Overview of EPA's Light-duty Greenhouse Gas Rule and the Role of Vehicle Mass Reduction

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1 Overview of EPA's Light-duty Greenhouse Gas Rule and the Role of Vehicle Mass Reduction Michael Olechiw United States Environmental Protection Agency w w w. a u t o s t e e l. o r g

2 Topics Overview of EPA and NVFEL CAFE and GHG Emissions CO2 Emissions Stringency Footprint curve Technologies considered Mass Reduction Effectiveness, cost, and Methodologies Safety considerations Conclusion w w w. a u t o s t e e l. o r g

3 EPA s Office of Transportation and Air Quality OTAQ has authority under US Clean Air Act (1970) to regulate emissions from all mobile sources The Office of Transportation and Air Quality (OTAQ) is divided between EPA's headquarters in Washington, D.C., and the National Vehicle and Fuel Emissions Lab in Ann Arbor, Michigan Over 400 employees (177 engineers) The NVFEL is a world-class state of the art testing & research facility w w w. a u t o s t e e l. o r g

4 U.S. Vehicle Criteria Emissions History U.S. was regulatory pioneer in 1970s In Clean Air Act, Congress gave EPA technology forcing powers and California ability to set its own standards Since then successful and cost-effective mobile source regulations have come OTAQ OTAQ rules responsible for 57% of benefits derived from all major federal rules (Recent Office of Management and Budget analysis) Tier 0, 1 & 2 criteria as well as toxics exhaust and evaporative light duty emissions standards Gasoline and Diesel Fuel Standards Fuel economy labeling rule Joint EPA and NHTSA Greenhouse Gas and CAFE LDV final rule EPA s principles Identify feasible and cost-effective technology Set performance standards to drive innovation and allow flexible compliance Allow lead time for normal business investment cycles Comprehensive approach with all subsectors and fuels Open and transparent process with broad stakeholder involvement w w w. a u t o s t e e l. o r g

5 Greenhouse Gas and Fuel Economy Regulatory History 1975: Congress passed Energy Policy and Conservation Act (EPCA) giving National Highway Traffic Safety Administration (NHTSA, part of DOT) to establish Corporate Average Fuel Economy (CAFE) standards 2004: State of California approved GHG standards for LDVs for model years states adopted these standards Rule requires a waiver from the US EPA 2006: NHTSA finalizes truck CAFE rule for MY Light trucks Reformed standards are footprint based 2007: Congress passed Energy Independence and Security Act (EISA) requiring 35 mpg average by : Supreme Court issued opinion in Massachusetts vs EPA that greenhouse gases were air pollutants as defined in the Clean Air Act EPA must determine whether emissions from motor vehicles endangered public health or welfare If finding endangerment, EPA must regulate w w w. a u t o s t e e l. o r g

6 History continued March, 2009 NHTSA finalizes CAFE standards for MY 2011 LDVs May 2009, President Obama announced joint EPA NHTSA program to set average emissions level of light duty vehicles to 35.5 MPG by auto manufacturers and California supported this approach June 2009, EPA granted California waiver for standards April 1, 2010, EPA Administrator Jackson and DOT Secretary LaHood signed a joint Final Rule adopting closely-related standards that together comprise a National Program for reducing GHG emissions and improving fuel economy of light-duty vehicles for MY Coordinated national standards can provide regulatory certainty and consistency for the auto industry Automakers will meet NHTSA, EPA, and California requirements with a single national fleet w w w. a u t o s t e e l. o r g

7 EPA CO 2 Standards EPA s standards estimated to achieve: Fleet-wide level of 250 grams/mile (155 g/km) of CO 2 in model year 2016 Standards would phase in beginning in model year 2012 EPA promulgates rules under Clean Air Act, which allowed EPA to include several flexibilities Example: Advanced Technology credits for Electric Vehicles Fleet-wide CO 2 standard could be met partially through credits from improved air conditioner (A/C) operation A/C credits include CO 2 & hydrofluorocarbon (HFC) refrigerant reductions HFC refrigerant is a powerful GHG The 250 gram/mile CO 2 standard corresponds to 35.5 mpg equivalent if all reductions resulted from fuel economy improvements (6.63 L/100km) NHTSA also adopted new CAFE standards which will lead to an estimated fleet average level of 34.1 mpg (6.9 L/100km) in 2016 The difference between the EPA and NHTSA standards lies mostly in the air conditioning technologies manufacturers are projected to use, which are not considered in the CAFE rule w w w. a u t o s t e e l. o r g

8 Standards are Footprint Attribute-based Each manufacturer s standard based on the footprint of the vehicles producted. Actual standards are curves which equate a vehicle size to its specific CO2 or MPG target. Each company s standard are footprint curves. Vehicle Type Example Models Example Model Footprint (sq. ft.) CO 2 Emissions Target (g/mi) Fuel Economy Target (mpg) Example Passenger Cars Compact car Honda Fit Midsize car Ford Fusion Fullsize car Chrysler Example Light-duty Trucks Small SUV 4WD Ford Escape Midsize crossover Nissan Murano Minivan Toyota Sienna Large pickup truck Chevy Silverado w w w. a u t o s t e e l. o r g 9

9 EPA CO2 Car and Truck Standard Curves: s per mile) CO2 (grams Car standard curves ` CO2 (grams per mile) Truck standard curves Footprint (sq feet) Footprint (sq feet) Reference: EPA/NHTSA Final Rule Making to Establish Light-duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards for MY s 2012~2016 w w w. a u t o s t e e l. o r g 10

10 EPA Program Flexibilities Emission banking and trading elements Flex-fuel vehicle (FFV) credits MY credits similar to CAFE, MY2016+ credits based on actual E85 fuel use Air conditioning HFC and CO 2 reduction credits Early credit opportunities for doing better than California or CAFE Advance technology credits (electric vehicles) Innovative technology credits Manufacturers with limited product lines and/or have historically paid fines to NHTSA may be especially challenged technologically in the early years of the program Under the Clean Air Act, manufacturers cannot pay fines in lieu of complying with motor vehicle emissions standards w w w. a u t o s t e e l. o r g 11

11 Technologies Considered Engine Valvetrain changes Stoichiometric Gas Direct Injection (SGDI) Turbo-charging /downsizing Transmission Higher speed transmissions (4-speed to 5-speed +) Dual Clutch Transmissions (DCT) Electrification of vehicles Start-stop Hybrids Accessories High efficiency alternators Electrification of ancillary systems Electric power steering Other Vehicle Technology Aerodynamic improvements Tire Rolling Resistance Mass Reduction w w w. a u t o s t e e l. o r g 12

12 Mass Reduction Effectiveness EPA believes mass reduction is a cost effective enabler for higher fuel economy and lower CO2 emissions without negative safety implications. Approximately 6-8% increase in fuel economy for every 10% drop in in vehicle mass Mass decompounding effect Reducing vehicle mass enables: Reduced vehicle power requirements Further downsizing of ancillary systems such as brakes and suspension, resulting in further mass reduction. Mass reduction can be used to offset the increased weight of alternative powertrains (hybrid electric vehicles, fuel cells) Historically, lightweighting has been offset by increased weight from added features w w w. a u t o s t e e l. o r g 13

13 Mass Reduction Is Not New In the past, mass reduction has been used to offset or mitigate weight gains in other subsystems Increased feature content Entertainment systems Active chassis controls Panoramic sunroof Improved NVH performance Increased stringency of FMVSS requirements Lightweight designs have also been used to improve vehicle performance Increased acceleration Vehicle handling Braking w w w. a u t o s t e e l. o r g 14

14 Vehicle Mass Trends w w w. a u t o s t e e l. o r g 15

15 Mass Reduction Cost Some mass reduction has minimal, if any, cost impact Elimination of parts Part integration For the GHG rule EPA used 3 studies 2002 NAS Report estimated that vehicle weight could be reduced for approximately $1.50 per pound Sierra Research estimated that a 10 percent reduction, with compounding, could be accomplished for a cost of $1.01 per pound. [i] Finally, an MIT study [ii] estimated that the weight of a vehicle could be reduced by 14 percent, with no compounding, for a cost of $1.36 per pound. The cost estimate used for the FRM is $1.32 per pound and is based on the average of the three referenced studies. w w w. a u t o s t e e l. o r g 16

16 Mass Reduction Cost TECHNOLOGY INCREMENTAL TO Cost LARGE CAR VEHICLE CLASS Cost/Effectiveness Effectiveness ($/% reduction CO2) 6-speed automatic transmission 4-speed automatic $99 5.5% $18 VVT- Coupled Cam Phasing Base Engine $80 4% $20 Electric Power Steering Base power steering $94 2% $47 Stop-Start Base engine and trans $ % $53 Mass reduction - 10% Base engine and trans $516 7% $74 Downsize to V6 DOHC and add twin turbo V8 SOHC 3V w/o turbo $736 6% $123 GDI - stoichiometric I4 Base I4 $209 2% $139 Power-split hybrid Base engine and trans $5,377 35% $154 $516 cost estimate: 10% mass reduction based on 2008 MY sales weighted average weight for a large car equipped with a V6 363 pounds x $1.32/lb x 1.11 (Indirect Cost Multiplier ICM) x 0.97 (3% year-over-year time based learning for 2016 CY $ s) w w w. a u t o s t e e l. o r g 17

17 Mass Reduction Methodologies Mass reduction may be accomplished through proven methods such as: Smart Design: Computer Aided Engineering (CAE) tools can be used to optimize load paths Sectional thickness of structural components can be optimized Smart designs can result in part integration, elimination and reductions in fasteners Material Substitution: Substitution of lower density and/or higher strength materials Includes the substitution of mild steels for high strength steels and low density materials. (Which will not be named at the GDIS!) Reduced Powertrain Requirements: Reducing vehicle weight sufficiently allows for the use of a smaller, lighter, and more efficient engine while maintaining or increasing performance. Half of weight savings could come from reduced powertrain output requirements. Half could be realized through the reduction in size of the of the transmission, driveshaft, etc. through the reduced torque required. Reference: EPA/NHTSA Final Rule Making to Establish Light-duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards for MY s 2012~2016 w w w. a u t o s t e e l. o r g 18

18 Mass Reduction Estimates for 2016 Rule Overall average reduction in vehicle weight: 4% Announcement or Assessment Mass reduction per-vehicle (lb) Mass reduction per-vehicle (%) Small cars average % EPA estimates for U.S. fleet Large cars average % Small trucks average % Large trucks average % Mazda average by 2016 ~440 13% Company plans Ford across vehicle platforms by ~14% Nissan average by 2015 ~550 15% Toyota small to mid-size vehicles, 2015 ~ % Reference: EPA/NHTSA Final Rule Making to Establish Light-duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards for MY s 2012~2016 w w w. a u t o s t e e l. o r g 19

19 Safety Considerations The prediction of potential safety effects resulting from mass reduction is both complex and controversial. The final rule presented results from 2 major studies regarding the historical relationship between mass and safety: 1. NHTSA s Kahane analyses 2003/ Dynamics Research, Inc. analysis w w w. a u t o s t e e l. o r g 20

20 Safety Considerations 1. NHTSA s Kahane analyses 2003/2010 Statistical analyses of real world fatalities which occurred from the fleet of MY vehicles driven in the U.S during the CY s. Concluded that a 100 lb. reduction in weight will result in an increase in societal fatalities in cars < 2950 lbs. A 100 lb reduction in weight will result in a decrease in societal fatalities in LTV s > 3,870 lbs. A 100 lb. reduction in weight will result in no statistically significant change in societal fatalities in other light duty vehicles. w w w. a u t o s t e e l. o r g 21

21 Safety Considerations Dynamics Research, Inc. analysis Statistical analyses of real world fatalities which occurred from the full fleet of MY vehicles driven in the U.S during the CY s. Concluded that a 100 lb. reduction in weight will result in an overall decrease in fatalities. w w w. a u t o s t e e l. o r g 22

22 Safety Considerations EPA Analysis of Crash Avoidance Consumer Reports Emergency Handling Speed vs. Curb Weight Emergency Hand dling Speed (MPH) Vehicles not equipped with ESC Vehicles Equipped with ESC Linear (Vehicles Equipped with ESC) Linear (Vehicles not equipped with ESC) Vehicle Curb Weight (lbs) Reference: EPA Regulatory Impact Analysis (RIA) for Light-duty Vehicle Greenhouse Gas Emission Standards for MY s 2012~2016 w w w. a u t o s t e e l. o r g 23

23 Safety Considerations EPA and NHTSA Position Based on the 2010 Kahane analysis the agencies now believe that the likely deleterious safety effects of the MYs standards may be much lower than originally estimated. They may be close to zero, or possibly beneficial if mass reduction is carefully undertaken in the future and if the mass reduction in the heavier LTVs is greater (in absolute terms) than in passenger cars. In light of these findings, we believe that the balancing is reasonable. The agencies intend to begin working collaboratively and to explore with DOE, CARB, and perhaps other stakeholders an interagency/ intergovernmental working group to evaluate all aspects of mass, size and safety. It would also be the goal of this team to coordinate government supported studies and independent research, to the extent possible, to help ensure the work is complementary to previous and ongoing research and to guide further research in this area. Reference: EPA/NHTSA Final Rule Making to Establish Light-duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards for MY s 2012~2016 w w w. a u t o s t e e l. o r g 24

24 Conclusion EPA believes mass reduction is a cost effective enabler for higher fuel economy and lower CO2 emissions without negative safety implications. Mass reduction will continue to be an important consideration for future rule makings. Future of mass reduction The latest mass reduction study recently completed by Lotus Engineering presents a potential path going forward. Tom Cackette from the California Air Resources Board will provide additional insight in his presentation. w w w. a u t o s t e e l. o r g 25

25 Mass Reduction CAFE Effect Error in Formula! w w w. a u t o s t e e l. o r g 26

26 Q&A Questions w w w. a u t o s t e e l. o r g

27 References [i] Basic Analysis of the Cost and Long-Term Impact of the Energy Independence and Security Act Fuel Economy Standards Sierra Research Report No. SR , Docket EPA-HQ-OAR [ii] Factor of Two: Halving the Fuel Consumption of New U.S. Automobiles by 2035 L. Cheah, C. Evans, A. Bandivadekar and J. Heywood, Publication No. LFEE RP, October 2007, Docket EPA-HQ- OAR w w w. a u t o s t e e l. o r g 28