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U.S. National Fuel Economy Policy Addresses Increased Vehicle Fuel Economy, Reduction of Vehicle GHG Emissions

June 14, 2009 // Published as a news service by IHS

  
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The U.S. government issued a national fuel economy policy on May 19 that is designed to increase the fuel economy and reduce the greenhouse gas (GHG) emissions of all new cars and trucks sold in the U.S.

The policy includes proposed fuel standards that will cover vehicle model years 2012-2016, achieving an average fuel economy of 35.5 miles per gallon (mpg) for model year 2016, according to the U.S. Department of Energy (DOE) Office of Energy Efficiency and Renewable Energy (EERE) Vehicle Technologies Program.

The policy is intended to exceed the requirements of the Energy Independence and Security Act of 2007, which required an average fuel economy of 35 mpg by model year 2020, according to the DOE EERE Vehicle Technologies Program.

The standards are also designed to reduce carbon dioxide (CO2) emissions from new vehicles 30% by 2016.

Over the lifetime of these new vehicles, experts estimate a savings of 1.8 billion barrels of oil, and the reduction of 900 million metric tons of CO2 emissions. Cars and light trucks cause 17% of the CO2 emissions in the U.S.

The policy represents collaboration among the U.S. Department of Transportation (DOT), the U.S. Environmental Protection Agency (EPA), 10 auto manufacturers, the United Auto Workers (UAW), leaders in the environmental community, California and other state governments, experts said.

Because the policy combines fuel economy regulations with GHG regulations for vehicles, it addresses the EPA's need to set GHG regulations for vehicles while also addressing California's request to set its own GHG regulations, according to the DOE EERE Vehicle Technologies Program.

Thirteen other states and the District of Columbia planned to adopt California's GHG regulations. Meanwhile, 10 car companies and the UAW endorsed the national program because it "provides certainty and predictability to 2016 and includes flexibilities that will significantly reduce the cost of compliance," according to the DOE EERE Vehicle Technologies Program.

To implement the policy, the EPA and DOT intend to initiate a joint rulemaking for new vehicle standards.

The proposed standards are expected to be divided into categories of vehicles - based on the size of the vehicles - and they are expected to include measures to allow flexibility in meeting the standards, including credits earned for actions such as implementing advanced air conditioning technologies and using additional technologies that reduce CO2 emissions. Such credits would be tradable among the auto manufacturers.

Program Elements - Level of Standards
EPA and National Highway Traffic Safety Administration (NHTSA) intend to propose two separate sets of standards each under their respective statutory authorities, according to the May 22, 2009 Federal Register posting titled, "Notice of Upcoming Joint Rulemaking To Establish Vehicle GHG Emissions and CAFE Standards."

The EPA expects to propose a national CO2 vehicle emissions standard under section 202(a) of the Clean Air Act (CAA). The agency is considering proposing standards that would, if made final, achieve on average 250 grams/mile of CO2 in model year 2016.

The standards for earlier years would begin with the 2012 model year with a generally linear phase-in from model year 2012 through model year 2016. NHTSA expects to propose appropriate related Corporate Average Fuel Economy (CAFÉ) standards.

In developing the proposals under consideration, EPA and NHTSA preliminarily evaluated the kinds of technologies that could be used by the automobile industry, as well as the associated costs for the industry and fuel savings for the consumer, the magnitude of the GHG and energy consumption reductions that may be achieved and other factors relevant under their respective statutory authorities.

With respect to technological feasibility, during model years 2012-2016, manufacturers are expected to go through the normal automotive business cycle of redesigning and upgrading their light-duty vehicle products (and in some cases introducing entirely new vehicles not on the market today), according to the Federal Register posting.

The proposal under consideration is expected to allow manufacturers the time needed to incorporate technology to achieve GHG reductions and improve fuel economy during the vehicle redesign process.

This is an important aspect of the proposal under consideration as it is promoted as avoiding higher costs than would occur if manufacturers needed to add or change technology at times other than these scheduled redesigns, experts said.

This time period would also provide manufacturers the opportunity to plan for compliance using a multiyear timeframe, in accord with normal business practice.

Over these five model years there would be an opportunity for manufacturers to evaluate almost every one of their vehicle model platforms and add technology in a way to control GHG emissions and improve fuel economy. This includes redesign of the air conditioner systems in ways that are designed to reduce GHG emissions.

The CAA requires EPA to establish "standards applicable to the emission of any air pollutant from new motor vehicles or new motor vehicle engines which, in the administrator's judgment, cause or contribute to air pollution, which may reasonably be anticipated to endanger public health or welfare."

Section 202(a) of the CAA further provides that standards set pursuant to it "shall take effect after such period as the administrator finds necessary to permit the development and application of the requisite technology, giving appropriate consideration to the cost of compliance within such period."

The Energy Policy and Conservation Act (EPCA) requires that the CAFE standards for each model year be set at the maximum feasible level, experts said.

In determining that level, NHTSA must consider technological feasibility, economic practicability, the effect of other motor vehicle standards of the government on fuel economy and the need of the U.S. to conserve energy.

NHTSA is prohibited from considering the availability of compliance flexibilities, such as the ability to earn credits for exceeding CAFE standards in setting CAFE standards.

Further, NHTSA must set the model year 2011-2020 CAFE standards sufficiently high to ensure that the industry-wide average of all new passenger cars and light trucks, combined, is not less than 35 mpg by model year 2020.

Technical work conducted by each agency over the last several years indicates that there is a range of technologies available for manufacturers to consider in upgrading vehicles to reduce GHG emissions and improve fuel economy. These include:

  • Improvements to the engines, such as use of gasoline direct injection and downsized engines that use turbochargers to provide performance similar to that of larger engines.
  • The use of advanced transmissions.
  • Increased use of start-stop technology.
  • Improvements in tire performance.
  • Reductions in vehicle weight.
  • Increased use of hybrid and other advanced technologies.
  • The initial commercialization of electric vehicles and plug-in hybrids.
Although many of these technologies are available today, the emissions reductions and fuel economy improvements under consideration for the proposal would be expected to involve more widespread use of these technologies across the fleet.

The relationship between emissions of CO2 and fuel consumption means the technologies to control CO2 emissions and to improve fuel economy overlap to a great degree, experts said.

Initial evaluations by EPA and NHTSA indicate that use of this suite of technologies provides a technical basis to proceed with consideration of a proposal containing model year 2016 GHG standards that would on average achieve 250 gram/mile of CO2.

If the automotive industry were to achieve this CO2 level all through fuel economy improvements, this would equate to achieving a fleet average level of 35.5 mpg. However, it is expected that most companies would also apply some air conditioning improvements to reduce GHG emissions, experts said.

This would not translate into fuel economy improvements, so on average it is expected that the fuel economy improvements will be somewhat below the 35.5 mpg value. These mpg equivalents should not be considered levels of potential CAFE standards.

The proposal under consideration would also include a harmonized CAFE standard for model year 2016.

Compatible GHG and CAFE standards for earlier model years would increase from the model year 2011 CAFE standard to the model year 2016 level of the national program, according to the Federal Register posting.

In developing their respective proposals, EPA and NHTSA will consider many of the same issues. Given differences in their respective statutory authorities, however, the agencies anticipate there will be some differences in the development of their proposals.

For example, under a GHG standard proposed under CAA section 202(a), EPA would expect manufacturers to take advantage of the option to generate credits by reducing emissions of hydrofluorocarbons and CO2 through upgrades to their air conditioner systems. EPA plans to take these reductions into account in developing a proposed GHG standard.

However, EPCA does not permit NHTSA to consider air conditioning credits in developing a proposed CAFE standard for passenger cars. CO2 emissions caused by air conditioning operation are not measured by the test procedure mandated by statute for use in establishing and enforcing CAFE standards for passenger cars.

As a result, improvements in the efficiency of passenger car air conditioners would not be considered as a possible control technology for purposes of CAFE.

For more information, review the May 22, 2009 Federal Register posting titled, "Notice of Upcoming Joint Rulemaking To Establish Vehicle GHG Emissions and CAFE Standards."

Source: U.S. Department of Energy (DOE) Office of Energy Efficiency and Renewable Energy (EERE) Vehicle Technologies Program.


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