Truck manufacturers, truck fleet owners and their trade groups greeted the Obama administration's new proposal on fuel emissions with some trepidation.
They support reduction of greenhouse gas (GHG) emissions and improvements in gas mileage, which save employers and owners money, as long as the payback for the new technology is not too onerous, and the standards are achievable for manufacturers.
But while the proposed joint rule from the Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) give manufacturers leeway as to what emissions and engine refinements to use to get to certain GHG/CAFE levels, there are doubts in some quarters about the accuracy of the agencies' evaluation of the readiness of some technologies.
The proposed rule issued in mid-June exceeds 1,300 pages, not counting about 4,000 additional pages in regulatory impact and environmental analysis.
Glen Kedzie, vice president, Energy and Environmental Counsel of the American Trucking Association, uses the example of waste heat recovery, which the EPA is depending on to some extent for its promise of reducing engine carbon emissions.
"That probably has the most question marks attached to it," explains Kedzie. Manufacturers who utilize that not-yet-ready-for-prime time technology may have to make changes to the configuration of the engine compartment; and the systems will certainly add weight to the truck.
The proposed rule does not address the potential of aftermarket technologies to improve emissions reductions and CAFE improvements. That’s because all the weight of meeting compliance deadlines for trucks fall on the truck manufacturers, not the fleets. Those deadlines in the proposal are 2021, 2024 and 2027. There are other deadlines for engines, and others for trailers.
But Kedzie and others think the EPA and the NHTSA should ease the carbon reduction and mileage improvement goals to account for aftermarket improvements a fleet makes on its own. He uses idle reduction devices as an example.
"How do we draw the bridge so manufacturers can get credit for those savings," he asks? "The EPA has market penetration rates for idle reduction, lightweight components and low-rolling resistance tires, which are the kinds of things truckers could add to their equipment, and for which the manufacturers should get some credit, which would ease their burden of meeting the standards.
"The agencies are open to listening to including counting aftermarket improvements if we can give them an approach they would be comfortable with including in the final rule," Kedzie said.
These would be the second round of truck standards. The Phase 1 program was announced in 2011 and covers new trucks and heavy vehicles in model years 2014 to 2018. These are heavy-duty pickup trucks and vans starting at a gross vehicle weight rating of 8500 pounds, which is class 2b and extending to Class 8. The Phase 2 standards would be phased in through 2027, with different categories – there are 10 – having different dates.
The EPA and NHTSA freely admit that the Phase 2 standards will push the envelope technologically. The proposed rule alludes to "technology-advancing" standards that would result in "an ambitious, yet achievable program." The standards would be based on "utilization of technologies now under development or not yet widely deployed."
For some of the more advanced technologies production prototype parts are not yet available, though they are in the research stage with some demonstrations in actual vehicles.
Truck and engine manufacturers, and users, will be dissecting the specifics on these technology assumptions at the public hearings, which have not been scheduled yet.
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