By Keith Reid
The 9th Integer Emissions Summit & DEF Forum USA, held October 25 – 27, 2016, provided its usual thorough overview of the diesel exhaust fluid (DEF) market, with content appropriate for interested parties ranging from emission equipment engineers to DEF marketers. Commercial Fuel Buyer staff concentrated on heavy-duty commercial vehicles to provide the most useful information for its readership.
The heavy-duty commercial vehicle coverage was fairly uniform in focus. The majority of presenters highlighted the outcome of the greenhouse gas (GHG) and fuel efficiency standards for heavy-duty trucks—finalized by the U.S. Environmental Protection Agency (EPA) and the Department of Transportation’s (DOT’s) National Highway Traffic Safety Administration (NHTSA)—as created through President Obama’s Climate Action Plan. Matt Spears, EPA’s Center Director, Heavy-Duty Diesel Standards, provided an overview of Phase 2 to attendees.
According to EPA, heavy-duty trucks are the second largest segment in the U.S. transportation sector and collectively make up the biggest increase in that sector in terms of emissions and energy use. These vehicles currently account for about 20% of GHG emissions and oil use in the U.S. transportation sector. Globally, GHG emissions from heavy-duty vehicles are growing rapidly and are expected to surpass emissions from passenger vehicles by 2030.
EPA noted, “NHTSA and EPA have worked together to harmonize their standards under this program. The agencies have worked closely with the state of California’s Air Resources Board (CARB) in developing and finalizing the standards. All three agencies are committed to the goal of setting harmonized national standards.
“Throughout every stage of development, this work has benefited from a collaborative dialogue with industry, labor and environmental organizations. For example, this feedback has improved the agencies’ ability to measure industry performance and enforce compliance for both full vehicle and engine standards.”
Phase 1 of the standards is already well into the implementation stage, and an equally aggressive Phase 2 was finalized on August 16, 2016. The regulation covers combination semi-tractors/trailers; vocational vehicles such as school buses, box vans and fire trucks; and large pickup trucks and vans.
The Phase 1 standards were extremely aggressive, yet turned out to be relatively simple to meet—at least by government regulatory standards. The Phase 1 implementation began in 2014 and will be fully completed by 2018. This represents a coordinated, national program where manufacturers produce a “single fleet” that complies with the standards.
These efforts were particularly effective since there was a heavy reliance on off-the-shelf technologies that did not require a significant amount of research and development. In fact, most of the success can be attributed to aerodynamic improvements, combined with the existing Selective Catalytic Reduction (SCR) technology that uses DEF.
Phase 1 is estimated to generate $50 billion in fuel savings, $49 billion in net benefits and a reduction of 270 million metric tons (MMT) of greenhouse gases.
The Phase 2 standards are set to begin implementation in 2018, and include EPA trailer standards and specific engine requirements. It is expected that Phase 2 standards will be fully implemented by model year 2027.
It’s useful to note up front that a great many of the Obama administration’s environmental initiatives are far less certain after the election of Donald Trump. His initial agency and cabinet picks represent a far less “rubber stamp” approach to the interests of the environmental Left. While the efficiency standards have not been noted specifically, he has expressed a commitment to roll back sweeping portions of Obama’s environmental initiatives and it would not be surprising to see some degree of impact to this program.
Trumps nomination of Oklahoma Attorney General Scott Pruitt to head the EPA is already being met with alarm thought the agency. Oklahoma is a primary energy producing state that has been in the cross hairs of much of the recent EPA policy, and Pruitt has led the legal push back against the agency. He will certainly be thoroughly familiar with the most controversial EPA policies.
The press release from Trump that announced Pruitt’s selection stated, “For too long, the Environmental Protection Agency has spent taxpayer dollars on an out-of-control anti-energy agenda that has destroyed millions of jobs, while also undermining our incredible farmers and many other businesses and industries at every turn.
“As my EPA Administrator, Scott Pruitt, the highly respected Attorney General from the state of Oklahoma, will reverse this trend and restore the EPA’s essential mission of keeping our air and our water clean and safe. My administration strongly believes in environmental protection, and Scott Pruitt will be a powerful advocate for that mission while promoting jobs, safety and opportunity.”
The environmental Left is not nearly as pleased. The New York Times, in a piece covering Pruitt’s selection, quoted Ken Cook, Co-Founder and President of the Environmental Working Group (EWG), a Washington, D.C. think tank. “It’s a safe assumption that Pruitt could be the most hostile EPA Administrator toward clean air and safe drinking water in history,” Cook said.
Of course, the response from the Right is far more supportive. American Petroleum Institute (API) President and CEO Jack Gerard stated, “Mr. Pruitt’s work as Oklahoma’s Attorney General shows that he understands how important America’s oil and natural gas industry is to our nation and to our economy. Under the [Obama] administration, our industry was facing a barrage of 145 regulations that would have unnecessarily destroyed jobs and added costs to consumers.
“Pruitt has a track record of dispelling the false idea that energy development and environmental stewardship cannot go hand in hand. Moving forward, we must have smart, common sense regulations that protect the environment and do not raise prices on Americans.”
Much will surely change as Pruitt’s position as Head of the EPA has been confirmed. The ability to go back and overturn regulation already in the Federal Register will be limited by date of passage, but such regulation can be modified. Given the state of Phase 1, it would be questionable to see significant review, but Phase 2 could most certainly be in the cross hairs depending upon the push from the various impacted parties.
Under Phase 2, fully implemented semi-tractors will see a combined carbon dioxide (CO2)/fuel consumption reduction of 25% (compared to a Phase 1 2018 vehicle). Trailers will see a reduction of 9%; vocational vehicles, 24%; and pickups and vans, 16%. A separate standard has been set to make sure these improvements include reductions related specifically to the engine. Semi-tractor engines are supposed to see a reduction of 5%, and vocational vehicle engines of 4%.
According to EPA, “The final standards are expected to lower CO2 emissions by approximately 1.1 billion metric tons, save vehicle owners fuel costs of about $170 billion and reduce oil consumption by up to 2 billion barrels over the lifetime of the vehicles sold under the program. Overall, the program will provide $230 billion in net benefits to society, including benefits to our climate and the public health of Americans. These benefits outweigh costs by about an 8-to-1 ratio.”
It is anticipated that this will increase the cost of a semi-tractor by $12,000, a trailer by $1,000, a vocational vehicle by approximately $2,700 and a pickup or van by approximately $1,300. EPA stated, “The final standards are cost-effective for consumers and businesses, delivering favorable payback periods for truck owners. The buyer of a new long-haul truck in 2027 would recoup the investment in fuel-efficient technology in less than two years through fuel savings.”
As with Phase 1, Phase 2 aims to provide vehicle and trailer manufacturers with a range of options to choose from to meet the final goal:
- The engine side, which is now mandatory, includes combustion, efficiency, after-treatment and waste heat recovery.
- For tractors, manufacturers can add aerodynamics, powertrain improvements, idle reduction and tire pressure systems.
- Vocational vehicles can have powertrain improvements, idle reduction, stop-start technology and neutral idle. Optional enhancements can include transmission efficiency, rear axle efficiency and overall powertrain testing.
The various speakers from the engine and vehicle manufacturers were cautiously optimistic about meeting the Phase 2 standards, though all admitted it would not be a painless process. As Dan Kieffer of PACCAR Inc. noted in his presentation, the following initial comments have been made relative to the “SuperTruck II” initiative, which aims to develop test beds for meeting the standards:
- Cummins, Inc. will design and develop a new, more efficient engine, along with advanced drivetrain and vehicle technologies.
- Daimler Trucks North America LLC will develop and demonstrate a tractor-trailer combination using a suite of technologies, including active aerodynamics, cylinder deactivation, hybridization and the electrification of accessories.
- Navistar, Inc. will design and develop a vehicle and powertrain with electrified engine components that can enable higher engine efficiency and a more aerodynamically reengineered cab.
- Volvo Technology of America LLC will develop and demonstrate a tractor-trailer combination with a lightweight cab, which achieves the freight efficiency goal using alternative engine designs and a variety of system technologies.
One enormous stumbling block, and indeed a key reason why Phase 2 had a high profile at a DEF conference, was the push by CARB to shoehorn in a national nitrogen oxides (NOx) standard of 0.02 grams per brake horsepower-hour (g/bhp-hr). William Robinson, CARB Vehicle Program Specialist, made his pitch for the need to include NOx.
CARB tends to be “the tail wagging the environmental dog,” particularly with administrations that have an aggressive environmental focus. In fact, as aggressive as the Phase 2 standards are, they still might not be enough for California’s statewide carbon reduction goals.
As has typically been the case recently, the finalized rule was more stringent than the proposed rule, particularly due to pressure from CARB. Areas where the final Phase 2 was more stringent than the proposed include:
- Achieving 10% more GHG and fuel consumption reductions
- Having more robust compliance provisions, including improved test procedures, enhanced enforcement audits and protection against defeat devices
- Including more rigid diesel engine standards
- Improving the vocational vehicle program with a regulatory structure better tailored to match the right technology for the job
- Maintaining the structure and incremental implementation of the proposed standards, allowing manufacturers to choose their own technology mix and giving them the lead time needed to ensure those technologies are reliable and durable
On the NOx front, California’s geography has long contributed to the state’s significant smog issues. CARB—with support from a handful of New England states—would like to see a national standard passed that would accommodate its specific, unique needs for ultra-low NOx. And, under the Obama administration or a potential Clinton administration, CARB would have likely seen little resistance.
As those pushing for immediate rulemaking noted in their petition to EPA, “Because the majority of heavy-duty trucks that operate in California are purchased out of state and may be operated as part of a nationwide fleet, substantial reductions in NOx emissions from this national fleet are required if Petitioner South Coast Air Quality Management District (SCAQMD) is to attain the ozone National Ambient Air Quality Standards (NAAQS).
“As a result, Petitioners assert that a nationwide standard would be far more effective than a California-only standard, with relative benefits increasing over time. The South Coast Basin must demonstrate attainment of the 0.75 parts per million (ppm) ozone NAAQS by 2031 (within the next 15 years).
“Thus, Petitioners believe commencement now of a rulemaking for a new on-highway heavy-duty engine NOx exhaust emissions standard is critical, especially given the time needed for such standards to be adopted, the lead time necessary for engine manufacturers to produce compliant engines and the time needed for the combination of new vehicle purchases and old vehicle scrappage to turn the fleet over to the lowest-emitting vehicles.”
Unfortunately, for technological reasons, it’s difficult (but not impossible) to have both fuel efficiency and carbon reduction on one side, and NOx reduction on the other using now-traditional engine technologies including SCR/DEF. This is generally the case with a cold system before it heats to operational temperatures.
Solutions to the problem could include some combination of new catalysts for SCR, new fluid formulations, combined catalyst approaches, pre-heating “burner” approaches, relocating the SCR system to the engine and after-treatment approaches. Some of the solutions outlined became fairly complex, leading to concerns over reliability and added costs.
Fortunately, EPA appears to have put the brakes on adding an immediate, aggressive NOx standard to the current Phase 2 requirements. That could conceivably be related to the incoming administration’s focus on business and jobs over environmentalism, or simply the fact that the issue is too complex to simply rush a requirement out the door.
As EPA stated in a December 20 announcement, “EPA has not recently performed a comprehensive assessment of the effectiveness and costs of new NOx emission control technology for heavy-duty engines and vehicles, but we are aware of work that has been published in the literature that speaks to the potential for additional NOx reductions that can be achieved as a result of technology developments that have occurred over the past decade.
“However, EPA also believes that, in order to achieve cost-effective real-world reductions, we must look beyond simply reducing the NOx standard over the test procedures and test cycles that we currently require. Therefore, it should not be presumed that EPA would eventually propose a NOx standard of 0.02 g/bhp-hr.”
The agency does see this as a worthy issue and promises to continue to research it. A potential implementation date for such a standard would be in the 2024 time frame.