Regulatory Environment

Transcription

1 Regulatory Environment Dan Carder, Marc Besch, Arvind Thiruvengadam, and Gregory Thompson West Virginia University

2 ICCT Light-Duty Diesel Project Initial request by ICCT Identify European-based diesel engines sold in the United States meeting at least Tier 2 Bin 5, LEV II emissions Proposed a plan to evaluate the in-use emissions from a representative selection of suggested vehicles request specified two SCR-equipped and one lean NOx trapped-equipped vehicles Proposed budget ~$193,662 with multiple options Project award ~ $69,387 Serendipity played a major role ICCT initiated, WVU investigated, CARB carried the torch 2

3 SOME CLARIFICATION WVU did not find any defeat devices 3 vehicle dataset cannot identify defeat device issues Study was indicative of high off-cycle emissions High emissions in regions of operation that would be otherwise characterized by low emissions (For example: highway with good SCR operation) Enforcement action takes time Detailed investigation by ARB. Time consuming to identify the real-issue behind the high off-cycle emissions Courtesy: Marian Kamensky, 3 Diesels can be clean- Truth or Myth? News cycles have focused largely on the failed VW vehicles. WVU study showed a third vehicle (BMW X5) low on emissions both in laboratory and real-world CLEAN DIESEL IS NOT A MYTH The image of diesel vehicles is always associated with smoke Modern diesel vehicles do not emit soot, in some cases cleaner than modern gasoline direct injection technology SCR provides the opportunity to achieve near zero NOx emissions Truth: It is a constant work in progress

4 HOW DID WE GET HERE? Certification and Compliance 1998 Consent Decrees OBD Maturity Inspection & Maintenance from dyno/emissions to OBD Scan 4

5 PEMS testing by regulators WHAT IS NEXT? Logistic issues involving delays in certification Third-party of OEM conducted, supervised under strict regulatory guidelines Miniature screening devices Current smog check practices are oriented towards gasoline engines Screening devices with miniature NOx and opacity meters for diesel vehicle World harmonized driving cycle Simplifies certification and compliance on a global market One cycle-different standards Geo-fencing based regulation Aggressive standards for non-attainment regions based on geo-fencing Use of proving grounds in lieu of on-road PEMS and chassis to replicate certification cycles IMPACT OF FUTURE REGULATIONS ON CONSUMER Impact of enforcing extensive real-world compliance on vehicle durability, warranty and fuel consumption is important Often the cost of clean vehicles is burdened by the consumer Technology innovation and investigating trade-off is key 5

6 Technology Acceleration? Aftertreatment Development Sensor Development Advanced Combustion Techniques Advanced Driveline Strategies Fuel Alternatives Connected Vehicle Enhanced Integration Ref: 6

7 Regulatory Action? Increased Certification Procedures to Identify Off-Cycle Emissions On-Road Emissions Measurements Similar to HDD Requirements Expand Certification Test Ambient Conditions Low/High Temperature, Humidity, Elevation Real-world Certification/Compliance Geofencing Incentivize Future Reductions Drive Cycles More Representative of Real-World Driving Surprise Cycles or Periodically Refreshed NTE and?-based Windows OBD.I/M.?? 7

8 AirCom - Prototype Barometric Pressure/Temperature Sensor Bosch BMP180 Resolution: up to 0.03hPa / 0.25m ( hPa) T accuracy: ± 2 C (Range: -40 to +85 C) CO 2 Sensor Humidity NDIR K-30, Sensor 1% CO2 Sensirion range SHT21 Accuracy: ± Resolution: 30ppm, ± 3% 0.04 %RH, of measured Accuracy: ± 2 value %RH 8

9 WVU Markov Drive Cycle Real world on-road driving dataset Drive Cycle Generating Tool ADVANTAGES: Interactive drive cycle generation tool for rapidly creating multiple unique cycles for any vehicle application that would statistically represent the real world driving Can generate both chassis dynamometer and engine dynamometer drive cycles Utilizes stochastic analysis using Markov Chain model opposed to traditional micro-trip based methods to create drive cycles Tool could be used by regulators to create drive cycles more representative of real world driving and surprise drive cycles to test engine and vehicles. 9

10 GLOBAL PERSPECTIVE 10

11 GLOBAL PERSPECTIVE The VW issue has had a global impact The contrast in emissions standards between different parts of the world is much better illustrated now Lesson for developing countries to consider, while their regulatory framework is being developed. Harmonization of standards and requirements Level the playing field Incentivize the cost of clean technology If motivation for emissions excursion is the cost of technology, then incentives could potentially prevent these excursions Cost of emissions control technology for gasoline vs clean diesel significantly different Low diesel fuel price countries can leverage the advantages of clean diesel 11

12 Thank You! / Acknowledgement 12

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14 Timeline Increased onroad (i.e. offcycle) NOx emissions measured in EU Nov. 7 th 2012 RFP by ICCT March May 2013 Testing of three vehicles (on-road and laboratory) May 15 th 2014 Submission of final report to ICCT Sept. 3 rd 2015 VW Engineers admit to CARB of use of defeat device Sep. 25 th 2015 CEO Winterkorn resigns, VW names Müller C.E.O. ICCT wants to test Diesel LDVs sold in US to demonstrate EU legislator the feasibility of low NOx emissions Nov. 22 th 2012 Submission of proposal March 30 th 2014 Presentation of data at 24 th CRC Real- World Emissions Workshop Dec Notification of voluntary recall by VW Sept. 18 th 2015 First Notice of Violation by U.S. EPA and CARB 14

15 History in the making Nov. 2 nd 2015 Second Notice of Violation by U.S. EPA and CARB Timeline.cont d Jan. 4 th 2016 DOJ files complaint on behalf of EPA against Volkswagen Group for alleged violations of the Clean Air Act. Fines estimated up to $46 Billion Jan. 22 nd 2016 Elizabeth Cabraser appointed sole lead class counsel in MDL against Volkswagen Mar. 24 th 2016 U.S. District Judge Charles Breyer requests definitive answer on the status of a fix Dec. 10 th 2015 Internal VW inquiry reports decision to cheat was made more than a decade ago Jan. 12 th 2016 EPA & CARB rejected WV s proposed fix Mar. 9 th 2016 Horn steps down as president and CEO of Volkswagen Group of America. Woebcken named president and CEO on an interim basis. 15