Truck & Off-Highway Engineering - February 2023 - 2

EDITORIAL
EDITORIAL
Bill Visnic
Editorial Director
Bill.Visnic@sae.org
Response to more-rigid NOx and GHG regs
In the waning days of 2022, the U.S. EPA
delivered news that likely dimmed the
good cheer of the season for many manufacturers
in the heavy-duty (HD) truck
industry. Not that it was unexpected, but
the agency's final rule on HD diesel engine
NOx emissions is stringent - more
than 80% stricter than current standards
and covering a wider range of engine
operating conditions. The new limits
begin with model year 2027 HD trucks.
The " two-phased approach " first increases
stringency in NOx emissions
from 0.2 to 0.035 g/bhp-hr by 2027 and
again from 0.035 to 0.02 g/bhp-hr in MY
2031 - a 90% reduction in total. The new
rule also increases useful life of governed
vehicles by 1.5 to 2.5 times and extends
emissions-related warranty requirements
by 2.8 to 4.5 times, the EPA says.
The new low-NOx standards are part
of the EPA's Clean Trucks Plan (CTP)
that also includes " Phase 3 " greenhouse
gas (GHG) standards for HD vehicles
beginning in MY 2027. The proposal for
Phase 3 is due in March, with the final
rule expected in December 2023.
Despite the deep NOx reductions, the
CTP rule remains less demanding than
California Air Resources Board's (CARB)
HD Omnibus regulation, which tightens
NOx limits to 0.050 g/bhp-hr from 2024
and to 0.02 g/bhp-hr from 2027.
" We're very excited about [EPA's new
standard, but] the two rules aren't the
same, " Bill Robertson, CARB vehicle
program specialist, said at the recent
SAE Government/Industry Meeting in
Washington, DC. " We recognize that
having a single national program does
have a lot of benefits to production and
cost of administrating programs and
managing parts and designs. We're interested
in where that alignment discussion
can go. "
While manufacturers overwhelmingly
desire a unified national standard - and
the new EPA limits move much closer to
that goal - " excited " is not the word to
describe how the Truck and Engine
Manufacturers Association (EMA) sees
2 February 2023
the situation, particularly when factoring
in GHG Phase 2 in 2027 and Phase 3
beyond that.
" We believe the NOx rule will require a
little bit of fuel consumption, which increases
greenhouse-gas emissions. So,
the 2027 GHG standard will become
more challenging, " Timothy Blubaugh,
executive VP at EMA, said at the SAE G/I
Meeting. GHG Phase 3 must consider
impacts of the new ultra-low NOx regulation
to ensure its success, he added.
Regardless of the stances policymakers
or manufacturers take, it's the purchasing
decisions of fleets that ultimately
will determine the success or failure of
the new standards.
" Diesel is dominant because of its reliability
and its durability. A diesel engine
can last a million miles, and it can be rebuilt
to extend its life, " Blubaugh said. " If
trucking fleets look at the product we're
providing them and it's too expensive or
costs too much in operation, they may
simply decide to invest in maintaining
their existing vehicles longer. This is not
something we want because we need to
sell our products to recoup our investments,
and it's not what the EPA wants. "
Without fleet turnover, older generations
of diesel technology with relatively
higher emissions stay in service longer,
negatively impacting air quality.
Unintended consequences - that's a
lesson learned from the last time EPA
enacted stricter NOx standards for HD
highway engines, phased in from 20072010.
" What happened in 2009-2010?
Lots of people bought lots of engines
right before the rules, " said Aymeric
Rosseau, director of vehicle and mobility
systems at Argonne National Laboratory.
History could be repeated in 2027.
Rosseau noted the hit to fuel efficiency
when engineering to reduce NOx emissions:
" Because of this 1- or 2- or 3-percent
efficiency loss that you may get,
that's hundreds of thousands of dollars
[to fleets]. "
And business is business, after all.
Ryan Gehm, Editor-in-Chief
Ryan Gehm
Editor-in-Chief
Ryan.Gehm@sae.org
Lindsay Brooke
Senior Editor
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Chris Clonts
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Matthew Wolfe
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Steven Ashley, Sebastian Blanco,
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Paul Weissler
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TRUCK & OFF-HIGHWAY ENGINEERING
Truck & Off-Highway Engineering - February 2023

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