California Low Emission Vehicle LEV Program An Overview

California Low Emission Vehicle (LEV) Program An Overview Transportation Work Group Phase III - Meeting 1 October 30, 2003 Coralie Cooper NESCAUM 101 Merrimac Street Boston, MA 02143 Page 617 -367 -8540 www. nescaum. org

Background (a) • § 209(a) of the Clean Air Act (CAA) prohibits states from setting standards for new vehicles or vehicle engines. • § 209(b) exempts any state that adopted standards before 3/30/66 -- only California meets this pioneering criterion. • Under the exemption, California has developed and administered state-specific standards for as long as vehicle emissions have been regulated. Page 2 2

Background (b) • Section 177(a) of the CAA provides authority to states to adopt California motor vehicle emission standards. – Implemented standards must be identical to California. – Two full model year (MY) lead time must be provided. – Case law in recent years has clarified adoption process. – States can adopt after CARB Board approval. – States can enforce after a California waiver is approved. Page 3 3

LEV and NLEV • Four states: NY, MA, VT, and ME have adopted the CA LEV II program • Four states in the NE currently participate in the National LEV (NLEV) program – voluntary agreement by manufacturers to reduce emissions beyond federal requirements. – NLEV states agreed to forebear on adoption of LEV until 2002 – NLEV will be replaced by Tier 2 between 2004 and 2007 Page 4 4

LEV II • In 1998, California implemented the second phase of their LEV program (LEV II). • Major changes: – Addition of SULEV (Super Ultra Low Emissions Vehicle) standard class. – Expansion of (to 8500 lbs GVW) and tightening of standards for the LDT 2 class (to equal PC and LDT 1). – Tightened NOx standards for LEV and ULEV classes. Page 5 5

Fleet Average NMOG Gray denotes possible alternative futures (alternatives that also meet required fleet averages). Note effect of NLEV in closing Tier 1/LEV I gap. Page 6 6

Tier 2 versus LEV II - Observations (b) • Detailed studies have been conducted to quantify the emissions reductions – 9/03 NESCAUM study estimates 15 -20% HC benefit and 20 -25% toxics benefit. • LEV approach (declining fleet average) promotes continuing review and update. Conversely, Tier 2 is fixed across time. – LEV II will continue to push vehicle technology. Page 7 7

LEV II and GHG • Neither LEV II nor Tier 2 currently include specific GHG provisions. • However, the ZEV component of LEV promotes advanced technology vehicles, including both high efficiency hybrids and low-carbon fuel SULEVs. – While Tier 2 has a zero-emission Bin 1 standard, it includes no associated sales mandate. – 9/03 NESCAUM study estimates a 2 -3% GHG benefit for LEV relative to Tier 2. Page 8 8

Brief Review of ZEV Mandate (a) • LEV is designed to be technology forcing, setting specific ZEV sales mandates independent of fleet average requirements. – As originally adopted, LEV required 2% ZEVs in MY 98 -MY 00, 5% in MY 01 -MY 02, and 10% in MY 03 MY 10. – Latest proposal is 10% ZEVs in MY 05 -MY 08, 11% in MY 09 -MY 11, 12% in MY 12 -MY 14, 14% in MY 15 MY 17, and 16% in MY 18+. Page 9 9

Brief Review of ZEV Mandate (b) • Latest proposal allows compliance with minimum number of pure ZEVs. • Compliance can be achieved with PZEVs (Partial ZEVs) and AT-PZEVs (Advanced Technology PZEVs). – Industry must make a minimum number of fuel cell vehicles (250 by MY 08, increasing to 50, 000 between MY 15 and MY 18). – AT-PZEVs required to account for 40% of compliance. Page 10 10

Brief Review of ZEV Mandate (c) • PZEV is a 150 K miles SULEV with zero evap and a 15 year/150 K mile warranty. • AT-PZEV is a PZEV that also has one or more of the following: – All electric range, electric vehicle componentry, high pressure gaseous storage system, low fuel-cycle propulsion system. – Hybrids and high pressure CNG systems most common current technology capable of high AT-PZEV credits. Page 11 11

California Motor Vehicle GHG Legislation • In 2002 former CA Governor Davis signed AB 1493 into law • The law requires CARB to develop passenger car GHG emissions standards • Regulations must be final by January of 2005 and will affect model year 2009 • A regulatory proposal will likely be developed by CARB by this summer Page 12 12

Conclusions • The LEV II program provides criteria and CO 2 emissions reductions above and beyond the Tier 2 program. • These benefits result from more stringent evaporative and tailpipe emission standards as well as the LEV advanced technology vehicle requirement. • The relative benefits of the LEV program over the federal program will increase over time as more stringent LEV regulations are developed (LEV III for example). • Adoption of LEV assists states in meeting air quality goals and GHG emission reduction targets. Page 13 13

Additional Detail and Expanded Explanations of Technical Issues Page 14 14

LEV I (or LEV when implemented) • When adopted in 1990, the LEV program represented a watershed approach to vehicle emissions control because: – (1) It included multiple levels of emission standards so that not all vehicles had to be controlled uniformly. In effect, a manufacturer could sell some “dirtier than average” vehicles, but only by also selling offsetting “cleaner than average” vehicles. – (2) Fuel control was recognized as an integral to emissions control and were regulated accordingly. Page 15 15

LEV I Vehicles • LEV I included five vehicle types (as follows, in order of increasing emission standard stringency): – – – Tier 1 vehicles (equivalent to federal standards), Transitional Low Emission Vehicles (TLEVs), Low Emission Vehicles (LEVs), Ultra Low Emission Vehicles (ULEVs), and Zero Emission Vehicles (ZEVs). • An annually declined fleet average standard was also established to ensure increasing numbers of cleaner vehicles each year. Page 16 16

LEV I vs. the Federal Program • Unlike the LEV program, the federal program of the early 1990 s consisted of a single standard (the so-called Tier 1 standard) that was set to remain fixed for at least a decade. • Since Tier 1 was equal in stringency to the least stringent LEV standard (and since ozone compliance remained elusive), other states (for the first time) considered “opting-in” to the LEV program. Page 17 17

LEV II (a) • In 1998, California implemented the second phase of their LEV program -- denoted as LEV II -taking LEV beyond the standards set in LEV I. • Major changes: – Addition of SULEV (Super Ultra Low Emissions Vehicle) standard class (between ULEV and ZEV). – Expansion of (to 8500 lbs GVW) and tightening of standards for the LDT 2 class (to equal PC and LDT 1). – Tightened NOx standards for LEV and ULEV classes. Page 18 18

LEV II (b) • Major changes (continued): – LD useful life extended to 120 K miles (from 100 K). – Extension of the declining fleet average NMOG standard through 2010 (LEV I stopped at 2003). – Optional 150 K mile certification (provides 15% credit for fleet average compliance determination -- NMOG for fleet averaging = 0. 85 50 K NMOG standard). – Prohibition of Tier 1 certifications after 2003. – Tightened PM standards. – Expanded ZEV allowances (discussed later). Page 19 19

Tier 2 versus LEV II (a) • In 2000, EPA adopted the federal Tier 2 program that included most of the LEV II provisions. – First federal program to include LEV-style multiple certification levels (termed “bins” in Tier 2) and associated fleet average compliance requirements. • However, there are continuing differences – Some of these differences are fundamental and make comparing the two programs “challenging. ” Page 20 20

Tier 2 versus LEV II (b) • LEV II sets a fleet average NMOG standard, while Tier 2 sets a fleet average NOx standard. • The LEV II fleet average standard is based on 50 K mile certification levels, while Tier 2 is based on 120 K mile certification. • Evaporative emissions standards are more stringent in the LEV II program than in the Tier 2 program. • Comparisons between the two programs can be made. Page 21 21

Available NMOG Certification Levels Page 22 22

Available NOx Certification Levels Page 23 23

Available CO Certification Levels Page 24 24

Available PM Certification Levels Page 25 25

Fleet Average NMOG Gray denotes possible alternative futures (alternatives that also meet required fleet averages). Note effect of NLEV in closing Tier 1/LEV I gap. Page 26 26

Fleet Average NOx Gray denotes possible alternative futures (alternatives that also meet required fleet averages). Note effect of NLEV in closing Tier 1/LEV I gap. Page 27 27

Fleet Average CO Gray denotes possible alternative futures (alternatives that also meet required fleet averages). Note effect of NLEV in closing Tier 1/LEV I gap. Page 28 28

Fleet Average PM Gray denotes possible alternative futures (alternatives that also meet required fleet averages). Note effect of NLEV in closing Tier 1/LEV I gap. Page 29 29

Evaporative HC • LEV II running loss and refueling loss standards are the same as Tier 2 (0. 05 g/mi and 0. 20 g/gal respectively). • However, LEV II diurnal+hot soak standards are substantially more stringent than Tier 2. – PC standards are just under 50% more stringent. – LDT standards are about 30% more stringent up to 6 K GVW, 5% more stringent 6 -8. 5 K GVW. Page 30 30

Tier 2 versus LEV II - Observations (b) Page 31 31