Rule Making by the EPA Essay

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The EPA proved that it is a mere technology upgradation that is not impossible to meet. However, it required extensive work on the part of the manufacturers, but nevertheless, many manufacturers were meeting the standard of 0.20 g/hp-hr and this made it easier to enforce this standard. Finally, only one manufacturer cannot meet the standards and since this company was running out of credits for 2012, it is estimated that they would need an alternate technology to compete in the market from 2012 onwards.

Medium Heavy Duty Diesel NOX standard

The EPA estimated that the first two criteria have been met for the medium heavy duty diesel vehicles. As with the previous category, only one manufacturer does not meet these standards and they are running out of credits. However, they have not submitted an application for alternate technology for its 2012 models.

Emission standards are currently not being proposed for light heavy-duty diesel NOX standard, heavy-duty gasoline engine standards, heavy-duty diesel engine NMHC, CO and PM standards and heavy duty CO2 standards.

IV. Penalty Rates

The NCP penalty rates are applicable for the model year 2012 and is calculated using a formula that was applied to the previous NCPs.

A. Parameters

The NCP formula takes into account the same parameters that were established in the earlier phases such as COC50, COC90, MC50, F and UL. Besides, it also takes into account the additional costs incurred by the manufacturer as well as the extra owner costs that come with it. However, it does not include certification costs because it is the same for complying and noncomplying manufacturers.

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The proposed calculation for COC50 is $462 for medium heavy-duty and $1,561 for heavy-duty engines; COC90 is $682 for medium heavy-duty and $1,919 for heavy-duty engines; MC50 is $1,540 per gram per horsepower hour for medium heavy-duty and $5,203 for heavy-duty engines; F. is 1.30 for medium heavy-duty and 1.23 for heavy-duty engines and finally, the upper limit (UL) is 0.50 g/hp-hr for both the categories.

B. Issues and Alternatives for NCPs

There are many issues that come up with this penalty structure and they include competitive advantage for non-complying manufacturers, baseline engine technology, hardware and other costs that are not included in the computation, the projected increase in fuel and discount costs, the future value of the costs, escalator adjustment factor for the first year and the calculation of the F. parameter.

V. Economic Impact

The economic impact on the manufacturer may force it to comply with the NCPs. Non-conforming manufacturers will fail the Selecive Enforcement Audit (SEA) and when this happens, the manufacturer has to fix the problem at a higher cost or prevent the vehicle from entering the market. The NCPs give them the third and convenient option and this flexibility may make it easier for the company to introduce its vehicle in the market.

VI. Environmental Impact

The role of the EPA is to reduce pollution and these NCPs will reduce the environmental impact of heavy-duty engines. These NCPs are also designed to help manufacturers to conform to the emission standards over a period of time so that it does not force anyone out of the competition......

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