Greenhouse Gas (GHG) Emission Requirements Heavy-Duty Pickup Trucks and Vans Presentation

Greenhouse Gas (GHG) Emission
Requirements
Heavy-Duty Pickup Trucks and Vans
Industry/EPA Workshop
Compliance Division
Washtenaw Community College
November 3, 2011

1

Organization of Topics
Topics

Slide Numbers

Overview

3-4

Standards

5-16

Application for Certification

17-26

Credits

28-30

Reporting

32-33

Additional Information Sources

34-35

2

How Does This Apply to HD Pickup Trucks and Vans?
•

Regulations are located at 40 CFR Part 1037
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•

Applicable to 2014 and later model year new heavy-duty Vehicles
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•

§1037.104 – Exhaust Emissions Standards for CO2, CH4, N2O
§ 1037.115 – Other Requirements
§ 1037.150 (a, b, c, e, f, g, h, i, l, m) – Interim Provisions
§ 1037.740 – Restrictions for Using Emission Credits
§ 1037.801 - Definitions

Specifically regulates emissions of carbon dioxide, nitrous oxide, methane, and hydrofluorocarbons

Excluded Vehicles include:
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–
–
–
–

Vehicles not meeting definition of “motor vehicle” or “heavy-duty vehicle”
Medium-duty passenger vehicles
Vehicles produced before 2014 model year, unless certified under §1037.150 (except early credits provision)
Vehicles subject to light-duty greenhouse gas standards of 40 CFR part 86
Small manufacturers qualifying under Small Business Administration regulations at 13 CFR 121

3

HD Pickup Truck and Van Program

• In general, the HD pickup truck and van
program strongly resembles the existing nonGHG program for these vehicles and the
existing LD GHG program
• Today’s briefing focuses on the aspects of the
program which are unique
4

GHG STANDARDS

5

HD Pickup Truck & Van CO2 Standards
1037.104

• The HD Pickup Truck and Van CO2 emissions standards:
– Begin in 2014MY
– Are CO2 standards, not CREE
– Represent a production-weighted fleet-average standard where all vehicles in
this category form a single averaging set

– The GHG emission standards for these vehicles apply for a weighted average of
55% FTP City and 45% Highway test cycle (new requirement for Federal HD)
where the vehicle is tested at Adjusted Loaded Vehicle Weight (ALVW)

6

HD Pickup Truck & Van CO2 Standards
1037.104

Spark Ignition
CO2 Target (g/mile) = 0.0440 x WF + 339

Compression Ignition
CO2 Target (g/mile) = 0.0416 x WF + 320

7

HD Pickup Truck & Van GHG Phase-in
1037.150(b)

Table 1 to 1037.150

Table 2 to 1037.150

8

Optional Certification under §1037.104
1037.150(l)

• You may certify certain complete or cab-complete
vehicles to the standards of §1037.104 (HD Pickup
Truck and Van standards), such as:
– Complete or cab-complete spark-ignition vehicles
– Cab-complete vehicles based on a complete sister vehicle
– Class 2b or 3 incomplete vehicles

Restrictions:
• Generally, does not affect criteria pollutant certification
9

HD Chassis-Certification Path #1
Complete HD Pickup Trucks and Vans
Class 2b/3
complete

Sparkignition

Criteria

C

GHG
Criteria

Diesel

C

or

E

E = engine-certified (g/hp-hr) for criteria
pollutants and treated as a vocational vehicle for
GHG with separate engine certification (g/hp-hr)
and vehicle certification with GEM (g/ton-mile)
C = chassis-certified (g/mile)
C or E = manufacturer can choose between
chassis-certification and engine-certification

GHG

• Spark Ignition vehicles must chassis certify for both criteria and GHG emissions
• Diesel vehicles may choose to either:
• Chassis certify for both criteria and GHG emissions –or• Engine certify for criteria emissions and certify as a vocational vehicle for
GHG emissions with separate engine certification and vehicle certification
using GEM
10

Optional HD Chassis-Certification Path #2
Incomplete HD Pickups and Vans
1037.104(f), 1037.150(l)
Class 2b/3
Incomplete
Sparkignition
Diesel

Criteria

C

GHG

C (sister)
C
C (sister)

Criteria
GHG

E
E

E = engine-certified (g/hp-hr) for criteria pollutants and
treated as a vocational vehicle for GHG with separate
engine certification (g/hp-hr) and vehicle certification
with GEM (g/ton-mile)
C = chassis-certified (g/mile)
C and E = manufacturer can choose between chassiscertification and engine-certification

• Spark Ignition and Diesel vehicles may choose to either:
• Chassis certify for both criteria and GHG emissions: further may use a
sister vehicle for purposes of GHG compliance
–or–
• Engine certify for criteria emissions and certify as a vocational vehicle for
GHG emissions with separate engine certification and vehicle certification
using GEM
11

Optional HD Chassis-Certification Path #3
Class 4 and Above Vehicles
1037.150(l)
Classes greater
than Class 3
Sparkignition
Diesel

Criteria

E

GHG

C or E

Criteria
GHG

E

E = engine-certified (g/hp-hr) for criteria pollutants
and treated as a vocational vehicle for GHG with
separate engine certification (g/hp-hr) and vehicle
certification with GEM (g/ton-mile)
C = chassis-certified (g/mile)
C or E = manufacturer can choose between chassiscertification and engine-certification

• Spark Ignition and Diesel vehicles must engine certify for criteria emissions
• Diesel vehicles must:
• Certify as a vocational vehicle for GHG emissions with separate engine
certification and vehicle certification
•Spark ignition vehicles may choose to either:
• Chassis certify for GHG emissions (2014MY and later) –or –
• Certify as a vocational vehicle for GHG emissions with separate engine
certification (2016MY and later) and vehicle certification using GEM
(2014MY and later)

12

Optional HD Chassis-Certification Path #4
Loose Engine Provision
1037.150(m)
Loose engines
(for any HD
vehicle class)
Sparkignition
Diesel

Criteria

E

GHG

C (surrogate) or E

Criteria
GHG

E

E = engine-certified (g/hp-hr) for criteria pollutants
and treated as a vocational vehicle for GHG with
separate engine certification (g/hp-hr) and vehicle
certification with GEM (g/ton-mile)
C = chassis-certified (g/mile)
C or E = manufacturer can choose between
chassis-certification and engine-certification

• Spark Ignition and Diesel vehicles must engine certify for criteria emissions
• Diesel vehicles must:
• Certify as a vocational vehicle for GHG emissions with separate engine certification
and vehicle certification using GEM
•Spark ignition vehicles may choose to either:
• Chassis certify for GHG emissions using the highest ETW vehicle powered by the
engine as a surrogate GHG result (with maximum of 15,000 engines or 10% of total
HD engine production of the family; also not allowed to generate credits) –or –
• Certify as a vocational vehicle for GHG emissions with separate engine certification
and vehicle certification

13

HD Pickup Truck and Van N2O and CH4
Standards
1037.104(c)

• The GHG emission standards for these vehicles apply for a
weighted average of 55% FTP City and 45% Highway test cycle
HD Pickup Truck and Van Standards (g/mile):
Model Years
2014 and Later

CH4 Emissions

N2O Emissions

0.05

0.05

• Use CO2 credits can be used to offset
14

HFC Standards
1037.115(c)

• HFC emissions are controlled through a leakage standard,
not a credit program
• No averaging, banking, or trading of HFC credits is allowed
• The leakage of refrigerant from an A/C system may not
exceed 1.50 percent per year
– For systems with refrigerant capacities less than 734 grams, the
leakage may not exceed 11.0 grams per year

15

Dual, Multi, or Flex Fuel Vehicles
1037.104(d)(10)

• Perform exhaust testing on each fuel type
• Use either the conventional fueled CO2 emission rate or
a weighted average of the emission results as specified
in 40 CFR 600.510-12(k)
• Must meet the N2O and CH4 standards on both fuels or:
– Certify to an alternate standard for N2O or CH4 emissions
(offset by the CO2 credit provision) and:
– Not exceed the alternate standard when tested on either fuel.
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CERTIFICATION

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GHG Certification/Compliance Timeline
• Submit pre model year report with cert preview
• 90 days after end of model year:
– Submit report including production volumes of vehicle
subconfigurations

• 270 days after end of model year:
– Submit final report
GHG Pre Model Year Report Templates will be available at
www.epa.gov/otaq/certdat2.htm
18

PMY Reports for Class 2b-3 Pickup Trucks and
Vans
• Required by EPA and NHTSA in accordance with 40
CFR 1037.104 (EPA) and 49 CFR 535.8 (NHTSA)
• Single submission through EPA database for both
agencies
• Reports can be submitted:
– As early as manufacturer’s first pre-certification meeting with
EPA and NHTSA
– As late as manufacturer’s first application submission for a
certificate of conformity

PMY Report - Purpose and Contents
• Purposes
– Built on continuing long-standing process for LD CAFE program
– Provides early estimates of manufacturers’ good faith efforts to comply with
GHG and FC standards
– Pre-requisite for EPA approving manufacturers’ applications for certificates of
conformity

• Overview of Contents
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Subconfiguration target and fleet standards
Test group and fleet certification results
Production volumes
Joint approvals for innovative technology
Certification statements for EPA and NHTSA
Credit plans

HD Pickup Truck PMY Template

21

Subconfigurations
1037.104(a)(4), 1037.104(d)(9)

•

May group subconfigurations that have the same equivalent test weight,
GVWR, and GCWR. Assume the curb weight equals two times ETW
minus GVWR.

•

May group together other subconfigurations if use the lowest target value
for any of the subconfigurations

•

Must test at least the greater of 10 subconfigurations or ten percent of
subconfigurations (unless we approve a lower number)

•

At least 90 percent of production volume in the configuration level must be
represented by test data (actual data, data substituted, or analytically
derived)
22

Analytically Derived CO2 (ADC)
1037.104(g)
– Provision allows the use of analytically derived CO2 emission rates based on
baseline test data instead of measured emissions rates
– ADCs are similar to ADFEs used for light-duty vehicles
– Calculated using the equation below, rounded to the nearest 0.1 g/mile

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ADC = Analytically derived combined city/highway CO2 emission rate (g/mile) for a new vehicle.
CO2base= Combined city/highway CO2 emission rate (g/mile) of a baseline vehicle.
Road load force coefficients
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•

ΔF0 = F0 of the new vehicle – F0 of the baseline vehicle.
ΔF1 = F1 of the new vehicle – F1 of the baseline vehicle.
ΔF2 = F2 of the new vehicle – F2 of the baseline vehicle.

ΔAR = Axle ratio of the new vehicle – axle ratio of the baseline vehicle.
ΔETW = ETW of the new vehicle – ETW of the baseline vehicle.

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ADC Constraints
1037.104(g)
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The baseline vehicle must (unless we approve otherwise)
– Comply with all applicable emission standards in the model year associated with the ADC
– Include in the pool of tests all official tests of the same or equivalent base engine,
transmission class, engine code, transmission code, engine horsepower, dynamometer
drive wheels, and compression ratio
– May supplement the pool with tests associated with the worst-case engine or transmission
codes and carryover or carry-across engine families
– Must eliminate from the pool tests that were previously used during the model year as
baseline tests in ten other ADC subconfigurations
– Select the tested configuration with the smallest absolute difference between the ADC and
the test CO2 emission rate as the baseline subconfiguration

–

Downward adjustment of ADC from the baseline is limited to ADC values 20 percent below the
baseline emission rate

–

Upward adjustment is not limited

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No more than 40 percent of the subconfigurations tested in the final CO2 submission may be
represented by ADCs
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HFC Emissions
1037.115(c)
• An excel file is available to calculate percent leakage and leakage
rate of HFC emissions
1. RIGID PIPE CONNECTIONS
3. FLEXIBLE HOSES
Enter the number of each type of fitting
in the
appropriateforcell
below:
Enter
the dimensions
each
hose, by hose type, in the system.
Type of connection
Single O ring:
Single captured O ring:
Multiple O ring:
Seal washer:
Seal washer with O ring:
Metal gasket:

No.

4. HEAT EXCHANGERS, MUFFLERS, RECEIVER/DRIERS, AND ACCUMULATORS
Inner
Emission rate for all devices combined assumed to be 0.5 x 0.522.
Length Diameter
Emission
rate for
all devices (g/year):
0.261
(mm)
(mm)

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1
All Rubber Hose
High pressure side, hose 1
2 hose 2
High pressure side,
High pressure side, hose 3
5. COMPRESSORS
High pressure side, hose 4
Enter the number of each type of fitting in the appropriate cell below:
Low pressure side, hose 1
650
16
Low pressure 6.368
side, hose 2
Rigid pipe connections emission rate (g/year):
Type of Fitting
No.
Low pressure side, hose 3
O-ring housing seals:
1
Low pressure side, hose 4
Molded housing seals:
1
Standard
barrier
or veneer hose
2. SERVICE PORTS AND REFRIGERANT
CONTROL
DEVICES
1
High
pressure
side,
hose 1
650 plates:
10
Enter the number of each type of port/control
device
in the
appropriate
cell below: Fitting adapter
High pressure side, hose 2
Gasket housing seals:
High pressure
Lips on shaft seal (belt-driven compressors only):
1
Type of connection
No. side, hose 3
High
pressure
side,
High side service ports:
1 hose 4
Low pressure side,1 hose 1
Low side service ports:
Compressor emission rate (g/year):
11.223
Low
pressure side,2 hose 2
Switches, transducers, and pressure relief
valves:
Low pressure side,1 hose 3
Refrigerant control devices:
6. REFRIGERANT CAPACITY FOR SYSTEMS WITH GREATER THAN 733 GRAMS
Low pressure side, hose 4
Enter the system's refrigerant capacity in grams in the appropriate cell below:
Ultra-low
permeation
barrier or veneer hose
Service port/control device emission
rate (g/year):
0.574
High pressure side, hose 1
Refrigerant Capacity (g)
1300
High pressure side, hose 2
High pressure side, hose 3
FOR REFRIGERANT CAPACITY FOR SYSTEMS WITH LESS THAN OR EQUAL TO 733 GRAMS
High pressure side, hose 4
TOTAL SYSTEM REFRIGERANT EMISSION RATE (G/YEAR):
19.2
Low pressure side, hose 1
Low pressure side, hose 2
Low pressure side, hose 3
FOR REFRIGERANT CAPACITY FOR SYSTEMS WITH GREATER THAN 733 GRAMS
Low pressure side, hose 4
TOTAL SYSTEM REFRIGERANT PERCENT LEAKAGE (%/YEAR):
1.5%

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HFC Emissions
• Provide HFC Emission Summary Sheet for A/C systems with
application
• Maintain records for each air conditioning system configuration
A/C System Information

A/C system
number

Refrigerant
GWP, if other
Refrigerant than R134a

Production
Volume

Rigid Pipe
Connectins
emission rate

Leakage Inputs
Service
port/control
Hose
Compressor
device
emission rate permeation emission rate
rate (g/year):
(g/year):
(g/year):

A/C Leakage Rate

Refrigerant
Capacity (g)

Refrigerant
GWP, if other
than R134a

Total System
HFC Emission
Rate (g/year)

Total System
HFC Percent
Leakage
(%/year)

26

Production and In-use Standards
1037.104(b)
•

Each vehicle has an in-use CO2 standard that is calculated from the test results and
applies for selective enforcement audits and in-use testing.
– The in-use CO2 standards is equal to the deteriorated emission level * 1.10,
rounded to the nearest 0.1 g/mile
– For multi-fuel vehicles, must determine in-use CO2 standards for each fuel

•

The in-use N2O & CH4 standards are the FEL (no multiplier)

•

Unlike LD GHG IUVP program, manufacturers are not required to perform any GHG
measurements or specific tests for HD pickup trucks and vans

•

EPA In-use Surveillance Testing
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–

EPA may measure CO2, N2O, CH4 on 2014 and later in-use vehicles
• FTP and Highway cycles only
Any failures or unusual results would need to be addressed by the manufacturer
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CREDITS

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CO2 Credits
Sum of five independent calculations (calculated separately for each averaging set)
= total credits in a model year
1.

Averaging, Banking, and Trading
–

2.
3.
4.
5.

1037.150(m) – loose engines certified under this provision cannot generate credits

Early Credits – 1037.150(a)
Innovative Technology Credits – 1037.104(d)(13)
Advanced Technology Credits – 1037.150(i)
CO2 credits to show compliance with CH4 and/or N2O standards –
1037.104(c)

Credits are always rounded to the nearest whole megagrams (Mg)

29

GHG Credit Programs
Early Credits – 1037.150
(a)(2):
•2013 MY only (except electric
vehicles)
•Entire fleet
• No multiplier

Advanced Technology Credits –
1037.150(i):
•Vehicles with Rankine cycle,
electric vehicles, fuel cell vehicles,
and hybrid powertrains
•Only a single certifier may
establish credits for an advanced
technology, no double counting
credits
•1.5x multiplier – 1037.150(i)

Innovative Technology Credits –
1037.104(d)(13):
•Vehicle or engine technology
which is not captured on test and
not in common use in 2010 MY for
heavy-duty pickups and vans
•Do not need justification for not
using the 5-cycle
•No multiplier

Restrictions:
•Credits stay in averaging set –
1037.740(a)
•5 year credit life - 1037.740(c)

Restrictions:
•Credits can go into any
averaging set, except only 60,000
Mg CO2 credits can come into a
service class from another service
class - 1037.740(b)
•5 year credit life – 1037.740(c)

Restrictions:
•Credits stay in averaging set –
1037.740(a)
•5 year credit life - 1037.740(c)

30

GHG Credit Programs (cont.)
CO2 Credits to Offset CH4 and/or N2O FEL – 1037.104(c):
• Calculate the CH4 and/or N2O emission credits needed using the
equation:
Emission credits needed (Mg) = (FEL – Standard) · (Volume) · (UL) ·
GWP · (10-6)
• where GWP of CH4 is 25 and GWP of N2O is 298 Mg

Restrictions:
• None

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REPORTING

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Compliance Information
• EPA is committed to both protecting CBI and to achieving
transparency in implementation of the GHG program
• EPA currently publishes:
• Compliance Report
• Certification data (certification testing summary)

• EPA does not consider emissions data to be CBI
• For GHG, EPA intends to publish as much non-CBI information for
each manufacturer after the end of the model year as possible
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Future Guidance

• EPA will issue guidance on future subjects
when and if necessary.
• Please use the index cards to submit questions

34

For More Information:
• A copy of this presentation will be available at
www.epa.gov/otaq/climate/regulations.htm
• See GHG rulemaking documents at
www.epa.gov/otaq/climate/regulations.htm
• See Federal Register at 76 FR 57106, September 15, 2011
• See Code of Federal Regulations, 40 CFR Part 1037 and Part 86
• Contact your EPA team member
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