Proposed Heavy-Duty Vehicle (HDV) Warranty Period ... For Otto-cycle heavy-duty vehicles and...
Transcript of Proposed Heavy-Duty Vehicle (HDV) Warranty Period ... For Otto-cycle heavy-duty vehicles and...
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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
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Webcast Information
• During the workshop, please submit any questions and comments to the following email address:
[email protected] (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
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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
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• 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
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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
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Proposed Amendments to the Regulations
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• Applicability
• Two-Step Process
• Modified Language
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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
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Questions for Stakeholders • Is any additional outreach recommended? How to
reach independent heavy-duty repair shops? • How should turbocharger durability be addressed? • Alternative proposals?
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ARB Contact Information • Jeff Lowry, Staff Air Pollution Specialist
Off-Road Control Section email: [email protected] phone: (626) 575-6841
• Ronald Haste, Manager Off-Road Control Section email: [email protected] phone: (626) 575-6676
• Kim Heroy-Rogalski, Branch Chief Mobile Source Regulatory Development Branch email: [email protected] phone: (916) 327-2200
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