EPA’S TRANSPORTATION OFFICE, EMISSIONS COMPLIANCE APPROACH, AND INTERNATIONAL HARMONIZATIONBill CharmleyOffice of Transportation and Air QualityU.S. Environmental Protection Agency

July 19, 2017

EPA’s Office of Transportation and Air QualityWho we are and what we do

EPA’s Mobile Source Control ProgramHow our compliance program works

International Cooperation and Harmonization

Overview

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To protect human health and the environment by reducing air pollution from mobile sources and the fuels that

power them.

Office of Transportation and Air Quality Mission Statement

Paper # (if applicable) 3

State of the Transportation Sector

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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

What we do

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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.

The National Vehicle & Fuel Emissions Laboratory (aka, the Ann Arbor lab)

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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

EPA Ann Arbor Lab Capabilities

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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.

Why does compliance matter?

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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

EPA Transportation Sector Compliance Obligations: Scope, Volume, and Complexity

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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)

EPA Transportation Sector Compliance Obligations: Scope, Volume, and Complexity

Model Year 1995 Certificates Post 2014 (~4,000 per year)Total = 810

LDV – 464ICI – 11Alt Fuel -205

HDDE - 57

NRCI – 506

Locomotive - 58

Marine SI - 87

Large SI - 88

Snowmobile - 26

Marine CI - 200 ATVs - 199

Small SI – 984Evap Components - 811

HDGE - 10

HMC – 380OFMC - 58

EPA Transportation Sector Compliance Obligations: Scope, Volume, and Complexity

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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

Achieving Emission Reductions

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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

Holding Manufacturers Attention

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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

Recruit, train, and empower an effective compliance team

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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

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EPA Light-Duty Vehicle Compliance Program

0 Miles 10,000 Miles

Low-mileage In-Use Verification Testing

Performed by Manufacturer

120,000 Miles(End of Useful

Life)

50,000 Miles

High-Mileage In-Use Verification Testing Performed

by Manufacturer

EPA In-Use Surveillance Testing

90,000 Miles

EPA Action

Manufacturer Action

20,000 Miles

Vehicle Design and Build

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)

EPA Follow-Up (Defect and Recall Reports, Mfr. In-Use Testing, EPA Testing)

EPA Test Data Review/Analysis CARB Coordination (Warranty Reporting)

OECA Coordination (Enforcement)

EPA Certification Preview and Pre-model

Year Reports

EPA Confirmatory Testing (Random and

Targeted)

EPA Review of Manufacturer Application

EPA Issues Certificate of Conformity

Manufacturer Emissions Vehicle

Prototype and Durability Testing

End of Useful Life (per CAA)Vehicle May Enter Commerce

Durability Review and

Approval Process

EPA Compliance Mindset

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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

Risk assessment is fundamental to our planning and to the daily work of the EPA compliance team

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Long-Term Annual Our CultureEvery 3 Years Every Fiscal Year Every Day

ParticipantsInternal and External

StakeholdersEPA Staff and Management Sector Leaders and Teams

Purpose

Prioritize EPA compliance resource

investments based on relative risk

Annual Test Planning / Budget / Staffing within a

Center/ Targetting

Myriad of individual decisions each day (certification and

compliance)

DetailComplete Detailed Risk

Assessment with Rankings

Update long-term assessment; rank to target specific high risk concerns

within each sector

Staff and Center Director's best judgment on environmental & programmatic risk

Planning Duration 6 months 3 months daily

OutputPrioritized Relative

Risks between SectorsPrioritized Relative Risks

within each SectorRelative Risk between two

choices

CD Risk Assessment Cycles

Frequency

EPA is Using a 3-by-3 Compliance Testing Strategy

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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)

Real World Driving (a.k.a PEMS Testing – Not RDE)

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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

International Cooperation & Harmonization

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Major International Forums for Vehicle Emission Standards Dialogue

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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

U.N. World Forum for Harmonization of Vehicle Regulatios

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Major Agreements Administered by U.N. WP-29

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“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

Example Global Technical Regulations developed under 1998 Agreement for Air Pollution

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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

International Harmonization Efforts: Light-duty efforts

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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.

Thank you!

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