EPA'S TRANSPORTATION OFFICE, EMISSIONS COMPLIANCE APPROACH, AND INTERNATIONAL HARMONIZATION - Bill Charmley Office of Transportation and Air ...
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EPA’S TRANSPORTATION OFFICE, EMISSIONS COMPLIANCE APPROACH, AND INTERNATIONAL HARMONIZATION Bill Charmley Office of Transportation and Air Quality U.S. Environmental Protection Agency July 19, 2017
Overview
EPA’s Office of Transportation and Air Quality
Who we are and what we do
EPA’s Mobile Source Control Program
How our compliance program works
International Cooperation and Harmonization
2Office of Transportation and Air Quality Mission Statement
To protect human health and the
environment by reducing air pollution
from mobile sources and the fuels that
power them.
Paper # (if applicable) 3State of the Transportation Sector
The transportation sector is in a period of rapid change and technological
advancement. Mobile sources of pollution account for over 50% of smog forming
emissions and 27% of greenhouse gas emissions in the U.S.
Cars and trucks
Manufacturers are introducing electric vehicles and expanding electrification technologies
Connected and automated vehicles along with different consumer preferences are transforming this
industry quickly
Freight and Shipping
Current EPA and DOT standards will make US trucks the most technologically advanced and fuel
efficient in the world
Freight transportation is growing rapidly worldwide
Fuels
The renewable fuels standard has spurred growth of biofuels for transportation
Globalization
Competition for markets both domestic and foreign is fierce
4What we do
Provide a level playing field for a highly competitive market through effective
compliance oversight and as needed, collaboration with EPA’s enforcement team.
Contribute to energy security through vehicle/engines and fuels program
implementation and compliance.
Engage with stakeholders and the public regarding programs and regulatory actions.
Ensure value and choice for consumers in both the vehicle/engines and fuels
markets.
Implement the programs based on science and the law.
5The National Vehicle & Fuel Emissions Laboratory (aka, the Ann Arbor lab)
Unique, one-of-a-kind facility among other Federal Labs.
NVFEL is the official Federal Laboratory that…
• Tests vehicles & engines to ensure compliance with emissions standards.
• Tests vehicles to ensure compliance with fuel economy standards
• Tests fuels to ensure compliance with standards
NVFEL has been awarded 90 U.S. patents on advanced technology
NVFEL is the benchmark against which all other automotive emissions labs
world-wide are measured
• So automakers have confidence that their measurements are consistent with NVFEL
• So EPA has confidence in automaker emissions labs
6EPA Ann Arbor Lab Capabilities
Light Duty Chassis Testing: Cars and light trucks are tested on a chassis dynamometer, under tightly-controlled
conditions that simulate the operation of a vehicle on the road. Testing supports certification and oversight of cars,
SUVs and light trucks to ensure vehicles meet pollution standards.
Heavy Duty Chassis Testing: In 2015, EPA installed and opened one of the largest capacity Heavy-Duty Chassis
dynamometers in the western hemisphere. This dynamometer can test onroad trucks and buses weighing up to 80,000
lbs extremely efficiently allowing more vehicles to be tested in less time.
Engine Emissions Testing Facilities: NVFEL uses various test methods and procedures for measuring the
emissions from engines, ranging in size from the small gasoline engines used in lawn and garden tools to the large
heavy-duty diesel engines used in heavy-duty trucks and buses, as well as agriculture and construction equipment.
Portable Emissions Measurement Systems: Used to understand in-use emissions performance of engines in
both vehicles and nonroad equipment operated under typical conditions. Critical to measure emissions on the road as
well as in the lab.
Fuels and Chemistry Center: Conducts fuel quality surveillance and provides the laboratory with standard test
fuels, experimental test fuels.
7Why does compliance matter?
Emissions from transportation sources do immense harm to public health,
welfare and the environment
EPA estimates that in 2030 alone, transportation-source air regulations will
prevent more than 38,000 premature mortalities and realize more than $380
billion in health and welfare benefits.
These benefit estimates describe the harm that will come if the vehicles and
engines produced fail to comply with our programs
EPA must ensure environmental compliance to deliver these
benefits
8EPA Transportation Sector Compliance Obligations: Scope, Volume,
and Complexity
Highway Vehicles and Engines
Cars, trucks, vans, SUVs, motorcycles
Heavy-duty trucks, buses
Nonroad Engines, Vehicles, and Equipment
Large diesel (construction equipment)
Large gas (forklifts, compressors, air ground service equipment)
Handheld utility engines (chainsaws, leaf-blowers, trimmers)
Non handheld utility engines (lawnmowers, garden tractors)
Marine (outboard/inboard motors, jet skis)
Recreational vehicles (snowmobiles, ATVs, off-road motorcycles)
Locomotives
Ocean Going Vessels
Fuels Regulations Apply To:
Gasoline and diesel refiners and importers
Renewable fuel producers and importers
Fuel additive producers and importers
Retail stations and terminal operators (oxygenate blenders)
9EPA Transportation Sector Compliance Obligations:
Scope, Volume, and Complexity
Model Year 1995 Certificates Post 2014 (~4,000 per year)
Total = 810
LDV – 464 HMC – 380
ICI – 11 OFMC - 58
Alt Fuel -
205
Snowmobile - 26
HDDE - 57
Large SI - 88
NRCI – 506
Small SI – 984
Locomotive - 58
Evap Components - 811
Marine SI - 87 HDGE - 10
Marine CI - 200 ATVs - 199EPA Transportation Sector Compliance Obligations: Scope,
Volume, and Complexity
Fourth tier of emission regulations – necessarily complex after earlier tiers picked the low
hanging fruit
Required technical and policy innovation - EPA has designed flexible approaches that enable industry to comply
As a result industry and EPA implementation inherently more complex
Extraordinarily diverse regulated community
Regulations must be flexible enough to work for huge conglomerates &mom-and-pop start-ups
New demands are adding to an already broad portfolio
GHG, RFS authorities introduce new and different compliance challenges
New vehicle and fuel technologies demand specialized expertise
Increased flexibility for industry increases implementation complexity for EPA
Industries and manufacturers new to EPA regulation require staff-intensive compliance support
Globalization and foreign manufacturers present some special challenges
Explosive growth especially from China
11Achieving Emission Reductions
It is vehicle manufacturers, vehicle owners and repair technicians that determine how much
pollution comes from cars
We accomplish our emission reduction goals through the minds and hands of manufacturers,
owners and technicians
We want manufacturers to design & manufacturer cars to limit vehicle emissions to the
greatest degree technology will allow for the full lifetime of the vehicles
We want vehicle manufacturers to fix any defects in their products through recall and
repair
We want vehicle owners and service technicians to properly operate and maintain
vehicles
EPA compliance efforts need to focus on these audiences to best effect their actions
12Holding Manufacturers Attention
Require a license to produce every year
Meet manufacturers with an equally capable technical team
Work to genuinely understand manufacturer challenges and help
solve legitimate problems
Visibly hold them accountable when they fail
13Recruit, train, and empower an effective compliance team
Seek staff with a passion for protecting the environment and a passion for
vehicle and engine technology
Cultivate a diverse team with deep technical and policy skills
Industry experience
Active in professional societies (e.g., SAE, ASME)
Empower the staff to develop new and innovative ways to accomplish their
work
14EPA Light-Duty Vehicle Compliance Program
EPA Action
Durability
Review and Manufacturer Action
EPA Follow-Up (Defect and Recall Reports, Mfr. In-Use Testing,
Approval EPA Issues Certificate of EPA Testing)
Process Conformity EPA Test Data Review/Analysis
CARB Coordination (Warranty Reporting)
EPA Review of Manufacturer OECA Coordination (Enforcement)
Application
EPA Confirmatory
Testing (Random and EPA In-Use Surveillance
Targeted) Testing
EPA
Certification
Preview and
10,000 20,000 50,000 90,000 120,000 Miles
Pre-model 0 Miles Miles Miles Miles Miles (End of Useful
Year Reports
Life)
Vehicle Design
and Build Vehicle May Low-mileage In-Use High-Mileage In-Use End of Useful Life (per CAA)
Enter Commerce Verification Testing Verification Testing Performed
Performed by by Manufacturer
Manufacturer
Manufacturer
Emissions Vehicle
Prototype and
Durability Testing
Warranty Tracking and Emission Warranty
Reports (EWIRs) to CARB
Emission Defect Information and Voluntary
Emission Recall Reports (EDIRs/VERRs) to EPA
(introduction into commerce – useful life miles)
15EPA Compliance Mindset
We can’t do everything, and we can’t be everywhere. We have to make choices
based on our assessment of environmental and programmatic risk
We empower our technical compliance teams to innovate in ways that can maximize
the environmental return for the public
Visible compliance and enforcement are powerful levers to deter noncompliance
and demonstrate our resolve
Compliance data are powerful. EPA must make it readily available so it can be
leveraged to improve policy decisions, regulatory determinations, compliance auditing
and program transparency
16Risk assessment is fundamental to our planning and to the
daily work of the EPA compliance team
CD Risk Assessment Cycles
Long-Term Annual Our Culture
Frequency Every 3 Years Every Fiscal Year Every Day
Internal and External
Participants EPA Staff and Management Sector Leaders and Teams
Stakeholders
Prioritize EPA Myriad of individual
Annual Test Planning /
compliance resource decisions each day
Purpose Budget / Staffing within a
investments based on (certification and
Center/ Targetting
relative risk compliance)
Update long-term Staff and Center Director's
Complete Detailed Risk
assessment; rank to target best judgment on
Detail Assessment with
specific high risk concerns environmental &
Rankings
within each sector programmatic risk
Planning Duration 6 months 3 months daily
Prioritized Relative Prioritized Relative Risks Relative Risk between two
Output
Risks between Sectors within each Sector choices
17EPA is Using a 3-by-3 Compliance Testing Strategy
Cars, SUVs, and pickup trucks are tested at 3 times during their product life
Preproduction
At the time of new product introduction
Vehicles in-use
Vehicles are tested for Certification & Compliance in 3 ways at any of the
above 3 times
EPA’s Standard 5 Test Procedures (FTP, HWFET, US06, FTP20, SC03)
Special Tests in the Lab
Real World driving on public roads (a.k.a PEMS)
18Real World Driving (a.k.a PEMS Testing – Not RDE)
The goal of EPA’s Real World driving compliance tests are to identify if the vehicle
behaves differently in the chassis dyno than on public roads during “Real World” driving
The vehicle emissions system effectiveness and behaviors during everyday road driving should
be consistent with emissions during EPA’s 5 Test Procedures
Tools used during Real World testing include both/either PEMS or simpler EPA designed
tools to ensure the emissions characteristics are consist on road and in the lab
The goal is not that emissions are measured “on road” but rather that vehicle emissions
behaviors are consistent between regular public road use and standard EPA tests.
EPA uses both PEMS and the flexibilities of the chassis emissions testing to ensure
compliance with EPA emission standards
19International Cooperation &
Harmonization
20Major International Forums for Vehicle Emission Standards
Dialogue
EPA actively participates in regular bilateral discussions with other countries
including Canada, Japan, China the European Commission, and other nations.
Typically used to share information technical information and opportunities for
coordination
In addition, EPA has been engaged as part of the United States delegation to the
United Nation’s World Forum for the Harmonization of Vehicle Standards (WP.29)
See next slide for structure of WP.29
Provides the opportunity for sharing technical information
Also a frame work for international harmonization of vehicle standards and test
procedures
21U.N. World Forum for Harmonization of Vehicle Regulatios
22Major Agreements Administered by U.N. WP-29
“1958 Agreement”
~ 50 nations are contracting parties – including all E.U. countries. The United
States is not a contracting party to the 1958 Agreement
>100 vehicle standards established under the 1958 Agreement, including many for
vehicle safety, as well as the various Euro emission standards for vehicles
Key element of 1958 Agreement: Type Approval and Mutual Recognition
“1998 Agreement”
~ 30 nations are contracting parties, including the U.S., Canada, China, Japan,
South Korea, the E.U., and many individual E.U. nations
Process for developing Global Technical Regulations
Does not require Type Approval process or Mutual Recognition
Rather, expectation is individual members will adopt a developed Global Technical
Regulation into their national regulations following their national process
23Example Global Technical Regulations developed under
1998 Agreement for Air Pollution
Nonroad diesel engines: test cycles & test procedures
Motorcycles: test cycles, test procedures, and emission standards
Highway heavy-duty diesel engines
Test cycles & test procedures
On-board diagnostics
Off-cycle emissions requirements and not-to-exceed test procedures
Highway light-duty vehicles: worldwide harmonized test cycles &
test procedures
24International Harmonization Efforts: Light-duty efforts
EPA believes that the current US test cycles are controlling under the majority of vehicle
operating conditions
International test procedure development has historically occurred very slowly and often
results in the “lowest common denominator” solution
Example is the latest evaporative emissions requirements being developed under WLTP that
are less controlling than U.S. Tier 2 standards (which have been in place more than 10 years)
Industry influence on the development of international test procedures is often not balanced
with public welfare
Government representation does not have the technical expertise to push back
EPA will not adopt test procedures or accept test results that are not equal to our existing
requirements.
25Thank you!
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