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California ARB holding hearing on adopting amendments to LEV III to support compliance options using new Federal GHG regulations

14 September 2012

The California Air Resources Board (ARB or Board) will conduct a public hearing on 15 November in Sacramento to consider adopting amendments to the Low-Emission Vehicle (LEV III) greenhouse gas emissions standards, and additional minor revisions to the LEV III criteria pollutant and Zero-Emission Vehicle (ZEV) regulations, approved by the Board earlier this year. (Earlier post.)

The objective of the rulemaking is to follow through on the commitment made to US Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) by ARB Chairman Mary Nichols in 2011 and in Board Resolutions 12-11 and 12-21 to propose for adoption appropriate language to accept manufacturer-demonstrated compliance with the new final national passenger motor vehicle greenhouse gas (GHG) regulations for MYs 2017–2025 (earlier post) as an option to achieve compliance with California’s separate but aligned regulations for those model years.

California committed to accept national program compliance for model years 2017 through 2025 (as it did for MYs 2012 through 2016) with the understanding that it would provide equivalent or better overall greenhouse gas reductions nationwide than California’s program. EPA projects that its standards will require, on an average industry fleet-wide basis, 163 grams/mile of carbon dioxide in model year 2025. The California LEV III GHG standards pull GHG emissions down to a fleet average of approximately 166 g/mile.

ARB has continued to work with EPA to ensure that the final federal rule—issued in August—and California’s regulations are harmonized to the extent that they meet both agencies’ air quality and greenhouse gas reduction needs.

In its review of the final federal program, ARB staff determined that the final rulemaking adopts greenhouse gas standards substantially as proposed in the earlier Notice of Proposed Rulemaking (NPRM). As a result, staff recommended that the Board fulfill its first commitment by not contesting the federal standards. The current proposed amendments to California’s passenger motor vehicle regulations fulfill the second commitment made by California and the direction of the Board to enable accepting manufacturer-demonstrated compliance with the federal regulations for the 2017 through 2025 model years.

The national greenhouse gas program for the 2017 through 2025 model years is marginally less stringent than California’s program due to differences between the two programs in their treatment of advanced technology vehicles and the application and calculation of credits for improved air conditioning systems, off-cycle technologies and hybridization of full-size trucks, ARB staff notes.

  • Treatment of Advanced Technology Vehicles. Since California requires the production of zero emission vehicles (e.g. plug-in hybrid electric vehicles, battery electric vehicles, and fuel cell vehicles), LEV III provides a performance-based, technology neutral approach for these ultra-low greenhouse gas technologies by assigning upstream emissions to these technologies when demonstrating compliance to the greenhouse gas requirements. However, the federal program, which does not require the production of these zero emission technologies, provides a temporary incentive for their production by assigning an upstream emission factor of zero.

    Specifically, for the 2017 through 2022 model years, an upstream emission factor of zero applies to all qualifying vehicles. For the 2022 through 2025 model years, the use of zero grams per mile CO2 is limited to the first 600,000 combined plug-in hybrid electric vehicles, battery electric vehicles and fuel cell vehicles for a manufacturer that sold 300,000 or more plug-in hybrid electric vehicles, battery electric vehicles and fuel cell vehicles combined in the 2019 through 2021 model years, and 200,000 for all other manufacturers. Net upstream emissions would be accounted for vehicles exceeding these caps.

    In addition to the zero upstream emission provision, the federal program provides an additional incentive to advanced technology vehicles such as plug-in hybrid electric vehicles, battery electric vehicles, and fuel cell vehicles, dedicated natural gas and dual fuel natural gas vehicles in the form of a vehicle multiplier (i.e., each vehicle would count as more than one vehicle when determining compliance with the greenhouse gas requirements). These vehicle multipliers apply to model years 2017 through 2022 with higher values assigned to plug-in hybrid electric vehicles, battery electric vehicles and fuel cell vehicles and lower values assigned to natural gas vehicles. These vehicle multipliers decrease over time.

  • Indirect Air Conditioning Credits. Manufacturers may receive credits for improving the efficiency of vehicle air conditioning (A/C) systems. The amount of credit available for different efficiency technologies is listed in a credit menu and manufacturers may claim up to a 5.0 grams carbon dioxide-equivalent per mile (gCO2e/mile) for cars and 7.2 gCO2e/mile for trucks. The LEV III rule, as approved 26 January 2012, contains the same credit structure as the final rule for the 2017 through 2025 model year national greenhouse gas program.

    However, based on further testing and comments from manufacturers on the NPRM, EPA made minor modifications to the process by which manufacturers qualify for indirect A/C credits. The primary change made by EPA was to allow manufacturers to test only those vehicles for which they are seeking indirect A/C credits, with no requirement to compare those vehicles with improved A/C systems to baseline vehicles through model year 2019.

    The primary differences between the ARB and EPA programs are largely limited to the first three years of the program, with the ARB program requiring a slightly higher bar for credit qualification during that period. The total number of indirect A/C credits available to manufacturers through each program remains equivalent.

  • Off Cycle Credits. Similar to the A/C provisions, off-cycle credits can be used by manufacturers to offset some tailpipe emissions and thus provide additional flexibility for achieving compliance with the CO2 standards. In their final rulemaking for the 2017-2025 model year national greenhouse gas program, EPA refined the off-cycle credit program based on additional testing and simulations. These refinements did not change the overall structure of the off-cycle credit program nor the total number of credits available, but did change how the credits are calculated for several technologies and the amount of credits available for a small number of individual technologies.

    The two off-cycle credit programs are largely identical given that the structure of the two programs has not changed and manufacturers may only claim a maximum of 10 gCO2e/mile off-cycle credits regardless of which accounting mechanism is used.

  • Full-Size Truck Credits. The full-size truck provisions provide special emission-reduction credit for the use of mild- and strong-hybrid technology in order to incentivize the widespread adoption of these technologies. Because full-size pick-up truck hybrid technologies are still in their infancy, in their final rulemaking for the 2017 through 2025 model year national greenhouse gas program EPA slightly loosened the qualification requirements for hybrid truck credits, primarily by decreasing the minimum percentage penetration requirements for mild hybrids by 10% for each of the first two years of their program, model years 2017 and 2018. Because full-size hybrid truck technologies are not in widespread use and the loosening of the penetration requirements applies for only the first two years of the federal program, the final federal full-size truck provisions can be considered sufficiently equivalent to those in LEV III.

  • Motor Vehicle High Leak Disincentive. Both the ARB and the USEPA programs include credits and disincentives that encourage manufacturers to employ A/C systems having low refrigerant leak rates. The effect of those differences is that under the ARB program, A/C systems must have lower leak rates than required under the EPA program in order to avoid the high leak disincentive or to minimize it to a given level.

    Although ARB’s program is more stringent, staff believes that inclusion of high leak disincentives provided by the EPA program offers substantial benefits compared to having no high leak disincentive. For this reason, staff believes the lesser stringency of the federal requirement compared to California’s requirement does not negate the substantial benefits and advantages of having a single unified program.

Staff determined that the differences in the federal credit scheme for select technologies are largely limited to the early years of the program and will have a minimal impact on greenhouse gas emission reductions from the light-duty fleet. ARB staff estimated that the combined impact of these federal provisions would result in a 4.5% loss of accumulated CO2 emission reductions in California in 2025.

The proposal makes minor changes to ARB’s regulations. In general these proposed changes correct errors, and update procedures to reflect information received since adoption of the regulations in January, 2012.

ARB staff is not proposing to amend the regulations to be identical to the final National Program. For example, ARB’s regulation would continue to treat upstream emissions differently than the final National Program.

In practice, most if not all manufacturers are expected to use compliance with the national rule to satisfy California requirements. However a manufacturer may choose to comply with the ARB requirements, and the ARB regulation would remain in place in the event the National Program ceases.

Adoption of the proposal would not eliminate the reporting requirements for California. Specifically, a manufacturer will still be required to submit emission testing data and sales data for California and each of the Section 177 states (states adopting California emissions standards) in sufficient detail to allow staff to verify the manufacturer’s average greenhouse gas levels for each model year. In addition, staff is also proposing minor revisions to the LEV III criteria pollutant regulations and the ZEV regulations to correct errors and to clarify the regulations.

Resources

  • Staff Report: Initial Statement of Reasons

  • LEV III” Amendments To The California Greenhouse Gas And Criteria Pollutant Exhaust And Evaporative Emission Standards And Test Procedures And To The On-Board Diagnostic System Requirements For Passenger Cars, Light-duty Trucks, And Medium-Duty Vehicles, And To The Evaporative Emission Requirements For Heavy-Duty Vehicles (August 2012)

September 14, 2012 in Climate Change, Emissions, Hydrogen Storage, Policy | Permalink | Comments (15) | TrackBack (0)

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Comments

Increasingly, these rather arbitrary changes and concessions bear no reflection any reality other than the theologians counting angels on the head of a pin did.

North America sequesters all its CO2 and then some emitted in North America by man or Nature, so why are we concerning ourselves or doing anything about CO2 reductions? Even though not a signatory, the USA has met the terms of the Kyoto Treaty requesting CO2 be reduced to 1990 levels that Herr Dr Hansen wanted, to save the World from the mystical and mythical CAGW, already.

Arbitrary credits for HVAC refrigerants are nothing more than indulgences being bought and sold, and constitute bureaucrats job justifications nothing more.

I support the reduction to Lev II SULEV II or T2B2 levels. I also support the evaporation regulations that transform the ICE auto into a category originally created to measure EV emissions, ie a ZEV. Period.

That is the only thing in all this nonsense worth anything.

Regulations must be assessed with attention to economic competitiveness of the State or the Nation. Too high regulatory burden will increase the cost of doing business, the cost of living, and will drive businesses elsewhere and will lead to job loss.

All members of a Free-Trade pact must have similar level of regulations in order to maintain a level playing field for all businesses and manufacturers within the Free-Trade pact. Tariffs should be assessed for products made from countries with less regulatory burden in order to maintain a level playing field for all manufacturers from all countries.

Roger there is job opportunity for your style of smoke and mirror calculations in California.

The real issue will be getting consumers to accept and actually buy Level III LEV.

North America sequesters all its CO2 and then some emitted in North America by man or Nature
And we know that if D ever produced a cite for this, it will turn out to have been debunked years ago and the paper likely retracted.

Once more, dear friends into the breach: her is the never refuted, and but one of a number of actual genuine scientific papers, peer reviewed, and published.

http://www.sciencemag.org/content/282/5388/442.abstract

I know the science illiterates here EP excepted, whose only acquaintance wiht genuine Science comes from the propaganda scribblings of the WWF, or the exhortations of that ignorant lout who claims to have actually attended and passed a single Science course in his life, the wonder, self-proclaimed inventor of the Internet and CAGW, the AlGorean. (Don't forget his autobiography was filmed as "Love Story", too.)

It really irritates me as; I did actual work with BBN designing the protocols for the Internet and later for the ISO comm protocols; and that fat fool was nowhere to be seen.

KP stated: "The real issue will be getting consumers to accept and actually buy Level III LEV."

Don't worry, KP. By then, batteries will cost 1/2 to 1/3 of today's cost. FCV's will be around in good numbers. Most people will drive PHEV's or BEV's or FCV's based on economical factor alone (lower fuel cost and lower maintenance cost). Gasoline vehicles may not meet such a stringent PM level of 1mg/mile and future HCHO emission. They (ICEV's) will need gasoline particle filter and better catalysts, or Natural Gas will take over, since NG vehicles have much lower level of PM emission and HC emission. I would predic that NG and H2 will take over gasoline and diesel as the fuel of choice for ICEV's or ICE-HEV's because it will cost less to meet very stringent LEV III and future EPA emission standards. It is a no-brainer to see that NG, as motor fuel, will reduce the fuel cost of motorists to 1/2 to 1/3 that of gasoline and diesel today.

Mercedes-Benz is now coming out with a real neat NG-powered car with decent power, fuel economy and no compromise in internal space. Cheers!

Quoth the D student:

Once more, dear friends into the breach: her is the never refuted, and but one of a number of actual genuine scientific papers, peer reviewed, and published.

http://www.sciencemag.org/content/282/5388/442.abstract

I predicted it would be "debunked years ago", and I got it in one (debunked in 2000):

http://www.sciencemag.org/content/287/5460/2004.abstract

US carbon sinks around 0.25 gigaton/yr, compared to emissions of well over 1 GT/yr.

I have to agree with E-P. The following quote is from prestigious, non-partisan authors and institutions:

"Atmospheric- and ground-based studies indicate that the carbon sink in the coterminous United States accumulated 0.37–0.71 Petagram Cy1 on average during the decade of the 1980s (1)." See:
http://www.pnas.org/content/99/3/1389.full.pdf

However, theUS total carbon emission was 1.64 Petagram in even economically-depressed year 2008, accordin to UN estimates. See:
http://en.wikipedia.org/wiki/List_of_countries_by_carbon_dioxide_emissions

Conclusion: Total US fossil carbon emission exceeded total US carbon sink by 4 folds!!! Ouch!!!

And this discrepancy is going to get worse, because, according to my first reference, increasing forest fires, droughts, flooding, deforrestation, and increase soil temperatures will significantly reduce the effectiveness of the carbon sink! Unless, of course, that we will progress toward largely renewable energy and nuclear energy for power generation and transportation.

“Don't worry, KP. ”

I am not worried about California since it has been twenty years since the looney politics drove my job out of state. I heard the same fantasies twenty year ago that Roger echoes now.

I am not worried when loons fail to solve a problem they do not have. Twenty years ago some places in California did have an air pollution problem. Air quality is much better now thanks to improvements in the ICE not the adoption BEV.

Also do not expect NG to become a major player but that is the Pickens Scam fantasy.

“It is a no-brainer ”

Really! Then everyone would be doing it sans government coercion.

Government coercion is the only thing preventing a mass shift to NGVs; the fee to certify a conversion shop to change ONE model year of ONE model over to CNG is in 6 figures.

Several truck-stop chains have announced cooperation with suppliers of LNG.  This is a change that WILL happen, because even at historical high prices for NG, it is still half the price per BTU of ULSD.

“because even at historical high prices for NG, it is still half the price per BTU of ULSD. ”

Really! NG is not anywhere near historic highs but is low relative to the cost of production which means it is the long term trend is up. Again we have to look at the payback period for investing in something that may lower fuel costs. At the current price of natural gas, producers are losing money and the rig count is going down. At the current price of a new NG truck it is hard to justify the investment. Conversions are even harder to justify.

@KP,
NG is domestic fuel while petroleum is 50% imported. So, the conversion of the fleet to NG is something that needs be done at any cost! This is of strategic and military importance. This is far more important than raising the defense budget. In fact, some of the currently huge defense budget should be diverted to finance the mass conversion of the HDV fleet to NG. The payback saving can be funnelled back to the national gov. budget. Imagine this: If the Hormuz strait is closed, and the petroleum pipeline is severed, how are we gonna maintain our economy that is so dependent on foreign oil? Wanna see a repeat of 2008 economic collapse?

Twit P.'s studied obtuseness is very funny.  Take NG vs. diesel.  Diesel, at 140 kBTU and $4.10 per gallon at the pump, costs around $29 per million BTU.  The historic peak for wholesale NG was about $15/mmBTU and it's currently going for about 1/5 of that.  Yet he thinks it's not attractive?

While he makes excuses, Kenworth and Peterbilt are adding a Cummins Westport NG engine to their list of options.  What he says isn't going to happen, is happening.

“This is of strategic and military importance. ”

BS! One of the first things I learned as a navy officer was a questioning attitude.

“If the Hormuz strait is closed, ”

And who has the ability to do that? It will take about 15 minutes for a carrier task force to destroying Iran's naval and air forces. You can strap pipe bombs on children and put them in a row boat but asymmetric does not work at sea. Right now the world is looking for the slightest provocation to go into Iran and destroy there enrichment facilities.

“Wanna see a repeat of 2008 economic collapse? ”

I want Roger to stop the childish manipulation.

Aside from the Picken's scam, I do not know many fleet managers who are making anything but a token purchase of into NGV.

First E-P complains about barriers to NGV, then he posts a link to the availability of HDNGV.

“Yet he thinks it's not attractive? ”

Yes, but that is because I checked the cost of new HDNGV. E-P is really stupid for saying the price of NG is low and then reminding them of the recent past. With a booming economy increasing the demand for NG will increase as will the demand. People who make business decisions know this.

Roger's plan is to let clueless government types spend out tax dollars like the well will never run dry.

I am all for PTC and incentives to build wind farms because it moderates the price of NG not exacerbate it.

“If the Hormuz strait is closed, ”

And who has the ability to do that? It will take about 15 minutes for a carrier task force to destroying Iran's naval and air forces.

No navy or air force required.  It takes one mine or small boat loaded with explosives to do to a supertanker what was done to the USS Cole.  With a bit of luck, they'll get a massive oil slick AND a fire.  Do it in the straits and navigation becomes impossible, and Iran retains plausible deniability.

Of course, all they have to do is have mines start turning up and the oil tankers become uninsurable, so they won't go to the straits anyway.  Iran doesn't actually have to blow anything up.

First E-P complains about barriers to NGV, then he posts a link to the availability of HDNGV.
Yet it's ridiculously expensive to buy a CNG Honda Civic, and there's a massive lack of CNG fueling stations.  The EPA effectively bars conversions by pricing them out of the market.  Those barriers are real.
E-P is really stupid for saying the price of NG is low and then reminding them of the recent past. With a booming economy increasing the demand for NG will increase as will the demand.
You missed the fact that NG was about half the per-BTU price of ULSD at its peak.

The kicker is that NG at $15/mmBTU is priced out of the electric market.  However, that makes nuclear look really, really good.

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