State of California - California Air Resources Board

State of California
AIR RESOURCES BOARD
Final Statement of Reasons for Rulemaking,
Including Summary of Comments and Agency Responses
PUBLIC HEARING TO CONSIDER AMENDMENTS TO ADOPT REDUCED EMISSION STANDARDS
FOR 2007 AND SUBSEQUENT MODEL YEAR
NEW HEAVY-DUTY DIESEL ENGINES
Public Hearing Date: October 25, 2001
Agenda Item No.: 01-8-1 Table of Contents
I. GENERAL 1
II. SUMMARY OF COMMENTS AND AGENCY RESPONSE 3
III. GENERAL 4
IV. ANALYSIS OF TECHNICAL ISSUES 5 A. Fuel 5
1. Need For Low Sulfur Diesel Fuel 5
a. Engine and aftertreatment system technology is integrally linked
to diesel fuel sulfur levels. 9
b. Cap standard for diesel fuel sulfur levels versus average
standard. 12
c. 5 ppm cap on diesel fuel sulfur levels. 14
d. Availability of ultra low sulfur fuel for Tier 2 light-duty
engines and vehicles. 16
2. The New Diesel Fuel Sulfur Standard Should Be Effective No Later Than
January 1, 2006. 17
3. Low Sulfur Nonroad Diesel Fuel. 21
4. Diesel Fuel Issues Outside of California. 24
5. Other Fuel Related Issues. 30
B. Emission Standards 38
1. Heavy-Duty Diesel Engine and Vehicle Standards 38
a. Technologically feasible demonstration. 40
(i) NOx and PM Standard 46
(ii) Optional combined NMHC+NOx standard. 53
(iii) Formaldehyde standard. 54
(iv) Issues with Major Systems Components 56
(v) Trap/Adsorber System Issues 65
(vi) Technological Feasibility of Proposed NOx and NMHC Standards for
Alternative-fueled Engines 67
(vii) Natural Physical Limitations of Emission Control Systems
68
b. Period of stability for introduction of the new standards. 69
c. Phase-in of NOx, NMHC and formaldehyde standards. 70
(i) NOx standard implementation. 76
(ii) Emission standards level and emission benefits. 78
(iii) Phase-in. 80
(iv) Alternative technologies. 82
2. Heavy-Duty Gasoline Engine And Vehicle Standards 84
a. Nationwide availability and use of California Phase III
reformulated gasoline, with a 30-ppm sulfur cap, to meet the proposed
2007 HDG Standards. 86
3. Closed Crankcase Requirement. 87
4. Technology Review. 89
5. Non-Conformance Penalties. 90
C. Supplemental Emission Tests 90
1. Technologically Feasibility of the Proposed Supplemental Emission
Requirements and Tests. 95
a. NTE caps. 100
b. SSS (Euro III) 106
c. Mystery Points/MAELs 108
d. Load response test 108
e. Expanded ambient conditions 108
f. Stringency impact of the new defeat device definition 112
g. Cost-effectiveness of the SERTs. 114
2. SERTs for 2007 and Later Model Year Engines. 114
D. Compliance And Other Issues 115
1. Averaging, Banking & Trading Program. 115
a. NOx and PM credits rounded to 0.01 megagram. 118
b. AB&T emission caps levels. 118
2. Requirements for Allowable Maintenance Procedures. 119
3. OBD Requirements 120
4. Voluntary Retrofit Program 121
5. Labeling Requirements for Vehicle Manufacturers. 121
6. Special Provisions For Intermittently Regenerating Aftertreatment
Devices. 122
7. Urban transit bus standards. 123
8. In-use compliance program. 130 V. HEALTH EFFECTS ANALYSIS 130 A. Health Effects Of Ambient PM And Diesel PM 132
B. Cancer Effects Associated With Diesel Exhaust 133
C. Non-Cancer Effects Of Diesel Exhaust 135 VI. COST ANALYSIS 136 A. Economic Impact and Cost Effectiveness Analysis 137
1. Development Cost Analysis 138
2. Hardware Costs Analysis 141
3. Operating Cost Analysis 145
4. Cost Effectiveness Analysis 147 VII. INVENTORY/MODELING ANALYSIS 148
VIII. LEGAL ANALYSIS 150 A. Due Process of Law. 150
B. Technologically Feasible and Cost Effective. 154
C. Lead Time and Period of Stability. 156
D. Arbitrary and Capricious. 158
E. Statutory Authority - "Not To Exceed" Requirements And Other
Supplemental Emissions Requirements And Tests. 159
F. Statutory Authority - Definition of "Defeat Device." 162
G. Unconstitutional. 162
H. Promulgate and Enforce the Proposed High Altitude Requirements.
163
I. Context of EPA Rule. 164
J. Applicability. 167
ABT Averaging, banking, and trading
AECD Auxiliary emission control device
ALA American Lung Association
AMG AM General Corporation/Hummer (also referenced as GEP)
ANPRM Advanced notice of proposed rulemaking
APBF Advanced Petroleum Based Fuels
API American Petroleum Institute
ARB Air Resources Board
ASTM American Society for Testing and Materials
BOTD Ball-on-Three-Discs
bsfc Brake specific fuel consumption
BSNOx Brake specific NOx
BSPM Brake specific PM
CAA Clean Air Act
CalEPA California Environmental Protection Agancy
CASAC Clean Air Scientific Advisory Committee
CCR California Code of Regulations
CCV Closed crankcase ventilation
CDPF Catalyzed diesel particulate filter
CETC California Electric Transportation Coalition
CF Correction factor
CO Carbon monoxide
CO2 Carbon dioxide
COV Coefficient of variance
CRC Coordinated Research Council
CVS Constant volume sampling
D.C. District of Columbia
DDC Detroit Diesel Corporation
DECSE Diesel Emissions Control Sulfur Effects
DNPR Diesel NOx Particulate Reduction
DOC Diesel oxidation catalyst
DOE Department of Energy (also see U.S. DOE)
DPF Diesel particulate filter
EGR Exhaust gas recirculation
EMA Engine Manufacturers Association
EPA Environmental Protection Agency (also see U.S. EPA)
ESC European stationary cycle
FEL Family emission limit
FR Federal Register
FSOR Final Statement of Reasons
FTP Federal Test Procedure
g/bhp grams per brake horsepower
g/bhp-hr grams per brake horsepower-hour
GVWR Gross vehicle weight rating
H2S Hydrogen Sulfide
HAD Health Assessment Document
HD Heavy-duty
HDDE Heavy-duty diesel engine
HDDV Heavy-duty diesel vehicle
HFRR High Frequency Reciprocating Rig
IARC International Agency for Research on Cancer
ISOR Initial statement of reasons (staff report)
lb/bhp pounds per brake horsepower
LRT Load response test
MAEL Maximum allowable emission limits
MAF Mass air flow
MECA Manufacturers of Emission Controls Association
MSTD Monterey-Salinas Transit District
MY Model year
NCP Non-conformance penalty
NIOSH National Institute of Occupational Safety and Health
NMHC Non-methane hydrocarbon
NMMAPS National Morbidity, Mortality, and Air pollution Study
NOx Oxides of nitrogen
NO Nitrogen oxide
NO2 Nitrogen dioxide
NPRM Notice of proposed rulemaking
NRDC Natural Resources Defense Council
NTE Not to Exceed
NVFEL National Vehicle and Fuel Emissions Laboratory
OBD On-board diagnosis
OEHHA Office of Environmental Health Hazard Assessment
OTAQ Office of Transportation and Air Quality
PM Particulate matter
ppm Parts per million
RIA Regulatory impact analysis
ROG Reactive organic gas
S Sulfur
SAE Society of Automotive Engineers
SCAQMD South Coast Air Quality Management District
SCR Selective catalytic reduction
SERT Supplemental emission requirement and test
SLBOCLE Scuffing Load Ball-on-Cylinder Lubricating Evaluator
SOx Oxides of sulfur
SO2 Sulfur dioxide
SO3 Sulfur trioxide, or sulfur (VI) oxide
SOP Statement of Principles
SRP Scientific Review Panel
SSS Supplemental steady state
TBN Total base number
UHC Unburned hydrocarbon
U.S. DOE United States Department of Energy
U.S. EPA United States Environmental Protection Agency
VOC Volatile organic compound
ZDDP Zinc-dialkyl-dithiophosphate Note: Acronyms listed above have been used in the abbreviated comments in
this Final Statement of Reasons and all other unabbreviated public
responses.
I. GENERAL The Staff Report: Initial Statement of Reasons for Rulemaking ("staff
report"), entitled "Public Hearing to Consider Amendments Adopting More
Stringent Emission Standards for 2007 and Subsequent Model Year New Heavy-
Duty Diesel Engines," released September 7, 2001, is incorporated by
reference herein. Following a public hearing on October 25, 2001, the Air Resources Board
(the Board or ARB) by Resolution 01-38 approved more stringent emission
standards for 2007 and subsequent model year new heavy-duty diesel engines
(HDDEs). Resolution 01-38 is attached and incorporated by reference herein.
The Board approved the regulatory language as proposed with non-
substantive corrections. The affected sections are title 13, California
Code of Regulations (CCR), section 1956.8 (amended) and the incorporated
"California Exhaust Emission Standards and Test Procedures for 1985 and
Subsequent Model Heavy-Duty Diesel Engines and Vehicles" (amended). Background: HDDEs are used in a variety of applications such as large
trucks, school buses, and motor homes.