Comparison of overall and annual average fleet fuel consumption reduction rates under proposed or enacted standards across regions. Source: ICCT. Click to enlarge.

In absolute terms, the proposed standard would put China third, behind the EU and Japan, with respect to passenger car fuel consumption and equivalent GHG emissions requirements during the 2016–2020 period. However, the ICCT cautions, looking only at the absolute fleet targets does not give the full picture of the regulatory stringency of the standards.

The proposed Phase 4 regulation includes both vehicle-maximum fuel consumption limits and a corporate-average fuel consumption (CAFC) standard for each manufacturer based on vehicle curb weight distribution across the manufacturer’s fleet. Manufacturers and importers must meet both standards.

The CAFC standard also sets separate targets for regular vehicles and two types of special-feature vehicles, which in this case are defined as: vehicles of curb mass less than or equal to 1,090 kilograms with three or more rows of seats; all other vehicles with three or more rows of seats.

However, the ICCT authors note, the regulation is expected to contain a variety of compliance flexibilities and credits that will likely reduce the overall stringency of the program.

The proposed Phase 4 standard provides three types of credits:

• New-energy vehicles (battery-electric, fuel cell and plug-in hybrids). New energy vehicles are counted as multiple vehicles towards manufacturers’ CAFC calculation for compliance. The multiplier is set at 5 in 2016–2017, falling to 3 in 2018–2019, and then to 2 in 2020. For the CAFC calculation, the energy consumption of battery-electric vehicles, the electric-drive part of plug-in hybrid vehicles and fuel cell vehicles are counted as zero.

  An alternative possible accounting for pure electric and the electric portion of PHEVs would be to use converted gasoline-equivalent fuel economy with an equation developed from a separate regulatory proposal.

• Other ultra-low fuel consumption vehicles with combined fuel consumption no more than 2.8L/100km (84 mpg US) will be counted as 3 vehicles in 2016–2017, 2.5 in 2018–2019, and 1.5 in 2020.

• Vehicles equipped with innovative technologies leading to real-world fuel saving (off-cycle technology credits). Currently the regulatory agency is considering four types of technologies eligible for the credits: tire pressure monitoring system; high-efficiency air-conditioning system; start-stop system; and transmission gear shift reminder.

  Manufacturers that install one or more of these technologies with demonstrated fuel-saving are eligible for up to 0.5 L/100km credit towards their CAFC standard compliance. The details of the off-cycle fuel-saving technology credits will be specified separately and issued at a later date.

The proposed Phase 4 standard will phase in gradually, beginning in 2016. The proposed standard does not specify any enforcement mechanism.