In 2020, three significant rulings were introduced both at the federal and state level – through the U.S. Environmental Protection Agency (EPA) and the California Air Resources Board (CARB), respectively – to address further reductions in greenhouse gas (GHG) emissions. Both the U.S. EPA and CARB rulings have incremental goals to reduce nitrogen oxide (NOx) emissions, but a discrepancy on timing.
Panelists discussed the implications of these varied standards at a state and federal level, and how it may impact fleets in the future, during the American Trucking Associations’ (ATA) virtual Management Conference & Exhibition (MCE) this week.
EPA versus CARB
Over the summer, CARB focused on two key initiatives to reduce NOx emissions and encourage the adoption of zero-emission vehicles (ZEVs).
In June, California proposed its Advanced Clean Truck (ACT) standard. The ACT standard requires incrementally higher adoption rates of on-road zero-emission vehicles from 2024 through 2040, in order to achieve carbon neutrality.
Beginning in 2024, 3% of Class 2 and 3, 7% of Class 4 through 8 trucks, and 3% of Class 7 and 8 tractors purchased in California must be ZEVs. By 2030, half of Classes 4-6 and 30% of Classes 7 and 8 sales must be ZEVs. By 2045, all new vehicles sold in the state would require they be ZEVs.
In August, CARB adopted a new ruling to lower NOx emissions for on-highway vehicles. Current CARB NOx limits are 0.2 grams per brake horsepower-hour (g/bhp-hr), noted Melina Kennedy, vice president, product compliance and regulatory affairs for Cummins. The incremental reductions for the California state ruling plan to require a further 75% reduction in 2024 to a limit of 0.05 g/bhp-hr and another 90% reduction by 2027 to 0.02 g/bhp-hr.
“There will be new test cycles, lower load cycles, idling standards, etc.,” said Kennedy. She also noted longer durability testing requirements that would require a longer time commitment from manufacturers, new in-use emissions limits for a longer period of time, as well as longer emissions warranty requirements. Additionally, California looks to offer a state-only credit bank for manufacturers that meet standards earlier than deadline, through either NOx technology or zero-emission technology development.
In early 2020, the U.S. EPA introduced its own notice of proposed rulemaking, called the Cleaner Trucks Initiative (CTI) proposal, aimed at reducing NOx emissions at a federal level. The EPA is likely to finalize this regulation in 2021, with the rule taking effect for 2027. It is important to note that the CTI is a separate proposal from the current EPA and National Highway Traffic Safety Administration (NHTSA) joint ruling for Phase 2 emissions standards already in place.
“Certainly, different standards will drive different product offerings between California and the rest of the U.S.,” said Kennedy. Two key items to consider beyond the discrepancy in requirements for those three years are if the 2027 EPA standards would eventually align with CARB requirements, and if other states decide to follow CARB’s lead by adopting similar more stringent state emissions requirements at the state level.
From a fleet perspective, Dave Williams, senior vice president, equipment and government relations for Knight-Swift Transportation, advised it could prove challenging for future planning.
“The big thing to consider there is we're going to have different rules, potentially, to deal with,” Williams said. “As more details come out about this particular rule, you're really going to have to understand how the laws apply to determine whether you fall into the California rule or whether the national rule.”
Williams also raised the concern of having required extended warranty requirements for emissions systems as part of the CARB low-NOx ruling. New technologies will already inherently drive up the cost of vehicles. But, Williams argues, having all fleets covered by an extended warranty would also create additional challenges.
“If everyone is now covered by the extended warranty, even those that don't take good care of their trucks, then the number of occurrences or the number of failures is going to increase, which means that warranty (cost) is going to also increase substantially,” said Williams.
Push for zero-emission vehicles
The drive for increasingly stringent emissions standards and encouraged adoption of ZEVs for California has been driven by air quality concerns and improving health standards for California residents, noted Steve Slesinski, director, global product management for Dana Inc.
“Eighty percent of smog is actually created from NOx emissions,” he said. “And then consider diesel engines; 95% of all diesel particulate matter is actually created in California.”
To address these concerns, battery-electric vehicles will play a key role in reducing emissions.
Slesinski suggested ZEVs are up to five times more efficient than a diesel powertrain. Additionally, ZEVs can help reduce the nation's dependence on petroleum as well as reduce maintenance costs for fleets.
Electric energy for charging these vehicles will continue to be created by cleaner sources as improvements are made to the power grid, he also noted.
While battery-electric technologies have played a prominent role in showcasing capabilities of reduced-emission and zero-emission vehicles, Slesinski suggested other power options such as renewable natural gas (RNG) will also play a key role in helping to reach incremental goals of the ACT regulations.
Moreover, most recent introductions to products such as hydrogen fuel cell technology will drive continued reductions in emissions.
After its introduction in June, 15 other states and Washington, D.C., agreed to adopt these same standards for incremental ZEV adoption. “These states make up almost 50% of the United States economy and about 40% by value of goods moved by trucks,” noted Slesinski.
“Understanding how these trucks might fit in your fleet is going to be key to really deciding whether these work for you,” noted Knight-Swift’s Williams. He advised there are three areas to consider when looking at future vehicle power: range, weight, and cost.
“I think this is our future. I think this is the right thing to do,” Williams said. “Our company has set a recent goal to reduce our carbon emissions by 50% over the next 15 years, so we anticipate these being substantial solutions for us. But at the same time, [there are] a lot of details to work out and a lot of engineering challenges to overcome. It's very important to stay educated.”
Vehicle inspection and maintenance
As part of the continued efforts to reduce GHG emissions, CARB is looking to also monitor vehicle emissions output after the initial sales of the equipment. This will require fleets to become more involved in monitoring and reporting vehicle emissions periodically to ensure continued compliance.
“The historical burden for compliance related to emissions has fallen on the OEM,” noted Knight-Swift’s Williams. “Now they're saying they’re going to check the effectiveness of the emission system throughout (the vehicle’s) life, and if it doesn't meet the standard, the fleet is going to be held accountable for that.”
Signed into law in September 2019, the CARB Heavy-Duty Inspection and Maintenance (HD I/M) Program would monitor and verify the proper functioning of heavy-duty truck emissions systems, ensuring the emissions systems are working properly throughout the entire life of the vehicle. Formal approval of the regulation is expected in late 2021, and comments are still welcome on the current draft.
Doug Powell, director of fleet management for Kenworth, advised the program currently looks to be implemented in three phases:
- Phase 1 – Jan. 1, 2023: Initial vehicle detection and fleet reporting begins
- Phase 2 – July 1, 2023: Enforcement of emission control system compliance on heavy-duty trucks
- Phase 3 – 2024: Periodic testing requirements to start
The main proponent of the HD I/M program requires quarterly data collection from vehicles to ensure adherence to the state emissions requirements and keep historical records of the testing results, noted Powell. This could be done through on-site or roadside testing, via an add-on device or dongle connected to the vehicle’s on-board diagnostics (OBD), or through telematics systems equipped on the vehicle.
“The easiest option would be to have some updates done within the telematics system, new software enabled to submit data,” said Powell. “That would be the easiest method in order to really seamlessly transfer the data.” However, he added, there are concerns raised that fleets or vehicle owners would not have the opportunity to first address issues before automatic reporting.
From a truck manufacturer perspective, Powell noted challenges may arise with having multiple designs and different development requirements for new or embedded software in order to provide the necessary data to state officials. Additionally, partnerships between truck OEs and telematics companies will be key to ensuring a streamlined approach to meet CARB requirements.
