“The industry is still suffering technology fatigue from all the ‘add-ons’ that were needed to meet earlier emission rules,” Nyberg said in speaking with the media over the weekend during the latest Volvo Ocean Race stopover.
Referring to the key unknown of the proposed Phase 2 GHG rule – that despite putting forward more stringent limits, it might require that both a total vehicle performance “assessment” and a separate engine “standard” be met for compliance – Nyberg argued that common sense should prevail as the rulemaking process proceeds.
“We need to be able to design equipment in the best way to meet regulations, but without having to add too much complexity,” he explained. Volvo would prefer to meet the new regulation “without being tied to an engine standard that would not take into account how different trucks actually operate.
“There is a difference between optimizing an engine [to meet a standard] running in a test cell vs. what will really work in all [truck] applications in different operating conditions,” he continued. “Those involved [in the rulemaking] must see the wider picture of what we will be dealing with as manufacturers.”
Nyberg pointed out that today, compared to 20 years ago when earlier emission rules were rolling out, “each fuel-efficient solution, such as aerodynamics, has to work for specific vehicles designed for specific applications.”
That's why Volvo contends that GHG rules with single, total-vehicle requirements make the most sense, in terms of environmental compliance and cost feasibility.
Speaking at the Rhode Island event during a symposium for Volvo customers and dealers, Susan Alt, senior vice president of public affairs, noted that, for the OEM, meeting the Phase 1 GHG rules— which at include a requirement that 2017 engines meet a 6% fuel-efficiency improvement threshold—was “not a big deal.”
As for why Phase 2 could be so onerous to deal with, Tony Greszler, vice president of government and industry relations, pointed out that environmental groups “pushed the agencies to increase its stringency and extend the rule out to 2027.” He said if the final rule’s GHG limits are too stringent, “it could force technology on the market before it’s ready. The result, he said, might be the kind of truck pre-buying that plagued the industry with the onset of the 2007 EPA engine-emission rules.
Greszler advised that to meet a separate engine standard within the tighter Phase 2 limits might require adding on such technology as waste-heat recovery. “WHR componentry would have to be added in addition to existing engine hardware and chassis equipment,” he explained, “that would impact overall vehicle efficiency.
He said incorporating WHR would decrease fuel efficiency because:
- More components would have to be packaged on the frame rails. That would increase the tractor-trailer gap, reducing the positive effect of aerodynamics.
- A new, less-aerodynamic hood design would be needed, which would cause a “severe loss of fuel efficiency.”
- The increased cooling capacity needed would result in more than a 1% fuel-efficiency loss for the vehicle.
Alt and Greszler advised the audience that depending on how the rulemaking is drafted, Volvo “may ask you to get involved” in helping to head off a separate engine standard by stating industry opposition to “a [GHG] target that will force technology before it has been fully tested and is commercially feasible” via emails to EPA and NHTSA, the agencies jointly promulgating the GHG rules.
“If reason does not prevail,” Greszler warned, “Phase 2 could force a mandate on the industry for increase engine efficiency that actually reduces total vehicle efficiency.
"Truck design,” he added, “should meet customers’ specific applications, not government’s regulation.”