Fleet Average NOx Emission Performance of 2008 Model Year

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• 1 Purpose
• 2 Introduction
• 3 Company Fleet Average NO_x Emission Performance for the 2008 Model Year
  • 3.1 Scope of Company Reports
  • 3.2 Distribution of LDV, LLDT and HLDT/MDPV
  • 3.3 Company Fleet Average NO_x Values
  • 3.4 NO_x Emission Credits/Deficits for the 2008 Model Year
  • 3.5 End of Model Year Balance of NO_x Emission Credits/Deficits
  • 3.6 Distribution of Bins and Fleet Average NO_x Values
  • 3.7 Fleet Average NO_x Values Trend
• 4 Conclusions

• Table 1: LDV, LLDT, HLDT and MDPV Full Useful Life Exhaust Emission Standards
• Table 2: Fleet Average NO_x Standards
• Table 3: Scope of Company Reports
• Table 4: Distribution of Canadian Fleet
• Table 5: Summary of Company Average NO_x Values for the LDV/LLDT Fleet
• Table 6: Summary of Company Average NO_x Values for the HLDT/MDPV Fleet
• Table 7: NO_x Emission Credits/Deficits for the 2008 Model Year
• Table 8: End of Model Year Balance of NO_x Emission Credits/Deficits
• Table 9: Distribution of Vehicles by NO_x Standard (Bin)

• Figure 1a: Distribution of LDV/LLDT by NO_x Standard (Bin) in Number of Vehicles
• Figure 1b: Distribution of HLDT/MDPV by NO_x Standard (Bin) in Number of Vehicles
• Figure 2a: Distribution of LDV/LLDT by NO_x Standard (Bin) in Percentage of Vehicles Relative to the Fleet
• Figure 2b: Distribution of HLDT/MDPV by NO_x Standard (Bin) in Percentage of Vehicles Relative to the Fleet
• Figure 3: Fleet Average NO_x Values and Standards

The purpose of this report is to summarize the fleet average NO_x emission performance of individual companies and the overall Canadian fleet for the 2008 model year (MY) based on data submitted by companies in their end of model year reports; furthermore, it is also to report on the effectiveness of the Canadian fleet average NO_x emission program in achieving the environmental performance objectives.

On January 1, 2004, the On-Road Vehicle and Engine Emission Regulations (hereafter referred to as the "Regulations") came into effect under the Canadian Environmental Protection Act, 1999 (CEPA 1999). These Regulations introduced more stringent national emission standards for on-road vehicles and engines. The Regulations align Canada's emission standards for light-duty vehicles, light-duty trucks, medium-duty passenger vehicles, heavy-duty vehicles, heavy-duty engines and motorcycles with those of the U.S. Environmental Protection Agency (EPA) through incorporation by reference to the U.S. Code of Federal Regulations (CFR).

The Regulations also establish fleet average NO_x standards for light-duty vehicles¹ (LDV), light light-duty trucks² (LLDT), heavy light-duty trucks³ (HLDT) and medium-duty passenger vehicles⁴ (MDPV). Each new LDV, LLDT, HLDT and MDPV is required to be certified to one of the bins presented in Table 1, for which there are specific emission standards for NO_x and other pollutants. A company's choice of bin to which individual vehicle models are certified in a given model year is limited by the obligation to comply with the fleet average NO_x standards associated with that model year. Table 2 presents the fleet average NO_x standards for a company's fleet of LDV and LLDT and its fleet of HLDT and MDPV.

Notes:

1. The equivalent limits in units of grams/km are obtained by multiplying the grams/mile value by 0.621.
2. Bin 11 is only for MDPV and is available up to and including the 2008 model year. Bins 9 and 10 are only available for the 2004 to 2006 model years for LDV and LLDT, and up to and including the 2008 model year for HLDT and MDPV. Bins 8 through 10 contain additional temporary, less stringent standards for certain pollutants and for certain vehicles.
3. Beginning in the 2009 model year, applicable standards are limited to bins 1 to 8 for all categories.

Note: A company's combined fleet of LDV, LLDT, HLDT and MDPV of the 2009 and later model years will be subject to a single fleet average NO_x standard of 0.07 grams/mile.

A company's fleet average NO_x value is the weighted average based on the number of vehicles certified to each bin. The emission bins, fleet average NO_x standards, and methods of calculating fleet average NO_x values are aligned with those of the U.S. EPA; however, there are differences in the structure of the NO_x averaging program in Canada, which is designed to recognize vehicles that are sold concurrently in Canada and the U.S. The regulatory requirements are structured to deliver fleet average emissions comparable to those of the U.S. while minimizing the regulatory burden on companies and enabling the marketing of vehicles in Canada independently from the U.S.

The Regulations require that all companies submit a report to the Minister of the Environment no later than May 1 after the end of each model year. The end of model year report must contain detailed information concerning the company's fleets and/or groups of vehicles, including information related to:

• statements of allowable elections made by the company in complying with the fleet average NO_x requirements of the Regulations;
• average NO_x value(s) achieved;
• values used in calculating a fleet average NO_x value;
• calculation of NO_x emission credits and/or deficits;
• balance of credits or deficits; and
• credit transfers to or from the company.

For more information regarding the calculation of fleet average NO_x values and NO_x emission credits/deficits please refer to the Regulations which can be found on the Environment Canada CEPA Registry. Reports for prior model years (2004-2007, inclusive) can also be found on the CEPA Registry.

Table 3 presents a summary of the companies that submitted a fleet average NO_x report for the 2008 model year in accordance with the requirements of the Regulations, including the vehicle makes and the number of test groups covered by the reports.

¹ A test group is the basic classification unit that comprises LDV, LLDT, HLDT or MDPV having similar exhaust emission performances and that share all of the features described in section 1827, subchapter C, part 86 of the CFR.

A total of 23 companies submitted reports for the 2008 model year covering a total of 288 test groups. It should be noted that certain test groups were common between companies that shared vehicle platforms and/or powertrains. As a result, the sum of all the test groups listed in Table 3 above will exceed the afore-mentioned total.

Table 4 summarizes the LDV, LLDT and HLDT/MDPV distribution of the Canadian fleet for the 2008 model year.

A total of 1 277 247 LDV/LLDT and 268 542 HLDT/MDPV were reported for the 2008 model year, for a combined total of 1 545 789 vehicles. The overall Canadian fleet for the 2008 model year was comprised of 55% LDV, 28% LLDT and 17% HLDT/MDPV compared to a 59% LDV, 27% LLDT and 13% HLDT/MDPV fleet distribution from the 2007 model year. There was a slight change in the distribution from light-duty vehicles and light light-duty trucks to heavy light-duty trucks and medium-duty passenger vehicles in the 2008 model year.

Tables 5 and 6 summarize the total number of vehicles and average NO_x values for each company's fleets of LDV/LLDT and HLDT/MDPV respectively.

Note: Fleet average NO_x values are rounded to the same number of significant figures that are contained in the total number of vehicles in a company's fleet.

Note: Fleet average NO_x values are rounded to the same number of significant figures that are contained in the total number of vehicles in a company's fleet.

The company average NO_x values ranged from 0.0657647 grams/mile to 0.0807837 grams/mile for the fleet of LDV/LLDT and 0.065250 grams/mile to 0.4219 grams/mile for the fleet of HLDT/MDPV. The calculated average NO_x values of two out of twenty-three companies' LDV/LLDT fleets are above the average NO_x standard of 0.07 grams/mile. The calculated average NO_x values of two out of eleven companies' HLDT/MDPV fleets are above the average NO_x standard of 0.14 grams/mile.

Average NO_x values above the applicable average NO_x standard for a given fleet can be attributed to the following factors:

1. The company elects to exclude from mandatory compliance with the fleet average NO_x standard its group of U.S.-certified vehicles that are sold in Canada and the U.S. This exclusion is allowed because the objective of the fleet averaging provisions is to achieve an overall Canadian vehicle fleet emission performance comparable to that of the U.S., while minimizing the regulatory burden on companies. An analysis⁵ conducted by Environment Canada indicated that, even under extreme scenarios, the variations between the Canadian and U.S. fleet averages are expected to be small.
   
2. The fleet includes a substantial number of diesel-fuelled vehicles. It is recognized that achieving low NO_x levels represents a greater technical challenge for diesel-fuelled vehicles. Diesel engines, however, typically produce lower emissions of non-methane organic gases (NMOG), carbon monoxide (CO) and carbon dioxide (CO₂) relative to comparable gasoline-fuelled vehicles.
   
3. The average NO_x value of only one of the fleets (LDV/LLDT or HLDT/MDPV) is above the average NO_x standard. A company can average values from the LDV/LLDT and HLDT/MDPV fleets to satisfy the requirements of the average NO_x emission program in Canada.
   
4. A company obtained NO_x emission credits by achieving better than average NO_x values in previous model years. A company can carry forward NO_x emission credits to offset a deficit in a subsequent model year.

Table 7 summarizes the NO_x emission credits/deficits obtained by each company for the 2008 model year. Companies that elected to exclude their group of vehicles from compliance with the fleet average NO_x standard (and that did not report credits) or those companies whose fleet average was equal to the standard are assigned "0" credits/deficits. "N/A" is used to represent companies that did not report vehicles for a particular fleet.

¹ NO_x emission credits/deficits are rounded to the nearest whole number. A negative sign (-) indicates a deficit.

² The company elected to exclude their entire fleet, which is sold concurrently in Canada and the U.S., from compliance with the fleet average NO_x standard pursuant to subsection 31(1) of the Regulations.

³ The company elected to exclude only parts of their fleet that satisfied the election from compliance with the fleet average NO_x standard pursuant to subsection 31(1) of the Regulations. However, the average NO_x value for their group of vehicles not subject to the election was at or below the applicable average NO_x standard and therefore did not incur a deficit.

⁴ The company reported a fleet average NO_x value that is equal to the fleet average NO_x standard.

A total of 5 932 credits were generated by companies for the 2008 model year. A total of fourteen companies, which did not elect to exclude their entire fleet from compliance with the fleet average NO_x standard, reported a fleet average NO_x value for LDV/LLDT that is equal to the fleet average NO_x standard (i.e. those denoted as footnote 3 or 4 in the preceding table). Only one company incurred an overall deficit with respect to their combined 2008 model year fleets.

Table 8 shows all activities relating to credits/deficits for the 2008 model year.

¹ NO_x emission credits/deficits are rounded to the nearest whole number. A negative sign (-) indicates a deficit.

² A transfer of 455 credits was made from Chrysler Canada Inc. to Mitsubishi Motor Sales of Canada, Inc.

None of the companies reported a negative balance at the end of the 2008 model year. Of the three companies that reported LDV/LLDT and/or HLDT/MDPV fleet average NO_x values above the respective standards, two used credits earned or their credit balance from previous years to offset the deficits incurred. The third company elected to exclude part of their LDV/LLDT fleet and all of their HLDT/MDPV fleet from compliance pursuant to the Regulations. As a result, they maintained a balance of zero credits for the 2008 model year.

Table 9 summarizes the distribution of vehicles by NO_x standard (bin) and calculated average NO_x values for each of the LDV/LLDT and HLDT/MDPV fleets for the 2008 model year.

For the 2008 model year, approximately 99% of the LDV/LLDT fleet and 71% of the HLDT/MDPV fleet were certified to a bin at or below the applicable fleet average NO_x standard.

The average NO_x value for the LDV/LLDT fleet was 0.07010463 grams/mile, which is 0.15% above the applicable fleet average NO_x standard of 0.07 grams/mile. The average NO_x value for the HLDT/MDPV fleet was 0.122550 grams/mile, which is 12% below the applicable fleet average NO_x standard of 0.14 grams/mile.

Figures 1a and 1b depict the changing distribution of LDV/LLDT and HLDT/MDPV fleets by NO_x standard (bin) across the 2004 to 2008 model years. In addition, figures 2a and 2b present this information on a percentage basis to facilitate year to year comparison within each fleet.

Figure 1a: Distribution of LDV/LLDT by NO_x Standard (Bin) in Number of Vehicles

Figure 1b: Distribution of HLDT/MDPV by NO_x Standard (Bin) in Number of Vehicles

Figure 2a: Distribution of LDV/LLDT by NO_x Standard (Bin) in Percentage of Vehicles Relative to the Fleet

Figure 2b: Distribution of HLDT/MDPV by NO_x Standard (Bin) in Percentage of Vehicles Relative to the Fleet

The percentage of LDV/LLDT certified to bin 5 or better increased from 36% of the fleet for the 2004 model year to 62% for the 2005 model year, to 85% for the 2006 model year, and to 99% for the 2007 and 2008 model years. While the portion of the LDV/LLDT certified to bin 5 increased for the 2008 model year compared to 2007 (96% versus 94%), the portion of the fleet certified to bin 4 or better decreased to approximately 3% versus 6% in 2007. As for the remaining portion of the fleet (i.e. certified to bin 6 and above), it increased slightly in 2008. These factors contributed to the slight increase in the overall LDV/LLDT fleet average NO_x value.

The percentage of HLDT/MDPV certified to bin 5 or better increased from less than 1% for the 2004 and 2005 model years to 9% for the 2006 model year, to 36% for the 2007 and to 71% for the 2008 model year.

Figure 3 presents the average NO_x values trend relative to the standard since 2004 for both the LDV/LLDT and HLDT/MDPV fleets.

Figure 3: Fleet Average NO_x Values and Standards

The average NO_x value for the fleet of LDV/LLDT steadily improved from 2004 to 2007, with an average NO_x value slightly below the phased-in standard of 0.07 grams/mile for the 2007 model year (bin 5). For the 2008 model year, the fleet average NO_x value increased slightly to 0.07010463 grams/mile. As for the average NO_x value for the fleet of HLDT/MDPV, it remained below the applicable fleet average NO_x standard for the fifth consecutive year.

It should be noted that the fleet average NO_x standards for both LDV/LLDT and HLDT/MDPV converge to a final combined fleet average NO_x standard of 0.07 grams/mile (bin 5) beginning in the 2009 model year.

This is the fifth year that companies were subject to the fleet average NO_x requirements under the Regulations. A total of 23 companies submitted reports for a total of 288 test groups comprising 1 545 789 vehicles manufactured or imported for the purpose of sale in Canada.

The average NO_x value for the entire Canadian LDV/LLDT fleet is 0.07010463 grams/mile compared to a fleet average NO_x standard of 0.07 grams/mile. The average NO_x value for the entire Canadian HLDT/MDPV fleet is 0.122550 grams/mile compared to a fleet average NO_x standard of 0.14 grams/mile. While the LDV/LLDT average NO_x value is 0.15% above the applicable standard, all companies have complied with the fleet averaging provisions of the Regulations based on their reports.

Overall, the average NO_x value for the combined fleets of LDV/LLDT and HLDT/MDPV continues to decrease which is consistent with the environmental performance objectives of the Regulations.

¹ Light-duty vehicles generally consist of passenger cars.

² Light light-duty trucks generally consist of vans, sport utility vehicles and pick-up trucks having a gross vehicle weight rating (GVWR) of 2 722 kg (6 000 pounds) or less.

³ Heavy light-duty trucks generally comprise vans, sport utility vehicles and pick-up trucks having a GVWR of more than 2 722 kg (6 000 pounds) and up to 3 856 kg (8 500 pounds).

⁴ Medium-duty passenger vehicles generally consist of heavier passenger-type vehicles, such as vans and sport utility vehicles having a GVWR greater than 3 856 kg (8 500 pounds) and less than 4 536 kg (10 000 pounds).

⁵ Scenario Analysis: Fleet Average NO_x Emissions in Canada. Transportation Systems Branch, Environment Canada, November, 2002.