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Why heavy-duty engine standards put India on the best path forward
Last week, my colleague Anup Bandivadekar and I held a webinar to discuss the heavy-duty truck and bus market in India and considerations for an upcoming regulatory program to improve the fuel efficiency of commercial vehicles. The presentation touched on various topics, including characteristics of new vehicles, comparisons to other major markets, as well as possible engine segmentations of the India HDV market.
During the Q&A session following the presentation, one of the participants asked whether an engine-based regulation would sidetrack regulators and stakeholders in India from the development of a regulation that will promote technologies across the entire vehicle. Given many stakeholders’ (including the ICCT) position that India should eventually adopt a simulation-based full vehicle regulation, this webinar participant wondered if intermediate policy action to regulation engine efficiency would simply be a distraction.
This important question deserves a better-articulated response than the answer I gave at the webinar. Not only do we think that efficiency standards for engines in India are not a distraction, we actually anticipate that an engine program will be highly complementary to the development of simulation-based performance standards for heavy-duty vehicles. Here are three reasons why:
- Engine testing can aid in the development of engine maps for simulation. As we’ve seen in the regulatory development process in Japan, the US, Canada, and China, proper representation of engines and powertrains in vehicle simulation programs takes a great deal of engine dynamometer testing. Introducing an engine standard will lead manufacturers to a deeper understanding of how engines perform across their full operating ranges, and across duty cycles. By strengthening the knowledge of efficiency performance across the engine map, manufacturers and other stakeholders will be better equipped to design and validate how engines are modeled in simulation.
- Engine standards alleviate the pressure to develop a simulation-based vehicle regulation in the near-term. Given the relatively straight-forward nature of engine testing, we estimate that an engine regulation could be proposed and finalized within 1-2 years, while the development of a full vehicle simulation tool would likely take 3-5 years before any regulatory activity can begin. Regulators can use engine efficiency and tire rolling resistance regulations as a way to begin realizing fuel and emissions benefits quickly. This will ease the pressure to expedite the development of a simulation-based regulation for full vehicles, which is worthwhile, but a time and resource intensive task.
- Engine standards still allow for maximum regulatory design flexibility going forward. Establishing an engine efficiency regulation allows regulators in India more time to determine the best course of action going forward, and all regulatory options will still be available. Assuming that the initial engine regulation has a finite duration (e.g., model year 2020 to 2023), India can opt to:
- Continue with engine standards only
- Sunset the engine standards and transition to a full vehicle regulation
- Maintain the engine standards and introduce a complementary full vehicle regulation (e.g., the approach taken in the US and Canada, where there is an engine standard as well as simulation-based vehicle standards)
Many vehicle manufacturers in India are advocating that India follow the European pathway and adopt a modified version of the Vehicle Energy Calculation Tool (or “VECTO”). Development of VECTO began about three years ago, and validation testing and trials are scheduled to continue for at least another year. Currently, the European Commission is anticipating that 2018 will be the first reporting year where manufacturers are required to use VECTO to certify vehicle CO2 levels. However, the tool cannot currently accommodate all heavy-duty vehicle types, and even more time will be needed to develop, validate, and implement these additional vehicle modules into VECTO. Another point to keep in mind is that the European Commission has not committed to establishing a GHG regulation for heavy-duty vehicles. Thus, it is by no means a forgone conclusion that VECTO can be quickly adapted to a regulatory context, so policymakers in India should keep this in mind when assessing the regulatory development timeline for this option. In our estimation, VECTO’s high level of complexity and very lengthy development timeline in Europe suggests that creating an ‘India-VECTO’ would be a very involved exercise that would also take many years due to the need to create custom drive cycles and vehicle technology profiles that match the local situation.
The existing GHG regulatory programs for heavy-duty vehicles in the US and Canada provide evidence of separate engine standards working in concert with simulation-based vehicle standards. Our analysis suggests that engine standards are necessary for promoting long-term investment in engine technology and acknowledging the market structure in which an independent engine manufacturer accounts for a large percentage of sales. These lessons from other markets along with the three points outlined above suggest that by starting with engine-based standards, India can reap the benefits of a more modern and fuel efficient commercial vehicle fleet as soon as possible, all while retaining maximum regulatory flexibility going forward.
