Costly testing requirements, mandated technologies, and the lack of a “system-level” approach to configuring tractor-trailers than can meet the new Phase 2 greenhouse gas (GHG) rules rolled out back in June will drive up costs and hamper successful implementation of the new regulations, argued Amy Kopin, regulatory compliance program manager for Daimler Trucks North America (DTNA), during a presentation this week the annual FTR Transportation Conference in Indianapolis.
According to DTNA’s projections, the proposed Phase 2 GHG rules as they stand today can upwards of $8,000 to $12,000 in extra costs to a tractor-trailer. That’s in addition to the estimated $6,000 already added as a result of the Phase 1 rules, Kopin noted.
“Also, as the rules stand today, the compliance margins are very tight,” she noted. “Phase 2 also includes new and more costly test procedures as well, which makes them that much more overly burdensome.”
Kopin also pointed out that both Phase 1 and 2 of the GHG rules establish separate carbon dioxide (CO2) reduction standards for the powertrain and the vehicle. DTNA would rather engage a “single vehicle systems standard” so OEMs could better optimize the entire tractor-trailer for real-world fuel efficiency, picking off most cost-effective technologies first.
“Regulation must accurately reflect real world fuel consumption reductions – and the only way to accurately reflect real-world fuel consumption is through a single, complete vehicle standard that Includes trailers,” she said.
DTNA compiled a list of several “high-level principles” to help simplify implementation of the new GHG rules as a whole while making them less costly to fleets in the process:
- Phase 2 must not force technology that doesn‘t reduce total cost of ownership for the first customer, achieving payback within 18 months, otherwise new technology won‘t be purchased and environmental benefits will be delayed.
- Phase 2 should be consistent with Phase 1 relative to current onboard diagnostic (OBD) requirements providing adequate protection for criteria and GHG emissions. This also prevents OBD from becoming a barrier to new GHG technologies entering the market.
- EPA [the Environmental Protection Agency], NHTSA [the National Highway Traffic Safety Administration] and CARB [the California Air Resources Board] must have one single program for GHG in the U.S. Should CARB request a waiver for the heavy truck portion of the GHG standards that are more stringent, it should be denied on the basis that such standards are not needed to meet compelling or extraordinary conditions.
- Make trade-offs between oxides of nitrogen (NOx) and CO2 reduction targets. Additional NOx stringency has negative impacts on GHG emissions and compromises the goal of fuel economy improvement.
- Complex diesel engine and vehicle technologies require long design cycles and so it is not feasible to work with EPA/CARB mandated three-year development periods.
At the end of the day, though, Kopin is unsure if the EPA and other government agencies involved in finalizing the Phase 2 GHG rules will consider such adjustments. “We believe these rules are actually twice as stringent as they should be,” she said.
