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6 Light-Duty-Vehicle Emissions Standards
Pages 165-224

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From page 165...
... THE LOW-EMISSION-VEHICLE PROGRAM The California legislature enacted the California Clean Air Act of 1988, which instructed CARB to "achieve the maximum degree of emission reduction possible from vehicular and other mobile sources" (Cal. Health & Safety Code § 43018(a)
From page 166...
... , and zero-emission vehicle (ZEV)
From page 168...
... Although the primary objective of the ZEV mandate was to reduce vehicle emissions, CARB identified secondary benefits, including the investment by industry and communities in batteries and infrastructure for ZEVs (CARB 1991) , the potential to "contribute to national and state energy diversity and security," and the potential "to revitalize California's economy through job creation and growth in an emerging industry" (CARB 1994a)
From page 169...
... . The Zero-Emission-Vehicle Mandate Although the overall LEV program was widely considered successful at reducing vehicle emissions and promoting advanced emissionscontrol technologies, the ZEV experiment has fallen short of its original expectations to promote the widespread use of electric vehicles.
From page 170...
... . (This manufacturer obligation was implemented through the National Low Emission Vehicle [NLEV]
From page 171...
... Unless the state and local air districts could provide the substantial funds that would be needed to subsidize these vehicles, manufacturers would have to either absorb the economic losses internally or pass on the costs to purchasers of other vehicles (CARB 2000a)
From page 172...
... . As part of this 2 Public Workshop to Discuss Issues Related to the Zero Emission Vehicle Regulations: Agenda and Background Material, Oct.
From page 173...
... . A study commissioned by CARB found that the California ZEV mandate had produced important secondary benefits in such categories as new economic development in California, advanced vehicle development, vehicle emissions reductions outside of California, and nonelectric vehicle applications of advanced batteries (Burke et al.
From page 174...
... serve as a laboratory for experimentation in emissions control. Impacts of LEV Program on LDV Emissions-Control Technologies The LEV program provides a good example of California's role as a laboratory for innovation and technology to reduce mobile-source emissions.
From page 175...
... Electrically heated catalysts reduce cold-start emissions, which account for a large majority of the remaining emissions from modern motor vehicles (CARB 1991)
From page 176...
... Influence of the LEV Program on National Mobile-Source Emissions Standards Many northeastern states actively pursued adoption of California's LEV program in the 1990s to achieve emissions reductions that would help to meet their air quality goals. Thirteen northeastern states that were the members of the Ozone Transport Commission (OTC)
From page 177...
... First, the technology-forcing nature of California standards can benefit not only California but also the rest of the country. The NLEV program, which resulted in substantial reductions of vehicle emissions across the nation beyond what was required under the 1990 CAA amendments, could exist only because of California's leadership in forcing stricter emissions controls and the rights of other states to adopt those standards under section 177 of the federal CAA.
From page 178...
... The LEV II program introduced another new emissions class called super-ultra-low emission vehicle (SULEV) and removed the transitional LEV (TLEV)
From page 179...
... Emissions reductions over the fleet of vehicles subject to Tier 2 and LEV II programs in coming years will depend on many factors and assumptions about the future mix of vehicles in each fleet. Given the greater than 95% emissions reductions achieved by both programs, California and federally certified passenger vehicles are considered by some to produce "near-zero" emissions of NOx, volatile organic compounds (VOCs)
From page 180...
... 180 devo eb 100%, 2008 rem (see stum in DT VP 11d lyno 75%, ely, 50% V/LL 2 aft W PVD 50%, ectiv least esclih T 0092 GVW Mr 6-4) el sper at 25% 07 Tiereb LD2r /MDTDLH2 0702re ve2 LLD after W lb Tab in least 20, V/ Tier er bl0058, GVbl0 GVbl0 fo11 MDPV, stum -Tienon n 006, % ase-in HLDT/ 2 0-, 0-, 508,-0006,,T ,0000 Bin lse 0062, 09 DT/ issionsme :ni allr no Tilalr : LDlal MDPV x 00-15,8 an01niB;11niBh levn at,TD all PV, Tier LDV LLDT HLD MD ugorht1niB HL ase- foi se-in; 0052 20ni ON 4, for on ph mi/g forimg/ pha DV/LLL 2; ph 200 100d all after certificatio For in Tier an sedaB ngiruD g/m030.
From page 181...
... 181 on ssii DT, evi life,l efusull em-wol, HL;T rnatetal -LD P, 60 LEV ghtil AC fu 20 i;m e;clhi by 00,0 mpp DT,LL ver k; nge 50 life, 30egar PZEV;-ygool ucrt hn y passe iate ed term im0000, ndateam ave ec-td at nce dut-htgil yut sales urf va T, ad In 12 No Sul LD r; ZEV, -P car -dmudiem,VPD M life,l stid plans) AT ge ens e;cl cre ACP efusull pas, vehi fu i;m forim0000, and ZEV;-lai PC yut V; egar itsd part, cre -dhtgil 00,0 15, ave 50 rtialap PZEV onalit fleet e;clhi a-LErtul,V LDV, life, e;cl iate ed term op;im0000, OG PZEV, ppm ve ULE 15 on vehi NM rd (with atr y lfu ssiim-e In 12 towa ZEV Su ro LEV;-artul ze, perus -dutmudiem e ZEV agn teadnam ents V, DV, .n ns:oita LEUS M pla T; requirem evi br e;cl LD- liancep Certificatio Sales Fuel Ab vehi heavy com
From page 182...
... 182 State and Federal Standards for Mobile-Source Emissions )
From page 183...
... . turers will produce larger numbers of near-zero-emission vehicles to satisfy the ACP option to meet their ZEV mandates (CARB 2005e)
From page 184...
... Attainment of the NAAQS, for ground-level ozone has in particular been the impetus for regulating mobile-source emissions in recent decades. CARB, as a state agency delegated the responsibility to attain the NAAQS in California, is required by the federal CAA to develop a state implementation plan (SIP)
From page 185...
... The analysis includes estimation of present and future emissions inventories, including mobile sources. The analysis also includes photochemical grid modeling to determine the expected reductions in ground-level ozone concentrations that result from precursor emissions reductions.
From page 186...
... included numerical values for Tier 2 standards as an alternative for EPA to consider if more stringent standards were deemed necessary, feasible, and cost-effective. The study, known as the "Tier 2 Report to Congress," concluded that there would be an air quality need for emissions reductions to aid in meeting and maintaining the NAAQS for both ozone and PM (EPA 1998)
From page 187...
... 187 gn sensor 2 gen oxy Tier gas adiollatempuo EPA gin gr s and exhaust or ust n oniat ng II LEV -offthgil sens rol sm ontc timelvav acity numiatpl rculi desi ber gen rec fast/ oxy cham ust of CARB gas eluf-rair systel jectioni le el capla ande sato start-up rotn pepi rol co ro futnio riabav emst xhaeotnirai gas ermht um at ngi ust oni injection ust and xhae sy volt onsi the sensors cont ust catalyst wlo tim eet gen haxe ndeil fuel sp washctsyal cy exhacni catfi fuel ltipum eslvav xhae onictjeni ry s/trar arkps ro M tial edzimi le upledo withdl catalysd catd odim bustmocd to oxy ersalv es dualvidi rottlethcin tivep croprocessim en ssisted ltip opt- free nda fo rbeo r-a easer prove ectell negi prove EPA Dual Uni In Ada Electro Faster Sequ Ai Mu Heat Leak- Close-c Seco Mani Ads Inc Im Retarded Ful En Im s or n noiat onipt Technologiy um sens rol sm sato s ontc s s rculi Likel gen systel esuq jectioni s s shcaw rec el oxy system sro emst pepi s system onscloi system ure gas crevicerebm ceu Most of srosn gas eluf-rair rotn rol co hnicet futnio ectjin sy ust emst cha sy catalysts start loading ust ust xhae oni se haxe ndeil cont oni A cy fuel rottlethcin ratbi ltipum ust catalysts injectors fuel 9991 cal tial fuel edzimi sorberda engine xhae heated redotsng upledo bonr catalystd eratpmet-hghid exhacni ustionbm ro desi co Estimates Ante BRAC engyxolauD onitcudnid ersalv dualvidi tivep negi en opt- free ectjniraicri prove ect easer prove ectell negi esmu EPA a; Uni In Ada Electro En Sequ Heated Air-assisted Im Heat Leak- Close-c El Electrically Hydroca Inc Im Abbreviated Ful En Reduced vol 98 Ex pe rof 19 Respectively Ty 6-5 es E ogy ogi nol nol elufgniv ization yer d based BRAC out rol atom pro livedd terr hance nceamrof ne TABL Standards, Tech Tech im cont Fuel an En catalytic conve per duceeR engi issionsme ces:r Sou
From page 188...
... EPA noted in its Tier 2 rule-making that manufacturers were already certifying vehicles below the level of the Tier 2 evaporative emissions standards; the RIA for the Tier 2 rule-making includes only an abbreviated discussion of evaporative emission-standard technical feasibility. The remaining assessments will focus on the exhaust emissions standards.
From page 189...
... . For model-year 1999, 48 of approximately 400 engines included at least one vehicle configuration, mostly for passenger cars, certified to meet lifetime NOx emissions below the average of 0.07 g/mi of the proposed emission standard.
From page 190...
... Emissions and Air Quality Impacts Assessment CARB and EPA use similar tools to measure emissions and air quality impacts of proposed regulations, but to different ends. CARB used its own mobile-source emissions model, EMFAC97G, to estimate that the LEV II program would result in a reduction of 6 tpd of ROG (exhaust and evaporative)
From page 191...
... AQMDs in California, including the South Coast, include new LDV emissions reductions when they use modeling to demonstrate attainment of the NAAQS. EPA used the Tier 2 emissions model, which was similar in function to the planned (at the time)
From page 192...
... CARB and EPA consider technical feasibility by examining how a small subset of vehicles could be redesigned to achieve the proposed standards. CARB sets statewide emissions standards focusing on meeting air quality standards in the worst nonattainment area in the state.
From page 193...
... The level of emissions reduction predicted for the standard should include realistic assumptions about the amount of compliance with the program, the number of vehicles sold, and the effectiveness of controls over the life of the vehicle. If those outcomes or conditions will require additional costs, those costs must be taken into account.
From page 194...
... Sources: CARB 1990, 1996; Sierra Research 1994. TABLE 6-7 Estimated Average Cost per Vehicle to Meet California LEV Standard Compared with the Tier 1 Standard (Cost per Vehicle)
From page 195...
... 195 I ltipliedum ULEVa cost hardware nt ad ed an with .l withe cy pone aptdana onalti ovrpmi of aredpm ght 0 com ti,orezsitsoclatnemercni .it in- kr seu cost. spa -eols to each edtcejorp toro onalitdi and,gnixim tegralin aretaht Ei 0 0 0 0 20 37 5 15 33 11 teda na lsed addi no Co moII dditiona at II estimeht When.
From page 196...
... . EPA attempts to estimate costs (and emissions reductions)
From page 197...
... 197 Short: ) ry a V (6+ NLE Standards2 with Tier aredp rmtegnoLrep)
From page 198...
... 198 State and Federal Standards for Mobile-Source Emissions Estimated costs of the federal Tier 2 standards are similar to the California ULEV vehicles, as shown in Table 6-9. In fact, the Tier 2 costs were derived in part from the work that CARB had done on costs for LEV II.
From page 200...
... The cost-per-ton-reduced estimates for the ZEV mandate are higher than most other air emissions-control programs. California acknowledges that, but argues that the program has the broader goal of pushing the automakers to develop alternative cleaner technologies.
From page 201...
... Because the fleet in this year would represent a nearly complete implementation of the rule, the year would include "the maximum emission reductions (and resultant benefits) and...the lowest costs...on a per mile basis"; and therefore "the resulting benefit-cost ratio will be close to its maximum point" (EPA 1999a)
From page 202...
... 202 State and Federal Standards for Mobile-Source Emissions The emissions and air quality impacts of the rule are calculated using models like those described for environmental impacts; however, it appears that the air quality analyses were repeated specifically for the benefits analysis because the future year was different. Air quality changes included ambient ozone and PM concentrations, airborne nitrogen deposition, and visibility.
From page 203...
... 203 2 b Tierrof ) snio Benefit illm Value)
From page 204...
... States adopting the California standards would need to assess whether they would face similar or different compliance issues and costs. A final important point about the cost analyses is how emissions controls affect the price of the vehicle.
From page 205...
... ADOPTION OF LEV BY AUTHORITY OF SECTION 177 OF THE CLEAN AIR ACT In September 1990, New York became the first state to use its authority under section 177 of the federal CAA to adopt California standards by adopting CARB's pre-LEV emissions standards. In October 1991, the 13 Northeast states that were the members of the Ozone Transport Commission (OTC)
From page 206...
... . Moreover, the court held that the EPA decision unlawfully circumvented the provision in the CAA that prohibited EPA from adopting new motor-vehicle emissions standards before the 2004 model year.
From page 207...
... In each case, adoptions have been based on the conclusion that California emission standards would provide greater mobile-source emissions reductions more quickly than federal standards. That conclusion was almost certain when California's original LEV program began, since EPA was not expected to introduce more stringent Tier 2 standards, if at all, until model-year 2004, as specified in the CAA.
From page 208...
... and that the additional costs do not outweigh the emissions benefits. Novel Issues in State Adoption of California Emissions Standards Beginning with the initial adoption of LEV in the Northeast, automakers and others have objected to states' authority to adopt California emissions standards.
From page 209...
... New York had violated section 177 of the federal CAA by adopting the LEV standards before they had received a preemption waiver and without providing the 2-year lead time required by section 177; (2) New York had failed to adopt the California clean-fuel regulations in conjunction with the LEV standards in violation of the section 177 requirements that state standards be "identical" to California's and not have the effect of creating a "third vehicle"; and (3)
From page 210...
... In two decisions, the Second Circuit Court of Appeals ultimately held in favor of the state on all claims except the lead-time claim (Motor Vehicle Mfrs Ass'n v. NY Dep't of Envtl Conservation, 17 F.3d 52 [2d Cir.
From page 211...
... . In summary, state adoption of the California LEV standards resulted in a series of legal controversies.
From page 212...
... When vehicle manufacturers sued New York, alleging that its adoption of the LEV standards violated section 177, EPA filed an amicus curiae brief in the Second Circuit Court of Appeals that had a key role in the appellate court's reversal of the district court's decision that the New York ZEV mandate violated section 177 (Brief for the United States as Amicus Curiae, Motor Vehicle Mfrs Ass'n v.
From page 213...
... . EPA does have one formal opportunity to review section 177 adoptions of California standards when it approves a state SIP revision that incorporates the California standards.
From page 214...
... established by the CAA. A regional air pollution agency, Northeast States for Coordinated Air Use Management (NESCAUM)
From page 215...
... ; however, they are the best tools available to regulatory agencies for assessing emissions benefits. Furthermore, many assumptions are needed to model future mobile-source emissions; for example, sales, fleet mix in future years, types of fuels, and the evolution of vehicle technology and emissions levels.
From page 216...
... 216 as .7 33 Mobile- r CO 38 10 17 NA NA NA NA ssede pr Ove ) ex California ng onitcudeR (% s,dr x rds .2 41- .7 .8 da NO 27 26 19 0 NA 14 10 andast on Stan ssii ral Adopti .2 61- .3 deralfe Em Fede HC 16 23 20 8 15 67.
From page 217...
... study, an AAM contractor reported benefits of 7% for VOC, 14% for NOx and 14% for HAPs in 2025 when modeling Connecticut mobilesource emissions according to EPA guidelines (Air, Inc.
From page 218...
... Using the same argument as Massachusetts, New York stated that there must be additional mechanic training but that this will generate new jobs for the region. However, fewer vehicles of other types will be sold, and the mix of services needed will change for mechanics.
From page 219...
... . The legislature directed CARB to "develop and adopt regulations that achieved the maximum feasible and cost-effective reduction of greenhouse gases from motor vehicles." The Pavey bill focuses on LDVs because approximately 40% of GHG emissions in the state are estimated to come from this source.
From page 220...
... Table 6-15 displays the proposed standards, which are given in grams per mile of CO2 equivalent.11 The proposal recognized four sources of motor vehicle GHG emissions: tailpipe emissions of carbon dioxide (CO2) , methane (CH4)
From page 221...
... The CARB assessment was based on vehicle simulation and cost analysis of GHG emissions reductions contained in a report done for the Northeast States Center for a Clean Air Future (NESCCAF 2004)
From page 222...
... , which concluded that average compliance costs would be approximately $3,000 per vehicle, assuming nationwide compliance with the CARB standards, and higher than $3,000 if separate vehicles are produced for states that enforce the California standards. Sierra Research also argued that the increased vehicle prices would decrease the sales of new vehicles, slowing the introduction of cleaner vehicles into the fleet, and that lower operating costs would result in vehicle owners driving more, thus increasing emissions.
From page 223...
... The following conclusions are drawn from the information presented in this chapter on the practices and issues related to LDV emissions standards. · CARB and EPA analyses of their emissions standards are found in CARB's staff paper and EPA's regulatory impact analysis, respectively.
From page 224...
... · To date, CAA section 177 authority has been used primarily by various northeastern states to adopt California LDV standards. Manufacturers of mobile sources have raised objections to the adoption of California standards by other states.


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