ICCT HDV Test Procedures India
ICCT HDV Test Procedures India
ICCT HDV Test Procedures India
Acknowledgements: This work was funded by the Shakti Sustainable Energy Foundation. The author thanks Anup Bandivadekar, Oscar Delgado, and
Fanta Kamakaté for their critical reviews.
Figure 1: Nations with active or emerging regulatory programs for heavy-duty vehicles
(BOE = barrels of oil equivalent)
Because of the complexities of the HDV sector, designing a important exceptions are Japan and South Korea, where
regulatory program for HDVs presents unique challenges. medium-duty trucks and buses dominate heavy-duty
For example, measuring the fuel efficiency of a HDV vehicle fuel use.
can be quite complicated since a single engine model
can be paired with a large number of chassis types and In the remainder of this section, brief program overviews
transmissions, with each combination having different are presented for each of the jurisdictions that have
fuel consumption characteristics. Furthermore, the fuel implemented fuel efficiency regulations for HDVs. Though
efficiency of a given vehicle in use may vary dramati- the E.U. has not put a mandatory performance standard
cally based upon the duty cycle. Another attribute of in place for commercial vehicles, we provide a summary
the heavy-duty industry that presents challenges from a of their approach for testing and certifying the fuel con-
regulatory perspective is the fact that vehicle manufactur- sumption and CO2 emissions from HDVs.
ing is often a fragmented and highly customized process.
Unlike passenger cars and light-duty trucks, the assembly
2.1 JAPAN
of HDVs can involve multiple different manufacturers,
suppliers, and upfitters. For example, for a particular city Japan deserves credit as the world’s first country to
delivery truck, one component manufacturer might make establish HDV fuel economy standards in 2006 as part of
the engine; another company might supply the transmis- the country’s commitment to the Kyoto Protocol (Ministry
sion; a separate manufacturer could be responsible for of Economy Trade and Industry (METI) and Ministry of
incorporating the engine and transmission and building the Land Infrastructure Transport and Tourism (MLIT) 2005).
rolling chassis; and, finally, an upfitter would be responsible Separate fuel economy standards were established for
for assembling the body that encapsulates the chassis and city buses and for heavy-duty trucks, and there are unique
carries the cargo. Given that vehicle design and manu- stringency requirements that vary by vehicle mass. Truck
facturing are often shared among multiple entities whose weight classes ranged from 3.5 to 20 metric tons, while
individual contributions can all have unique impacts on buses ranged from less than 8 to greater than 14 metric
the ultimate fuel efficiency performance of a vehicle, this tons. On average, the standards required an improvement
can potentially present challenges in terms of identifying a in fuel economy of 12% by 2015, or a 1.2% annual improve-
single regulated entity. ment. These standards were incorporated into Japan’s
broad Top Runner system for energy efficiency, where
The HDV market is so complex and varied that the the current best performer efficiency is used to set future
U.S., Canada, and China have focused the bulk of their standards. Each manufacturer is required to meet the fuel
regulatory attention on the most energy intensive economy target in each bin it sells vehicles, based upon
vehicle types. In these three nations, long-haul tractor- a sales-weighted average for that bin, with no opportuni-
trailers are the top energy consumers. Indeed, as shown ties for cross-bin crediting (The International Council on
in Fig. 1, the heaviest class of commercial vehicles, which Clean Transportation (ICCT) 2008).
includes long-haul tractor-trailers, account for the bulk
of fuel consumption for seven out of the nine nations After considering several testing options based upon
currently considering fuel economy standards. The two multiple criteria — equipment and labor costs, accuracy,
the ability to account for non-engine efficiency improve- their respective authorities. The EPA developed GHG
ments, and overlaps with emissions test cycles — the emission standards under the Clean Air Act, and the
Japanese government chose to measure fuel economy NHTSA developed fuel consumption standards under
under its heavy-duty standards through a combination the 2007 Energy Independence and Security Act.
of engine-only fuel consumption testing and simulation Environment Canada’s authority covers GHG emissions,
modeling of gear shifting and vehicle resistance loads. so its standards are linked to the EPA’s GHG regulation.
The test method as designed essentially constrains The fuel efficiency and GHG standards are designed
compliance options for manufacturers to engine to be functionally equivalent, based on carbon dioxide
efficiency improvements only. Since the simulation model (CO2) conversion factors for each fuel. In addition, the
assigns standard values by fuel efficiency category for EPA standard also includes limits on engine nitrous oxide
driving resistance and chassis size, efficiency improve- (N2O) and methane (CH4), as well as limits on emissions of
ments due to changes in these variables are not counted refrigerant from air-conditioning systems.
toward compliance.
The U.S. approach mirrors the Japanese program by
Japan’s focus on engine efficiency improvements in adopting a simulation modeling strategy, but the U.S.
its regulation aligns well with the technology potential program is distinct in two important ways. First, the U.S.
that exists at lower driving speeds. At lower speeds that program sets an engine standard that is separate and
are typical of urban driving, losses in the engine and unconnected from the vehicle standard. The second major
transmission tend to dominate, while as speed increases, contribution from the U.S. rule proposal is the expansion
aerodynamic and rolling resistance drag represent of the simulation modeling approach to include additional
an increasing share of overall energy consumption elements of potential efficiency gains from tires, aerody-
(Delorme, Karbowski et al. 2009). Given that urban namics, weight reduction, and other factors as discussed
driving accounts for a large percentage of overall HDV below. As with Japan’s fuel economy rule, compliance with
fuel consumption in Japan, the regulation’s emphasis on the U.S. regulation is based on sales-weighted averaging.
engine improvements is a logical point of focus for its Thus each manufacturer’s product mix must meet the
first phase regulation. targets, on average, based on sales-weighting of vehicles
that generate credits (i.e., vehicles that perform better
For the next iteration of its heavy-duty standards, Japan’s than the target) and debits (i.e., vehicles that consume
regulatory agencies are researching how to update their more fuel/emit more CO2 than the target).
testing and simulation methods as well as how best to
incorporate a wider range of technology improvements The U.S. rule can be thought of as four rules combined
beyond just the engine (e.g., aerodynamics, reduced tire into one regulation. There are distinct provisions for the
rolling resistance, light-weighting, advanced transmis- four primary regulatory subcategories: tractor trucks,
sions, and hybrid powertrains). pickup trucks and vans, vocational vehicles, and engines
of tractor trucks and vocational vehicles.
2.2 UNITED STATES AND CANADA Tractor trucks account for the largest percentage of
Five years after Japan’s policy action, the U.S. finalized fuel consumption and GHG emissions from the HDV
fuel efficiency and GHG emission standards for medium- sector and thus attract the greatest amount of regulatory
and HDVs in the fall of 2011 (The International Council attention in the rule. There are nine separate standards for
on Clean Transportation (ICCT) 2011, U.S. Environmental tractor trucks based on combinations of three categories
Protection Agency 2011). Canada followed roughly a year- of vehicles (Class 7, Class 8 day cab, and Class 8 sleeper
and-a-half later with its own rule, which was published cab) and three roof height categories (low, medium, and
in the spring of 2013 and is largely identical to the high). Regulatory stringency ranges from 9% to 23% for
U.S. regulation (Environment Canada 2013). The U.S. model year (MY) 2017 vehicles compared with the MY
Environmental Protection Agency (EPA) and the National 2010 baseline. Table 1 presents a high-level summary of
Highway Traffic Safety Administration (NHTSA) worked the tractor standards as well as the primary elements of
collaboratively to deliver these Phase 1 regulations under the other three major regulatory categories.
Table 1: Major elements of the U.S. and Canada heavy-duty vehicle regulations
Stringency versus
Regulatory Category Regulatory Subcategories Compliance Assessment MY 2010 Baseline
Greenhouse Gas Emissions Model
(GEM) simulation
Nine subcategories based on weight,
Tractor trucks Inputs: aerodynamics, tire rolling 9% to 23%
cab configuration, and roof height
resistance, weight reduction, idle
reduction, vehicle speed limiter
Heavy-duty pickup trucks • Diesel 12% for gasoline
Chassis dynamometer testing
and vans • Gasoline 17% for diesel
• Light heavy-duty (Classes 2B-5)
• Medium heavy-duty GEM simulation
Vocational vehicles 6% to 9%
(Classes 6 and 7) Inputs: tire rolling resistance
• Heavy heavy-duty (Class 8)
• Light heavy-duty (Classes 2B-5)
• Medium heavy-duty
Engines for tractors and (Classes 6 and 7)
Engine dynamometer testing 5% to 9%
vocational vehicles • Heavy heavy-duty (Class 8)
• Gasoline and spark-ignited engines
(all classes)
Tractor manufacturers must demonstrate compliance or heavy-duty pickup trucks or vans and includes a vast
with the tractor standards using the Greenhouse Gas array of different vehicle configurations (e.g., bucket
Emissions Model (GEM), a vehicle simulation program that trucks, refuse vehicles, and buses), duty cycles, and
was developed by the EPA and NHTSA. For tractors, inputs payloads. The regulated entity is the chassis manufac-
to the model include data on aerodynamics, tire rolling turer. Manufacturers comply with the vocational vehicles
resistance, weight reduction, extended idle reduction, standards using the GEM software by inputting tire rolling
and vehicle speed limiting. In addition, there is a separate resistance test data.
standard for engines of tractor trucks as discussed below.
Notably, transmissions are not included in the suite of The stringency of the vocational vehicle standards is
technologies that are part of the standard compliance premised solely on improvements in engines (driven by
pathway using the GEM program. In the regulation, the the separate engine standard) and tires rolling resistance
EPA and NHTSA explain that transmissions (and axle and does not incorporate savings opportunities from
ratios) were not included in the core set of compliance other areas such as aerodynamics, transmissions and
technologies for tractors and vocational vehicles for two hybrids, and weight reduction. This is not because the
primary reasons: (1) lack of baseline data and (2) the desire agencies have rejected the technology potential across
to avoid unintended disruptions to the market. many vocational applications, but rather that there are
obstacles to capturing these savings given the structure
Heavy-duty pickup trucks and vans with a gross vehicle and protocols of the regulation. For example, the aero-
weight (GVW) between 8,500 and 14,000 pounds are dynamic coefficient of drag is not an input parameter
often very similar to their counterparts in the light-duty in the vocational vehicle module in GEM, since a single
category. Because of the similarities among light- and chassis may be used with multiple bodies that have vastly
heavy-duty pickups and vans, the testing and compliance different aerodynamic profiles.
approach is closely related to the program for LDVs. The
Class 2B and 3 vehicles are tested on a chassis dynamom- Engine testing for compliance with fuel consumption and
eter with the stringency of the standards scaled by a newly GHG standards is designed to occur simultaneously with
created “work factor” that reflects the vehicle’s utility (i.e., testing for criteria pollutants using the same procedures
hauling capacity, payload, and capacity for four-wheel and test cycles that are currently used. In effect, three
drive). There are separate standards for diesel and gasoline more pollutants must be measured and reported: CO2,
vehicles, and, in MY 2018, the average CO2 emissions CH4, and N2O. The procedures to determine which engines
compared with a MY 2010 baseline must be 12% lower for must actually be tested will also remain the same as in
gasoline vehicles and 17% lower for diesel vehicles. current criteria pollutant testing. Engines are categorized
as light-heavy (Class 2B through 5), medium-heavy (Class
The vocational vehicle category is a catchall group for the 6 and 7), and heavy-heavy (Class 8) based on what
rest of the HDVs that are not classified as tractor trucks vehicle class they are ultimately used in.
Regulation
Type 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Impact assessment
Fuel Regulatory development and
Korea Technical studies and test procedure
efficiency finalization
development
End-user
Requirements for new Additional requirements for existing tractors Additional requirements for existing trailers and reefers (< MY
California purchase
tractors, trailers (2011+) and trailers (< MY 2010) 2010)
requirements
(Text in orange represents the ICCT’s best estimate as to the timing of these regulatory developments)
TESTING METHODS FOR HDV FUEL EFFICIENCY: TRENDS, AND IMPLICATIONS FOR INDIA
3. Testing and certification pathways emissions and fuel economy tests of heavy-duty
vehicles on chassis dynamometers (SAE J2711) (Society
Heavy-duty vehicles are produced in a much greater of Automotive Engineers (SAE) 2002), and the EPA has
range of sizes and configurations than light-duty detailed procedures for conducting emissions testing
vehicles, and have a more diverse range of in-use duty (40 CFR Part 86 (U.S. Environmental Protection Agency
cycles. Also, chassis dynamometers and the associated (EPA) 2015), 40 CFR Part 1065 (U.S. Environmental
facilities that can accommodate the significant loads Protection Agency (EPA) 2015)).
and test apparatus of heavy-duty vehicles are often
expensive and much less common than light-duty The most significant benefit of this test method is that
chassis dynamometers. As such, governments and it effectively brings the entire drivetrain into the test.
industry have historically opted for work-specific As such, it can be used to provide a realistic assessment
engine-based standards and engine dynamometer of distance-specific emissions and fuel use for a wide
testing for criteria pollutant emissions certification. range of advanced vehicle and drivetrain technologies,
However, because traditional engine dynamometer including all hybrid configurations.
testing may not be fully adequate for properly repre-
Compared to engine testing, chassis dynamometer
senting vehicle operations, governments and industry
testing is time consuming and expensive. In this method
have been formulating different strategies for certifying
the vehicle is stationary during the test, and the aero-
CO 2 emissions and fuel consumption performance.
dynamic load is not imposed on the vehicle surface as it
These options include certification pathways based on
is during driving. Instead, a simulated aerodynamic load
the following testing methods:
is imposed on the vehicle through the tires by adjusting
• Chassis dynamometer the load on the dynamometer rolls. In effect, the dyna-
• Engine dynamometer mometer uses inertial and electrically generated loads
applied through the vehicle’s tires to simulate aerody-
• Powertrain dynamometer
namic load.
• Simulation modeling
The required load is determined by conducting an
• Closed test track
on-road coastdown test prior to the dynamometer
All of these options are described further below. testing. In a coastdown test the vehicle is accelerated to
Following the test procedure descriptions below, some speed and then allowed to coast to a stop without
Section 3.2 presents a comparison of these options applying the brakes, while vehicle speed versus time is
according to a number of criteria as well as how the recorded. By calculating the varying deceleration rate of
regulatory programs discussed in Section 2 differ in the vehicle over time, one can compute the forces (rolling
terms of testing and certification strategies. resistance and aerodynamic drag) that were operating on
it at each speed. This information is programmed into
the dynamometer so that it will impose the appropri-
3.1 METHODS OF TESTING AND CERTIFYING ate load on the vehicle at each point in the test cycle.
HEAVY-DUTY VEHICLES The vehicle is then mounted on the dynamometer,
and a dynamometer coastdown test is conducted to
3.1.1 Full vehicle chassis dynamometer testing ensure that the coastdown profile is the same on the
In this test method, the full vehicle is mounted on a dynamometer as it was on the road. An alternative to
dynamometer with the drive wheels resting on one or performing coastdowns is constant speed testing. As
more large cylindrical rolls. The vehicle is stationary the name suggests, constant speed tests derive the
during testing, but the drive wheels spin the rolls to total driving resistance by evaluating the vehicle during
simulate driving at different speeds1. The dynamometer steady-state operation on a test track.
imparts varying loads to the drive wheels to represent
varying vehicle inertial load, rolling resistance, and While this method of evaluating and simulating rolling
aerodynamic drag throughout the drive cycle. The resistance and aerodynamic drag on a dynamometer
vehicle driver follows a specific profile of speed versus is theoretically sound, it is critical that the coastdown
time, and is usually given a computerized driver’s aid, (or constant speed) test be conducted correctly. The
which shows actual speed versus target speed in real accuracy of chassis dynamometer testing is limited by
time. The Society of Automotive Engineers (SAE) has the accuracy of the coastdown data used to calibrate
developed a recommended practice for conducting the dynamometer for a specific vehicle. The largest
constraint on coastdown testing is finding an appropri-
1 To avoid tire slippage during high torque operations, some heavy-duty ate location to conduct the test (a straight and level
chassis dynamometers are designed such that the load-transmitting road of sufficient length where the air is relatively still).
axle is directly connected to the wheel hubcap.
The accuracy and repeatability of coastdown tests are certification testing. For many years, governments and
significantly affected by test track configuration and industry have been accustomed to using engine test
ambient conditions. cycles such as the U.S. Federal Test Procedure (FTP)
transient cycle and the European Transient Cycle (ETC)
There are several standardized HDV cycles in existence; for criteria pollutant certification purposes. Moreover,
TransportPolicy.net is an extensive online reference. There another advantageous aspect of this test method is
are cycles specific to a number of different types of HDV the relatively high test-to-test repeatability of the mea-
driving patterns, including cycles tailored to tractor- surements compared to chassis dynamometer results.
trailers, delivery trucks, transit buses, coach buses, and Unlike the chassis dynamometer procedure, there is
refuse vehicles. All of these cycles have vehicle speed no tire slip, no error introduced by human drivers,
versus time (in seconds), and the vehicle operator (i.e., and most temperatures and pressures can be tightly
the person operating the vehicle on the chassis dyna- controlled in a laboratory setting (e.g., air, fuel, engine
mometer) must following the speed trace as closely as coolant, oil, etc.).
possible. In addition to chassis dynamometer testing,
vehicle cycles are also used in simulations models to A key drawback of using engine testing for HDV fuel
evaluate vehicle performance. efficiency testing is that existing cycles are arguably
not reasonably representative of how modern engines
From a regulatory perspective, China is the only juris- operate under real-world conditions. Certain stakehold-
diction that requires chassis dynamometer testing. The ers, including vertically integrated original equipment
cycle used for evaluating all HDVs in China (on both manufacturers (OEMs), contend that optimizing engine
the chassis dynamometer for “base” vehicles and in performance to engine cycles leads to sub-optimal fuel
the simulation model for “variant” vehicles) is a slightly efficiency during actual operations (Daimler Trucks
modified version of the World Harmonized Vehicle North America 2014, Volvo Group 2014).
Cycle (WHVC), the C-WTVC. As shown in Figure A1,
the C-WTVC is very similar to the WHVC. Some of the All of the countries with criteria pollutant regulations
original WHVC acceleration and deceleration values have utilized standardized engine cycles for testing and
are reduced in order to reflect Chinese HDVs, which, certification for many years. The introduction of the U.S.
on average, have lower engine power-to-vehicle weight and Canada’s Phase 1 GHG regulations represent the
ratios than HDVs from other major markets (i.e., Europe, first time that these engine cycles have been used for
North America, and Japan) that were used to develop testing fuel consumption and CO 2 emissions. Some of
the WHVC. the key advantages and disadvantages of using engine
cycles that were originally derived to test criteria
Both the WHVC and C-WTVC are comprised of three mini- pollutants to evaluate an engine’s fuel consumption
cycles: an urban, interurban, and highway driving portion. performance are discussed below in Section 4.1.
In China’s regulation, the fuel efficiency for each of these
three mini-cycles is weighted according to the type of 3.1.3 Powertrain dynamometer testing
HDV, and the final certification value for each vehicle
A powertrain dynamometer test differs from a traditional
model is based on the weighted score. The weighting
engine dynamometer test in that it requires a dynamom-
factors for each of the regulatory subcategories are
eter that can accommodate the additional rotational
listed in Table A2, which summarizes all of the engine
inertia and torques associated with the inclusion of
and vehicle test cycles that are utilized in the regulatory
the transmission in the test setup. In practical terms, a
programs in Japan, the U.S. and Canada, and China.
powertrain test cell needs to have the power absorption
capabilities of a traditional heavy-duty chassis dyna-
3.1.2 Engine dynamometer testing
mometer, but with the power absorbers connected
Existing engine certification test cycles are designed directly to the transmission output shaft, rather than to
to offer a reasonable approximation of how an engine rollers that support the drive wheels of the test vehicle.
installed in a conventional vehicle would operate during
in-use driving. In this testing approach, the engine There are typically two strategies for testing a
is exercised using a standard engine dynamometer, powertrain in a dynamometer test cell. In the first
in which power and torque are measured from the strategy, the physical engine and transmission are linked
crankshaft of the engine. to computer-simulated models of the remaining vehicle
systems. In this powertrain-in-the-loop simulation
One of the most attractive aspects of the engine (PILS), the powertrain is exercised using a vehicle
dynamometer test method is that it is consistent with duty cycle (i.e., vehicle speed versus time). In this PILS
existing criteria pollutant regulatory programs, which approach, the engine and transmission operate as if
currently use engine dynamometers for all emissions they were in an actual vehicle. This PILS method requires
inputs for all of the other non-powertrain components functioning of all major systems such as engines and
(vehicle weight, aerodynamic drag coefficient, tire transmissions. In a regulatory context, for a single
rolling resistance, etc.). The second strategy aims at simulation model it is practically impossible to exactly
generating speed and torque at the output shaft of the replicate all of the various control strategies for the
transmission that will cause the engine to mimic the individual manufacturers, since regulators do not have
same operation it would experience during a specific access to CBI data.
engine certification duty cycle. In this setup, there is
no need for virtual vehicle parameters since there is Vehicle simulation has been an indispensible part
only physical hardware being tested. Since the speed of the vehicle design process for many years and is
and torque used in engine test cycles are not suitable now becoming an essential component of regulatory
programs as well. As discussed in more detail in Section
for powertrain testing (because they simulate torque-
3.2, simulation is an integral piece of all of the regulatory
speed characteristics at the engine output shaft), a test
certification procedures in existence today (including
cycle that simulates torque-speed characteristics at the
the E.U., which is developing an official simulation-
transmission output shaft is required for this strategy.
based certification process but has not indicated that
For more information about powertrain test cycles, see
a regulation will be pursued in the future). Vehicle
(Andreae and Sun 2012). Of the two methods described
simulation models can provide a relatively inexpensive
here, the PILS strategy generally does a much better
design platform and valuable source of timely informa-
job producing results closer to what would be experi-
tion, particularly in cases where physical testing and
enced under real-world vehicle operations.
experimenting becomes difficult.
Table 3: Advantages and disadvantages of the various methods for testing heavy-duty vehicles
Figure 2: Test procedure comparison across the various HDV regulatory programs
From the figure, the most common element across all of the input of engine-specific data into the model a critical
the regulatory programs is simulation modeling. Though requirement to properly evaluate engine improvements.
the individual certification models in Japan, U.S./Canada,
China, and the E.U. are all unique, when we look at the Separate engine standards were a major point of
key input requirements and simulation conditions across contention between various stakeholders during the
the five jurisdictions, some important commonalities regulatory development of the Phase 1 rule, and this
emerge. Looking at engine data requirements, default debate continues on as the regulators in the U.S. and
engine maps are used in GEM (U.S./Canada), whereas Canada weigh options for the Phase 2 standards. Namely,
engine dynamometer-derived maps are needed for the the crucial decision is whether or not to maintain the
models in Japan, China, and the E.U. In their respective stand-alone program for engines. The advantages and
Phase 1 programs, both the U.S. and Canada elected to use disadvantages presented by separate engine standards
default engine maps in their certification process primarily are discussed more in Section 4 in the context of a
based on the fact that engines have their own separate potential HDV fuel efficiency regulation in India.
certification process. In other words, the North America
Another prominent question that policymakers in the
agencies were confident that the engine standards based
U.S. and Canada face is about how best to design the
on mandatory engine dynamometer testing would be
regulation to promote not only engine and road load
sufficient to drive engine technologies into the market
improvements, but also credit transmission improve-
and did not think that testing-derived engine data was a
ments within the core certification process. Transmission
necessary input to the GEM simulations. Therefore, Phase
advancements and the benefits of deeper engine-trans-
1 GEM is not designed to be as accurate as possible with
mission integration were not credited in the Phase 1 rule
respect to the powertrain (i.e., engine plus transmission).
within the primary testing and certification framework.
Furthermore, transmission and improved driveline tech-
As a result, the development of updated test procedures
nologies are not promoted within the standard GEM cer-
and certification methods that are more comprehensive
tification framework, and default values are used for these
in capturing powertrain technology efficiency benefits is
systems as well. In effect, since the GEM virtual vehicles
an issue of high importance to many stakeholders in the
all have default engines, transmissions, axle ratios, and tire
upcoming Phase 2 rulemaking.
radii, the function of GEM is explicitly limited to evaluating
road load-based technologies — namely, aerodynamics, Going back to Figure 2, aerodynamics and tire rolling
tire rolling resistance, weight and idle reduction, and speed resistance are key road load inputs in four out of five cer-
limiting. For the certification programs in Japan, China, tification pathways, with Japan being the only exception
and the E.U., the lack of a separate engine standard makes that uses default values for these parameters. Input
data for the aerodynamics of a vehicle is determined in the previous section, all of the simulation models
by coastdown testing (or constant speed testing in the require input data derived from physical component
European process) on a test track. For tires, the rolling testing (e.g., engines, aerodynamics, tires). However, what
resistance coefficient is determined by laboratory testing sets the European and Japanese approaches apart is that
in the U.S., Canada, and E.U., whereas, for the certifica- there are no separate dynamometer-based standards
tion process in China, the tire rolling resistance coef- that go along with the simulation requirement. The lower
ficient is determined using a formula (China Automotive right-hand corner of the figure represents a scheme solely
Technology and Research Center (CATARC) 2010, Zheng, dependent on physical chassis dynamometer testing. The
Jin et al. 2011). only country that requires chassis dynamometer testing
is China for “base” vehicles; however, “variants” may be
Some of the standardized test procedures that are most certified using the official simulation model.
commonly used for component testing input data for
aerodynamics, rolling resistance, and powertrains are If we look at the two options in the middle of the figure
listed in Table A1 in the appendix. — those which combine requirements for both simulation
and separate dynamometer testing as part of certification
process — we find the two regulatory programs in North
4. Test procedure challenges and America. Option (2) represents the Phase 1 regulation in
opportunities for India the U.S. and Canada in which both the GEM simulation and
As policymakers in India consider developing fuel engine dynamometer testing are mandatory for tractor
efficiency standards for HDVs, one of the fundamental trucks and vocational vehicles (heavy-duty pickup trucks
questions will be how the regulation is designed in terms and vans must be chassis dynamometer tested, similar to
of testing methods and certification pathways. Figure the light-duty vehicle certification process). As discussed in
3 (adapted from Sanchez 2013) shows how the various the previous section, regulators in the U.S. and Canada are
certification frameworks around the world compare in currently deliberating 1) how to integrate transmissions into
terms of the mix of simulation and vehicle testing. On the the program, and 2) whether or not to require engine-spe-
continuum, the upper left represents one extreme in which cific data inputs into GEM as part of the Phase 2 regulation.
simulation is the sole basis for certification. As discussed These developments are represented in option (3).
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As shown by the orange and purple arrows in Figure 3, engine standards disrupt their integrated design process
there is an inherent tradeoff in moving in either direction and limit their ability to pursue the most cost-effective
along the continuum. As we move from the top left to means of reducing fuel use and GHG emissions from the
the bottom right, testing costs and capital expenses vehicles that they produce.
increase, while the burden of simulation model fidelity and
validation decreases (or goes away completely in the case Yet another key issue is the linkage of fuel efficiency
of a regulatory scheme that solely relies on chassis dyna- and criteria pollutant emissions standards. Not having a
mometer testing). Conversely, moving in the opposite separate engine standard could divorce the two standards
and open the door for the possibility of gaming (e.g.,
direction, the trends reverse for both parameters. Where
designing an engine control strategy that produces low
India falls on this continuum is a critical question that
nitrogen oxide (NOX) emissions over the engine cycles
policymakers in India are currently deliberating. We will
but higher NOX over vehicle cycles). It is important to
analyze this issue and provide our recommendations over
keep in mind that standards should promote technologies
the remainder of this section.
and engine optimization strategies that will translate
to real-world fuel savings. This is key for customer
4.1 SEPARATE ENGINE STANDARDS IN INDIA acceptance as well as overall societal benefit.
The issue of whether or not separate engine standards Table 4 summarizes some of the key arguments posited
make sense in the Indian context is perhaps the first by both sides of the debate around the existence of
fundamental regulatory design question that must be separate engine standards.
addressed. The HDV market structure in India is similar
to North America in that there are large independent As evidenced in Table 4, there are valid arguments on
component manufacturers (e.g., independent engine both side of the debate. By introducing some additional
and transmission manufacturers) as well as vertically evaluation criteria, we can provide greater clarity as to
integrated vehicle OEMs. This results in an inherent what testing and certification strategy (or combination
tension amongst these two types of companies. In thereof) makes the most sense for India’s first phase
general, engine manufacturers prefer a separate engine regulation and beyond. The assessment criteria we have
standard so that they have clarity regarding technology chosen and the evaluation matrix are shown below in
investments. Conversely, vehicle OEMs contend that Table 5.
For Against
• Maintains linkage of criteria pollutants with CO2 — minimizes • Could promote non-optimal powertrain design — separate
the potential gaming situation in which an engine might be engine standards fail to consider the impact of engine
tuned for low NOX /high CO2 emissions during the engine requirements on vehicle design and vice versa
cycles versus high NOX /low CO2 emissions over vehicle
• Limits compliance flexibility — vehicle OEMs may not be able
cycles and in-use operations
to pursue the most cost-effective pathway to compliance
• Uses existing test procedures — leverages engine cycles,
• Perpetuates inappropriate test cycles — engines are
which industry are very familiar with, in order to minimize the
optimized to the engine certification cycles, which may not
testing burden
accurately represent in-use driving
• Acknowledges the current market structure — allows engines
• Correlates poorly to in-use results — improved efficiency that
to be certified individually and sold into many different
is evidenced on the engine test bench may not translate to
vehicle platforms
real-world fuel savings, depending on the in-use duty cycle
• Can drive improvements in engine and vehicle technologies
— provides engine technology investment clarity for both
independent engine manufacturers and vertically integrated
vehicle manufacturers
5-7 years
? 5-7 years
5-7 years
Chassis dynamometer
3-5 years
Engine dynamometer
The top two rows represent certification pathways for full to familiarize themselves with simulation modeling and the
vehicles based solely on simulation modeling. The only dis- plethora of other research an engagement required to enact
tinction between the two options is the simulation program full vehicle standards, it is reasonable to estimate that a
that is employed: a currently existing simulation model regulation in India centered around simulation could not be
such as VECTO or GEM (or a slightly modified version for finalized for another 3 to 4 years. Assuming that the industry
adaptation in India), or a completely new model that is needs roughly 3 to 4 years of lead-time after a regulation is
developed specifically for a regulatory program in India. codified before actual implementation, our best estimate
In both cases, there is somewhat limited ability to take is that the process of designing, finalizing, and executing a
advantage of existing testing facilities. Certainly, manufac- simulation-based full vehicle regulation in India would take
turers can utilize existing engine dynamometer capacity roughly 6 to 8 years from now to go into effect.
for developing engine map inputs, but it is unclear whether
or not there are sufficient test track facilities in India to The chassis dynamometer option is unattractive for India
accommodate aerodynamic testing (this is also true for primarily based on the limited number of existing facilities
chassis dynamometer testing, which requires coastdown and the significant capital expenditures and time required
or constant speed testing). Looking at the second criteria, to construct new facilities.
complexity of the certification process, there would likely
be a fairly steep learning curve for manufacturers in India Introducing engine-based standards in India as a first phase
to be able to learn an existing simulation model sufficiently regulation for HDV fuel efficiency is attractive for a number
enough to successfully navigate the entire certification of reasons. This option leverages the strong industry famil-
process. Even if a completely new simulation program is iarity with engine testing and presents minimal testing
developed for India, no matter how simplistic the model and compliance burden to manufacturers. Moreover, a
is in terms in inputs and operation, the fact that it is a new efficiency improvement requirement based on engine
new tool will mean a certain level of learning is required dynamometer testing would not likely require any new
amongst manufacturers and the regulatory community. testing infrastructure. A list of the accredited organizations
Given the long lead-time needed for stakeholders in India in India that do heavy-duty testing is provided in Table 6.
The relatively simplistic nature of engine standards 4.2 TRANSITIONING FROM ENGINE STANDARDS
make it such that a regulation could be proposed and TO A MORE COMPREHENSIVE APPROACH
finalized within the next 2 years and then implemented
As engine improvements only represent a subset of the
by the 2020 timeframe. Thus, electing to pursue engine
technologies that are available for improving the efficiency
standards as a first regulatory step maximizes the ability
of HDVs, India will need to transition from an engine testing-
to realize meaningful fuel savings and environmental
based regulation to a more comprehensive ‘full vehicle’
benefits as soon as possible. The primary downside to
approach in order to maximize fuel savings for this sector.
engine standards is that they can potentially yield engines
This more long-term objective must be able to ensure
that are optimized to the test cycles as opposed to being
that technology areas such as aerodynamics, tire rolling
designed to maximize fuel savings during typical vehicle
resistance, transmissions, and weight reduction are included
operations. The extent to which an engine’s actual duty
in the regulatory framework in a manner that makes sense
cycle in real-world driving differs from the standardized
in the Indian context. As discussed in the previous sections,
test cycles will dictate the magnitude if this negative
there are a myriad of different regulatory design and test
impact. However, this issue can be mitigated by intro-
procedure approaches that are available to policymakers
ducing weighting factors to the transient and steady-
in India. Given the challenges and long lead-time needed
state portions of engine cycles such that engines can be
for deciding amongst these options to create protocols for
evaluated to better match what the engine will experience
physical testing and simulation, developing (or adopting)
in an actual HDV such as a tractor truck or transit bus. This
duty cycles, and educating all of the necessary stakeholders
analysis suggests that the benefits of engine standards
about these new procedures, it would be prudent to begin
outweigh the disbenefits, and a first phase regulation
this process as soon as possible. As shown in Figure 4, we
in India centered on engine dynamometer testing is the
recommend that regulators in India actively begin planning
most attractive alternative. Assuming that India develops
the transition to a more comprehensive second phase
engine-based standards using existing engine test cycles,
regulation in parallel to the efforts to design a first phase
there are virtually no technical barriers to finalizing and
regulatory program for engines.
implementing an engine dynamometer-based regulation
by the 2020 timeframe. If regulatory development for engine standards proceeds
such that a proposed rule and then a final regulation can
Table 6: Accredited organizations in India that perform heavy-
duty vehicle testing be established over roughly the next 1-2 years, it seems
reasonable that implementation can begin in the 2020
Organization Location(s) timeframe. This would give manufacturers and the industry
Automotive Research Association as a whole approximately three years of lead-time. In
Pune, Maharashtra
of India (ARAI) addition, as shown in red on the bottom half of the figure,
International Center for Automotive
Gurgaon, Haryana
the process for developing full vehicle standards can
Technology (ICAT) begin in parallel to the regulatory efforts for engines.
Vehicle Research & Development Technical studies to support this process would ideally
Vahannagar, Maharashtra
Establishment (VRDE) include in-depth analyses in the following areas:
Central Farm Machinery Training
Sehore, Madhya Pradesh • Market conditions and anticipated impacts
and Testing Institute (CFMTTI)
Central Institute of Road Transport • Vehicle segmentation
Pune, Maharashtra
(CIRT)
• Technology potential
Indian Institute of Petroleum (IIP) Dehradun, Uttarakhand
• Test procedures and certification pathways
Engine standards
Figure 4: Idealized regulatory timeline for engine and full vehicle standards in India
Table 7: Regulatory design summaries for Japan, the U.S. and Canada, China, and the European Union
* Regulatory design is currently under development in the EU. This information represents an upcoming certification program, not necessarily a standard.
Appendix
100
90
80
Vehicle speed (km/hour)
70
60
50
40
30
20
10
0
0
0
10
20
30
40
50
60
70
80
90
0
17
10
11
12
13
14
15
16
18
Time (seconds)
C-WTVC WHVC
Figure A1: The World Harmonized Vehicle Cycle (WHVC) and the China-World Harmonized Vehicle Cycle (C-WTVC)
Table A2. Regulatory test cycles in Japan, the U.S. and Canada, and China