appendix e - further detail on phase 2 greenhouse gas emission standards · · 2017-12-19staff is...

E-1 Date of Release: December 19, 2017 Date of Hearing: February 8, 2018

Appendix E - Further Detail on Phase 2 Greenhouse Gas Emission Standards This appendix provides further detail on the Phase 2 GHG standards. I. Maintenance Requirements/In-Use Standards

A. CH4 and N2O Engine and Vehicle Standards

U.S. EPA is maintaining the Phase 1 standards for CH4 and N2O emissions at their Phase 1 numeric values. CARB adopted these standards as part of the California Phase 1 GHG regulations adopted in December 2013 (CARB, 2013). U.S. EPA chose not to increase the stringency of the N2O standards for Phase 2 because it was not clear what impact that would have on manufacturers’ ability to achieve lower CO2 emissions. Regarding CH4, U.S. EPA was not aware of any technology that would have allowed them to adopt more stringent CH4 standards. (U.S. EPA, 2016)

The Phase 1 standards require that medium- and heavy-duty engines meet engine emission standards of 0.10 g/bhp-hr for N2O and 0.10 g/bhp-hr for CH4 over the applicable useful life of the engine. Tractor engines are tested over the SET, while vocational engines are tested over the FTP. For PUVs, the N2O standard is 0.05 g/mile and the CH4 standard is 0.05 g/mile. As described further in 40 CFR 1036.705(d) and 86.1819-14(c), manufacturers may apply CO2 emission credits to meet CH4 and N2O standards, if needed. Staff is not proposing any changes to the CH4 and N2O engine and vehicle standards. (CFR, 2017)

B. Air Conditioning Leakage Standards

The Phase 1 standards stipulate that the refrigerant leak rate of an A/C system using HFC-134a not exceed 11.0 grams per year, or 1.50 percent of the system refrigerant capacity per year, whichever is greater. If the system uses an alternative refrigerant, the leak rate of the system is adjusted by multiplying it by the ratio of the GWP of the refrigerant to the GWP of HFC-134a. (U.S. EPA, 2011) This was intended to provide modest incentive for manufacturers to adopt low-GWP refrigerants. The leakage standards apply to Class 7 and 8 combination tractors and Class 2b/3 PUVs. CARB adopted these standards as part of the California Phase 1 regulation.

In its Phase 2 rule, the U.S. EPA no longer allows the adjustment of leak rate based on the refrigerant’s GWP value. This change was made in response to concerns from CARB and several NGOs that the adjustment mechanism might incentivize manufacturers to use more leak-prone technologies when they transition to a low-GWP refrigerant. The U.S. EPA Phase 2 rule also extended the leakage standards to vocational vehicles, thereby covering all vehicles to which the Phase 2 tailpipe CO2 emission standards apply. Staff proposes to adopt the updated Phase 2 U.S. EPA leakage standards as part of the California Phase 2 regulation. As discussed further in


Section III. A.2.d., staff’s proposal would also require that manufacturers provide detailed A/C system information as part of the certification application.

C. PUV standards

Staff is proposing to align California’s PUV standards with the federal Phase 2 standards. Each vehicle manufacturer must meet the PUV standards on a fleet average basis for its entire produced fleet. Vehicles will continue to be tested using the same heavy-duty chassis procedures currently used by U.S. EPA for measuring criteria pollutant emissions from these vehicles, including the city fuel economy test cycle and the HFET. As with Phase 1, U.S. EPA’s PUV Phase 2 vehicle standard for each manufacturer varies depending on the WF of each individual vehicle family. The WF is determined based upon two key characteristics: payload and towing capacity. Payload is estimated by subtracting the curb weight, taking into account the weight of a four- or all-wheel drive system, from the vehicle’s GVWR. Towing capacity is estimated by subtracting the vehicle’s GCWR from the GVWR. The WF is calculated using the following equation:

Equation E-1: Work Factor Equation for Class 2b and 3 PUVs

WF = 0.75 × (GVWR − Curb Weight + xwd) + 0.25 × (GCWR − GVWR)

Where:

xwd = 500 pounds if the vehicle has four-wheel drive or all-wheel drive; xwd = 0 pounds for all other vehicles. As explained further in 40 CFR 86.1819-14, the fleet average standards for each manufacturer are then calculated each year, by taking the average of each fleet’s total production volume, multiplied by a unique CO2 target value for that fleet, as shown in Equation E-2 (CFR, 2017).

Equation E-2: Proposed Standard for Class 2b and 3 PUVs

Fleet-Average Standard = Σ[CO2 Targeti x Volumei]

Σ[ Volumei]

U.S. EPA has created separate CO2 standard formulas for SI and CI PUVs. Electric vehicles, fuel cell vehicles, and vehicles that operate without engines are treated as CI vehicles. Such zero-emission vehicles will help manufacturers meet the fleet-average standard.


Manufacturers must meet progressively more stringent target standards before meeting the MY 2027 and later target standards which vary based on WF, as shown in Table E-1 for SI PUVs and Table E-2 for CI PUVs.

Table E-1: Proposed Phase-In Standards for SI PUVs

Vehicle MY CO2 target (g/mile) 2021 [0.0429 × (WF)] + 331 2022 [0.0418 × (WF)] + 322 2023 [0.0408 × (WF)] + 314 2024 [0.0398 × (WF)] + 306 2025 [0.0388 × (WF)] + 299 2026 [0.0378 × (WF)] + 291

2027 and subsequent [0.0369 × (WF)] + 284

Table E-2: Proposed Phase-In Standards for CI PUVs

Vehicle MY CO2 target (g/mile)

2021 [0.0406 × (WF)] + 312 2022 [0.0395 × (WF)] + 304 2023 [0.0386 × (WF)] + 297 2024 [0.0376 × (WF)] + 289 2025 [0.0367 × (WF)] + 282 2026 [0.0357 × (WF)] + 275

2027 and subsequent [0.0348 × (WF)] + 268

1. Vehicle Technologies to Set Phase 2 Vehicle Standards Tables E-3 and E-4 list the suites of technologies that U.S. EPA considered when setting the federal primary tractor and vocational vehicle standards, respectively. Table E-5 lists a similar suite of technologies for PUVs. Not every vehicle will have all of these technologies. When setting the Phase 2 standards, U.S. EPA assumed an emission reduction effectiveness and adoption rate for each technology listed. Over time, the standards become more stringent based on either an expected increase in the effectiveness of the technologies used to set the standard, or an expected increase in adoption rate of the technologies, or a combination of both. There are additional technologies that are not on these lists that may be included in a vehicle manufacturers certified vehicle configuration. Although these technologies were not considered by U.S. EPA when standard setting, manufacturers can use these technologies to apply for emission credit. Examples of these technologies for vocational vehicles include ATIS,


aerodynamic fairings, full-electric vehicles, and e-PTO. For tractors and trailers, the use of lighter weight materials is an example of a technology that was not used in standards setting but may be utilized to meet the standards. (U.S. EPA, 2016)

Table E-3: Projected Tractor Technologies to Set Proposed Phase 2 Tractor

Primary Standards

Technology Technology Component Engine improvement (See subsection 6, below.) Aerodynamic Improvement • Roof fairing

• Fuel-Tank fairing • Gap Fairing • Aerodynamic bumpers and mirror • Underbody aero improvements

Transmission improvement • AMT • Improved Automatic • Dual Clutch • Top Gear Direct • Neutral Idle

Axle improvement • Advanced low friction axle lubricant and efficiency

• 6 x2, Part-time 6x2 axle configuration, or 4 x 2 • Down speed (Rear Axle Ratio)

Lower rolling resistance tires

• Drive and steer tires

Idle reduction • Adjustable AESS • Adjustable AESS w/Battery APU • Adjustable AESS w/ auto stop-start • Adjustable AESS with fuel operated heater

Accessory Improvements • Electric A/C compressor • Electric power steering

Other Technologies • Predictive cruise control • TPMS • ATIS • Neutral Coast


Table E-4: Projected Vocational Vehicle Technology Package to Set Phase 2 Vocational Vehicle Primary Standards

Phase 2 Vocational

Vehicle (Primary

Standards)

Technology Technology Component Engine improvement (See subsection 6 below.) Transmission improvement • Driveline optimization

• Architectural improvement

• Hybrid powertrain system

Axle improvement • Advanced low friction axle lubricant and efficiency

• Part-time 6x2 axle configuration

Lower rolling resistance tires • Drive and steer tires Workday idle reduction • Neutral idle

• Stop-start • Automatic engine

shutdown Weight reduction • Alternative light weight

material parts (e.g., door, roof, suspension, frame, wheels, etc.)

Electrified accessories • Electric power steering • Electric A/C compressor


Table E-5: PUV Technology Pathways to meeting the PUV standards Continued from Phase 1 New for Phase 2

• 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 • Light weighting • Gasoline direct injection • Diesel after treatment optimization • A/C system leakage reduction

• Advanced engine improvements for friction reduction and low friction lubricants

• Improved engine parasitics, including fuel pumps, oil pumps, and coolant pumps

• Valve train variable lift and timing • Cylinder deactivation • Direct gasoline injection • Cooled exhaust gas recirculation • Turbo downsizing of gasoline

engines • Diesel engine efficiency

improvements • Downsizing of diesel engines • 8-speed automatic transmissions • Electric power steering • High efficiency transmissions 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

Table E-6 below list the suite of technologies that U.S EPA considered when setting the trailer standards. The aerodynamic improvement technologies apply only to full and partial-aero box vans.


Table E-6: Trailer Technology Pathways used to Set the Trailer standards

Technology Technology Component Aerodynamic Improvement

• Trailer Aerodynamic Side Skirt • Trailer Aerodynamic Rear Fairing • Trailer Aerodynamic Underbody

Device

Lower rolling resistance tires

• Trailer tires

Tire pressure system • ATIS Table E-7 below lists a suite of technologies that U.S EPA considered when setting the federal custom chassis standards.

Table E-7: Phase 2 Custom Chassis Technology Packages

Custom Chassis Category Technology Package Motor home • TPMS

• Low rolling resistance tires Transit bus • Workday idle reduction (neutral idle, stop-start)

• TPMS or ATIS • Low rolling resistance tires • Weight reduction

Refuse truck • Workday idle reduction (neutral idle, stop-start) • TPMS or ATIS • Low rolling resistance tires

Coach bus • Workday idle reduction (neutral idle) • TPMS or ATIS • Simplified transmission improvement (added gears) • Low rolling resistance tires

School bus • Workday idle reduction (neutral idle, stop-start, automatic engine shutdown)

• TPMS or ATIS


Custom Chassis Category Technology Package • Simplified transmission improvement (added gears) • Low rolling resistance tires

Concrete mixer • Low rolling resistance tires (current average rolling resistance level)

Emergency vehicle • Low rolling resistance tires (current average rolling resistance level)

2. Design Standards for Select Custom Chassis

In the federal Phase 2 program as described in 40 CFR 1037.105, custom chassis manufacturers of motor homes, cement mixers, and emergency vehicles have an option to certify those vehicles with design standards (non-GEM standards). This path of certification will not require the use of GEM; instead, manufacturers are required to install specific technologies on every certified vehicle. Staff is proposing to align with these federal optional design standards for California Phase 2 program (shown in Table E-8). (CFR, 2017)

Table E-8: Optional Design (Non-GEM) Standards

Vehicle Type Required Technology MY 2021 MY 2027

Motor Home Combined CRR 6.7 kg/ton or less, and either TPMS or

ATIS

Combined CRR 6.0 kg/ton or less, and either TPMS or

ATIS Emergency Combined tire CRR 8.7

kg/ton or less Combined tire CRR 8.4

kg/ton or less Mixer Combined tire CRR 7.6

kg/ton or less Combined tire CRR 7.1

kg/ton or less Note: Combined tire CRR = Steer tire CRR x 0.3 + Drive tire CRR x 0.7

3. Engine Technologies Used to Set the Phase 2 Engine

Standards

Tables E-9, E-10, and E-11 list the suites of technologies that U.S. EPA considered when setting the federal tractor and vocational vehicle engine standards. For vocational vehicles, separate standards were developed for gasoline (SI engines), and diesel (CI engines). Gasoline engines are not used in tractors, so the tractor standards are for CI engines only. Not every engine will have all of these technologies. When setting the Phase 2 standards, U.S. EPA assumed an emission reduction effectiveness and adoption rate for each technology listed. Over time, the standards become more stringent based either an expected increase in the effectiveness of the technologies


used to set the standard, or an expected increase in adoption rate of the technologies, or a combination of both. (U.S. EPA, 2016) Table E-9: Projected Tractor Engine Technologies to Set Phase 2 Tractor Engine

Standards

Technology Category Technology Component Waste heat recovery • Turbo compound with clutch

• Rankine Waste Heat Recovery Parasitic/Friction improvement • Cylinder kits

• Variable-speed pumps • Advanced low-friction engine lubrication

After-treatment improvement • Increased SCR efficiency • Lower backpressure designs

Engine intake and exhaust system improvements

• Improved turbocharger • Higher efficiency EGR • Improved thermal control • Improved flow efficiency (intake and exhaust)

Combustion Optimization • High pressure fuel injection • Piston bowl optimization • Fuel injector tip design improvement • Model based calibration

Downsizing • 11 liter vs. 15 liter engine Downspeeding • Lug curve reshaping to optimize over SET

Table E-10: Projected Engine Technologies to Set Phase 2 the Vocational Gasoline (SI) Engine Standard

• Engine Friction Reduction (low-tension piston rings, piston skirt design, roller cam followers, improved crankshaft design and bearings, material coatings)

• Coupled Cam Phasing for Overhead Valve • Coupled Cam Phasing for Single Overhead Camshaft • Intake Cam Phasing for Dual Overhead Camshaft Engines • Stoichiometric Gasoline Direct Injection • Cylinder deactivation • Variable valve timing • Variable Valve Lift • Discrete Variable Valve Lift • Turbocharging and Downsizing • Engine Down Speeding


Table E-11: Projected Engine Technologies to Set Phase 2 the Vocational Diesel

(CI) Engine Standard

• Model based control • Engine Parasitic Reduction (variable speed pumps) • Engine Friction Reduction • Low Temperature EGR • Advanced Turbocharging System (variable geometry turbocharger) • Improve Engine Breathing Systems • Variable valve timing • Combustion System Optimization Technologies • Integrated High-Efficiency Aftertreatment System • Engine Downsizing • Engine Down Speeding

4. Transition Flexibility to Meeting Phase 2 engine standards Staff is proposing to include the transition flexibility provisions contained in the federal Phase 2 rule, as described in 40 CFR 1036.150 (CFR, 2017). Specifically, these provisions provide optional ABT flexibility standards for HHD and MHD vocational and tractor engines. This was in response to some engine manufacturers voicing concern that the 2024 MY heavy-duty engine standards may be too constraining. These optional provisions include the following:

• A pull ahead of the engine standards, from MY 2021 to MY 2020; • Extended life for engine credits generated by MY 2018 and 2019 engines,

MY 2020 pull ahead engines, and MYs 2021 to 2023 engines; and • Slightly less stringent tractor engine standards for MYs 2024 to 2026

(U.S. EPA, 2016) Table E-12 compares both the Phase 1 and Phase 2 standards to the Phase 2 ABT flexibility standards. As shown, the Phase 2 ABT flexibility standards for MY 2020 engines are more stringent than the applicable Phase 1 standards. However, the Phase 2 ABT flexibility standards for MYs 2024 through 2026 tractor engines are less stringent than the applicable Phase 2 standards. Engine manufacturers could elect to apply this provision separately to MHD and HHD engines, since these remain separate averaging sets.


A manufacturer that elects to certify all 2020 MY MHD and/or HHD vocational and tractor engines to 2021 MY standards, would be eligible to certify its MY 2024 through 2026 MHD and/or HHD tractor engines to slightly less stringent tractor engine standards. The GHG emission credits generated with 2018 to 2024 engines may be used through 2030 MY, even beyond the established 5-year credit life limit.

Table E-12: Optional ABT Flexibility Standards for Heavy Heavy-Duty (33,000 pounds + GVWR) and Medium Heavy-Duty (19,501 – 33,000 pounds GVWR)

Engines

II. Maintenance Requirements/In-Use Standards

A. Manufacturer Maintenance Requirements

Staff is proposing to align California’s maintenance requirements with the federal Phase 2 program requirements for manufacturers, as described in 40 CFR 1037.125. (CFR, 2017) As with Phase 1, the Phase 2 program requires vehicle manufacturers to submit detailed maintenance schedules with their certification application. This maintenance schedule must include instructions on lubricant replacement, fairing adjustments, periodic inspections of aerodynamics, and other operations that ensure products maintain compliance with emissions standards throughout the useful life of the vehicle (U.S. EPA, 2016). The federal program also requires manufacturers to ensure that critical emission-related maintenance is performed. Manufacturers can accomplish this supplemental maintenance by submitting survey data that shows at least 80 percent of their engines receive the required in-use maintenance or by providing critical emission-related maintenance at no cost to the user (ibid). The federal program also requires vehicle manufacturers to include detailed information in the owner’s manual to instruct owner/operators on how to replace LRR tires with tires performing equal to or better than the original tires (ibid). However, while tire replacement instructions must be provided in the owner’s manual, vehicle manufacturers are not directly responsible for ensuring owner/operators replace original tires with LRR tires.


B. Owner/Operator Maintenance Requirements

Staff is also proposing to align with federal maintenance requirements for owners/operators. As stated in 40 CFR 1037.655 and consistent with Phase 1, the federal Phase 2 program prohibits any person from removing or rendering inoperative any emission control device during its useful life (CFR, 2017). Vehicle owners are expected to maintain installed vehicle equipment, and modifications after useful life must be done on a reasonable technical basis that does not result in increased emissions of any regulated pollutant.

C. Vehicle Warranty

Staff’s proposal would maintain the same vehicle warranty requirements as those established by the federal Phase 1 program and retained for the Phase 2 program, as stated in 40 CFR 1037.120. The Phase 2 program adds warranty requirements for trailers; staff’s proposal would align with those requirements as well. At the time of certification, the federal program requires manufacturers to submit a copy of a vehicle’s warranty statement. GHG emission-related components are to be covered under the vehicle warranty. The federal Phase 2 program also requires manufacturers to design and build products that comply with emissions requirements at the time of sale. The warranty period is dependent on the type of vehicle certified. For LHD vehicles (8,500pounds – 19,500 pounds GVWR), the warranty period is 5 years or 50,000 miles. For MHD (19,501 – 33,000 pounds GVWR) - and HHD (33,000 pounds + GVWR) vehicles, the warranty period is 5 years or 100,000 miles (except tires). For trailers, the warranty period is 5 years (except tires). For tires, the warranty is 1 year for trailer tires and 2 years or 24,000 miles for all other tires. Vehicle manufacturers must describe emissions related warranty agreements in the owner’s manual. (CFR, 2017)

D. In-Use Vehicle Standards

As with the Phase 1 program, the federal Phase 2 program requires vehicles to be in compliance with the CO2 FEL throughout the useful life of the vehicle. Staff is proposing to align with the federal in-use compliance periods (useful lives) for heavy-duty vehicles and trailers as shown in Table E-13 and E-14 below, and as described in 40 CFR 1037.105 and 40 CFR 1037.140 (CFR, 2017). For all vehicle types except trailers, the useful life of a vehicle can be expressed in miles or years, whichever comes first. For heavy-duty PUV vehicles, the in-use standard of a vehicle varies, depending on the vehicle type and the GVWR of the vehicle. As with Phase 1, the in-use Phase 2 GHG standards for PUVs would be established by adding an adjustment factor to the full useful life emissions


used to calculate the GHG fleet average. Each model’s in-use CO2 standard will be the model-specific level used in calculating the fleet average, plus 10 percent. (U.S. EPA, 2016). This adjustment factor is intended to provide a reasonable margin for production and testing variability from initial and in-use testing results.

Table E-13: GHG Useful Life periods for Certified Heavy-duty Vehicles

with CI Engines and Trailers

Heavy Duty Vehicle Category Useful Life: Miles or Years (whichever comes first)

Class 8 Heavy-Heavy* GVWR >33,000 pounds

435,000 miles 10 years

Class 6- 7 Medium-Heavy* 19,501 pounds < GVWR ≤ 33,000 pounds


Class 2b- 5 Light- Heavy** GVWR ≤ 19,500 pounds

150,000 miles*** 15 years

Trailers 10 years NOTE: Useful life periods are defined separately for criteria pollutant and GHG emissions. Criteria pollutant vehicle useful life provisions only apply to heavy duty vehicles that are chassis certified and typically less than 14,000 pounds GVWR (i.e. PUVs). The current criteria pollutant useful life period for these vehicles is 150,000 miles (15 years). * Class 6 through 8 vocational vehicles with CI engines are considered “Heavy Heavy Duty Vehicles” if the installed engine’s primary intended service class is heavy-heavy duty. All other Class 6 through 8 vocational vehicles are considered “Medium Heavy Duty Vehicles”. ** PUVs (Class 2b-3) are included in this category. *** Beginning with MY 2021

Table E-14: GHG Useful Life periods for Certified Heavy-duty Vehicles with SI Engines

Heavy Duty Vehicle Category Useful Life: Miles or Years

(whichever comes first) Class 6- 8 Medium-Heavy

19,501 pounds < GVWR ≤ 33,000 pounds 185,000 miles

10 years Class 2b- 5 Light- Heavy* GVWR ≤ 19,500 pounds

150,000 miles** 15 years

NOTE: Useful life periods are defined separately for criteria pollutant and GHG emissions. Criteria pollutant vehicle useful life provisions only apply to heavy duty vehicles that are chassis certified and typically less than 14,000 pounds GVWR (i.e. PUVs). The current criteria pollutant useful life period for these vehicles is 150,000 miles (15 years). * PUVs (Class 2b-3) are included in this category. ** Beginning with MY 2021

E. In-Use Engine Standards


As with the Phase 1 program, the federal Phase 2 program requires engines to remain in compliance with their CO2 FEL throughout the useful life of the engine. Staff is proposing to align with the federal Phase 2 in-use compliance periods as shown in Table E-15 below. For engines, useful life values are the same as those applicable to criteria air pollutants. Beginning with MY 2021, the useful life period for all SI engines is 150,000 miles or 15 years, whichever comes first, regardless of vehicle category.

Table E-15: GHG Useful Life Requirements for Certified Engines

Useful life: Miles or Years (whichever comes first)

Heavy-Duty Engine Category

CI Engines SI Engines

Heavy-heavy duty • Designed for multiple rebuild • GVWR normally >33,000

pounds


Medium-heavy duty • May be designed for rebuild • GVWR normally between

19,500 pounds and 33,000 pounds

185,000 miles 10 years 150,000 miles* 15 years*

Light-heavy duty • Not designed for rebuild • GVWR normally ≤19,500

pounds

150,000 miles* 15 years*

NOTE: Useful life periods are defined separately for criteria pollutant and GHG emissions. Criteria pollutant engine useful life provisions are identical to the GHG engine useful life provisions, with the following exception: the useful life for light-heavy duty CI and SI engines subject to the criteria pollutant regulations is 110,000 miles (10 years). * Beginning with MY 2021(40 CFR 1036.108 (d))

For in-use engine standards, the FEL serves as the primary emission standard for engine family testing, excluding certification and confirmatory testing. FCLs are used to calculate the FEL value. As explained in 40 CFR 1036.108, the CO2 FEL is calculated by multiplying the FCL by 1.03. (CFR, 2017)

F. Vehicle Labels

Both the federal Phase 1 and Phase 2 standards establish vehicle labeling requirements for medium- and heavy-duty vehicles as verification that vehicles meet required GHG emission standards. Phase 2 also added similar requirement for trailers. Similar to the emission control labels found on engines, the vehicle labels include a heading, corporate name and trademark, vehicle family name, regulatory subcategory,


date of manufacture, fuel and lubricant requirements (as applicable), and a compliance statement. Vehicle manufacturers meeting the small business provision requirements may delay compliance with the vehicle standards for one year and must label any excluded vehicles with the following statement, “THIS VEHICLE IS EXCLUDED UNDER 40 CFR 1037.150(C)”(CFR, 2017; U.S. EPA, 2016).

For Phase 1, the agencies also required the labels on all vocational vehicles and tractors to include a list of installed emission control devices to help CARB enforcement staff verify that necessary components are installed by manufacturers, as originally submitted during the certification process (U.S. EPA, 2016). Emission reduction components include idle reduction technologies, LRR tires, vehicle speed limiters, vehicles with hybrid powertrains, aerodynamic devices, and other advanced or innovative technologies present on the vehicle. The complete list of emission control identifiers for the labels can be found in Appendix III of 40 CFR Part 1037. (CFR, 2017)

However, for federal Phase 2, it would be optional for vehicle manufacturers to include the emission identifiers on vocational vehicle and tractor labels, while for trailers, it would be mandatory. Staff is proposing to align California’s trailer labeling requirements with the federal Phase 2 program’s requirements. However, for vocational vehicles and tractors, staff is proposing that specific emission control systems would need to be included on the label of Phase 2 vehicles sold in California. The systems required to be identified are those that can be visually inspected by CARB enforcement personnel. See Chapter III of this report for further discussion and the list of systems required to be identified on the labels.

G. Engine Labels

The federal Phase 2 program retains the Phase 1 labeling requirements for new heavy-duty engines meeting GHG standards. As specified in 40 CFR 86.095-35, the federal Phase 2 program requires emission control labels, stating that engines meet both criteria and GHG emission standards, to be attached to a permanent part of the engine. Engine labels are to include a heading, the full corporate name and trademark, engine family and model designations, compliance statement, engine specifications, and recommended adjustments. As specified in 40 CFR 1036.135, the labels must identify emission control systems and any limitations on certification. Specifically, the label will need to indicate whether the engine is certified for use in vocational vehicles, tractor-trailers, or both. For example, if a manufacturer certifies HHD engines to the CO2 standards using only the transient cycle testing, they would include the statement “VOCATIONAL VEHICLES ONLY.” Diesel engines that use the ABT credit program must also include the FEL to which the engine is certified. (CFR, 2017)

III. Small Business Compliance Delay


Staff is proposing to retain the same compliance delays for small businesses as allowed by the federal Phase 2 program, as stated in 40 CFR 86.1819-14(k), 1036.150(d), and 1037.150(c) (CFR, 2017). The Phase 2 regulation has the following delays in place for qualifying small businesses:

• Engine, PUV, vocational vehicle, and tractor manufacturers are not

subject to the Phase 2 regulations until January 1, 2022. • Trailer manufacturers are not subject to the Phase 2 regulations until

January 1, 2019. (This delay is not applicable to California Phase 2 since the trailer requirements will not become effective until January 1, 2020.)

• Manufacturers of engines or vehicles that run on any fuel other than gasoline, E85, or diesel fuel may delay complying with every standard by one year.

Currently, the Small Business Administration defines a small business for heavy-duty vehicle manufacturing and engine manufacturing as 1,000 employees and 750 employees, respectively. Qualifying entities will need to submit a written declaration as outlined in the reporting section of the proposal.

IV. Test Procedures and Certification Process

This section includes a discussion of the test procedures and the GEM model, and how they are used to show compliance with the Phase 2 standards. Manufacturers are required to California-certify vehicles and engines that are produced and distributed for sale in California. For Phase 1, manufacturers were “deemed to comply” with the California Phase 1 regulation if they demonstrated compliance with the federal Phase 1 regulations. For Phase 2, CARB staff is proposing the “deemed-to-comply” approach would no longer be an option.

A. Test Procedures

The proposed Phase 2 test procedures for heavy-duty engines and vehicles are outlined below.

1. Engines

Manufacturers would be required to demonstrate compliance with the California GHG heavy-duty engine standards using one of the following test procedures, as applicable: the “California Exhaust Emission Standards and Test Procedures for 2004 and Subsequent Model Heavy-Duty Diesel Engines and Vehicles” as last amended


[September 1, 2017] and the “California Exhaust Emission Standards and Test Procedures for 2004 and Subsequent Model Heavy-Duty Otto-Cycle Engines” as last amended [September 1, 2017]. These two test procedures would be amended to incorporate the federal Phase 2 certification emission standards and requirements for the control of GHG emissions from heavy-duty engines, Subparts A through I, Part 1036, Title 40, CFR, which specify the certification GHG emission standards, engine family certification process, in-use and certification test procedures, special compliance provisions, and ABT provisions for Phase 2. By utilizing the two test procedures above, manufacturers would be able to comply with both federal and California certification requirements.

2. Vehicles

Manufacturers would be required to demonstrate compliance with the Phase 2 vehicle GHG emission standards using the “California Greenhouse Gas Exhaust Emission Standards and Test Procedures for 2014 and Subsequent Model Heavy-Duty Vehicles”. These test procedures would be amended to incorporate the federal Phase 2 certification emission standards and requirements, which specify GHG emission standards, requirements to certify vehicle families, in-use testing provisions and certification (such as fuel and dynamometer specifications), test and modeling procedures, special compliance procedures, and ABT provisions. By complying with the proposed procedure, manufacturers would be able to comply with the federal and California certification requirements simultaneously.

3. GEM

The Phase 2 GEM builds upon the version of the GEM currently being used to certify Phase 1 tractors and vocational vehicles (PUVs require a chassis test for certification.) While the version of GEM used in Phase 1 contained most of the technical and mathematical features needed to run a vehicle simulation, the model was limited. Phase 2 GEM accounts for the broader range of engine and vehicle technologies that were used during the Phase 2 standard setting development process.

Unlike Phase 1 GEM, Phase 2 GEM requires the manufacturer to provide an engine fuel map and specific transmission information as separate input files. Manufacturers also have the option of using engine and transmission performance data obtained from a powertrain test. Phase 2 GEM also allows a user to modify or adjust performance information for specific components. Like Phase 1 GEM, Phase 2 GEM recognizes the benefits of aerodynamic improvements, low rolling resistance tires, vehicle speed limiters, weight reduction, and idle reduction (only for high roof sleeper tractors). In addition, Phase 2 GEM requires inputs for axle configuration, axle ratio, and size of tires. Phase 2 GEM also accounts for additional technology improvements including neutral idle, intelligent controls, and tire pressure systems.


Trailer manufacturers can use either Phase 2 GEM or a mathematical equation that is based on GEM simulations. Trailer emissions are the emissions modeled from a GEM-simulated tractor. Phase 2 user defined parameters for trailers include tire-rolling resistance, change in aerodynamic drag when compared to the baseline trailer, weight reduction, and tire pressure systems.

Based on the inputs, Phase 2 GEM will calculate the expected GHG emissions of the vehicle over three pre-defined drive cycles: CARB HHDDT cycle, 55 miles per hour cruise cycle, and 65 miles per hour cruise cycle. The two cruise cycles have varying road grade. For vocational vehicles, two additional cycles are utilized, one simulating parked idling operation and the other idling in traffic. The results are expressed in terms of weighted grams of CO2 per ton-mile. (U.S. EPA, 2016e)

B. Certification Process

As discussed in Chapter III, engine and vehicle manufacturers will not be “deemed to comply” with the California Phase 2 regulation if they demonstrate compliance with the U.S. EPA Phase 2 GHG regulations. This is a departure from the approach used for California Phase 1 certification. Instead, manufacturers would be required to submit all their data to CARB for independent review and approval before being issued an EO to legally sell vehicles/engines in the state.

The major steps for California certification are:

1. Pre-certification meetings. As is customary, staff would meet with

manufacturers prior to submitting any certification application information. These meetings are referred to as Certification Preview Program meetings. These meetings give all parties an opportunity to discuss the Phase 2 GHG standards and requirements, manufacturer planned product offerings, testing and certification plans, timing, and any other certification-related matters.

2. As is currently the practice, manufacturers would be required to register with CARB’s DMS. This system stores the certification documents (e.g., label design, warranty statement, engine emission test data, GEM input data, GEM output data). While this practice would continue for California Phase 2, CARB is currently developing an E-Cert system for use in the 2019 timeframe that will replace the DMS system for most data submittals. The DMS system would still be used for submitting supporting documentation (i.e., warranty documents). Once established, manufacturers would submit the certification data elements (i.e., GEM inputs and outputs) into the E-Cert database for certification. This would be a web-based submittal process. Once approved, the E-Cert system would also be used to


generate an EO to certify the engine or vehicle family. Staff plans to conduct certification guidance workshops to explain in detail how to submit the required certification data. Staff would also develop standardized forms and templates to facilitate data submittal.

3. Engine, vehicle (tractor and vocational vehicle), and trailer manufacturers would be required to submit specific information, as outlined below (CFR, 2017).

Engine Manufacturers: • Submit to CARB information relating to:

o Durability Plan/Report; o Carryacross Table; o Sensors Table; o SCR Inducement Strategies; o Description of SCR Catalyst; o DPF Regeneration Strategies; o Tamper Resistance declaration; o Emission test data in (g/bhp-hr) for criteria, ammonia, and

GHG pollutants; o Engine/ECI Label Picture; o Clean Idle label picture; o Statement of Compliance/cover letter; o Warranty Statement; o Maintenance instructions/schedule; o Auxiliary Emission Control Devices (AECDs); o ABT Plans; o Delegated assembly plan; o Any approved waivers; and o OBD approval letter.

• Staff would review the submitted information and verify that all

requirements are met. Once verified, CARB would then issue an EO to certify the engine family.

• Submit EOY reports (per 40 CFR 1036.250) as part of completing the certification process to approve engine use and sale. Engine manufacturers must submit EOY reports 90 days after the end of the model year pertaining to:

o U.S directed production volumes by serial number and engine configuration;

o California directed production volume; and


o Manufacturers may combine the information from this report with the ABT plan described below and submit a single ABT report instead.

• Engine manufacturers participating in an ABT plan must submit a preliminary report by March 31 following the end of model year and a final report by September 30 following the end of model year (per 40 CFR 1036.730). The final report requirement may be waived. The report must include:

o engine family designation and averaging set; o emission standards for engine family; o CO2 FCL; o final production volumes by serial number and engine,

U.S and California directed; o The transient cycle conversion factor for each engine

configuration as described in §1036.705; o useful life values for engine families; and o a credit plan identifying the manufacturer’s actual credit

balances, flexibilities, trades, and credit deficit plan. Vehicle Manufacturers:

• Submit to CARB information relating to: o GEM user-defined input parameters and technology

improvement inputs (See Tables E-16 through E-19 for GEM user defined inputs for tractors and vocational vehicles.(U.S. EPA, 2016e));

o GEM Output FEL (g/ton-mile) CO2; o Applicable useful Life; o Statement of Compliance; o Warranty Statement; o Maintenance instructions; o AECDs; o A/C System Information (See Chapter III for discussion

of California requirements); o ABT Plans; and o Engine family names and models used in each vehicle

family.

• Staff would review the submitted information and verify that all requirements are met and GEM output accurately reflects technology inputs. Once verified, CARB would then issue an EO to certify the vehicle family.


Table E-16: User-Defined Modeling Parameters for Class 7 and 8 Combination

Tractors

Table E-17: Technology Improvement Options for Tractor Manufacturers


Table E-18: User-Defined Modeling Parameters for Vocational Vehicles

Table E-19: Technology Improvement Options for Vocational Vehicle Manufacturers

• Submit EOY annual reports (per 40 CFR 1037.250) 90 days after the end of the model year pertaining to:

o U.S directed production figures of each vehicle family during MY;

o Report by VIN, and vehicle configuration, and subfamily; o Report uncertified vehicles sold to secondary vehicle

manufacturers; and o California directed production volume.


• Vehicle manufacturers participating in an ABT plan must submit a preliminary report by March 31 following the end of model year and a final report by September 30 following the end of model year (per 40 CFR 1037.730). The final report requirement may be waived. The report must include for each vehicle family participating in ABT:

o Vehicle family and subfamily designations, and averaging set;

o Regulatory subcategory and CO2 emission standards that would otherwise apply;

o Applicable vehicle emissions standards (FEL); o Final U.S. production volumes by VIN and vehicle

configuration/subfamily; o California directed production volumes; o Useful life values for vehicle families; and o A credit plan identifying the manufacturer’s actual credit

balances, flexibilities, trades, and credit deficit plan. This would include separate California credit tracking as discussed in Chapter III. (A further discussion on ABT credits is in Section iv, Compliance and Flexibility).

Trailer Manufacturers:

• Define trailer families, subfamilies, and configurations; • Submit results from aerodynamic evaluation, tire CRR testing,

other inputs used in GEM-derived compliance equation.(See Table E-20 for inputs into GEM-derived compliance equation (U.S. EPA, 2016e));

• Provide off-cycle technology improvement factor and supporting documentation (if applicable);

• Identify applicable CO2 emission standard for family/subfamily; • Provide CO2 emission calculation inputs and results using

compliance equation; • Averaging allowed only for 2027and subsequent MYs. Trailers

would have a limited averaging program at that time. Applies to full-aero box vans only. Credits only apply to given model year (no carryover). Limited carry-over deficits.

• Staff would review the submitted information and verify that all requirements are met and compliance equation output accurately reflects technology inputs. Once verified, CARB would then issue an EO to certify the trailer family.

• Trailer manufacturers are required to submit EOY annual reports 90 days after the end of the model year (per 40 CFR 1037.250(a)) pertaining to:


o U.S. directed production figures of each trailer family by VIN, vehicle configuration, and subfamily;

o California directed production volumes; and o Trailers exempt under transitional allowance flexibility, if

applicable • Trailer manufacturers in an averaging plan must submit a

preliminary report by March 31 following the end of model year and a final report by September 30 following the end of model year (per 40 CFR 1037.730). The final report requirement may be waived. The report must include:

o Trailer family and subfamily designations, and averaging set;

o Regulatory subcategory and CO2 emission standards that would otherwise apply;

o Applicable vehicle emissions standards (FEL); o Final U.S. production volumes by VIN and vehicle

configuration/subfamily; o California directed production volumes; o Useful life values for vehicle families; and o A credit plan identifying the manufacturer’s actual credit

balances and credit deficit plan.

4. Manufacturers are currently required to keep records for at least eight years after the due date for the end-of-year report. This requirement would be retained for California Phase 2. Engine and vehicle credits would not be recognized by CARB if the records are not kept on file as required. The records can be kept in any format on any media, and must be readily available in English if CARB staff requests them at any time.

Table E-20: User-Defined Modeling Parameters for Trailers

V. Compliance Flexibility-Credits


As with Phase 1, the federal Phase 2 program recognizes the need to provide compliance flexibility in order to set stringent CO2 standards that would reduce emissions at a reasonable rate. Also, to accommodate any technology feasibility issues and lead time for manufacturers, the federal Phase 2 program would continue the ABT program and other flexibility provisions including off-cycle credits (referred to as innovative technology credits in Phase 1), and ATCs to help manufacturers meet CO2 standards. The ABT program allows a manufacturer to exercise maximum flexibility in redesigning and planning where and how to achieve emission reductions with credit options. The Phase 2 program would also allow manufacturers with a surplus of credits from the Phase 1 program to use those credits in Phase 2. Because staff is proposing the same CO2 standards as in the federal Phase 2 program, even though CARB’s regulations will take effect after implementation of the federal Phase 2 program has begun, staff is proposing to adopt the federal CO2 credit programs and flexibilities. (U.S. EPA, 2016)

A. ABT Credits

Averaging is defined in the federal Phase 1 and 2 programs as the exchange of emission credits between engine families or truck families within a given manufacturer’s regulatory subcategories and averaging sets (U.S. EPA, 2011b). The averaging concept of this credit program allows manufacturers to certify one or more engine or vehicle families within the same averaging set at levels above the applicable emission standard. Of course, the increased emissions from the engine or vehicle families within a manufacturer’s averaging set would need to be offset by a certified engine or vehicle with cleaner emissions so that the average emissions from all of the manufacturer’s engine or vehicle families would be below or equal to the level of the applicable emission standard. Banking is defined as the retention of emission credits by the manufacturer for use in future MY averaging or trading. Trading is defined as the exchange of emission credits between manufacturers, which are then used for averaging or banking purposes, or trading with another manufacturer (U.S.EPA, 2016).

The Phase 2 ABT program for tractors and vocational vehicles generally continues the Phase 1 approach with few revisions. However, trailers are a new category of vehicles where the ABT approach would be limited and doesn’t begin until 2027. For trailers, averaging would be allowed only within two averaging sets: 1) long dry and refrigerated van trailers, and 2) short dry and refrigerated van trailers. There would be no credit banking or trading allowed for trailers, and, averaging would only be allowed for full-aero box vans.

Staff is proposing to adopt identical ABT program guidelines and restrictions as established by the federal Phase 2 program. As allowed in the current heavy-duty ABT engine program for criteria pollutants, manufacturers would be restricted to ABT credits within a regulatory subcategory. For engines and vehicles, the federal program allows credit averaging within and across vocational and tractor subcategories within the same


weight class groups: LHD, MHD, and HHD (U.S. EPA, 2016). For the PUVs category, the federal program has defined only one averaging set or subcategory.

Under the ABT credit program, while credits could be retained by a manufacturer for a period of up to five years, manufacturers could carry forward credit deficits for up to three years before reconciling any shortfall. However, a manufacturer would need to use or reconcile any credit deficits before acquiring any banked and traded credits for additional MYs (U.S. EPA, 2016).

B. Off-Cycle Credits

Staff is proposing to align with the federal Phase 2 off-cycle program (formerly known as the innovative technology program in Phase 1). For Phase 1, eligible innovative technologies are those that are newly introduced in one or more engine or vehicle models, but not yet widely implemented in the manufacturer’s fleet or averaging set for which the credit is generated. Such technologies resulting in innovative technology credits include predictive cruise control, gear-down protection, engine cooling strategies, advanced drivelines, light-weight components, active aerodynamic features, and adjustable ride heights.

Beginning in MY 2021, technologies that are not accounted for in the GEM simulation tool or engine or chassis dynamometer testing would be considered “off-cycle”. This would exclude some of the Phase 1 innovative technologies like predictive cruise control. Additionally, no off-cycle credits would be granted for crash avoidance technologies. To qualify as an “off-cycle” technology, manufacturers would need to demonstrate that the technology was not in common use prior to 2010. Manufacturers would be able to carry-over innovative technology credits from Phase 1 into Phase 2. (U.S. EPA, 2016)

Note that the term “credit” in this section describes an additive adjustment to emission rates and is not equivalent to an emission credit in the ABT program. Off-cycle credits/adjustments are to be based on A to B testing of pairs of vehicles differing only with respect to the technology in question.

C. Carryover of Phase 1 Credits and Credit life

The federal Phase 2 program continued the five-year credit life provisions from Phase 1, and did not adopt any general restriction on the use of banked Phase 1 credits in Phase 2. In other words, Phase 1 credits in MY 2019 could be used in Phase 1 or in Phase 2 in MYs 2021–2024. Staff is proposing the same carryover of Phase 1 credit provisions and credit life provisions as in the federal Phase 2 program. (U.S. EPA, 2016)

D. Advanced Technology Credits


The Phase 2 ATC provisions differ significantly from those provisions in Phase 1. Eligible technologies for the Phase 1 ATC program include hybrid powertrain designs with energy storage systems, Rankine cycle engines with a waste heat recovery system, all-electric vehicles, and fuel cell vehicles. The federal Phase 1 program established a 1.5 multiplier for a manufacturer that accrues ATCs, but also sets a cap of 60,000 megagrams for the amount of advanced credits that can be used by any averaging set for any MY to prevent market distortions (U.S. EPA, 2011b).

Staff proposes to align with the federal Phase 2 program’s ATC provisions. Table E-21, below, lists the ATC multipliers (U.S. EPA, 2016)

Table E-21: Advanced Technology Multipliers

The ATC multiplier values were based on a cost analysis that compared the costs of these technologies to costs of other conventional technologies. Staff’s cost analysis showed that adopting multipliers in this range would make these technologies much more competitive with the conventional technologies and could allow manufacturers to more easily generate a viable business case to develop these technologies for the heavy-duty sector and bring them to market at a competitive price.

One feature of the Phase 1 advanced technology program that is not being continued in Phase 2 is the allowance to use ATCs across averaging sets.

As discussed in Chapter III, although staff is proposing to generally align with the federal ATCs, staff is proposing to limit ATCs for PHEVs sold in California that emit more NOx emissions than a comparable vehicle or that do not have adequate AER. These requirements would require manufacturers to adjust the federal credits gained from selling these vehicles in California, or they could choose not to sell PHEVs with NOx increases in California. PHEVs with NOx increases would also not typically be eligible for CARB incentive funding. See Chapter III for more information on the federal credit adjustment option.

appendix e - further detail on phase 2 greenhouse gas emission standards · · 2017-12-19staff is...

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