meet the requirements of Alternative 3
would be to use strong hybrids in up to 9.9 percent of pickups and 5.5
percent of vans on an industry-wide basis whereas Alternative 4 shows
strong hybrids on up to 19 percent of pickups. The analysis shows that
the two years of additional lead time provided by the proposed
Alternative 3 would provide manufacturers with a better opportunity to
maximize the use of more cost effective technologies over time thereby
reducing the need for strong hybrids which may be particularly
challenging for this market segment. The agencies seek comment on the
potential use of technologies in response to Alternatives 3 and 4, as
well as the corresponding lead times proposed in each alternative.
Table VI-8--CAFE Model Technology Adoption Rates for Proposal and Alternative 4 Summary--Flat Baseline
----------------------------------------------------------------------------------------------------------------
Proposal (2.5% per year) 2021 to Alternative 4 (3.5% per year) 2021
2027 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, the agencies also conducted a sensitivity
analysis to determine a compliance pathway where no strong hybrids
would be selected. Although the agencies project that strong hybrids
may be the most cost effective approach, manufacturers may select
another compliance path. This no strong hybrid analysis included the
use of downsized turbocharged engine 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 the agencies 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, the agencies
believe it would be feasible for vans in the time-frame of these
proposed rules. Table VI-9 below reflects the difference in penetration
rates of technologies for the proposal and Alternative 4 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. While strong hybridization may provide the most cost
effective path for a manufacturer to comply with the Proposal or
Alternative 4, there are other means to comply with the requirements,
mainly a 20 percent penetration rate of mild hybrids for the Proposal
or a 66 percent penetration of mild hybrids for Alternative 4. The
modeling of both alternatives predicts a 1 to 4 percent penetration of
stop/start engine systems.
The table also shows that when strong hybrids are used as a pathway
to compliance, penetration rates of all hybrid technologies increase
substantially between the proposal 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 proposal. Also, by having the final standards apply in MY2027
instead of MY2025, the proposal is not premised on use of any mild
hybrids or stop/start engine systems to achieve the same level of
stringency as Alternative 4.
[[Page 40360]]
Table VI-9--CAFE Model Technology Adoption Rates for Proposal and Alternative 4 Combined Fleet and Fuels
Summary--Flat Baseline
----------------------------------------------------------------------------------------------------------------
Proposal (2.5% per year) 2021 to Alternative 4 (3.5% per year)
2027 2021 to 2025
Technology ------------------------------------------------------------------------
With strong Without strong With strong Without 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
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 Proposal and the Alternative 4 to provide a compliance path.
Table VI-10 and Table VI-11 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 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. The technology adoption rates projected for gasoline
pickups and gasoline vans due to the proposed Alternative 3 and
Alternative 4 are shown in Table VI-10 and Table VI-11, respectively.
Table VI-10--CAFE Model Technology Adoption Rates for Proposal and Alternative 4 on Gasoline Pickup Trucks--Flat
Baseline
----------------------------------------------------------------------------------------------------------------
Proposal (2.5% per year) 2021 to 2027 Alternative 4 (3.5% per year) 2021 to
----------------------------------------- 2025
Technology ---------------------------------------
With strong hybrids Without strong With strong hybrids Without strong
(%) 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.................... Up to 42 \a\........ 0% 18-86 \a\........... 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.
[[Page 40361]]
Table VI-11--CAFE Model Technology Adoption Rates for Proposal and Alternative 4 on Gasoline Vans--Flat Baseline
----------------------------------------------------------------------------------------------------------------
Proposal (2.5% per year) 2021 to 2027 Alternative 4 (3.5% per year) 2021
------------------------------------------- to 2025
Technology -----------------------------------
With strong hybrids (%) Without strong With strong Without strong
hybrids (%) hybrids (%) hybrids (%)
----------------------------------------------------------------------------------------------------------------
Low friction lubricants.......... 100.................... 100 100 100
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...................... Up to 13 \b\........... 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 Proposal 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.
The tables above show that many technologies would 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 would be needed. The additional lead time provided
by the proposed Alternative 3 reduces these concerns because
manufacturers would have more flexibility to implement their compliance
strategy and are more likely to contain a product redesign cycle
necessary for many new technologies to be implemented.
GM may have a particular challenge meeting new standards compared
to other manufacturers because their production consists of a larger
portion of gasoline-powered vehicles and because they continue to offer
a traditional style HD van equipped only with a V-8 engine. Under the
strong hybrid analysis for Alternative 3, GM is projected to apply
strong hybrids to 46 percent of their HD gasoline pickups and 17
percent their HD gasoline vans. Under Alternative 4, GM is projected to
apply a combination of 53 percent strong and 43 percent mild hybrids to
their HD gasoline pickups and 44 percent mild hybrids to their HD vans.
The no strong hybrid analysis shows that GM could comply without strong
hybrids based on the use of turbo downsizing on all of their HD
gasoline vans to fully comply with either Alternative 3 or Alternative
4. As modeled, Alternative 4 would also require GM to additionally
utilize several other technologies such as higher penetration of mild
hybridization. If GM were to choose to maintain a V-8 version of their
current HD van and not fully utilize turbo downsizing, another
compliance path such as some use of strong hybrids would be needed.
This would also be the case if GM chose not to fully utilize some other
technologies under Alterative 4 as well.
In addition to the possibility of an increased level of
hybridization, the agencies are also requesting comment on other
possible outcomes associated especially with Alternative 4; in
particular, the possibility of traditional van designs or other
products being discontinued. Several manufacturers now offer or are
moving to European style HD vans. Ford, for example, has discontinued
its E-series body on frame HD van and has replaced it with the unibody
Transit van for MY 2015. While other manufacturers have replaced their
traditional style vans with new European style van designs, GM
continues to offer the traditional full frame style van with eight
cylinder gasoline engines for higher towing capability (up to 16,000 lb
GCWR). Typically, the European style vans are equipped with smaller
engines offering better fuel consumption and lower CO2
emissions but with reduced towing capability, similar to light-duty
trucks (though Ford offers a Transit van with a GCWR of 15,000 lb).
The agencies request comment on the potential for Alternative 4 in
particular to incentivize GM to discontinue its current traditional
style van and replace it with an as yet to be designed European style
van similar to its competitor's products. See Bluewater Network v. EPA,
370 F. 3d 1, 22 (D.C. Cir. 2004) (standard implementing technology-
forcing provision of CAA remanded to EPA for an explanation of why the
standard was not based on discontinuation of a particular model);
International Harvester v. Ruckelshaus, 478 F. 2d 615, 640-41 (D.C.
Cir. 1973) (``We are inclined to agree with the Administrator that as
long as feasible technology permits the demand for new passenger
automobiles to be generally met, the basic requirements of the Act
would be satisfied, even though this might occasion fewer models and a
more limited choice of engine types''). Such an outcome could limit
consumer choice both on the style of van available in the marketplace
and on the range of capabilities of the vehicles available. The
agencies have not attempted to cost out this possible compliance path.
The agencies request comments on the likelihood of this type of
redesign as a possible outcome of Alternative 3 and Alternative 4, and
whether it would be appropriate. We are especially interested in
comments on the potential
[[Page 40362]]
impact on consumer choice and the costs associated with this type of
wholesale vehicle model replacement.
In addition, another potential outcome of Alternative 4 would be
that manufacturers could change the product utility. For example,
although GM's traditional van discussed above currently offers similar
towing capacity as gasoline pickups, GM could choose to replace engines
designed for those towing capacities with small gas or diesel engines.
The agencies request comment on the potential for Alternative 4 to lead
to this type of compliance approach.
The agencies also request comment on the possibility that
Alternative 4 could lead to increased dieselization of the HD pickup
and van fleet. Dieselization is not a technology path the agencies
included in the analysis for the Phase 1 rule or the Phase 2 proposal
but it is something the agencies could consider as a technology path
under Alternative 4. As discussed earlier, diesel engines are
fundamentally more efficient than gasoline engines providing the same
power (even gasoline engines with the technologies discussed above).
Alternative 4 could result in manufacturers switching from gasoline
engines to diesel engines in certain challenging segments. However,
while technologically feasible, this pathway could cause a distortion
in consumer choices and significantly increase the cost of those
vehicles, particularly considering Alternative 4 is projected to
require penetration of some form of hybridization. Also, if
dieselization occurs by manufacturers equipping vehicles with larger
diesel engines 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.
The issue of surplus towing capability is also discussed above in VI.B.
(1).
The technologies associated with meeting the proposed standards are
estimated to add costs to heavy-duty pickups and vans as shown in Table
VI-12 and Table VI-13 for the flat baseline and dynamic baseline,
respectively. These costs are the average fleet-wide incremental
vehicle costs relative to a vehicle meeting the MY2018 standard in each
of the model years shown. Reductions associated with these costs and
technologies are considerable, estimated at a 13.6 percent reduction of
fuel consumption and CO2eq emissions from the MY 2018
baseline for gasoline and diesel engine equipped vehicles.\357\ A
detailed cost and cost effectiveness analysis for both the proposed
preferred Alternative 3 are provided in Section IX and Chapter 7.1 of
the draft RIA. As shown by the analysis, the long-term cost
effectiveness of the proposal is similar to that of the Phase 1 HD
pickup and van standards and also falls within the range of the cost
effectiveness for Phase 2 standards proposed for the other HD
sectors.\358\ The cost of controls would 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.L of
this preamble. Consistent with the agencies' respective statutory
authorities under 42 U.S.C. 7521(a) and 49 U.S.C. 32902(k)(2), and
based on the agencies' analysis, EPA and NHTSA are proposing
Alternative 3. The agencies seek comment on Alternative 4, as we may
seek to adopt it in whole or in part in the final rule.
---------------------------------------------------------------------------
\357\ See Table VI-5.
\358\ Analysis using the MOVES model indicates that the cost
effectiveness of these standards is $95 per ton CO2 eq
removed in MY 2030 (Draft RIA Table 7-31), almost identical to the
$90 per ton CO2 eq removed (MY 2030) which the agencies
found to be highly cost effective for these same vehicles in Phase
1. See 76 FR 57228.
---------------------------------------------------------------------------
We also show the costs for the potential Alternative 4 standards in
Table VI-14 and Table VI-15. As shown, the costs under Alternative 4
would be significantly higher compared to Alternative 3.
Table VI-12--HD Pickups and Vans Incremental Technology Costs per Vehicle Preferred Alternative vs. Flat Baseline
[2012$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021 2022 2023 2024 2025 2026 2027
--------------------------------------------------------------------------------------------------------------------------------------------------------
HD Pickups & Vans....................... $516 $508 $791 $948 $1,161 $1,224 $1,342
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VI-13--HD Pickups and Vans Incremental Technology Costs per Vehicle Preferred Alternative vs. Dynamic Baseline
[2012$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021 2022 2023 2024 2025 2026 2027
--------------------------------------------------------------------------------------------------------------------------------------------------------
HD Pickups & Vans....................... $493 $485 $766 $896 $1,149 $1,248 $1,366
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VI-14--HD Pickups and Vans Incremental Technology Costs per Vehicle Alternative 4 vs. Flat Baseline
[2012$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021 2022 2023 2024 2025 2026 2027
--------------------------------------------------------------------------------------------------------------------------------------------------------
HD Pickups & Vans....................... $1,050 $1,033 $1,621 $1,734 $1,825 $1,808 $1,841
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 40363]]
Table VI-15--HD Pickups and Vans Incremental Technology Costs per Vehicle Alternative 4 vs. Dynamic Baseline
[2012$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021 2022 2023 2024 2025 2026 2027
--------------------------------------------------------------------------------------------------------------------------------------------------------
HD Pickups & Vans....................... $909 $894 $1,415 $1,532 $1,627 $1,649 $1,684
--------------------------------------------------------------------------------------------------------------------------------------------------------
D. DOT CAFE Model Analysis of the Regulatory Alternatives for HD
Pickups and Vans
Considering the establishment of potential HD pickup and van fuel
consumption and GHG standards to follow those already in place through
model year 2018, the agencies evaluated a range of potential regulatory
alternatives. The agencies estimated the extent to which manufacturers
might add fuel-saving and CO2-avoiding technologies under
each regulatory alternative, including the no-action alternative
described in Section X. of this proposal. For HD pickups and vans both
agencies analyzed two no-action alternatives, where one no-action
alternative could be described as a ``flat baseline'' and the other as
a ``dynamic baseline''. Please refer to Section X. of this proposal for
a complete discussion of the assumptions that underlie these baselines.
The agencies then estimated the extent to which additional technology
that would be implemented to meet each regulatory alternative would
incrementally (compared to the no-action alternative) impact costs to
manufacturers and vehicle buyers, physical outcomes such as highway
travel, fuel consumption, and greenhouse gas emissions, and economic
benefits and costs to vehicle owners and society. The remainder of this
section and portions of Sections VII through X present the regulatory
alternatives the agencies have considered, summarize the agencies'
analyses, and explain the agencies' selection of the HD pickup and van
preferred alternative defined by today's proposed standards.
The agencies conducted coordinated and complementary analyses by
employing both DOT's CAFE model and EPA's MOVES model and other
analytical tools to project fuel consumption and GHG emissions impacts
resulting from the proposed standards for HD pickups and vans, against
both the flat and dynamic baselines. In addition to running the DOT
CAFE model to provide per vehicle cost and technology values, NHTSA
also used the model to estimate the full range of impacts for pickups
and vans, including fuel consumption and GHG emissions, including
downstream vehicular emissions as well as emissions from upstream
processes related to fuel production, distribution, and delivery. The
CAFE model applies fuel properties (density and carbon content) to
estimated fuel consumption in order to calculate vehicular
CO2 emissions, applies per-mile emission factors (in this
analysis, from MOVES) to estimated VMT 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 (in this analysis, from GREET) in order to calculate upstream
GHG (and non-GHG) emissions. EPA also 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 proposed standards for HD pickup trucks and vans. The
agencies note that these two independent analyses of aggregate costs
and benefits both support the proposed standards.
While both agencies fully analyzed the regulatory alternatives
against both baselines, 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. On the other hand, EPA considered both baselines and EPA's
less dynamic or flat baseline analysis is presented in Sections VII
through X of this proposal as well as the draft Regulatory Impact
Analysis accompanying this proposal. In Section X both the flat and
dynamic baseline analyses are presented for all of the regulatory
alternatives.
This section provides a discussion of the CAFE model, followed by
the comprehensive results of the CAFE model against the dynamic
baseline to show costs, benefits, and environmental impacts of the
regulatory alternatives for HD pickups and vans. This presentation of
regulatory analysis is consistent with NHTSA's presentation of similar
analyses conducted in support of the agencies joint light-duty vehicle
fuel economy and GHG regulations. The CAFE analysis against the flat
baseline as well as EPA's complementary analysis of GHG impacts, non-
GHG impacts, and economic and other impacts using MOVES is presented in
Sections VII through IX of this proposal, as well as in the draft
Regulatory Impact Analysis accompanying this proposal. These are
presented side-by-side with the agencies' joint analyses of the other
heavy-duty sectors (i.e., tractors, trailers, vocational vehicles). The
presentation of the EPA analyses of HD pickups and vans in these
sections is consistent with the agencies' presentation of similar
analyses conducted as part of the agencies' joint HD Phase 1
regulations and with EPA's presentation of similar analyses conducted
in support of the agencies' joint light-duty vehicle fuel economy and
GHG regulations. The agencies' intention for presenting both of these
complementary and coordinated analyses is to offer interested readers
the opportunity to compare the regulatory alternatives considered for
Phase 2 in both the context of our Phase 1 analytical approaches and
our light-duty vehicle analytical approaches.
(1) Evaluation of Regulatory Alternatives
As discussed in Section C above, the agencies used DOT's CAFE model
to conduct an analysis of potential standards for HD pickups and vans.
The basic operation of the CAFE model was described in section VI.C.2,
so will not be repeated here. However, this section provides additional
detail on the model operation, inputs, assumptions, and outputs.
DOT developed the CAFE model in 2002 to support the 2003 issuance
of CAFE standards for MYs 2005-2007 light trucks. DOT has since
significantly expanded and refined the model, and has applied the model
to support every ensuing CAFE rulemaking;
2006: MYs 2008-2011 light trucks
[[Page 40364]]
2008: MYs 2011-2015 passenger cars and light trucks (final
rule prepared but withheld)
2009: MY 2011 passenger cars and light trucks
2010: MYs 2012-2016 passenger cars and light trucks (joint
rulemaking with EPA)
2012: MYs 2017-2021 passenger cars and light trucks (joint
rulemaking with EPA)
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 would compromise
confidential business information (CBI) manufacturers have provided to
NHTSA--all model inputs and outputs underlying published rulemaking
analyses.
This analysis reflects 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, related 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:
Expansion and restructuring of model inputs, compliance
calculations, and reporting 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.
Expansion of the Monte Carlo simulation procedures used to
perform probabilistic uncertainty analysis.
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. DOT invites comment on the updated
model, and in particular, on the updated handling of shared vehicle
platforms, engines, and transmissions, and on the new procedures to
estimate changes to test weight, GVWR, and GCWR as vehicle curb weight
is reduced.
(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 DOT 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, DOT 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. DOT 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 request comment on the
suitability of this viewpoint, and 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
[[Page 40365]]
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, and the agency requests 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.
While today's analysis examines the HD pickup and van fleet in
isolation, as a basis for analysis supporting the planned final rule,
the agencies intend to develop an overall analysis fleet spanning both
the light-duty and HD pickup and van fleets. Doing so could show some
technology ``spilling over'' to HD pickups and vans due, for example,
to the application of technology in response to current light-duty
standards. More generally, modeling the two fleets together should tend
to more realistically limit the scope and complexity of estimated
compliance pathways.
The agencies anticipate that the impact of modeling a combined
fleet will primarily arise from engine-transmission inheritance. While
platform sharing between the light-duty and MD pickup and van fleets is
relatively small (MDPVs aside), there are a number of instances of
engine and transmission sharing across the two fleets. When the fleets
are modeled together, the agencies anticipate that engine inheritance
will be implemented across the combined fleet, and therefore only one
engine-transmission leader can be defined across the combined fleet. As
with the fleets separately, all vehicles using a shared engine/
transmission would automatically adopt technologies adopted by the
engine-transmission leader.
The agencies request comment on plans to analyze the light-duty and
MD pickup and van fleets jointly in support of planning for the final
rule.
(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,
[[Page 40366]]
inputs for today's analysis de-emphasize reliance on phase-in caps.
In this 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
timeframe of this rulemaking, so decided to reject any model runs where
they were selected. Due to the cost ineffectiveness of this technology,
it was never chosen. The agencies request comment on the
appropriateness of these phase-in caps as proxies for constraints that,
though not monetized by the agencies, nonetheless limit rates at which
these two technologies can practicably be deployed, and on the
appropriateness of setting inputs to stop applying phase-in caps to
other technologies in this analysis. Comments on this issue should
provide information supporting any alternative recommended inputs.
(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.
4,000 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] TP13JY15.011
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, and the agencies invite comment on
the extent to which these changes to account explicitly for changes in
TW are likely to produce more realistic estimates of the compliance
impacts of reductions in vehicle mass.
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.
[[Page 40367]]
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):
Table VI-16--Ratios for Modifying GVW and GCW as a Function of Mass
Reduction
------------------------------------------------------------------------
Group Maximum ratios assumed enabled by
----------------------------------- mass reduction
-------------------------------------
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, DOT 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 would 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 invite comment on these methods for estimating how
changes in vehicle mass may impact fuel consumption, GVWR, and GCWR,
and on corresponding inputs to today's analysis.
(2) Development of the Analysis Fleet
As discussed above, both agencies used DOT's CAFE modeling system
to estimate technology costs and application rates under each
regulatory alternative, including the no action alternative (which
reflects continuation of previously-promulgated standards). Impacts
under each of the ``action'' alternatives are calculated on an
incremental basis relative to impacts under the no action alternative.
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 would 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 would 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.
The resultant analysis fleet is provided in detail at NHTSA's Web
site, along with all other inputs to and outputs from today's analysis.
The agencies invite comment on this analysis fleet and, in particular,
on any other information that should be reflected in an analysis fleet
used to update the agencies' analysis for the final rule. Also, the
agencies also invites comment on the potential expansion of this
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.
(a) Data Sources
Most of the information about the vehicles that make up the 2014
analysis fleet was gathered from the 2014 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. Updated data were provided by Chrysler and GM.
These updated data were used 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
MY2014 vehicle models have been produced, which makes data about them
essentially public information.
These data (by individual vehicle configuration produced in MY2014)
include: Projected Production Volume/MY2014 Sales, Drive Type, Axle
Ratio, Work Factor, Curb Weight, Test Weight,\359\ GVWR, GCWR, Fuel
Consumption (gal/100 mile), engine type (gasoline or diesel), engine
displacement, transmission type and number of gears.
---------------------------------------------------------------------------
\359\ Chrysler and GM did not provide test weights in their
submittals. Test weights were calculated as the average of GVWR and
curb weight rounded up to the nearest 100 lb.
---------------------------------------------------------------------------
The column ``Engine'' of the Pre-Model Year report for each OEM was
copied to the column ``Engine Code'' of the vehicle sheet of the CAFE
model market data input file. Values of ``Engine'' were changed to
Engine Codes for use in the CAFE model. The codes indicated on the
vehicle sheet map the detailed engine data on the engine sheet to the
appropriate vehicle on the vehicle sheet of the CAFE model input file.
The column ``Trans Class'' of the Pre-Model Year report for each
OEM was copied to the column ``Transmission Code'' of the vehicle sheet
of the market data input file. Values of ``Trans Class'' were changed
to Transmission Codes for use in the CAFE model. The codes indicated on
the vehicle sheet map the detailed transmission data on the
transmission sheet to the appropriate vehicle on the vehicle sheet of
the CAFE model input file.
In addition to information about each vehicle, the agencies need
additional
[[Page 40368]]
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. Thus, the agencies augmented this information with
publicly-available data that includes more complete technology
descriptions. Specific engines and transmissions associated with each
manufacturer's trucks were identified using their respective internet
sites. Detailed technical data on individual engines and transmissions
indicated on the engine sheet and transmission sheet of the CAFE model
input file were then obtained from manufacturer internet sites, spec
sheets and product literature, Ward's Automotive Group and other
commercial internet sites such as cars.com, edmunds.com, and
motortrend.com. Specific additional information included:
``Fuel Economy on Secondary Fuel'' was calculated as E85 =
.74 gasoline fuel economy, or B20 = .98 diesel fuel economy. These
values were duplicated in the columns ``Fuel Economy (Ethanol-85)'' and
``Fuel Economy (Biodiesel-20)'' of the CAFE market data input file.
Values in the columns ``Fuel Share (Gasoline)'', ``Fuel
Share (Ethanol-85)'', ``Fuel Share (Diesel),'' and ``Fuel Share
(Biodiesel-20)'' are Volpe assumptions.
The CAFE model also requires that values of Origin,
Regulatory Class, Technology Class, Safety Class, and Seating (Max) be
present in the file in order for the model to run. Placeholder values
were added in these columns.
In addition to the data taken from the OEM Pre Model Year
submittals, NHTSA added additional data for use by the CAFE model.
These included Platform, Refresh Years, Redesign Years, MSRP, Style,
Structure and Fuel Capacity.
MSRP was obtained from web2carz.com and the OEM Web sites.
Fuel capacity was obtained from OEM spec sheets and
product literature.
The Structure values (Ladder, Unibody) used by the CAFE
model were added. These were determined from OEM product literature and
the automotive press. It should be noted that the new vans such as the
Transit in fact utilize a ladder/unibody structure. Ford product
literature uses the term ``Uniladder'' to describe the structure. Vans
based on this structure are noted in the Vehicle Notes column of the
NHTSA input file.
Style values used by the CAFE model were also added:
Chassis Cab, Cutaway, Pickup and Van.
(b) 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 agencies request comment on the
anticipated future use of redesign cycles in this product segment.
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 Model Year used in this analysis represents 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
request comment on this anticipated product design cycle.
Additional detail on product cadence assumptions for specific
manufacturers is located in Chapter 10 of the draft RIA.
(c) 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.
For today's analysis, the agencies relied on the MY 2014 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 MY 2014. For all future
model years, we combine the manufacturer submissions with sales
projections from the 2014 Annual Energy Outlook Reference Case and IHS
Automotive to determine model variant level sales volumes in future
years.\360\ The projected sales volumes by class that appear in the
2014 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 draft RIA.
---------------------------------------------------------------------------
\360\ 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).
---------------------------------------------------------------------------
For this analysis, the agencies have limited this analysis fleet to
class 2b and 3 HD pickups and vans. However, especially considering
interactions between the light-duty and HD pickup and van fleets (e.g.,
MDPVs being included in the light-duty fleet), the agencies are
evaluating the potential to analyze the fleets in an integrated fashion
for the final rule, and invite comment on the extent to which doing so
could provide more realistic estimates of the incremental impacts of
new standards applicable HD pickups and vans.
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.
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.
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-17 shows the implied shares of the total
new 2b/3 vehicle market broken down by manufacturer and vehicle type.
[[Page 40369]]
Table VI-17--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.......................................... 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.......................................... 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
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 40370]]
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 would not be 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 MY2015
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 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 MY2015 and MY2020, at which time the Econolines cease
to exist in any form and all corresponding volume resides with the
Transits.
(3) Additional Technology Cost and Effectiveness Inputs
In addition to the base technology cost and effectiveness inputs
described in VI. of this preamble, the CAFE model has some additional
cost and effectiveness inputs, described as follows.
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 this analysis are described in
VI-18.
Table VI-18--Technology Pair Effectiveness Synergy Factors for HD Pickups and Vans
----------------------------------------------------------------------------------------------------------------
Adjustment
Technology pair (%) Technology pair Adjustment (%)
----------------------------------------------------------------------------------------------------------------
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
[[Page 40371]]
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 mark up direct costs
for the agencies' central analysis.
The agencies invite comment on all efficacy and cost inputs
involved in today's analysis and request that commenters provide any
additional data or forward-looking estimates that could be used to
support alternative inputs, including those related to costs beyond
those reflected in the cost to purchase new vehicles.
(4) 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:
Today's 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, in the case of survival
rates, and usage data collected as part of the last Vehicle In Use
Survey (the 2002 VIUS), in the case of mileage accumulation.
(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.
(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 draft 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.
(e) Past Fuel Consumption Levels
Though not reported here, cumulative fuel consumption and
CO2 emissions are presented in the accompanying draft 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.
(f) Long-Term Fuel Consumption Levels
Though not reported here, longer-term estimates of fuel consumption
and emissions are presented in the accompanying draft 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.\361\
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 this analysis,
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.
---------------------------------------------------------------------------
\361\ Volpe CAFE Model, available at http://www.nhtsa.gov/fuel-economy.
---------------------------------------------------------------------------
(h) Civil Penalties
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.
(i) Coefficients for Fatality Calculations
Today's analysis considered 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 \362\ and, most relevant to this proposal, 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 likely there
will be fatalities among the occupants of the other vehicles. In
addition to the effects of mass reduction, the analysis anticipates
that
[[Page 40372]]
the proposed standards, by reducing the cost of driving HD pickups and
vans, would lead to increased travel by these vehicles and, therefore,
more crashes involving these vehicles. The Method A 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.
---------------------------------------------------------------------------
\362\ 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.
---------------------------------------------------------------------------
The Method A 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.
(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 proposed 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.\363\ 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.\364\
---------------------------------------------------------------------------
\363\ EPA MOVES model available at http://www.epa.gov/otaq/models/moves/index.htm (last accessed Feb 23, 2015).
\364\ 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-, accident-, 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.
(5) DOT CAFE Model Analysis of Impacts of Regulatory Alternatives for
HD Pickups and Vans
(a) Industry Impacts
The agencies' 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 proposed 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, but 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 MY2014-MY2018 HD pickups and vans (the final standard
for MY2018 is held constant for model years 2019 and 2020). The
forward-looking nature of product plans that determine which vehicle
models will be offered in the model years affected by the proposed
standards lead to additional technology application to vehicles in the
analysis fleet that occurs in the years prior to the start of the
proposed standards. From the industry perspective, this means that
manufacturers will incur costs to comply with the proposed standards in
the baseline and that the total cost of the proposed 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.
[[Page 40373]]
Table VI-19--MY2021 Baseline Costs for Manufacturers in 2b/3 Market
Segment in the Dynamic Baseline, or Alternative 1b
------------------------------------------------------------------------
Average Total cost
Manufacturer technology increase
cost ($) ($m)
------------------------------------------------------------------------
Chrysler/Fiat................................. 275 27
Daimler....................................... 18 0
Ford.......................................... 258 78
General Motors................................ 782 191
Nissan........................................ 282 3
Industry...................................... 442 300
------------------------------------------------------------------------
As Table VI-19 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
Chrysler/Fiat) 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. To examine this possibility, all regulatory
alternatives were also analyzed using the DOT CAFE model (Method A)
with a 0-month payback period in lieu of the 6-month payback period
discussed above. (A sensitivity analysis using Method A, discussed
below, also explores longer payback periods, as well as the combined
effect of payback period and fuel price on vehicle design decisions).
Resultant technology costs in model year 2021 results for the no-action
alternative, summarized in Table VI-20 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-20--MY2021 Baseline Costs for HD Pickups and Vans in the Flat
Baseline, or Alternative 1a
------------------------------------------------------------------------
Average Total cost
Manufacturer technology increase
cost ($) ($m)
------------------------------------------------------------------------
Chrysler/Fiat................................. 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 proposed standards, as
incremental changes over the baseline, where the baseline is defined as
the state of the world in the absence of the proposed regulatory
action. 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 MDHD rulemaking 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 the proposed
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-21 shows a summary \365\ of outcomes
by alternative incremental to the baseline (Alternative 1b) for Model
Year 2030 \366\, with the exception of technology penetration rates,
which are absolute.
---------------------------------------------------------------------------
\365\ 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 draft RIA.
\366\ The DOT CAFE model estimates that redesign schedules will
``straddle'' model year 2027, the latest year for which the agencies
are proposing increases in 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 by the CAFE model 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 will 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, for example.
[[Page 40374]]
Table VI-21--Summary of HD Pickups and Vans Alternatives' Impact on Industry 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
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, the model projects that the standards would cause
manufacturers to produce HD pickups and vans that are lighter, more
aerodynamic, and more technologically complex across all the
alternatives. As Table VI-21 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). Despite the fact that the required
average fuel consumption level changes by about 3 percent between
Alternative 4 and Alternative 5, average technology cost increases by
more than 25 percent. These differences help illustrate the clustered
character of this market segment, where relatively small increases in
fuel economy can lead to much larger cost increases if entire platforms
must be changed in response to the standards.
The contrast between alternatives 3 and 4 is even more prominent,
with an identical required fuel economy improvement leading 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
[[Page 40375]]
certain technology penetration rates decrease between alternatives of
increasing stringency (cylinder deactivation or mass reductions in
Table VI-21, 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 lower-complexity
technology that is applied.
One driver of the change in technology cost between Alternative 3
and Alternative 4 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 hybridization required 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 Chrysler (Fiat), are expected to have
approximately 95 percent of the 2b/3 new vehicle market during the
years that the proposed 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-22, Table VI-23, and Table VI-24 for General Motors, Ford, and
Chrysler/Fiat, respectively.
Table VI-22--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-23--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
[[Page 40376]]
Stringency Increase Through MY.................. 2025 2027 2025 2025
----------------------------------------------------------------------------------------------------------------
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-24--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
[[Page 40377]]
8-Speed AT...................................... 65 88 88 88
EPS, Accessories................................ 0 100 100 100
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 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, the agencies estimate that
General Motors would 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, GM is estimated to engage in the least amount of mass
reduction among the Big 3 after Phase 1, and much less than Chrysler/
Fiat, 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,
Chrysler/Fiat is projected to apply less hybridization than the others,
and much less than General Motors, which is simulated 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, in Alternative 4 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 the proposed 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 Chrysler/Fiat 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 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 Chrysler/Fiat 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, when Ford and Chrysler/
[[Page 40378]]
Fiat 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, 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 impacted much differently by the proposed
standards. For the least stringent alternative considered, Daimler adds
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-21. This
difference could increase if the analysis fleet supporting the final
rule includes forthcoming Nissan HD pickups.
Table VI-25--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-26--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
----------------------------------------------------------------------------------------------------------------
[[Page 40379]]
Average Fuel Consumption (gallons/100 mi.)
----------------------------------------------------------------------------------------------------------------
Required........................................ 5.09 44.72 4.78 4.66
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-25 and Table VI-26 show, Nissan applies 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 agencies do 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.
(b) Estimated Owner/Operator Impacts With Respect to HD Pickups and
Vans Using Method A
The owner/operator impacts of the proposed rules are more
straightforward. Table VI-27 shows the impact on the average owner/
operator who buys a new class 2b or 3 vehicle in model year 2030 using
the worst case assumption that manufacturers pass through the entire
cost of technology to the purchaser. (All dollar values are discounted
at a rate of 7 percent per year from the time of purchase, except the
average price increase, which occurs at the time of purchase). The
additional costs associated with increases in taxes, registration fees,
and financing costs are also captured in the table.
Table VI-27--Summary of Individual Owner/Operator Impacts in MY 2030 in the HD Pickup and Van Market Segment
Using Method A and Versus the Dynamic Baseline, Alternative 1\b\ \a\
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Stringency Increase Increases............ 2.0%/y 2.5%/y 3.5%/y 4.0%/y
Stringency Increase Through MY.................. 2025 2027 2025 2025
----------------------------------------------------------------------------------------------------------------
[[Page 40380]]
Value of Lifetime Fuel Savings (discounted 2012 dollars)
----------------------------------------------------------------------------------------------------------------
Pretax.......................................... 2,068 3,924 4,180 4,676
Tax............................................. 210 409 438 491
Total........................................... 2,278 4,334 4,618 5,168
----------------------------------------------------------------------------------------------------------------
Economic Benefits (discounted 2012 dollars)
----------------------------------------------------------------------------------------------------------------
Mobility Benefit................................ 244 437 472 525
Avoided Refueling Time.......................... 86 164 172 193
----------------------------------------------------------------------------------------------------------------
New Vehicle Purchase (vs. No-Action Alternative)
----------------------------------------------------------------------------------------------------------------
Avg. Price Increase ($)......................... 578 1,348 1,655 2,080
Avg. Payback (years)............................ 2.5 3 3.4 3.9
Additional costs ($)............................ 120 280 344 432
----------------------------------------------------------------------------------------------------------------
Net Lifetime Owner/Operator Benefits (discounted $)
----------------------------------------------------------------------------------------------------------------
Total Net Benefits.............................. 1,910 3,307 3,263 3,374
----------------------------------------------------------------------------------------------------------------
Notes:
* All dollar values are discounted at a rate of 7 percent per year from the time of purchase, except the average
price increase, which occurs at the time of purchase).
\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.
As expected, an owner/operator's lifetime fuel savings increase
monotonically across the alternatives. The mobility benefit in Table
VI-27 refers to the value of additional miles that an individual owner/
operator travels as a result of reduced per-mile travel costs. The
additional miles result in additional fuel consumption and represent
foregone fuel savings, but are valued by owner/operators at the cost of
the additional fuel plus the owner/operator surplus (a measure of the
increase in welfare that owner/operators achieve by having more
mobility). The refueling benefit measures the value of time saved
through reduced refueling events, the result of improved fuel economy
and range in vehicles that have been modified in response to the
standards.
There are some limitations to using payback period as a measure, as
it accounts for fuel expenditures and incremental costs associated with
taxes, registration fees and financing, and increased maintenance
costs, but not the cost of potential repairs or replacements, which may
or may not be more expensive with more advanced technology.
Overall, the average owner/operator is likely to see discounted
lifetime benefits that are multiples of the price increases faced when
purchasing the new vehicle in MY 2030 (or the few model years preceding
2030). In particular, the net present value of future benefits at the
time of purchase are estimated to be 3.5, 3.0, 2.2, and 1.8 times the
price increase of the average new MY2030 vehicle for Alternatives 2-5,
respectively. As Table VI-27 illustrates, the preferred alternative has
the highest ratio of discounted future owner/operator benefits to
owner/operator costs.
(c) Estimated Social and Environmental Impacts for HD Pickups and Vans
Social benefits increase with the increasing stringency of the
alternatives. As in the owner/operator analysis, the net benefits
continue to increase with increasing stringency--suggesting that
benefits are still increasing faster than costs for even the most
stringent alternative.
Table VI-28--Summary of Total Social Costs and Benefits Through MY 2029 in the HD Pickup and Van Market Segment
Using Method A and Versus the Dynamic Baseline, Alternative 1\b\ \a\
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Stringency Increase...................... 2.0% 2.5% 3.5% 4.0%
Stringency Increase Through MY.................. 2025 2027 2025 2025
----------------------------------------------------------------------------------------------------------------
Fuel Purchases ($billion)
----------------------------------------------------------------------------------------------------------------
Pretax Savings.................................. 9.6 15.9 19.1 22.2
----------------------------------------------------------------------------------------------------------------
Fuel Externalities ($billion)
----------------------------------------------------------------------------------------------------------------
Energy Security................................. 0.5 0.9 1.1 1.3
CO2 emissions \b\............................... 1.9 3.2 3.8 4.4
----------------------------------------------------------------------------------------------------------------
VMT-Related Externalities ($billion)
----------------------------------------------------------------------------------------------------------------
Driving Surplus................................. 1.1 1.8 2.1 2.4
Refueling Surplus............................... 0.4 0.7 0.8 0.9
[[Page 40381]]
Congestion...................................... -0.2 -0.4 -0.4 -0.5
Accidents....................................... -0.1 -0.2 -0.2 -0.3
Noise........................................... 0 0 0 0
Fatalities...................................... 0.1 -0.2 -0.2 -0.5
Criteria Emissions.............................. 0.6 1.1 1.3 1.6
----------------------------------------------------------------------------------------------------------------
Technology Costs vs. No-Action ($billion)
----------------------------------------------------------------------------------------------------------------
Incremental Cost................................ 2.5 5.0 7.2 9.7
Additional Costs................................ 0.5 1.0 1.5 2.0
----------------------------------------------------------------------------------------------------------------
Benefit Cost Summary ($billion)
----------------------------------------------------------------------------------------------------------------
Total Social Cost............................... 3.3 6.8 9.5 13.0
Total Social Benefit............................ 13.9 22.7 27.4 31.7
Net Social Benefit.............................. 10.6 15.9 17.9 18.7
----------------------------------------------------------------------------------------------------------------
Notes:
* All dollar values are discounted at a rate of 3 percent per year from the time of purchase.
\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\ Using the 3% average social cost of CO2 value. There are four distinct social cost of CO2 values presented
in the Technical Support Document: Social Cost of Carbon for Regulatory Impact Analysis under Executive Order
12866 (2010 and 2013). The CO2 emissions presented here would be valued lower with one of those other three
values and higher at the other two values.
Table VI-28 provides a summary of benefits and costs, cumulative
from MY2015-MY2029 (although the early years of the series typically
have no incremental costs and benefits over the baseline), for each
alternative. In the social perspective, fuel savings are considered net
of fuel taxes, which are a transfer from purchasers of fuel to society
at large. The energy security component represents the risk premium
associated with exposure to oil price spikes and the economic
consequences of adapting to them. This externality is monetized on a
per-gallon basis, just as the social cost of carbon is used in this
analysis. Just as the previous two externalities are caused by fuel
consumption, others are caused by travel itself. The additional VMT
resulting from the increase in travel demand that occurs when the price
of driving decreases (i.e. the rebound effect), not only leads to
increased mobility (which is a benefit to drivers), but also to
increases in congestion, noise, accidents, and per-mile emissions of
criteria pollutants like carbon monoxide and diesel particulates.
Although increases in VMT lead to increases in tailpipe emissions of
criteria pollutants, the proposed regulations decrease overall
consumption enough that the emissions reductions associated with the
remainder of the fuel cycle (extraction, refining, transportation and
distribution) are large enough to create a net reduction in the
emissions of criteria pollutants (shown below in Table VI-29 and VI-
30).\367\ A full presentation of the costs and benefits, and the
considerations that have gone into each cost and benefit category--such
as how energy security premiums were developed, how the social costs of
carbon and co-pollutant benefits were developed, etc.--is presented in
Section IX of this preamble and in Chapters 7 and 8 of the draft RIA
for each regulated segment (engines, HD pickups and vans, vocational
vehicles, tractors and trailers).
---------------------------------------------------------------------------
\367\ For a more detailed discussion of the results from the
CAFE Model on the proposed heavy duty pickups and vans regulation's
impact on emissions of CO2 and criteria pollutants, see
NHTSA's accompanying Draft Environmental Impact Statement.
---------------------------------------------------------------------------
Another side effect of increased VMT is the likely increase in
crashes, which is a function of the total vehicle travel in each year.
Although additional crashes could involve additional fatalities, we
estimate that this potential could be partially offset by the
application of mass reduction to HD pickup trucks and vans, which could
make fatalities less likely in some crashes involving these vehicles.
As Table VI-28 illustrates, the social cost associated with traffic
fatalities is the result of an additional -10 (Alternative 2 leads to a
reduction in fatalities over the baseline, due to the application of
mass reduction technologies), 35, 36, and 66 fatalities for
Alternatives 2-5, respectively. The baseline contains nearly 25,000
fatalities involving 2b/3 vehicles over the same period. The
incremental fatalities associated with Alternative 2-5 are -0.4, 0.1,
0.1, and 0.3 percent relative to the MYs 2015-2029 baseline,
respectively.
The CAFE model was used to estimate the emissions impacts of the
various alternatives that are the result of lower fuel consumption, but
increased vehicle miles traveled for vehicle produced in model years
subject to the standards in the alternatives. Criteria pollutants are
largely the result of vehicle use, and accrue on a per-mile-of-travel
basis, but the alternatives still generally lead to emissions
reductions. Although vehicle use increases under each of the
alternatives, upstream emissions associated with fuel refining,
transportation and distribution are reduced for each gallon of fuel
saved and that savings is larger than the incremental increase in
emissions associated with increased travel. The net of the two factors
is a savings of criteria (and other) pollutant emissions.
[[Page 40382]]
Table VI-29--Summary of Environmental Impacts Through MY2029 in the HD Pickup and Van Market Segment, Using
Method A and Versus the Dynamic Baseline, Alternative 1b a
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Stringency Increase...................... 2.0% 2.5% 3.5% 4.0%
Stringency Increase Through MY.................. 2025 2027 2025 2025
----------------------------------------------------------------------------------------------------------------
Greenhouse Gas Emissions vs. No-Action Alternative
----------------------------------------------------------------------------------------------------------------
CO2 (MMT)....................................... 54 91 110 127
CH4 and N2O (tons).............................. 65,600 111,400 133,700 155,300
----------------------------------------------------------------------------------------------------------------
Other Emissions vs. No-Action Alternative (tons)
----------------------------------------------------------------------------------------------------------------
CO.............................................. 10,400 20,700 25,800 30,400
VOC and NOX..................................... 23,800 43,600 53,500 62,200
PM.............................................. 1,470 2,550 3,090 3,590
SO2............................................. 11,400 19,900 24,100 28,000
Air Toxics...................................... 44 47 49 55
Diesel PM10..................................... 2,470 4,350 5,300 6,160
----------------------------------------------------------------------------------------------------------------
Other Emissions vs. No-Action Alternative (% reduction)
----------------------------------------------------------------------------------------------------------------
CO.............................................. 0.1 0.3 0.4 0.4
VOC and NOX..................................... 1.1 2.1 2.6 3.0
PM.............................................. 1.7 3.0 3.6 4.2
SO2............................................. 2.9 5.1 6.2 7.2
Air Toxics...................................... 0.1 0.1 0.1 0.2
Diesel PM10..................................... 2.7 4.8 5.9 6.8
----------------------------------------------------------------------------------------------------------------
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.
In addition to comparing environmental impacts of the alternatives
against a dynamic baseline that shows some improvement over time,
compared to today's fleet, even in the absence of the alternatives, the
environmental impacts from the Method A analysis were compared against
a flat baseline. This other comparison is summarized below, but both
comparisons are discussed in greater detail in the Draft EIS.
Table VI-30--Summary of Environmental Impacts Through MY2029 in the HD Pickup and Van Market Segment, Using
Method A and Versus the Flat Baseline, Alternative 1\a\
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Stringency Increase...................... 2.0% 2.5% 3.5% 4.0%
Stringency Increase Through MY.................. 2025 2027 2025 2025
----------------------------------------------------------------------------------------------------------------
Greenhouse Gas Emissions vs. No-Action Alternative
----------------------------------------------------------------------------------------------------------------
CO2 (MMT)....................................... 66 105 127 142
CH4 and N2O (tons).............................. 79,700 127,400 154,800 172,800
----------------------------------------------------------------------------------------------------------------
Other Emissions vs. No-Action Alternative (tons)
----------------------------------------------------------------------------------------------------------------
CO.............................................. 11,630 22,160 28,030 32,370
VOC and NOX..................................... 28,280 48,770 60,180 68,050
PM.............................................. 1,780 2,900 3,550 3,980
SO2............................................. 13,780 22,580 27,660 31,020
Air Toxics...................................... 60 65 72 73
Diesel PM10..................................... 2,980 4,930 6,060 6,810
----------------------------------------------------------------------------------------------------------------
Other Emissions vs. No-Action Alternative (% reduction)
----------------------------------------------------------------------------------------------------------------
CO.............................................. 0.2 0.3 0.4 0.4
VOC and NOX..................................... 1.4 2.3 2.9 3.3
PM.............................................. 2.1 3.4 4.2 4.7
SO2............................................. 3.5 5.7 7.0 7.9
Air Toxics...................................... 0.2 0.2 0.2 0.2
Diesel PM10..................................... 3.3 5.4 6.7 7.5
----------------------------------------------------------------------------------------------------------------
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.
[[Page 40383]]
(6) Sensitivity Analysis Evaluating Different Inputs to the DOT 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.''
\368\ 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:
---------------------------------------------------------------------------
\368\ 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
2014 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 2014 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/operatorBenefit and
50pctOwner/operatorBenefit.)
5. 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).
6. Rebound Effect: Evaluated side cases involving rebound effect
values of 5 percent, 15 percent, and 20 percent. (These are labeled as
05PctReboundEffect, 15PctReboundEffect and 20PctReboundEffect).
7. RPE-based Markup: Evaluated a side case using a retail price
equivalent (RPE) markup factor of 1.5 for non-electrification
technologies, which is consistent with the NAS estimation for
technologies manufactured by suppliers, and a RPE markup factor of 1.33
for electrification technologies (mild and strong HEV).
8. ICM-based Post-Warranty Repair Costs: NHTSA evaluated a side
case that scaled the frequency of repair by vehicle survival rates,
assumes that per-vehicle repair costs during the post-warranty period
are the same as in the in-warranty period, and that repair costs are
proportional to incremental direct costs (therefore vehicles with
additional components will have increased repair costs).
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. 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.
11. Diesel Downsizing: Evaluated a side case in which downsizing of
diesel engines was estimated to be more widely available to HD pickups
and vans.
12. Technology Effectiveness: Evaluated side cases involving inputs
reflecting lower and higher impacts of technologies on fuel
consumption.
13. Technology Direct Costs: Evaluated side cases involving inputs
reflecting lower and higher direct incremental costs for fuel-saving
technologies.
14. Fleet Mix: Evaluated a side case in which the shares of
individual vehicle models and configurations were kept constant at
estimated current levels.
Table VI-31 below, summarizes key metrics for each of the cases
included in the sensitivity analysis using Method A for the proposed
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 proposed alternative 3. For each
sensitivity run, the change in the metric can we 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] TP13JY15.012
Each metric represents the sum of the impacts of the preferred
alternative over the model years 2018-2029, 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-31--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\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel savings CO2 savings Fuel savings Social costs Social Social net
Sensitivity case (gallons) (%) (MMT) (%) ($) (%) (%) benefits (%) benefits (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0 Month Payback......................................... 14.0 14.5 15.1 5.6 15.1 18.2
[[Page 40384]]
12 Month Payback........................................ -4.8 -4.7 -4.5 -2.5 -4.7 -5.4
18 Month Payback........................................ -29.2 -28.1 -26.5 -14.1 -26.8 -31.1
24 Month Payback........................................ -42.9 -42.4 -41.9 -23.2 -42.1 -48.4
AEO-Low................................................. 3.3 3.5 -27.9 -10.8 -22.2 -26.1
AEO-High................................................ -7.0 -7.2 23.3 1.4 19.5 25.6
AEO-Low, 0 Month Payback................................ 18.6 19.3 -16.5 -3.4 -10.1 -12.3
AEO-High, 24 Month Payback.............................. -63.8 -64.6 -54.4 -49.9 -55.7 -57.7
50pct Owner/operator Benefit............................ 0.0 0.0 -50.0 0.0 -34.6 -46.2
75pct Owner/operator Benefit............................ 0.0 0.0 -25.0 0.0 -17.3 -23.1
Low SCC................................................. 0.0 0.0 0.0 0.0 -10.6 -14.1
Low SCC, 0 Month Payback................................ 14.0 14.5 15.1 5.6 2.9 2.0
High SCC................................................ 0.0 0.0 0.0 0.0 7.8 10.4
High SCC, 0 Month Payback............................... 14.0 14.5 15.1 5.6 24.0 30.1
Very High SCC........................................... 0.0 0.0 0.0 0.0 28.7 38.4
Very High SCC, 0 Month Payback.......................... 14.0 14.5 15.1 5.6 48.0 62.2
05 Pct Rebound Effect................................... 4.6 4.6 4.6 -12.9 0.4 4.8
15 Pct Rebound Effect................................... -4.6 -4.6 -4.6 12.9 -0.4 -4.8
20 Pct Rebound Effect................................... -9.1 -9.2 -9.2 25.7 -0.8 -9.7
RPE-Based Markup........................................ -3.2 -1.5 0.3 31.4 -0.1 -10.6
Mass Fatality Coeff 05pct............................... 0.0 0.0 0.0 -23.6 0.0 7.9
Mass Fatality Coeff 95pct............................... 0.0 0.0 0.0 23.9 0.0 -8.0
NoSHEVs................................................. -6.7 -5.8 -5.0 2.3 -5.1 -7.6
NoSHEVs, 0 Month Payback................................ 8.2 9.8 11.5 -1.2 11.3 15.4
Lower Effectiveness..................................... -7.8 -7.8 -8.1 39.5 -8.0 -23.9
Higher Effectiveness.................................... -10.6 -10.3 -10.0 -23.3 -10.2 -5.8
Lower Direct Costs...................................... 0.9 2.7 4.8 18.4 4.3 -0.4
Higher Direct Costs..................................... -4.1 -3.8 -3.5 75.3 -3.8 -30.3
Wider Diesel Downsizing................................. -1.5 -1.0 -0.6 -10.3 -0.8 2.4
07 Pct Discount Rate.................................... 0.0 0.0 -100.0 -41.7 -100.0 -119.5
07 Pct DR, 0 Month Payback.............................. 14.0 14.5 -37.9 -30.7 -30.7 -30.7
Allow Gas To Diesel..................................... 15.5 5.3 -100.0 16.8 -100.0 -139.1
Allow Gas To Diesel, 0 Month Payback.................... 32.1 22.6 14.5 46.8 17.0 7.0
flat mix after 2016..................................... 1.1 0.9 0.7 2.6 0.8 0.2
--------------------------------------------------------------------------------------------------------------------------------------------------------
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 the
proposed standards in an intuitive way. Some other cases warrant closer
consideration:
First, cases involving alternatives to the reference six-month
payback period involve different degrees of fuel consumption
improvement, and these differences are greatest in the no-action
alternative defining the baseline. Because all estimated impacts of the
proposed standards are shown as incremental values relative to this
baseline, longer payback periods correspond to smaller estimates of
incremental impacts, as fuel economy increasingly improves in the
absence of the rule and manufacturers are compelled to add less
technology in order to comply with the standards.
Second, 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. Lower
fuel prices correspond to increases in fuel savings on a volumetric
basis, as the standard is responsible for a greater amount of the fuel
economy improvement, but the value of fuel savings decreases because
each gallon saved is worth less when fuel prices are low. Higher fuel
prices correspond to reductions in the volumetric fuel savings
attributable to the proposed standards, but lead to increases in the
value of fuel saved because each gallon saved is worth more when fuel
prices are high.
Third, because the payback period and fuel price inputs work in
opposing directions, the relative magnitude of each is important to
consider for the combined sensitivity cases. While the low price and 0-
month payback case leads to significant volumetric savings compared to
the main analysis, the low fuel price is still sufficient to produce a
negative change in net benefits. Similarly, the high price and 24-month
payback case results in large reductions to volumetric savings that can
be attributed to the proposed standards, but 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.
Fourth, the cases involving different inputs defining the
availability of some technologies do not impact equally the estimated
impacts across all manufacturers. Section C.8 above
[[Page 40385]]
provides a discussion of a sensitivity analysis that excludes strong
hybrids and includes the use of downsized turbocharged engines in vans
currently equipped with large V-8 engines. The modeling results for
this analysis are provided in Section C.8 and in the table above. The
no strong hybrid analysis shows that GM could comply with the proposed
preferred Alternative 3 without strong hybrids based on the use of
turbo downsizing on all of their HD gasoline vans. Alternatively, when
the analysis is modified to allow for wider application of diesel
engines, strong HEV application for GM drops slightly (from 19 percent
to 17 percent) in MY2030, average per-vehicle costs drop slightly (by
about $50), but MY2030 additional penetration rates of diesel engines
increase by about 10 percent. Manufacturer-specific model results
accompanying today's rules show the extent to which individual
manufacturers' potential responses to the standards vary with these
alternative assumptions regarding the availability and applicability of
fuel-saving technologies. However, across all of these sensitivity
cases, the model projects that social costs increase (as a result of
increases in technology costs) when manufacturers choose to comply with
the proposed regulations without the use of strong hybrids.
Fifth, the cases that vary the effectiveness and direct cost of
available technologies produce nuanced results in the context of even
the 0-month payback case. In the case of effectiveness changes, both
sensitivity cases result in reductions to the volumetric fuel savings
attributable to the proposal; lower effectiveness because the
technologies applied in response to the standards save less fuel, and
higher effectiveness because more of the increase in fuel economy
occurs in the baseline. However, for both cases, social costs (a strong
proxy for technology costs) move in the intuitive direction.
The cases that vary direct costs show volumetric fuel savings
increasing under lower direct technology costs despite additional fuel
economy improvements in the baseline, as more aggressive technology
becomes cost effective. Higher direct costs lead to decreases in
volumetric fuel savings, as more of the fuel economy improvement can be
attributed to the rule. In both cases, social costs (as a result of
technology costs) move in the intuitive direction.
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 proposed rule would be as they appear in Table VI-
32, below.
Table VI-32--Costs and Benefits of Proposed Standards for HD Pickups and Vans Under Alternative Assumptions
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel savings Social Net social
Sensitivity case (billion CO2 reduction Fuel savings Social costs benefits benefits
gallons) (MMT) ($billion) ($billion) ($billion) ($billion)
--------------------------------------------------------------------------------------------------------------------------------------------------------
6 Month Payback (main).................................. 7.8 94.1 15.9 5.5 23.5 18.0
0 Month Payback......................................... 8.9 107.7 18.3 5.8 27.0 21.3
12 Month Payback........................................ 7.4 87.2 15.2 5.6 21.9 16.3
18 Month Payback........................................ 5.5 65.8 11.7 4.9 16.8 11.9
24 Month Payback........................................ 4.5 52.7 9.2 4.4 13.3 8.9
AEO-Low................................................. 8.1 94.7 11.5 5.1 17.8 12.7
AEO-High................................................ 7.3 84.9 19.6 5.8 27.4 21.6
AEO-Low, 0 Month Payback................................ 9.3 109.1 13.3 5.6 20.6 15.1
AEO-High, 24 Month Payback.............................. 2.8 32.4 7.2 2.9 10.2 7.3
50pct Owner/operator Benefit............................ 7.8 91.5 8.0 5.8 15.0 9.2
75pct Owner/operator Benefit............................ 7.8 91.5 11.9 5.8 19.0 13.2
Low SCC................................................. 7.8 91.5 15.9 5.8 20.5 14.8
Low SCC, 0 Month Payback................................ 8.9 104.7 18.3 6.1 23.6 17.5
High SCC................................................ 7.8 91.5 15.9 5.8 24.7 19.0
High SCC, 0 Month Payback............................... 8.9 104.7 18.3 6.1 28.5 22.4
Very High SCC........................................... 7.8 91.5 15.9 5.8 29.5 23.8
Very High SCC, 0 Month Payback.......................... 8.9 104.7 18.3 6.1 34.0 27.9
05 Pct Rebound Effect................................... 8.2 95.7 16.6 5.0 23.0 18.0
15 Pct Rebound Effect................................... 7.5 87.2 15.2 6.5 22.9 16.4
20 Pct Rebound Effect................................... 7.1 83.0 14.4 7.2 22.8 15.5
RPE-Based Markup........................................ 7.6 90.1 16.0 7.6 22.9 15.4
Mass Fatality Coeff 05pct............................... 7.8 91.5 15.9 4.4 23.0 18.5
Mass Fatality Coeff 95pct............................... 7.8 91.5 15.9 7.1 23.0 15.8
NoSHEVs................................................. 7.2 84.3 14.6 8.0 21.1 13.1
NoSHEVs, 0 Month Payback................................ 7.0 82.0 14.3 4.4 20.6 16.2
Lower Effectiveness..................................... 7.9 94.0 16.7 6.8 23.9 17.1
Higher Effectiveness.................................... 7.5 88.0 15.3 10.1 22.1 12.0
Lower Direct Costs...................................... 7.7 90.5 15.8 5.2 22.8 17.6
Higher Direct Costs..................................... 7.8 91.5 8.5 3.8 13.8 10.0
Wider Diesel Downsizing................................. 8.9 104.7 9.9 4.0 15.9 11.9
07 Pct Discount Rate.................................... 9.0 96.3 15.3 7.2 22.7 15.5
07 Pct DR, 0 Month Payback.............................. 10.3 112.2 18.2 8.5 26.9 18.4
Allow Gas To Diesel..................................... 7.9 92.3 16.0 5.9 23.1 17.2
Allow Gas To Diesel, 0 Month Payback.................... 7.3 85.8 15.1 6.9 21.7 14.8
Flat mix after 2016..................................... 8.4 99.8 17.6 7.4 25.4 17.9
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(7) Uncertainty Analysis
As in previous rules, NHTSA has conducted an uncertainty analysis
to determine the extent to which uncertainty about input assumptions
could impact the costs and benefits attributable to the proposed rule.
Unlike the preceding sensitivity analysis, which is useful for
understanding how
[[Page 40386]]
alternative values of a single input assumption may influence the
estimated impacts of the proposed standards, the uncertainty analysis
considers multiple states of the world, characterized by a distribution
of specific values of all relevant inputs, based on their relative
probability of occurrence. A sensitivity analysis varies a single
parameter of interest, holding all others constant at whatever nominal
values are used to generate the single point estimate in the main
analysis, and measures the resulting deviation. However, the
uncertainty analysis allows all of those parameters to vary
simultaneously--relaxing the assumption that ``all else is equal''.
Each trial, of which there are 14,000 in this analysis, represents
a different state of the world in which the standards are implemented.
To gauge the robustness of the estimates of impacts in the proposal,
NHTSA varied technology costs and effectiveness, fuel prices, market
demand for fuel economy improvements in the absence of the rule, the
amount of additional driving associated with fuel economy improvements
(the rebound effect), and the on-road gaps between realized fuel
economy and laboratory test values for gasoline and diesel vehicles.
The shapes and types of the probability distributions used in the
analysis vary by uncertainty parameter, though the costs and
effectiveness values for technologies are sampled as groups to minimize
issues associated with interdependence. The most important input to the
uncertainty analysis, fuel prices (which drive the majority of benefits
from the proposed standards), are drawn from a range of fuel prices
characterized by permutations of the Low, Reference, and High fuel
price cases in the Annual Energy Outlook 2014.
[GRAPHIC] [TIFF OMITTED] TP13JY15.013
Figure VI-7 displays the distribution of net benefits estimated by
the ensemble of simulation runs. As Figure VI-7 indicates, the analysis
produces a wide distribution of possible outcomes that are much broader
than the range of estimates characterized by only the difference
between the more and less dynamic baselines. While the expected value,
the probability-weighted average outcome, is only about 70 percent of
the net benefits estimated in the main analysis, almost all of the
trials produce positive net benefits. In fact, the distribution
suggests there is only a one percent chance of the proposal producing
negative net benefits for HD pickups and vans. So while the estimated
net benefits in the main analysis may be higher than the expected value
when uncertainty is considered, net benefits at least as high as those
estimated in the main analysis are still 20 times as likely as an
outcome that results in net costs.
Figure VI-8 shows the distribution of payback periods (in years)
for Model Year 2029 trucks across 14,000 simulation runs. The ``payback
period'' typically refers to the number of years of vehicle use that
occur before the savings on fuel expenditures offset the additional
technology cost associated with improved fuel economy. As Figure VI-8
illustrates, the expected incremental technology cost of both Phase 1
and Phase 2 is eclipsed by the value of fuel savings by year three of
ownership in most cases
[[Page 40387]]
[GRAPHIC] [TIFF OMITTED] TP13JY15.014
This is an important metric for owner/operator acceptability and,
though Figure VI-8 illustrates the long right tail of the payback
distribution (where payback periods are likely to be unacceptably
long), fewer than ten percent of the trials result in payback periods
longer than four years. This suggests that, even in the face of
uncertainty about future fuel prices and fuel economy in real-world
driving conditions, buyers of the vehicles that are modified to comply
with the requirements of the proposal will still see fuel savings
greater than their additional vehicle cost in a relatively short period
of time. As one would expect, the technologies used in Phase 1 of the
MDHD program are likely to be more cost effective and serve to lower
the expected payback period, even compared to the main analysis of
Phase 2.
E. 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 proposing the 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 \369\ and the
agencies are proposing to maintain this averaging set approach for
Phase 2.
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\369\ 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.
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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 standard would
be allowed to generate credits. Conversely, if the fleet average
CO2 or fuel consumption level does not meet its standard,
the fleet would incur debits (also referred to as a shortfall).
A manufacturer whose fleet generates credits in a given model year
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
[[Page 40388]]
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 are not proposing changes to any of these
provisions for the Phase 2 program.
While the agencies are proposing to retain 5 year carry-forward of
credits for all HD sectors, the agencies request 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. EPA included a similar provision in
the MY 2017-2025 light-duty vehicle rule, which allows a one-time
credit carry-forward of MY 2010-2015 credits to be carried forward
through MY 2021.\370\ Such a credit carry-forward extension for HD
pickups and vans may provide manufacturers with additional flexibility
during the transition to the proposed Phase 2 standards. A temporary
credit carry-forward period of longer than five years for Phase 1
credits may help manufacturers resolve lead-time issues they might face
as the proposed more stringent Phase 2 standards phase-in and help
avoid negative impacts to their product redesign cycles which tend to
be longer than those for light-duty vehicles.
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\370\ 77 FR 62788, October 15, 2012.
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As discussed in Section VI.B.4., EPA and NHTSA are proposing to
change 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
propose 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 proposed 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 (10x1,000x120,000/1,000,000). Under Phase 2, the same
vehicles would generate 1,500 Mg of credit (10x1,000x150,000/
1,000,000). The agencies do not believe that this proposed 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 would be
unnecessary and could negatively impact the feasibility of the proposed
Phase 2 standards. EPA and NHTSA request comment on all aspects of the
averaging, banking, and trading program.
[GRAPHIC] [TIFF OMITTED] TP13JY15.096
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)
(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 would count as 1.5 vehicles in a manufacturer's compliance
calculation. A manufacturer also has the option to subtract these
vehicles out of its fleet and determine their performance as a separate
fleet calculating advanced technology credits that can be used for all
other HD vehicle categories, but these credits would, of course, not
then be reflected in the manufacturer's conventional pickup and van
category credit balance. The credits are thus `special' in that they
can be applied across the entire heavy-duty sector, unlike the ABT and
early credits discussed above and the proposed off-cycle technology
credits discussed in the following subsection. The agencies also capped
the amount of advanced credits that can be transferred into any
averaging set into any model year at 60,000 Mg to prevent market
distortions.
The advanced technology multipliers were included on an interim
basis in the Phase 1 program and the agencies are proposing to end the
incentive multipliers beginning in MY 2021, when the more stringent
Phase 2 standards are proposed to begin phase-in. The agencies are
proposing a similar approach for the other HD sectors as
[[Page 40389]]
discussed in Section I.C. (1). The advanced technology incentives are
intended to promote the commercialization of technologies that have the
potential to provide substantially better GHG emissions and fuel
consumption if they were able to overcome major near-term market
barriers. However, the incentives are not intended to be a permanent
part of the program as they result in a decrease in overall GHG
emissions and fuel consumption benefits associated with the program
when used. More importantly, as explained in Section I. above, the
agencies are already predicating the stringency of the proposed
standards on development and deployment of two of these Phase 1
advanced technologies (waste heat recovery and strong hybrid
technology), so that it would be inappropriate (and essentially a
windfall) to include credits for use of these technologies in Phase
2.\371\
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\371\ 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.
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As discussed in Section I, the agencies request comment on the
proposed approach for the advanced technology multipliers for HD
pickups and vans as well as the other HD sectors, including comments on
whether or not the 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 manufacturer to meet the proposed Phase 2 standards for HD pickups
and vans. Waste heat recovery is also not projected to be used for HD
pickups and vans in the time frame of the proposed rules. EV and fuel
cell technologies would presumably need to overcome the highest hurdles
to commercialization for HD pickups and vans in the time frame of the
proposed rules, and also have the potential to provide the highest
level of benefit. We welcome comments on the need for such incentives,
including information on why an incentive for specific technologies in
this time frame may be warranted, recognizing that the incentive would
result in reduced benefits in terms of CO2 emissions and
fuel use due to the Phase 2 program.
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 market;
therefore, we believe that this provision is still appropriate. Unlike
the MY2012-2016 light-duty rule, which adopted a cap whereby upstream
emissions would be counted after a certain volume of sales (see 75 FR
25434-25436), we believe there is no need to propose 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 propose to
continue to deem electric vehicles as having zero CO2,
CH4, and N2O emissions as well as zero fuel
consumption. We welcome comments on this approach. See also Section I
for a discussion of the treatment of lifecycle emissions for
alternative fuel vehicles 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).\372\ As discussed in Sections
III.F. and V.E.3., the agencies are proposing approaches for Phase 2
off-cycle technology credits for tractors and vocational vehicles with
proposed provisions tailored for those sectors. 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 proposing to
retain this approach for Phase 2. 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 \373\ 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
proposed off-cycle credit calculation methodology and provide
opportunity for comment.
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\372\ See 76 FR 57251, September 15, 2011, 40 CFR
1037.104(d)(13), and the proposed 40 CFR 86.1819-14(d)(13).
\373\ 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.
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As noted above, the approach finalized for HD pickups and vans
paralleled provisions for off-cycle credits in the MY 2012-2016 light-
duty vehicle GHG program.\374\ In the MY 2017-2025 light-duty vehicle
program, EPA revised the off-cycle credits program for light-duty
vehicles to streamline the credits process. In addition to the process
established in the MY 2012-2016 rule, EPA added a list or ``menu'' of
pre-approved off-cycle technologies and associated credit levels.\375\
Manufacturers may use the pre-defined off-cycle technology menu to
generate light-duty vehicle credits by demonstrating at time of
certification that the vehicles are equipped with the technology
without providing additional test data. Different levels of credits are
provided for cars and light trucks in the light-duty program. NHTSA
also included these credits in the CAFE program (in gallons/mile
equivalent) starting with MY 2017. The list of pre-approved off-cycle
technologies for light-duty vehicles is shown below.
---------------------------------------------------------------------------
\374\ See 75 FR 25440, May 7, 2010 and 40 CFR 86.1869-12(d).
\375\ 77 FR 62832-62839, October 15, 2012.
[[Page 40390]]
Table VI-33--Pre-Approved Off-Cycle Technologies for Light-Duty Vehicles
------------------------------------------------------------------------
Pre-approved technologies
-------------------------------------------------------------------------
High Efficiency Exterior Lighting (at 100W)
Waste Heat Recovery (at 100W; scalable)
Solar Roof Panels (for 75 W, battery charging only)
Solar Roof Panels (for 75 W, active cabin ventilation plus battery
charging)
Active Aerodynamic Improvements (scalable)
Engine Idle Start-Stop w/heater circulation system
Engine Idle Start-Stop without/heater circulation system
Active Transmission Warm-Up
Active Engine Warm-Up
Solar/Thermal Control
------------------------------------------------------------------------
The agencies initially note that where vehicles are not chassis-
certified, but rather evaluate compliance using the GEM simulation
tool, with the proposed modifications to GEM, many more technologies
(especially those related to engine and transmission improvements) will
now be `on-cycle'--evaluated directly by the GEM compliance tool.
However, with respect to the proposed standards which would be chassis-
certified--namely, the standards for heavy duty pickups and vans, the
effectiveness of some technologies will be only partially captured (or
not captured at all). EPA and NHTSA are requesting comment on
establishing a pre-defined technology menu list for HD pickups and
vans. The list for HD pickups and vans could include some or all of the
technologies listed in Table VI-33. As with the light-duty program, the
pre-defined list may simplify the process for generating off-cycle
credits and may further encourage the introduction of these
technologies. However, the appropriate default level of credits for the
heavier vehicles would need to be established. The agencies request
comments with supporting HD pickup and van specific data and analysis
that would provide a substantive basis for appropriate adjustments to
the 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.
As with the light-duty vehicle program, the agencies would also
consider including a cap on credits generated from a pre-defined list
established for HD pickups and vans. The cap for the light-duty vehicle
program is 10 g/mile (and gallons/mi equivalent) applied on a
manufacturer fleet-wide basis.\376\ The 10 g/mile cap limits the total
off-cycle credits allowed based on the pre-defined list across the
manufacturer's light-duty vehicle fleet. The agencies adopted the cap
on credits to address issues of uncertainty regarding the level of
credits automatically assigned to each technology. Manufacturers able
to demonstrate that a technology provides improvements beyond the menu
credit level would be able to apply for additional credits through the
individual demonstration process noted above. Credits based on the
individual manufacturer demonstration would not count against the
credit cap. If a menu list of credits is developed to be included in
the HD pickup and van program, a cap may also be appropriate depending
on the technology list and credit levels. The agencies request comments
on all aspects of the off-cycle credits program for HD trucks and vans.
---------------------------------------------------------------------------
\376\ See 40 CFR 86.1869-12(b).
---------------------------------------------------------------------------
(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. The agencies are proposing to extend
the optional chassis certification provisions to Phase 2 and are not
proposing to extend the loose engine provisions. See the vocational
vehicle Section V.E. and XIV.A.2 for a detailed discussion of the
proposal for optional chassis certification and 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 the proposed standards would 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 the proposed standards, as well as the impacts of Alternative 4.
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, for each regulatory
alternative, the projected environmental impacts related to fuel
consumption, GHG emissions, and climate change. Detailed documentation
of this analysis is provided in Chapters 3 and 5 of NHTSA's DEIS
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).\377\
The agencies used the most current version of the model, MOVES2014, to
quantify the impacts of the proposed standards for vocational vehicles
and combination tractor-trailers on GHG emissions and fuel consumption
for each regulatory alternative. MOVES was run with user
[[Page 40391]]
input databases, described in more detail below, that reflected the
projected technological improvements resulting from the proposed rules,
such as the improvements in engine and vehicle efficiency, aerodynamic
drag, and tire rolling resistance.
---------------------------------------------------------------------------
\377\ MOVES homepage: http://www.epa.gov/otaq/models/moves/index.htm (last accessed Feb 23, 2015).
---------------------------------------------------------------------------
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. For
today's analysis of potential new standards for HD pickups and vans,
the model was reconfigured to 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 will be produced in a given model year, technologies available to
improve fuel efficiency on those vehicles, potential regulatory
standards that would 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 the resulting
improved vehicle fleet, 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.C of the preamble and Chapter 2 of the draft
RIA.
For these rules, the agencies conducted coordinated and
complementary analyses by using 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
complementary analyses, which we refer to as ``Method A'' and ``Method
B''. In Method A, 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 both methods. The agencies
concluded that both methods led the agencies to the same conclusions
and the same selection of the proposed standards. See Chapter 5 of the
draft RIA for additional discussions of these two methods.
For both methods, the agencies analyzed the impact of the proposed
rules and Alternative 4, relative to two different reference cases--
less dynamic and more dynamic. The less dynamic baseline projects very
little improvement in new vehicles in the absence of new Phase 2
standards. In contrast, the more dynamic baseline projects more
improvements in vehicle fuel efficiency. The agencies considered both
reference cases (for additional details, see Chapter 11 of the draft
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 the RIA Chapter 11 and
NHTSA's DEIS Chapters 3 and 5 for complete sets of these analyses. In
this section, Method A is presented for both the proposed standards
(i.e., Alternative 3--the agencies' preferred alternative) and for the
standards the agencies considered in Alternative 4, relative to both
the more dynamic baseline (Alternative 1b) and the less dynamic
baseline (Alternative 1a). Method B is presented also for the proposed
standards and Alternative 4, but relative only to the less dynamic
baseline. The agencies' intention for presenting both of these
complementary and coordinated analyses is to offer interested readers
the opportunity to compare the regulatory alternatives considered for
Phase 2 in both the context of our HD Phase 1 analytical approaches and
our light-duty vehicle analytical approaches. The agencies view these
analyses as corroborative and reinforcing: Both support agencies'
conclusion that the proposed standards are appropriate and at the
maximum feasible levels.
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 and the MOVES model. As described in Section VI, Method A uses
the CAFE model to estimate vehicular fuel consumption and emissions
impacts 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,\378\ used in the
LD GHG rulemakings,\379\ HD GHG Phase 1,\380\ 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 draft RIA. The
upstream tool used for the Method B can be found in the docket.\381\ As
noted in Section VI above, these analyses corroborate each other's
results.
---------------------------------------------------------------------------
\378\ 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
\379\ 2017 and Later Model Year Light-Duty Vehicle Greenhouse
Gas Emissions and Corporate Average Fuel Economy Standards (77 FR
62623, October 15, 2012).
\380\ Greenhouse Gas Emission Standards and Fuel Efficiency
Standards for Medium- and Heavy-Duty Engines and Vehicles (76 FR
57106, September 15, 2011).
\381\ Memorandum to the Docket ``Upstream Emissions Modeling
Files for HDGHG Phase 2 NPRM'' Docket No. EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
The agencies analyzed the anticipated emissions impacts of the
proposed rules and Alternative 4 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 proposed rules, only 2025, 2035 and 2050
will be shown) by comparing to both reference cases.\382\ Additional
runs were performed for just the three of the greenhouse gases
(CO2, CH4, and N2O) and for fuel
consumption for every calendar year from 2014 to 2050, inclusive, which
fed the economy-wide modeling, monetized greenhouse gas benefits
estimation, and climate impacts
[[Page 40392]]
analyses, discussed in sections below.\383\
---------------------------------------------------------------------------
\382\ The emissions impacts of the proposed rules on non-GHGs,
including air toxics, were also estimated using MOVES. See Section
VIII of the preamble for more information.
\383\ 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 agencies included
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 proposal.
---------------------------------------------------------------------------
B. Analysis of Fuel Consumption and GHG Emissions Impacts Resulting
From Proposed Standards and Alternative 4
The following sections describe the model inputs and assumptions
for both the less dynamic and more dynamic reference cases and the
control case representing the agencies' proposed fuel efficiency and
GHG standards. The agencies request comment on the model inputs,
projected reductions in energy rates and fuel consumption rates
presented in this section, as well as in Chapter 5 of the draft RIA.
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.\384\ 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.
---------------------------------------------------------------------------
\384\ Memorandum to the Docket ``Runspecs, Model Inputs, MOVES
Code and Database for HD GHG Phase 2 NPRM Emissions Modeling''
Docket No. EPA-HQ-OAR-2014-0827
---------------------------------------------------------------------------
(1) Model Inputs and Assumptions for the Less Dynamic Reference Case
The less dynamic reference case (identified as Alternative 1a in
Section X), includes the impact of Phase 1, but generally 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 proposed standards can be
evaluated. This case projects some 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. For other HD
vehicle sectors, no market-driven improvement in fuel efficiency was
assumed. For HD pickups and vans, the CAFE model was applied in a
manner that assumes manufacturers would only add fuel-saving technology
as needed to continue complying with Phase 1 standards. MOVES2014
defaults were used for all other parameters to estimate the emissions
inventories for this case. The less dynamic reference case assumed the
MOVES2014 default vehicle population and miles traveled estimates. The
growth in vehicle populations and miles traveled in MOVES2014 is based
on the relative annual VMT growth from AEO2014 Early Release for model
years 2012 and later.\385\
---------------------------------------------------------------------------
\385\ MOVES2014 assumes the population and VMT growth based on
the early release version of AEO2014 because it was the only version
that was available at the time of MOVES2014 development. Annual
Energy Outlook 2014. http://www.eia.gov/forecasts/aeo/er/ (last
accessed Feb 23, 2015).
\386\ 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).
---------------------------------------------------------------------------
(2) Model Inputs and Assumptions for the More Dynamic Reference Case
The more 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 would 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 would
continue to apply technologies for which increased purchase costs would
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 less dynamic
reference case.
(3) Model Inputs and Assumptions for ``Control'' Case
(a) Vocational Vehicles and Tractor-Trailers
The ``control'' case represents the agencies' proposed 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
proposed rules to develop the road load inputs for the control case,
based on the GEM analysis. The agencies also used 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 proposed rules to develop energy inputs for
the control case runs.
Table VII-1 and Table VII-2 describe the proposed improvements in
engine and vehicle efficiency from the proposed rules 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 the Chapter 5 of the
draft RIA.
Table VII-1--Estimated Reductions in Energy Rates for the Proposed Standards
----------------------------------------------------------------------------------------------------------------
Reduction from
Vehicle type Fuel Model years reference case
(percent)
----------------------------------------------------------------------------------------------------------------
Long-haul Tractor-Trailers and HHD Vocational. Diesel.......................... 2018-2020 1.3
2021-2023 5.2
2024-2026 9.7
2027+ 10.4
Short-haul Tractor-Trailers and HHD Vocational Diesel.......................... 2018-2020 0.9
[[Page 40393]]
2021-2023 5.0
2024-2026 9.5
2027+ 10.4
Single-Frame Vocational \386\................. Diesel and CNG.................. 2021-2023 5.3
2024-2026 8.9
2027+ 13.3
Gasoline........................ 2021-2023 3.3
2024-2026 5.4
2027+ 10.3
----------------------------------------------------------------------------------------------------------------
Table VII-2--Estimated Reductions in Road Load Factors for the Proposed Standards
----------------------------------------------------------------------------------------------------------------
Reduction in Reduction in
tire rolling aerodynamic Weight
Vehicle type Model years resistance drag reduction (LB)
coefficient coefficient \a\
(percent) (percent)
----------------------------------------------------------------------------------------------------------------
Combination Long-haul Tractor-Trailers....... 2018-2020 5.5 5.1 -131
2021-2023 9.8 15.3 -199
2024-2026 15.7 20.5 -246
2027+ 17.9 26.9 -304
Combination Short-haul Tractor-Trailers \387\ 2018-2020 4.0 1.6 -41
2021-2023 10.5 9.3 -79
2024-2026 13.9 12.3 -100
2027+ 17.6 15.9 -127
Intercity Buses.............................. 2021-2023 6.5 0 0
2024-2026 9.2 0 0
2027+ 16.5 0 0
Transit Buses................................ 2021-2023 0 0 0
2024-2026 2.9 0 0
2027+ 3.0 0 0
School Buses................................. 2021-2023 0 0 0
2024-2026 2.9 0 0
2027+ 4.0 0 0
Refuse Trucks................................ 2021-2023 0 0 20
2024-2026 2.9 0 20
2027+ 3.0 0 25
Single Unit Short-haul Trucks................ 2021-2023 4.8 0 5.8
2024-2026 8.3 0 5.8
2027+ 13.0 0 7
Single Unit Long-haul Trucks................. 2021-2023 6.5 0 20
2024-2026 9.2 0 20
2027+ 16.5 0 25
Motor Homes.................................. 2021-2023 3.0 0 0
2024-2026 6.2 0 0
2027+ 7.4 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 draft RIA.
In addition, the proposed CO2 standard for tractors
reflecting the use of auxiliary power units (APU) during extended
idling, 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.
---------------------------------------------------------------------------
\387\ 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
------------------------------------------------------------------------
APU
Vehicle type Model year penetration
\a\ (percent)
------------------------------------------------------------------------
Combination Long-Haul Trucks............ 2010-2020 30
2021-2023 80
[[Page 40394]]
2024+ 90
------------------------------------------------------------------------
Note:
\a\ The assumed APU penetration remains constant for model years 2024
and later.
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 proposed rules (also known as
the ``rebound effect'' and described in more detail in Chapter 5 of the
draft RIA), the control case assumed an increase in VMT from the
reference levels by 1.83 percent for the vocational vehicles and 0.79
percent for the combination tractor-trailers.
(b) Heavy-Duty Pickups and Vans
As explained above and as also discussed in the draft 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 the proposed 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 proposed standards for HD
pickups and vans--that is, the functions defining fuel consumption and
GHG targets that each depend work factor--increase in stringency by 2.5
percent annually during model years 2021-2027. The standards define
targets specific to each vehicle model, but no 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. The standards are
specified separately for gasoline and diesel vehicles, and vary with
work factor. Work factors could change, and today's analysis assumes
that some applications of mass reduction could enable increased work
factor in cases where manufacturers could increase a vehicle's rated
payload and/or towing capacity. Therefore, average required levels will
depend on the mix of vehicles and work factors of the vehicles produced
for sale in the U.S., and since these can only be estimated at this
time, average required and achieved fuel consumption and CO2
emission rates are subject to uncertainty. Between today's notice and
issuance of the ensuing final rule, the agencies intend to update the
market forecast (and other inputs) used to analyze HD pickup and van
standards, and expect that doing so will lead 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 proposed standards defining the Preferred Alternative.
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, the
proposed standards could reduce average required fuel consumption and
CO2 emission rates to about 4.86 gallons/100 miles and about
458 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 would, even absent today's proposed
standards, voluntarily make improvements that pay back within six
months, these model year 2027 levels are about 13.5 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 would, absent today's proposed standards, only apply
technology as required to achieve compliance, these model year 2027
levels are about 15 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 would 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 produce cadence).
[[Page 40395]]
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 mi.) Ave. achieved fuel cons. (gal./100 mi.)
Model year Stringency (vs. -----------------------------------------------------------------------------------------------
2018) (%) No action Proposed Reduction (%) No action Proposed Reduction (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2014.............................. MYs 2014-2020 6.41 6.41 0.0 6.21 6.21 0.0
2015.............................. Subject to Phase 1 6.41 6.41 0.0 6.12 6.12 0.0
2016.............................. Standards. 6.27 6.27 0.0 6.15 6.15 0.0
2017.............................. 6.11 6.11 0.0 5.89 5.88 0.2
2018.............................. 5.80 5.80 0.0 5.75 5.70 0.8
2019.............................. 5.78 5.78 0.0 5.72 5.68 0.7
2020.............................. 5.78 5.78 0.0 5.69 5.64 0.8
2021.............................. 2.5................. 5.77 5.64 2.2 5.63 5.42 3.8
2022.............................. 4.9................. 5.77 5.50 4.7 5.63 5.42 3.8
2023.............................. 7.3................. 5.77 5.38 6.8 5.63 5.28 6.3
2024.............................. 9.6................. 5.77 5.25 9.0 5.63 5.23 7.1
2025.............................. 11.9................ 5.77 5.12 11.4 5.63 4.99 11.5
2026.............................. 14.1................ 5.77 4.98 13.7 5.63 4.93 12.5
2027.............................. 16.2................ 5.77 4.86 15.8 5.62 4.86 13.7
2028*............................. 16.2................ 5.77 4.86 15.8 5.62 4.86 13.7
2029*............................. 16.2................ 5.77 4.86 15.8 5.62 4.85 13.7
2030*............................. 16.2................ 5.77 4.86 15.8 5.62 4.85 13.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.
*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 CO2 Emission Rates for Method A, Relative to Alternative
1b \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ave. required CO2 Rate (g./ Ave. achieved CO2 Rate (g./mi.)
Stringency (vs. mi.) ---------------------------------------------------------------
Model year 2018) (%) --------------------------------
No action Proposed Reduction No Action Proposed Reduction (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2014.............................. MYs 2014-2020 602 602 0.0 581 581 0.0
2015.............................. Subject to Phase 1 608 608 0.0 578 578 0.0
2016.............................. Standards. 593 593 0.0 580 580 0.0
2017.............................. 578 578 0.0 556 554 0.2
2018.............................. 548 548 0.0 543 538 0.8
2019.............................. 545 545 0.0 539 535 0.7
2020.............................. 545 545 0.0 536 532 0.8
2021.............................. 2.5................. 544 532 2.2 530 510 3.8
2022.............................. 4.9................. 544 519 4.7 530 510 3.8
2023.............................. 7.3................. 544 507 6.8 530 496 6.4
2024.............................. 9.6................. 544 495 9.1 530 492 7.2
2025.............................. 11.9................ 544 482 11.3 530 470 11.3
2026.............................. 14.1................ 544 470 13.6 530 465 12.3
2027.............................. 16.2................ 544 458 15.8 529 458 13.4
2028*............................. 16.2................ 544 458 15.8 529 458 13.4
2029*............................. 16.2................ 544 458 15.8 529 458 13.5
2030*............................. 16.2................ 544 458 15.8 529 458 13.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.
*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 1a \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ave. required fuel cons. (gal./100 mi.) Ave. achieved fuel cons. (gal./100 mi.)
Model year Stringency (vs. -----------------------------------------------------------------------------------------------
2018)(%) No action Proposed Reduction (%) No Action Proposed Reduction (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2014.............................. MYs 2014-2020 6.41 6.41 0.0 6.21 6.21 0.0
2015.............................. Subject to Phase 1 6.41 6.41 0.0 6.12 6.12 0.0
2016.............................. Standards. 6.27 6.27 0.0 6.15 6.15 0.0
2017.............................. 6.11 6.11 0.0 5.89 5.87 0.3
2018.............................. 5.80 5.80 **[caret]0.0 5.75 5.70 0.9
2019.............................. 5.78 5.78 0.0 5.73 5.68 0.8
2020.............................. 5.78 5.78 0.0 5.73 5.68 0.8
2021.............................. 2.5................. 5.77 5.64 2.3 5.72 5.44 4.8
2022.............................. 4.9................. 5.77 5.50 4.7 5.72 5.44 4.8
2023.............................. 7.3................. 5.77 5.38 6.8 5.72 5.29 7.6
[[Page 40396]]
2024.............................. 9.6................. 5.77 5.25 9.1 5.72 5.23 8.5
2025.............................. 11.9................ 5.77 5.12 11.4 5.72 4.98 12.9
2026.............................. 14.1................ 5.77 4.98 13.7 5.72 4.94 13.6
2027.............................. 16.2................ 5.77 4.86 15.8 5.72 4.87 14.9
2028*............................. 16.2................ 5.77 4.86 15.8 5.72 4.87 14.9
2029*............................. 16.2................ 5.77 4.86 15.8 5.72 4.86 15.0
2030*............................. 16.2................ 5.77 4.86 15.8 5.72 4.86 15.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.
*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 CO2 Emission Rates for Method A, Relative to Alternative
1a \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ave. required CO2 Rate (g./mi.) Ave. achieved CO2 Rate (g./mi.)
Model year Stringency (vs. -----------------------------------------------------------------------------------------------
2018) (%) No action Proposed Reduction (%) No action Proposed Reduction (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2014.............................. MYs 2014-2020 6.02 602 0.0 581 581 0.0
2015.............................. Subject to Phase 1 6.08 608 0.0 578 578 0.0
2016.............................. Standards. 593 593 0.0 580 580 0.0
2017.............................. 578 578 0.0 556 554 0.3
2018.............................. 548 548 **-0.0 543 538 0.9
2019.............................. 545 546 **-0.1 539 535 0.8
2020.............................. 545 545 **-0.1 539 535 0.8
2021.............................. 2.5................. 544 532 2.2 538 512 4.9
2022.............................. 4.9................. 544 519 4.7 538 512 4.9
2023.............................. 7.3................. 544 507 6.8 538 497 7.7
2024.............................. 9.6................. 544 495 9.1 538 492 8.6
2025.............................. 11.9................ 544 482 11.4 538 470 12.7
2026.............................. 14.1................ 544 470 13.6 538 466 13.4
2027.............................. 16.2................ 544 458 15.8 538 459 14.7
2028*............................. 16.2................ 544 458 15.8 538 459 14.7
2029*............................. 16.2................ 544 458 15.8 538 459 14.8
2030*............................. 16.2................ 544 458 15.8 538 459 14.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.
*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 CO2 emission rate.
While the above tables show the agencies' estimates of average fuel
consumption and CO2 emission rates manufacturers might
achieve under today's proposed 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 the proposed
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 by 1.18
percent for HD pickups and vans.
[[Page 40397]]
Table VII-8--Estimated Total Vehicle CO2 Reductions for the Proposed
Standards and In-Use Emissions for HD Pickup Trucks and Vans in Method B
\a\
------------------------------------------------------------------------
CO2
reduction
Vehicle type Fuel Model year from
reference
case (%)
------------------------------------------------------------------------
HD pickup trucks and vans.... Gasoline and 2021 2.50
Diesel.
2022 4.94
2023 7.31
2024 9.63
2025 11.89
2026 14.09
2027+ 16.24
------------------------------------------------------------------------
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.
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 proposed rules--fuel consumption reductions
from more efficient vehicles, emission reductions from both downstream
(tailpipe) and upstream (fuel production and distribution) sources, and
HFC emissions from the proposed air conditioning leakage standards. The
following subsections summarize two slightly different analyses of the
annual GHG emissions and fuel consumption reductions expected from
these proposed rules, as well as the reductions in GHG emissions and
fuel consumption expected over the lifetime of each heavy-duty vehicle
categories. In addition, because the agencies are carefully considering
Alternative 4 along with Alternative 3, the preferred alternative, the
results from both are presented here for the reader's reference.
Section VII. C. (1) shows the impacts of the proposed rules and
Alternative 4 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--less dynamic and more dynamic. Section VII. C. (2)
shows the impacts of the proposed standards and Alternative 4, relative
to the less dynamic reference case only, using the MOVES model for all
heavy-duty vehicle categories. NHTSA also analyzes these impacts
resulting from the proposed rules and reasonable alternatives in
Chapters 3 and 5 of its DEIS.
(1) Impacts of the Proposed Rules and Alternative 4 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
proposed 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 and
proposed standards defining the No-Action and Preferred alternatives,
respectively, using Method A. Table VII-9 shows results assuming
manufacturers would voluntarily make improvements that pay back within
six months (i.e., Alternative 1b). Table VII-10 shows results assuming
manufacturers would 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 GHG emissions (MMT CO2eq) over
fleet's useful life fleet's useful life
Model year -----------------------------------------------------------------------------
Reduction Reduction
No action Proposed (%) No action Proposed (%)
----------------------------------------------------------------------------------------------------------------
2014.............................. 9.41 9.41 0.0 115 115 0.0
2015.............................. 9.53 9.53 0.0 117 117 0.0
2016.............................. 9.72 9.72 0.0 119 119 0.0
2017.............................. 9.49 9.47 0.2 116 116 0.2
2018.............................. 9.26 9.19 0.7 113 113 0.7
2019.............................. 9.20 9.14 0.7 113 112 0.7
2020.............................. 9.19 9.12 0.7 112 112 0.7
2021.............................. 9.10 8.79 3.4 111 107 3.4
2022.............................. 9.13 8.82 3.4 112 108 3.4
2023.............................. 9.11 8.59 5.7 111 105 5.7
2024.............................. 9.32 8.72 6.4 114 107 6.4
[[Page 40398]]
2025.............................. 9.49 8.49 10.5 116 104 10.4
2026.............................. 9.67 8.56 11.5 118 105 11.3
2027.............................. 9.78 8.55 12.6 120 105 12.3
2028.............................. 9.90 8.66 12.6 121 106 12.3
2029.............................. 10.02 8.75 12.6 122 107 12.4
2030.............................. 10.03 8.76 12.6 123 107 12.4
----------------------------------------------------------------------------------------------------------------
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.
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 GHG Emissions (MMT CO2eq) over
fleet's useful life fleet's useful life
Model year -----------------------------------------------------------------------------
Reduction Reduction
No action Proposed (%) No action Proposed (%)
----------------------------------------------------------------------------------------------------------------
2014.............................. 9.41 9.41 0.0 115 115 0.0
2015.............................. 9.53 9.53 0.0 117 117 0.0
2016.............................. 9.72 9.72 0.0 119 119 0.0
2017.............................. 9.49 9.46 0.3 116 116 0.3
2018.............................. 9.27 9.19 0.8 114 113 0.8
2019.............................. 9.20 9.14 0.7 113 112 0.7
2020.............................. 9.25 9.18 0.7 113 112 0.8
2021.............................. 9.23 8.82 4.4 113 108 4.4
2022.............................. 9.26 8.85 4.4 113 108 4.4
2023.............................. 9.23 8.60 6.9 113 105 6.9
2024.............................. 9.45 8.72 7.7 116 107 7.7
2025.............................. 9.62 8.48 11.8 118 104 11.7
2026.............................. 9.81 8.58 12.5 120 105 12.3
2027.............................. 9.93 8.57 13.7 121 105 13.5
2028.............................. 10.05 8.68 13.7 123 106 13.5
2029.............................. 10.17 8.77 13.7 124 108 13.5
2030.............................. 10.18 8.78 13.7 124 108 13.5
----------------------------------------------------------------------------------------------------------------
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.
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 would appear sufficiently similar that
differences between Alternative 1a and Alternative 1b remain best
communicated by comparing values in the above tables.
[[Page 40399]]
[GRAPHIC] [TIFF OMITTED] TP13JY15.015
[[Page 40400]]
[GRAPHIC] [TIFF OMITTED] TP13JY15.016
Table VII-11 Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Preferred
Alternative vs. Alt 1b Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
Total
CY CO2 (MMT) CH4 (MMT N2O (MMT downstream
CO2eq) CO2eq)\9\ (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025........................................................ -26.9 -0.4 0 -27.2
2035........................................................ -86.0 -1.0 0 -86.9
2050........................................................ -121.6 -1.4 0 -123.0
----------------------------------------------------------------------------------------------------------------
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.
Table VII-12--Annual Fuel Savings in Calendar Years 2025, 2035 and 2050--
Preferred Alternative vs. Alt 1b Using Analysis Method A \a\
------------------------------------------------------------------------
Gasoline
Diesel savings savings
CY (billion (billion
gallons) gallons)
------------------------------------------------------------------------
2025.................................... 2.5 0.2
2035.................................... 7.6 0.9
2050.................................... 10.8 1.2
------------------------------------------------------------------------
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.
[[Page 40401]]
Table VII-13--Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Preferred
Alternative vs. Alt 1a Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
Total
CY CO2 (MMT) CH4 (MMT N2O (MMT downstream
CO2eq) CO2eq)\9\ (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025............................................ -27.7 -0.4 0 -28.1
2035............................................ -93.6 -1.0 0 -94.6
2050............................................ -133.5 -1.4 0 -134.9
----------------------------------------------------------------------------------------------------------------
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.
Table VII-14--Annual Fuel Savings in Calendar Years 2025, 2035 and 2050--
Preferred Alternative vs. Alt 1a Using Analysis Method A \a\
------------------------------------------------------------------------
Diesel Gasoline
savings savings
CY (billion (billion
gallons) gallons)
------------------------------------------------------------------------
2025.......................................... 2.5 0.2
2035.......................................... 8.3 1.0
2050.......................................... 11.9 1.3
------------------------------------------------------------------------
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.
Table VII-15--Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Alternative 4 vs.
Alt 1b Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
Total
CY CO2 (MMT) CH4 (MMT N2O (MMT downstream
CO2eq) CO2eq)\9\ (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025............................................ -33.2 -0.4 0 -33.5
2035............................................ -89.9 -1.0 0 -90.9
2050............................................ -122.6 -1.4 0 -124.0
----------------------------------------------------------------------------------------------------------------
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.
Table VII-16--Annual Fuel Savings in Calendar Years 2025, 2035 and 2050--
Alternative 4 vs. Alt 1b Using Analysis Method A \a\
------------------------------------------------------------------------
Diesel Gasoline
savings savings
CY (billion (billion
gallons) gallons)
------------------------------------------------------------------------
2025.......................................... 3.0 0.3
2035.......................................... 7.9 1.0
2050.......................................... 10.8 1.3
------------------------------------------------------------------------
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.
Table VII-17--Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Alternative 4 vs.
Alt 1a Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
Total
CY CO2 (MMT) CH4 (MMT N2O (MMT downstream
CO2eq) CO2eq) \9\ (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025............................................ -34.3 -0.4 0 -34.6
2035............................................ -97.7 -1.0 0 -98.7
2050............................................ -134.6 -1.4 0 -136.0
----------------------------------------------------------------------------------------------------------------
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.
[[Page 40402]]
Table VII-18--Annual Fuel Savings in Calendar Years 2025, 2035 and 2050--
Alternative 4 vs. Alt 1a Using Analysis Method A \a\
------------------------------------------------------------------------
Diesel Gasoline
savings savings
CY (billion (billion
gallons) gallons)
------------------------------------------------------------------------
2025.......................................... 3.1 0.3
2035.......................................... 8.6 1.1
2050.......................................... 12.0 1.3
------------------------------------------------------------------------
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.
(ii) Upstream (Fuel Production and Distribution) Emissions Projections
Table VII-19--Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Preferred Alternative
vs. Alt 1b Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CH4 (MMT N2O (MMT Total upstream
CY CO2 (MMT) CO2eq) CO2eq) (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025............................................ -8.4 -0.9 -0.1 -9.3
2035............................................ -26.6 -2.8 -0.2 -29.7
2050............................................ -37.7 -4.0 -0.3 -42.0
----------------------------------------------------------------------------------------------------------------
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.
Table VII-20--Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Preferred Alternative
vs. Alt 1a Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CH4 (MMT N2O (MMT Total upstream
CY CO2 (MMT) CO2eq) CO2eq) (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025............................................ -8.6 -0.9 -0.1 -9.6
2035............................................ -29.0 -3.1 -0.2 -32.3
2050............................................ -41.4 -4.4 -0.3 -46.1
----------------------------------------------------------------------------------------------------------------
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.
Table VII-21--Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Alternative 4 vs. Alt
1b Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CH4 (MMT N2O (MMT Total upstream
CY CO2 (MMT) CO2eq) CO2eq) (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025............................................ -10.3 -1.1 -0.1 -11.5
2035............................................ -27.8 -3.0 -0.2 -31.0
2050............................................ -38.0 -4.0 -0.3 -42.3
----------------------------------------------------------------------------------------------------------------
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.
Table VII-22--Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Alternative 4 vs. Alt
1a Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CH4 (MMT N2O (MMT Total upstream
CY CO2 (MMT) CO2eq) CO2eq) (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025............................................ -10.6 -1.1 -0.1 -11.8
2035............................................ -30.2 -3.2 -0.2 -33.7
2050............................................ -41.7 -4.4 -0.3 -46.5
----------------------------------------------------------------------------------------------------------------
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.
(iii) HFC Emissions Projections
The projected HFC emission reductions due to the proposed AC
leakage standards are 93,272 metric tons of CO2eq in 2025,
253,118 metric tons of CO2eq in 2035, and 299,590 metric
tons CO2eq in 2050.
(iv) Total (Downstream + Upstream + HFC) Emissions Projections
[[Page 40403]]
Table VII-23--Annual Total GHG Emissions Impacts in Calendar Years 2025,
2035 and 2050--Preferred Alternative vs. Alt 1b Using Analysis Method A
\a\
------------------------------------------------------------------------
2025 (MMT 2035 (MMT 2050 (MMT
CY CO2eq) CO2eq) CO2eq)
------------------------------------------------------------------------
Downstream................... -27.2.......... -86.9 -123.0
Upstream..................... -9.3........... -29.7 -42.0
HFC.......................... -0.09.......... -0.25 -0.3
Total.................... -36.4.......... -116.4 -164.7
------------------------------------------------------------------------
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.
Table VII-24--Annual Total GHG Emissions Impacts in Calendar Years 2025,
2035 and 2050 2050--Preferred Alternative vs. Alt 1a Using Analysis
Method A \a\
------------------------------------------------------------------------
2025 (MMT 2035 (MMT 2050 (MMT
CY CO2eq) CO2eq) CO2eq)
------------------------------------------------------------------------
Downstream................... -28.1.......... -94.6 -134.9
Upstream..................... -9.6........... -32.3 -46.1
HFC.......................... -0.09.......... -0.25 -0.3
Total.................... -37.6.......... -126.4 -180.7
------------------------------------------------------------------------
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.
Table VII-25--Annual Total GHG Emissions Impacts in Calendar Years 2025,
2035 and 2050--Alternative 4 vs. Alt 1b Using Analysis Method A \a\
------------------------------------------------------------------------
2025 (MMT 2035 (MMT 2050 (MMT
CY CO2eq) CO2eq) CO2eq)
------------------------------------------------------------------------
Downstream................... -33.5.......... -90.9 -124.0
Upstream..................... -11.5.......... -31.0 -42.3
HFC.......................... -0.09.......... -0.25 -0.3
Total.................... -44.9.......... -121.7 -166.0
------------------------------------------------------------------------
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.
Table VII-26--Annual Total GHG Emissions Impacts in Calendar Years 2025,
2035 and 2050 2050--Alternative 4 vs. Alt 1a Using Analysis Method A \a\
------------------------------------------------------------------------
2025 (MMT 2035 (MMT 2050 (MMT
CY CO2eq) CO2eq) CO2eq)
------------------------------------------------------------------------
Downstream................... -34.6.......... -98.7 -136.0
Upstream..................... -11.8.......... -33.7 -46.5
HFC.......................... -0.09.......... -0.25 -0.3
Total.................... -46.3.......... -132.2 -182.2
------------------------------------------------------------------------
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.
(b) Model Year Lifetime Analysis
Table VII-27--Lifetime GHG Reductions and Fuel Savings Using Analysis Method A--Summary for Model Years 2018-
2029 \a\
----------------------------------------------------------------------------------------------------------------
Alternative 3 (proposed) Alternative 4
----------------------------------------------------------------------------------------------------------------
1b (More 1a (Less 1b (More 1a (Less
No-Action Alternative (Baseline) Dynamic) Dynamic) Dynamic) Dynamic)
----------------------------------------------------------------------------------------------------------------
Fuel Savings (Billion Gallons).............................. 72.2 76.7 81.9 86.7
Total GHG Reductions (MMT CO2eq)........................ 974 1,034 1,102 1,166
Downstream (MMT CO2eq).............................. 726.1 771.3 821.9 870.3
Upstream (MMT CO2eq)................................ 247.7 262.9 279.9 296.1
----------------------------------------------------------------------------------------------------------------
Note:
[[Page 40404]]
\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.
(2) Impacts of the Proposed Rules and Alternative 4 using Analysis
Method B
(a) Calendar Year Analysis
(i) Downstream (Tailpipe) Emissions Projections
As described in Section VII. A., the Method B used MOVES to
estimate downstream GHG inventories from the proposed rules and
Alternative 4 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 proposed rules.\388\ 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 significantly
less for APUs than for on-road diesel engines during extended idling.
Overall, the downstream GHG emissions would be reduced significantly
and are described in the following subsections.
---------------------------------------------------------------------------
\388\ 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 proposed rules, resulting in a slight
increase in downstream N2O inventory.
---------------------------------------------------------------------------
Since fuel consumption is not directly modeled in MOVES, the total
energy consumption was run as a surrogate in MOVES. Then, the total
energy consumption was converted to fuel consumption based on the fuel
heating values assumed in the Renewable Fuels Standard rulemaking \389\
and used in the development of MOVES emission and energy rates.\390\
---------------------------------------------------------------------------
\389\ Renewable Fuels Standards assumptions of 115,000 BTU/
gallon gasoline (E0) and 76,330 BTU/gallon ethanol (E100) were
weighted 90% and 10%, respectively, for E10 and 85% and 15%,
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).
\390\ The conversion factor for diesel is 138,451 kJ/gallon. See
MOVES2004 Energy and Emission Inputs. EPA420-P-05-003, March 2005.
http://www.epa.gov/otaq/models/ngm/420p05003.pdf (last accessed Feb
23, 2015).
---------------------------------------------------------------------------
Table VII-28 and Table VII-29 show the impacts on downstream GHG
emissions and fuel savings in 2025, 2035 and 2050, relative to
Alternative 1a, for the preferred alternative and Alternative 4,
respectively.
Table VII-30 and Table VII-31 show the estimated fuel savings from
the preferred alternative and Alternative 4 in 2025, 2035, and 2050,
relative to Alternative 1a. For both GHG emissions and fuel savings,
the annual impacts are greater for Alternative 4 than the preferred
alternative in earlier years, but the differences become
indistinguishable by 2050. The results from the comparable analyses
relative to Alternative 1b are presented in Section VII. C. (1).
Table VII-28--Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Preferred
Alternative vs. Alt 1a Using Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
Total
CY CO2 (MMT) CH4 (MMT N2O (MMT downstream
CO2eq) CO2eq) (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025........................................................ -27.0 -0.4 0.002 -27.4
2035........................................................ -93.7 -1.0 0.004 -94.7
2050........................................................ -135.1 -1.4 0.005 -136.5
----------------------------------------------------------------------------------------------------------------
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.
Table VII-29--Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Alternative 4 vs.
Alt 1a using Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
Total
CY CO2 (MMT) CH4 (MMT N2O (MMT downstream
CO2eq) CO2eq) (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025........................................................ -33.3 -0.4 0.002 -33.7
2035........................................................ -97.3 -1.0 0.004 -98.3
2050........................................................ -135.5 -1.4 0.005 -136.9
----------------------------------------------------------------------------------------------------------------
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.
[[Page 40405]]
Table VII-30--Annual Fuel Savings in Calendar Years 2025, 2035 and 2050--
Preferred Alternative vs. Alt 1a using Analysis Method B \a\
------------------------------------------------------------------------
Diesel Gasoline
savings savings
CY (billion (billion
gallons) gallons)
------------------------------------------------------------------------
2025.......................................... 2.5 0.2
2035.......................................... 8.5 0.8
2050.......................................... 12.3 1.1
------------------------------------------------------------------------
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.
Table VII-31--Annual Fuel Savings in Calendar Years 2025, 2035 and 2050--
Alternative 4 vs. Alt 1a using Analysis Method B \a\
------------------------------------------------------------------------
Diesel Gasoline
savings savings
CY (billion (billion
gallons) gallons)
------------------------------------------------------------------------
2025.......................................... 3.1 0.3
2035.......................................... 8.8 0.9
2050.......................................... 12.3 1.1
------------------------------------------------------------------------
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.
(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 were based on
emission factors from DOE's ``Greenhouse Gases, Regulated Emissions,
and Energy Use in Transportation'' (GREET) model. In some cases, the
GREET values were modified or updated by the agencies to be consistent
with EPA's National Emissions Inventory (NEI), and emission factors
from MOVES. More information regarding these modifications can be found
in Chapter 5 of the draft RIA. These estimates show the impacts for
domestic emission reductions only. Additionally, since this rulemaking
is not expected to impact biofuel volumes mandated by the Annual
Renewable Fuel Standards (RFS) regulations \391\, the impacts on
upstream emissions from changes in biofuel feedstock (i.e.,
agricultural sources such as fertilizer, fugitive dust, and livestock)
are not shown. GHG emission reductions from upstream sources can be
found in Table VII-32 and Table VII-33 for preferred alternative and
Alternative 4, respectively.
---------------------------------------------------------------------------
\391\ 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.
Table VII-32--Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Preferred Alternative
vs. Alt 1a using Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
Total
CY CO2 (MMT) CH4 (MMT N2O (MMT uptream
CO2eq) CO2eq) (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025........................................................ -8.4 -0.9 -0.04 -9.3
2035........................................................ -29.1 -3.0 -0.14 -32.2
2050........................................................ -41.9 -4.4 -0.20 -46.5
----------------------------------------------------------------------------------------------------------------
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.
Table VII-33--Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050--Alternative 4 vs. Alt
1a using Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
Total
CY CO2 (MMT) CH4 (MMT N2O (MMT uptream
CO2eq) CO2eq) (MMT CO2eq)
----------------------------------------------------------------------------------------------------------------
2025........................................................ -10.4 -1.0 -0.1 -11.5
2035........................................................ -30.1 -3.2 -0.1 -33.4
2050........................................................ -42.0 -4.4 -0.2 -46.6
----------------------------------------------------------------------------------------------------------------
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.
(iii) HFC Emissions Projections
Based on projected HFC emission reductions due to the proposed AC
leakage standards, EPA estimates the HFC reductions to be 93,272 metric
tons of CO2eq in 2025, 253,118 metric tons of
CO2eq in 2035, and 299,590 metric tons CO2eq in
2050, as detailed in Chapters 5.3.4 of the draft RIA. EPA welcomes
comments on the methodology used to quantify the HFC emissions
benefits, as detailed in Chapter 5 of the draft RIA.
(iv) Total (Downstream + Upstream + HFC) Emissions Projections
Table VII-34 combines the impacts of the preferred alternative from
downstream (Table VII-28), upstream (Table VII-32), and HFC to
summarize the total GHG reductions in calendar years 2025, 2035 and
2050, relative to Alternative 1a. The combined impact of Alternative 4
on total GHG emissions are shown in Table VII-35.
Because of the differences in lead time, as expected, Alternative 4
shows greater annual GHG reductions in earlier years (i.e., calendar
year 2025), but by
[[Page 40406]]
2050, the preferred alternative and Alternative 4 show the same
magnitude of reductions in annual GHG emissions.
Table VII-34--Annual Total GHG Emissions Impacts in Calendar Years 2025,
2035 and 2050--Preferred Alternative vs. Alt 1a using Analysis Method B
\a\
------------------------------------------------------------------------
2025 (MMT 2035 (MMT 2050 (MMT
CY CO2eq) CO2eq) CO2eq)
------------------------------------------------------------------------
Downstream....................... -27.4 -94.7 -136.5
Upstream......................... -9.3 -32.2 -46.5
HFC.............................. -0.1 -0.25 -0.3
Total........................ -36.8 -127.2 -183.3
------------------------------------------------------------------------
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.
Table VII-35--Annual Total GHG Emissions Impacts in Calendar Years 2025,
2035 and 2050--Alternative 4 vs. Alt 1a using Analysis Method B \a\
------------------------------------------------------------------------
2025 (MMT 2035 (MMT 2050 (MMT
CY CO2eq) CO2eq) CO2eq)
------------------------------------------------------------------------
Downstream....................... -33.7 -98.3 -136.9
Upstream......................... -11.5 -33.4 -46.6
HFC.............................. -0.1 -0.25 -0.3
Total........................ -45.3 -132.0 -183.8
------------------------------------------------------------------------
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.
(b) Model Year Lifetime Analysis
In addition to the annual GHG emissions and fuel consumption
reductions expected from the proposed rules and Alternative 4, the
combined (downstream and upstream) GHG and fuel consumption impacts for
the lifetime of the impacted vehicles were estimated. Table VII-36
shows the fleet-wide GHG reductions and fuel savings from the preferred
alternative and Alternative 4, relative to Alternative 1a, through the
lifetime \392\ of heavy-duty vehicles. Compared to the preferred
alternative, Alternative 4 shows greater lifetime GHG reductions and
fuels savings by 12 percent and 13 percent, respectively. For the
lifetime GHG reductions and fuel savings by vehicle categories, see
Chapter 5 of the draft RIA.
---------------------------------------------------------------------------
\392\ A lifetime of 30 years is assumed in MOVES.
Table VII-36--Lifetime GHG Reductions and Fuel Savings using Analysis
Method B--Summary for Model Years 2018-2029 \a\
------------------------------------------------------------------------
Model years Alternative Alternative
----------------------------------------------- 3 4
(proposed) ------------
-------------
No-action alternative (baseline) 1a (less 1a (less
dynamic) dynamic)
------------------------------------------------------------------------
Fuel Savings (Billion Gallons)................ 75.8 85.4
Total GHG Reductions (MMT CO2eq).......... 1,036.4 1,163.1
Downstream (MMT CO2eq)................ 772.6 867.3
Upstream (MMT CO2eq).................. 263.8 295.8
------------------------------------------------------------------------
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.
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, and the 2017-2025 light-duty vehicle rulemaking,
and the proposed standards for new electricity utility generating
units. See 74 FR 66496; 75 FR 25491; 76 FR 57294; 77 FR 62894; 79 FR
1456-1459 (January 8, 2014). This section briefly discusses again some
of the climate impact of EPA's proposed actions in context of
transportation emissions. NHTSA has analyzed the climate impacts of its
specific proposed actions (i.e., excluding EPA's HFC regulatory
provisions) as well as reasonable alternative in its DEIS that
accompanies
[[Page 40407]]
this proposed rule. 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 proposed 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).\393\
---------------------------------------------------------------------------
\393\ 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.
---------------------------------------------------------------------------
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'') \394\ 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.
---------------------------------------------------------------------------
\394\ 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)
---------------------------------------------------------------------------
Based on these assessments, the EPA Administrator determined that
the emissions from new motor vehicles and engines contributes 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.\395\ These
assessments include the ``Special Report on Managing the Risks of
Extreme Events and Disasters to Advance Climate Change Adaptation''
\396\, the 2013-14 Fifth Assessment Report (AR5),\397\ the 2014
National Climate Assessment report,\398\ the ``Ocean Acidification: A
National Strategy to Meet the Challenges of a Changing Ocean,'' \399\
``Report on Climate Stabilization Targets: Emissions, Concentrations,
and Impacts over Decades to Millennia,'' \400\ ``National Security
Implications for U.S. Naval Forces'' (National Security
Implications),\401\ ``Understanding Earth's Deep Past: Lessons for Our
Climate Future,'' \402\ ``Sea Level Rise for the Coasts of California,
Oregon, and Washington: Past, Present, and Future,'' \403\ ``Climate
and Social Stress: Implications for Security Analysis,'' \404\ and
``Abrupt Impacts of Climate Change'' (Abrupt Impacts) assessments.\405\
---------------------------------------------------------------------------
\395\ ``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'').
\396\ Intergovernmental Panel on Climate Change (IPCC). 2012:
Managing the Risks of Extreme Events and Disasters to Advance
Climate Change Adaption. 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.
\397\ 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.
\398\ 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.
\399\ National Research Council (NRC). 2010. Ocean
Acidification: A National Strategy to Meet the Challenges of a
Changing Ocean. National Academies Press. Washington, DC.
\400\ National Research Council (NRC). 2011. Climate
Stabilization Targets: Emissions, Concentrations, and Impacts over
Decades to Millennia. National Academies Press, Washington, DC.
\401\ National Research Council (NRC) 2011. National Security
Implications of Climate Change for U.S. Naval Forces. National
Academies Press. Washington, DC.
\402\ 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.
\403\ 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.
\404\ National Research Council (NRC). 2013. Climate and Social
Stress: Implications for Security Analysis. National Academies
Press. Washington, DC.
\405\ National Research Council (NRC). 2013. Abrupt Impacts of
Climate Change: Anticipating Surprises. National Academies Press.
Washington, DC.
---------------------------------------------------------------------------
EPA has reviewed these assessments and finds that in general, the
improved understanding of the climate system they present are
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
[[Page 40408]]
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 proposed
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 proposed 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 proposed
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 \406\ coupled with the MAGICC (Model for
the Assessment of Greenhouse-gas Induced Climate Change) simple climate
model.\407\ 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 emissions reductions associated with these rules, a simple
climate model such as MAGICC is appropriate for estimating the
atmospheric and climate response.
---------------------------------------------------------------------------
\406\ 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.
\407\ 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.
---------------------------------------------------------------------------
The analysis projects that the proposed rules would 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-37, demonstrate that relative to the
[[Page 40409]]
reference case, by 2100 projected atmospheric CO2
concentrations are estimated to be reduced by 1.1 to 1.2 part per
million by volume (ppmv), global mean temperature is estimated to be
reduced by 0.0026 to 0.0065 [deg]C, and sea-level rise is projected to
be reduced by approximately 0.023 to 0.057 cm, based on a range of
climate sensitivities (described below). Details about this modeling
analysis can be found in the draft RIA Chapter 6.3.
Table VII-37--Impact of GHG Emissions Reductions on Projected Changes in Global Climate Associated With Proposed
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 CO2 CONCENTRATION....... ppmv................... 2100 -1.1 to -1.2
Global Mean Surface Temperature..... [deg]C................. 2100 -0.0026 to -0.0065
Sea Level Rise...................... cm..................... 2100 -0.023 to -0.057
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 seal 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 proposed 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 proposed Phase 2
standards would 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 draft 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-37 to estimate
changes in these impacts associated with this proposed 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.\408\ 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.
---------------------------------------------------------------------------
\408\ 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)
---------------------------------------------------------------------------
EPA's analysis of this proposed 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.
VIII. How will this proposed action impact non-GHG emissions and their
associated effects?
The proposed heavy-duty vehicle standards are expected to influence
the emissions of criteria air pollutants and several air toxics. This
section describes the projected impacts of the proposed rules and
Alternative 4 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 proposed rules and reasonable alternatives in Chapter 4 of its
DEIS.
A. Emissions Inventory Impacts
As described in Section VII, the agencies conducted coordinated and
complementary analyses for these rules by employing both 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 complementary analyses using the CAFE model (``Method A'')
and the MOVES model (``Method B'') to estimate non-GHG emissions from
these vehicles. For both methods, the agencies analyzed the impact of
the proposed rules, relative to two different reference cases--less
dynamic and more dynamic. The less dynamic baseline projects very
little improvement in new vehicles in the absence of new Phase 2
standards. In contrast, the more dynamic baseline
[[Page 40410]]
projects more 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 the RIA Chapter 11 and
NHTSA's DEIS Chapters 3 and 5 for complete sets of these analyses. In
this section, Method A is presented for both the proposed standards
(i.e., Alternative 3--the agencies' preferred alternative) and for the
standards the agencies considered in Alternative 4, relative to both
the more dynamic baseline (Alternative 1b) and the less dynamic
baseline (Alternative 1a). Method B is presented also for the proposed
standards and Alternative 4, but relative only to the less dynamic
baseline. The agencies' intention for presenting both of these
complementary and coordinated analyses is to offer interested readers
the opportunity to compare the regulatory alternatives considered for
Phase 2 in both the context of our HD Phase 1 analytical approaches and
our light-duty vehicle analytical approaches. The agencies view these
analyses as corroborative and reinforcing: Both support agencies'
conclusion that the proposed standards are appropriate and at the
maximum feasible levels.
The following subsections summarize two slightly different analyses
of the annual non-GHG emissions reductions expected from the proposed
standards and Alternative 4. Section VIII. A. (1) presents the impacts
of the proposed rules and Alternative 4 on non-GHG emissions using the
analytical Method A, relative to two different reference cases--less
dynamic and more dynamic. Section VIII. A. (2) presents the impacts of
the proposed standards and Alternative 4, relative to the less dynamic
reference case only, using the MOVES model for all heavy-duty vehicle
categories.
(1) Impacts of the Proposed Rules and Alternative 4 Using Analysis
Method A
(a) Calendar Year Analysis
(i) Upstream Impacts of the Proposed Program and Alternative 4
Increasing efficiency in heavy-duty vehicles would result in
reduced fuel demand, and therefore, reductions in the emissions
associated with all processes involved in getting petroleum to the
pump. Both Method A and Method B project these impacts for fuel
consumed by vocational vehicles and combination tractor-trailers, using
the same methods. See Section VIII.A.(2) (a)(i) 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 draft RIA.
The following four tables summarize the projected upstream emission
impacts of the preferred alternative and Alternative 4 on both criteria
pollutants and air toxics from the heavy-duty sector, relative to
Alternative 1b (more dynamic baseline conditions under the No-Action
Alternative) and Alternative 1a (less dynamic baseline conditions under
the No-Action Alternative).
Table VIII-1--Annual Upstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar
Years 2025, 2035 and 2050--Preferred Alternative vs. Alt 1b using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -1 -5 -3 -14 -5 -17
Acetaldehyde...................... -3 -3 -10 -11 -15 -13
Acrolein.......................... 0 -4 -1 -12 -2 -15
Benzene........................... -21 -4 -74 -13 -104 -15
CO................................ -3,798 -5 -12,087 -14 -17,120 -17
Formaldehyde...................... -19 -5 -59 -14 -84 -17
NOX............................... -9,472 -5 -30,333 -14 -42,839 -17
PM2.5............................. -1,019 -5 -3,257 -14 -4,609 -17
SOX............................... -5,983 -5 -19,190 -14 -27,074 -17
VOC............................... -3,066 -4 -11,029 -13 -15,386 -15
----------------------------------------------------------------------------------------------------------------
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.
Table VIII-2--Annual Upstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar
Years 2025, 2035 and 2050--Alternative 4 vs. Alt 1b using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -1 -6 -3 -15 -5 -17
Acetaldehyde...................... -4 -5 -11 -12 -15 -14
Acrolein.......................... -1 -5 -1 -13 -2 -15
Benzene........................... -28 -5 -78 -13 -105 -16
CO................................ -4,679 -6 -12,640 -15 -17,263 -17
Formaldehyde...................... -23 -6 -62 -15 -85 -17
NOX............................... -11,708 -6 -31,769 -15 -43,263 -17
PM2.5............................. -1,259 -6 -3,408 -15 -4,649 -17
SOX............................... -7,402 -6 -20,107 -15 -27,356 -17
[[Page 40411]]
VOC............................... -4,081 -5 -11,717 -13 -15,645 -15
----------------------------------------------------------------------------------------------------------------
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.
Table VIII-3--Annual Upstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar
Years 2025, 2035 and 2050--Preferred Alternative vs. Alt 1a using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -1 -5 -4 -15 -5 -18
Acetaldehyde...................... -3 -3 -11 -12 -16 -14
Acrolein.......................... 0 -4 -1 -13 -2 -15
Benzene........................... -22 -4 -80 -14 -113 -16
CO................................ -3,911 -5 -13,153 -15 -18,794 -18
Formaldehyde...................... -19 -5 -65 -15 -92 -18
NOX............................... -9,787 -5 -33,021 -15 -47,028 -18
PM2.5............................. -1,051 -5 -3,545 -15 -5,058 -18
SOX............................... -6,189 -5 -20,896 -15 -29,726 -18
VOC............................... -3,193 -4 -11,848 -13 -16,625 -16
----------------------------------------------------------------------------------------------------------------
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.
Table VIII-4--Annual Upstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar
Years 2025, 2035 and 2050--Alternative 4 vs. Alt 1a using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -1 -6 -4 -16 -5 -18
Acetaldehyde...................... -4 -5 -12 -12 -16 -14
Acrolein.......................... -1 -5 -1 -13 -2 -16
Benzene........................... -29 -5 -84 -14 -114 -17
CO................................ -4,816 -6 -13,720 -16 -18,945 -18
Formaldehyde...................... -24 -6 -67 -16 -93 -18
NOX............................... -12,098 -6 -34,501 -16 -47,477 -18
PM2.5............................. -1,298 -6 -3,700 -16 -5,101 -18
SOX............................... -7,658 -6 -21,843 -16 -30,024 -18
VOC............................... -4,251 -5 -12,541 -14 -16,870 -16
----------------------------------------------------------------------------------------------------------------
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.
(ii) Downstream Impacts of the Proposed Program and Alternative 4
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 the
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 draft RIA. The
following four tables summarize the projected downstream emission
impacts of the preferred alternative and Alternative 4 on both criteria
pollutants and air toxics from the heavy-duty sector, relative to
Alternative 1b and Alternative 1a.
[[Page 40412]]
Table VIII-5--Annual Downstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar
Years 2025, 2035 and 2050--Preferred Alternative vs. Alt 1b using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -8 -3 -21 -12 -30 -16
Acetaldehyde...................... -669 -10 -1,882 -31 -2,667 -36
Acrolein.......................... -97 -10 -272 -31 -385 -37
Benzene........................... -123 -6 -347 -19 -490 -24
CO................................ -26,485 -3 -75,199 -8 -106,756 -9
Formaldehyde...................... -2,100 -12 -5,910 -32 -8,376 -37
NOX............................... -92,444 -7 -260,949 -28 -370,663 -34
PM2.5 \b\......................... 643 2 1,722 8 2,410 10
SOX............................... -229 -4 -715 -13 -1,026 -15
VOC............................... -13,161 -6 -38,051 -21 -54,139 -26
----------------------------------------------------------------------------------------------------------------
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\ Positive number means emissions would increase from reference to control case. PM2.5 from tire wear and
brake wear are included.
Table VIII-6--Annual Downstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar
Years 2025, 2035 and 2050--Alternative 4 vs. Alt 1b using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -8 -2 -21 -12 -30 -16
Acetaldehyde...................... -669 -10 -1,882 -31 -2,667 -36
Acrolein.......................... -97 -10 -271 -31 -385 -37
Benzene........................... -124 -6 -347 -19 -490 -24
CO................................ -26,705 -3 -75,407 -8 -106,874 -9
Formaldehyde...................... -2,100 -12 -5,908 -32 -8,375 -37
NOX............................... -93,984 -8 -262,150 -28 -370,704 -34
PM2.5 \b\......................... 619 2 1,705 8 2,412 10
SOX............................... -280 -5 -742 -13 -1,029 -15
VOC............................... -13,925 -7 -38,472 -22 -54,150 -26
----------------------------------------------------------------------------------------------------------------
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\ Positive number means emissions would increase from reference to control case. PM2.5 from tire wear and
brake wear are included.
Table VIII-7--Annual Downstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar
Years 2025, 2035 and 2050--Preferred Alternative vs. Alt 1a using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -8 -3 -21 -12 -30 -16
Acetaldehyde...................... -669 -10 -1,880 -31 -2,664 -36
Acrolein.......................... -97 -10 -271 -31 -384 -37
Benzene........................... -123 -6 -346 -19 -490 -24
CO................................ -26,576 -3 -75,571 -8 -107,287 -9
Formaldehyde...................... -2,100 -12 -5,904 -32 -8,369 -37
NOX............................... -93,197 -8 -266,890 -29 -380,303 -35
PM2.5 \b\......................... 632 2 1,635 8 2,267 9
SOX............................... -232 -4 -776 -14 -1,125 -16
VOC............................... -13,210 -6 -38,964 -22 -55,628 -26
----------------------------------------------------------------------------------------------------------------
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\ Positive number means emissions would increase from reference to control case. PM2.5 from tire wear and
brake wear are included.
[[Page 40413]]
Table VIII-8--Annual Downstream Impacts on Criteria Pollutants and Air Toxics from Heavy-Duty Sector in Calendar
Years 2025, 2035 and 2050--Alternative 4 vs. Alt 1a using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -8 -2 -21 -12 -29 -16
Acetaldehyde...................... -668 -10 -1,880 -31 -2,664 -36
Acrolein.......................... -97 -10 -271 -31 -384 -37
Benzene........................... -124 -6 -346 -19 -489 -24
CO................................ -26,821 -3 -75,795 -8 -107,414 -9
Formaldehyde...................... -2,099 -12 -5,902 -32 -8,367 -37
NOX............................... -94,724 -8 -268,075 -29 -380,328 -35
PM2.5 \b\......................... 609 2 1,618 8 2,269 9
SOX............................... -282 -5 -803 -14 -1,127 -16
VOC............................... -13,971 -7 -39,383 -22 -55,638 -26
----------------------------------------------------------------------------------------------------------------
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\ Positive number means emissions would increase from reference to control case. PM2.5 from tire wear and
brake wear are included.
(iii) Total Impacts of the Proposed Program and Alternative 4
The following four tables summarize the projected upstream emission
impacts of the preferred alternative and Alternative 4 on both criteria
pollutants and air toxics from the heavy-duty sector, relative to
Alternative 1b and Alternative 1a.
Table VIII-9--Annual Total Impacts (Upstream and Downstream) of Criteria Pollutants and Air Toxics From Heavy-
Duty Sector in Calendar Years 2025, 2035 and 2050--Preferred Alternative vs. Alt 1b Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % reduction tons % reduction tons % reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -9 -3 -25 -13 -34 -16
Acetaldehyde...................... -672 -10 -1,893 -30 -2,682 -36
Acrolein.......................... -97 -10 -273 -31 -387 -37
Benzene........................... -145 -5 -421 -18 -595 -22
CO................................ -30,282 -3 -87,286 -8 -123,876 -10
Formaldehyde...................... -2,119 -11 -5,969 -32 -8,460 -37
NOX............................... -101,916 -7 -291,282 -26 -413,501 -31
PM2.5............................. -376 -1 -1,535 -3 -2,199 -4
SOX............................... -6,213 -5 -19,905 -14 -28,101 -17
VOC............................... -16,227 -6 -49,080 -18 -69,525 -22
----------------------------------------------------------------------------------------------------------------
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.
Table VIII-10--Annual Total Impacts (Upstream and Downstream) of Criteria Pollutants and Air Toxics From Heavy-
Duty Sector in Calendar Years 2025, 2035 and 2050--Alternative 4 vs. Alt 1b Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % reduction tons % reduction tons % reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -9 -3 -25 -13 -34 -16
Acetaldehyde...................... -673 -10 -1,893 -30 -2,682 -36
Acrolein.......................... -97 -10 -273 -31 -387 -37
Benzene........................... -152 -6 -426 -18 -595 -22
CO................................ -31,383 -3 -88,047 -8 -124,137 -10
Formaldehyde...................... -2,123 -11 -5,970 -32 -8,460 -37
NOX............................... -105,693 -7 -293,918 -26 -413,967 -31
PM2.5............................. -639 -1 -1,703 -4 -2,237 -4
SOX............................... -7,682 -6 -20,849 -15 -28,385 -17
[[Page 40414]]
VOC............................... -18,006 -6 -50,189 -19 -69,796 -22
----------------------------------------------------------------------------------------------------------------
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.
Table VIII-11--Annual Total Impacts (Upstream and Downstream) of Criteria Pollutants and Air Toxics From Heavy-
Duty Sector in Calendar Years 2025, 2035 and 2050--Preferred Alternative vs. Alt 1a Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % reduction tons % reduction tons % reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -9 -3 -25 -13 -35 -16
Acetaldehyde...................... -672 -10 -1,891 -30 -2,680 -36
Acrolein.......................... -97 -10 -273 -31 -386 -37
Benzene........................... -145 -5 -425 -18 -603 -22
CO................................ -30,487 -3 -88,724 -8 -126,081 -10
Formaldehyde...................... -2,119 -11 -5,969 -32 -8,461 -37
NOX............................... -102,983 -7 -299,911 -26 -427,332 -32
PM2.5............................. -419 -1 -1,910 -4 -2,791 -5
SOX............................... -6,421 -5 -21,672 -15 -30,850 -18
VOC............................... -16,403 -6 -50,812 -19 -72,253 -23
----------------------------------------------------------------------------------------------------------------
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.
Table VIII-12--Annual Total Impacts (Upstream and Downstream) of Criteria Pollutants and Air Toxics From Heavy-
Duty Sector in Calendar Years 2025, 2035 and 2050--Alternative 4 vs. Alt 1a Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % reduction tons % reduction tons % reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -9 -3 -25 -13 -35 -16
Acetaldehyde...................... -672 -10 -1,891 -30 -2,679 -36
Acrolein.......................... -97 -10 -273 -31 -386 -37
Benzene........................... -153 -6 -430 -18 -603 -22
CO................................ -31,637 -3 -89,514 -8 -126,360 -10
Formaldehyde...................... -2,123 -11 -5,969 -32 -8,460 -37
NOX............................... -106,822 -7 -302,575 -26 -427,805 -32
PM2.5............................. -689 -1 -2,082 -5 -2,833 -5
SOX............................... -7,941 -6 -22,646 -16 -31,151 -18
VOC............................... -18,222 -6 -51,924 -19 -72,509 -23
----------------------------------------------------------------------------------------------------------------
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.
(b) Model Year Lifetime Analysis
Table VIII-13--Lifetime Non-GHG Reductions Using Analysis Method A--Summary for Model Years 2018-2029 (US Short
Tons) \a\
----------------------------------------------------------------------------------------------------------------
Alternative 3 (proposed) Alternative 4
-----------------------------------------------------------------------
No-action alternative (baseline) 1b (more 1a (less 1b (more 1a (less
dynamic) dynamic) dynamic) dynamic)
----------------------------------------------------------------------------------------------------------------
NOX..................................... 2,359,548 2,409,738 2,420,931 2,472,021
Downstream.......................... 2,103,163 2,137,232 2,130,659 2,164,458
[[Page 40415]]
Upstream............................ 256,385 272,506 290,272 307,563
PM2.5................................... 13,496 15,706 17,524 19,839
Downstream \b\...................... -14,051 -13,546 -13,649 -13,153
Upstream............................ 27,547 29,252 31,173 32,992
SOX..................................... 167,415 177,948 189,670 200,992
Downstream.......................... 5,326 5,562 6,079 6,311
Upstream............................ 162,089 172,386 183,591 194,681
----------------------------------------------------------------------------------------------------------------
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\ Negative number means emissions would increase from reference to control case. PM2.5 from tire wear and
brake wear are included.
(2) Impacts of the Proposed Rules and Alternative 4 using Analysis
Method B
(a) Calendar Year Analysis
(i) Upstream Impacts of the Proposed Program and Alternative 4
Increasing efficiency in heavy-duty vehicles would result in
reduced fuel demand, and therefore, reductions in the emissions
associated with all processes involved in getting petroleum to the
pump. 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,\409\ used
in the LD GHG rulemakings,\410\ HD GHG Phase 1,\411\ 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
draft RIA.
---------------------------------------------------------------------------
\409\ 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.
\410\ 2017 and Later Model Year Light-Duty Vehicle Greenhouse
Gas Emissions and Corporate Average Fuel Economy Standards (77 FR
62623, October 15, 2012).
\411\ Greenhouse Gas Emission Standards and Fuel Efficiency
Standards for Medium- and Heavy-Duty Engines and Vehicles (76 FR
57106, September 15, 2011).
---------------------------------------------------------------------------
Table VIII-14 and Table VIII-15 summarizes the projected upstream
emission impacts of the Preferred Alternative and Alternative 4 on both
criteria pollutants and air toxics from the heavy-duty sector, relative
to Alternative 1a. The comparable estimates relative to Alternative 1b
are presented in Section VIII. A. (1).
Table VIII-14--Annual Upstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar
Years 2025, 2035 and 2050--Preferred Alternative vs. Alt 1a Using Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -1 -5.0 -4 -15.3 -5 -18.4
Acetaldehyde...................... -4 -3.0 -18 -11.9 -26 -14.6
Acrolein.......................... -0.5 -3.4 -2 -12.7 -3 -15.5
Benzene........................... -24 -3.8 -92 -13.4 -132 -16.3
CO................................ -3,798 -4.9 -13,001 -15.3 -18,772 -18.4
Formaldehyde...................... -19 -4.7 -67 -14.9 -98 -18.0
NOX............................... -9,282 -4.9 -31,782 -15.3 -45,888 -18.4
PM2.5............................. -1,020 -4.9 -3,514 -15.2 -5,072 -18.2
SOX............................... -5,817 -4.9 -19,902 -15.3 -28,736 -18.4
VOC............................... -3,283 -3.7 -12,724 -13.2 -18,214 -16.1
----------------------------------------------------------------------------------------------------------------
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.
[[Page 40416]]
Table VIII-15--Annual Upstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar
Years 2025, 2035 and 2050--Alternative 4 vs. Alt 1a Using Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -1 -6.1 -4 -15.9 -5 -18.4
Acetaldehyde...................... -6 -4.3 -20 -12.6 -26 -14.7
Acrolein.......................... -1 -4.7 -2 -13.3 -3 -15.5
Benzene........................... -32 -5.0 -97 -14.0 -133 -16.3
CO................................ -4,661 -6.1 -13,485 -15.9 -18,812 -18.4
Formaldehyde...................... -24 -5.9 -70 -15.5 -97 -18.0
NOX............................... -11,393 -6.1 -32,965 -15.9 -45,986 -18.4
PM2.5............................. -1,256 -6.0 -3,647 -15.7 -5,083 -18.3
SOX............................... -7,137 -6.1 -20,641 -15.9 -28,797 -18.4
VOC............................... -4,342 -4.9 -13,326 -13.8 -18,273 -16.1
----------------------------------------------------------------------------------------------------------------
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.
(ii) Downstream Impacts of the Proposed Program and Alternative 4
Both the proposed program and Alternative 4 would 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 are
expecting reductions in downstream emissions of NOX, 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.
Additional reductions in tailpipe emissions of NOX and CO
and refueling emissions of VOC would 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,\412\ non-GHG emissions would increase very slightly due to VMT
rebound. In addition, brake wear and tire wear emissions of
PM2.5 would also increase very slightly due to VMT rebound.
The agencies estimate that downstream emissions of SOX would
be reduced, because they are roughly proportional to fuel consumption.
Alternative 4 would have directionally similar effects as the preferred
alternative.
---------------------------------------------------------------------------
\412\ 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, agencies used MOVES
to determine non-GHG emissions impacts of the proposed rules and
Alternative 4, relative to the less dynamic baseline (Alternative 1a).
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.
(Note that for the comparable analysis as described in Section VIII. A.
(1), Method A used DOT's CAFE model). Further information about the
modeling using DOT's CAFE and MOVES model is available in Section VII
and Chapter 5 of the draft RIA.
The downstream criteria pollutant and air toxics impacts of the
Preferred Alternative and Alternative 4, relative to Alternative 1a,
are presented in Table VIII-16 and Table VIII-17, respectively.
Table VIII-16--Annual Downstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in
Calendar Years 2025, 2035 and 2050--Preferred Alternative vs. Alt 1a Using Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -8 -2.6 -22 -15.1 -31 -19.6
Acetaldehyde...................... -670 -10.3 -1,884 -31.0 -2,671 -36.5
Acrolein.......................... -97 -9.9 -272 -31.6 -385 -37.3
Benzene........................... -125 -5.9 -353 -21.0 -501 -25.7
CO................................ -25,824 -1.7 -72,960 -6.0 -103,887 -7.6
Formaldehyde...................... -2,102 -11.5 -5,911 -32.1 -8,379 -37.5
NOX............................... -93,220 -7.5 -267,125 -29.1 -380,721 -35.2
PM2.5 \b\......................... 634 1.6 1,631 7.6 2,257 9.1
SOX............................... -254 -4.8 -876 -15.0 -1,264 -18.1
VOC............................... -13,440 -6.4 -40,148 -21.7 -57,308 -26.1
----------------------------------------------------------------------------------------------------------------
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\ Positive number means emissions would increase from reference to control case. PM2.5 from tire wear and
brake wear are included.
[[Page 40417]]
Table VIII-17--Annual Downstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in
Calendar Years 2025, 2035 and 2050--Alternative 4 vs. Alt 1aUsing Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
tons % Reduction tons % Reduction tons % Reduction
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -8 -2.6 -22 -15.1 -31 -19.6
Acetaldehyde...................... -670 -10.3 -1,884 -31.0 -2,671 -36.5
Acrolein.......................... -97 -9.9 -272 -31.6 -385 -37.3
Benzene........................... -126 -5.9 -354 -21.0 -501 -25.7
CO................................ -25,919 -1.7 -73,041 -6.0 -103,891 -7.6
Formaldehyde...................... -2,101 -11.5 -5,910 -32.1 -8,378 -37.5
NOX............................... -94,787 -7.6 -268,373 -29.2 -380,810 -35.2
PM2.5 \b\......................... 610 1.5 1,611 7.5 2,256 9.1
SOX............................... -313 -5.9 -909 -15.6 -1,267 -18.1
VOC............................... -14,310 -6.8 -40,640 -22.0 -57,348 -26.1
----------------------------------------------------------------------------------------------------------------
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\ Positive number means emissions would increase from reference to control case. PM2.5 from tire wear and
brake wear are included.
As shown in Table VIII-16, a net increase in downstream
PM2.5 emissions is expected. Although the improvements in
engine efficiency and road load are expected to reduce tailpipe
emissions of PM2.5, the projected increased use \413\ of
APUs would lead to higher PM2.5 emissions that more than
offset the reductions from the tailpipe, since engines powering APUs
are currently required to meet less stringent PM standards than on-road
engines. Therefore, EPA conducted an evaluation of a program that would
reduce the unintended consequence of increase in PM2.5
emissions from increased APU use by fitting the APU with a diesel
particulate filter or having the APU exhaust plumbed into the vehicle's
exhaust system upstream of the particulate matter aftertreatment
device. Such program requiring additional PM2.5 controls on
APU could significantly reduce PM2.5 emissions, as shown in
Table VIII-18 below. For additional details, see Section III.C.3 of the
preamble.
---------------------------------------------------------------------------
\413\ The projected use of APU during extended idling is
presented in Table VII-3 of the preamble.
Table VIII-18--Projected Impact on PM2.5 Emissions of Further PM2.5 Control on APUs--Preferred Alternative vs.
Alt 1a Using Analysis Method B (US Short Tons) \a\
----------------------------------------------------------------------------------------------------------------
Proposed
program Proposed
inventory program Net impact of
CY without inventory with further PM2.5
further PM2.5 further PM2.5 control on
control on control on APUs
APUs APUs
----------------------------------------------------------------------------------------------------------------
2035............................................................ 23,083 19,999 -3,084
2050............................................................ 26,932 22,588 -4,344
----------------------------------------------------------------------------------------------------------------
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.
It is worth noting that the emission reductions shown in Table
VIII-16 are not incremental to the emissions reductions projected in
the Phase 1 rulemaking. This is because, as described in Sections
III.D.2.a of the preamble, the agencies have revised their assumptions
about the adoption rate of APUs. This proposal assumes that without the
proposed Phase 2 program (i.e., in the Phase 2 reference case), the APU
adoption rate will be 30 percent for model years 2010 and later, which
is the value used in the Phase 1 reference case. EPA conducted an
analysis to estimate the combined emissions impacts of the Phase 1 and
the proposed Phase 2 programs for NOX, VOC, SOX
and PM2.5 in calendar year 2050 using MOVES2014. The results
are shown in Table VIII-19. For NOX and PM2.5
only, we estimated the combined Phase 1 and Phase 2 downstream and
upstream emissions impacts for calendar year 2025, and project that the
two rules combined would reduce NOX by up to 120,000 tons
and PM2.5 by up to 2,000 tons in that year. For additional
details, see Chapter 5 of the draft RIA.
[[Page 40418]]
Table VIII-19--Combined Phase 1 and Phase 2 Annual Downstream Impacts on Criteria Pollutants From Heavy-Duty
Sector in Calendar Year 2050--Preferred Alternative vs. Alt 1a Using Analysis Method B
[US short tons] \a\
----------------------------------------------------------------------------------------------------------------
CY NOX VOC SOX PM2.5b
----------------------------------------------------------------------------------------------------------------
2050........................................ -403,915 -69,415 -2,111 1,890
----------------------------------------------------------------------------------------------------------------
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\ Positive number reflects an increase in emissions.
(iii) Total Impacts of the Proposed Program and Alternative 4
As shown in Table VIII-20 and Table VIII-21, agencies estimate that
both the proposed program and Alternative 4 would result in overall net
reductions of NOX, VOC, SOX, CO,
PM2.5, and air toxics emissions. The downstream increase in
PM2.5 due to APU use is expected to be more than offset by
reductions in PM2.5 from upstream.\414\ The results are
shown both in changes in absolute tons and in percent reductions from
the less dynamic reference to the alternatives for the heavy-duty
sector. By 2050, the total impacts of the proposed program and
Alternative 4 on criteria pollutants and air toxics are
indistinguishable.
---------------------------------------------------------------------------
\414\ Although net reduction in PM2.5 is expected at
the national level, it is unlikely that the geographic location of
increases in downstream PM2.5 emissions will coincide
with the location of decreases in upstream PM2.5
emissions. For further details, see Section VIII.D of this preamble
and in Chapter 8 of the draft RIA.
Table VIII-20--Annual Total Impacts (Upstream and Downstream) of Criteria Pollutants and Air Toxics From Heavy-
Duty Sector in Calendar Years 2025, 2035 and 2050--Preferred Alternative vs. Alt 1a Using Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
-----------------------------------------------------------------------------
Pollutant US short US short US short
% Reduction tons % Reduction tons % Reduction tons
----------------------------------------------------------------------------------------------------------------
1,3-Butadiene..................... -9 -2.7 -25 -15.1 -36 -19.4
Acetaldehyde...................... -674 -10.1 -1,902 -30.5 -2,697 -36.0
Acrolein.......................... -97 -9.8 -274 -31.3 -388 -36.9
Benzene........................... -149 -5.4 -445 -18.8 -633 -22.9
CO................................ -29,622 -1.9 -85,961 -6.6 -122,659 -8.4
Formaldehyde...................... -2,121 -11.4 -5,978 -31.7 -8,475 -37.0
NOX............................... -102,502 -7.2 -298,907 -26.6 -426,610 -32.1
PM2.5............................. -386 -0.6 -1,883 -4.2 -2,815 -5.4
SOX............................... -6,070 -4.9 -20,777 -15.3 -30,000 -18.4
VOC............................... -16,724 -5.6 -52,872 -18.8 -75,521 -22.7
----------------------------------------------------------------------------------------------------------------
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.
Table VIII-21--Annual Total Impacts (Upstream and Downstream) of Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar Years 2025, 2035
and 2050--Alternative 4 vs. Alt 1a Using Analysis Method B \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2035 CY2050
Pollutant -----------------------------------------------------------------------------------------------
US short tons % Reduction US short tons % Reduction US short tons % Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,3-Butadiene........................................... -9 -2.8 -26 -15.2 -36 -19.4
Acetaldehyde............................................ -676 -10.1 -1,903 -30.6 -2,697 -36.0
Acrolein................................................ -97 -9.8 -274 -31.3 -388 -36.9
Benzene................................................. -157 -5.7 -450 -18.9 -634 -22.9
CO...................................................... -30,580 -1.9 -86,526 -6.6 -122,703 -8.4
Formaldehyde............................................ -2,125 -11.4 -5,980 -31.7 -8,476 -37.0
NOX..................................................... -106,180 -7.4 -301,339 -26.8 -426,796 -32.1
PM2.5................................................... -646 -1.1 -2,036 -4.6 -2,827 -5.4
SOX..................................................... -7,450 -6.1 -21,550 -15.9 -30,064 -18.4
VOC..................................................... -18,652 -6.2 -53,966 -19.2 -75,621 -22.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.
[[Page 40419]]
(b) Model Year Lifetime Analysis
In addition to the annual non-GHG emissions reductions expected
from the proposed rules and Alternative 4, the combined (downstream and
upstream) non-GHG impacts for the lifetime of the impacted vehicles
were estimated. Table VIII-22 shows the fleet-wide reductions of
NOX, PM2.5 and SOX from the preferred
alternative and Alternative 4, relative to Alternative 1a, through the
lifetime \415\ of heavy-duty vehicles. For the lifetime non-GHG
reductions by vehicle categories, see Chapter 5 of the draft RIA.
---------------------------------------------------------------------------
\415\ A lifetime of 30 years is assumed in MOVES.
Table VIII-22--Lifetime Non-GHG Reductions Using Analysis Method B--
Summary for Model Years 2018-2029
[US short tons] \a\
------------------------------------------------------------------------
Alternative 3 Alternative 4
(proposed) ------------------
No-action alternative (baseline) -------------------
1a (Less 1a (Less
dynamic) dynamic)
------------------------------------------------------------------------
NOX............................... 2,399,990 2,459,497
Downstream.................... 2,139,331 2,167,512
Upstream...................... 260,659 291,986
PM2.5............................. 15,206 19,151
Downstream \b\................ -13,528 -13,089
Upstream...................... 28,733 32,240
SOX............................... 169,436 189,904
Downstream.................... 6,158 7,035
Upstream...................... 163,278 182,869
------------------------------------------------------------------------
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\ Negative number means emissions would increase from reference to
control case. PM2.5 from tire wear and brake wear are included.
B. Health Effects of Non-GHG Pollutants
In this section, we discuss health effects associated with exposure
to some of the criteria and air toxic pollutants impacted by the
proposed and alternative 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
micrometer ([micro]m, or 10-6 meter) in diameter (for
reference, a typical strand of human hair is 70 [micro]m in diameter
and a grain of salt is about 100 [micro]m). Atmospheric particles can
be grouped into several classes according to their aerodynamic and
physical sizes. Generally, the three broad classes of particles
considered by EPA include ultrafine particles (UFP, aerodynamic
diameter <0.1 [micro]m), ``fine'' particles (PM2.5;
particles with a nominal mean aerodynamic diameter less than or equal
to 2.5 [micro]m), and ``thoracic'' particles (PM10;
particles with a nominal mean aerodynamic diameter less than or equal
to 10 [micro]m).\416\ 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 [micro]m and greater than
2.5 [micro]m). EPA currently has standards that regulate
PM2.5 and PM10.\417\
---------------------------------------------------------------------------
\416\ 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.
\417\ 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).
---------------------------------------------------------------------------
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 ambient PM is associated with a broad range
of health effects. These health effects are discussed in detail in the
December 2009 Integrated Science Assessment for Particulate Matter (PM
ISA).\418\ The PM ISA summarizes health effects evidence associated
with both short- and long-term exposures to PM2.5,
PM10-2.5, and ultrafine particles. The PM ISA concludes that
human exposures to ambient PM2.5 concentrations are
associated with a number of adverse health effects and characterizes
the weight of evidence for these health
[[Page 40420]]
outcomes.\419\ 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
PM2.5 can also be found in the rulemaking documents for the
most recent review of the PM NAAQS completed in 2012.420 421
---------------------------------------------------------------------------
\418\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F.
\419\ 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).
\420\ 78 FR 3103-3104, January 15, 2013.
\421\ 77 FR 38906-38911, June 29, 2012.
---------------------------------------------------------------------------
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 a likely causal relationship
exists 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).\422\
---------------------------------------------------------------------------
\422\ 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).
---------------------------------------------------------------------------
As summarized in the Final PM NAAQS rule, 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 premature mortality, while providing indications
that the magnitude of the PM2.5- mortality association with
long-term exposures may be larger than previously estimated.
423 424 The strongest evidence comes from recent 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 new studies that demonstrated an
improvement in community health following reductions in ambient fine
particles.
---------------------------------------------------------------------------
\423\ 78 FR 3103-3104, January 15, 2013.
\424\ 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).
---------------------------------------------------------------------------
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.\425\
---------------------------------------------------------------------------
\425\ 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.
---------------------------------------------------------------------------
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.\426\
---------------------------------------------------------------------------
\426\ 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.
---------------------------------------------------------------------------
The body of scientific evidence detailed in the 2009 p.m. 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).\427\ 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.'' \428\
---------------------------------------------------------------------------
\427\ 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.
\428\ 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
---------------------------------------------------------------------------
Specific groups within the general population are at increased risk
for experiencing adverse health effects related to PM
exposures.429 430 431 432 The evidence detailed in the 2009
p.m. 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.\433\
---------------------------------------------------------------------------
\429\ 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.
\430\ 77 FR 38890, June 29, 2012.
\431\ 78 FR 3104, January 15, 2013.
\432\ 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.
\433\ 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).
---------------------------------------------------------------------------
For PM10-2.5, the 2009 p.m. 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 ED visits, changes in cardiovascular function),
respiratory effects (e.g., ED visits and hospital admissions, increase
in markers of pulmonary inflammation), and premature mortality. Data
were inadequate to draw conclusions regarding the relationships between
long-term exposure to PM10-2.5 and various health
effects.434 435 436
---------------------------------------------------------------------------
\434\ 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.
\435\ 78 FR 3167-3168, January 15, 2013.
\436\ 77 FR 38947-38951, June 29, 2012.
---------------------------------------------------------------------------
[[Page 40421]]
For ultrafine particles, the 2009 p.m. 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 ultrafine particles
and respiratory effects, including lung function and pulmonary
inflammation, with limited and inconsistent evidence for increases in
ED visits and hospital admissions. Data were inadequate to draw
conclusions regarding the relationship between short-term exposure to
ultrafine particle and additional health effects including premature
mortality as well as long-term exposure to ultrafine particles and all
health outcomes evaluated.437 438
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\437\ 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.
\438\ 78 FR 3121, January 15, 2013.
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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
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.\439\ The information
in this section is based on the information and conclusions in the
February 2013 Integrated Science Assessment for Ozone (Ozone ISA).\440\
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.\441\ 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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\439\ 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.
\440\ 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.
\441\ The ISA evaluates evidence and draws conclusions on the
causal 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 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, interindividual variation in human responses to ozone
exposure can result in some groups being at increased risk for
detrimental effects in response to exposure. 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
Nitrogen dioxide (NO2) is a member of the NOX
family of gases. Most NO2 is formed in the air through the
oxidation of nitric oxide (NO) emitted when fuel is burned at a high
temperature. NO2 and its gas phase oxidation products can
dissolve in water droplets and further oxidize to form nitric acid
which reacts with ammonia to form nitrates, which are important
components of ambient PM. The health effects of ambient PM are
discussed in Section VIII.B.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.B.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 2008 Integrated Science Assessment
for Oxides of Nitrogen--Health Criteria (Oxides of Nitrogen ISA).\442\
EPA concluded that the findings of epidemiological, controlled human
exposure, and animal toxicological
[[Page 40422]]
studies provided evidence that was sufficient to infer a likely causal
relationship between respiratory effects and short-term NO2
exposure. The 2008 ISA for Oxides of Nitrogen concluded that the
strongest evidence for such a relationship comes from epidemiological
studies of respiratory effects including increased respiratory
symptoms, emergency department visits, and hospital admissions. Based
on both short- and long-term exposure studies, the 2008 ISA for Oxides
of Nitrogen concluded that individuals with preexisting pulmonary
conditions (e.g., asthma or COPD), children, and older adults are
potentially at greater risk of NO2-related respiratory
effects. Based on findings from controlled human exposure studies, the
2008 ISA for Oxides of Nitrogen also drew two broad conclusions
regarding airway responsiveness following NO2 exposure.
First, the ISA concluded that NO2 exposure may enhance the
sensitivity to allergen-induced decrements in lung function and
increase the allergen-induced airway inflammatory response following
30-minute exposures of asthmatic adults to NO2
concentrations as low as 260 ppb.\443\ Second, exposure to
NO2 was found to enhance the inherent responsiveness of the
airway to subsequent nonspecific challenges in controlled human
exposure studies of healthy and asthmatic adults. Statistically
significant increases in nonspecific airway responsiveness were
reported for asthmatic adults following 30-minute exposures to 200-300
ppb NO2 and following 1-hour exposures to 100 ppb
NO2.\444\ Enhanced airway responsiveness could have
important clinical implications for asthmatics since transient
increases in airway responsiveness following NO2 exposure
have the potential to increase symptoms and worsen asthma control.
Together, the epidemiological and experimental data sets formed a
plausible, consistent, and coherent description of a relationship
between NO2 exposures and an array of adverse health effects
that range from the onset of respiratory symptoms to hospital
admissions and emergency department visits for respiratory causes,
especially asthma.\445\
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\442\ U.S. EPA (2008). Integrated Science Assessment for Oxides
of Nitrogen--Health Criteria (Final Report). EPA/600/R-08/071.
Washington, DC: U.S. EPA.
\443\ U.S. EPA (2008). Integrated Science Assessment for Oxides
of Nitrogen--Health Criteria (Final Report). EPA/600/R-08/071.
Washington, DC: U.S. EPA, Section 3.1.3.1.
\444\ U.S. EPA (2008). Integrated Science Assessment for Oxides
of Nitrogen--Health Criteria (Final Report). EPA/600/R-08/071.
Washington, DC: U.S.EPA, Section 3.1.3.2.
\445\ U.S. EPA (2008). Integrated Science Assessment for Oxides
of Nitrogen--Health Criteria (Final Report). EPA/600/R-08/071.
Washington, DC: U.S. EPA, Section 3.1.7.
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In evaluating a broader range of health effects, the 2008 ISA for
Oxides of Nitrogen concluded evidence was ``suggestive but not
sufficient to infer a causal relationship'' between short-term
NO2 exposure and premature mortality and between long-term
NO2 exposure and respiratory effects. The latter was based
largely on associations observed between long-term NO2
exposure and decreases in lung function growth in children.
Furthermore, the 2008 ISA for Oxides of Nitrogen concluded that
evidence was ``inadequate to infer the presence or absence of a causal
relationship'' between short-term NO2 exposure and
cardiovascular effects as well as between long-term NO2
exposure and cardiovascular effects, reproductive and developmental
effects, premature mortality, and cancer.\446\ The conclusions for
these health effect categories were informed by uncertainties in the
evidence base such as the independent effects of NO2
exposure within the broader mixture of traffic-related pollutants,
limited evidence from experimental studies, and/or an overall limited
literature base.
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\446\ U.S. EPA (2008). Integrated Science Assessment for Oxides
of Nitrogen--Health Criteria (Final Report). EPA/600/R-08/071.
Washington, DC: U.S. EPA.
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(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.B.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).\447\ Short-term peaks 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 sensitive groups 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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\447\ 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 and, particularly in urban areas, the
majority of CO emissions to ambient air come from mobile sources.
(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).\448\
The CO ISA concludes that ambient concentrations of CO are associated
with a number of adverse health effects.\449\ This section provides a
summary of the health effects associated with exposure to ambient
concentrations of CO.\450\
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\448\ 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.
\449\ 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.
\450\ 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.
---------------------------------------------------------------------------
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 show associations between short-term CO
exposure and
[[Page 40423]]
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. The epidemiologic studies provide limited evidence of a CO-
induced effect on preterm births and birth defects, with weak evidence
for a decrease in birth weight. Animal toxicological studies have found
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
ambient 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 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 studies provide evidence of an
association between short-term exposure to CO and mortality, but
limited evidence is available to evaluate cause-specific mortality
outcomes associated with CO exposure. In addition, the attenuation of
CO risk estimates which was often observed in copollutant models
contributes to the uncertainty as to whether CO is acting alone or as
an indicator for other combustion-related pollutants. The 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 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 [micro]m), of which a
significant fraction is ultrafine particles (< 0.1 [micro]m). These
particles have a large surface area which makes them an excellent
medium for adsorbing organics and their small size makes them highly
respirable. Many of the organic compounds present in the gases and on
the particles, such as polycyclic organic matter, are individually
known to have mutagenic and carcinogenic properties.
Diesel exhaust varies significantly in chemical composition and
particle sizes between different engine types (heavy-duty, light-duty),
engine operating conditions (idle, accelerate, decelerate), and fuel
formulations (high/low sulfur fuel). Also, there are emissions
differences between on-road and nonroad engines because the nonroad
engines are generally of older technology. After being emitted in the
engine exhaust, diesel exhaust undergoes dilution as well as chemical
and physical changes in the atmosphere. The lifetime for some of the
compounds present in diesel exhaust ranges from hours to days.
(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.451 452 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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\451\ 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.
\452\ 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.
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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
[[Page 40424]]
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. 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 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.453 454 455 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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\453\ 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.
\454\ 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.
\455\ 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.'' \456\ This designation was an update from its 1988 evaluation
that considered the evidence to be indicative of a ``probable human
carcinogen.''
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\456\ 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 known or suspected as human or animal carcinogens, or that have
noncancer health effects. The population experiences an elevated risk
of cancer and other noncancer health effects from exposure to the class
of pollutants known collectively as ``air toxics.'' \457\ 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 2005 National-scale Air Toxics
Assessment and have significant inventory contributions from mobile
sources.\458\
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\457\ U.S. EPA. (2011) Summary of Results for the 2005 National-
Scale Assessment. www.epa.gov/ttn/atw/nata2005/05pdf/sum_results.pdf.
\458\ U.S. EPA (2011) 2005 National-Scale Air Toxics Assessment.
http://www.epa.gov/ttn/atw/nata2005.
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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.459 460 461 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 as the unit risk
estimate (URE) for benzene.462 463 The International Agency
for Research on Carcinogens (IARC) has determined that benzene is a
human carcinogen and the U.S. Department of Health and Human Services
(DHHS) has characterized benzene as a known human
carcinogen.464 465
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\459\ U.S. EPA. (2000). Integrated Risk Information System File
for Benzene. This material is available electronically at: http://www.epa.gov/iris/subst/0276.htm.
\460\ 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.
\461\ 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.
\462\ 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.
\463\ U.S. EPA. (2000). Integrated Risk Information System File
for Benzene. This material is available electronically at: http://www.epa.gov/iris/subst/0276.htm.
\464\ 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.
\465\ 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.466 467
[[Page 40425]]
The most sensitive noncancer effect observed in humans, based on
current data, is the depression of the absolute lymphocyte count in
blood.468 469 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.470 471 472 473 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.474 475
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\466\ Aksoy, M. (1989). Hematotoxicity and carcinogenicity of
benzene. Environ. Health Perspect. 82: 193-197.
\467\ Goldstein, B.D. (1988). Benzene toxicity. Occupational
medicine. State of the Art Reviews. 3: 541-554.
\468\ 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.
\469\ 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://www.epa.gov/iris/subst/0276.htm.
\470\ 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.
\471\ 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.
\472\ Lan, Qing, Zhang, L., Li, G., Vermeulen, R., et al.
(2004). Hematotoxically in Workers Exposed to Low Levels of Benzene.
Science 306: 1774-1776.
\473\ 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.
\474\ 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.
\475\ 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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(c) 1,3-Butadiene
EPA has characterized 1,3-butadiene as carcinogenic to humans by
inhalation.476 477 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.478 479 480 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\.\481\ 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.\482\ 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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\476\ U.S. EPA. (2002). Health Assessment of 1,3-Butadiene.
Office of Research and Development, National Center for
Environmental Assessment, Washington Office, Washington, DC. Report
No. EPA600-P-98-001F. This document is available electronically at
http://www.epa.gov/iris/supdocs/buta-sup.pdf.
\477\ U.S. EPA. (2002). ``Full IRIS Summary for 1,3-butadiene
(CASRN 106-99-0)'' Environmental Protection Agency, Integrated Risk
Information System (IRIS), Research and Development, National Center
for Environmental Assessment, Washington, DC http://www.epa.gov/iris/subst/0139.htm.
\478\ 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.
\479\ 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.
\480\ NTP. (2014). 13th Report on Carcinogens. Research Triangle
Park, NC: U.S. Department of Health and Human Services, Public
Health Service, National Toxicology Program.
\481\ U.S. EPA. (2002). ``Full IRIS Summary for 1,3-butadiene
(CASRN 106-99-0)'' Environmental Protection Agency, Integrated Risk
Information System (IRIS), Research and Development, National Center
for Environmental Assessment, Washington, DC http://www.epa.gov/iris/subst/0139.htm.
\482\ 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.\483\ 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.484 485
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\483\ EPA. Integrated Risk Information System. Formaldehyde
(CASRN 50-00-0) http://www.epa.gov/iris/subst/0419/htm.
\484\ NTP. (2014). 13th Report on Carcinogens. Research Triangle
Park, NC: U.S. Department of Health and Human Services, Public
Health Service, National Toxicology Program.
\485\ 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.486 487 488 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.\489\ 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.\490\
Finally, a study of embalmers reported formaldehyde exposures to be
associated with an increased risk of myeloid leukemia but not brain
cancer.\491\
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\486\ 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.
\487\ 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.
\488\ 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.
\489\ Pinkerton, L.E. 2004. Mortality among a cohort of garment
workers exposed to formaldehyde: An update. Occup. Environ. Med. 61:
193-200.
\490\ Coggon, D., E.C. Harris, J. Poole, K.T. Palmer. 2003.
Extended follow-up of a cohort of British chemical workers exposed
to formaldehyde. J National Cancer Inst. 95:1608-1615.
\491\ 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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[[Page 40426]]
Health effects of formaldehyde in addition to cancer were reviewed
by the Agency for Toxics Substances and Disease Registry in 1999 \492\
and supplemented in 2010,\493\ and by the World Health
Organization.\494\ 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,
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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\492\ ATSDR. 1999. Toxicological Profile for Formaldehyde, U.S.
Department of Health and Human Services (HHS), July 1999.
\493\ ATSDR. 2010. Addendum to the Toxicological Profile for
Formaldehyde. U.S. Department of Health and Human Services (HHS),
October 2010.
\494\ 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.\495\
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.\496\ EPA is currently developing a
new draft assessment in response to this review.
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\495\ 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.
\496\ 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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(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.\497\ The URE in
IRIS for acetaldehyde is 2.2 x 10-6 per [mu]g/m\3\.\498\
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.499 500 EPA is currently conducting a reassessment of
cancer risk from inhalation exposure to acetaldehyde.
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\497\ 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://www.epa.gov/iris/subst/0290.htm.
\498\ U.S. EPA (1991). Integrated Risk Information System File
of Acetaldehyde. This material is available electronically at http://www.epa.gov/iris/subst/0290.htm.
\499\ NTP. (2014). 13th Report on Carcinogens. Research Triangle
Park, NC: U.S. Department of Health and Human Services, Public
Health Service, National Toxicology Program.
\500\ 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.\501\ In
short-term (4 week) rat studies, degeneration of olfactory epithelium
was observed at various concentration levels of acetaldehyde
exposure.502 503 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.\504\ The agency is
currently conducting a reassessment of the health hazards from
inhalation exposure to acetaldehyde.
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\501\ U.S. EPA (1991). Integrated Risk Information System File
of Acetaldehyde. This material is available electronically at http://www.epa.gov/iris/subst/0290.htm.
\502\ 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://www.epa.gov/iris/subst/0364.htm.
\503\ 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.
\504\ 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.\505\ The IARC determined in
1995 that acrolein was not classifiable as to its carcinogenicity in
humans.\506\
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\505\ U.S. EPA. (2003). Integrated Risk Information System File
of Acrolein. Research and Development, National Center for
Environmental Assessment, Washington, DC. This material is available
at http://www.epa.gov/iris/subst/0364.htm.
\506\ 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.\507\ 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.\508\ EPA is considering
updating the acrolein assessment with data that have become available
since the 2003 assessment was completed.
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\507\ 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://www.epa.gov/iris/subst/0364.htm.
\508\ 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://www.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.\509\ These data and additional
studies regarding acute effects of human exposure to acrolein are
summarized in EPA's 2003 IRIS Human Health Assessment for
acrolein.\510\ 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
[[Page 40427]]
hyper-responsiveness. Based on animal data (more pronounced respiratory
irritancy in mice with allergic airway disease in comparison to non-
diseased mice \511\) 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.\512\
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\509\ 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://www.epa.gov/ncea/iris/toxreviews/0364tr.pdf.
\510\ 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://www.epa.gov/ncea/iris/toxreviews/0364tr.pdf.
\511\ Morris J.B., Symanowicz P.T., Olsen J.E., et al. (2003).
Immediate sensory nerve-mediated respiratory responses to irritants
in healthy and allergic airway-diseased mice. J Appl Physiol
94(4):1563-1571.
\512\ 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.513 514 Animal studies
have reported respiratory tract tumors from inhalation exposure to
benzo[a]pyrene and alimentary tract and liver tumors from oral exposure
to benzo[a]pyrene.\515\ 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.\516\ 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).517 518 These and similar studies are being
evaluated as a part of the ongoing IRIS assessment of health effects
associated with exposure to benzo[a]pyrene.
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\513\ 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.
\514\ 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.
\515\ 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.
\516\ 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://www.epa.gov/ncea/iris/subst/0457.htm.
\517\ 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.
\518\ 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.\519\ Chronic
(long term) exposure of workers and rodents to naphthalene has been
reported to cause cataracts and retinal damage.\520\ EPA released an
external review draft of a reassessment of the inhalation
carcinogenicity of naphthalene based on a number of recent animal
carcinogenicity studies.\521\ The draft reassessment completed external
peer review.\522\ 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.\523\ 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.\524\
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\519\ 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://www.epa.gov/iris/subst/0436.htm.
\520\ 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://www.epa.gov/iris/subst/0436.htm.
\521\ 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://www.epa.gov/iris/subst/0436.htm.
\522\ 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.
\523\ NTP. (2014). 13th Report on Carcinogens. U.S. Department
of Health and Human Services, Public Health Service, National
Toxicology Program.
\524\ 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.\525\ 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\.\526\ The
[[Page 40428]]
ATSDR MRL for acute exposure to naphthalene is 0.6 mg/kg/day.
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\525\ U.S. EPA. (1998). Toxicological Review of Naphthalene,
Environmental Protection Agency, Integrated Risk Information System,
Research and Development, National Center for Environmental
Assessment, Washington, DC. This material is available
electronically at http://www.epa.gov/iris/subst/0436.htm.
\526\ 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://www.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.\527\
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\527\ U.S. EPA Integrated Risk Information System (IRIS)
database is available at: www.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 recent large-scale review of air quality measurements in 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.\528\ 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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\528\ 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.
However, several studies have measured aldehydes in multiple weather
conditions, and found higher concentrations of many carbonyls downwind
of roadways.529 530 These findings suggest a substantial
roadway source of these carbonyls.
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\529\ Liu, W.; Zhang, J.; Kwon, J.l; et l. (2006).
Concentrations and source characteristics of airborne carbonyl
comlbs measured outside urban residences. J Air Waste Manage Assoc
56: 1196-1204.
\530\ 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.\531\ In
addition, numerous studies have found adverse health effects associated
with spending time in traffic, such as commuting or walking along high-
traffic roadways.532 533 534 535 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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\531\ 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.
\532\ 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.
\533\ 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.
\534\ 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.
\535\ 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.\536\ 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 as ``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.537 538 539 540 However, researchers from the U.S.
Centers for Disease Control and Prevention (CDC) recently 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.\541\
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\536\ 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.
\537\ 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.
\538\ 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.
\539\ 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.
\540\ Raaschou-Nielsen, O.; Reynolds, P. (2006). Air pollution
and childhood cancer: A review of the epidemiological literature.
Int J Cancer 118: 2920-9.
\541\ Boothe, V.L.; 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).542 543 544 545
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\542\ 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.
\543\ 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].
\544\ Power, M.C.; Weisskopf, M.G.; Alexeef, S.E.; et al.
(2011). Traffic-related air pollution and cognitive function in a
cohort of older men. Environ Health Perspect 2011: 682-687.
\545\ Wu, J.; Wilhelm, M.; Chung, J.; et al. (2011). Comparing
exposure assessment methods for traffic-related air pollution in an
adverse pregnancy outcome study. Environ Res 111: 685-6692.
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[[Page 40429]]
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.546 547 548 549 Long-term exposures in near-road
environments have been associated with inflammation-associated
conditions, such as atherosclerosis and asthma.550 551 552
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\546\ 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.
\547\ Alexeef, S.E.; 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.
\548\ 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.
\549\ 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].
\550\ 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.
\551\ Kan, H.; Heiss, G.; Rose, K.M.; et al. (2008). Proxpective
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.
\552\ 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.553 554 555
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\553\ 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).
\554\ 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.
\555\ 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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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.\556\
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.\557\ As
discussed in Section VIII. B. (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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\556\ 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.
\557\ 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 and is working with
states to ensure that air quality monitors be placed near high-traffic
roadways for determining NAAQS compliance for 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.
As discussed in Section VIII. B. (8) of this document and NHTSA's
DEIS, 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
[[Page 40430]]
State of California 558 559 560 561 562 563 Such disparities
may be due to multiple factors.\564\
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\558\ Marshall, J.D. (2008) Environmental inequality: Air
pollution exposures in California's South Coast Air Basin.
\559\ 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].
\560\ 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].
\561\ 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].
\562\ 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].
\563\ 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.
\564\ 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.565 566 567 568 Household-level stressors such as
parental smoking and relationship stress also may increase
susceptibility to the adverse effects of air
pollution.569 570
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\565\ 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].
\566\ 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].
\567\ 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.
\568\ 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].
\569\ 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].
\570\ 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.571 572 573 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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\571\ 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.
\572\ 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.
\573\ 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.'' \574\ We analyzed whether there were differences between
households in such locations compared with those in locations farther
from these transportation facilities.\575\ 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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\574\ 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.
\575\ 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.\576\ 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.\577\ 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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\576\ http://nces.ed.gov/ccd/.
\577\ 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
[[Page 40431]]
ethnicity, and/or low SES. The emission reductions from these proposed
rules would likely result in widespread air quality improvements, but
the impact on pollution levels in close proximity to roadways would be
most direct. Thus, these proposed rules would likely help in mitigating
the disparity in racial, ethnic, and economically-based exposures.
C. Environmental Effects of Non-GHG Pollutants
(1) Visibility
Visibility can be defined as the degree to which the atmosphere is
transparent to visible light.\578\ 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.\579\
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\578\ 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/.
\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.
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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 simple 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 regulations such as the Acid
Rain Program.\580\
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\580\ 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>.
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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.\581\ In 1999, EPA finalized the regional
haze program to protect the visibility in Mandatory Class I Federal
areas.\582\ There are 156 national parks, forests and wilderness areas
categorized as Mandatory Class I Federal areas.\583\ 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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\581\ See Section 169(a) of the Clean Air Act.
\582\ 64 FR 35714, July 1, 1999.
\583\ 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 protected by the Regional
Haze Rule, 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.\584\ In those sensitive species,\585\ 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.\586\ 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.\587\ 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,\588\ 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.\589\
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\584\ 73 FR 16486, March 27, 2008.
\585\ 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.
\586\ 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.
\587\ 73 FR 16492, March 27, 2008.
\588\ 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.
\589\ 73 FR 16490-16497, March 27, 2008.
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The Integrated Science Assessment (ISA) for Ozone presents more
detailed information on how ozone effects vegetation and
ecosystems.\590\ 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.\591\ The ISA concludes that visible foliar injury effects
on vegetation,
[[Page 40432]]
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.
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\590\ 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.
\591\ 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.
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(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.\592\
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.\593\
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\592\ U.S. EPA. Integrated Science Assessment for Particulate
Matter (Final Report). U.S. Environmental Protection Agency,
Washington, DC, EPA/600/R-08/139F, 2009.
\593\ 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.
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The ecological effects of acidifying deposition and nutrient
enrichment are detailed in the Integrated Science Assessment for Oxides
of Nitrogen and Sulfur-Ecological Criteria.\594\ 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.
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\594\ NOX and SOX secondary ISA\594\ 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.
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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.\595\ 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).\596\ 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.
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\595\ 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>.
\596\ 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.
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(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.\597\ In laboratory experiments, a wide range of
tolerance to VOCs has been observed.\598\ 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.\599\
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\597\ U.S. EPA. (1991). Effects of organic chemicals in the
atmosphere on terrestrial plants. EPA/600/3-91/001.
\598\ 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.
\599\ 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.
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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.600 601 602
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\600\ Viskari E-L. (2000). Epicuticular wax of Norway spruce
needles as indicator of traffic pollutant deposition. Water, Air,
and Soil Pollut. 121:327-337.
\601\ Ugrekhelidze D, F Korte, G Kvesitadze. (1997). Uptake and
transformation of benzene and toluene by plant leaves. Ecotox.
Environ. Safety 37:24-29.
\602\ 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.
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[[Page 40433]]
D. Air Quality Impacts of Non-GHG Pollutants
(1) Current Concentrations of Non-GHG Pollutants
Nationally, levels of PM2.5, ozone, NOX,
SOX, CO and air toxics are declining.\603\ However, as of
July 2, 2014 approximately 147 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
the NAAQS in the future.\604\ 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.\605\ In addition, populations who live,
work, or attend school near major roads experience elevated exposure
concentrations to a wide range of air pollutants.\606\
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\603\ U.S. EPA, 2011. Our Nation's Air: Status and Trends
through 2010. EPA-454/R-12-001. February 2012. Available at: http://www.epa.gov/airtrends/2011/.
\604\ Data come from Summary Nonattainment Area Population
Exposure Report, current as of July 2, 2014 at: http://www.epa.gov/oar/oaqps/greenbk/popexp.html and contained in Docket EPA-HQ-OAR-
2014-0827.
\605\ U.S. EPA. (2011) Summary of Results for the 2005 National-
Scale Assessment. www.epa.gov/ttn/atw/nata2005/05pdf/sum_results.pdf.
\606\ 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].
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EPA recognizes that states and local areas are particularly
concerned about the challenges of reducing NOX and attaining
as well as maintaining the ozone NAAQS. States and local areas are
required to adopt emission control measures to attain the NAAQS. States
may then choose to seek redesignation to attainment and if they do so
they must demonstrate that control measures are in place sufficient to
maintain the NAAQS for ten years (and eight years later, a similar
demonstration is required for another ten-year period). The most recent
revision to the ozone standards was in 2008; the previous 8-hour ozone
standards were set in 1997. Attaining and maintaining the NAAQS has
been challenging for some areas in the past, and EPA has recently
issued a proposal that would strengthen the ozone NAAQS (79 Fed. Reg
75,234, Dec. 17, 2014).
(2) Impacts of Proposed Standards on Future Ambient Concentrations of
Non-GHG Pollutants
Full-scale photochemical air quality modeling is necessary to
accurately project levels of criteria pollutants and air toxics. For
the final rulemaking, national-scale air quality modeling analyses will
be performed to analyze the impacts of the standards on
PM2.5, ozone, NO2, and selected air toxics (i.e.,
benzene, formaldehyde, acetaldehyde, naphthalene, acrolein and 1,3-
butadiene). The length of time needed to prepare the necessary
emissions inventories, in addition to the processing time associated
with the modeling itself, has precluded us from performing air quality
modeling for this proposal.
Section VIII.A of the preamble presents projections of the changes
in criteria pollutant and air toxics emissions due to the proposed
vehicle standards; the basis for those estimates is set out in Chapter
5 of the draft RIA. NHTSA also provides its projections in Chapter 4 of
its DEIS. The atmospheric chemistry related to ambient concentrations
of PM2.5, ozone and air toxics is very complex, and making
predictions based solely on emissions changes is extremely difficult.
However, based on the magnitude of the emissions changes predicted to
result from the proposed standards, the agencies expect that there will
be improvements in ambient air quality, pending more comprehensive
analyses for the final rulemaking.
For the final rulemaking national-scale air quality modeling
analyses will be performed to estimate future year ambient ozone,
NO2, and PM2.5 concentrations, air toxics
concentrations, visibility levels and nitrogen and sulfur deposition
levels for 2040. The agencies intend to use a 2011-based Community
Multi-scale Air Quality (CMAQ) modeling platform as the tool for the
air quality modeling. The CMAQ modeling system is a comprehensive
three-dimensional grid-based Eulerian air quality model designed to
estimate the formation and fate of oxidant precursors, primary and
secondary PM concentrations and deposition, and air toxics, over
regional and urban spatial scales (e.g., over the contiguous United
States).607 608 609 610 The CMAQ model is a well-known and
well-established tool and is commonly used by EPA for regulatory
analyses, by States in developing attainment demonstrations for their
State Implementation Plans, and in numerous other national and
international applications.611 612 613 614 The CMAQ model
version 5.0 was most recently peer-reviewed in September of 2011 for
the U.S. EPA.\615\ CMAQ includes numerous science modules that simulate
the emission, production, decay, deposition and transport of organic
and inorganic gas-phase and particle-phase pollutants in the
atmosphere. This 2011 multi-pollutant modeling platform used the most
recent multi-pollutant CMAQ code available at the time of air quality
modeling (CMAQ version 5.0.2; multipollutant version).\616\ CMAQ v5.0.2
reflects updates to version 5.0 to improve the underlying science
algorithms as well as include new diagnostic/scientific
[[Page 40434]]
modules which are detailed at http://www.cmascenter.org.617 618 619
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\607\ U.S. Environmental Protection Agency, Byun, D.W., and
Ching, J.K.S., Eds, 1999. Science algorithms of EPA Models-3
Community Multiscale Air Quality (CMAQ modeling system, EPA/600/R-
99/030, Office of Research and Development). Docket EPA-HQ-OAR-2010-
0162
\608\ Byun, D.W., and Schere, K.L., 2006. Review of the
Governing Equations, Computational Algorithms, and Other Components
of the Models-3 Community Multiscale Air Quality (CMAQ) Modeling
System, J. Applied Mechanics Reviews, 59 (2), 51-77. Docket EPA-HQ-
OAR-2010-0162
\609\ Dennis, R.L., Byun, D.W., Novak, J.H., Galluppi, K.J.,
Coats, C.J., and Vouk, M.A., 1996. The next generation of integrated
air quality modeling: EPA's Models-3, Atmospheric Environment, 30,
1925-1938. Docket EPA-HQ-OAR-2010-0162
\610\ Carlton, A., Bhave, P., Napelnok, S., Edney, E., Sarwar,
G., Pinder, R., Pouliot, G., and Houyoux, M. Model Representation of
Secondary Organic Aerosol in CMAQv4.7. Ahead of Print in
Environmental Science and Technology. Accessed at: http://pubs.acs.org/doi/abs/10.1021/es100636q?prevSearch=CMAQ&searchHistoryKey Docket EPA-HQ-OAR-2010-
0162.
\611\ U.S. EPA (2007). Regulatory Impact Analysis of the
Proposed Revisions to the National Ambient Air Quality Standards for
Ground-Level Ozone. EPA document number 442/R-07-008, July 2007.
Docket EPA-HQ-OAR-2010-0162
\612\ Hogrefe, C., Biswas, J., Lynn, B., Civerolo, K., Ku, J.Y.,
Rosenthal, J., et al. (2004). Simulating regional-scale ozone
climatology over the eastern United States: model evaluation
results. Atmospheric Environment, 38(17), 2627-2638.
\613\ United States Environmental Protection Agency. (2008).
Technical support document for the final locomotive/marine rule: Air
quality modeling analyses. Research Triangle Park, N.C.: U.S.
Environmental Protection Agency, Office of Air Quality Planning and
Standards, Air Quality Assessment Division.
\614\ Lin, M., Oki, T., Holloway, T., Streets, D.G., Bengtsson,
M., Kanae, S., (2008). Long range transport of acidifying substances
in East Asia Part I: Model evaluation and sensitivity studies.
Atmospheric Environment, 42(24), 5939-5955.
\615\ Brown, N., Allen, D., Amar, P., Kallos, G., McNider, R.,
Russell, A., Stockwell, W. (September 2011). Final Report: Fourth
Peer Review of the CMAQ Model, NERL/ORD/EPA. U.S. EPA, Research
Triangle Park, NC. http://www.epa.gov/asmdnerl/Reviews/2011_CMAQ_Review_FinalReport.pdf. It is available from the Community
Modeling and Analysis System (CMAS) as well as previous peer-review
reports at: http://www.cmascenter.org.
\616\ CMAQ version 5.0.2 was released in April 2014. It is
available from the Community Modeling and Analysis System (CMAS) Web
site: http://www.cmascenter.org.
\617\ Community Modeling and Analysis System (CMAS) Web site:
http://www.cmascenter.org, RELEASE_NOTES for CMAQv5.0--February
2012.
\618\ Community Modeling and Analysis System (CMAS) Web site:
http://www.cmascenter.org, RELEASE_NOTES for CMAQv5.0.1--July 2012.
\619\ Community Modeling and Analysis System (CMAS) Web site:
http://www.cmascenter.org. CMAQ version 5.0.2 (April 2014 release)
Technical Documentation.--May 2014.
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IX. Economic and Other Impacts
This section presents the costs, benefits and other economic
impacts of the proposed Phase 2 standards. It is important to note that
NHTSA's proposed fuel consumption standards and EPA's proposed GHG
standards would both be in effect, and each would lead to average fuel
efficiency increases and GHG emission reductions.
The net benefits of the proposed Phase 2 standards consist of the
effects of the program on:
The 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,
the economic value of reductions in GHGs,
the economic value of reductions in non-GHG pollutants,
costs associated with increases in noise, congestion, and
accidents resulting from increased vehicle use,
savings in drivers' time from less frequent refueling,
benefits of increased vehicle use associated with the
``rebound'' effect,
the 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.\620\ These rates 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.
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\620\ 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
F.1 for more information.
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The program may also have other economic effects that are not
included here. The agencies seek comment on whether any costs or
benefits are omitted from this analysis, so that they can be explicitly
recognized in the final rules. In particular, as discussed in Sections
III through VI of this preamble and in Chapter 2 of the draft RIA, the
technology cost estimates developed here take into account the costs to
hold other vehicle attributes, such as size and performance, constant.
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,\621\ price increases for new vehicles measure the welfare
losses to the vehicle buyers.\622\ 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.
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\621\ 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.
\622\ 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.
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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.\623\ 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 owners trade
off higher vehicle purchase price against future fuel savings. The
agencies seek comments, including supporting data and quantitative
analyses, of any additional impacts of the proposed standards on
vehicle attributes and performance, or other potential aspects that
could positively or negatively affect the welfare implications of this
proposed rulemaking.
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\623\ 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). For HD pickups and vans, the agencies
explicitly analyzed the uncertainty surrounding its estimates of the
economic impacts from requiring higher fuel efficiency in Preamble
Section VI. The agencies have also 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 draft 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. The agencies seek
comments on the methods and assumptions used to quantify uncertainty in
this analysis, as well as comments on methods and data that might
inform relevant uncertainty analyses not quantified in this analysis.
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 preferred alternative and in Section X for all alternatives.
A. Conceptual Framework
The HD Phase 2 proposed standards would implement both the 2007
Energy Independence and Security Act requirement that NHTSA establish
fuel
[[Page 40435]]
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 proposed Phase 2 standards would 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 would 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,\624\ the proposed fuel efficiency
and GHG emission standards would also reduce HDV operators' outlays for
fuel purchases. These fuel savings are one measure of the proposed
rule's effectiveness in promoting NHTSA's statutory goal of conserving
energy, as well as EPA's obligation to assess the cost of standards
under section 202(a)(1) and (2) of the Clean Air Act. 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 this proposal.
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\624\ State of Massachusetts v. EPA, 549 U.S. at 533.
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Potential savings in fuel costs would appear to offer HDV buyers
strong incentives to pay higher prices for vehicles that feature
technology or equipment that reduces fuel consumption. These potential
savings would 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. Nevertheless, on the basis of evidence reviewed below, the
agencies believe that a significant number of fuel efficiency improving
technologies would remain far less widely adopted in the absence of
these proposed 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. These 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. Other explanations for the limited use of
apparently cost-effective technologies that do not involve market
failures include HDV operators' concerns about the performance,
reliability, or maintenance requirements of new technology under the
demands of everyday use, uncertainty about the fuel savings they will
actually realize, and questions about possible effects on carrying
capacity or other aspects of HDVs' utility.
In the HD Phase 1 rulemaking (which, in contrast to these proposed
standards, did not apply to trailers), the agencies raised five
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.
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.\625\
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\625\ 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).
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[[Page 40436]]
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 it 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.
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. Buyers may react to
this uncertainty by implicitly discounting potential future savings at
rates above discount rates used in this analysis. In contrast, the
costs of fuel-saving or maintenance-reducing technologies are immediate
and thus not subject to discounting. 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.
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 would 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.
Some of these explanations imply failures in the private market for
fuel-saving technology beyond the externalities caused by producing and
consuming fuel, while others suggest that complications in valuing or
adapting to technologies that reduce fuel consumption may partly
explain buyers' hesitance to purchase more fuel-efficient vehicles. In
either case, adopting this proposed rule would provide regulatory
certainty and generate important economic benefits in addition to
reducing externalities.
Since the HD Phase 1 rulemaking, new research has provided further
insight into potential barriers to adoption of fuel-saving
technologies. Several studies utilized focus groups and interviews
involving small numbers of participants, who were people with time and
inclination to join such studies, rather than selected at random.\626\
As a result, the information from these groups is not necessarily
representative of the industry as a whole. While these studies cannot
provide conclusive evidence about how all HDV buyers make their
decisions, they do describe issues that arise for those that
participated.
---------------------------------------------------------------------------
\626\ Klemick, Heather, Elizabeth Kopits, Keith Sargent, and Ann
Wolverton (2014). ``Heavy-Duty Trucking and the Energy Efficiency
Paradox.'' US EPA NCEE Working Paper Series. Working Paper 14-02;
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; 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.
---------------------------------------------------------------------------
One common theme that emerges from these studies is the inability
of HDV buyers to obtain reliable information about the fuel savings,
reliability, and maintenance costs of technologies that improve fuel
efficiency. In many product markets, such as consumer electronics,
credible reviews and tests of product performance are readily available
to potential buyers. In the trucking industry, however, 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. One source of imperfect
information is the lack of availability of certain technologies from
preferred suppliers. 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).
Although these studies appear to show that information in the new
HDV market is often limited or viewed as unreliable, the evidence for
imperfect information in the market for used HDVs is mixed. On the one
hand, some studies noted that fuel-saving technology is often not
valued or demanded 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. The lack of demand might also be due to the intended use of
the used HDV, which may not require or 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.
All of the recent research identifies split incentives, or
principal-agent problems, as a potential barrier to technology
adoption. These occur when those responsible for investment decisions
are different from the main beneficiaries of the technology. For
instance, businesses that own and lease trailers to HDV operators may
not have an incentive to invest in trailer-specific fuel-saving
technology, since they do not collect the savings from the lower fuel
costs that result. Vernon and Meier (2012) estimate that 23 percent of
trailers may be exposed to this kind of principal-agent problem,
although they do not quantify its financial significance.\627\
---------------------------------------------------------------------------
\627\ 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.
---------------------------------------------------------------------------
Split incentives can also exist when the HDV driver is not
responsible for paying fuel costs. Some technologies require additional
effort, training, or changes in driving behavior to achieve their
promised fuel savings; drivers who do not pay for fuel may be reluctant
to undertake those changes, thus reducing the fuel-saving benefits from
the perspective of the individual or company paying for the fuel. For
[[Page 40437]]
instance, drivers might not consistently deploy boat-tails equipped on
trailers to improve vehicle aerodynamics.\628\ Vernon and Meier also
calculate that 91 percent of HDV fuel use is subject to this form of
principal-agent problem, although they do not estimate how much it
might reduce fuel savings to those who are paying for the fuel.
---------------------------------------------------------------------------
\628\ Some boat-tails are being developed with technology to
open them automatically when the trailer reaches a suitable speed,
to reduce this problem.
---------------------------------------------------------------------------
The studies based on focus groups and interviews (Klemick et al.
2013, Aarnink et al. 2012, Roeth et al. 2013) provide mixed evidence on
the severity of the split-incentive problem. Focus groups often do
identify diverging incentives between drivers and the decision-makers
responsible for purchasing vehicles, and economics literature
recognizes that this split incentive can be a barrier to adopting new
technology. 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, although they may not be
effective where it arises from different ownership of combination
tractors and trailers.
Uncertainty about future costs for fuel and maintenance, or about
the reliability of new technology, also appears to be a significant
obstacle that can slow the adoption of fuel-saving technologies. These
examples illustrate the problem of uncertain or unreliable information
about the actual performance of fuel efficiency technology discussed
above. In addition, businesses that operate HDVs may be concerned about
how reliable new technologies will prove to be on the road, and whether
significant additional maintenance costs or equipment malfunctions that
result in costly downtime could occur. Roeth et al. (2013) and Klemick
et al. (2013) 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.
These studies also provide some support for the view that
adjustment and transactions costs may impede HDV buyers from investing
in higher fuel efficiency. As discussed above, several 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.
Some studies also cite 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. For some technologies that can be used to meet the proposed
standards, such as automatic tire inflation systems, training costs are
likely to be minimal. Other technologies such as stop-start systems,
however, 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.\629\
---------------------------------------------------------------------------
\629\ 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.
---------------------------------------------------------------------------
In addition to these factors, the studies considered other possible
explanations for HDV buyers' apparent reluctance or slowness to invest
in fuel-saving equipment or technology. Financial constraints--access
to lending sources willing to finance purchases of more expensive
vehicles--do not appear to be a problem for the medium- and large-sized
businesses participating in Klemick et al.'s (2013) study. However,
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. In general, businesses that operate HDVs
face a range of competing uses for available capital other than
investing in fuel-saving technologies, and may assign higher priority
to these other uses, even when investing in higher fuel efficiency HDVs
appears to promise adequate financial returns.
Other potentially important barriers to the adoption of measures
that improve fuel efficiency may arise from ``network externalities,''
where the benefits to new users of a technology depend on how many
others have already adopted it. 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, the
proposed standards may assist in overcoming these difficulties.
As discussed previously, the lack of availability of fuel-saving
technologies from preferred manufactures can also be a significant
barrier to adoption (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) also noted that it can take years, and
sometimes as much as a decade, for a specific technology to become
available from all manufacturers. 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 businesses follow quickly.\630\ 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.
---------------------------------------------------------------------------
\630\ 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; Tirole, Jean (1998). The Theory of
Industrial Organization. Cambridge, MA: MIT Press, pp.400, 402. This
first-mover disadvantage must large enough to overcome the incentive
normally offered by the potential to for first movers to earn
unusually high (but temporary) profit levels.
---------------------------------------------------------------------------
In summary, the agencies recognize that businesses that operate
HDVs are under competitive pressure to reduce operating costs, which
should compel
[[Page 40438]]
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.631 632
---------------------------------------------------------------------------
\631\ American Transportation Research Institute, An Analysis of
the Operational Costs of Trucking, September 2013 (Docket ID: EPA-
HQ-OAR-2014-0827).
\632\ 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).
---------------------------------------------------------------------------
However, the short payback periods that buyers of new HDVs appear
to require suggest that some combination of uncertainty about future
cost savings, transactions costs, and imperfectly functioning markets
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, the proposed
standards may help to overcome such barriers by ensuring that these
measures would 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.
Some HDV manufacturers may delay in investing in the development
and production of new technologies, instead waiting for other
manufacturers to bear the risks of those investments first. Competitive
pressures in the HDV freight transport industry can provide a strong
incentive to reduce fuel consumption and improve environmental
performance. However, 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 would be attributed to the program. To account for this
possibility, the agencies analyzed the proposed standards and the
regulatory alternatives against two reference cases, or baselines, as
described in Section X.
The first case uses a baseline that projects some improvement in
fuel efficiency for new trailers, but no improvement in fuel efficiency
for other vehicle segments in the absence of new Phase 2 standards.
This first case is referred to as the less dynamic baseline, or
Alternative 1a. The second case uses a baseline that projects some
improvement in vehicle fuel efficiency for tractors, trailers, pickup
trucks, and vans but not for vocational vehicles. This second case is
referred to as the more dynamic baseline, or Alternative 1b.
The agencies will continue to explore reasons for the slow adoption
of readily available and apparently cost-effective technologies for
improving fuel efficiency. We also seek comments on our hypotheses
about its causes, as well as data or other information that can inform
our understanding of why this situation seems to persist.
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.\633\ We have updated those costs by converting them to 2012
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.\634\ 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 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.
---------------------------------------------------------------------------
\633\ ICF International. Investigation of Costs for Strategies
to Reduce Greenhouse Gas Emissions for Heavy-Duty On-Road Vehicles.
July 2010.
\634\ 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.
---------------------------------------------------------------------------
For HD pickups and vans, we have 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.\635\
---------------------------------------------------------------------------
\635\ 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
[[Page 40439]]
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 draft 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, would 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).\636\ As
learning effects decrease the DMC with production volumes, it makes
sense that warranty costs would 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 would result in higher indirect cost estimates,
at least in the time periods typically considered in our rules (four to
ten years).
---------------------------------------------------------------------------
\636\ 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.
---------------------------------------------------------------------------
The agencies are concerned 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 proposed requirements. Specifically, we may not have
adequately estimated the costs for accelerated R&D or potential
reliability issues with advanced technologies required by Alternative
4. There is a great deal of uncertainty regarding these costs, and this
makes estimates for this alternative of particular concern. We request
comment on that aspect of our estimates and on all aspects of our
indirect cost estimation approach.
We provide more details on our ICM approach and the markups used
for each technology in Chapter 2.12 of the draft RIA.
(c) Learning Effects on Direct and Indirect Costs
For some of the technologies considered in this analysis,
manufacturer learning effects would 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).\637\
---------------------------------------------------------------------------
\637\ 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 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
[[Page 40440]]
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 would 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 request
comment on this approach to estimating these effects, and request that
commenters provide data and forward-looking information to support any
alternative methods or specific estimates.
We provide more details on the concept of learning-by-doing and the
learning effects applied in this analysis in Chapter 2 of the draft
RIA.
(d) Technology Adoption Rates and Developing Package Costs
Determining the stringency of the proposed 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
the proposed 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 each of the
technologies for which costs have been developed to be employed by all
trucks and trailers across the board. Further, many of today's vehicles
are already equipped with some of the technologies and/or are expected
to adopt them by MY2018 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.
For HD pickups and vans, the CAFE model determines the technology
adoption rates that most cost effectively meet the standards being
proposed. Similar to vocational vehicles, tractors and trailers,
package costs are rarely if ever a simple sum of all the technology
costs since each technology would be expected to be adopted at
different rates. The methods for estimating technology adoption rates
and resultant costs (and other impacts) for HD pickups and vans are
discussed above in Section 6.
We provide details of expected adoption rates in Chapter 2 of the
draft RIA. We present package costs both in Sections III through VI of
this preamble and in more detail in Chapter 2 of the draft RIA.
(e) Conversion of Technology Costs to 2012 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 dollars). For this analysis, the agencies sought to
have all costs in terms of 2012 dollars to be consistent with the
dollars used by AEO in its 2014 Annual Energy Outlook.\638\ 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.\639\
---------------------------------------------------------------------------
\638\ U.S. Energy Information Administration, Annual Energy
Outlook 2014, Early Release; Report Number DOE/EIA-0383ER (2014),
December 16, 2013.
\639\ Bureau of Economic Analysis, Table 1.1.9 Implicit Price
Deflators for Gross Domestic Product; as revised on March 27, 2014.
Table IX-1--Implicit Price Deflators and Conversion Factors for Conversion to 2012$
--------------------------------------------------------------------------------------------------------------------------------------------------------
2006 2007 2008 2009 2010 2011 2012 2013
--------------------------------------------------------------------------------------------------------------------------------------------------------
Price index for GDP............................................. 94.818 97.335 99.236 100 101.211 103.199 105.002 106.588
Factor applied for 2012$........................................ 1.107 1.079 1.058 1.050 1.037 1.017 1.000 0.985
--------------------------------------------------------------------------------------------------------------------------------------------------------
(2) Compliance Program Costs
The agencies have also estimated additional and/or new compliance
costs associated with the proposed standards. Normally, compliance
program costs would be considered part of the indirect costs and,
therefore, would 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 proposal are
new powertrain testing within the vocational vehicle program, and an
all-new compliance program where none has existed to date within the
trailer program. Note that for HD pickups and vans, HD engines,
vocational vehicles and tractors, the Phase 1 rule included analogous
compliance program costs meant to account for costs incurred in the
all-new compliance program placed on the regulated firms by that rule.
Compliance program costs cover costs associated with any necessary
compliance testing and reporting to the agencies and differ somewhat by
alternative since, for example, more manufacturers are expected to
conduct powertrain testing under alternative 4 than under alternative
3, etc. The details behind the estimated compliance program costs are
provided in Chapter 7 of the draft RIA. We request comment on our
estimated compliance costs.
(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 the proposed 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 the proposed standards come into force and industry
works on means to comply. After that period, the additional R&D costs
go to $0 as R&D expenditures return to their normal levels and R&D
costs are accounted for via the ICMs--and the RPEs behind them--used
for these segments. Note that, due to the accelerated implementation of
some technologies, alternative 4 has higher R&D costs than does
alternative 3. The details behind the estimated R&D costs are provided
in Chapter 7 of the draft RIA. We request comment on our estimated R&D
costs.
[[Page 40441]]
(4) Summary of Costs of the Proposed Vehicle Programs
The agencies have estimated the costs of the proposed vehicle
standards on an annual basis for the years 2018 through 2050, and have
also estimated costs for the full model year lifetimes of MY2018
through MY2029 vehicles. Table IX-2 shows the annual costs of the
proposed standards along with net present values using both 3 percent
and 7 percent discount rates. Table IX-3 shows the discounted model
year lifetime costs of the proposed standards at both 3 percent and 7
percent discount rates along with sums across applicable model years.
Table IX-2--Annual Costs of the Preferred Alternative and Net Present Values at 3% and 7% Discount Rates Using
Method B and Relative to the Less Dynamic Baseline
[$Millions of 2012$] a
----------------------------------------------------------------------------------------------------------------
Calendar year New technology Compliance R&D Sum
----------------------------------------------------------------------------------------------------------------
2018............................................ 116 0 0 116
2019............................................ 113 0 0 113
2020............................................ 112 0 0 112
2021............................................ 2,173 18 240 2,432
2022............................................ 2,161 6 240 2,407
2023............................................ 2,224 6 240 2,470
2024............................................ 3,455 6 240 3,701
2025............................................ 3,647 6 0 3,653
2026............................................ 3,736 6 0 3,742
2027............................................ 5,309 6 0 5,315
2028............................................ 5,334 6 0 5,340
2029............................................ 5,376 6 0 5,381
2030............................................ 5,399 6 0 5,405
2035............................................ 5,856 6 0 5,862
2040............................................ 6,316 6 0 6,322
2050............................................ 6,987 6 0 6,992
NPV, 3%......................................... 85,926 104 759 86,789
NPV, 7%......................................... 40,516 56 561 41,133
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the less
dynamic baseline, 1a, and more dynamic baseline, 1b, please see Section X.A.1.
[[Page 40442]]
Table IX-3--Discounted MY Lifetime Costs of the Preferred Alternative Using Method B and Relative to the Less Dynamic Baseline
[$Millions of 2012$] a
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Discounted at 3% Discounted at 7%
Model year -------------------------------------------------------------------------------------------------------------------------------
New technology Compliance R&D Sum New technology Compliance R&D Sum
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
2018............................................................ 104 0 0 104 91 0 0 91
2019............................................................ 99 0 0 99 84 0 0 84
2020............................................................ 95 0 0 95 77 0 0 77
2021............................................................ 1,794 15 198 2,007 1,401 12 155 1,567
2022............................................................ 1,731 5 193 1,928 1,302 3 145 1,450
2023............................................................ 1,730 4 187 1,921 1,252 3 135 1,390
2024............................................................ 2,610 4 181 2,795 1,818 3 126 1,947
2025............................................................ 2,674 4 0 2,678 1,793 3 0 1,796
2026............................................................ 2,660 4 0 2,664 1,717 3 0 1,719
2027............................................................ 3,670 4 0 3,673 2,280 2 0 2,283
2028............................................................ 3,580 4 0 3,583 2,141 2 0 2,143
2029............................................................ 3,502 4 0 3,506 2,017 2 0 2,019
Sum............................................................. 24,248 48 759 25,055 15,973 33 561 16,568
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
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.
[[Page 40443]]
New technology costs begin in MY2018 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 proposed 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. We request comment on all aspects of our
technology costs, both individual technology costs and package costs,
as detailed in Chapter 2 of the draft RIA.
C. Changes in Fuel Consumption and Expenditures
(1) Changes in Fuel Consumption
The new GHG and fuel consumption standards would result in
significant improvements in the fuel efficiency of affected vehicles,
and drivers of those vehicles would see corresponding savings
associated with reduced fuel expenditures. The agencies have estimated
the impacts on fuel consumption for the proposed 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 draft
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 the proposed standards and include any increased
consumption resulting from the rebound effect (discussed below in
Section IX.E).
Table IX-4--Annual Fuel Consumption Reductions Due to the Preferred Alternative Using Method B and Relative to the Less Dynamic Baseline
[Millions of gallons] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Gasoline Diesel
-----------------------------------------------------------------------------------------------
Calendar year Fuel Fuel
Reference case consumption % Reduction Reference case consumption % Reduction
reduction reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018.................................................... 6,781 0 0 45,999 74 0
2019.................................................... 6,799 0 0 46,362 150 0
2020.................................................... 6,832 0 0 46,768 227 0
2021.................................................... 6,884 10 0 47,236 523 1
2022.................................................... 6,944 29 0 47,761 894 2
2023.................................................... 7,005 57 1 48,309 1,276 3
2024.................................................... 7,054 99 1 48,807 1,895 4
2025.................................................... 7,113 151 2 49,400 2,523 5
2026.................................................... 7,169 210 3 49,967 3,152 6
2027.................................................... 7,221 291 4 50,420 3,890 8
2028.................................................... 7,273 369 5 50,821 4,600 9
2029.................................................... 7,332 445 6 51,262 5,278 10
2030.................................................... 7,396 516 7 51,792 5,924 11
2035.................................................... 7,732 801 10 54,602 8,517 16
2040.................................................... 8,075 968 12 58,082 10,209 18
2050.................................................... 8,806 1,127 13 65,937 12,310 19
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.
Table IX-5--Model Year Lifetime Fuel Consumption Reductions Due to the Preferred Alternative Using Method B and Relative to the Less Dynamic Baseline
[Millions of Gallons] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Gasoline Diesel
-----------------------------------------------------------------------------------------------
Model year Fuel Fuel
Reference consumption % Reduction Reference consumption % Reduction
reduction reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018.................................................... 0 0 0 33,384 754 2
2019.................................................... 0 0 0 33,922 745 2
2020.................................................... 0 0 0 34,575 738 2
2021.................................................... 7,128 113 2 47,792 4,424 9
2022.................................................... 7,118 216 3 48,112 4,568 9
2023.................................................... 7,106 317 4 48,366 4,703 10
2024.................................................... 7,225 493 7 49,577 7,628 15
2025.................................................... 7,376 602 8 51,050 7,967 16
2026.................................................... 7,535 714 9 52,420 8,289 16
2027.................................................... 7,628 982 13 53,532 9,984 19
2028.................................................... 7,711 992 13 54,524 10,181 19
2029.................................................... 7,769 999 13 55,421 10,360 19
-----------------------------------------------------------------------------------------------
[[Page 40444]]
Sum..................................................... 66,596 5,430 8 562,673 70,342 13
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.
(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 2014 Annual Energy Outlook.\640\ 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 would 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 would 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 would be
received by state and federal governments, or about $240 million in
2021 and $5.2 billion by 2050 as shown in Table IX-6 where annual
changes in monetized fuel savings are shown along with net present
values using 3 percent and 7 percent discount rates. Table IX-7 Table
IX-8 show the discounted model year lifetime fuel savings using 3
percent and 7 percent discount rates, respectively.
---------------------------------------------------------------------------
\640\ U.S. Energy Information Administration, Annual Energy
Outlook 2014, Early Release; Report Number DOE/EIA-0383ER (2014),
December 16, 2013.
Table IX-6--Annual Fuel Savings and Net Present Values at 3% and 7% Discount Rates Using Method B for the Preferred Alternative and Relative to the Less
Dynamic Baseline
[$Millions of 2012$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel savings--retail Fuel savings--untaxed
Calendar year ------------------------------------------------------------------------------------------------ Change in
Gasoline Diesel Sum Gasoline Diesel Sum transfer
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018.................................... $0 $261 $261 $0 $227 $227 $34
2019.................................... 0 540 540 0 472 472 68
2020.................................... 0 834 834 0 731 731 103
2021.................................... 31 1,958 1,989 27 1,723 1,750 239
2022.................................... 92 3,413 3,505 80 3,015 3,095 410
2023.................................... 183 4,936 5,119 160 4,372 4,532 587
2024.................................... 324 7,426 7,750 285 6,594 6,879 871
2025.................................... 496 10,035 10,531 436 8,937 9,372 1,158
2026.................................... 695 12,683 13,378 613 11,321 11,934 1,445
2027.................................... 976 15,883 16,859 861 14,215 15,076 1,782
2028.................................... 1,243 18,938 20,181 1,099 16,980 18,079 2,102
2029.................................... 1,511 21,974 23,485 1,338 19,745 21,083 2,402
2030.................................... 1,770 24,905 26,675 1,571 22,422 23,993 2,682
2035.................................... 2,921 38,047 40,968 2,621 34,621 37,242 3,726
2040.................................... 3,778 48,300 52,078 3,427 44,357 47,783 4,295
2050.................................... 4,397 58,241 62,638 3,988 53,486 57,474 5,164
NPV, 3%................................. 37,319 506,971 544,290 33,603 461,992 495,595 48,695
NPR, 7%................................. 15,211 212,373 227,584 13,663 192,984 206,646 20,937
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the less dynamic baseline, 1a, and more dynamic
baseline, 1b, please see Section X.A.1.
[[Page 40445]]
Table IX-7--Discounted Model Year Lifetime Fuel Savings, 3% Discount Rate Using Method B for the Preferred Alternative and Relative to the Less Dynamic
Baseline
[$Millions of 2012$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel savings--retail Fuel savings--untaxed
Model year ------------------------------------------------------------------------------------------------ Change in
Gasoline Diesel Sum Gasoline Diesel Sum transfer
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018.................................... $0 $2,183 $2,183 $0 $1,937 $1,937 $246
2019.................................... 0 2,123 2,123 0 1,890 1,890 234
2020.................................... 0 2,066 2,066 0 1,844 1,844 222
2021.................................... 258 12,178 12,436 228 10,898 11,126 1,310
2022.................................... 487 12,369 12,856 431 11,094 11,525 1,331
2023.................................... 700 12,513 13,212 620 11,247 11,867 1,346
2024.................................... 1,067 19,934 21,001 947 17,953 18,901 2,100
2025.................................... 1,277 20,435 21,712 1,136 18,441 19,577 2,135
2026.................................... 1,484 20,858 22,342 1,323 18,858 20,180 2,161
2027.................................... 2,001 24,642 26,643 1,787 22,319 24,106 2,537
2028.................................... 1,981 24,610 26,592 1,772 22,329 24,101 2,491
2029.................................... 1,957 24,536 26,493 1,754 22,298 24,052 2,441
Sum..................................... 11,211 178,448 189,659 9,997 161,107 171,105 18,554
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.
Table IX-8--Discounted Model Year Lifetime Fuel Savings, 7% Discount Rate Using Method B for the Preferred Alternative and Relative to the Less Dynamic
Baseline
[Millions of 2012] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel savings--retail Fuel savings--untaxed
Model year ------------------------------------------------------------------------------------------------ Change in
Gasoline Diesel Sum Gasoline Diesel Sum transfer
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018.................................... $0 $1,529 $1,529 $0 $1,352 $1,352 $176
2019.................................... 0 1,428 1,428 0 1,267 1,267 161
2020.................................... 0 1,331 1,331 0 1,185 1,185 146
2021.................................... 163 7,538 7,701 143 6,731 6,874 827
2022.................................... 295 7,383 7,678 260 6,608 6,869 810
2023.................................... 408 7,200 7,607 361 6,458 6,819 789
2024.................................... 599 11,055 11,654 531 9,938 10,469 1,186
2025.................................... 690 10,917 11,607 613 9,834 10,447 1,160
2026.................................... 772 10,734 11,505 687 9,688 10,374 1,131
2027.................................... 1,003 12,215 13,218 894 11,046 11,940 1,278
2028.................................... 956 11,741 12,697 854 10,636 11,490 1,206
2029.................................... 909 11,269 12,179 814 10,228 11,041 1,137
Sum..................................... 5,794 94,339 100,134 5,157 84,971 90,128 10,005
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.
D. Maintenance Expenditures
The agencies expect minimal increases in maintenance costs under
the proposed standards, having estimated increased maintenance costs
associated only with installation of lower 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. 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 draft RIA. We
request comment on all aspects of the maintenance estimates.
Specifically, for electrified vehicles (mild/strong hybrids) which are
expected in alternatives 3 and 4 and in each vehicle category, we have
not estimated any increased maintenance costs. We have heard from at
least one source \641\ 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.
Given the uncertainty, we have not estimated maintenance costs
specifically for these electrified vehicles but request comment so that
we might be able to include potential costs in the final rule. We also
request comment on any other maintenance costs that should be
considered along with supporting data.
---------------------------------------------------------------------------
\641\ Allison Transmission's Responses to EPA's Hybrid
Questions, November 6, 2014.
---------------------------------------------------------------------------
Table IX-9 shows the annual increased maintenance costs of the
preferred alternative 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 preferred
alternative at both 3 percent and 7 percent discount rates along with
sums across applicable model years.
[[Page 40446]]
Table IX-9--Annual Maintenance Expenditure Increase Due to the Proposal
and Net Present Values at 3% and 7% Discount Rates Using Method B and
Relative to the Less Dynamic Baseline
[$Millions of 2012$] \a\
------------------------------------------------------------------------
Maintenance
Calendar year expenditure
increase
------------------------------------------------------------------------
2018.................................................... $6
2019.................................................... 11
2020.................................................... 16
2021.................................................... 28
2022.................................................... 39
2023.................................................... 50
2024.................................................... 64
2025.................................................... 78
2026.................................................... 90
2027.................................................... 104
2028.................................................... 116
2029.................................................... 127
2030.................................................... 127
2035.................................................... 127
2040.................................................... 127
2050.................................................... 127
NPV, 3%................................................. 1,796
NPV, 7%................................................. 860
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the less dynamic baseline, 1a, and more
dynamic baseline, 1b, please see Section X.A.1.
Table IX-10--Discounted MY Lifetime Maintenance Expenditure Increase due
to the Proposal using Method B and Relative to the Less Dynamic Baseline
[$Millions of 2012$] \a\
------------------------------------------------------------------------
3% Discount 7% Discount
Model year rate rate
------------------------------------------------------------------------
2018.................................... 51 36
2019.................................... 49 33
2020.................................... 47 31
2021.................................... 90 57
2022.................................... 89 54
2023.................................... 89 52
2024.................................... 112 63
2025.................................... 113 61
2026.................................... 102 53
2027.................................... 116 58
2028.................................... 111 54
2029.................................... 101 47
-------------------------------
Sum................................. 1,071 600
------------------------------------------------------------------------
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.
E. Analysis of the Rebound Effect
The ``rebound effect'' has been defined a number of ways in the
literature, and 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.\642\ \643\
\644\ In 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.\645\ 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 this rulemaking proposes.
---------------------------------------------------------------------------
\642\ 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.
\643\ Greene, D.L., Kahn, J.R., Gibson, R.C., 1999, ``Fuel
economy rebound effect for U.S. household vehicles'', The Energy
Journal, 20.
\644\ 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.
\645\ We discuss other potential rebound effects in section
IX.D.3, 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.
---------------------------------------------------------------------------
Unlike the light-duty vehicle (LDV) rebound effect, the HDV rebound
effect has not been extensively studied. According to a 2010 HDV report
published by the National Research Council of the National Academies
(NRC),\646\ it is ``not possible to provide
[[Page 40447]]
a confident measure of the rebound effect,'' yet NRC concluded that a
HDV rebound effect probably exists and that, ``estimates of fuel
savings from regulatory standards will be somewhat misestimated if the
rebound effect is not considered.'' Although we believe the HDV rebound
effect needs to be studied in more detail, we have nevertheless
attempted to capture its potential effect in our analysis of these
proposed rules, rather than to await further study. We have elected to
do so because the magnitude of the rebound effect is an important
determinant of the actual fuel savings and emission reductions that are
likely to result from adopting stricter fuel efficiency and GHG
emission standards.
---------------------------------------------------------------------------
\646\ 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,'' Washington,
DC. The National Academies Press. Available electronically from the
National Academies Press Web site at http://www.nap.edu/catalog.php?record_id=12845 (last accessed September 10, 2010).
---------------------------------------------------------------------------
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 ``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.
Using VMT rebound to approximate the fuel consumption impact from
all types of more intensive vehicle use may not be completely accurate.
Many factors other than distance traveled--for example, a vehicle's
loaded weight--play a role in determining its fuel consumption, so it
is also important to consider how changes in these factors are
correlated with variation in vehicle miles traveled. Empirical
estimates of the effect of weight on HDV fuel consumption vary, but
universally show that loaded weight has some effect on fuel consumption
that is independent of distance traveled. Therefore, the product of
vehicle payload and miles traveled, which typically is expressed in
units of ``ton-miles'' or ``ton-kilometers'', has also been considered
as a metric to approximate the rebound effect. Because this metric's
value depends on both payload and distance, it is important to note
that changes in these two variables can have different impacts on HDV
fuel consumption. This is because the fuel consumed by HDV freight
transport is determined by several vehicle attributes including engine
and accessory efficiencies, aerodynamic characteristics, tire rolling
resistance and total vehicle mass--including payload carried, if any.
Other factors such as vehicle route and traffic patterns can also
affect how each of these vehicle attributes contributes to the overall
fuel consumption of a vehicle. While it seems intuitive that if all of
these other conditions remain constant, a vehicle driving the same
route and distance twice will consume twice as much fuel as driving
that same route once. However, because of the other vehicle attributes,
it is less intuitive how a change in vehicle payload would affect
vehicle fuel consumption. We request comment on how the agencies should
consider the relationship between changes in vehicle miles traveled,
changes in vehicle ton-miles achieved, and overall fuel consumption
when considering how best to measure the rebound effect.
Because the factors influencing HDV VMT rebound are generally
different from those affecting LDV VMT rebound, much of the research on
the LDV sector is likely to not apply to the HDV sector. For example,
the owners and operators of LDVs may respond to the costs and benefits
associated with changes in their personal vehicle's fuel efficiency
very differently than a HDV fleet owner or operator would view the
costs and benefits (e.g., profits, offering more competitive prices for
services) associated with changes in their HDVs' fuel efficiency. To
the extent the response differs, such differences may be smaller for HD
pickups and vans, which share some similarities with LDVs. As discussed
in the 2010 NRC HD report, one difference from the LDV case is that
when calculating the change in HDV costs that causes the rebound
effect, it is more important to consider all components of HDV
operating costs. The costs of labor and fuel generally constitute the
two largest shares of HDV operating costs, depending on the price of
petroleum, distance traveled, type of vehicle, and commodity
transported (if any).647 648 Equipment depreciation costs
associated with the purchase or lease of an HDV are another significant
component of total operating costs. Even when HDV purchases involve
upfront, one-time payments, HDV operators must recover the depreciation
in the value of their vehicles resulting from their use, so this is
likely to be considered as an operating cost they will attempt to pass
on to final consumers of HDV operator services.
---------------------------------------------------------------------------
\647\ American Transportation Research Institute, An Analysis of
the Operational Costs of Trucking, September 2013.
\648\ 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.
---------------------------------------------------------------------------
Estimates of the impact of fuel efficiency standards on HDV VMT,
and hence fuel consumption, should account for changes in all of these
components of HDV operating costs. The higher the net savings in total
operating costs is, the higher the expected rebound effect would be.
Conversely, if higher HDV purchase costs outweigh future cost savings
and total operating costs increase, HDV costs could rise, which would
likely result in a decrease in HDV VMT. In theory, other cost changes
resulting from any requirement to achieve higher fuel efficiency, such
as changes in maintenance costs or insurance rates, should also be
taken into account, although information on these elements of HDV
operating costs is extremely limited. In this analysis, the agencies
adapt estimates of the VMT rebound effect to project the response of
HDV use to the estimated changes in total operating costs that result
from the proposed Phase 2 standards. We seek comment and data on how
our proposed standards could impact these and other types of HDV
operating costs, as well as on our procedure for adapting the VMT
rebound effect to estimate the response of HDV use to changes in total
operating costs.
Since businesses are profit-driven, one would expect their
decisions to be based on the costs and benefits of different operating
decisions, both in the near-term and long-term. Specifically, one would
expect commercial HDV operators to take into account changes in overall
operating costs per mile when making decisions about HDV use and
setting rates they charge for their services. If demand for those
services is sensitive to the rates HDV operators charge, HDV VMT could
change in response to the effect of higher fuel efficiency on the rates
HDV operators charge. If demand for HDV services is insensitive to
price (e.g., due to lack of good substitutes), however, or if changes
in HDV operating costs due to the proposed standards are not
[[Page 40448]]
passed on to final consumers of HDV operator services, the proposed
standards may have a limited impact on HDV VMT.
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 proposal.
(1) Factors Affecting the Magnitude of HDV VMT Rebound
The magnitude and timing of HDV VMT rebound result from the
interaction of many different factors.\649\ 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. For example, HDV operators may pass on the fuel cost savings
to their customers by decreasing prices for shipping products or
providing services, which in turn could stimulate more demand for those
products and services (e.g., increases in freight output), and result
in higher VMT. As discussed later in this section, HDV VMT rebound
estimates determined via other proxy elasticities vary widely, 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).
---------------------------------------------------------------------------
\649\ 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.
---------------------------------------------------------------------------
If fuel cost savings are passed on to the HDV operators' customers
(e.g., logistics businesses, manufacturers, retailers, municipalities,
utilities consumers), 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 our proposed standards.
It is also important to note that any increase in HDV VMT resulting
from our proposed 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 8.3.3 of the Draft 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) 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
\650\ for the U.S. This section discusses econometric analyses of other
related elasticities that could potentially be used as a proxy for
measuring HDV VMT rebound, as well as other analyses that may provide
insight into the magnitude of HDV VMT rebound. We seek comment on the
applicability of the findings from these analyses, as well as
additional data and research on the topic of HDV VMT rebound.
---------------------------------------------------------------------------
\650\ 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.
---------------------------------------------------------------------------
One of the challenges to developing robust econometric analyses of
HDV VMT rebound in the U.S. is data limitations. For example, the main
source of time-series HDV fuel efficiency data in the U.S. is derived
from aggregate fuel consumption and HDV VMT data. This may introduce
interdependence or ``simultaneity'' between measures of HDV VMT and HDV
fuel efficiency, because estimates of HDV fuel efficiency are derived
partly from HDV VMT. This mutual interdependence makes it difficult to
isolate the causal effect of HDV fuel efficiency on HDV VMT and to
measure the response of HDV VMT to changes in HDV fuel efficiency.
Data on other important determinants of HDV VMT, such as freight
shipping rates, shipment sizes, HDV payloads, and congestion levels on
key HDV routes is also limited, of questionable reliability, or
unavailable. Additionally, data on HDVs and their use is usually only
available at an aggregate level, making it difficult to evaluate
potential differences in determinants of VMT for different types of HDV
operations (e.g., long-haul freight vs. regional delivery operations)
or vehicle sub-classes (e.g., utility vehicles vs. school buses).
Another challenge inherent in using econometric techniques to
measure the response of HDV VMT to HDV fuel efficiency is developing
model specifications that incorporate the mathematical form and range
of explanatory variables necessary to produce reliable estimates of HDV
VMT rebound. Many different factors can influence HDV VMT, and the
complex relationships among those factors should be considered when
measuring the rebound effect.\651\
---------------------------------------------------------------------------
\651\ A useful framework for understanding how various responses
interact to determine the rebound effect is presented in Section 2
and Appendix B of De Borger, B. and Mulalic, I. (2012), ``The
determinants of fuel use in the trucking industry--volume, fleet
characteristics and the rebound effect'', Transportation Policy,
Volume 24, pp. 284-295. See also Section 3.4 of 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.
---------------------------------------------------------------------------
In practice, however, most studies have employed simplified models.
Many use price variables (e.g., price per gallon of fuel, or fuel cost
per mile driven) and some measure of aggregate economic activity, such
as GDP. However, some of these studies exclude potentially important
variables such as the amount of road capacity (which affects travel
speeds and may be related to other important characteristics of highway
infrastructure), or the price or availability of competing forms of
freight transport such as rail or barge (i.e., characteristics of the
overall freight transport network).
[[Page 40449]]
(a) Fuel Price and Fuel Cost Elasticities
This sub-section reviews econometric analyses of 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.
Gately (1990) employed an econometric analysis of U.S. data for the
years 1966-1988 to examine the relationship between HDV VMT and average
fuel cost per mile, real Gross National Product (GNP), and variables
capturing the effects of fuel shortages in 1974 and 1979.\652\ The
study found no statistically significant relationship between HDV VMT
and fuel cost per mile. Gately's estimates of the elasticity of HDV VMT
with respect to fuel cost per mile were -0.035 with and -0.029 without
the fuel shortage variables, but both estimates had large standard
errors. However, Gately's study was beset by numerous statistical
problems, which raise serious questions about the reliability of its
results.\653\
---------------------------------------------------------------------------
\652\ Gately, D., The U.S. Demand for Highway Travel and Motor
Fuels, The Energy Journal, Volume 11, No. 3, July 1990, pp.59-73.
\653\ The most important of these problems--similar historical
time trends in the model's dependent variable and the measures used
to explain its historical variation--can lead to ``spurious
regressions,'' or the appearance of behavioral relationships that
are simply artifacts of the similarity (or correlation) in
historical trends among the model's variables.
---------------------------------------------------------------------------
More recently, Matos and Silva (2011) analyzed road freight
transportation sector data for the years 1987-2006 in Portugal to
identify the determinants of demand for HDV freight
transportation.\654\ Using a reduced-form equation relating HDV use
(measured in ton-km) to economic activity (GDP) and the energy cost of
HDV use (measured in fuel cost per ton-km carried), these authors
estimated the elasticity of HDV ton-km with respect to energy costs to
be -0.241. An important strength of Matos and Silva's study is that it
also estimated this same elasticity using a procedure that accounted
for the effect of potential mutual causality between HDV ton-km and
energy costs, and arrived at an identical value.
---------------------------------------------------------------------------
\654\ Matos, F.J.F., and Silva, F.J.F., ``The Rebound Effect on
Road Freight Transport: Empirical Evidence from Portugal,'' Energy
Policy, 39, 2011, pp. 2833-2841.
---------------------------------------------------------------------------
Differences between HDV use and the level of highway service in
Portugal and in the U.S. might limit the applicability of Matos and
Silva's result to the U.S. The volume and mix of commodities could
differ between the two nations, as could the levels of congestion on
their respective highway networks, transport distances, the extent of
intermodal competition, and the characteristics of HDVs themselves.
HDVs also operate over a more limited highway network in Portugal than
in the United States. Unfortunately, it is difficult to anticipate how
these differences might cause Matos and Silva's elasticity estimates to
differ from what we might find in the U.S. Finally, their analysis
focused on HDV freight transport and did not consider non-freight uses
of HDVs, which somewhat limits its usefulness in the analysis of this
proposed rulemaking.
De Borger and Mulalic (2012) examined the determinants of fuel use
in the Denmark HDV freight transport sector for the years 1980-2007.
The authors developed a system of equations that capture linkages among
the demand for HDV freight transport, HDV fleet characteristics, and
HDV fuel consumption.\655\ As De Borger and Mulalic state, ``we
precisely define and estimate a rebound effect of improvements in fuel
efficiency in the trucking industry: Behavioral adjustments in the
industry imply that an exogenous improvement in fuel efficiency reduces
fuel use less than proportionately. Our best estimate of this effect is
approximately 10 percent in the short run and 17 percent in the long
run, so that a 1 percent improvement in fuel efficiency reduces fuel
use by 0.90 percent (short-run) to 0.83 percent (long-run).''
---------------------------------------------------------------------------
\655\ De Borger, B. and Mulalic, I., ``The determinates of fuel
use in the trucking industry--volume, fleet characteristics and the
rebound effect'', Transportation Policy, Volume 24, November 2012,
pp. 284-295.
---------------------------------------------------------------------------
While De Borger and Mulalic capture a number of important responses
that contribute to the rebound effect, some caution is appropriate when
using their results to estimate the VMT rebound effect for this
proposal. Like the Matos and Silva study, this study examined HDV
activity in another country, Denmark, which has a less-developed
highway system, lower levels of freight railroad service than the U.S.,
and is also likely to have a different composition of freight shipping
activity. Although the effect of some of these differences is unclear,
greater competition from rail shipping in the U.S. and the resulting
potential for lower trucking costs to divert some rail freight to truck
could cause the VMT rebound effect to be larger in the U.S. than De
Borger and Mulalic's estimate for Denmark.
On the other hand, if freight networks are denser and commodity
types are more homogenous in Denmark than the U.S., then shippers may
have wider freight trucking options. If this is the case, shippers in
Denmark might be more sensitive to changes in freight costs, which
could cause the rebound effect in Denmark to be larger than the U.S.
Like the Matos and Silva study, this analysis also focuses on freight
trucking and does not consider non-freight HDVs (e.g. vocational
vehicles). We have been unable to identify adequate data to employ De
Borger and Mulalic's model for the U.S. (mainly because time-series
data on freight carriage by trucks, driver wages, and vehicle prices in
the U.S. are limited).
The Volpe National Transportation Systems Center previously has
developed a series of travel forecasting models for the Federal Highway
Administration (FHWA).\656\ Work conducted by the Volpe Center during
2009-2011 to develop the original version of FHWA's forecasting model
was presented in the Regulatory Impact Analysis for the HD GHG Phase 1
rule (see Table 9-2 in that document, which is reproduced below as
Table IX-11).\657\ In the analysis for the Phase 1 rule, Volpe
estimated both state-level and national aggregate models to forecast
HDV single unit and combination truck VMT that included fuel cost per
mile as an explanatory variable. This analysis used data from 1970-2008
for its national aggregate model, and data for the 50 individual states
from 1994-2008 for its state-level model.658 659
---------------------------------------------------------------------------
\656\ FHWA Travel Analysis Framework Development of VMT
Forecasting Models for Use by the Federal Highway Administration May
12, 2014 http://www.fhwa.dot.gov/policyinformation/tables/vmt/vmt_model_dev.pdf. Volpe's work was advised by a panel of
approximately 20 experts in the measurement, analysis, and
forecasting of travel, including academic researchers,
transportation consultants, and members of local, state, and federal
government transportation agencies. It was also summarized in the
paper ``Developing a Multi-Level Vehicle Miles of Travel Forecasting
Model,'' November, 2011, which was presented to the Transportation
Research Board's 91st Annual Meeting in January, 2012.
\657\ EPA/NHTSA, August 2011. Chapter 9.3.3, Final Rulemaking to
Establish Greenhouse gas Emission Standards & Fuel Efficiency
Standards for Medium-and Heavy-Duty Engines and Vehicles, Regulatory
Impact Analysis. EPA-420-R-11-901. (http://www.epa.gov/otaq/climate/documents/420r11901.pdf).
\658\ Combination trucks are defined as ``all [Class 7/8] trucks
designed to be used in combination with one or more trailers with a
gross vehicle weight rating over 26,000 lbs.'' (AFDC, 2014; ORNL,
2013c). Single-unit trucks are defined as ``single frame trucks that
have 2-axles and at least 6 tires or a gross vehicle weight rating
exceeding 10,000 lbs.'' (FHWA, 2013).
\659\ The national-level and functional class VMT forecasting
models utilize aggregate time-series data for the nation as a whole,
so that only a single measure of each variable is available during
each time period (i.e., year). In contrast, the state-level VMT
models have an additional data dimension, since both their dependent
variable (VMT) and most explanatory variables have 51 separate
observations available for each time period (one for each of the 50
states as well as Washington, DC). In this context, the states
represent a ``cross-section,'' and a continuous annual sequence of
these cross-sections is available.
---------------------------------------------------------------------------
[[Page 40450]]
Volpe analysts tested a large number of different specifications
for its national and state level models that incorporated the effects
of factors such as aggregate economic activity and its composition, the
volume of U.S. exports and imports, and factors affecting the cost of
producing trucking services (e.g., driver wage rates, truck purchase
prices, and fuel costs), and the extent and capacity of the U.S. and
states' highway networks.
Table IX-11 summarizes Volpe's Phase 1 estimates of the elasticity
of truck VMT with respect to fuel cost per mile.\660\ As it indicates,
these estimates vary widely, and the estimates based on state-level and
national data differ substantially.
---------------------------------------------------------------------------
\660\ One drawback of the fuel cost measure employed in Volpe's
models is that it is based on estimates of fuel economy derived from
truck VMT and fuel consumption, which introduces the potential for
mutual causality (or ``simultaneity'') between VMT and the fuel cost
measure and makes the effect of the latter difficult to isolate.
This may cause their estimates of the sensitivity of truck VMT to
fuel costs to be inaccurate, although the direction of any resulting
bias is difficult to anticipate.
Table IX-11--Summary of Volpe Center Estimates of Elasticity of Truck VMT With Respect to Fuel Cost per Mile
----------------------------------------------------------------------------------------------------------------
National data State data
Truck type ----------------------------------------------------------------
Short run Long run Short run Long run
----------------------------------------------------------------------------------------------------------------
Single Unit.................................... 13-22% 28-45% 3-8% 12-21%
Combination.................................... N/A 12-14% N/A 4-5%
----------------------------------------------------------------------------------------------------------------
Volpe staff conducted additional analysis of the models that
yielded the estimates of the elasticity of truck VMT with respect to
fuel cost per mile reported in Table IX-11, using updated information
on fuel costs and other variables appearing in these models, together
with revised historical data on truck VMT provided by DOT's Federal
Highway Administration. The newly-available data, statistical
procedures employed in conducting this additional analysis, and its
results are summarized in materials that can be found in the docket for
this rulemaking. This new Volpe analysis was not available at the time
the agencies selected the values of the rebound effect for this
proposal, but the agencies will consider this work and any other work
in the analysis supporting the final rule.
Finally, EPA has contracted with Energy and Environmental Research
Associates (EERA), LLC to analyze the HDV rebound effect for regulatory
assessment purposes. Excerpts of EERA's initial report to EPA are
included in the docket and contain detailed qualitative discussions of
the rebound effect as well as data sources that could be used in
quantitative analysis.\661\ EERA also conducted follow-on quantitative
analyses focused on estimating the impact of fuel prices on VMT and
fuel consumption. We have included a working paper in the docket on
this work, and we seek comment on this work.\662\ Note that EERA's
working paper was not available at the time the agencies conducted the
analysis of the rebound effect for this proposal, but the agencies will
consider this work and any other work in the analysis supporting the
final rule.
---------------------------------------------------------------------------
\661\ 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.
\662\ 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.
---------------------------------------------------------------------------
There are reasons to be cautious about interpreting the
elasticities from the studies reviewed in this section as a measure of
VMT rebound resulting from our proposed standards. For example, vehicle
capacity and loaded weight can vary dynamically in the HDV sector--
possibly in response to changes in fuel price and fuel efficiency--and
data on these measures are limited. This makes it difficult to
confidently infer a direct relationship between trucking output (e.g.,
ton-miles carried) and VMT assuming a constant average payload.
In addition, fuel cost per mile--calculated by multiplying fuel
price per gallon by fuel efficiency in gallons per mile--and fuel price
may be imprecise proxies for an improvement in fuel efficiency, because
the response of VMT to these variables may differ. For example, if
truck operators are more attentive to variation in fuel prices than to
changes in fuel efficiency, then fuel price or fuel cost elasticities
may overstate the true magnitude of the rebound effect.
Similarly, there is some evidence in the literature that demand for
crude petroleum and refined fuels is more responsive to increases than
to decreases in their prices, although this research is not specific to
the HDV sector.\663\ Since improved fuel efficiency typically causes
fuel costs for HDVs to fall (and assuming fuel costs are not fully
offset by increases in vehicle purchase prices), fuel price or cost
elasticities derived from historical periods when fuel prices were
increasing or fuel efficiency was declining may also overstate the
magnitude of the rebound effect. An additional unknown is that HDV
operators may factor fuel prices and fuel costs into their decision-
making about rates to charge for their service differently from the way
they incorporate initial vehicle purchase costs.
---------------------------------------------------------------------------
\663\ Gately, D. 1993. The Imperfect Price-Reversibility of
World Oil Demand. The Energy Journal, International Association for
Energy Economics, vol. 14 (4), pp. 163-182; Dargay, J.M., Gately, D.
1997. The demand for transportation fuels: Imperfect price-
reversibility? Transportation Research Part B 31(1); and Sentenac-
Chemin, E., 2012. Is the price effect on fuel consumption symmetric?
Some evidence from an empirical study. Energy Policy, vol. 41, pp.
59-65.
---------------------------------------------------------------------------
Despite these limitations, elasticities with respect to fuel price
and fuel cost can provide some insight into the magnitude of the HDV
VMT rebound effect. The agencies request comment on all of the studies
presented in this section.
(b) Freight Price Elasticities
Freight price elasticities measure the percent change in demand for
freight in response to a percent change in freight prices, controlling
for other variables that may influence freight demand such as GDP, the
extent that goods are traded internationally, and road supply and
capacity. This type of elasticity is only applicable to the HDV
subcategory of freight trucks (i.e., combination tractors and
vocational vehicles that transport freight). One desirable attribute of
such measures for purposes of this analysis is that they show the
response of freight
[[Page 40451]]
trucking activity to changes to trucking rates, including changes that
result from fuel cost savings as well as increases in HDV technology
costs.\664\
---------------------------------------------------------------------------
\664\ Note however that a percent change in freight activity in
response to a percent change in freight rates should theoretically
be larger than a percent change in freight activity in response to a
percent change in fuel efficiency because fuel efficiency only
impacts a portion of freight operating costs (e.g., fuel and vehicle
costs, but not likely driver wages or highway tolls).
---------------------------------------------------------------------------
Freight price elasticities, however, are imperfect proxies for the
rebound effect in freight trucks for a number of reasons.\665\ For
example, in order to apply these elasticities we must assume that our
proposed rule's impact on fuel and vehicle costs is fully reflected in
freight rates. This may not be the case if truck operators adjust their
profit margins or other operational practices (e.g., loading practices,
truck driver's wages) instead of freight rates. It is not well
understood how trucking firms respond to different types of cost
changes (e.g., changes to fuel costs versus labor costs).
---------------------------------------------------------------------------
\665\ 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.
---------------------------------------------------------------------------
Freight price elasticity estimates in the literature typically
measure freight activity in tons or ton-miles, rather than VMT. As
discussed in the previous section, average truck capacity and payload
in the HDV sector varies dynamically--possibly in response to changes
in fuel price and fuel efficiency--and data on these measures are
limited. This makes it difficult to confidently infer a direct
relationship between ton-miles and VMT by assuming a constant average
payload. Inferring a direct relationship between tons and VMT is even
less straightforward. Additionally, there are significant limitations
on national freight rate and freight truck ton-mile data in the U.S.,
making it difficult to confidently measure the impact of a change in
freight rates on ton-miles.\666\
---------------------------------------------------------------------------
\666\ See, for example, Appendix E in EERA (2014), ``Research to
Inform Analysis of the Heavy-Duty Vehicle Rebound Effect'', Draft
Final Report of Phase 1 under EPA contract EP-C-13-025.
---------------------------------------------------------------------------
Finally, freight price elasticity estimates in the literature vary
significantly based on commodity type, length of haul, region,
availability of alternative modes (discussed further in Section
IX.E.b.iii below), and functional form of the model (i.e., log-linear,
linear, translog) making it difficult to confidently apply any single
estimate reported in the literature to nationwide freight activity. For
example, elasticity estimates for longer trips tend to be larger in
magnitude than those for shorter trips, while demand to ship bulk
commodities tends to be less elastic than for non-bulk commodities.
Although these factors explain some of the differences among
reported estimates, much of the observed variation cannot be explained
quantitatively. For example, one study that controlled for mode,
commodity class, demand elasticity measure (i.e., tons or ton-miles),
model estimation form, country, and temporal nature of data only
accounted for about half of the observed variation.\667\
---------------------------------------------------------------------------
\667\ Li, Z., D.A. Hensher, and J.M. Rose, Identifying sources
of systematic variation in direct price elasticities from revealed
preference studies of inter-city freight demand. Transport Policy,
2011.
---------------------------------------------------------------------------
(c) Mode Shift Case Study
Although the total demand for freight transport is generally
determined by economic activity, there is often the choice of shipping
freight on modes other than HDVs. This is because the United States has
extensive rail, waterway, pipeline, and air transport networks in
addition to an extensive highway network; these networks often closely
parallel each other and are often viable choices for freight transport
for many long-distance shipping routes within the continental U.S. If
rates for one mode decline, demand for that mode is likely to increase,
and some of this new demand could represent shifts from other
modes.\668\ The ``cross-price elasticity of demand,'' which measures
the percentage change in demand for shipping by another mode (e.g.,
rail) given a percentage change in the price of HDV freight transport
services, provides a measure of the importance of such mode shifting.
Aggregate estimates of cross-price elasticities vary widely,\669\ and
there is no general consensus on the most appropriate value to use for
analytical purposes.
---------------------------------------------------------------------------
\668\ Rail lines in parts of the U.S. are thought to be
currently oversubscribed. If that is the case, and new freight
demand is already being satisfied by trucks, then this would limit
the potential for intermodal freight shifts between trucks and rail
as the result of this proposed rule.
\669\ 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.
---------------------------------------------------------------------------
When considering intermodal shift, one of the most relevant kinds
of shipments are those that are competitive between rail and HDV modes.
These trips generally include long-haul shipments greater than 500
miles, which weigh between 50,000 and 80,000 lbs (the legal road limit
in many states). Special kinds of cargo like coal and short-haul
deliveries are of less interest because they are generally not
economically transferable between HDV and rail modes, so they would not
be expected to shift modes except under an extreme price change.
However, to the best of our knowledge, the total amount of freight that
could potentially be subject to mode shifting has not been studied
extensively.
In order to explore the potential for HDV fuel efficiency standards
to produce economic conditions that favor a mode shift from rail to
HDVs, EPA commissioned GIFT Solutions, LLC to perform case studies on
the HD GHG Phase 1 rule using a number of data sources, including the
Commodity Flow Survey, interviews with trucking firms, and the
Geospatial Intermodal Freight Transportation (GIFT) model developed by
Winebrake and Corbett, which includes information on infrastructure and
other route characteristics in the U.S.670 671
---------------------------------------------------------------------------
\670\ Winebrake, James and James J. Corbett (2010). ``Improving
the Energy Efficiency and Environmental Performance of Goods
Movement,'' in Sperling, Daniel and James S. Cannon (2010) Climate
and Transportation Solutions: Findings from the 2009 Asilomar
Conference on Transportation and Energy Policy. See http://www.its.ucdavis.edu/events/2009book/Chapter13.pdf.
\671\ Winebrake, J.J.; Corbett, J.J.; Falzarano, A.; Hawker,
J.S.; Korfmacher, K.; Ketha, S.; Zilora, S., Assessing Energy,
Environmental, and Economic Tradeoffs in Intermodal Freight
Transportation, Journal of the Air & Waste Management Association,
58(8), 2008 (Docket ID: EPA-HQ-OAR-2010-0162-0008).
---------------------------------------------------------------------------
A central assumption in the case studies was that economic
conditions would favor a shift from rail to HDVs if either the price
per ton-mile to ship a commodity by HDV, or the price to ship a given
quantity of a commodity by HDV, became lower relative to rail transport
options post-regulation. The results of the case studies indicate that
the HD Phase 1 rule would not seem to create obvious economic
conditions that lead to a mode shift from rail to truck, but there are
a number of limitations and caveats to this analysis, which are
discussed in the final report to EPA by GIFT.672 673 For
example, even if trucking did not become less expensive than rail post-
regulation, a relative decrease in the truck versus rail rates might be
enough to produce a shift, given that other factors could influence
shippers' decisions on modal choice. The study did not, however,
consider these other factors such as time-of-delivery and modal
capacity. As another example, the analysis assumes all fuel cost
savings and incremental vehicle
[[Page 40452]]
costs from the HD Phase 1 rule would be passed on to shippers via
changes in freight rates, even though the analysis found some evidence
that this might not occur (in two cases, the charges for shipping a
truckload over a given route and distance were the same despite
differences in payloads that should have been reflected in their fuel
costs). Given these limitations, more work is needed in this area to
explore the potential for mode shift in response to HD fuel efficiency
standards.
---------------------------------------------------------------------------
\672\ See GIFT Solutions, LLC, ``Potential for Mode Shift due to
Heavy Duty Vehicle Fuel Efficiency Improvements''. February, 2012.
\673\ Winebrake, James, J. Corbett, J. Silberman, E. Erin, & B.
Comer, 2012. Potential for Mode Shift due to Heavy Duty Vehicle Fuel
Efficiency Improvements: A Case Study Approach. GIFT Solutions, LLC.
---------------------------------------------------------------------------
(d) Case Study Using Freight Price Elasticities
Cambridge Systematics, Inc. (CSI) employed a case study approach
using freight price elasticity estimates in the literature to show
several examples of the magnitude of the HDV rebound effect.\674\ In
their unpublished paper commissioned by the National Research Council
of the National Academies in support of its 2010 HDV report, CSI
estimated the effect on HDV VMT from a net decrease in operating costs
associated with fuel efficiency improvements, using two different
technology cost and fuel savings scenarios for Class 8 combination
tractors. Scenario 1 increased average fuel efficiency of the tractor
from 5.59 miles per gallon to 6.8 miles per gallon, with an additional
cost of $22,930 for purchasing the improved tractor. Scenario 2
increased the average fuel efficiency to 9.1 miles per gallon, at an
incremental cost of $71,630 per tractor. Both of these scenarios were
based on the technologies and targets from a report authored by the
Northeast States Center for a Clean Air Future (NESCCAF) and
International Council on Clean Transportation (ICCT).\675\
---------------------------------------------------------------------------
\674\ Cambridge Systematics, Inc., Assessment of Fuel Economy
Technologies for Medium and Heavy Duty Vehicles: Commissioned Paper
on Indirect Costs and Alternative Approaches, 2009.
\675\ Northeast States Center for a Clean Air Future, Southeast
Research Institute, TIAX, LLC., and International Council on Clean
Transportation, Reducing Heavy-Duty Long Haul Truck Fuel Consumption
and CO2 Emissions, September 2009. See http://www.nescaum.org/documents/heavy-duty-truck-ghg_report_final-200910.pdf.
---------------------------------------------------------------------------
The CSI estimates were based on a range of direct (or ``own-
price'') freight elasticities (-0.5 to -1.5) \676\ and cross-price
freight elasticities (0.35 to 0.59) \677\ obtained from the
literature.\678\ In their calculations, CSI assumed 142,706 million
miles of tractor VMT and 1,852 billion ton-miles were affected. The
tractor VMT was based on the Bureau of Transportation Statistics' (BTS)
estimate of highway miles for combination tractors in 2006, and the
rail ton-miles were based on the BTS estimate of total railroad miles
during 2006. This assumption is likely to overstate the rebound effect,
since not all freight shipments occur on routes where tractors and rail
service shipments compete directly. Nevertheless, this assumption
appears to be reasonable in the absence of more detailed information on
the percentage of total miles and ton-miles that are subject to
potential mode shifting.
---------------------------------------------------------------------------
\676\ Graham and Glaister, ``Road Traffic Demand Elasticity
Estimates: A Review,'' Transport Reviews Volume 24, 3, pp. 261-274,
2004.
\677\ Based upon a study for the National Cooperative Highway
Research Program by Cambridge Systematics, Inc., Characteristics and
Changes in Freight Transportation Demand: A Guidebook for Planners
and Policy Analysts Phase II Report, National Cooperative Highway
Research Program Project 8-30, June 1995.
\678\ The own (i.e., self) price elasticity provides a measure
for describing how the volume of truck shipping (demand) changes
with its price while the cross-price elasticity provides a measure
for describing how the volume of rail shipping changes with truck
price. In general, an elasticity describes the percent change in one
variable (e.g. demand for trucking) in response to a percent-change
in another (e.g. price of truck operations).
---------------------------------------------------------------------------
For CSI's calculations, all costs except fuel costs and vehicle
costs were taken from a 2008 ATRI study.\679\ It is not clear from the
report how the new vehicle costs were incorporated into CSI's
calculations of per-mile tractor operating costs. For example, neither
the ATRI report nor the CSI report discusses assumptions about
depreciation, useful lifetimes of tractors, and the opportunity cost of
capital.
---------------------------------------------------------------------------
\679\ American Transportation Research Institute, ``An Analysis
of the Operational Costs of Trucking'', October 2008.
---------------------------------------------------------------------------
Based on these two scenarios, CSI estimated the change in tractor
VMT in response to a net decrease in operating costs (i.e., accounting
for fuel cost and changes in tractor purchase costs) associated with
fuel efficiency improvement of 11-31 percent for Scenario 1 and 5-16
percent for Scenario 2, without accounting for any fuel savings from
reduced rail service. When the fuel savings from reduced rail usage
were included in the calculations, they estimated the change in tractor
VMT in response to a net decrease in operating costs associated with
fuel efficiency improvement would be 9-30 percent for Scenario 1, and
3-15 percent for Scenario 2.
Note that these estimates reflect changes to tractor VMT with
respect to total operating costs, so they should theoretically be
larger than a percent change in tractor VMT with respect to a percent
change in fuel efficiency because fuel efficiency only impacts a
portion of truck operating costs (e.g., fuel and vehicle costs, but not
likely driver wages or highway tolls).
CSI included caveats associated with these calculations. For
example, their report states that freight price elasticity estimates
derived from the literature are ``heavily reliant on factors including
the type of demand measures analyzed (vehicle-miles of travel, ton-
miles, or tons), geography, trip lengths, markets served, and
commodities transported.'' These factors can increase variability in
the results. Also, estimates in CSI's study have the limitation of
using freight price elasticities to estimate the HDV rebound effect
discussed previously in Section IV.D.2.b.
(e) Simulation Model Study Using Freight Price Elasticities
Guerrero (2014) constructs a freight simulation model of the
California trucking sector to measure the impact of fuel saving
investments and fleet management on GHG emissions.\680\ Rather than
estimating these impacts using econometric analysis of raw data, the
study uses values from the existing literature. Guerrero determines
that ``. . . improving the performance of trucking also increases the
number of trips demanded because the market price also decreases. This
`rebound' effect offsets around 40-50 percent of these vehicle
efficiency emission reductions, with 9-14 percent of the effect coming
from increased pavement deterioration and 31-36 percent coming from
increased fuel combustion.'' Note that to the extent that trip lengths
also vary in response to improvements in HDV fuel efficiency, changes
in the number of HDV trips may not exactly reflect changes in the total
number of miles the vehicles are operated.
---------------------------------------------------------------------------
\680\ Guerrero, Sebastian. Modeling fuel saving investments and
fleet management in the trucking industry: The impact of shipment
performance on GHG emissions. Transportation Research Part E, May
2014.
---------------------------------------------------------------------------
However, these findings are based on freight price elasticities,
which--as we discuss in Section IV.D.2.b and in the context of the CSI
study above--have significant limitations. The study also simulates
only one state's freight network (California), which may not be a good
representation of national activity.
(3) How the Agencies Estimated the HDV Rebound Effect for This Proposal
(a) Values Used in the Phase 1 Analysis
At the time the agencies conducted their analysis of the Phase 1
fuel efficiency and GHG emissions standards, the only evidence on the
HDV rebound effect were the previously
[[Page 40453]]
described studies from CSI and the Volpe Center.\681\ The agencies
determined that this evidence did not lend itself to a specific
quantitative value for use in the analysis. Rather, based on a
qualitative assessment of this evidence informed by the agencies' best
professional judgement, the agencies chose rebound effects of 15
percent for vocational vehicles and 5 percent for combination tractors,
both of which were toward the lower end of the range of values from
these studies. The agencies found no evidence on the rebound effect for
HD pickup trucks and vans, but concluded it would be inappropriate to
use the values selected for vocational vehicles or combination tractors
for those vehicles. Because the usage patterns of HD pickup trucks and
vans can more closely resemble those of large light-duty vehicles, the
agencies used our judgement to select the 10 percent rebound effect we
had employed in our most recent light-duty rulemaking to analyze the
Phase 1 standards for 2b/3 vehicles.
---------------------------------------------------------------------------
\681\ The Gately study was also available, however, the agencies
were not aware of the work at the time.
---------------------------------------------------------------------------
(b) How the Agencies Analyzed VMT Rebound in This Proposal
After considering the new evidence that has become available since
the HD Phase 1 final rule, the agencies elected to continue using the
rebound effect estimates we used previously in the HD Phase 1 rule in
our analysis of Phase 2 proposed standards. In arriving at this
decision, the agencies considered the shortcomings and limitations of
the newly-available studies described previously, particularly the
limited applicability of the two published studies using data from
European nations to the U.S. context. After weighing these attributes
of the more recent studies, the agencies concluded that we had
insufficient evidence to justify revising the rebound effect values
that were used in the Phase 1 analysis.
In our assessment, we do not differentiate between short-run and
long-run rebound effects, although these effects may differ. The
vocational and combination truck estimates are based on the Volpe
Center analysis presented in the HD Phase 1 rule and the case study
from CSI. As with the HD Phase 1 rule, we did not find any literature
specifically examining the HD pickup and truck sector. Since these
vehicles are used for very different purposes than combination tractors
and vocational vehicles, and they are more similar in use to large
light-duty vehicles, we have chosen the light-duty rebound effect of 10
percent used in the final rule establishing fuel economy and GHG
standards for MYs 2017-2025 light-duty vehicles in our analysis of HD
pickup trucks and vans.
While for this proposal, the agencies have selected to use these
rebound effect values of 5 percent for combination tractors, 10 percent
for heavy duty pickup trucks and vans and 15 percent for vocational
vehicles, we acknowledge the literature shows a wide range of rebound
effect estimates. Therefore, we will review and consider revising these
estimates in the final rule, taking into consideration all available
data and analysis, including submissions from public commenters and new
research on the rebound effect.
It should be noted that the rebound estimates we have selected for
our analysis represent the VMT impact from our proposed standards with
respect to changes in the fuel cost per mile driven. As described
previously, 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 proposal, 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.
The agencies made simplifying assumptions in the VMT rebound
analysis for this proposal, similar to the approach taken during the
development of the HD GHG Phase 1 final rule. However, for the HD Phase
2 final rulemaking, we plan to use a more comprehensive approach. Due
to timing constraints during the development of this proposal, the
agencies did not have the technology package costs for each of the
alternatives prior to the need to conduct the inventory analysis,
except for the pickup truck and van category in analysis Method A.
Therefore, the same ``overall'' VMT rebound values were used for
Alternatives 2 through 5 (as discussed in Chapter 8.3.3 of the Draft
RIA and analyzed in Chapter 6 of the Draft RIA), despite the fact that
each alternative results in a different change in incremental
technology and fuel costs. For the final rulemaking, we plan to
determine VMT rebound separately for each HDV category and for each
alternative. Tables 64 through 66 in Chapter 7 of the Draft RIA present
VMT rebound for each HDV sector that we estimated for the preferred
alternative. 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 VI and VII of this preamble for all
categories.
Section 9.3.3 in the draft RIA provides more details on our
assessment of HDV VMT rebound. We invite comment on our approach, the
rebound estimates, and the related assumptions we made. In particular,
we invite comment on the most appropriate methodology for factoring new
vehicle purchase or leasing costs into the per-mile operating costs.
For the purposes of this proposal, 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. We invite comment on this assumption, as well as
suggestions on alternative modeling frameworks that could be used to
assess mode shifting implications of our proposed regulations.
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. We invite comment on
suggested modeling frameworks or data that could be used to assess the
potential for activity to shift from older to newer, more efficient
HDVs in response to our proposed standards.
Note that while we focus on the VMT rebound effect in our analysis
of this proposed rule, there are at least two other types of rebound
effects discussed in the 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.
Research on indirect and economy-wide rebound effects is nascent,
and we have not identified any that attempts to quantify indirect or
economy-wide rebound effects for HDVs. In particular, the agencies are
not aware of any data to indicate that the magnitude of indirect or
economy-wide rebound effects, if any, would be significant for this
proposed rule.\682\ Therefore, we rely
[[Page 40454]]
the same analysis of vehicle miles traveled to estimate the rebound
effect in this proposal that we did for the HD Phase 1 rule, where we
attempted to quantify only rebound effects from our rule that impact
HDV VMT. We welcome comments and any new work in this area that helps
to assess and quantify different rebound effects that could result from
improvements in HDV efficiency, including different types of more
intensive truck usage that affect fuel consumption but not VMT such as
loaded weight, truck routing, and scheduling.
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\682\ One entity 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.
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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 Phase 2 Preferred Alternative 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 the
proposed standards under the assumptions of 5, 15, and 20 percent
rebound effects.
Alternative values of the rebound effect change the estimates of
benefits and costs from the proposed standards in three ways. First,
higher values of the rebound effect increase the amount of additional
VMT that results from improved fuel efficiency; this increases costs
associated with additional congestion, accidents, and noise, thus
increasing total costs associated with the proposed standards.
Conversely, smaller values of the rebound effect reduce costs from
additional congestion, accidents, and noise, so they reduce total costs
of the proposed standards. Larger increases in VMT associated with
higher values of the rebound effect reduce the value of fuel savings
and related benefits (such as reductions in GHG emissions) by
progressively larger amounts, while smaller values of the rebound
effect cause smaller reductions in these benefits. At the same time,
however, a higher rebound effect generates larger benefits from
increased vehicle use, while a smaller rebound effect reduces these
benefits. Thus the impact of alternative values of the rebound effect
on total benefits from the proposed standards depends on the exact
magnitudes of these latter two effects. On balance, these three effects
can cause net benefits to increase or decrease for alternative values
of the rebound effect.
Table IX-12--Sensitivity of Preferred Alternative Impacts Under Different Assumptions About Rebound Effect for
Pickups and Vans, Using 3% Discount Rate
----------------------------------------------------------------------------------------------------------------
Rebound effect
---------------------------------------------------------------
Main analysis Sensitivity cases using
HD pickups and vans -------------------------------- alternative rebound
assumptions
10% 5% -------------------------------
15% 20%
----------------------------------------------------------------------------------------------------------------
Fuel Reductions (Billion Gallons)............... 7.8 8.2 7.5 7.1
GHG Reductions (MMT CO2 eq)..................... 94.1 95.7 87.2 83.0
Total Costs ($ billion)......................... 5.5 5.0 6.5 7.2
Total Benefits ($ billion)...................... 23.5 23.0 22.9 22.8
Net Benefits ($ billion)........................ 18.0 18.0 16.4 15.5
----------------------------------------------------------------------------------------------------------------
Table IX-12 summarizes the impact of these alternative assumptions
on fuel and GHG emissions savings, total costs, total benefits, and net
benefits. As it indicates, using a 5 percent value for the rebound
effect reduces benefits and costs of the proposed standards by
identical amounts, leaving net benefits unaffected. As the table also
shows, rebound effects of 15 percent and 20 percent increase costs and
reduce benefits compared to their values in the main analysis, thus
reducing net benefits of the proposed standards. Nevertheless, the
preferred alternative has significant net benefits under each
alternative assumption about the magnitude of the rebound effect for HD
pickups and vans. Thus, these alternative values of the rebound effect
would not have affected the agencies' selection of the preferred
alternative, 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.
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 proposed 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.\683\
NHTSA and EPA qualitatively evaluated the proposed 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;
[[Page 40455]]
from combination tractors to vocational vehicles; and within vocational
vehicles.
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\683\ 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 Phase 1 program and
will meet GHG/CAFE Phase 2 emission standards beginning in 2017. 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 even absent this program. These proposed 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 proposed 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 our proposed
regulation of heavy-duty pickups and vans could conceivably encourage a
class shift towards lighter pickups, this unintended consequence 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 proposed action differ
between Class 8 day cabs and Class 8 sleeper cabs, reflecting our
expectation that compliance with the proposed standards would lead
truck consumers to specify sleeper cabs equipped with APUs 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 higher cost for an 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.\684\ 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.\685\
---------------------------------------------------------------------------
\684\ 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.
\685\ The average marginal cost difference between sleeper cabs
and day cabs in the proposal 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 assume the purchase of an APU
for compliance, in fact our proposed 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 our
proposed 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 are proposing to 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 proposed regulatory program
would cause class shifting within the vocational vehicle class. The
marginal cost difference due to the regulation of vocational vehicles
is minimal. The cost of LRR tires on a per tire basis is the same for
all vocational vehicles so the only difference in marginal cost of the
vehicles is due to the number of axles. The agencies believe that the
utility gained from the additional load carrying capability of the
additional axle would outweigh the additional cost for heavier
vehicles.\686\
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\686\ The proposed rule projects the difference in costs between
the HHD and MHD vocational vehicle technologies is approximately
$30.
---------------------------------------------------------------------------
In conclusion, NHTSA and EPA believe that the proposed regulatory
structure for HD trucks would not significantly change the current
competitive and market factors that determine purchaser preferences
among truck types. 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 fuel efficiency. Therefore, the agencies did not include
an impact of class shifting on the vehicle populations used to assess
the benefits of the proposed program.
[[Page 40456]]
(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.
The 2010 NAS HD Report discussed the topics associated with HD
truck 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.\687\ However, those regulations increased upfront costs to firms
without any offsetting future cost savings from reduced fuel purchases.
In summary, NAS stated that:
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\687\ 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.
. . . 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.\688\
---------------------------------------------------------------------------
\688\ See NAS Report, Note 687, page 151.
The proposed regulations are projected to return fuel savings to
the truck 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 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 proposed 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, the
proposed 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 would 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.
Whether vehicle sales appear to be affected by the HD Phase 1
standards could provide some insight into the impacts of the proposed
standards. At the time of this proposed rule, sales data are not yet
available for 2014 model year, the first year of the Phase 1 standards.
In addition, any trends in sales are likely to be affected by
macroeconomic conditions, which have been recovering since 2009-2010.
As a result, it is unlikely to be possible, even when vehicle sales
data are available, 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 proposed heavy-duty GHG and fuel
efficiency standards using the social cost of carbon (SC-
CO2) estimates presented in the 2013 Technical Support
Document: Technical Update of the Social Cost of Carbon for Regulatory
Impact Analysis Under Executive Order 12866 (2013 SCC TSD).\689\ (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 used in regulatory impact analyses to quantify the benefits of
reducing CO2 emissions, or the disbenefit from increasing
emissions.
---------------------------------------------------------------------------
\689\ Docket ID EPA-HQ-OAR-2014-0827, Technical Support
Document: Technical Update of the Social Cost of Carbon for
Regulatory Impact Analysis Under Executive Order 12866, 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 (May 2013, Revised
November 2013). Available at: http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf.
---------------------------------------------------------------------------
The SC-CO2 estimates used in this analysis were
developed over many 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 \690\ and
[[Page 40457]]
updated in 2013 using new versions of each IAM. These estimates were
published in the 2013 SCC TSD. 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 SCC Technical Support Document
(2010 SCC TSD) provides a complete discussion of the methods used to
develop these estimates and the 2013 SCC TSD presents and discusses the
updated estimates.
---------------------------------------------------------------------------
\690\ 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.
---------------------------------------------------------------------------
The 2010 SCC 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. Current 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 SCC 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 have considered the
extensive public comments on ways to improve SC-CO2
estimation received via the notice and comment periods that were part
of numerous rulemakings. In addition, OMB's Office of Information and
Regulatory Affairs sought public comment on the approach used to
develop the SC-CO2 estimates (78 FR 70586, November 26,
2013). The comment period ended on February 26, 2014, and OMB is
reviewing the comments received. OMB also responded in January 2014 to
concerns submitted in a Request for Correction on the SCC TSDs.\691\
---------------------------------------------------------------------------
\691\ OMB's 1/24/14 response to the petition is available at
https://www.whitehouse.gov/sites/default/files/omb/inforeg/ssc-rfc-under-iqa-response.pdf.
---------------------------------------------------------------------------
The four global SC-CO2 estimates, updated in 2013, are
as follows: $13, $46, $68, and $140 per metric ton of CO2
emissions in the year 2020 (2012$).\692\ 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
higher-than-expected impacts from temperature change further out in the
tails of the SC-CO2 distribution (representing less likely,
but potentially catastrophic, outcomes). 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.
---------------------------------------------------------------------------
\692\ The 2013 SCC TSD presents the SC-CO2 estimates
in $2007. These estimates were adjusted to 2012$ using the GDP
Implicit Price Deflator. Bureau of Economic Analysis, Table 1.1.9
Implicit Price Deflators for Gross Domestic Product; last revised on
March 27, 2014.
---------------------------------------------------------------------------
Applying the global SC-CO2 estimates, shown in Table IX-
13, to the estimated reductions in domestic CO2 emissions
for the proposed 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 proposed rule.\693\ The SC-
CO2 benefit estimates for each calendar year are shown in
Table IX-14. The SC-CO2 benefit estimates for each model
year are shown in Table IX-15.
---------------------------------------------------------------------------
\693\ 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-13--Social Cost of CO\2\, 2012-2050 \a\
(in 2012$ per metric ton)
----------------------------------------------------------------------------------------------------------------
3%, 95th
Calendar year 5% Average 3% Average 2.5% Average Percentile
----------------------------------------------------------------------------------------------------------------
2012................................ $12 $37 $58 $100
2015................................ 12 40 61 120
2020................................ 13 46 69 140
2025................................ 15 51 74 150
2030................................ 17 56 81 170
2035................................ 20 60 86 190
2040................................ 23 66 93 210
2045................................ 26 71 99 220
2050................................ 28 77 100 240
----------------------------------------------------------------------------------------------------------------
Note:
\a\ The SC-CO2values are dollar-year and emissions-year specific and have been rounded to two significant
digits. Unrounded numbers from the 2013 SCC TSD were used to calculate the CO2 benefits.
[[Page 40458]]
Table IX-14--Upstream and Downstream Annual CO2 Benefits for the Given SC-CO2 Value \a\ Using Method B and
Relative to the Less Dynamic Baseline
[millions of 2012$] \b\
----------------------------------------------------------------------------------------------------------------
3%, 95th
Calendar year 5% Average 3% Average 2.5% Average Percentile
----------------------------------------------------------------------------------------------------------------
2018................................ $13 $43 $65 $130
2019................................ 26 91 130 270
2020................................ 40 140 210 420
2021................................ 92 330 500 1,000
2022................................ 170 590 880 1,800
2023................................ 250 860 1,300 2,600
2024................................ 400 1,300 1,900 4,000
2025................................ 540 1,800 2,600 5,500
2026................................ 720 2,300 3,400 7,000
2027................................ 890 2,900 4,200 8,900
2028................................ 1,100 3,500 5,100 11,000
2029................................ 1,300 4,200 5,900 13,000
2030................................ 1,500 4,800 6,900 15,000
2035................................ 2,500 7,400 11,000 23,000
2040................................ 3,300 9,700 14,000 30,000
2050................................ 5,000 14,000 19,000 42,000
NPV................................. 22,000 100,000 160,000 320,000
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ The SC-CO2 values are dollar-year and emissions-year specific.
\b\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the less
dynamic baseline, 1a, and more dynamic baseline, 1b, please see Section X.A.1.
Table IX-15--Upstream and Downstream Discounted Model Year Lifetime CO2 Benefits for the Given SC-CO2 Value
Using Method B and Relative to the Less Dynamic Baseline
[millions of 2012$] a b
----------------------------------------------------------------------------------------------------------------
3%, 95th
Model year 5% Average 3% Average 2.5% Average Percentile
----------------------------------------------------------------------------------------------------------------
2018................................ $93 $380 $580 $1,100
2019................................ 90 370 570 1,100
2020................................ 87 360 560 1,100
2021................................ 520 2,200 3,400 6,600
2022................................ 540 2,300 3,500 6,900
2023................................ 550 2,300 3,600 7,200
2024................................ 870 3,700 5,800 11,000
2025................................ 900 3,900 6,100 12,000
2026................................ 920 4,000 6,300 12,000
2027................................ 1,100 4,800 7,600 15,000
2028................................ 1,100 4,800 7,600 15,000
2029................................ 1,100 4,900 7,700 15,000
Sum................................. 7,800 34,000 53,000 100,000
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ The SC-CO2 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 less
dynamic baseline, 1a, and more dynamic baseline, 1b, please see Section X.A.1.
(2) Sensitivity Analysis--Monetized Non-CO2 GHG Impacts
One limitation of the primary benefits analysis is that it does not
include the valuation of non-CO2 GHG impacts (e.g.,
CH4, N2O, HFC-134a). Specifically, the 2010 and
2013 SCC TSDs do not include estimates of the social costs of non-
CO2 GHG emissions using an approach analogous to the one
used to estimate the SC-CO2. However, EPA recognizes that
non-CO2 GHG impacts associated with this rulemaking (e.g.,
net reductions in CH4,N2O, and HFC-134a) would
provide additional benefits to society. To understand the potential
implication of omitting these benefits, EPA has conducted sensitivity
analysis using two approaches: (1) An approximation approach based on
the global warming potentials (GWP) of non-CO2 GHGs, which
has been used in previous rulemakings, and (2) a set of recently
published SC-CH4 and SC-N2O estimates that are
consistent with the modeling assumptions underlying the SC-
CO2 estimates (Marten et al. 2014). This section presents
estimates of the non-CO2 benefits of the proposed rulemaking
using both approaches. Other unquantified non-CO2 benefits
are discussed in this section as well. Additional details are provided
in the RIA of these rules.
Currently, EPA is undertaking a peer review of the application of
the Marten et al. (2014) non-CO2 social cost estimates in
regulatory analysis. Pending a favorable peer review, EPA plans to
include monetized benefits of CH4 and N2O
emission reductions in the main benefit-cost analysis of the RIA for
the final rule, using the directly modeled estimates of SC-
CH4 and SC-N2O from Marten et al. EPA seeks
comments on the use of directly modeled estimates for the social cost
of non-CO2 GHGs.
[[Page 40459]]
(a) Non-CO2 GHG Benefits Based on the GWP Approximation
Approach
In the absence of directly modeled estimates, one potential method
for approximating the value of marginal non-CO2 GHG emission
reductions is to convert non-CO2 emissions reductions to
CO2-equivalents that may then be valued using the SC-
CO2. Conversion to CO2-equivalents is typically
based on the global warming potentials (GWPs) for the non-
CO2 gases. 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).\694\ 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.
---------------------------------------------------------------------------
\694\ 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://www.epa.gov/ttn/ecas/regdata/RIAs/oil_natural_gas_final_neshap_nsps_ria.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 SCC 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.
Similar to the approach used in the RIA of the Final Rulemaking for
2017-2025 Light-Duty Vehicle Greenhouse Gas Emission Standards and
Corporate Average Fuel Economy Standards (U.S. EPA, 2013), EPA applies
the GWP approach to estimate the benefits associated with reductions of
CH4, N2O and HFCs in each calendar year. Under
the GWP Approach, EPA converted CH4, N2O and HFC-
134a to CO2 equivalents using the AR4 100-year GWP for each
gas: CH4 (25), N2O (298), and HFC-134a
(1,430).\695\ 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 non-CO2
GHG benefits using the GWP approach are presented in Table IX-16
through Table IX-18. The total net present value of the GHG benefits
for this proposed rulemaking would increase by about $760 million to
$11 billion (2012$), depending on discount rate, or roughly 3 percent
if these non-CO2 estimates were included.
---------------------------------------------------------------------------
\695\ 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.''
Table IX-16--Annual Upstream and Downstream CH4 Benefits for the Given SC-CO2 Value Using Method B and Relative
to the Less Dynamic Baseline, Using the GWP Approach a b
[$Millions of 2012$] \b\
----------------------------------------------------------------------------------------------------------------
CH4
---------------------------------------------------------------------------
Calendar year 3%, 95th
5% Average 3% Average 2.5% Average Percentile
----------------------------------------------------------------------------------------------------------------
2018................................ $0.3 $1.1 $1.6 $3.2
2019................................ 0.6 2.2 3.3 6.6
2020................................ 1.0 3.5 5.2 10
2021................................ 3.1 11 17 33
2022................................ 6.0 20 30 62
2023................................ 8.8 30 45 93
2024................................ 14 46 68 140
2025................................ 19 62 91 190
2026................................ 25 79 120 240
2027................................ 30 99 140 300
2028................................ 36 120 170 360
2029................................ 43 140 200 420
2030................................ 49 160 230 480
2035................................ 82 240 350 760
2040................................ 110 320 440 990
2050................................ 160 440 600 1,400
NPV................................. 730 3,400 5,400 11,000
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ The SC-CO2 values are dollar-year and emissions-year specific
\b\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the less
dynamic baseline, 1a, and more dynamic baseline, 1b, please see Section X.A.1.
[[Page 40460]]
Table IX-17--Annual Upstream and Downstream N2O Benefits for the Given SC-CO2 Value Using Method B and Relative
to the Less Dynamic Baseline, Using the GWP Approach \a\ \b\
[$Millions of 2012$] \b\
----------------------------------------------------------------------------------------------------------------
N2O
---------------------------------------------------------------------------
Calendar year 3%, 95th
5% Average 3% Average 2.5% Average Percentile
----------------------------------------------------------------------------------------------------------------
2018................................ $0.0 $0.0 $0.1 $0.2
2019................................ 0.0 0.1 0.2 0.3
2020................................ 0.0 0.2 0.2 0.5
2021................................ 0.1 0.4 0.5 1.1
2022................................ 0.2 0.6 1.0 1.9
2023................................ 0.3 0.9 1.4 2.8
2024................................ 0.4 1.4 2.1 4.4
2025................................ 0.6 2.0 2.9 6.0
2026................................ 0.8 2.6 3.7 7.8
2027................................ 1.0 3.2 4.7 10
2028................................ 1.2 3.9 5.7 12
2029................................ 1.5 4.6 6.6 14
2030................................ 1.6 5.3 7.7 16
2035................................ 2.8 8.3 12 26
2040................................ 3.8 11 15 34
2050................................ 5.6 15 21 47
NPV................................. 25 120 180 360
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ The SC-CO2 values are dollar-year and emissions-year specific.
\b\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the less
dynamic baseline, 1a, and more dynamic baseline, 1b, please see Section X.A.1.
Table IX-18--Annual Upstream and Downstream HFC-134a Benefits for the Given SC-CO2 Value Using Method B and
Relative to the Less Dynamic Baseline, Using the GWP Approach \a\ \b\
[$Millions of 2012$] \b\
----------------------------------------------------------------------------------------------------------------
HFC-134a
---------------------------------------------------------------------------
Calendar year 3%, 95th
5% Average 3% Average 2.5% Average Percentile
----------------------------------------------------------------------------------------------------------------
2018................................ $0.0 $0.0 $0.0 $0.0
2019................................ 0.0 0.0 0.0 0.0
2020................................ 0.0 0.0 0.0 0.0
2021................................ 0.2 0.8 1.3 2.6
2022................................ 0.5 1.7 2.6 5.3
2023................................ 0.8 2.7 4.0 8.1
2024................................ 1.1 3.7 5.4 11
2025................................ 1.4 4.7 6.9 14
2026................................ 1.8 5.9 8.6 18
2027................................ 2.2 7.1 10 22
2028................................ 2.5 8.3 12 25
2029................................ 3.0 10 14 29
2030................................ 3.4 11 16 34
2035................................ 5.2 15 22 48
2040................................ 6.1 18 25 56
2050................................ 8.4 23 31 71
NPV................................. 44 200 320 630
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ The SC-CO2 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 less
dynamic baseline, 1a, and more dynamic baseline, 1b, please see Section X.A.1.
(b) Non-CO2 GHG Benefits Based on Directly Modeled Estimates
Several researchers have directly estimated the social cost of non-
CO2 emissions using integrated assessment models (IAMs),
though the number of such estimates is small compared to the large
number of SC-CO2 estimates available in the literature. As
discussed in previous RIAs (e.g., EPA 2012), 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. However, none of the other published estimates of the
social cost of non-CO2 GHG are consistent with the SC-
CO2 estimates, and most are likely underestimates due to
changes in the underlying science since their publication.
Recently, a paper by Marten et al. (2014) provided the first set of
published SC-CH4 and SC-N2O
[[Page 40461]]
estimates that are consistent with the modeling assumptions underlying
the SC-CO2.\696\ 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.
---------------------------------------------------------------------------
\696\ 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-19. 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). The tables do not
include HFC-134a because EPA is unaware of analogous estimates.
Table IX-19--Social Cost of CH4 and N2O, 2012-2050 \a\ [in 2012$ per metric ton]
[Source: Marten et al., 2014]
--------------------------------------------------------------------------------------------------------------------------------------------------------
SC-CH4 SC-N2O
-------------------------------------------------------------------------------------------------------
Year 2.5% 3% 95th 2.5% 3% 95th
5% Average 3% Average Average percentile 5% Average 3% Average Average percentile
--------------------------------------------------------------------------------------------------------------------------------------------------------
2012............................................ $440 $1,000 $1,400 $2,800 $4,000 $14,000 $20,000 $37,000
2015............................................ 500 1,200 1,500 3,100 4,400 15,000 22,000 39,000
2020............................................ 590 1,300 1,700 3,500 5,200 16,000 24,000 44,000
2025............................................ 710 1,500 19,000 4,100 6,000 18,000 27,000 50,000
2030............................................ 840 1,700 2,300 4,600 7,000 20,000 29,000 55,000
2035............................................ 990 2,000 2,500 5,400 8,100 23,000 32,000 61,000
2040............................................ 1,200 2,300 2,800 6,000 9,300 25,000 35,000 67,000
2045............................................ 1,300 2,500 3,100 6,800 11,000 27,000 38,000 73,000
2050............................................ 1,500 2,700 3,300 7,400 12,000 29,000 41,000 80,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ The values are emissions-year specific and have been rounded to two significant digits. Unrounded numbers were used to calculate the GHG benefits.
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-19 are used
to monetize the benefits of changes in CH4 and
N2O emissions expected as a result of the proposed
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-20.
Including these benefits would increase the total net present value of
the GHG benefits for this proposed rulemaking by about $1.5 billion to
$12 billion (2012$), or roughly 4 to 7 percent, depending on discount
rate.
Table IX-20--Annual Upstream and Downstream non-CO2 GHG Benefits for the Given SC-Non-CO2 Value Using Method B and Relative to the Less Dynamic
Baseline, Using the Directly Modeled Approach \a\ \b\
[Millions of 2012$] \c\
--------------------------------------------------------------------------------------------------------------------------------------------------------
CH4 N2O
-------------------------------------------------------------------------------------------------------
Calendar year 2.5% 3% 95th 2.5% 3% 95th
5% Average 3% Average Average percentile 5% Average 3% Average Average percentile
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018............................................ $0.6 $1.3 $1.6 $3.3 $0.0 $0.1 $0.1 $0.2
2019............................................ 1.1 2.6 3.4 6.8 0.0 0.1 0.2 0.3
2020............................................ 1.8 3.9 5.2 10 0.1 0.2 0.3 0.5
2021............................................ 5.8 13 17 35 0.1 0.4 0.6 1.2
2022............................................ 11 24 31 65 0.3 0.8 1.1 2.1
2023............................................ 17 35 49 97 0.4 1.1 1.7 3.1
2024............................................ 26 56 72 150 0.6 1.8 2.5 4.7
2025............................................ 35 74 95 200 0.8 2.4 3.5 6.5
2026............................................ 46 99 130 260 1.0 3.0 4.5 8.4
2027............................................ 57 120 150 320 1.3 4.0 5.8 11
2028............................................ 69 140 190 390 1.6 4.8 6.9 13
2029............................................ 82 170 220 460 1.9 5.8 8.2 15
2030............................................ 95 190 260 520 2.2 6.5 9.3 18
2035............................................ 160 330 400 870 3.7 10 15 28
2040............................................ 230 430 540 1,200 5.2 14 19 37
2050............................................ 350 620 770 1,700 7.9 20 27 53
NPV............................................. 1,500 4,600 6,400 12,000 34 150 230 400
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
[[Page 40462]]
\a\ The SC-CH4 and SC-N2O 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-N2O at 5, 3, and 2.5 percent) is used to calculate net present value discounted
values of SC-CH4 and SC-N2O for internal consistency. Refer to SCC TSD for more detail.
\c\ 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.
As illustrated above, compared to the use of directly modeled
estimates the GWP-based approximation approach underestimates the
climate benefits of the CH4 emission reductions by 12
percent to 52 percent and the climate benefits of N2O
reductions by 10 percent to 26 percent, depending on the discount rate
assumption.
(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, namely 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 \697\ ). Recent studies have produced an
estimate of a monetized benefit of methane emissions reductions, with
results on the order of $1,000 per metric ton of CH4
emissions reduced (Anenberg et al. 2012 \698\; Shindell et al. 2012
\699\), an estimate similar in magnitude to the climate benefits of
CH4 reductions estimated by the Marten et al. or GWP
methods. However, though EPA is continuing to monitor this area of
research as it evolves, EPA is not applying them for benefit estimates
at this time.
---------------------------------------------------------------------------
\697\ 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.
\698\ 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.
\699\ 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 analyzes 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 proposed
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 proposed standards are also significant sources of
mobile source air pollution such as direct PM, NOX, VOCs and
air toxics. The proposed standards would affect exhaust emissions of
these pollutants from vehicles and would 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 would result from the proposed 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 welfare.
It is important to quantify the health and environmental impacts
associated with the proposed standards because a failure to adequately
consider these 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.
Although EPA typically quantifies and monetizes the health and
environmental impacts related to both PM and ozone in its regulatory
impact analyses (RIAs), it was unable to do so in time for this
proposal. Instead, EPA has applied PM-related ``benefits per-ton''
values to its estimated emission reductions as an interim approach to
estimating the PM-related benefits of the proposal. 700 701
EPA also characterizes the health and environmental impacts that will
be quantified and monetized for the final rulemaking.
---------------------------------------------------------------------------
\700\ 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.
\701\ See also: http://www.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://www.epa.gov/airquality/benmap/models/Source_Apportionment_BPT_TSD_1_31_13.pdf (accessed
September 9, 2014).
---------------------------------------------------------------------------
This section is split into two sub-sections: the first presents the
benefits-per-ton values used to monetize the benefits from reducing
population exposure to PM associated with the proposed standards; the
second explains what PM- and ozone-related health and environmental
impacts EPA will quantify and monetize in the analysis for the final
rule. 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,\702\ the final 2012 p.m. NAAQS
Revision,\703\ and the final
[[Page 40463]]
2017-2025 Light Duty Vehicle GHG Rule.\704\
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\702\ 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://www.epa.gov/otaq/documents/tier3/420r14005.pdf.
\703\ 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://www.epa.gov/ttnecas1/regdata/RIAs/finalria.pdf.
\704\ 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://www.epa.gov/otaq/climate/documents/420r12016.pdf.
---------------------------------------------------------------------------
Though EPA is characterizing the changes in emissions associated
with toxic pollutants, we are not able to quantify or monetize the
human health effects associated with air toxic pollutants for either
the proposal or the final rule analyses (see Section VIII.G.1.b.iii for
more information). Please refer to Section VIII for more information
about the air toxics emissions impacts associated with the proposed
standards.
(1) Economic Value of Reductions in Criteria Pollutants
As described in Section VIII, the proposed standards would reduce
emissions of several criteria and toxic pollutants and their
precursors. In this analysis, EPA 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.\705\ Furthermore, the 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.
---------------------------------------------------------------------------
\705\ 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 could
be substantial.
---------------------------------------------------------------------------
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 proposed rules,
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 for this proposal. We will conduct this modeling
for the final rule.
The dollar-per-ton estimates used in this analysis are provided in
Table IX-21. 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 proposal.
Table IX-21--Benefits-per-Ton Values
[Thousands, 2012$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
On-road mobile sources Upstream sources \d\
Year \c\ -----------------------------------------------------------------------------------------------
Direct PM2.5 SO2 NOX Direct PM2.5 SO2 NOX
--------------------------------------------------------------------------------------------------------------------------------------------------------
Estimated Using a 3 Percent Discount Rate \b\
--------------------------------------------------------------------------------------------------------------------------------------------------------
2016.................................................... $380-$850 $20-$45 $7.7-$18 $330-$750 $69-$160 $6.8-$16
2020.................................................... 400-910 22-49 8.1-18 350-790 75-170 7.4-17
2025.................................................... 440-1,000 24-55 8.8-20 390-870 83-190 8.1-18
2030.................................................... 480-1,100 27-61 9.6-22 420-950 91-200 8.7-20
--------------------------------------------------------------------------------------------------------------------------------------------------------
Estimated Using a 7 Percent Discount Rate \b\
--------------------------------------------------------------------------------------------------------------------------------------------------------
2016.................................................... $340-$770 $18-$41 $6.9-$16 $290-$670 $63-$140 $6.2-$14
2020.................................................... 370-820 20-44 7.4-17 320-720 67-150 6.6-15
2025.................................................... 400-910 22-49 8.0-18 350-790 75-170 7.3-17
2030.................................................... 430-980 24-55 8.6-20 380-850 81-180 7.9-18
--------------------------------------------------------------------------------------------------------------------------------------------------------
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 proposed 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. Full-scale air quality modeling, and the associated benefits analysis, will include upstream
emissions from all sources in the FRM.
The benefit-per-ton technique has been used in previous analyses,
including EPA's 2017-2025 Light-Duty Vehicle Greenhouse Gas Rule,\706\
the Reciprocating Internal Combustion Engine rules,707 708
and the Residential
[[Page 40464]]
Wood Heaters NSPS.\709\ Table IX-22 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.
---------------------------------------------------------------------------
\706\ 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://www.epa.gov/otaq/climate/documents/420r12016.pdf.
\707\ 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://www.epa.gov/ttnecas1/regdata/RIAs/RICE_NESHAPreconsideration_Compression_Ignition_Engines_RIA_final2013_EPA.pdf.
\708\ 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://www.epa.gov/ttnecas1/regdata/RIAs/NESHAP_RICE_Spark_Ignition_RIA_finalreconsideration2013_EPA.pdf>
.
\709\ 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>.
Table IX-22--Human Health and Welfare Effects of PM2.5
------------------------------------------------------------------------
Quantified and monetized Unquantified effects
Pollutant/ effect in primary estimates Changes in:
------------------------------------------------------------------------
PM2.5............... Adult premature Chronic and subchronic
mortality. bronchitis cases.
Acute bronchitis........ Strokes and
cerebrovascular
disease.
Hospital admissions: Low birth weight.
Respiratory and Pulmonary function.
cardiovascular.
Emergency room visits Chronic respiratory
for asthma. diseases other than
chronic bronchitis.
Nonfatal heart attacks Non-asthma respiratory
(myocardial infarction). emergency room visits.
Lower and upper Visibility.
respiratory illness.
Minor restricted- Household soiling.
activity days.
Work loss days..........
Asthma exacerbations
(asthmatic population).
Infant mortality........
------------------------------------------------------------------------
A more detailed description of the benefit-per-ton estimates is
provided in Chapter VIII of the Draft 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.'' \710\
Readers can also refer to Fann et al. (2012) \711\ for a detailed
description of the benefit-per-ton methodology.
---------------------------------------------------------------------------
\710\ For more information regarding the updated values, see:
http://www.epa.gov/airquality/benmap/models/Source_Apportionment_BPT_TSD_1_31_13.pdf (accessed September 9,
2014).
\711\ 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-20 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.\712\
These projected increases reflect rising income levels, which increase
affected individuals' willingness to pay for reduced exposure to health
threats from air pollution.\713\ 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.\714\
---------------------------------------------------------------------------
\712\ As we discuss in the emissions chapter of the DRIA
(Chapter V), the rule would yield emission reductions from upstream
refining and fuel distribution due to decreased petroleum
consumption.
\713\ The issue is discussed in more detail in the 2012 p.m.
NAAQS RIA, Section 5.6.8. 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://www.epa.gov/ttnecas1/regdata/RIAs/finalria.pdf.
\714\ For more information about EPA's population projections,
please refer to the following: http://www.epa.gov/air/benmap/models/BenMAPManualAppendicesAugust2010.pdf (See Appendix K).
---------------------------------------------------------------------------
(2) Human Health and Environmental Benefits for the Final Rule
(a) Human Health and Environmental Impacts
To model the ozone and PM air quality benefits of the final rule,
EPA will use the Community Multiscale Air Quality (CMAQ) model (see
Section VIII for a description of the CMAQ model). The modeled ambient
air quality data will serve as an input to the Environmental Benefits
Mapping and Analysis Program--Community Edition (BenMAP CE).\715\
BenMAP CE is a computer program developed by EPA that integrates a
number of the modeling elements used in previous RIAs (e.g.,
interpolation functions, population projections, health impact
functions, valuation functions, analysis and pooling methods) to
translate modeled air concentration estimates into health effects
incidence estimates and monetized benefits estimates.
---------------------------------------------------------------------------
\715\ Information on BenMAP, including downloads of the
software, can be found at http://www.epa.gov/air/benmap/.
---------------------------------------------------------------------------
Chapter VIII in the DRIA that accompanies this proposal lists the
co-pollutant health effect concentration-response functions EPA will
use to quantify the non-GHG incidence impacts associated with the
proposed heavy-duty vehicle standards. These include PM- and ozone-
related premature mortality, nonfatal heart attacks, hospital
admissions (respiratory and cardiovascular), emergency room visits,
acute bronchitis, minor restricted activity days, and days of work and
school lost.
(b) Monetized Impacts
To calculate the total monetized impacts associated with quantified
health impacts, EPA applies values derived from a number of sources.
For premature mortality, EPA applies a value of a statistical life
(VSL) derived from the mortality valuation literature. For certain
health impacts, such as a number of respiratory-related ailments, EPA
applies willingness-to-pay estimates derived from the valuation
literature. For the remaining health impacts, EPA applies values
derived from current cost-of-illness and/or wage estimates. Chapter
VIII in the DRIA that accompanies this proposal presents the monetary
values EPA will apply to changes in the incidence of health and welfare
effects associated with reductions in non-GHG pollutants that will
occur when these GHG control strategies are finalized.
[[Page 40465]]
(c) Other Unquantified Health and Environmental Impacts
In addition to the co-pollutant health and environmental impacts
EPA will quantify for the analysis of the final standard, there are a
number of other health and human welfare endpoints that EPA will not be
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 VIII of the DRIA 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.\716\ While EPA has since improved the tools, there remain
critical limitations for estimating incidence and assessing benefits of
reducing mobile source air toxics.\717\ EPA continues to work to
address these limitations; however, EPA does not anticipate having
methods and tools available for national-scale application in time for
the analysis of the final rules.\718\
---------------------------------------------------------------------------
\716\ Science Advisory Board. 2001. NATA--Evaluating the
National-Scale Air Toxics Assessment for 1996--an SAB Advisory.
http://www.epa.gov/ttn/atw/sab/sabrev.html.
\717\ 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 Perspect. Jan 2011; 119(1): 125-130.
\718\ 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 U.S. energy security. This section summarizes the agency's
estimates of U.S. oil import reductions and energy security benefits of
the proposed Phase 2 standards. Additional discussion of this issue can
be found in Chapter 8 of the draft RIA.
(1) Implications of Reduced Petroleum Use on U.S. Imports
U.S. energy security is broadly defined 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. However, it is not imports alone,
but both imports and consumption of petroleum from all sources and
their role in economic activity, that expose the U.S. to risk from
price shocks in the world oil price. The relative significance of
petroleum consumption and import levels for the macroeconomic
disturbances that follow from oil price shocks is not fully understood.
Recognizing that changing petroleum consumption will change U.S.
imports, this assessment of oil costs focuses on those incremental
social costs that follow from the resulting changes in imports,
employing the usual oil import premium measure. The agencies request
comment on how to incorporate the impact of changes in oil consumption,
rather than imports exclusively, into our energy security analysis.
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 2012, U.S. net expenditures for imports of crude oil
and petroleum products were $290 billion and expenditures on both
imported oil and domestic petroleum and refined products totaled $634
billion (see Figure IX-1).\719\ Import costs have declined since 2011
but total oil expenditures (domestic and imported) remain near
historical highs, at roughly triple the inflation-adjusted levels
experienced by the U.S. from 1986 to 2002.
---------------------------------------------------------------------------
\719\ 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.''
---------------------------------------------------------------------------
In 2010, just over 40 percent of world oil supply came from OPEC
nations and the AEO 2014 (Early Release) \720\ projects that this share
will rise gradually to over 45 percent by 2040. Approximately 31
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.\721\ Eight of these countries are
members of OPEC, and a ninth is Russia.\722\ 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.\723\
[[Page 40466]]
Historically, the countries of the Middle East have been the source of
eight of the ten major world oil disruptions,\724\ with the ninth
originating in Venezuela, an OPEC country, and the tenth being
Hurricanes Katrina and Rita.
---------------------------------------------------------------------------
\720\ The agencies used the AEO 2014 (Early Release) since this
version of AEO was available at the time that fuel savings from the
rule were being estimated. The AEO 2014 (Early Release) and the AEO
2014 have very similar energy market and economic projections. For
example, world oil prices are the same between the two forecasts.
\721\ Based on data from the CIA, combining various recent
years, https://www.cia.gov/library/publications/the-world-factbook/rankorder/2242rank.html.
\722\ The other three are Norway, Canada, and the EU, an
exporter of product.
\723\ 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 was associated with a 28
percent world oil price increase.
\724\ IEA 2011 ``IEA Response System for Oil Supply
Emergencies.''
[GRAPHIC] [TIFF OMITTED] TP13JY15.017
The agencies used EPA's MOVES model to estimate the reductions in
U.S. fuel consumption due to this proposed rule 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 Chapters 5 and 10 of the draft RIA. See IX.C of the preamble
for estimates of reduced fuel consumption from the proposed rule).
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 standards and
fuel efficiency standards is likely to be reflected in reduced U.S.
imports of crude oil and net imported petroleum products.\726\ 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.\727\ 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 from these proposed rules are
estimated for the years 2020, 2025, 2030, 2040, and 2050 (in millions
of barrels per day (MMBD)) in Table IX-25 below. For comparison
purposes, Table IX-25 also shows U.S. imports of crude oil in 2020,
2025, 2030 and 2040 as projected by DOE in the Annual Energy Outlook
2014 (Early Release) Reference Case. U.S. Gross Domestic
[[Page 40467]]
Product (GDP) is projected to grow by roughly 59 percent over the same
time frame (e.g., from 2020 to 2040) in the same AEO projections.
---------------------------------------------------------------------------
\725\ 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''.
\726\ We looked at changes in crude oil imports and net
petroleum products in the Reference Case in comparison to two cases
from the AEO 2014. The two cases are the Low (i.e., Economic Growth)
Demand and Low VMT cases. See the spreadsheet ``Impacts on Fuel
Demands and ImportsJan9.xlsx'' comparing the AEO 2014 Reference Case
to the Low Demand Case. See the spreadsheet ``Impact of Fuel Demand
and Impacts January20VMT.xlsl'' for a comparison of AEO 2014
Reference Case and the Low VMT Case. We also considered a paper
entitled ``Effect of a U.S. Demand Reduction on Imports and Domestic
Supply Levels'' by Paul Leiby, 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''.
\727\ The NHTSA analysis uses a slightly different value that
was estimated using unique runs of the National Energy Modeling
System (NEMS) that forms the foundation of the Annual Energy
Outlook. NHTSA ran a version of NEMS from 2012 (which would have
been used in the 2013 AEO) and computed the change in imports of
petroleum products with and without the Phase 1 MDHD program to
estimate the relationship between changes in fuel consumption and
oil imports. The analysis found that reducing gasoline consumption
by 1 gallon reduces imports of refined gasoline by 0.06 gallons and
domestic refining from imported crude by 0.94 gallons. Similarly,
one gallon of diesel saved by the Phase 1 rule was estimated to
reduce imports of refined diesel by 0.26 gallons and domestic
refining of imported crude by 0.74 gallons. The agencies will update
this analysis for the Final Rule using the model associated with
AEO2014, modeling the Phase 2 Preferred Alternative explicitly.
Table IX-23--Projected U.S. Imports of Crude Oil and U.S. Oil Import
Reductions Resulting From the Proposed Phase 2 Heavy-Duty Vehicle Rule
in 2020, 2025, 2030, 2040 and 2050 Using Method B and Relative to the
Less Dynamic Baseline
[Millions of barrels per day (MMBD)] a
------------------------------------------------------------------------
Reductions
Year U.S. oil from proposed
imports HD rule
------------------------------------------------------------------------
2020.................................... 4.93 0.01
2025.................................... 5.04 0.16
2030.................................... 5.35 0.37
2040.................................... 5.92 0.65
2050.................................... * 0.78
------------------------------------------------------------------------
Notes:
* The AEO 2014 (Early Release) only projects energy market and economic
trends through 2040.
\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.
(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.\728\ 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.
---------------------------------------------------------------------------
\728\ 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 the 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 the rule, 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 United States. Given the redistributive nature of this
monopsony effect from a global perspective, and the fact that an
increasing fraction of it represents a transfer between U.S. consumers
and producers, it is excluded in the energy security benefits
calculations for these proposed 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 proposed 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 proposed 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
2014 (Early Release) into its model.\729\ ORNL developed energy
security premium estimates for a number of different years. Table IX-24
provides estimates for energy security premiums for the years 2020,
2025, 2030 and 2040,\730\ 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.
---------------------------------------------------------------------------
\729\ Leiby, P., Factors Influencing Estimate of Energy Security
Premium for Heavy-Duty Phase 2 Proposed Rule, 11/1/2014, Oak Ridge
National Laboratory.
\730\ AEO 2014 (Early Release) 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.
[[Page 40468]]
Table IX-24--Energy Security Premiums in 2020, 2025, 2030 and 2040
[2012$/Barrel] *
----------------------------------------------------------------------------------------------------------------
Avoided
macroeconomic
Year (range) Monopsony (range) disruption/ Total mid-point
adjustment costs (range)
(range)
----------------------------------------------------------------------------------------------------------------
2020................................................... $4.91 $6.35 $11.25
(1.63-9.15) (3.07-10.15) (6.67-16.53)
2025................................................... $5.46 $7.29 $12.75
(1.81-10.47) (3.57-11.67) (7.58-18.65)
2030................................................... $6.04 $8.39 $14.43
(2.00-11.67) (4.12-13.41) (8.54-21.13)
2040................................................... $7.17 $10.74 $17.91
(2.32-14.03) (5.36-17.22) -26.14)
----------------------------------------------------------------------------------------------------------------
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.
A variety of oil market and economic factors have contributed to
lowering the estimated monopsony premium compared to monopsony premiums
cited in recent EPA/NHTSA rulemakings. Three principal factors
contribute to lowering the monopsony premium: Lower world oil prices,
lower U.S. oil imports and less responsiveness of world oil prices to
changes in U.S. oil demand. For example, between 2012 (using the AEO
2012 (Early Release)) and 2014 (using the AEO 2014 (Early Release)),
there has been a general downward revision in world oil price
projections in the near term (e.g. 19 percent in 2020) and a sharp
reduction in projected U.S. oil imports in the near term, due to
increased U.S. supply (i.e., a 41 percent reduction in U.S. oil imports
by 2017 and a 36 percent reduction in 2020). Over the longer term,
oil's share of total U.S. imports is projected to gradually increase
after 2020 but still remain 27 percent below the AEO2012 (Early
Release) projected level in 2035.
Another factor influencing the monopsony premium is that U.S.
demand on the global oil market is projected to decline, suggesting
diminished overall influence and some reduction in the influence of
U.S. oil demand on the world price of oil. Outside of the U.S.,
projected OPEC supply remains roughly steady as a share of world oil
supply compared to the AEO2012 (Early Release). OPEC's share of world
oil supply outside of the U.S. actually increases slightly. Since OPEC
supply is estimated to be more price sensitive than non-OPEC supply,
this means that under AEO2014 (Early Release) world oil supply is
slightly more responsive to changes in U.S. oil demand. Together, these
factors suggest that changes in U.S. oil import reductions have a
somewhat smaller effect on the long-run world oil price than changes
based on 2012 estimates.
These changes in oil price and import levels lower the monopsony
portion of energy security premium since this portion of the security
premium is related to the change in total U.S. oil import costs that is
achieved by a marginal reduction in U.S oil imports. Since both the
price and the quantity of oil imports are lower, the monopsony premium
component is 46-57 percent lower over the years 2017-2025 than the
estimates based upon the AEO 2012 (Early Release) projections.
There is disagreement in the literature about the magnitude of the
monopsony component, and its relevance for policy analysis. Brown and
Huntington (2013),\731\ 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) \732\ 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) \733\ and others in prior literature (e.g.,
Toman 1993) \734\ 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),\735\ yet still implying marginal social costs to importers.
---------------------------------------------------------------------------
\731\ Brown, Stephen P.A. and Hillard G. Huntington. 2013.
Assessing the U.S. Oil Security Premium. Energy Economics, vol. 38,
pp 118-127.
\732\ Reassessing the Oil Security Premium. RFF Discussion Paper
Series, (RFF DP 10-05). doi: RFF DP 10-05
\733\ 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.
\734\ Reassessing the Oil Security Premium. RFF Discussion Paper
Series, (RFF DP 10-05). doi:RFF DP 10-05.
\735\ Ledyard, John O. ``Market Failure.'' The New Palgrave
Dictionary of Economics. Second Edition. Eds. Steven N. Durlauf and
Lawrence E. Blume. Palgrave Macmillan, 2008.
---------------------------------------------------------------------------
There is also a question about the ability of gradual, long-term
reductions, such as those resulting from this proposed rule, 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
[[Page 40469]]
savings resulting from this rule 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 would 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)).\736\
---------------------------------------------------------------------------
\736\ 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.
---------------------------------------------------------------------------
It is important to note that the decrease in global petroleum
prices resulting from this rulemaking could spur increased consumption
of petroleum in other sectors and countries, leading to a modest uptick
in GHG emissions outside of the United States. This increase in global
fuel consumption could offset some portion of the GHG reduction
benefits associated with these proposed rules. The agencies have not
quantified this increase in global GHG emissions. We request comments,
data sources and methodologies for how global rebound effects may be
quantified.
(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 $6.34/barrel when U.S. oil imports are reduced in 2020,
with a range from $3.07/barrel to $10.15/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.
With updated oil market and economic factors, the avoided
macroeconomic disruption component of the energy security premiums is
slightly lower in comparison to avoided macroeconomic disruption
premiums used in previous rulemakings. Factors that contribute to
moderately lowering the avoided macroeconomic disruption component are
lower projected GDP, moderately lower oil prices and slightly smaller
price increases during prospective shocks. For example, oil price
levels are 5-19 percent lower over the 2020-2035 period, and the likely
increase in oil prices in the event of an oil shock are somewhat
smaller, given small increases in the responsiveness of oil supply to
changes in the world price of oil. Overall, the avoided macroeconomic
disruption component estimates for the oil security premiums are 2-19
percent lower over the period from 2020-2035 based upon different
projected oil market and economic trends in the AEO2014 (Early Release)
compared to the AEO2012 (Early Release).
There are several reasons why the avoided macroeconomic disruption
premiums change only moderately. One reason is that the macroeconomic
sensitivity to oil price shocks is assumed unchanged in recent years
since U.S. oil consumption levels and the value share of oil in the
U.S. economy remain at high levels. For example, Figure IX-2 below
shows that under AEO2014 (Early Release), projected U.S. real annual
oil expenditures continue to rise after 2015 to over $800 billion
(2012$) by 2030. The value share of oil use in the U.S. economy remains
between three and four percent, well above the levels observed from
1985 to 2005. A second factor is that oil disruption risks are little
changed. The two factors influencing disruption risks are the
probability of global supply interruptions and the world oil supply
share from OPEC. Both factors are not significantly different from
previous forecasts of oil market trends.
The energy security costs estimated here follow the oil security
premium framework, which is well established in the energy economics
literature. The oil import premium gained attention as a guiding
concept for energy policy around the time of the second and third major
post-war oil shocks (Bohi and Montgomery 1982, EMF 1982).\737\ Plummer
(1982) \738\ provided valuable discussion of many of the key issues
related to the oil import premium as well as the analogous oil
stockpiling premium. Bohi and Montgomery (1982) \739\ detailed the
theoretical foundations of the oil import premium established many of
the critical analytic relationships through their thoughtful analysis.
Hogan (1981) \740\ and Broadman and Hogan (1986, 1988)\741\ revised and
extended the established analytical framework to estimate optimal oil
import premia with a more detailed accounting of macroeconomic effects.
---------------------------------------------------------------------------
\737\Bohi, Douglas R. And W. David Montgomery 1982. Social Cost
of Imported and Import Policy, Annual Review of Energy, 7:37-60.
Energy Modeling Forum, 1981. World Oil, EMF Report 6 (Stanford
University Press: Stanford 39 CA. https//emf.stanford.edu/publications/emf-6-world-oil.
\738\ Plummer, James L. (Ed.) 1982. Energy Vulnerability,
``Basic Concepts, Assumptions and Numerical Results'', pp. 13-36,
(Cambridge MA: Ballinger Publishing Co.)
\739\ Bohi, Douglas R. And W. David Montgomery 1982. Social Cost
of Imported and U.S. Import Policy, Annual Review of Energy, 7:37-
60.
\740\ Hogan, William W., 1981. ``Import Management and Oil
Emergencies'', Chapter 9 in Deese, 5 David and Joseph Nye, eds.
Energy and Security. Cambridge, MA: Ballinger Publishing Co.
\741\Broadman, H.G. 1986. ``The Social Cost of Imported Oil,''
Energy Policy 14(3):242-252. Broadman H.G. and W.W. Hogan, 1988.
``Is an Oil Import Tariff Justified? An American Debate: The Numbers
Say `Yes'.'' The Energy Journal 9: 7-29.
---------------------------------------------------------------------------
Since the original work on energy security was undertaken in the
1980's, there have been several reviews on this topic. For example,
Leiby, Jones, Curlee and Lee (1997) \742\ provided an extended review
of the literature and issues regarding the estimation of the premium.
Parry and Darmstadter (2004) \743\ also provided an overview of extant
oil security premium estimates
[[Page 40470]]
and estimated of some premium components.
---------------------------------------------------------------------------
\742\ 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 1, 1997.
\743\ Parry, Ian W.H. and Joel Darmstadter 2004. ``The Costs of
U.S. Oil Dependency,'' Resources for the Future, November 17, 2004
(also published as NCEP Technical Appendix Chapter 1: Enhancing Oil
Security, the National Commission on Energy Policy 2004 Ending the
Energy Stalemate--A Bipartisan Strategy to Meet America's Energy
Challenges.)
---------------------------------------------------------------------------
The recent economics literature on whether oil shocks are a 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.\744\ Analyses by Nordhaus (2007) and Blanchard and Gali (2010)
question the impact of more recent oil price shocks on the
economy.\745\ They were motivated by 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.
---------------------------------------------------------------------------
\744\ National Research Council, 2009. Hidden Costs of Energy:
Unpriced Consequences of Energy Production and Use. National Academy
of Science, Washington, DC.
\745\ 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,\746\ 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.
---------------------------------------------------------------------------
\746\ 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.'' \747\ 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.''
---------------------------------------------------------------------------
\747\ 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 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
high oil prices. The resulting decrease in foreign imports, down to
about one-third of domestic consumption (from 60 percent in 2005, for
example \748\), effectively permits U.S. supply to act as a buffer
against artificial or other supply restrictions (the latter due to
conflict or natural disaster, for example).
---------------------------------------------------------------------------
\748\ 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 of a given size seems to have a
decreasing effect over time, but noted that the declining price-
elasticity of demand meant that a given physical disruption had a
bigger effect on price and turned out to have a similar effect on
output as in the earlier data.'' \749\ 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'' (citing as recent examples Kim 2012,
Engemann, Kliesen, and Owyang 2011 and Daniel, et. al. 2011).
Alternatively, rather than a declining effect, Ramey and Vine (2010)
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.'' \750\
---------------------------------------------------------------------------
\749\ 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.
\750\ Ramey, V.A., & Vine, D.J. (2010). ``Oil, Automobiles, and
the U.S. Economy: How Much have Things Really Changed?'', National
Bureau of Economic Research Working Papers, WP 16067 (June).
Retrieved from http://www.nber.org/papers/w16067.pdf.
---------------------------------------------------------------------------
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 Robays, 2010). A recent
paper by Kilian and Vigfusson (2014), 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
Vigfussen 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.
[[Page 40471]]
economy in the short run and some of which slow down U.S. growth (see
Kilian 2009a). 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.''
The general conclusion that oil supply-driven shocks reduce
economic output is also reached in a recently published paper by Cashin
et al. (2014) 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 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.
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. Reducing fuel
consumption reduces the amount of domestic economic activity associated
with a commodity whose price depends on volatile international markets.
Also, reducing U.S. oil import levels reduces the likelihood and
significance of supply disruptions.
---------------------------------------------------------------------------
\751\ Historical data are from EIA Annual Energy Review, various
editions. For data since 2011 and projected data: Source is EIA
Annual Energy Outlook (AEO) 2014 (Reference Case). See Table 11,
file ``aeotab_11.xlsx'' and Table 20 (Macroeconomic Indicators,''
(file ``aeotab_20.xlsx'').
[GRAPHIC] [TIFF OMITTED] TP13JY15.018
(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
[[Page 40472]]
vary with incremental variations in U.S. oil imports.
(3) Energy Security Benefits of This Program
Using the ORNL ``oil premium'' methodology, updating world oil
price values and energy trends using AEO 2014 (Early Release) and using
the estimated fuel savings from the proposed rules estimated from the
MOVES/CAFE models, the agencies has calculated the annual energy
security benefits of this proposed rule through 2050.\752\ 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-25. 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-26.
---------------------------------------------------------------------------
\752\ 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 proposed rule. Since the AEO 2014
(Early Release) only goes to 2040, we only calculate energy security
premiums to 2040.
Table IX-25--Annual U.S. Energy Security Benefits of the Preferred
Alternative and Net Present Values at 3% and 7% Discount Rates Using
Method B and Relative to the Less Dynamic Baseline
[In millions of 2012$] \a\
------------------------------------------------------------------------
Benefits
Year (2012$)
------------------------------------------------------------------------
2018....................................................... 10
2019....................................................... 20
2020....................................................... 31
2021....................................................... 77
2022....................................................... 140
2023....................................................... 211
2024....................................................... 328
2025....................................................... 456
2026....................................................... 596
2027....................................................... 770
2028....................................................... 947
2029....................................................... 1,126
2030....................................................... 1,306
2035....................................................... 2,156
2040....................................................... 2,920
2050....................................................... 3,498
NPV, 3%.................................................... 28,947
NPV, 7%.................................................... 11,857
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the less dynamic baseline, 1a, and more
dynamic baseline, 1b, please see Section X.A.1.
Table IX-26--Discounted Model Year Lifetime Energy Security Benefits Due
to the Preferred Alternative at 3% and 7% Discount Rates Using Method B
and Relative to the Less Dynamic Baseline
[Millions of 2012$] \a\
------------------------------------------------------------------------
3% discount 7% discount
Calendar year rate rate
------------------------------------------------------------------------
2018.......................................... 86 60
2019.......................................... 85 56
2020.......................................... 84 53
2021.......................................... 534 326
2022.......................................... 579 341
2023.......................................... 621 353
2024.......................................... 996 546
2025.......................................... 1,060 560
2026.......................................... 1,121 571
2027.......................................... 1,375 676
2028.......................................... 1,388 657
2029.......................................... 1,397 637
-------------------------
Sum........................................... 9,325 4,837
------------------------------------------------------------------------
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.
J. Other Impacts
(1) Costs of Noise, Congestion and Accidents 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 traffic congestion, motor vehicle accidents,
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 accidents 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, accident, 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.\753\ We provide the details behind the estimates in
Chapter 8.7 of the draft RIA. The agencies request comment on all input
metrics used in the analysis of accidents, congestion and noise and on
the calculation methodology. Table IX-27 presents the estimated annual
impacts associated with accidents, congestion and noise along with net
present values at both 3 percent and 7 percent discount rates. Table
IX-28 presents the estimated discounted model year lifetime impacts
associated with accidents, congestion and noise.
---------------------------------------------------------------------------
\753\ 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-27--Annual Costs Associated With Accidents, Congestion and
Noise and Net Present Values at 3% and 7% Discount Rates Using Method B
and Relative to the Less Dynamic Baseline
[Millions of 2012$] \a\
------------------------------------------------------------------------
Costs of
accidents,
Calendar year congestion,
and noise
------------------------------------------------------------------------
2018.................................................... $0
2019.................................................... 0
2020.................................................... 0
2021.................................................... 117
2022.................................................... 172
2023.................................................... 226
2024.................................................... 279
2025.................................................... 330
2026.................................................... 379
2027.................................................... 425
2028.................................................... 467
2029.................................................... 506
2030.................................................... 542
2035.................................................... 676
2040.................................................... 758
2050.................................................... 871
NPV, 3%................................................. 9,334
NPV, 7%................................................. 4,202
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the less dynamic baseline, 1a, and more
dynamic baseline, 1b, please see Section X.A.1.
[[Page 40473]]
Table IX-28--Discounted Model Year Lifetime Costs of Accidents,
Congestion and Noise at 3% and 7% Discount Rates Using Method B and
Relative to the Less Dynamic Baseline
[Millions of 2012$] \a\
------------------------------------------------------------------------
3% discount 7% discount
Calendar year rate rate
------------------------------------------------------------------------
2018.......................................... 132 85
2019.......................................... 146 94
2020.......................................... 162 103
2021.......................................... 450 284
2022.......................................... 438 266
2023.......................................... 427 250
2024.......................................... 424 239
2025.......................................... 422 229
2026.......................................... 420 219
2027.......................................... 415 209
2028.......................................... 409 198
2029.......................................... 402 187
-------------------------
Sum......................................... 4,247 2,362
------------------------------------------------------------------------
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.
(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 would 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 would 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 would 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.\754\ The input metrics used in the analysis are presented in
greater detail in draft RIA Chapter 9.7. The annual benefits associated
with reduced refueling time are shown in Table IX-29 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-30.
---------------------------------------------------------------------------
\754\ U.S. Department of Transportation, Valuation of Travel
Guidance, July 9, 2014, at page 14.
Table IX-29--Annual Refueling Benefits and Net Present Values at 3% and
7% Discount Rates Using Method B and Relative to the Less Dynamic
Baseline
[Millions of 2012$] \a\
------------------------------------------------------------------------
Refueling
Calendar year benefits
------------------------------------------------------------------------
2018....................................................... 3
2019....................................................... 6
2020....................................................... 9
2021....................................................... 25
2022....................................................... 47
2023....................................................... 72
2024....................................................... 113
2025....................................................... 157
2026....................................................... 205
2027....................................................... 266
2028....................................................... 327
2029....................................................... 386
2030....................................................... 444
2035....................................................... 698
2040....................................................... 890
2050....................................................... 1,195
NPV, 3%.................................................... 9,410
NPV, 7%.................................................... 3,868
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the less dynamic baseline, 1a, and more
dynamic baseline, 1b, please see Section X.A.1.
Table IX-30--Discounted Model Year Lifetime Refueling Benefits Using
Method B and Relative to the Less Dynamic Baseline
[Millions of 2012$] \a\
------------------------------------------------------------------------
3% discount 7% discount
Model year rate rate
------------------------------------------------------------------------
2018.......................................... 23 16
2019.......................................... 22 15
2020.......................................... 21 14
2021.......................................... 163 101
2022.......................................... 184 110
2023.......................................... 203 117
2024.......................................... 325 181
2025.......................................... 349 187
2026.......................................... 372 191
2027.......................................... 466 231
2028.......................................... 465 222
2029.......................................... 463 213
-------------------------
Sum......................................... 3,055 1,597
------------------------------------------------------------------------
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.
(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 would 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-31 along with net present values at both
[[Page 40474]]
3 percent and 7 percent discount rates. The discounted model year
lifetime benefits are shown in Table IX-32.
Table IX-31--Annual Value of Increased Travel and Net Present Values at
3% and 7% Discount Rates Using Method B and Relative to the Less Dynamic
Baseline
[Millions of 2012$] \a\
------------------------------------------------------------------------
Benefits of
Calendar year increased
travel
------------------------------------------------------------------------
2018....................................................... 0
2019....................................................... 0
2020....................................................... 0
2021....................................................... 445
2022....................................................... 636
2023....................................................... 821
2024....................................................... 1,001
2025....................................................... 1,179
2026....................................................... 1,346
2027....................................................... 1,506
2028....................................................... 1,647
2029....................................................... 1,783
2030....................................................... 1,909
2035....................................................... 2,445
2040....................................................... 2,873
2050....................................................... 3,286
NPV, 3%.................................................... 34,240
NPV, 7%.................................................... 15,316
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the less dynamic baseline, 1a, and more
dynamic baseline, 1b, please see Section X.A.1.
Table IX-32--Discounted Model Year Lifetime Value of Increased Travel at
3% and 7% Discount Rates Using Method B and Relative to the Less Dynamic
Baseline
[Millions of 2012$] \a\
------------------------------------------------------------------------
Calendar year 3% discount rate 7% discount rate
------------------------------------------------------------------------
2018.............................. $554 $353
2019.............................. 618 390
2020.............................. 686 429
2021.............................. 1,510 942
2022.............................. 1,488 894
2023.............................. 1,463 847
2024.............................. 1,434 799
2025.............................. 1,442 774
2026.............................. 1,447 748
2027.............................. 1,421 708
2028.............................. 1,415 678
2029.............................. 1,406 649
-------------------------------------
Sum............................. 14,884 8,211
------------------------------------------------------------------------
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.
K. Summary of Benefits and Costs
This section presents the costs, benefits, and other economic
impacts of the proposed Phase 2 standards. It is important to note that
NHTSA's proposed fuel consumption standards and EPA's proposed GHG
standards would both be in effect, and would 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 draft RIA. These include:
The vehicle program costs (costs of complying with the
vehicle CO2 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,