Proposed Heavy-Duty Vehicle (HDV) Warranty Period Amendments

Public Workshop at

South Coast Air Quality Management District 21865 Copley Drive

Diamond Bar, CA, 91765

July 12, 2017

California Air Resources Board

Webcast Information

• During the workshop, please submit any questions and comments to the following email address:

hdwarrantyworkshop@arb.ca.gov (all one word, lowercase, no spaces, no numerals)

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Outline • Current Warranty Requirements • Need for Longer Warranty

— Reduced Emissions — Better Durability — Early Adoption is Important

• Feasibility of Longer Warranty • Proposal to Amend the Regulations

— Applicability — Two-Step Process — Modified Language

• Board Hearing Information • Contact Information

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Current Warranty Requirements

Heavy-Duty Compression-Ignition Vehicles 4

Title 13, CCR, §§ 2036(c)(4) and (8)

• Current Warranty Periods: —For compression-ignition heavy-duty vehicles

and engines, a period of use of five years, 100,000 miles, or 3,000 hours of operation, whichever first occurs.

—For Otto-cycle heavy-duty vehicles and engines, a period of use of five years or 50,000 miles, whichever first occurs.

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HEAVY-DUTY CATEGORY CURRENT

WARRANTY (miles)

CURRENT USEFUL-LIFE

(miles)

DIESEL OTTO-CYCLE DIESEL OTTO-CYCLE

Class 8 Heavy-Heavy

GVWR > 33,000 lbs. 100,000

5 years/3,000 hours 50,000

5 years

435,000 10 years/

22,000 hours

110,000 10 years

Class 6-7 Medium-Heavy

19,500 lbs. < GVWR ≤ 33,000 lbs. 100,000

5 years/3,000 hours

50,000 5 years

185,000 10 years

110,000 10 years

Class 4-5 Light-Heavy

14,000 lbs. < GVWR ≤ 19,500 lbs. 100,000

5 years/3,000 hours 50,000

5 years 110,000

10 years 110,000

10 years

Current HDV Warranty & Useful-Life

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The Need for Longer Warranty

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• Reduced Emissions

• Better Durability

• Early Adoption is Important

• NOx benefits in 2031 from current program — Mobile source emissions reduced

over 50 percent — Heavy-duty vehicle emissions

reduced by nearly 70 percent • Heavy-duty trucks and federal

sources remain largest contributors

• Heavy-duty trucks emit 33% of statewide NOx

• Need to further reduce heavy-duty NOx by 90 percent

South Coast - Emissions Inventory

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The Benefits of Longer Warranty • More timely repair of malfunctioning emission-related

components that HDV owners would not otherwise fix if they had to pay out-of-pocket;

• Better maintenance and less tampering;

• More HDVs remaining at or below applicable emission standards longer in-use;

• Longer warranty period for HDVs may encourage manufacturers to develop more durable components;

• Lower NOx emissions – 2.1 tons per day reduction Statewide in 2030

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Better Durability Needed • High Warranty Reporting Claim Rates for Recent MY HDVs

— Greater than 100% failure rates are being reported within the warranty periods for turbochargers

— Other reported failures remain high at up to 40% for DPFs, injectors, and EGR related components

• CARB’s New HD In-use Compliance Program — 12 out of 18 HDVs failed NTE testing outside warranty, but within

useful-life — High NTE events as high as 4.5 g/bhp-hr

• CARB’s Truck and Bus In-Use Surveillance Program — 2 out of 3 HDVs observed had NOx emission levels above their

applicable NOx emission certification standards — Some levels multiple times the NOx standard (some >2.0 g/bhp-hr)

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Early Adoption is Important • Heavy-duty trucks are already “required” to remain

durable throughout the engine’s useful life, but this is not happening

• Longer warranty periods will protect truck owners from “unfair” repair costs when faced with expected stricter PSIP and HD I/M requirements

• Lengthening warranty now does not impede future standards, but is needed to ensure that current standards are being met throughout useful-life

• Long-term emission reductions will be greater the sooner that warranty is amended

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PSIP and HD I/M Programs • Beginning in 2019, HDV owners will need to meet

Periodic Smoke Inspection Program (PSIP) lower opacity limits – 5% for filter equipped trucks – Keeps DPFs in working order – DPF problems often caused by upstream engine problems

• Beginning in 2022, HD truck owners may need to comply with a more comprehensive Heavy-Duty Inspection and Maintenance Program (HD I/M) – Repair any fault that lights the malfunction indicator light (MIL)

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The Feasibility of Longer Warranty

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Warranty vs. Real-World Longevity

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• The real-world operational longevity of HDVs is far greater than the currently required warranty and useful-life periods based on industry established B10 and B50 statistics

Feasibility Considerations • Input from HDV Manufacturers

— Virtually all Class 8 Trucks are warranted to 250,000 miles — Many new HDVs are warranted to 500,000 miles

• U.S. EPA Warranty Regulations — Do not include 3,000 hour limit

• Input from MECA — DPFs and SCR are designed for 1,000,000 mile operation

• HDV Warranty Survey – CSUS/ISR Sacramento — 64% of truck owners are dissatisfied with 100k warranty — 40% of new HDVs are already warranted to useful-life — Average out-of-pocket repair cost is over $4,000 per claim

• Input from 3rd-Party Warranty Providers — Extended warranties already being offered to 1,000,000 miles

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3,000-Hour Warranty Limit • Currently applicable only to California-certified HDVs • Mostly benefits vocational HDVs that travel less than

15,000-20,000 miles per year • Manufacturers have been certifying HDVs federally

without the 3,000-hour limit for many years • Operating conditions in California are no more

severe than in other states • Vocational vehicle warranties outside California are

usually decided by the 5-Year warranty limit, which will continue to remain in effect

• Difficult to justify keeping this limit only for California

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CARB Warranty Survey • The Sacramento Institute for Social Research (ISR) was

contracted to conduct a survey of heavy-duty truck owners and operators

• The purpose of the survey was to better understand the cost structure and administration of base, corporate, and extended warranties currently being offered for HDVs

• Approximately 500 truck owners and 100 dealer/repair facilities participated in the survey

• The survey data are still under review at this time, but a final report will be available in the near future

• The data will be used for cost analyses and the calculation of emission benefits with respect to this rulemaking. 17

Proposed Amendments to the Regulations

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• Applicability

• Two-Step Process

• Modified Language

Applicability • New Model-Year HDVs

— Warranty periods for in-use HDVs will not be modified

• California Certified HDVs — Does not include federally certified vehicles operating in California

• Compression-Ignition and Spark-Ignition HDVs • Classes 4 - 8 HDVs (> 14,000 GVWR) • 2022 and Subsequent Model Year HDVs • Criteria Pollutant Standards Only

— Warranty periods for GHG Standards will not be modified

• No Modification to EWIR requirements at this time — Clarification of existing language and grammar may occur

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Two-Step Process • “Step 1” to be adopted in 2017 and implemented in 2022

— Lengthen warranty periods for HDVs equal to useful-life

— Retain 5-year warranty period limit

— Eliminate the 3,000 hour warranty period limit

— Estimated NOx reduction of ≈ 2.1 tons-per-day in 2030

• “Step 2” to be adopted in 2019 and implemented in 2024 — Establish appropriate useful-life periods for HDVs certified to

future standards and duty-cycles

— Lengthen warranty periods to appropriate fractions of useful-life

— Costs and emission benefits to be determined

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Title 13, CCR, §§ 2036(c)(4) and (8) Modified Language

• Proposed Warranty Periods: —For compression-ignition heavy-duty vehicles and

engines, the first occurring of either a period of five years, or

110,000 miles for heavy-duty vehicles 14,000 lbs. < GVWR ≤ 19,500 lbs.;

185,000 miles for heavy-duty vehicles 19,500 lbs. < GVWR ≤ 33,000 lbs.;

435,000 miles for heavy-duty vehicles GVWR > 33,000 lbs.

—For Otto-cycle heavy-duty vehicles and engines, the first occurring of either a period of five years, or 110,000 miles for heavy-duty vehicles with GVWR > 14,000 lbs.

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Board Hearing Information

Date: December 14-15, 2017

Time: TBD

Location: Cal-EPA Headquarters Building

Byron Sher Auditorium

Sacramento, CA 95814

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California Air Resources Board

Questions for Stakeholders • Is any additional outreach recommended? How to

reach independent heavy-duty repair shops? • How should turbocharger durability be addressed? • Alternative proposals?

ARB Contact Information • Jeff Lowry, Staff Air Pollution Specialist

Off-Road Control Section email: Jeffrey.Lowry@arb.ca.gov phone: (626) 575-6841

• Ronald Haste, Manager Off-Road Control Section email: Ron.Haste@arb.ca.gov phone: (626) 575-6676

• Kim Heroy-Rogalski, Branch Chief Mobile Source Regulatory Development Branch email: Kim.Heroy-Rogalski@arb.ca.gov phone: (916) 327-2200

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