Office of Transportation
          and Air Quality
EPA420-S-04-001
March 2004
United States
Environmental Protection
Agency
          Highway Diesel
          Progress Review
          Report 2
          Executive Summary
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                                                            EPA420-S-04-001
                                                                 March 2004
              Highway Diesel  Progress Review
                              Report 2

                       Executive Summary
                      Assessment and Standards Division
                    Office of Transportation and Air Quality
                     U.S. Environmental Protection Agency
                                NOTICE
  This Technical Report does not necessarily represent final EPA decisions or positions.
It is intended to present technical analysis of issues using data that are currently available.
        The purpose in the release of such reports is to facilitate an exchange of
       technical information and to inform the public of technical developments.

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                                                                 Executive Summary
                             Executive  Summary
       The Environmental Protection Agency (EPA or the Agency) established in 2000 new far
reaching emission standards beginning in 2007 for heavy-duty diesel vehicles and the fuel used
in them. These standards were premised on the introduction of new catalyst based emission
controls for diesel engines and the removal of a catalyst poison, sulfur, from diesel fuel. The
scale of the changes and the long-term benefit for society have only one parallel in the thirty plus
year history of mobile source emission control: the introduction of unleaded gasoline and
catalysts on cars in the 1970s. The monetized benefits of this program exceed its cost by more
than 16 to one.

       Given the scope of these new regulations and their importance for public health, it is only
prudent that the Agency carefully follow the progress of industry in implementing this rule. This
report is the second in a series of technical progress reviews by EPA to document the status of
engine and vehicle technology development to meet the 2007 standards. The first report,
published in June of 2002, concluded that progress to that time had been substantial and was in
keeping with the expected progress necessary for successful implementation of the new
standards in 2007. We concluded this based primarily on the extensive research efforts since the
rule was finalized and the good results from that research.

       This second report also considers the continuing progress in the research laboratory but,
more importantly, the transition of these technologies from research into business plans, product
development programs, engines and vehicles for field testing, and finally into real products for
sale in the marketplace in 2007. Thus, while we continue to be impressed by the amount of
technical progress shown in the laboratory, it is the concrete steps that manufacturers have taken
in their new product development programs that gives us great confidence for 2007.

       The data that we have used in reaching the conclusions summarized here come from a
number of sources gathered  over the last year and a half. The most compelling evidence,  and
that which we rely on most heavily, came from confidential one-on-one technical and business
reviews conducted with engine manufacturers and with manufacturers of emission control
technologies.  EPA has met with almost 30 companies to gather this information and to
understand fully the breadth of development for 2007. The companies we have met with are
making substantial investments to bring products to the market for 2007 because of the
confidence they have  in those products.

       As projected by the Agency in the 2007 rulemaking, all manufacturers are planning to
use catalyzed diesel paniculate filters (CDPFs) to comply with the 2007 paniculate matter (PM)
standard. In applications where 15  ppm sulfur diesel fuel is available, manufacturers have
already introduced PM filter systems on engines for urban and school buses meeting the 2007

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Highway Diesel Progress Review Report 2 - March 2004	


standards. This report documents the continued improvements in CDPF system technology to
improve filter regeneration, lower fuel consumption, and reduce maintenance.

       The report documents substantial progress to develop the NOx adsorber technology
including improvements in catalyst formulation, durability, overall system performance and
vehicle integration.  In fact, late last year the first light heavy-duty diesel truck equipped with the
NOx adsorber technology went into limited production in Japan.  Although, we are not
projecting that NOx adsorbers will be broadly used in 2007 to comply with these standards, we
are continuing to conclude from the evidence shared during our review that manufacturers could
comply using the NOx adsorber technology in 2007.

       For 2007, all of the engine manufacturers have demonstrated the ability to further
improve their current 2004 NOx emission control systems (either cooled EGR or ACERT™) to
comply with the program.  While the final NOx standard in 2010 is 0.20 g/bhp-hr, the 2007
program includes a number of implementation flexibilities that will allow manufacturers to
comply with engines meeting an averaging level of approximately 1.2 g/bhp-hr in the years
2007-2009. All engine manufacturers have indicated they intend to adopt such a two-step
compliance strategy. This strategy will allow engine manufacturers that choose to do so to make
incremental changes to their current proven 2004 products for NOx control in 2007.

       Engine manufacturers that sell similar products in Europe will have urea SCR based
solutions for Euro IV that could be adopted to the US standards provided they can address issues
related to urea infrastructure and end-user compliance. Two engine manufacturers are
considering such an approach for 2007 in a limited way for centrally-fueled fleets. While it
seems unlikely that such an approach could be broadly applied by 2007 given the significant
urea infrastructure that would need to be put in place we believe such a solution could have a
limited role in 2007 and potentially a broader role by 2010.

       All of the engine manufacturers follow similar new product introduction programs built
around a series of milestone reviews (i.e., gateway reviews to the next step in product
development).  The first of these gateway reviews defines the step from research to product
development and requires that manufacturers have defined the product they  intend to build, a
target production cost, a business plan built around that target cost, and the resources necessary
to bring the product to market.  Prior to this step, engine manufacturers and technology suppliers
have worked primarily to prove out potential technology  solutions from which an engine
manufacturer can then choose to define a new product. Completing this step means
manufacturers are ready to begin the hard but well-defined work of successfully bringing a new
product to market.

       In earlier meetings with engine manufacturers, they indicated to us their confidence that
they would be able to clear this first crucial  step for 2007 products successfully and on time.

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                                                                  Executive Summary
The manufacturers have been working over the last year to complete all of the necessary
analyses required to complete this first milestone review.  The detailed confidential information
shared with the Agency during our meetings reflected these analyses.  In the time between our
last detailed review meetings and the drafting of this report, four of the five major engine
manufacturers have completed this crucial first step. The one company that has not completed
this step has indicated to the Agency that it will in the coming weeks. The fact that the engine
manufacturers have cleared this gateway says clearly that companies are on track to comply with
the 2007 standards.  This is not to say that no development tasks remain or that the remaining
challenges are trivial. Substantial work to prove out these engines must be done over the next
three years prior to their introduction in 2007, but completing this review step  means
manufacturers have concluded that the issues they have identified will be satisfactorily addressed
in the hard work of their development programs.

       To help allay concerns expressed by some in the trucking industry, engine manufacturers
are planning to use their normal product development process as an avenue for their customers to
learn more about the 2007 products. The manufacturers are indicating they will provide early
prototype vehicles for selected customer testing in 2005.

       This second progress report documents an extensive range of ongoing emission control
technology  development.  Whether for PM or NOx control, the ingenuity shown by industry to
develop better technologies or further enhance existing emission control solutions for diesel
engines is impressive. Yet, it is not this impressive progress that provides us with continued
confidence that 2007 products will be developed on time, but rather the fact that manufacturers
can say  with confidence that they have technological solutions that can be brought to market
through their rigorous product development programs. Based on our careful review of both the
detailed confidential information shared with the Agency during this review and the broader
public information summarized in this report, we can conclude:

       • Engine manufacturers are on track for 2007 implementation.
       • CDPFs will be used by all manufacturers for PM control.
       • Generally,  manufacturers will treat the NOx standards as a two-step process.
       • All manufacturers can comply in 2007 with existing proven technologies.
       • NOx control should not adversely affect fuel consumption and improvement may be
        possible over today's engines.
       • Engine manufacturers will provide prototype vehicles in 2005 for early customer fleet
        testing consistent with their product development plans.
       • Engine manufacturers' 2007 compliance  plans are a building block for the technology
        package they plan to use to meet the 0.20 g/bhp-hr NOx standard in 2010.

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