A decade ago, the Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) finalized the first ever fuel economy and global warming emissions standards for heavy-duty trucks. Last week, EPA released its first scorecard on how truck manufacturers are faring under these new standards. The simple answer is: quite well.
Below, I take a look at what this scorecard says about the industry, the relative success of EPA’s program for heavy-duty trucks, and what we should be expecting and calling for moving forward.
The world of heavy-duty trucks is complicated
This first report from the EPA covers the entire “Phase 1” of the global warming emissions programs for heavy-duty trucks, model years 2014–2018.
While most likely people tend to think of tractor-trailers as the “trucks” of interest, because they are the largest fuel hogs and emitters in the industry, the trucks covered by this rule span from heavy-duty pickups like the Ford Super-Duty F-250/350 to school and transit buses to garbage trucks to package delivery vans and everything in between.
The large variety of the different vehicle types can make regulation of these vehicles complex, and historically heavy-duty trucks have been regulated solely by their engines because when a vehicle is manufactured, it is frequently done so as an incomplete chassis that may then be modified for use as anything from a utility crane to an airport shuttle.
Truck companies aren’t just complying — they’re banking credits
Given the relatively short lead-time and complexity of the market, EPA’s Phase 1 regulation was much less about driving significant innovation in the fleet by 2018 and instead ensuring a strong regulatory platform that could then be built on in the future to help drive the emissions reductions needed in the long run.
Of course, this approach meant that Phase 1 largely codified what manufacturers were likely to plan on doing anyway. As a result, manufacturers have far exceeded what they were required to do. In exceeding the requirements of the standard, manufacturers generate “extra” credits which can be banked for usage at another time, similar to the light-duty vehicle standards. In later years when the standard is strengthened, these credits can then be applied to make up for any difference between the standard and a manufacturer’s performance if it falls short of requirements.
The Phase 2 standards are substantially harder for manufacturers to achieve than Phase 1, pushing manufacturers to advance and improve beyond business as usual, but the large bank of credits generated under Phase 1 could potentially be used to delay these much-needed improvements to heavy-duty trucks.
It’s not yet clear to what extent the credits generated under Phase 1 will undermine the Phase 2 program, as many of these credits were anticipated by the agency when writing the Phase 2 rules and led to more stringent targets in the first years of the Phase 2 program. For example, Class 8 tractor manufacturers have accrued enough credits that they could delay meeting the 2021 standard by about a full year, but it would be more prudent behavior for the manufacturers to instead use this buffer of credits to weather fluctuations in the market related to COVID-19 or to smooth out issues related to the long product cycle of heavy-duty trucks.
EPA underestimated the potential for reductions
Unfortunately, the potential for credits generated from the weak Phase 1 program isn’t the only concern with the Phase 2 standards. In the five years since the rules were finalized, innovation has truly exploded in the truck industry, with a number of new technologies arising that the agencies hadn’t considered.
Most obviously, EV trucks have far exceeded the capabilities originally envisioned when the rule was finalized, and at reduced costs. While the Phase 2 rules did not project EV trucks “to be widely commercially available in the time frame of the final Phase 2 rules” and therefore did not base the Phase 2 rules on their adoption, EV trucks are already here, and strong state rules (e.g, CA, NJ, OR) will help push them to hundreds of thousands of vehicle sales annually by the end of the decade. Even the Phase 1 report shows transit bus manufacturer New Flyer earning a tremendous number of advanced technology vehicle credits thanks to its strong EV sales.
The agency also did not anticipate the developments in technologies like cylinder deactivation or 48V mild hybrids that can simultaneously reduce fuel usage and emissions of harmful smog-forming and soot pollution (nitrogen oxides [NOx] and particulate matter [PM], respectively). These and other engine technologies can be used to further reduce harmful pollution from diesel trucks.
Resetting the near-term goals will help get us where we need to be in the long term
These developments are part of the reason why EPA is seeking to revise its 2027–2029 global warming standards and set even stronger smog-forming and soot pollution standards for these vehicles. We expect a rule to begin the interagency review process any day now and be proposed by January 2022, consistent with an executive order from President Biden earlier this year. And we’ll press the administration to align it with state regulations that are already working to drive EV adoption and reduce harmful diesel pollution.
But we also know that this joint proposal for new truck pollution standards and refinement to Phase 2 has to be just the first step taken by the administration — the Biden E.O. calls for a “Phase 3” of regulations to simultaneously reduce global warming, smog-forming, and soot emissions in 2030 and beyond from new commercial trucks, and the best way to do that is to focus on electrifying the fleet as quickly as possible.
We must seize the moment and go big. EPA’s first emissions scorecard on heavy-duty trucks shows that manufacturers can easily reduce pollution from these vehicles, and we need to make sure that EPA does not let them off the hook again when setting the Phase 3 standards — it’s time to end pollution from heavy-duty trucks as swiftly as possible, both for the climate and for the health of the communities suffering from the impacts of diesel pollution.
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