the vehicles actually experience in use. The ICCT recommends that the test fueluse E10.5.
The ICCT has similar concerns on any future use of engines using E30. Inaddition, we are concerned that E30 could open the door to E30 credits againstthe CAFE and GHG standards, similar to what has already occurred for FFVs. Itwould be much better for EPA to focus on increasing the octane rating of allgasoline.6.
The ICCT supports maintaining fuel-neutral criteria emissions standards forheavy-duty vehicles. We also fully support extending chassis-based emissionrequirements to all complete vehicles up to 14,000 gross vehicle weight andextending the supplemental FTP requirements to complete vehicles between8,500 and 14,000.7.
The ICCT supports updating the R-factor in the carbon balance equation for NHVchanges. Specifically, the R-factor determined by ORNL for Tier 2 vehicleswithout the data outlier should be used, or R=0.96.8.
A key concern for natural gas vehicles is the atmospheric venting of natural gasthat occurs during refueling. It is very important that this venting of natural gas becontrolled and recaptured. The ICCT recommends that EPA develop and adoptrequirements for refueling emissions from all gaseous-fueled vehicles.9.
The ICCT recommends that EPA harmonize with both the CARB 1 mg/mileparticulate mass standard starting with 2025 and the European particulatenumber standards. Currently, both requirements are hindered by the lack ofmeasurement precision, but continuing research into particulate measurementshould resolve these issues in the future.
1) Vehicle Emission Control Cost Assessments
The adoption of more stringent standards usually requires the improvement of currenttechnologies or the adoption of new ones. This results in additional cost tomanufacturers and the public. It is frequently difficult to assess the cost of improvedtechnology, as manufacturers regard cost information as confidential for competitivereasons.As emission control technology cost estimates had not been updated in 10 to 15 years,the ICCT conducted a study to update emission control costs, published last year.
Costestimates were conducted for the main emission control technologies, using updatedassessments of technology actually being used, impacts of learning as manufacturingvolumes increase, and technology improvements that have made the systems simpleror more efficient.