US GHG Regulation, Phase 2. Final Rule Summary
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1 US GHG Regulation, Phase 2 Final Rule Summary Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles - Phase 2 Marc Miller PPL, Regulation NA
2 Contents Regulatory Timeline and Overview The Vehicle Program Regulatory Flexibilities What s Next? Closing Comments 2 03 April 2017
3 Implementation Timeline Phase 1 Phase 2 Engines Vehicles Trailers Applicable to US including California, and Canada 3 03 April 2017
4 Requirements Overview Engines Vehicles Trailers Engine Dyno Test Simulation Model (regulated standard trailer) Simulation Model (regulated standard tractor) CO2, CH4, N2O (g/hph) Gallons fuel (gal/hph) CO2 (g/ton-mile) Gallons fuel (gal/ton-mile) Gallons CO2, fuel (g/ton-mile) (gal/ton-mile) 4 03 April 2017
5 Requirements Overview -- Categories Engines Vehicles Trailers Tractor Engines 1 CO2 measured on RMC Vocational Engines 2 CO2 measured on FTP All Engines N2O, CH4 measured over FTP Sleepers 1 High-Roof Mid-Roof Low-Roof Daycabs 1 High-Roof Mid-Roof Low-Roof Vocational 2 Urban Multi-purpose Regional Special Categories Heavy-haul tractors 3 Custom Chassis 4 Full-Aero Box Vans Dry Van Short Long Refer Van Short Long Partial-Aero Box Vans Dry Van Short Long Refer Van Short Long Non-Aero Box Vans Non-Box Trailers 1 Class 7 and 8 2 Class 2b-8 3 >120,000 Lbs. GCWR 4 Class April 2017
6 Class 8 CO2 / Fuel Consumption Reductions versus Phase baseline standards Phase 2 HHD Engines Tractor 2.0% 4.9% 5.5% 7.6% 8.8% 9.4% Reweighted RMC will provide ~1-2% relief from these levels Vocational Phase 1 Proposal Final Trailers 2% 5% 7% 9% Class 8 Vehicles (including engine efficiency) Sleepers Daycabs 14% 19% 23-25% 12-13% 16-18% 19-23% 7-9% 12-16% 14-20% Vocational 6 03 April 2017
7 Vehicle Program 7 03 April 2017
8 Phase I Vehicle Program Engine Agency Defined Default Values Transmission Type, features Coast-down Axles Ratio, efficiency EPA GHG Emissions Model GEM CO2 (g/ton-mi) CFD Aero CdA Tires Rolling Resistance (Regulated simulation tool) Idle shutdown Speed Limiter Weight Reduction Innovative Technology Advanced Technology Ecofeatures 8 03 April 2017
9 Phase II Vehicle Program Actual Values From Installed Components 55 mph w/ grade Transient Coast-down 65 mph w/ grade Dyno Work Fuel map Fuel map CO2 N/V Engine Transmission Type, features Axles Ratio, efficiency EPA GHG Emissions Model GEM CO2 (g/ton-mi) CFD Aero CdA Tires Rolling Resistance (Regulated simulation tool) Idle shutdown + APU Predictive cruise VSL Tire Pressure Monitoring Tire Auto-Inflation Stop-Start 6x2 etc, Ecofeatures 9 03 April 2017
10 Flexibilities April 2017
11 Custom Chassis Program Targeted at small manufacturers, but open to all OEMs Less stringent CO2 standards Either GEM simulation is not applied, or limited GEM inputs are used 1, 2 No credit trading across vehicle types, or outside the custom chassis program Custom Chassis Standards Custom Chassis Vehicle Types MY MY School bus Motor home Coach bus Other bus Refuse hauler Concrete mixer Mixed-use vehicle (primarily off-road) Emergency vehicle Some Custom Chassis types are deemed to meet standards with specific tire rolling resistance levels. 2. No engine, transmission, tire size, drive axle ratio, axle efficiency, or aerodynamic improvement April 2017
12 Early Vehicle Credit Opportunities Certain vehicle technologies that are defined as applicable for fuel efficiency gains in Phase 2 are being made available to apply to vehicles in the Phase 1 program. When included in the vehicle spec, they will generate a fixed CO2 improvement as indicated below. Technology Applies To Improvement Factor Automatic Tire Inflation System (all axles) Tractors and Vocational Vehicles 1.20% Automatic Engine Shutdown (60 sec. shut down) Vocational Vehicles 5% Engine Stop-Start Vocational Vehicles 8% Neutral-at-Idle (AT only) Vocational Vehicles Up to 2% April 2017
13 Advanced Technology Credits To encourage the deployment of advanced technology vehicles, a multiplier is applied to the credits gained: Plug-in Hybrid vehicles: 3.5x Fully-electric vehicles: 4.5x Fuel-cell vehicles: 5.5x Multipliers are applied to vehicle credits only; not engine credits April 2017
14 What s Next? April 2017
15 New Administration Heavy Truck Rule not currently under consideration for review under the Congressional Review Act Repeal not as simple as signing an Executive Order The Agency has built a strong public record of the rulemaking Administration must make a credible case as to why the regulatory process was not sound GHG Endangerment Finding In Massachusetts v. EPA the court ruled: The CAA gave the EPA authority to regulate GHG emissions Remanded the issue back to the EPA. The Court found the Agency s rationale for not regulating to be inadequate and required the agency to articulate a reasonable basis in order to avoid regulation. The Endangerment Finding was based on strong public record which, again, the new administration would have to prove was incorrect based on credible fact April 2017
16 California Air Resources Board- CARB CARB held their first public workshop Feb. 6 th, A second workshop will be held Spring of The CARB rule will align with the Federal rule in terms of timing and stringency, with some modifications to structure; however, no longer deemed to comply with the CA rule if the engine or vehicle is covered under an EPA certificate (CA unique certification burden). CARB views their rule as a backstop against repeal of the Federal rule. Where CA Phase II may differ from Federal Phase II Additional credit for Low GWP refrigerants CARB requesting additional emissions control system information on labels Refuse and Transit Buses excluded from Custom Chassis Additional certification data requested for A/C leakage rate Likely will result in CA specific credit calculation, reporting, and balances Refusal of the EPA to issue a waiver to CA would result in litigation April 2017
17 Closing Comments April 2017
18 In Short This is a technology forcing regulation with expected vehicle improvements of 3-4% per year. The Phase II rule is not likely to be repealed or modified. Any repeal or reduction in stringency would result in litigation and a more stringent CA rule to which several states would likely opt-in. Vehicle manufacturers prefer a single, national program. OEMs will need to make significant investments to meet the regulatory timeline April 2017
19 Questions? April 2017
20 Marc Miller, Greenhouse Gas Regulation Specialist April 2017
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