Southwest Research Institute® San Antonio, Texas

GHG Emissions – A Canadian Perspective

Issues With the Introduction of EPA

GHG Regulations

Outline

• How do the US and Canadian truck markets vary? –  Applications & vehicle specifications –  Climate conditions

•  How do these differences affect GHG regulations? –  Would adoption of the US GHG regulations

introduce market distortions or operational problems in Canada?

•  Conclusions 2

HD Vehicle Applications

•  The US and Canadian markets have essentially the same range of truck applications –  Long haul with 53’ box van trailers, flat beds,

tankers, bulk haulers, etc. –  LCVs and heavy haulers –  Mining, logging, and oil field service –  Regional and short haul (mostly LTL) –  Urban applications

§  Garbage trucks, dump trucks, cement mixers, busses, local delivery

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HD Vehicle Applications

•  The difference is in relative market shares •  Canada has a higher share of:

–  LCVs and heavy haulers §  This is a good thing from a GHG perspective, although

the current GHG regulation does not consider this, and may actually inhibit use of LCVs & heavy haulers because of limits on the number of vocational tractors

§  53’ doubles reduce CO2 by 25% plus compared to 53’ singles on a ton- or cube-mile basis

§  A good approach for additional GHG reduction would be to expand the scope for LCV and heavy hauler applications. Provincial and US state limitations vary widely and are an impediment to CO2 reduction

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HD Vehicle Applications

• Canada also has a higher share of: –  On/off road applications such as logging,

mining, and oil field service §  These demand high traction capability and

rugged construction, and are thus classified as “vocational” tractors

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Turnpike Doubles

Operating Climate

•  Canada enjoys lots of ice, snow, and cold weather operation –  Dealing with ice and snow buildup is crucial to

achieving reliability / durability –  Traction on snow and ice is important –  Air conditioning is less important than in the

US, but is still often installed

•  The US has a wide range of climate –  The northern US is not that different from

Canada 6

What Is Regulated?

•  What is a combination tractor? –  Primary purpose is to pull

trailers with a 5th wheel –  Exceptions will be described later

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What Is Regulated?

•  For combination tractors: –  Engine CO2, including credit for alt fuels –  Vehicle efficiency, based on a combination of

§  Vehicle aerodynamics §  Tire rolling resistance §  Weight reduction features (optional, but there is an

assumed adoption rate) §  Idle reduction features (optional, but the regulations

anticipate 100% adoption in tractors with sleepers) §  Road speed governor (optional) §  Credits can be generated by using innovative fuel

saving features not contemplated in the regulation 8

What Is Regulated?

•  EPA definition of “vocational” –  All straight trucks

§  Anything not pulling a trailer using a 5th wheel §  Pulling a trailer with a pintle hook is still

vocational

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What Is Regulated?

•  For vocational trucks, regulations cover –  Engine efficiency –  Vehicle efficiency, based only on:

§  Tire rolling resistance §  Available credits for hybrid vehicles and

“innovative technologies”

• Certain tractors can be classified as vocational trucks

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Which Tractors are Vocational?

•  “Vocational tractors” have a 5th wheel, but are –  Low roof urban P&D, –  ≥ 120,000 pounds GCWR (heavy hauler), or –  Designed for off-road or mixed

service operation

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Limitations on Vocational Tractors

•  EPA limits the volume of vocational tractors to 21,000 in any consecutive 3 model year period (for each OEM) –  Effective limit of 7,000 per year per OEM, based

on a running 3 year average –  Includes tractors classified as “vocational” and

as “off road” –  OEMs can decide how to classify tractors,

subject to EPA review §  Must apply the vocational provision in good faith

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Which Trucks Are Exempt from the Tire Rolling Resistance Requirement?

•  Off-road and “low speed” vehicles –  Intended primarily for off-road use, such as

forestry, oil field, and construction site trucks –  Criteria:

§  Tires with a maximum speed rating of ≤ 55 MPH, or §  Has components attached which are designed to work

in an off-road environment or designed to operate at low speed so it is unsuitable for highway operation, and one of the following: o  A gross axle rating (GAWR) of 29,000 pounds or more o  Capable of ≤ 33 MPH in 2 miles o  Capable of ≤ 45 MPH in 2 miles, and has an unloaded weight ≥

95% of GVWR 13

Which Trucks Are “Designed for Off-Road Use”?

•  “Off-road” is further defined by: –  High ground clearance –  Reinforced frame

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Effects of Climate

•  The primary issues are: –  Durability / effectiveness of aerodynamic

features in ice and snow –  Performance of low rolling resistance tires on

ice and snow –  Idle reduction features (sleeper cabs only)

•  The EPA standards take these issues into account, since the northern US has a similar situation –  Done by weighting of penetration rates for

specific technologies, and choice of goals 15

Effects of Climate

•  EPA assumes: –  100% penetration of idle shutdown for

sleeper tractors –  High penetration

of tractor aerodynamic features with low ground clearance §  Bumpers §  Side skirts

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Effects of Climate

•  Manufacturers are working to improve aero feature durability in snow and ice –  Fuel saving benefit can be reduced and even go

negative with snow and ice buildup

•  EPA and EC believe there are low Crr tires with adequate traction performance for most on-road applications – industry is not sure

•  These issues should be watched in case problems arise, but they should not be show stoppers 17

Effects of Climate

•  Idle reduction is an issue in Canada –  EPA requirement is 5 minute shutdown, which

assumes an APU or other means of handling hotel load

–  In the US, this covers heat and A/C needs –  In Canada, fuel fired cab heaters are cost

effective, but an APU to provide A/C is often not, because of the short A/C season & limited use

–  Canada needs a provision to allow pro-rating of idle shutdown §  EPA is working on this. A “technical revision” is

expected soon 18

Idle Reduction Pro-Rating

•  EPA plans to add pro-rating to the rule: –  Based on allowable idle hours per calendar year –  The pro-rate percentage is:

§  100 – 100 X (Allowed idle hours / 1800) §  Assumes an idle reduction of 1800 hours = 100%

–  Note: EPA still assumes 100% idle reduction adoption in sleeper tractors §  OEMs must add other technology to compensate for

pro-rated idle reduction §  High use of pro-rating in Canada has the effect of

making the rest of the regulation more stringent

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Effects of Application Market Share

• Canada has more LCVs and heavy haulers

• Canada has more on/off road applications

•  This could cause significant issues, because…

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Effects of Application Market Share

• Canada plans to use the EPA assumptions for vocational tractor market share –  This would limit importers to 2,100

vocational tractors in any consecutive 3 model year period §  The limit of 2,100 includes off-road tractors §  One OEM told me that they sell nearly 2,100

vocational tractors in Canada per year

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Effects of Application Market Share

•  Effect of using EPA assumptions for vocational tractor market share: –  This may force OEMs to list vocational

tractors as standard combination tractors in Canada, adding features that won’t provide a real-world benefit §  Issues with aero features that rarely see high

speed, plus ice/snow accumulation and ground clearance problems

§  Poor cost/benefit, “road kill” issues

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Effects of Application Market Share

•  Vocational tractors represent a higher percentage of the tractor total in Canada –  A survey to understand the actual market is

needed –  The regulation should be modified in this one

feature to match the Canadian situation, as necessary

–  Averaging over the North American market is another option, but §  This would have the effect of making the US regulation

more stringent unless the overall cap takes Canadian vocational volumes into account

§  The EPA is not interested in this approach 23

Fleet Baseline CO2

•  The Canadian fleet is likely to have a different baseline CO2 level from the US –  Different average payload –  Different operating conditions (speeds, road

types, grades) –  Increased use of LCVs and heavy haulers –  Different current penetration of existing fuel

saving technologies §  Aero features, low Crr tires, etc.

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Fleet Baseline CO2

• Carrying the US baseline into the Canadian regulation is risky –  This may make the Canadian standard more

or less stringent in its effect than the US standard

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Implementation Issues

• Canada plans to apply the regulations to the importer –  In the case of vocational trucks, the importer

may be a dealer or body builder

• Canada plans to implement the same timing as EPA –  Some 2013 model trucks being used to create

EPA GHG credits are already in production –  Very little time to sort out any issues

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Conclusions

•  Introduction of harmonized GHG standards in Canada is in general a good idea, but –  There are some issues that need to be

considered

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Conclusions

1.  There may be some applications where aerodynamic features run into problems with ice / snow buildup

a)  Fuel saving performance deteriorates with ice and snow buildup, so benefits in Canada will be lower than those projected for the US

b)   There may be some “road kill” issues c)  These problems will also occur in the US, but

they will be more prevalent in Canada

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Conclusions

2.  There may be a few applications where low rolling resistance tires could provide inadequate traction

a)  This could also be a problem in the northern US, but in the US it will be much easier to handle it via credit averaging

i.  Based on climate conditions and the composition of the US fleet

b)   Canada is likely to have a more difficult situation

i.  Canada lacks the range of climates that would allow OEMs flexibility with tire rolling resistance

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Conclusions

3.  The share of vocational tractors in Canada is higher than in the US

a)  Possible allowance for more than 2,100 vocational and off-road tractors in any 3 consecutive model years

b)   Possible overall North American market vocational allowance is unlikely to get EPA acceptance

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Conclusions

4.  Need to allow idle reduction pro-rating, to fit widespread use of fuel-fired cab heaters

–  Recognize that this has the effect of making the overall regulation more stringent

5.  The Canadian baseline CO2 level is probably not the same as in the US

6.  There are some implementation issues to consider, such as timing

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Not Every Good Idea is Practical

Southwest Research Institute®

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