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CAFE and GHG
Industry Perspectives on the Mid-term Evaluation, Off-cycle Credits and Autonomous Tech
Chris Nevers | Apri l 7, 2017
/autoalliance/auto_allianceAutoAlliance.org
Agenda
• CAFE/ GHG, the Basics
• Past Performance
• Current Fleet Performance
• Status of Midterm Evaluation
• Off-Cycle Process
• AV Off-Cycle Benefits/ Barriers
• Next Steps
One National Program
ARBAdvanced Clean Cars
GHG (GHG and Petroleum Use)
LEV III(Ozone, criteria Emissions)
ZEV(Ozone, GHG, Petroleum Use)
U.S. EPA
GHG(GHG, Petroleum Use)
Tier 3(Ozone, Criteria Emissions)
NHTSA
CAFE(Petroleum Use, GHG)
OneNationalProgram
50 Years of Progress, Criteria Emissions
0
2
4
6
8
10
12
Gra
ms/
Mile
(H
C +
No
x)
Year / Technology
HC NOx
99.7% Cleaner (ARB)
10.4
1994 → 2000 2004 → 2014
0.03
2015 → 2025
Source: California Code of Regulations
Alliance Members Committed to Improved Efficiency
• The Alliance supports reducing greenhouse gas (“GHG”) emissions associated with the operation of light-duty vehicles, but believes that reductions must be made in a manner that accounts for market realities.
• Automakers are committed to zero emission vehicle technology (electric) not just to meet regulatory requirments, but to meet global demands.
Industry R&D Spending
2015
High Mileage Vehicles201640+
MPG(Highway)
30+ MPG
(Highway)
Hybrid & Electric Models for Sale2016
Hybrid & Plug-in Electric
Source: https://autoalliance.org/
80Models
25 Models
60 Models
509 Models
$ 109Billion
Fuel Economy Progress
25
30
35
40
45
50
2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025
Fuel
Eco
no
my
[MP
G]
U.S. Fleet Fuel Economy
Source: NHTSA, Novation AnalyticsIncludes flexible fuel vehicle credits (phase-out starting 2015)
7
Even more progress is needed: 45% increase over the next nine years
LDV CAFE Compliance Trend
1.0 1.3 1.2
0.6
(0.7)
(1.2)
2012 2013 2014 2015 2016Projected
2017Projected
Industry Average Annual CAFE (Fuel Economy) Compliance Margin [miles per gallon, mpg]
Source: NHTSA
Trends observed for CAFE (fuel economy) compliance
• Between 2012 and 2014, manufacturers averaged 1.0 to 1.3 miles per gallon (mpg) better fuel economy than their standards.
• In 2015, this compliance margin dropped in half to 0.6 mpg.
• In 2016, manufacturers on average are expected to fail to meet the CAFE standards.
• In 2017, manufacturers are expected to fall even further behind.
ONP Process
Joint Draft TARJuly 18
Proposed Determination
Nov. 30
Comment Period Closed Dec. 30
Final Determination Issued Jan. 13
FD Reconsideration
March 22
Joint Draft TARJuly 18
NHTSA de novo NPRM
NHTSA Final Rule Before
April 2020
Joint Draft TARJuly 18
CARB Releases MTE Report
MTE/ZEV Hearing
Mar 23 Affirms Withdrawn FD
Workshops, Hearings, Waiver
Request
Alliance Perspective: Early Final Determination
10
Draft Technical Assessment Report (TAR)• Over 1,300 pages• Over 1 gigabytes of modeling data (compressed)• 60 days for stakeholders to review and comment
Proposed Determination• Issued just over two months after TAR comments• Nearly 1,000 pages• Over 1.5 gigabytes of additional modeling data• 30 days for review and comment
Final Determination• Issued only 13 days after Proposed
Determination comments• Concluded the EPA midterm evaluation process
over a year in advance of the requirement
EPA bypassed procedural requirements
EPA action conflicted with commitment to a single National Program
Multiple technical flaws remained in the analysis
Our Ask:Return to the process as originally envisioned and re-engage with the auto industry to understand and address its concerns
Off-Cycle Pathways
3 Pathways to obtain EPA and post 2017-MY NHTSA “Off-Cycle” credits
• Pre-defined Table Values
• 5- Cycle or “Five minus Two”
• Alternative Method
Off-cycle credits can only be requested by vehicle manufacturers
40 CFR 86.1869-12 CO2 credits for off-cycle CO2-reducing technologies
Off-Cycle Process
Predefined Table of Technologies
• Growing use by manufacturers
• Evidence that some technologies have greater benefit than first estimated
• EPA questioning manufacturer application of some technologies
• EPA resistant to expanding list
“5-Cycle” Test Method
• No known use (yet)
• Potential EPA concerns?
Alternative Method
• Strong interest from manufacturers and suppliers
• Suppliers excluded from process in the U.S.
• Efforts to harmonize with E.U. eco-innovation process are challenging
• Significant data requirements and long process following application
• Almost all applications approved thus far are for on-table technologies applied before 2014
• Only application with significant expansion of credit met with significant resistance
GHG/ FE AV Benefits
Source: https://autoalliance.org/
• Congestion mitigation due to
• Accident avoidance
• Route navigation
• Efficient traffic patterns, for example, traffic lights, speed optimization, closer following distance
• Panic braking reduced (sun, fog, merging, etc.)
• “Platooning” to decrease wind resistance
• Vehicle sharing can reduce costs of more expensive/ efficient vehicles
• When combined with ride sharing, could reduce vmt
• EV remote charging possible
AV Off-Cycle Credit Pathway/ Barriers
• Only the “Alternative Method” would be available for autonomy GHG credits
• Agency concerns with AV• AV technology could increase vehicle miles traveled due to “non-occupant” vmt, increase sprawl due to
better traffic flow, and increase vmt by providing transport to those that otherwise would not travel (elderly and young).
• Benefits would be difficult to quantify and could change based on penetration rate.• Gains could vary based on vehicle, driver demographics, and topography.
• If AV technology was to be a safety requirement, AV credits could be construed as a “give-away” regardless of real world GHG/ CAFE benefits.
• Barriers• An agency accepted baseline driving and traffic pattern (control case) is needed beyond the National
Household Transportation Survey (NHTS) data.
• Extensive data requirements may change based on model and age of vehicle.• Expect a multi-year approval process.
• Agencies do not have a “trail blazer” type of off-cycle approval process.
AV Off-Cycle Next Steps
• A National Dataset of driving behavior and conditions is needed. The National Labs are ideally suited to develop this.
• Modeling required to estimate real world GHG/ CAFE benefits based on penetration rates and level of automation.
• Convince agencies to accept manufacturer system data applied to “driving templates”.
• Work with vehicle manufacturers to get the off-cycle alternative method started.
• Comments count; comment on future Federal Register Notices.
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