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Reply to Comments on the Proposed On-Road Vehicle and Engine Emission Regulations - Transportation Systems Branch

Appendix 1: Scenario Analysis: Fleet Average NOx Emissions in Canada - Estimation of Future Vehicle Emission Certification Bin Distribution

The final U.S. Tier 2 standards are based on a system where manufacturers have the option of certifying any particular vehicle to one of eight emission categories or "bins", each having specified standards of differing stringency for a variety of air pollutants, provided that the manufacturer meets an annual sales-weighted corporate fleet average NOx standard of 0.07 g/mi. Manufacturers will select which bin to certify their various vehicle models based on the characteristics of the U.S. vehicles sales market while ensuring the 0.07 g/mi NOxfleet average is achieved in the U.S. The Canadian Regulations continue the current approach of requiring vehicles to meet the same emission standards to which they are certified to in the U.S.

The U.S. EPA, in their report2 entitled "Accounting for the Tier 2 and Heavy-Duty 2005/2007 Requirements in MOBILE6", developed a default fleet-wide distribution depicting how manufacturers might comply with the Tier 2 requirements (i.e., the percentages of vehicles within each vehicle class certified to a bin with the objective of meeting the fleet average NOx standard). The MOBLIE6 model is used to estimate emissions from on-road vehicles in the U.S. The default bin distribution in the MOBILE6 model represents one possible distribution and is based on the premise that manufacturers will take full advantage of the opportunity to trade off higher emissions on heavier light-duty trucks with lower emissions on cars and lighter trucks.

Table 3 presents a summary of the bin distribution assumed by the U.S. EPA for the 2009 model year, which is the year when the Tier 2 standards become fully phased-in. Since the vast majority of vehicle models offered for sale in Canada will be sold concurrently in the U.S. and will be certified to the same emission standard bin as in the U.S., the same projected bin distribution can be used to calculate the Canadian fleet average NOx emission rate.

Table 3: MOBILE6 Vehicle/Bin Distribution for the 2009 Model Year
Bin #87654321
NOxStd0.20.150.10.070.040.030.020.00
LDV---0.10.10.550.25-
LDT1---0.10.10.550.25-
LDT2-0.30.30.20.2---
LDT30.26--0.74----
LDT41-------

The Canadian Vehicle Manufacturers' Association (CVMA) and the Association of International Vehicle Manufacturers of Canada (AIAMC) have stated "it is very likely that many manufacturers will certify the majority of their products to the Tier 2 average (bin 5) level of emissions. This approach allows manufactures to ensure compliance to the Tier 2 standards while allowing flexibility to respond to any changes in customer preferences."1 A second distribution reflecting this scenario is presented in Table 4, with the majority of LDVs, LDT1s, LDT2s and LDT3s certified to bin 5. Heavier light-duty trucks and diesel-fuelled vehicles may be more difficult to certify to bin 5 and may likely be certified to one of the higher bins (e.g., bin 8 with a NOx emission standard of 0.2 g/mi). To offset the impact on the NOx fleet average emission rate of certifying those vehicles to higher bins, manufacturers would likely certify some of the lighter vehicles to bins with lower NOx emission standards.

Table 4: Alternative Vehicle/Bin Distribution with Majority of LDV and LDT1-3 Certified to Bin 5
Bin #87654321
NOxStd0.20.150.10.070.040.030.020.00
LDV---0.750.10.10.05-
LDT1---0.750.10.10.05-
LDT2---1----
LDT3---1----
LDT40.70.10.10.1----

1CVMA & AIAMC, "Cleaner Vehicles, Engines and Fuels: A Policy Analysis and Recommendations on Environment Canada's Notice of Intent and Support Document - February 17th, 2001," September, 2001.

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