As the Director of the Office of Transportation and Air Quality (OTAQ) for the U.S. EPA, Christopher Grundler and his staff of nearly 400 employees strive to protect public health and the environment by reducing air pollution from vehicles, engines, and the fuels used to operate them. Grundler gave a keynote speech at the 2016 Commercial Vehicle Engineering Congress as part of a symposium discussing Phase 2 greenhouse gas (GHG) standards impacting heavy trucks and trailers. He’s also scheduled to be a featured speaker on the opening day of the SAE 2017 Government/Industry Meeting, taking place January 25-27 in Washington, DC. This excerpt is from the audience Q&A session following his COMVEC presentation.
Do you feel the Phase 2 rule is future-proof such that technologies not yet developed will be recognized?
We’re not in the habit of establishing standards that aren’t feasible, so we do need to have a technology forecast. That’s based on the technical record that we’ve built, but very often that’s wrong because you guys [a roomful of engineers] invent something else. We see this on the car side, we see this off-road, we see this on-highway. So when you read the 2500 pages [of the rule] and you see all the tables with these very precise testaments of effectiveness and cost, that’s just us fulfilling our obligation to demonstrate that there can be a feasible pathway—and we do show more than one [pathway]. But in reality what’s going to happen is firms are going to decide what’s best for their customers, what’s best based on their technology position. And these standards are performance-based, so they establish a performance level, but they do not prescribe the way that that needs to be achieved. So it opens up the door for all kinds of alternative approaches and we can provide different testing procedures [if] something gets invented or you have something now that isn’t recognized by the current test procedures.
How did the industry make itself heard during the rule-making process?
Loud and clear. A school of thought is that most of the progress in human history is the result of technology progress. That’s what’s really at the forefront of our mind. I think we went several extra miles to go out and discover new approaches, new technologies, new perspectives. Not only through our testing but we took advantage of test programs that other organizations did on their own, whether they’re non-government organizations or industry associations. We sought as much information and data as we could. The voices we hear loud and clear because you know how often we harass you; again, thank you for all those who accepted our invitation, were patient answering all of our questions, and hosting us at your development centers. It really made a difference.
Is there a realistic path to global harmonization of emissions regulations?
In principle, that sounds really good, especially when you’re dealing with global products…The truth is, different countries place different values on public health. We’re always a little bit glib about this—we’re always eager and willing to participate in the harmonization process so long as everyone harmonizes with us. (Audience laughter.) But seriously, there has been progress in the heavy-duty world on test procedure development, so I think at a minimum the idea that all these markets ought to test the same way seems pretty basic. But again, I hate to be a skeptic here—it turns out there are good test procedures and there are not-so-good test procedures, and there’s no way that we’re going to compromise American [public health] to come up with a lowest-common-denominator test procedure.
Are you willing to make any comments about an ultra-low NOx standard?
Yes, I am. We got a lot of comments from many different corners as part of this [Phase 2] rule-making process. We disappointed some of those stakeholders, but we were very clear from the beginning that this rule was about greenhouse gases. We didn’t feel that we had enough information to act on NOx. There is no question that there are parts of the country that need further NOx reduction to achieve clean-air goals. We have numerous petitions in front of us right now asking us to act on NOx in a new national heavy-duty emissions standard. So we’re considering that right now. The way we’re going to go about this…we’re going to be asking for your perspectives, individual firms, our friends at the Engine Manufacturers Association, we’ll talk to environmental groups, [etc.] before we make any decisions. If we decide to pursue a new NOx standard, I can promise you one thing—it will be a comprehensive effort. Before we intervene in the economy with federal regulations, we want to make sure it will produce a [positive] result in the real world.