Assessment of Technologies for Improving Light-Duty Vehicle Fuel Economy—2025-2035 (2021) / Chapter Skim
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12 Regulatory Structure and Flexibilities
12 Regulatory Structure and Flexibilities
Pages 334-364
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From page 334... ...
In the late 1980s, Congress relaxed both the passenger car and light truck standards by a few MPG but returned to 27.5 MPG for passenger cars by 1990 and to 20.7 MPG for light trucks by 1996. From 1996 until 2004, standards stayed flat.
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From page 335... ...
(GWP) pollutants EPCA, EISA, and CAA, withdrawal of California Passenger cars waiver 2021–2026: 1.5%/year increase Light trucks 2021–2026: 1.5%/year increase Major regulatory features • Agreement for one national program including DOT, EPA, but eliminating CARB GHG regulations • Footprint-based standards • Fuel economy: • Continuation of fleet average fuel economy, passenger car and light truck fleets, domestic fleet, and compliance by fleet average fuel economy, credits, or fines • EISA: Maximum feasible fuel economy for each MY, for at least 1 but not more than 5 MYs at a time • GHG: • Credit earning, banking, and trading based on GHG performance, on advanced technologies, on off-cycle technologies, and on low GWP pollutants NOTE: Years reported in model year (MY)
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From page 336... ...
, making consistent regulations across markets desirable. 12.2 MEASURING FUEL ECONOMY AND GHG EMISSIONS 12.2.1 Discrepancies with Real-World Fuel Consumption It has long been recognized that the combined city and highway test cycle estimates on which compliance with fuel economy and GHG standards are based are neither accurate nor unbiased estimates of what is achieved in actual vehicle use (McNutt et al., 1978)
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From page 337... ...
Most vehicles now monitor their own fuel consumption and can report fuel economy estimates to the driver, log estimates in the onboard vehicle diagnostic, or even send them back to the manufacturer via an internal internet connection. There are issues with the accuracy of onboard estimates, but they are relatively small and solvable (e.g., Posada and German, 2013)
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From page 338... ...
Provided that off-cycle credits are assigned accurate values representing real-world benefits of the technologies in terms of reducing fuel consumption and GHG emissions, they offer a mechanism of correcting for the inability of the test conditions to simulate real-world operation. However, in practice it is difficult to accurately estimate the real-world benefit, or verify whether the fuel consumption and GHG reductions assigned by the credits are realized on the road.
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From page 339... ...
Furthermore, the submis sion of off-cycle applications, and the agencies' approval process, is often done on an ad-hoc basis. FINDING 12.3: Telemetric technologies exist that would allow agencies to collect fuel consumption and emissions data from vehicles on the road.
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From page 340... ...
. 12.2.3.3 Fuel Cell Vehicles As with BEVs, fuel cell electric vehicles (FCEVs)
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From page 341... ...
The fuel economy and GHG standards are quantity-based policies that determine the rate of fuel consumption or emissions per mile traveled. In contrast, a price-based policy affects the cost of emissions or the cost of using a technology that depends on its emissions.
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From page 342... ...
Emissions reduction is one of the three primary goals of the CAFE/GHG regulations. When considering all three goals of fuel consumption, energy, and emissions reduction, there are other policies that relate to and influence the light-duty sector's impact on these goals.
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From page 343... ...
. Regulating fuels can provide meaningful GHG emissions reductions, with an analysis of California's Low Carbon Fuel Standards finding them resulting in a 10% reduction in CO2 in California's transportation sector (Huseynov and Palma, 2018)
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From page 344... ...
. While this analysis found the vehicle's use-phase to still contribute 87%–95% of life cycle GHG emissions, the choice of lightweighting material did still matter, with it taking longer for use-phase emissions reductions to offset the added manufacturing emissions for aluminum than for high strength steel.
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From page 345... ...
EPA credits GHG emissions and NHTSA credits fuel economy, but fuel economy credits can be traded across vehicles after converting to fuel consumption. In the CAFE program, firms can pay a penalty for non-compliance 2 A manufacturer's sales-weighted harmonic mean fuel economy is equal to the inverse of the sales-weighted arithmetic average of rates of fuel consumption.
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From page 346... ...
These GHG emissions are referred to here as CO2 emissions for shorthand. bThere are also some restrictions by NHTSA on transfers and trades between imported and domestically produced car fleets and truck fleets.
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From page 347... ...
Therefore, if the regulator is setting standards separately for cars and light trucks, and if marginal costs are expected to be higher for light trucks than for cars, the regulator would impose weaker standards on light trucks than cars (in this case, weaker means a lower fuel economy and higher GHG emissions rate conditional on footprint)
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From page 348... ...
FINDING 12.4: Compared to setting separate fuel economy and greenhouse gas standards for cars and light trucks, a single standard across cars and light trucks would reduce the total societal costs of achieving a particular level of fuel consumption or emissions, if cross-class trading is included. Equivalently, a single standard would cause greater fuel consumption and emissions reductions than separate standards that have the same cost as the single standard.
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From page 349... ...
Figure 12.4 shows the industry average GHG emissions (blue bars) and standard (green bars)
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From page 350... ...
200 10 Credits/Deficits (Tg) GHG Emissions 100 5 0 0 -100 -5 -200 -10 -300 -15 Standard Achieved Credit/Deficit FIGURE 12.5 GHG emissions achieved, standards, and credits/deficits by manufacturer: 2018.
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From page 351... ...
. SOURCE: Committee generated using data from EPA Automotive Trends Reports and Manufacturer Performance Reports.
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From page 352... ...
, which makes evaluation of manufacturer compliance costs more difficult. RECOMMENDATION 12.3: The National Highway Traffic Safety Administration should publicly report credit trade quantities and prices between manufacturers.
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From page 353... ...
These estimates are the basis for crediting lifetime GHG emissions in the EPA program and for trading fuel economy credits in the NHTSA program. New technologies like CAVs could affect vehicle use, as well as the timing and magnitude of fuel consumption/emissions changes.
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From page 354... ...
. 12.4.1 Fuel Efficiency and Alternative-Fueled Vehicles Several other jurisdictions have taken, or announced plans to take, aggressive regulatory actions to improve light-duty vehicle fuel economy and to advance ZEV technologies such as BEVs.
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From page 355... ...
. Starting from 2012, vehicle manufacturers need to meet the productionweighted corporate average fuel consumption (CAFC)
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From page 356... ...
. average fuel consumption of Chinese ICE passenger vehicles continues to decrease, despite increases in vehicle footprint, weight, and power and the CAFC compliance flexibility with NEV sales, as shown in Figure 12.10.
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(#) = value in 2013 FIGURE 12.10 China's ICE vehicle fuel consumption, curb weight, footprint, average power, and displacement over 2013–2018 (normalized to 2013 level)
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From page 358... ...
. 12.4.1.4 Japan Japan's current fuel efficiency standards for passenger cars were adopted in 2009 and took effect in 2020.
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From page 359... ...
market and valuable learning experience for incentivizing consumer adoption of electric vehicles. RECOMMENDATION 12.4: The 2025–2035 Corporate Average Fuel Economy standard should be set and designed to depend on and incentivize a significant market share of zero-emission vehicles (plug-in hybrid electric vehicles, battery electric vehicles, and fuel cell electric vehicles)
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From page 360... ...
RECOMMENDATION 12.5: The National Highway Traffic Safety Administration should continue to align the Corporate Average Fuel Economy program with the U.S. Environmental Protection Agency greenhouse gas emissions program for light-duty vehicles, seeking to reduce or eliminate any inconsistencies between the programs.
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From page 361... ...
2012. "2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards." Federal Register 77(99)
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2016. Alternative fuel vehicle adoption increases fleet gasoline consumption and greenhouse gas emissions under United States corporate average fuel economy policy and greenhouse gas emissions standards.
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From page 363... ...
2020a. Measures for the Parallel Administration of the Average Fuel Consumption and New Energy Vehicle Credits of Passenger Vehicle Enterprises.
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From page 364... ...
2019. Quest for control of fuel consumption and CO2 emission in Indian passenger cars -- an analysis of the progress and prognosis.
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