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Crediting Real World Fuel Efficiency in GHG Phase 2: Daimler Trucks North Americas Suggested Approach October 22 nd , 2013 Mike Christianson Daimler Trucks North America - Compliance and Regulatory Affairs Daimler Trucks North America 1


  1. Crediting Real World Fuel Efficiency in GHG Phase 2: Daimler Trucks North America’s Suggested Approach October 22 nd , 2013 Mike Christianson Daimler Trucks North America - Compliance and Regulatory Affairs Daimler Trucks North America 1

  2. Overview of Test Methods in Place/Planned by Region Test method application in major markets Road testing Chassis dyno testing Complete Vehicle Engine/ Power train Simulation testing Approach In use / planned * * Level of… high low / n.a. Simulation Comparability high low Costs Complete vehicle simulation with tested inputs is suggested for GHG Phase 2. It is the most cost effective method, is repeatable, and can generate real-world FE values on a comparable basis. Compliance and Regulatory Affairs Daimler Trucks North America 2

  3. Capturing Engine/Powertrain Interaction Over More Realistic Drive Cycles Requires Vehicle Simulation Chassis dyno testing Complete Vehicle Engine/ Power train Simulation testing • Issue: current engine regulatory test cycles 25 Line-Haul 40 Walk-in Van 20 do not match real-world driving, do not reflect 35 30 15 achievable CO 2 reductions. % Time 25 % Time 20 10 15 • Options for testing powertrains: 5 10 5 • Chassis dyno testing: very costly and 600 600 Good 800 800 1000 1000 resource-intensive 1200 1200 1400 10 20 30 40 50 60 70 80 90 100 10 20 30 40 50 60 70 80 90 100 1400 RPM R 1600 P 1600 M 1800 1800 2000 • Engine powertrain testing: resource 2000 2200 % Load % Load Better 2400 2200 0 0 25 intensive in that it requires a lot of RMC 40 FTP 20 35 testing and costly new facilities 30 15 % Time 25 % Time Best • Complete Vehicle Simulation: Max. 20 10 15 flexibility for efficient, repeatable and 10 5 5 accurate assessment of multiple 400 600 600 800 800 1000 configurations. Minimizes testing 1200 1000 1400 10 20 30 40 50 60 70 80 90 100 10 20 30 40 50 60 70 80 90 100 1200 RPM R 1600 P 1400 M 1800 (required for inputs e.g. fuel maps) 1600 2000 2200 1800 % Load % Load 2400 -10 0 2000 0 Data collected from ECM downloads of customer vehicles Compliance and Regulatory Affairs Daimler Trucks North America 3

  4. Future Technology Evaluation Through Simulation Looks at the vehicle as a complete system Industry already uses tools like Autonomie • • Uses a Forward-Looking Vehicle Model extensively to assess technology potential • − Driver Model (PI Controller) generates commands sent Allows for easy integration of various • to different components (throttle to the engine, gear powertrain architectures without extensive number to the transmission,…) in order to follow a physical testing desired speed profile − Components will realistically react to the commands − Possible to develop control strategies Driver Environment Driver Vehicle Level Controller Route Throttle, Engine Brake Vehicle Clutch Gear Powertrain Activation Number Architecture Compliance and Regulatory Affairs Daimler Trucks North America 4

  5. Energy Balance: Modeling System Interactions Aero Gearbox Axle Wheels Engine Mech. Aux. Fuel η = N/A η = N/A η = 95% η = 42% η = N/A η = 98% % Loss: 33% % Loss: 40% % Loss: 5% %Loss: N/A % Loss: 2% % Loss: 2% Legend Elec. Aux. %Loss: Mechanical Energy Balance* Grade *For Illustrative Purposes Only - % Loss: 16% Numbers Not To Scale! Inertia % Loss: 1% Portland – Canyonville Test Route η = N/A % Loss: 1% OEMs have all evolved to applying a complete vehicle approach using simulation to develop and validate new products. A regulation should mirror this approach to ensure that the regulation acurately reflects the CO 2 reductions our customers see in the real world Compliance and Regulatory Affairs Daimler Trucks North America 5

  6. US GHG Phase 1 to Phase 2 High Level Comparison GEM LSFC for comparison to limit values Standard Fuel Map Vehicle characteristics Standard speed- (aero tools, tire testing) based drive Advanced/Innovative Technology Component cycles Characteristics 80 (literature values) Vehicle Speed (mph) 60 40 20 Source: 0 NHTSA 0 200 400 600 800 Time (s) Improvement • Standard power train factor inputs Key changes: • No separate engine certification • Engine fuel mapping • Component efficiencies • Distanced based cycles w/ road grade • Additional cycles by vocation • Trailer aero improvements Compliance and Regulatory Affairs Daimler Trucks North America 6

  7. Complete Vehicle Approach: Flexibility without CO 2 Backsliding • Provides manufacturers with flexibility needed to design the most cost effective solutions optimized for the application – without limiting innovation and competition • CO 2 backstops can be designed to prevent backsliding Backstops prevent GHG17 Std Tractor vehicle backsliding "Future" Std Tractor GHG17 Std Truck "Future" Std Truck Vehicle Power Demand [(hp ⋅ hr)/(ton ⋅ mile)] Backstops prevent engine backsliding Backstops prevent vehicle backsliding Backstops prevent engine backsliding Engine CO 2 [g/(hp ⋅ hr)] Compliance and Regulatory Affairs Daimler Trucks North America 7

  8. Advanced and Innovative Technologies • Many Phase 1 Innovative Technologies will likely be quantified by Phase 2 and should be incorporated into GEM 2.0 via a pull-down menu. These menu options should be based on realistic fuel economy improvements. • If an OEM wishes to show a greater benefit, they can override default values with test data generated following innovative technology certification procedures (below). • Continue the Phase 1 approach of allowing advanced technology credits to be generated as “Super Credits.” Compliance and Regulatory Affairs Daimler Trucks North America 8

  9. Trailer regulations: Without Trailers, Phase 2 is Incomplete • Further improvements to the tractor cannot be optimized independent from trailer aero improvements • System optimization is the key to full-vehicle fuel economy improvements • Test procedure is exactly like Phase 1 aero for tractors but translated to trailers: • EPA- defined reference tractor • Trailers put in bins or subject to max C d A requirement Trailers are clearly on the table for Phase 2. At a minimum, the reference trailer must be updated to reflect more aerodynamic designs Compliance and Regulatory Affairs Daimler Trucks North America 9

  10. Summary and High Level Principles for Phase 2 Regulation must accurately reflect real world reductions. The only way to accurately reflect real- • world consumption is through a complete vehicle standard that includes trailers Phase 2 must not force technology that doesn‘t reduce total cost of ownership for the first • customer (payback within 18 months) otherwise new technology won‘t be purchased and environmental benefits will be delayed. Phase 2 should be consistent with Phase 1 relative to current OBD requirements providing • adequate protection for criteria and GHG emissions. This also prevents OBD from becoming a barrier to new GHG technologies entering the market. EPA, NHTSA and ARB must have one single program for GHG in the U.S . Should ARB request a • waiver for HD GHG standards that are more stringent, it should be denied on the basis that such standards are not needed to meet compelling or extraordinary conditions. Trade-off of NOx and CO2 reduction targets. Additional NOx stringency has negative impacts on GHG • emissions and compromises our joint goal of FE improvement. Complex clean diesel technology requires long design cycles. It is not feasible to work to EPA/ARB 3- • year mandated cycles. Consequently, at least one manufacturer has already left the market and another is struggling to meet requirements. Compliance and Regulatory Affairs Daimler Trucks North America 10

  11. THANK YOU! Questions or Comments: Michael.Christianson@daimler.com Compliance and Regulatory Affairs Daimler Trucks North America 11

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