Ensuring the Real World Benefits of Mobile

Source Regulatory Programs

12 September 2012

International Environmentally Friendly Vehicle Conference

Byron Bunker

Director

Compliance Division

Office of Transportation and Air Quality

1

Outline

• Importance of Compliance

• You get what you measure

• EPA Light-Duty Compliance Programs

• EPA’s HD Not-to-Exceed (NTE) standards

• Continuing EPA efforts to control real world emissions

2

Why is compliance important?

Ensuring Our Environmental Goals

• In virtually every corner of the globe, emissions from transportation

and industrial engines contribute significantly to air quality problems.

– In the US, vehicle and industrial engines account for more than 50% of all NOx

emissions in the country

• Compliance with regulatory programs can reduce mobile source

emissions by more than 90% if implemented as intended.

• EPA estimates that the 1990 Clean Air Act Amendments will result

in the following environmental gains from 1990-2020

– 4.2 million lives saved

– Monitized health and welfare benefit to cost ratio of > 15:1

• US LD vehicle GHG and fuel economy program is projected to result

in:

– $1.7 trillion dollars of fuel savings over the lifetime of vehicles produced between

2011 and 2025

– 12 billion fewer barrels of oil consumed 3

Why is compliance important?

Ensuring A Level Playing Field

• The automotive and industrial engine sectors represent trillions of dollars in products

globally.

– about 9% of GDP in the US

• While technologies to control emissions represent only a small fraction of the total

cost of a vehicle, manufacturers can only introduce products into commerce after

meeting emissions regulations.

• Vehicle, engine, and fuels industries are global in nature and highly competitive.

• If a competitor evades an emissions regulations they will not only realize a cost

savings, but they will likely be able to offer product at a price point that gains sales

that should have gone to other parties in the market. The gain realized is not just the

cost savings – it is the incremental sales.

• Manufacturers expect regulatory agencies to implement and enforce their programs

in a way that ensures a fair and level playing field for all participants.

4

You get what you measure

• You are what you measure, John R. Hauser and Gerald M. Katz, Sloan School of Management, 1998

– http://web.mit.edu/~hauser/www/Papers/Hauser-Katz%20Measure%2004-98.pdf

– “Choosing the right metrics is critical to success, but the road to good metrics is fraught with pitfalls.”

• Product engineers are faced with a wide range of engineering tradeoffs and design metrics that

must be met.

– Cost targets, weight targets, performance targets, emissions stds, reliability targets, durability targets….

• Product engineers strive to satisfy each of the metrics as they are defined.

• Poorly designed metrics, will likely lead to subpar results against the actual intent of the metric

– An example: acceleration performance of a passenger car

– Typical in the US for that to be measured in time to go from 0 to 100 km/h (60 mph) with a target for a typical

sedan of perhaps 8 seconds

– Optimizing gear selection, shift points, engine calibrations, vehicle power to weight ratio ….. etc. to achieve

that target comes with significant tradeoffs in cost, weight, fuel economy, and potentially acceleration

performance in other speed ranges.

– In reality, most customers are concerned about launch feel (acceleration from stopped to 30 km/h) and

passing performance (acceleration from 100 km/h to 130 km/h).

– Optimizing for 0 to 100 km/h performance may be suboptimal for achieving what customers actually want

and may add unnecessary cost or remove weight that could have provided better comfort.

• As Hauser and Katz show, real world outcomes will be driven by the metrics

companies/organizations/managers use to make decisions.

5

Ensuring Real World Performance

• Regulatory standards and test procedures define the metrics

manufacturers will use to design their products to meet our

environmental goals.

• Over the last 40 years, EPA has repeatedly changed or augmented

its test procedures and standards to address shortcomings

uncovered when evaluating the in-use performance of vehicles.

• Two key things a regulatory agency should do in order to ensure

environmental goals.

• First – continually evaluate its test procedures and metrics

• Second – ensure that manufacturers do not defeat or circumvent

regulations through elements of design or control

6

7

EPA’s Light-Duty Compliance Program

8

LD Vehicle Compliance

0 Miles 10,000

Miles

Low-mileage In-Use Verification Testing

Performed by Manufacturer

120,000 Miles (End of Useful Life)

50,000

Miles

High-Mileage In-Use Verification

Testing Performed by

Manufacturer

EPA In-Use Surveillance Testing

90,000

Miles

EPA Action

Manufacturer Action

20,000

Miles

Vehicle Design

and Build

Warranty Tracking and Emission Warranty

Reports (EWIRs) to CARB

Emission Defect Information and Voluntary

Emission Recall Reports (EDIRs/VERRs) to EPA

(introduction into commerce – useful life miles)

EPA Follow-Up (Defect and Recall Reports, Mfr. In-Use Testing,

EPA Testing)

EPA Test Data Review/Analysis

CARB Coordination (Warranty Reporting)

OECA Coordination (Enforcement)

EPA

Certification

Preview

EPA Confirmatory

Testing (Random and

Targeted)

EPA Review of Manufacturer

Application

EPA Issues Certificate of

Conformity

Manufacturer Emissions Vehicle Prototype and

Durability Testing

End of Useful Life (per CAA) Vehicle May Enter Commerce

Examples of Supplemental

LD Test Cycles

• Supplemental Federal Test Procedure

– US06 - 2000 MY • High speed (80 mph) and load test (accel 8.5 mph/s)

– SC03 - 2000 MY • Hot Ambient (95 F) with solar loading and A/C

• Cold Testing 20F (-7C) – 1994 MY

– Tests for CO at low ambient temperature

– NMHC added in 2010 MY

– Vehicle may not exceed 20F emissions between 25F and 68F

9

Impacts of Supplemental

LD Tests

• US06 – Less enrichment for exhaust emissions protection

• Less CO and NMOG near highway

– Real world FE label impact at higher speeds

– Check for lean operation at highway speeds • Less Nox

• SC03 – Check for unique operating modes in real world

• Examples include rich operation w/ AC active

– Real world FE label incentive during A/C operation

• Cold CO test – Establishes endpoint for linearity checks

– Check for emissions warm-up strategy • Reduced CO and NMHC

– Prior to 7F test, cold emissions not monitored

10

LD Compliance Statements & Results

• Compliance Statements – In-use vehicle should operate off-cycle as the test vehicle

operates on-cycle • Lean on Cruise

• Altitude

• Leak Free Exhaust

• Defeat device free

• Cold linearity

• EPA may and have investigated statements or required additional data to support statements of compliance

• All Certificates are conditional (incl. upon statements) – False statements could/have lead to certificates being denied,

suspended, or revoked

11

Manufacturer Run In-Use Verification

Program (IUVP)

• Manufacturers must procure and test in-use vehicles – One year old low mileage (10K miles)

– Four year old high mileage (50K miles) • One vehicle per test group must have 75% of useful life

• One vehicle per test group at high altitude

• Vehicles are screened for proper maintenance

• Vehicle tests run are: – FTP, US06, +(Highway in 2012MY)

– 2-Day Evap, ORVR, OBD status

Number of Vehicles Tested Based on Test Group Size

Sales Per

Test Group

1-5000

(Small Vol.)

5,001-14,999

(Small Vol.) 1-50,000 50,000-250,000 Over 250,000

Low Mileage (>10k) Voluntary 0 2 3 4

High Mileage (>50k) Voluntary 2 4 5 6

Evap & ORVR Voluntary 1 vehicle per evaporative/refueling family

12

History of IUVP Testing

• Low Mileage Data: MY2004 - MY2009

• High Mileage Data: MY2000 - MY2005

13

Low

Mileage

High

Mileage

All

Vehicles

Veh per

Year

Total

Vehicles

Veh per

Year

Total

Vehicles Total

FTP 657 3,569 1,021 6,430 9,999

US06 576 3,137 764 2,144 5,281

Evap 147 807 108 698 1,505

ORVR 144 798 90 582 1,380

14

Historic IUVP Failure Rates

FTP US06 Evap ORVR High Alt

Low

Mileage 4.1% 0.70% 3.2% 4.4%

High

Mileage 4.2% 1.5% 3.7% 6.2%

75% of

Useful

Life

6.5% 1.7% N/A N/A N/A

Total

4.2% 1.1% 3.5% 5.1% 3.7%

What do we do with IUVP

results?

• In-Use Confirmatory Program (IUCP) – IUCP triggered if avg results for test group exceed 1.30 times std

and 50% of vehicles fail same pollutant

– Vehicles subject to Mfr-conducted recall-quality in-use testing which can be basis for recall

• Failing IUVP Tests – Manufacturers must notify EPA within 72 hours of any failing

tests • Submit failed test report

– We review each failure and enter it into a unique IUVP failure database

– Focus on failures that should trigger IUCP, that are close to IUCP thresholds, or are major failures

• Contact mfr when appropriate

• Test similar vehicles in our in-use surveillance program

15

EPA Surveillance Testing

• EPA conducts exhaust and evaporative

testing of in-use vehicles

• Vehicles selected using:

– IUVP

– Defect reporting

– Confirmatory test data

– Staff experience

• Failures could lead to IUCP or recall action 16

17

EPA’s HD Not-to-Exceed (NTE) standards

Heavy-Duty Engine Not-to-Exceed

NTE Standards

• In late 1990s, it came to light that HD engine manufacturers were using advance on cruise strategies to improve fuel economy and reduce oil soot loading at the expense of increased NOx emissions.

• Given the difficulty in determining when modifications to emissions strategies under cruise conditions were or were not appropriate, EPA developed a new test procedure and standard, the NTE.

• NTE standard is determined by multiplying certification standard by a fixed value (e.g., 1.5)

• Compliance is measured over a 30-second-or-greater period in the NTE “zone”

• In evaluating in-use performance, we look at a “pass ratio”, the ratio of the total time during the road test in which the pollutant level in the “events” is below the standard, and the duration of all valid NTE “events” during the test.

0

100

200

300

400

500

0 500 1000 1500 2000 2500 3000 3500

To

rqu

e (

lb-f

t)

Engine RPM

NTE zone

map data

30% torque

30% max HP

15% ESCspeed

30% max.

HP

30% torque

15% ESC

speed

NTE zone (Bounded by max torque,

30% torque, 30% power,

and 15% ESC speed)

2010 Observations – NTE Performance

• Vehicles have had no issues

meeting NTE requirements when

tested according to §86, subpart T

• Compliant with emission

standard (0.20 g/bhp-hr) in most

operating conditions

•NTE performance on highway

routes was similar to urban driving

•However, urban driving led

to far fewer NTE events

(transient effect)

20

Averages of 5 to 6 days of testing (2 vehicles

per manufacturer). Pass ratio error bars are the

limits witnessed during testing. NOx error bars

represent one standard deviation.

--Deliberative Material--

21

Total NOx emissions (g/bhp-hr)

A B C

Test Route Truck 1 Truck 2 Truck 1 Truck 2 Truck 1 Truck 2

1 0.36 0.32 0.16 0.16 0.10 0.11

2 0.32 0.31 0.24 0.08 0.09 0.07

3 0.43 0.35 0.24 0.20 0.10 0.14

4 0.64 0.35 0.16 0.15 0.08 0.15

4-No trailer 0.24 0.28

5 0.41 0.36 0.12 0.20 0.09 0.11

Urban 0.10 0.13 0.16 0.33

•Total emissions

•Sum of all NOx emissions

throughout the test day

•Normalized by total work

•Includes driving and idling

conditions

•Not for compliance, but

good comparison tool

•Higher NOx emissions noted for

vehicle A are related to extended

idle operation

Total NOx emissions for each testing day.

Quantifying Non-NTE Emissions

--Deliberative Material--

Vehicle

Result

Number

of

Vehicles

Range in “Pass Ratio” by Pollutant

HC NOx HC+NOx CO

Pass

24 100% 93 –

100% - 100%

41 - - 93 –

100% 100%

Fail

1 - 87% - -

6 - - 0- 82% -

Analysis of Pass Ratios from Manufacturer

Run In-Use Test Program (2009)

22

23

Continuing EPA efforts to control

real world emissions

Continuing EPA efforts to control

real world emissions

• Evaluating vehicle coast down procedures

– We are meeting with OEMs and testing vehicles to confirm that across the industry the road load estimates provided to the agency are accurate and consistent.

• Developing new test metric to evaluate drive trace quality – Currently use SAEJ2951 as information only

– Could lead to confirmatory test decisions

• Diesel Emissions Fluid (DEF) field surveys

24

Driver Trace Variation Example

0

5

10

15

20

25

30

35

40

45

1 201 401 601 801 1001 1201 1401 1601 1801 2001

Time (0.1 seconds)

Sp

eed

(M

PH

)

Trace

EPA Vehicle Speed

MFR Vehicle Speed

Muted response to

micro-transients

EPA and

Target Trace

Data indicates lower manufacturer

acceleration rate sustained for a

shorter period of time.

MFR

25

Driver Trace Variation Example

• Example (continued)

Vehicle Speed Data Average Power Requirement Difference Compared to Target

Target trace speed 6.313 HP NA

Manufacturer test speed 5.752 HP -8.89%

EPA test speed 6.292 HP -0.32%

• For this vehicle, the manufacturer offset in fuel economy was

approximately 8%, comparable in magnitude to the – 8.6% difference in

estimated power demand between the manufacturer and EPA

• In addition to confirmatory testing, a similar effect was observed in a

recent correlation program; statistics indicated up to 90% of observed

variation in fuel economy could be attributed to variation in power

demanded from the vehicle

26

Conclusions

• Regulatory agencies should work with industry and other

interested parties to develop test procedures and

standards (design metrics) that will lead to vehicle

designs which achieve environmental goals.

• Developing and overseeing compliance with these

procedures is an ongoing challenge.

• The substantial health and welfare benefits of

environmental programs and the significant level playing

consequences of noncompliance make the investment in

oversight more than worthwhile.

27