1 UNITED ST AT ES ENVIRONMENT AL PROTECTION AGENCY

ANN ARBOR, MI 48105

September 10 , 20 10 O FFICE OF AIR AND RADIATION MEMORANDUM SUBJECT: PROCESS FOR DETERMI N ING CLASS 2B AND 3 C O 2 STANDARD FROM: A. Neam, J. Cherry , Assessment and Standards Division TO: Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Heav y - Duty

Engines and Vehicles ; Docket Number EPA

- HQ

- OAR

- 2010

- 0162



## 1 Intr oduction The heav y dut y (class 2b and class 3) pickup trucks and vans sold currently in the United States, and those which are anticipated to be sold in the MY 201 4

- 2018 timeframe, are highl y varied and satisfy

a wide range of needs. Examples for these vehicle classes include vans that can transport 15 passengers and pickup trucks that can tow over 20,000 pounds. American consumers require man y vehicle options to accommodate their utility needs and p references. Recent volatility in oil prices and the state of the economy have demonstrated that consumer demand and choice of vehicles within this wide range can be sensitive to these factors. Although it is impossible for an y organization to precisel y p redict the future, a characterization and quantification of the future fleet are required to assess the impacts of rules which would affect that future fleet. The historic perturbations in the U.S. econom y and especiall y i n the automotive sector in recent ye ars make such forecasting particularl y problematic, and so f or this rulemaking, it is assumed the future mix of heav y duty trucks and vans, and volumes of heav y dut y vehicles, will be the same as those in the 2008 model y ear , the most recent relativel y stable sales y ear . In order to accomplish this, manufacturers have provided details on their 2008 models and volumes. This data along with available emissions data was used to determine the baseline fleet. T his document provides details of how the basel ine fleet was created, how the CO 2 emissions for each vehicle was determined, how the baseline and standard emissions curves for the fleet were determined, and gives the phase in for the standard.2

1.1 Why do the agencies establish a baseline vehicle fleet? In order to calculate the impacts of proposed standards , it is necessary to estimate the composition of the future vehicle fleet absent the standards in order to conduct comparisons. We have developed a comparison fleet. The first step in this process was to develop a baseline fleet based on model y ear 2008 data. EPA and NHTSA created a baseline fleet in order to track the volumes and types of fuel econom y - improving and CO 2 - reducing technologies which are already present in today ’s fleet. Creating a basel ine fleet helps to keep, to some extent, the agencies’ from adding technologies to vehicles that already have these technologies, which would result in “double counting” of technologies’ costs and benefits when model ing

. 1.2 The 2008 baseline vehicle fleet 1.2.1 Why

did the agencies choose 2008 as the baseline model year? The 2008 model y ear is the most recent model ye ar for which the industry had normal sales. The 2009 model year data was available, but this model year was disrupted by the economic downturn and the bankruptcies of both General Motors and Chry sler. There was a significant reduction in the number of vehicles sold by both companies and the industry as a whole. These abnormalities made the 2009 model y ear data unsuitable for use as a future fleet. Therefore, the agencies chose to use the 2008 model y ear data as the baseline since it was the latest representative transparent data set available.
1.2.1.1 On what data is the baseline vehicle fleet based? EPA used several sources to determine the compositio n, volumes, and emissions of the vehicles in the fleet. Though the composition and volumes of the fleet are from the 2008 model y ear, some advances in fuel econom y technology have occurred since the 2008 model y ear, so emissions data from newer vehicles ( when available) was used to model the emissions of the vehicles. Representative emissions data from the 2008, 2009, and 2010 model year’s vehicles was used. The source of the heav y duty fleet composition and volumes are the automotive manufacturers. Chry sler, Ford, and General Motors each submitted product plans which included their fleet composition, details of each unique (weight and capability) truck and van sold, and their volume. The manufacturers included the 2008 model y ear at the agency ’s request

. There were two sources for the CO 2 emissions data. The first was emissions data submitted by

the manufacturers at vehicle certification. Manufacturers are required to submit city

cycle emissions data when they certify vehicle for sale in Federal stat es. Manufacturers are also required to submit highway cycle emissions data for vehicles that are certified for sale in California. Since not all vehicles were certified for California sale, only a subset of emissions data was available from the certification database.3

The second source for CO 2 emissions data is a test program run b y EPA. EPA tested a number of vehicles to acquire data from vehicles that are currently in service. The vehicles chosen augmented the certification data, to insure adequate CO 2 values were available for modeling the 2008 model y ear fleet.
1.2.1.2 How were the 2008 vehicles CO 2 emissions modeled?
Id eall y, the light dut y C AFE ADFE approach would have been used, but the necessary data is not available for each heav y duty vehicle. Also, many y ears worth of fuel econom y data was anal yzed to determine the coefficients of the light duty equation. Since the method that is used for CAFE was not available, a new method was derived. The 2008 model y ear vehicles CO 2 emissions were modeled us ing characteristics of each vehicle that relate to CO 2 performance. Although other characteristics affect CO 2 performance, the characteristics available were test weight, axle ratio, and 4 wheel drive vs. 2 wheel drive. In order to model vehicle CO 2 em issions, data was acquired from both the certification database and the test program that match the vehicle ty pe (truck or van), class (2b or 3), and engine. Multiple vehicles were examined to determine a factor that could be used with each of the charact eristics that were used to model CO 2 emissions. Two equations were determined, one for Cit y CO 2 and one for highway CO 2 . They are as follows: City CO 2 = { A + [ ( C

- B ) * D ]} * { 1 + [ ( ( E /F )

- 1) * G ] } + H Where: A= Base City

CO 2 B= Test_Vehicle_Test Weight C= CurrentVehicles Test Weight D= Weight Multiplier City E= Vehicle Axle Ratio F= TestVehicleAxle Ratio G= City Axle Multiplier H= 0 if test and current vehicle have the same wheel drive =
– City 2wd4wd Adder if test vehicle had 4wd and the current vehicle has 2wd

= + City 2wd4wd Adder if test vehicle had 2wd and the current vehicle has 4wd Highway CO 2 = { I + [ ( C

- B ) * J ]} * { 1 + [ ((E/F)

- 1) * K ]} + L Where: I =Base Highway

CO 2 B=Test_Vehicle_Test Weight C=CurrentVehicles Test Weight J=Weight Multiplier C ity4

E=Vehicle Axle Ratio F=TestVehicleAxle Ratio K=Highway

Axle Multiplier L = 0 if test and current vehicle have the same wheel drive =
– Highway 2wd4wd Adder if test vehicle had 4wd and the current vehicle has 2wd =+ Highway 2wd4wd Adder if tes t vehicle had 2wd and the current vehicle has 4wd

Combined CO 2 is used to set the standard. It is derived using the following equations: Combined CO 2 =55% * City CO 2 + 45% * Highway

CO 2
1.3 The MY 201 4 - 2018 Standards
Heav y dut y vehicles are required for many applications that are beyond the capabilities of vehicles from the light duty fleet. It is important that the CO 2 standard for heav y dut y vehicles does not prevent them from continuing to satisfy these needs. The baseline data set used for the 2014

- 2018 model year standards was anal yz ed in man y wa ys to determine the best way

to create a baseline and ultimately a standard.
1.3.1 What criterion was examined for determining the Baseline? In order to preserve the utility of heav y dut y vehicles, many criteria were evaluated to determine the input for the baseline equation. Examples include EPA curb weight, ALVW, Payload, GCW, GVWR, Footprint, and Trailer Tow. The definition for each is below. EPA curb weight = curb weight of the vehicle with 33% of the opt ional content added. ALVW = EPA curb weight + 1⁄2 Payload Payload = GVWR

- EPA curb weight GVWR = Gross Vehicle Weight Rating, GCWR = Gross Combined Weight Rating Footprint = Wheelbase

– (Front Track Width + Rear Track Width) / 2 Trailer Tow = GCWR

- GVWR
1.3.2 How was the criterion chosen for the Baseline? The main applications for heav y dut y vehicles include hauling payload/people and/or towing. Most of the criteria were evaluated graphically with the exception of footprint. After reviewing the footprint data, it was obvious that footprint did not track well with CO 2 and the capability

of heav y dut y vehicles.5

CO 2 was graphed vs. EPA curb weight, and it was observed that at the same weight, vehicles can vary

several hundred grams per mile of CO 2 . This is due t o the fact that at the same curb weight, vehicles can have both different test weights (which relates to payload) and different towing capacities. EPA curb weight was determined to be an inadequate criterion to base the standard on. CO 2 was graphed vs. AL VW, and a more linear relationship was observed in comparison to the graph using EPA curb weight. There was still large variation in CO 2 , due to the fact of not capturing the capability of the vehicle completely . ALVW was determined to be an inadequate c riterion to base the standard on. CO 2 was graphed vs. payload, and the graph was not linear. A large variation in CO 2 was observed, due to the fact of not capturing the capability of the vehicle completely

. Payload is not a good criterion to base the standard on. CO 2 was graphed vs. GCWR, and the graph was linear, but at the same GCWR vehicles can have very

different CO 2 . The large variation in CO 2 showed that GCWR does not completely

capture the capability

of a vehicle. GCWR was determined to be an ina dequate criterion to base the standard on. CO 2 was graphed vs. GVWR, and the graph was linear, but like GCWR at the same GVWR, vehicles can have very different CO 2 . The large variation in CO 2 indicated that GVWR does not completely capture the capability of a vehicle. GVWR was determined to be an inadequate criterion to base the standard on. These vehicle attributes individually did not adequately

capture the capability

of the heav y dut y vehicles. The EPA also looked at a measure of capability that is a combination of attributes. It is called the “Work Factor” of the vehicle. The work factor is defined as .75 * (payload +500 if 4wd) +. 25 * towing. Work factor gives a very linear graph with CO 2 . There are some outlier vehicles, but overall it was dete rmined to be the best measure of capability

. 1.3.3 How was the Baseline stringency determined? To determine the baseline level of stringency , a curve was determined using the baseline CO 2 data. The data was anal yz ed based on the criterion (work factor) calcul ated in the previous section. It was necessary to anal yz e the baseline using a linear line fit given that it is one of our goals not to eliminate vehicles in this category . Using a linear line fit gives equal weighting to each vehicle configuration ensuring that no vehicle configuration dominated the standard whether it has high or low CO 2 given its work factor. The linear fit produces the equation: CO 2 = 0.0489 * (Work Factor) + 377 Baselines for future standards may be created using production weighting . Production weighting will give greatest weight to vehicles with the largest production. This is a good method when a fleet’s demand is well known, but given the uncertainty with the current fleet, it is best to use a linear line fit.6 1.3.4 How was the Base line used to determine the Standard? To determine a standard, CO 2 reducing technologies for this segment were reviewed. It was determined that different technologies applied to gas vehicles than to diesel vehicles. There were more CO 2 technologies avail able for diesel vehicles than gas vehicles. This led to two different percent CO 2 reductions, and separate standards for the gas and diesel vehicles. A 15 percent reduction is possible for diesel vehicles given the technology currentl y on vehicles in the baseline and the CO 2 reducing technologies available. A 10 percent reduction is possible for gas vehicles given the technology currentl y on vehicles in the baseline and the CO 2 reduction technologies available.
Using these percentages, separate stand ards were determined for gas and diesel vehicles. The final standard for gas has the equation: CO 2 = 0.0440 * (Work Factor) + 339 The final standard for diesel has the equation: CO 2 = 0.0416 * (Work Factor) + 320
1.3.5 What is the phase in for the Standard?
T he phase in percentages (shown in Table 1.3

- 1 Phase in Percentages ) are the same for both the gasoline and diesel standard.
Table 1.3 - 1 Phase in Percentages Year Phase - In Percentage 2014 15% 2015 20% 2016 40% 2017 60% 2018 100% Table 1.3

- 2 Diesel CO 2 Standard Equations ) shows how the standard is phased in for diesel vehicles. Table 1.3

- 2 Diesel CO 2 Standard Equations Year Equation 2014 CO 2 = 0.0478 * (Work Factor) + 368 2015 CO 2 = 0.047 4 * (Work Factor) + 366 2016 CO 2 = 0.0460 * (Work Factor) + 354 2017 CO 2 = 0.0445 * (Work Factor) + 3437 2018 CO 2 = 0.0416 * (Work Factor) + 320

Table 1.3

- 3 Gasoline CO 2 Standard Equations ) shows how the standard is phased in for gasoline vehicles.

Table 1.3 - 3 Gasoline CO 2 Standard Equations Year Equation 2014 CO 2 = 0.0482 * (Work Factor) + 371 2015 CO 2 = 0.04 79 * (Work Factor) + 369 2016 CO 2 = 0.04 69 * (Work Factor) + 362 2017 CO 2 = 0.0460 * (Work Factor) + 354 2018 CO 2 = 0.0440 * (Work Factor) + 339
1.3.6 How is the vehicle technology package effectiveness determined? The individual CO2 reducing te chnologies are discussed in the Preamble and Chapter 3 of the draft RIA . Each technology discussed has a range of CO2 reduction potential taking into account vari ations of implementation for c lass 2B and 3 vehicles. As in the 2016 light duty

final rule, the combined CO2 reduction for vehicle technology packages are determined using the lumped parameter model. A c lass 2B and 3 version of the lumped parameter is located in the docket.