American Council for an Energy-Efficient Economy ● Environmental Defense Fund

● Natural Resources Defense Council ● Northeast States for Coordinated Air Use Management ● Sierra Club ● Union of Concerned Scientists



## Key Opportunities to Strength en Proposed Medium- & HeavyDuty Truck Standards

Our organizations commend EPA and NHTSA for releasing the Notice of Proposed Rulemaking (NPRM) to establish fuel effi ciency and greenhouse gas standards for new medium- and heavy-duty trucks sold in model years 2014 to 2018. Setting the first-ever standards for these vehicles is an important part of meeting the President’s commitment to reduce America’s oil dependence and cut greenhouse gas emissions from the transportation sector.

While the proposed standards represent a step forward, we urge the agencies to make critical improvements before finalizing the st andards in order to improve the program’s efficacy in the short-term and to establis h a strong foundation for future rulemakings. Our organizations appreciate d the opportunity to recomm end these improvements in testimony given during the recent public hearin gs and will provide more technical details

in our written submissions to the docket.

Overall, it is critical that the agencies fina lize strong standards for tr ucks that achieve the greatest possible fuel savings and greenhouse gas reductions. The technology exists to set more stringent standards in the model year 2014-2018 tim eframe for all classes of trucks. Specifically, trailer improvements offe r a tremendous opportunity to increase fuel efficiency and reduce emissions and should be subject to standards starting in model year 2014. In addition, this rulemaking must esta blish a strong foundation for future truck

standards that are base d on full-vehicle testing.

Beyond these overarching improvements, we pr ovide six specific recommendations to strengthen the final rule by modifying exis ting elements of the proposed standards and adding new provisions:

1. Establish a Pathway to a Mature Program; Ensure Adequate Data Collection and Transparency : The agencies should design th e rule to transition from a technology/component-based approach to a pe rformance-based vehicle standard by 2018. This will involve rapid development of duty-cycl e-specific test protocols and standards. To achieve this and to ensure transparenc y, the program needs to include a major data collection component from the outset, including i) in-use testing and full vehicle testing data from manufacturers and government agenci es; ii) manufacturer re porting of actual configurations sold and their simulated fu el consumption; and iii) the status of manufacturer compliance including credit balances for each compliance category. The agencies should make the collected data public and provide annua l reports describing new and on-road fleet performance.

2. Increase the Stringency for Class 2B and 3 Pick-ups and Vans : The standards should be accelerated to achieve the proposed 2018 requirements by 2016 in order to beconsistent with the 2012-2016 light-duty rule . For gasoline picks-up and vans, the standards should be strengthe ned to achieve at least a 15 percent reduction by 2018.

3. Increase the Stringency for Vocational Trucks : The vocational truck emissions reduction requirement should be at least 6 percentage points great er than currently proposed for medium-duty vocational trucks and 3 percentage points greater for heavyduty vocational trucks in 2017, reflecting the potential for sa vings from hybridization, advanced transmissions, weight reduction, and other efficiency improvements. This modest increase in the string ency of the proposed standard s, along with refinements to the protocols for demonstrating innova tive technology benefits, will encourage improvements beyond engines and tires and resu lt in greater overall emission reductions and fuel savings.

4. Incentivize Advanced Technologies : The program needs to provide greater incentive for advanced technologies and other efficiency improvements that are not necessary to meet the standards as proposed. To that end, the agencies should i) further develop the supplemental powerpack testing options and en sure they are applicable to a range of technologies, and ii) increase th e stringency of the vocational st andards (as in item 3) to ensure that advanced technology credits have value in the marketplace.

5. Establish a Long-Term Trajectory for Engine Standards : The rule needs to provide enough information on the trajectory of engine standards to ensure sustained investment in next generation engine technologies. In the final preamble, EPA should include a 2020 target for stringency in e ach engine category based on technologies identified by the National Academy of Sciences (NAS) available over this time period.

6. Require Fuel Economy Labels for Trucks: Labels should allow truck buyers, and, in particular used truck buyers, to better compare the fuel efficiency performance of the trucks they are considering. Heavy-duty pickups and vans sh ould display fuel consumption on a consumer label. For larger vehicles and their engines, a permanent

label should show estimates of fuel use ove r a few key cycles, analogous to city and highway MPG for light-duty vehicles. Resear ch previously submitted to EPA shows how truck fuel use over a small number of cycles can be used to predict fuel use on a wide range of duty-cycles.1. Adequate Data Collection and Transparency

Overview In the proposed rule, DOT/EPA discuss the need for a new, more sophisticated approach to vehicle testing than cu rrently proposed to “completely capture the complex interactions of the total vehicle and the pot ential to reduce fuel consumption and GHG emissions through the optimization of those interactions.” (75 Fed. Reg. at 74172) The Heavy-duty National Program should transition to a compliance scheme based on actual technology performance in a full-vehi cle configuration. Doing so will enable future standards to encourage technologies th at fail to be differentiated in the current compliance regime but can actually cut emissi ons and fuel consumption. To enable the transition, the agencies should include requirements in this rule to collect and publicly disseminate existing vehicle perf ormance data and data generated in future model years. The agencies should also establish procedures to demonstrate progress and to enhance the

program transparency.

Comments/Concerns Requirements for public data are intended to accomplish three goals: (a) Establish a broad technical database to support transition of the compliance regime from one based on simulation resu lts of specific components to one based on full-vehicle technology implementation and testing that is validated by on-road

measurements, (b) Enhance public understanding of actual technology adoption, and (c) Track actual on-road emissions and fuel consumption performance of new

vehicles and the full on-road fleet.

Proposed Solutions

1. Collect in-use testing and full vehicle testing data performed by manufacturers and the federal agencies. Expand agency on-road testing to validate current compliance models and encourage manuf acturers to provide more data. Make data publicly available.

2. Require manufacturers to report actual spec ifications for vehicle configurations sold. Run GEM using these specifications.

3. Build a truck market database for public use and evaluation. In clude a description of the truck fleet population and its oper ating characteristics through data types previously provided through the U.S. Cens us Vehicle Inventory and Use Survey but also organize data consistent with the subcategories used in the truck emissions and fuel economy compliance regime.

4. Publish an annual report describing new and on-road fleet performance. For new vehicles, the report should contain data similar to EPA’s a nnual publication of “Light-Duty Automotive Technology, Ca rbon Dioxide Emissions, and Fuel Economy Trends.” The report should be expanded to cover performance and summary characteristics (from the database described in section 3 above) of the existing fleet so an overall picture of medium- and heavy-duty truck emissions and fuel consumption progress is clear.

5. Publish an annual report describing manu facturer credit bala nces within each compliance category and the use of any credit flexibility mechanisms, such as advanced technology credits.2. Stringency for Class 2B and 3 Pickups and Vans

Overview For heavy-duty pickup trucks and vans, the agencies propose a 10 percent and 14 percent

reduction in CO 2 emissions from 2010 levels from ga soline and diesel fueled vehicles,

resp e ctively, in 2018. For gasoline vehicles , they consider a technology package combining low friction lubricants, reduction of engine friction loss, stoichiometric gasoline direct injection (S-GDI), automatic 6- and 8-speed transmissions, low rolling resistance, 5 percent mass reduction, and improved aerodynamics. The agencies estimate

CO 2 emissions reductions of 10 percent and a cost of about $1,368 for this package, leading to a 5-year payb ack. (75 Fed. Reg. 74234-74239)

Comments/Concerns AEO 2010 projects that heavy-duty pickups a nd vans will already achieve virtually the same efficiency in the Reference Case as the proposed standard requires, because these vehicles will take advantage of the te chnologies brought to market by the 2012-2016 light-duty rule. Therefore, to accelerate that take-up, the st andard for heavy pickups and vans should require the proposed improvements by 2016.

In the proposed package, the agencies di d not include technologies like cylinder deactivation and coupled cam phasing, which in their own assessment are cheap (together costing less than $250) but effective, reducing CO 2 by 4 to 8 percent. Adding these two technologies to the agencies’ proposed packag e would provide a reduc tion of 15 percent, according to EPA’s Lumped Parameter Model. The revised package offers a payback in less than 4 years, which is le ss than the payback period for th e agencies’ original package achieving only 10 percent savings.

Furthermore, the proposed standard does not take advantage of other promising technologies including Turbo-GDI, whic h combines S-GDI, turbocharging, and downsizing for gasoline vehicles. Accordi ng to the TIAX 2009 report submitted to the NAS, this package will reduce CO 2 emissions for large trucks by 11 to 17 percent compared to stoichiometric GDI. The tec hnologies have an added cost of $2,000-$3,000, but the payback period for these technologies on top of the agencies’ proposed package is 5 years. The 2010 NAS study also estimated a 10 to 14 percent reduction potential for

CO 2 from turbocharged downsized direct injection engine wi th Variable Valve Actuation (VVA).

Proposed Solutions

1. Accelerate phase-in of the gasoline and diesel standards for heavy-duty pickups and vans to achieve the pr oposed 2018 requirements by 2016.

2. For gasoline pickups and vans, strengthen standard to achieve at least 15 percent reduction by 2018 by including cylinder deac tivation and coupled cam phasing in the proposed package.

3. Consider other promising technologies including Turbo-GDI and VVA that have the potential to significantly reduce CO 2 emissions and provide a reasonable payback period.3. Stringency for Vocational Trucks

Overview The proposed standards for vocational trucks would bring 1 to 2 pe rcent savings beyond what is gained through engine efficiency impr ovements. This reflects the benefits of low rolling resistance tires alone. Other po tential vehicle improvements, including aerodynamics and mass reduction, cannot be captured by the proposed regulations because the regulated entities are the chassis manufacturers, and the regulated vehicle has a standard body by assumption. Similarly, gearing and tran smission selection are not captured by the standard. Manufacturers may obtain credit for transmission improvements and other “innovative” technologie s if they can demonstrate the savings from these technologies to the satisfaction of the EPA. Credits are also available for hybrids and other “advanced” technologies.

Comments/Concerns The NAS report explored savings opportuni ties beyond engine and tires for vocational vehicles, including hybridization, aerodynamic improvements, advanced transmission, and mass reduction. For transmissions, for example, the NAS found savings in the range of 2 to 8 percent. Significant penetration of hybrid s is anticipated in the vocat ional sector. For example, Pike Research projects 300,000 medium- and heavy-duty hybrid sales, or 7 percent of projected sales, by 2015. 1 Furthermore, at least one transmission manufacturer is claiming savings of more than 8 percen t for vocational trucks on average using

automated manual or dual clutch transmissions to replace the torque converter automatics

that now dominate the market. Assumi ng two percent savings on average from hybridization across vocational trucks along w ith other savings consistent with NAS, additional savings (beyond those from tires) on the order of 12 percent for medium and 7 percent for heavy vocational vehicles will be achievable by 2017.

To a large degree, the gap between the agen cies’ proposed standards and what others have concluded is possible to achieve reflects the constraints of the rule structure and testing protocol for vocational trucks, rather than a differe nce in views of technological potential. The proposal to allow credit fo r “advanced” and “innovative” technologies could help to bridge this ga p, but only if the protocols for gaining credit are well defined and the vocational standard is strong enough to provide manufacturers with an incentive to adopt these technologies.

Proposed Solutions

1. Establish specific test protocols for credi ting of advanced transmissions and other efficiency technologies.

2. Require vocational trucks to reduce emissions by at least an additional 6 percent for light and medium vehicles and an a dditional 3 percent for heavy vehicles by 2017 (a total of 12 percent and 7 percent, respectively), prom oting the production of hybrids and the faster uptak e of advanced technologies.

1 Pike Research http://greenbigtruck.com/2010/06/pike-research-f orecasts-300000-medium-heav y-duty-hybrids-by-2015 ; AEO 2010.4. Incentivizing Advanced Technologies

Overview EPA and NHTSA have proposed a crediting syst em to incentivize the adoption of certain advanced vehicle technologies. As propos ed, manufacturers would receive special Advanced Technology Credits for hybrid vehicles, Rankine (bottoming) cycle engines, all-electric vehicles, and fuel cell vehicles . Unlike credits generated by ‘conventional’ engines and vehicles, these advanced technology credits would be tran sferable to any of the seventeen regulatory subcategorie s for both engines and vehicles.

Comments/Concerns

Transmissions . In its current form, the GEM software does not quantify the impact of transmission technologies. Th e NAS reported that advances in transmission systems represented a potential 3 to 7 percent re duction in fuel consumption, depending on the vehicle category in th e 2015-2020 timeframe.

Hybrid vehicle test procedure . There are currently three options for testing the benefits of hybrid vehicles as compared to their conventi onal counterparts. The fi rst option is to test entire vehicles using a chassis dynamometer a nd a designated test cycle. The second and third option are to use an e ngine or “powertrain” dynamome ter to conduct “hardware-inthe-loop” testing of the complete hybrid pow ertrain, including the engine and all hybrid system components. Option 2 can be used to test only pre-transm ission hybrid systems, while Option 3 can be used to test any pre-transmission or post-transmission hybrid system. Option 3 could also be used to test other advanced power tr ain technologies such as continuously variable transmissions (CVT) and automated manual transmissions (AMT).

Sufficient incentive for advanced technologies . The stringency level in the program must be strong enough to drive accelerated pe netration of advanced technology. Also, in addition to cross-category trading, the agenci es are requesting comment as to whether a multiplier of 1.5 for these credits would be appropriate for further incentivizing the introduction of advanced technologies. It is not clear that these a dditional credits would be redeemable, given the modest stringency le vels set forth in the proposal—especially in the case of vocational vehicles where the pot ential is greatest for technologies such as hybrids and electric vehicles. As such, multiplier values should not be used at this time.

Proposed Solutions

1. To catalyze further development in tran smission and hybrid technologies, develop a chassis and/or ‘post-transmission’ testi ng procedure that coul d better capture the

benefits of a host of driv eline-related improvements including AMT, CVT, and hybrid technologies.

2. For hybrid test procedure, adopt chassis te sting or hardware-in-the-loop powertrain testing using the same test cycles and cycle weightings as proposed for chassis testing. However, if engine or powertr ain testing is allowed for certifying pretransmission hybrids, the agencies must define negative torques in the motoring sections of the FTP to represent recharging events such as braking or downhill driving.

3. In the longer term, move towards harmonizati on of engine and cha ssis cycles, with a reduced dependence on the FTP cycle.5. Engine Standards - Trajectory for 2020

Overview Engine standards for medium- and heavy-duty ve hicles should be designed to maximize fuel savings and spur investment in ne xt generation technologies. The proposed standards establish two phase s of medium- and heavy-duty engine emissions and fuel consumption stringency levels beginning in model year 2014 and model year 2017. The stringency levels are based on an assessmen t of engine-related technologies that are currently available today. Additional techno logies not captured by the standards are identified but are not evaluated for their pote ntial impact on future engine standards.

Comments/Concerns There are technologies under de velopment, such as advanced waste heat recovery, that could improve engine performance beyond the leve ls required in the proposed standards. These technologies will require significan t levels of investment to reach full commercialization by 2020. A strong indication of the direction of future standards would help ensure these advanced engine technologies are ready in the post-2017

timeframe.

Forthcoming technologies could provide ma jor efficiency gains by 2020. The National Academies of Science identified engine tec hnologies that would allow heavy-duty tractor engines to achieve a 13 percent to 17 pe rcent reduction in fuel consumption by 2020, compared to a 2010 engine. These technologi es are in many cases being advanced through the SuperTruck program. In compar ison, the proposal calls for a 6 percent reduction in fuel consumption by 2017.

The proposed engine standards will improve fuel consumption by requiring the use of off-the-shelf technology, but further advances in engine technol ogy will require greater incentives. Laying out a t echnical roadmap and string ency target for engine improvements that go beyond 2017 would provide technology developers an indication

of the future direction of th e standards and encourage furt her investment, development, and deployment of these technologies.

Proposed Solution EPA should include in the final preamble a 2020 target for stringency in each engine category based on an evaluation of technologi es identified by the National Academy of Sciences expected over this time period.6. Labeling

Overview Labeling requirements in the proposed rule are as follows:

• For Class 2B and Class 3 pickups, the labe l would show complia nce with criteria pollutant standards only. (75 Fed. Reg. at 74263)

• For engines, the current label for criteri a pollutants is permanent and provides descriptive information, including displacement, emission control systems, and tune-up specifications. Under this rule, th e label would also indicate whether the engine is certified for trac tor or vocational use and, if the manufacturer is using

ABT , the Family Emissions Limit. (75 Fed. Reg. at 74268)

• For tractor trailers, the label would in clude descriptive information about the

vehicle and its certified e ngine, and about any featur es that would affect GHG emissions such as aerodynamic equipmen t and tires. It would also list the vehicle’s Family Emissions Limit for GHG if the manufacturer is using ABT

.

• Vocational trucks would be labeled sim ilarly to tractors. Aerodynamic equipment would not be included, but hybrid powe rtrain or other ad vanced technology applied to the certification of the vehicle would be.

The agencies decline to require fuel consum ption labeling, because they believe it could mislead the purchaser. (75 Fed. Reg. at 74352)

Comments/Concerns The label should serve not only as a complia nce tool, but also to provide consumer

information. Lack of standardized fuel cons umption information is a market barrier to efficient technologies. For heavy pickups a nd vans, a label simila r to the light-duty vehicle label would be appropriate.

For engines, tractors, and vocational trucks, the Family Emissions Limit, at a minimum, should be provided on the label, whether or not the manufacturer is pa rticipating in ABT. While such information may not at this stag e allow for meaningful estimates of on-road fuel consumption, it should allow comparis ons across similar vehicles and promote the deployment of efficiency technologies. For vocational vehicles, labels showing performance on each of the drive cycles (trans ient, 55 mph, 65 mph) would allow users to better understand the suitability of a gi ven vehicle for their duty cycles.

Proposed Solutions

1. Class 2bs should be labeled with fuel c onsumption in gallons per 100 miles. Fuel consumption could be supplemented with payload and towing capacity

information on the label.

2. Engine, tractor, and vocational truck labels should include the Family Emissions Limit, regardless of whether the manuf acturer is participating in ABT.

3. Tractor and vocational truck labels s hould list the vehicle’s (or family’s) performance on each cycle test cycle, instead of, or in addition to, the weighted average used for certification.