73478 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
1As discussed in Section I.A, the term heavy- 
duty is generally used in this rulemaking to refer to all vehicles with a gross vehicle weight rating 
above 8,500 lbs, including vehicles that are sometimes otherwise known as medium-duty vehicles. ENVIRONMENTAL PROTECTION 
AGENCY 
40 CFR Parts 9, 22, 85, 86, 600, 1033, 
1036, 1037, 1039, 1042, 1043, 1065, 1066, and 1068 
DEPARTMENT OF TRANSPORTATION National Highway Traffic Safety 
Administration 
49 CFR Parts 523, 534, 535, and 538 
[EPA–HQ–OAR–2014–0827; NHTSA–2014– 
0132; FRL–9950–25–OAR] 
RIN 2060–AS16; RIN 2127–AL52 
Greenhouse Gas Emissions and Fuel 
Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles— Phase 2 
AGENCY : Environmental Protection 
Agency (EPA) and National Highway Traffic Safety Administration (NHTSA), Department of Transportation (DOT). 
ACTION : Final rule. 
SUMMARY : EPA and NHTSA, on behalf of 
the Department of Transportation, are establishing rules for a comprehensive Phase 2 Heavy-Duty (HD) National Program that will reduce greenhouse gas (GHG) emissions and fuel consumption from new on-road medium- and heavy- duty vehicles and engines. NHTSA’s fuel consumption standards and EPA’s carbon dioxide (CO
2) emission 
standards are tailored to each of four regulatory categories of heavy-duty vehicles: Combination tractors; trailers used in combination with those tractors; heavy-duty pickup trucks and vans; and vocational vehicles. The rule also includes separate standards for the engines that power combination tractors and vocational vehicles. Certain requirements for control of GHG emissions are exclusive to the EPA program. These include EPA’s hydrofluorocarbon standards to control leakage from air conditioning systems in vocational vehicles and EPA’s nitrous oxide (N
2O) and methane (CH 4) 
standards for heavy-duty engines. Additionally, NHTSA is addressing misalignment between the Phase 1 EPA GHG standards and the NHTSA fuel 
efficiency standards to virtually eliminate the differences. This action also includes certain EPA-specific provisions relating to control of emissions of pollutants other than GHGs. EPA is finalizing non-GHG emission standards relating to the use of diesel auxiliary power units installed in new tractors. In addition, EPA is clarifying the classification of natural gas engines and other gaseous-fueled heavy-duty engines. EPA is also finalizing technical amendments to EPA rules that apply to emissions of non- GHG pollutants from light-duty motor vehicles, marine diesel engines, and other nonroad engines and equipment. Finally, EPA is requiring that engines from donor vehicles installed in new glider vehicles meet the emission standards applicable in the year of assembly of the new glider vehicle, 
including all applicable standards for criteria pollutants, with limited exceptions for small businesses and for other special circumstances. 
DATES : This final rule is effective on 
December 27, 2016. The incorporation by reference of certain publications listed in this regulation is approved by the Director of the Federal Register as of December 27, 2016. 
ADDRESSES : EPA and NHTSA have 
established dockets for this action under Docket ID No. EPA–HQ–OAR–2014– 0827 (for EPA’s docket) and NHTSA– 2014–0132 (for NHTSA’s docket). All documents in the docket are listed on the https://www.regulations.gov Web 
site. Although listed in the index, some information is not publicly available, e.g., CBI or other information whose 
disclosure is restricted by statute. Certain other material, such as copyrighted material, is not placed on the Internet and will be publicly available only in hard copy form. Publicly available docket materials are available either electronically in https:// 
www.regulations.gov or in hard copy at 
the following locations: 
EPA: Air and Radiation Docket and 
Information Center, EPA Docket Center, EPA/DC, EPA WJC West Building, 1301 Constitution Ave. NW., Room 3334, Washington, DC. The Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Public Reading Room is (202) 566–1744, and the telephone number for the Air Docket is (202) 566–1742. 
NHTSA: Docket Management Facility, 
M–30, U.S. Department of Transportation, West Building, Ground Floor, Rm. W12–140, 1200 New Jersey Avenue SE., Washington, DC 20590. The telephone number for the docket management facility is (202) 366–9324. The docket management facility is open between 9 a.m. and 5 p.m. Eastern Time, Monday through Friday, except Federal Holidays. 
FOR FURTHER INFORMATION CONTACT : 
EPA: Tad Wysor, Office of 
Transportation and Air Quality, Assessment and Standards Division (ASD), Environmental Protection Agency, 2000 Traverwood Drive, Ann Arbor, MI 48105; telephone number: (734) 214–4332; email address: wysor.tad@epa.gov. 
NHTSA: Ryan Hagen, Office of Chief 
Counsel, National Highway Traffic Safety Administration, 1200 New Jersey Avenue SE., Washington, DC 20590. Telephone: (202) 366–2992; ryan.hagen@dot.gov. 
SUPPLEMENTARY INFORMATION : 
A. Does this action apply to me? 
This action will affect companies that 
manufacture, sell, or import into the United States new heavy-duty engines and new Class 2b through 8 trucks, including combination tractors, all types of buses, vocational vehicles including municipal, commercial, recreational vehicles, and commercial trailers as well as 
3⁄4-ton and 1-ton pickup trucks 
and vans. The heavy-duty category incorporates all motor vehicles with a gross vehicle weight rating of 8,500 lbs. or greater, and the engines that power them, except for medium-duty passenger vehicles already covered by the greenhouse gas standards and corporate average fuel economy standards issued for light-duty model year 2017–2025 vehicles.
1Regulated 
categories and entities include the following: 
Category NAICS codea Examples of potentially affected entities 
Industry ............. 336111 Motor Vehicle Manufacturers, Engine Manufacturers, Truck Manufacturers, Truck Trailer Manufacturers . 
336112 
333618 
336120 
336212 
Industry ............. 541514 Commercial Importers of Vehicles and Vehicle Components. 
811112 
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2The White House, The President’s Climate 
Action Plan (June, 2013). http://
www.whitehouse.gov/share/climate-action-plan. 
3United States of America, Intended Nationally 
Determined Contribution, March 31, 2015, http://www4.unfccc.int/submissions/INDC/Published%20Documents/United%20States%20of%20America/1/ U.S.%20Cover%20Note%20INDC%20and%20Accompanying%20Information.pdf. 4EPA’s HD Phase 2 GHG emission standards are 
authorized under the Clean Air Act, and NHTSA’s HD Phase 2 fuel consumption standards are authorized under the Energy Independence and Security Act of 2007. 
5The White House, Improving the Fuel Efficiency 
of American Trucks—Bolstering Energy Security, Cutting Carbon Pollution, Saving Money and Supporting Manufacturing Innovation (Feb. 2014), 2. 
6U.S. Environmental Protection Agency. April 
2016. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990–2012. EPA 430–R–16–002. Mobile sources emitted 28 percent of all U.S. GHG emissions in 2012. Available at https://www3.epa.gov/climatechange/Downloads/ghgemissions/US–GHG-Inventory-2016-Main-Text.pdf. Category NAICS codea Examples of potentially affected entities 
811198 
Industry ............. 336111 Alternative Fuel Vehicle Converters. 
336112 
422720 
454312 
541514 
541690 
811198 
Note: 
aNorth American Industry Classification System (NAICS). 
This table is not intended to be 
exhaustive, but rather provides a guide 
for readers regarding entities likely covered by these rules. This table lists the types of entities that the agencies are aware may be regulated by this action. Other types of entities not listed in the table could also be regulated. To determine whether your activities are regulated by this action, you should carefully examine the applicability criteria in the referenced regulations. You may direct questions regarding the applicability of this action to the persons listed in the preceding 
FOR 
FURTHER INFORMATION CONTACT section. 
B. Did EPA conduct a peer review before issuing this document? 
This regulatory action is supported by 
influential scientific information. Therefore, EPA conducted a peer review consistent with OMB’s Final Information Quality Bulletin for Peer Review. As described in Section II.C, a peer review of updates to the vehicle simulation model (GEM) for the Phase 2 standards has been completed. This version of GEM is based on the model used for the Phase 1 rule, which was peer reviewed by a panel of four independent subject matter experts. The peer review report and EPA’s response to the peer review comments are available in Docket ID No. EPA–HQ– OAR–2014–0827. We note that this rulemaking is based on a vast body of existing peer-reviewed work, i.e., work 
that was peer-reviewed outside of this action, as noted in the references throughout this Preamble, the Regulatory Impacts Analysis, and the rulemaking docket. EPA also notified the SAB of its plans for this rulemaking and on June 11, 2014, the chartered SAB discussed the recommendations of its work group on the planned action and agreed that no further SAB consideration of the supporting science was merited. C. Executive Summary 
(1) Commitment to Greenhouse Gas 
Emission Reductions and Vehicle Fuel Efficiency 
In June 2013, the President 
announced a comprehensive Climate Action Plan for the United States to reduce carbon pollution, prepare for the impacts of climate change, and lead international efforts to address global climate change.
2In this plan, President 
Obama reaffirmed his commitment to reduce U.S. greenhouse gas emissions in the range of 17 percent below 2005 levels by 2020. More recently, in December 2015, the U.S. was one of over 190 signatories to the Paris Climate Agreement, widely regarded as the most ambitious climate change agreement in history. The Paris agreement reaffirms the goal of limiting global temperature increase to well below 2 degrees Celsius, and for the first time urged efforts to limit the temperature increase to 1.5 degrees Celsius. The U.S. submitted a non-binding intended nationally determined contribution (NDC) target of reducing economy-wide GHG emissions by 26–28 percent below its 2005 level in 2025 and to make best efforts to reduce emissions by 28 percent.
3This pace would keep the U.S. 
on a trajectory to achieve deep economy-wide reductions on the order of 80 percent by 2050. 
As part of his Climate Action plan, 
the President specifically directed the Environmental Protection Agency (EPA) and the Department of Transportation’s (DOT) National Highway Traffic Safety Administration (NHTSA) to set the next round of standards to reduce greenhouse gas (GHG) emissions and improve fuel efficiency for heavy-duty vehicles pursuant to and consistent with the agencies’ existing statutory authorities.
4More than 70 percent of the 
oil used in the United States and 26 
percent of GHG emissions come from the transportation sector, and since 2009 EPA and NHTSA have worked with industry, states, and other stakeholders to develop ambitious, flexible standards for both the fuel economy and GHG emissions of light-duty vehicles and the fuel efficiency and GHG emissions of heavy-duty vehicles.
56The standards 
here (referred to as Phase 2) will build 
on the light-duty vehicle standards spanning model years 2012 to 2025 and on the initial phase of standards (referred to as Phase 1) for new medium and heavy-duty vehicles (MDVs and HDVs) and engines in model years 2014 to 2018. Throughout every stage of development for these programs, EPA and NHTSA (collectively, the agencies, or ‘‘we’’) have worked in close partnership not only with one another, but also with the vehicle manufacturing industry, environmental community leaders, and the State of California among other entities to create a single, effective set of national standards. 
Through two previous rulemakings, 
EPA and NHTSA have worked with the auto industry to develop new fuel economy and GHG emission standards for light-duty vehicles. Taken together with NHTSA’s 2011 CAFE standards, the light-duty vehicle standards span model years 2011 to 2025 and are the first significant improvement in fuel economy in approximately two decades. Under the final program, average new car and light truck fuel economy is expected to nearly double by 2025 
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7The White House, Improving the Fuel Efficiency 
of American Trucks—Bolstering Energy Security, 
Cutting Carbon Pollution, Saving Money and Supporting Manufacturing Innovation (Feb. 2014), 2. 
8Id. 
9Id. at 3. 
10Id. 
11Id. 
12Id. at 4. 13The President’s Climate Action Plan calls for 
GHG-cutting actions including, for example, reducing carbon emissions from power plants and curbing hydrofluorocarbon and methane emissions. 
14‘‘Heavy-Duty Phase 2 Stakeholder Meeting 
Log’’, August 2016. 15The Phase 2 program will also include NHTSA 
recreational vehicle fuel efficiency standards. 
16The White House, Improving the Fuel 
Efficiency of American Trucks—Bolstering Energy compared to 2010 vehicles.7In the 2012 
rule, the agencies projected the 
standards would save consumers $1.7 trillion at the pump—roughly $8,200 per vehicle for a MY 2025 vehicle— reducing oil consumption by 2.2 million barrels a day in 2025 and slashing GHG emissions by 6 billion metric tons over the lifetime of the vehicles sold during this period.
8These fuel economy 
standards are already delivering savings for American drivers. Between model years 2008 and 2013, the unadjusted average test fuel economy of new passenger cars and light trucks sold in the United States has increased by about four miles per gallon. Altogether, light- duty vehicle fuel economy standards finalized after 2008 have already saved nearly one billion gallons of fuel and avoided more than 10 million tons of carbon dioxide emissions.
9 
Similarly, EPA and NHTSA have 
previously developed joint GHG emission and fuel efficiency standards for MDVs and HDVs. Prior to these Phase 1 standards, heavy-duty trucks and buses—from delivery vans to the largest tractor-trailers—were required to meet pollution standards for soot and smog-causing air pollutants, but no requirements existed for the fuel efficiency or carbon pollution from these vehicles.
10By 2010, total fuel 
consumption and GHG emissions from MDVs and HDVs had been growing, and these vehicles accounted for 23 percent of total U.S. transportation-related GHG emissions
11and about 20 percent of 
U.S. transportation-related energy use. 
In August 2011, the agencies finalized the groundbreaking Phase 1 standards for new MDVs and HDVs in model years 2014 through 2018. This program, developed with support from the trucking and engine industries, the State of California, Environment and Climate Change Canada, and leaders from the environmental community, set standards based on the use of off-the- shelf technologies. These standards are expected to save a projected 530 million barrels of oil and reduce carbon emissions by about 270 million metric tons, representing one of the most significant programs available to reduce domestic fuel consumption and emissions of GHGs.
12The Phase 1 
program, as well as the many additional actions called for in the President’s 2013 
Climate Action Plan13including this 
Phase 2 rulemaking, not only result in meaningful decreases in GHG emissions and fuel consumption, but also support—indeed are critical for—United States leadership to encourage other countries to also achieve meaningful GHG reductions and fuel conservation. 
This rule builds on our commitment 
to robust collaboration with stakeholders and the public. It follows an expansive and thorough outreach effort in which the agencies gathered input, data and views from many interested stakeholders, involving over 400 meetings with heavy-duty vehicle and engine manufacturers, technology suppliers, trucking fleets, truck drivers, dealerships, environmental organizations, and state agencies.
14As 
with the previous light-duty rules and the heavy-duty Phase 1 rule, the agencies have consulted frequently with the California Air Resources Board (CARB) staff during the development of this rule, given California’s unique ability among the states to adopt their own GHG standards for on-highway engines and vehicles. Through this close coordination, the agencies are finalizing a Phase 2 program that will be fully aligned between EPA and NHTSA, while providing CARB with the opportunity to adopt a Phase 2 program that will allow manufacturers to continue to build a single fleet of vehicles and engines. 
(2) Overview of Phase 1 Medium- and 
Heavy-Duty Vehicle Standards 
The Phase 1 program covers new 
trucks and heavy vehicles in model years 2014 and later. That program includes specific standards for combination tractors, heavy-duty 
pickup trucks and vans, and vocational vehicles and includes separate standards for both vehicles and engines. The program offers extensive flexibility, allowing manufacturers to reach standards through average fleet calculations, a mix of technologies, and the use of various credit and banking programs. 
The Phase 1 program was developed 
by the agencies through close consultation with industry and other stakeholders, resulting in standards tailored to the specifics of each different class of vehicles and engines. 
•Heavy-duty combination tractors. 
Combination tractors—semi trucks that typically pull trailers—are regulated under nine subcategories based on weight class, cab type, and roof height. These vehicles represent approximately 60 percent of the fuel consumption and GHG emissions from MDVs and HDVs. 
•Heavy-duty pickup trucks and vans. 
Heavy-duty pickup and van standards are based on a ‘‘work factor’’ attribute that combines a vehicle’s payload, towing capabilities, and the presence of 4-wheel drive. These vehicles represent about 23 percent of the fuel consumption and GHG emissions from MDVs and HDVs. 
•Vocational vehicles. Specialized 
vocational vehicles, which consist of a very wide variety of truck and bus types (e.g., delivery, refuse, utility, dump, 
cement, transit bus, shuttle bus, school bus, emergency vehicles, and recreational vehicles) are regulated in three subcategories based on engine classification. These vehicles represent approximately 17 percent of the fuel consumption and GHG emissions from MDVs and HDVs. The Phase 1 program includes EPA GHG standards for recreational vehicles, but not NHTSA fuel efficiency standards.
15 
•Heavy-duty engines. The Phase 1 
rule has independent standards for heavy-duty engines to assure they contribute to reducing GHG emissions and fuel consumption because the Phase 1 tractor and vocational vehicle standards do not account for the contributions of engine improvements to reducing fuel consumption and GHG emissions. 
The Phase 1 standards were premised 
on utilization of technologies that were already in production on some vehicles at the time of the Phase 1 FRM and are adaptable to the broader fleet. The Phase 1 program provides flexibilities that facilitate compliance. These flexibilities help provide sufficient lead time for manufacturers to make necessary technological improvements and reduce the overall cost of the program, without compromising overall environmental and fuel consumption objectives. The primary flexibility provisions are an engine averaging, banking, and trading (ABT) program and a vehicle ABT program. These ABT programs allow for emission and/or fuel consumption credits to be averaged, banked, or traded within each of the averaging sets. 
The Phase 1 program was projected to 
save 530 million barrels of oil and avoid 270 million metric tons of GHG emissions.
16At the same time, the 
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Security, Cutting Carbon Pollution, Saving Money and Supporting Manufacturing Innovation (Feb. 
2014), 4. program was projected to produce $50 
billion in fuel savings and $49 billion of net societal benefits. Today, the Phase 1 fuel efficiency and GHG reduction standards are already reducing GHG emissions and U.S. oil consumption, and producing fuel savings for America’s trucking industry. The market appears to be very accepting of the Phase 1 technologies. 
(3) Overview of Phase 2 Medium- and 
Heavy-Duty Vehicle Standards 
The Phase 2 GHG and fuel efficiency 
standards for MDVs and HDVs are a critical next step in improving fuel efficiency and reducing GHG emissions. The Phase 2 national program carries forward our commitment to meaningful collaboration with stakeholders and the public, as they build on more than 400 meetings with manufacturers, suppliers, trucking fleets, dealerships, state air quality agencies, non-governmental organizations (NGOs), and other stakeholders; over 200,000 public comments; and two public hearings to identify and understand the opportunities and challenges involved with this next level of fuel-saving technology. These meetings and public feedback, in addition to close coordination with CARB, have been invaluable to the agencies, enabling the development of a program that appropriately balances all potential impacts, effectively minimizes the possibility of unintended consequences, and allows manufacturers to continue to build a single fleet of vehicles and engines. 
Phase 2 will include technology- 
advancing standards that will phase in over the long-term (through model year 2027) to result in an ambitious, yet achievable program that will allow manufacturers to meet standards 
through a mix of different technologies at reasonable cost. The terminal requirements go into effect in 2027, and would apply to MY 2027 and subsequent model year vehicles, unless modified by future rulemaking. The Phase 2 standards will maintain the underlying regulatory structure developed in the Phase 1 program, such as the general categorization of MDVs and HDVs and the separate standards for vehicles and engines. However, the Phase 2 program will build on and advance Phase 1 in a number of important ways including the following: basing standards not only on currently available technologies but also on utilization of technologies now under development or not yet widely deployed 
while providing significant lead time to assure adequate time to develop, test, and phase in these controls; developing first-time GHG and fuel efficiency standards for trailers; further encouraging innovation and providing flexibility; including vehicles produced by small business manufacturers with appropriate flexibilities for these companies; incorporating enhanced test procedures that (among other things) allow individual drivetrain and powertrain performance to be reflected in the vehicle certification process; and using an expanded and improved compliance simulation model. 
The Phase 2 program will provide 
significant GHG reductions and save fuel by: 
•Strengthening standards to account 
for ongoing technological advancements. Relative to the baseline 
as of the end of Phase 1, these final standards are projected to achieve vehicle fuel savings as high as 25 percent, depending on the vehicle category. While costs are higher than for Phase 1, benefits greatly exceed costs, and payback periods are short, meaning that consumers will see substantial net savings over the vehicle lifetime. Payback is estimated at about two years for tractors and trailers, about four years for vocational vehicles, and about three years for heavy-duty pickups and vans. The agencies are finalizing a program that phases in the MY 2027 standards with interim standards for model years 2021 and 2024 (and for certain types of trailers, EPA is finalizing model year 
2018 phase-in standards as well). The final program includes both significant strengthening of certain standards from the NPRM as well as adjustments to better align other standards with new data, analysis, and stakeholder and public feedback received since the time of the proposal. 
•Setting standards for trailers for the 
first time. In addition to retaining the vehicle and engine categories covered in the Phase 1 program, the Phase 2 standards include fuel efficiency and GHG emission standards for trailers used in combination with tractors. Although the agencies are not finalizing standards for all trailer types, the majority of new trailers will be covered. 
•Encouraging technological 
innovation while providing flexibility and options for manufacturers. For each category of HDVs, the standards will set performance targets that allow manufacturers to achieve reductions through a mix of different technologies 
and generally leave manufacturers free to choose any means of compliance. For tractor standards, for example, different combinations of improvements like advanced aerodynamics, engine improvements and waste-heat recovery, 
automated transmission, lower rolling resistance tires, and automatic tire inflation can be used to meet standards. For tractors and vocational vehicles, enhanced test procedures and an expanded and improved compliance simulation model enable the vehicle standards to encompass more of the complete vehicle than the Phase 1 program and to account for engine, transmission and driveline improvements. With the addition of the powertrain and driveline to the compliance model, representative drive cycles and vehicle baseline configurations become critically important to assure the standards promote technologies that improve real world fuel efficiency and GHG emissions. This rule updates drive cycles and vehicle configurations to better reflect real world operation. The final program includes adjustments to technical elements of the proposed compliance program, e.g., test 
procedures, reflecting the significant amount of stakeholder and public comment the agencies received on the program. Additionally, the agencies’ analyses indicate that this rule should have no adverse impact on vehicle or engine safety. 
•Providing flexibilities to help 
minimize effect on small businesses. All small businesses are exempt from the Phase 1 standards. The agencies are regulating small business entities under Phase 2 (notably certain trailer manufacturers), but we have conducted extensive proceedings pursuant to section 609 of the Regulatory Flexibility Act, and engaged in extensive consultation with stakeholders, and developed an approach to provide targeted flexibilities geared toward helping small businesses comply with the Phase 2 standards. Specifically, the agencies are delaying the initial implementation of the Phase 2 standards by one year and simplifying certification requirements for small businesses. We are also adopting additional flexibilities and exemptions adapted to particular vehicle categories. 
The following tables summarize the 
impacts of the Heavy-Duty Phase 2 rule. 
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SUMMARY OF THE PHASE 2 M EDIUM - ANDHEAVY -DUTYVEHICLE RULEIMPACTS TO FUELCONSUMPTION , GHG 
EMISSIONS , BENEFITS AND COSTS OVER THE LIFETIME OF MODEL YEARS 2018–2029ab 
3% 7% 
Fuel Reductions (billion gallons) .............................................................................................. ............................... 71–82 
GHG Reductions (MMT, CO 2eq) ............................................................................................................................. 959–1098 
Pre-Tax Fuel Savings ($billion) ................................................................................................ ............................... 149–169 80–87 
Discounted Technology Costs ($billion) ......................................................................................... ......................... 24–27 16–18 
Value of reduced emissions ($billion) .......................................................................................... ........................... 60–69 48–52 
Total Costs ($billion) ......................................................................................................... ....................................... 29–31 19–20 
Total Benefits ($billion) ...................................................................................................... ...................................... 225–260 136–151 
Net Benefits ($billion) ........................................................................................................ ...................................... 197–229 117–131 
Notes: 
aRanges reflect two analysis methods: Method A with the 1b baseline and Method B with the la baseline. For an explanation of ana lytical 
Methods A and B, please see Section I.D; for an explanation of the ‘‘flat’’ baseline, 1a, and the ‘‘dynamic’’ baseline, 1b, please see Section 
X.A.1. 
bBenefits and net benefits (including those in the 7% discount rate column) use the 3 percent average Social Cost of CO 2, the Social Cost of 
CH4, and the Social Cost of N 2O. 
SUMMARY OF THE PHASE 2 M EDIUM - ANDHEAVY -DUTYVEHICLE ANNUAL FUEL AND GHG R EDUCTIONS , PROGRAM  
COSTS , BENEFITS AND NETBENEFITS IN CALENDAR YEARS 2040 AND2050a 
2040 2050 
Fuel Reductions (Billion Gallons) .............................................................................................. .............................. 10.8 13.0 
GHG Reduction (MMT, CO 2eq) ............................................................................................................................ .. 166.8 199.3 
Vehicle Program Costs (including Maintenance; Billions of 2013$) ............................................................... ........ ¥$6.5 ¥$7.5 
Fuel Savings (Pre-Tax; Billions of 2013$) ...................................................................................... ......................... $53.1 $63.4 
Benefits (Billions of 2013$) ................................................................................................... ................................... $24.8 $31.7 
Net Benefits (Billions of 2013$) ............................................................................................... ................................ $71.4 $87.6 
Note: 
aBenefits and net benefits (including those in the 7% discount rate column) use the 3 percent average Social Cost of CO 2, the Social Cost of 
CH4, and the Social Cost of N 2O. Values reflect the final program using Method B relative to the flat baseline (a reference case that projects very 
little improvement in new vehicle fuel economy absent new standards). 
SUMMARY OF THE PHASE 2 M EDIUM - ANDHEAVY -DUTYVEHICLE PROGRAM EXPECTED PER-VEHICLE FUELSAVINGS , 
GHG E MISSION REDUCTIONS , ANDCOST FOR KEYVEHICLE CATEGORIES  
MY 2021 MY 2024 MY 2027 
Maximum Vehicle Fuel Savings and Tailpipe GHG Reduction (%): 
Tractorsb............................................................................................................ 13 20 25 
Trailersa.............................................................................................................. 5 7 9 
Vocational Vehiclesb.......................................................................................... 12 20 24 
Pickups/Vans ...................................................................................................... 2.5 10 16 
Per Vehicle Cost ($)cd(% Increase in Typical Vehicle Price): 
Tractors ............................................................................................................... $6,400–$6,480 
(6%) $9,920–$10,100 
(10%) $12,160–$12,440 
(12%) 
Trailers ................................................................................................................ $850–$870 
(3%) $1,000–$1,030 
(4%) $1,070–$1,110 
(4%) 
Vocational Vehicles ............................................................................................ $1,110–$1,160 
(1%) $1,980–$2,020 
(2%) $2,660–$2,700 
(3%) 
Pickups/Vans ...................................................................................................... $520–$750 
(1%) $760–$960 
(2%) $1,340–$1,360 
(3%) 
Notes: 
aNote that the EPA standards for trailers begin in model year 2018 
bAll engine costs are included 
cPlease refer to Preamble Chapters 6 and 10 for additional information on the reference fleet used to analyze costs and benefits of the rule. 
Please also refer to these chapters for impacts of the rule under more dynamic baseline assumptions for pickups and vans. 
dRanges reflect two analysis methods: Method A with the 1b baseline and Method B with the la baseline. For an explanation of ana lytical 
Methods A and B, please see Section I.D; for an explanation of the ‘‘flat’’ baseline, 1a, and the ‘‘dynamic’’ baseline, 1b, please see Section X.A.1. 
eFor this table, we use an approximate minimum vehicle price today of $100,000 for tractors, $25,000 for trailers, $100,000 for vocational vehi-
cles and $40,000 for HD pickups/vans. 
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17Available on EPA and NHTSA’s Web sites and 
in the public docket for this rulemaking. 
18Available on EPA’s Web site and in the public 
docket for this rulemaking. PAYBACK PERIODS FOR MY 2027 V E-
HICLES UNDER THE FINAL STAND -
ARDS , B ASED ON BOTH ANALYSIS  
METHODS A ANDB 
[Payback occurs in the year shown; using 7% 
discounting] 
Final 
standards 
Tractors/Trailers ........................... 2nd. 
Vocational Vehicles ...................... 4th. 
Pickups/Vansa.............................. 3rd. 
Note: 
aPlease refer to Preamble Chapters 6 and 
10 for additional information on the reference 
fleet used to analyze costs and benefits of the rule. Please also refer to these chapters for impacts of the rule under more dynamic base-line assumptions for pickups and vans. 
(4) Issues Addressed in This Final Rule 
This Preamble contains extensive 
discussion of the background, elements, 
and implications of the Phase 2 program, as well as updates made to the final program from the proposal based on new data, analysis, stakeholder feedback and public comments. Section I includes information on the MDV and HDV industry, related regulatory and non-regulatory programs, summaries of Phase 1 and Phase 2 programs, costs and benefits of the final standards, and relevant statutory authority for EPA and NHTSA. Section II discusses vehicle simulation, engine standards, and test procedures. Sections III, IV, V, and VI detail the final standards for combination tractors, trailers, vocational vehicles, and heavy-duty pickup trucks and vans. Sections VII and VIII discuss aggregate GHG impacts, fuel consumption impacts, climate impacts, and impacts on non-GHG emissions. Section IX evaluates the economic impacts of the final program. Sections X and XI present the alternatives analyses and consideration of natural gas vehicles. Finally, Sections XII and XIII discuss the changes that the Phase 2 rules will have on Phase 1 standards and other regulatory provisions. In addition to this Preamble, the Regulatory Impact Analysis (RIA),
17 
provides additional data, analysis and discussion of the standards, and the Response to Comments Document for Joint Rulemaking (RTC) provides responses to comments received on the Phase 2 rulemaking through the public comment process.
18 
Table of Contents 
A. Does this action apply to me? B. Did EPA conduct a peer review before 
issuing this document? 
C. Executive Summary 
I. Overview 
A. Background 
B. Summary of Phase 1 Program C. Summary of the Phase 2 Standards and 
Requirements 
D. Summary of the Costs and Benefits of 
the Final Rules 
E. EPA and NHTSA Statutory Authorities F. Other Issues 
II. Vehicle Simulation and Separate Engine 
Standards for Tractors and Vocational Chassis 
A. Introduction B. Phase 2 Regulatory Structure C. Phase 2 GEM and Vehicle Component 
Test Procedures 
D. Engine Test Procedures and Engine 
Standards 
III. Class 7 and 8 Combination Tractors 
A. Summary of the Phase 1 Tractor 
Program 
B. Overview of the Phase 2 Tractor 
Program and Key Changes From the Proposal 
C. Phase 2 Tractor Standards D. Feasibility of the Final Phase 2 Tractor 
Standards 
E. Phase 2 Compliance Provisions for 
Tractors 
F. Flexibility Provisions 
IV. Trailers 
A. The Trailer Industry 
B. Overview of the Phase 2 Trailer Program 
and Key Changes From the Proposal 
C. Phase 2 Trailer Standards D. Feasibility of the Trailer Standards E. Trailer Standards: Compliance and 
Flexibilities 
V. Class 2b–8 Vocational Vehicles 
A. Summary of Phase 1 Vocational Vehicle 
Standards 
B. Phase 2 Standards for Vocational 
Vehicles 
C. Feasibility of the Vocational Vehicle 
Standards 
D. Compliance Provisions for Vocational 
Vehicles 
VI. Heavy-Duty Pickups and Vans 
A. Summary of Phase 1 HD Pickup and 
Van Standards 
B. HD Pickup and Van Final Phase 2 
Standards 
C. Use of the CAFE Model in Heavy-Duty 
Rulemaking 
D. NHTSA CAFE Model Analysis of the 
Regulatory Alternatives for HD Pickups and Vans: Method A 
E. Analysis of the Regulatory Alternatives 
for HD Pickups and Vans: Method B 
F. Compliance and Flexibility for HD 
Pickup and Van Standards 
VII. Aggregate GHG, Fuel Consumption, and 
Climate Impacts 
A. What methodologies did the agencies 
use to project GHG emissions and fuel consumption impacts? 
B. Analysis of Fuel Consumption and GHG 
Emissions Impacts Resulting From Final Standards 
C. What are the projected reductions in 
fuel consumption and GHG emissions? 
D. Climate Impacts and Indicators 
VIII. How will these rules impact non-GHG 
emissions and their associated effects? A. Health Effects of Non-GHG Pollutants B. Environmental Effects of Non-GHG 
Pollutants 
C. Emissions Inventory Impacts D. Air Quality Impacts of Non-GHG 
Pollutants 
IX. Economic and Other Impacts 
A. Conceptual Framework B. Vehicle-Related Costs Associated With 
the Program 
C. Changes in Fuel Consumption and 
Expenditures 
D. Maintenance Expenditures E. Analysis of the Rebound Effect F. Impact on Class Shifting, Fleet 
Turnover, and Sales 
G. Monetized GHG Impacts H. Monetized Non-GHG Health Impacts I. Energy Security Impacts J. Other Impacts K. Summary of Benefits and Costs 
L. Employment Impacts M. Cost of Ownership and Payback 
Analysis 
N. Safety Impacts 
X. Analysis of the Alternatives 
A. What are the alternatives that the 
agencies considered? 
B. How do these alternatives compare in 
overall fuel consumption and GHG emissions reductions? 
XI. Natural Gas Vehicles and Engines 
A. Natural Gas Engine and Vehicle 
Technology 
B. GHG Lifecycle Analysis for Natural Gas 
Vehicles 
C. Projected Use of LNG and CNG D. Natural Gas Emission Control Measures E. Dimethyl Ether 
XII. Amendments to Phase 1 Standards 
A. EPA Amendments B. Other Compliance Provisions for 
NHTSA 
XIII. Other Regulatory Provisions 
A. Amendments Related to Heavy-Duty 
Highway Engines and Vehicles 
B. Amendments Affecting Glider Vehicles 
and Glider Kits 
C. Applying the General Compliance 
Provisions of 40 CFR Part 1068 to Light- Duty Vehicles, Light-Duty Trucks, Chassis-Certified Class 2b and 3 Heavy- Duty Vehicles and Highway Motorcycles 
D. Amendments to General Compliance 
Provisions in 40 CFR Part 1068 
E. Amendments to Light-Duty Greenhouse 
Gas Program Requirements 
F. Amendments to Highway and Nonroad 
Test Procedures and Certification Requirements 
G. Amendments Related to Locomotives in 
40 CFR Part 1033 
H. Amendments Related to Nonroad Diesel 
Engines in 40 CFR Part 1039 
I. Amendments Related to Marine Diesel 
Engines in 40 CFR Parts 1042 and 1043 
J. Miscellaneous EPA Amendments K. Competition Vehicles L. Amending 49 CFR Parts 512 and 537 To 
Allow Electronic Submissions and Defining Data Formats for Light-Duty Vehicle Corporate Average Fuel Economy (CAFE) Reports 
XIV. Statutory and Executive Order Reviews 
A. Executive Order 12866: Regulatory 
Planning and Review and Executive 
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1980 FR 40137. 
2081 FR 10824. 212017 and Later Model Year Light-Duty Vehicle 
Greenhouse Gas Emissions and Corporate Average 
Fuel Economy Standards; Final Rule, 77 FR 62623, October 15, 2012. 
22The CAA defines heavy-duty as a truck, bus or 
other motor vehicles with a gross vehicle weight rating exceeding 6,000 lbs (CAA section 202(b)(3)). The term HD as used in this action refers to a subset of these vehicles and engines. 
23The Energy Independence and Security Act of 
2007 requires NHTSA to set standards for commercial medium- and heavy-duty on-highway vehicles, defined as on-highway vehicles with a GVWR of 10,000 lbs or more, and work trucks, defined as vehicles with a GVWR between 8,500 and 10,000 lbs and excluding medium duty passenger vehicles. 
24The term ‘‘medium-duty’’ is sometimes used to 
refer to the lighter end of this range of vehicles. This is typically in the context of statutes or reports that use the term ‘‘medium-duty.’’ For example, because the term medium-duty is used in EISA, the term is also used in much of the discussion of NHTSA’s statutory authority. 
25Vehicle chassis manufacturers are known in 
this industry as original equipment manufacturers 
or OEMs. Order 13563: Improving Regulation and 
Regulatory Review 
B. National Environmental Policy Act C. Paperwork Reduction Act D. Regulatory Flexibility Act E. Unfunded Mandates Reform Act F. Executive Order 13132: Federalism G. Executive Order 13175: Consultation 
and Coordination With Indian Tribal Governments 
H. Executive Order 13045: Protection of 
Children From Environmental Health Risks and Safety Risks 
I. Executive Order 13211: Actions 
Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use 
J. National Technology Transfer and 
Advancement Act and 1 CFR Part 51 
K. Executive Order 12898: Federal Actions 
To Address Environmental Justice in Minority Populations and Low-Income Populations 
L. Endangered Species Act (ESA) M. Congressional Review Act (CRA) 
XV. EPA and NHTSA Statutory Authorities 
A. EPA B. NHTSA 
List of Subjects 
I. Overview 
The agencies issued a Notice of 
Proposed Rulemaking (NPRM) on July 
13, 2015, that proposed Phase 2 GHG and fuel efficiency standards for heavy- duty engines and vehicles.
19The 
agencies also issued a Notice of Data Availability (NODA) on March 2, 2016, to solicit comment on new material not available at the time of the NPRM.
20The 
agencies have revised the proposed standards and related requirements to address issues raised in public comments. Nevertheless, the final rules being adopted today remain fundamentally similar to the proposed rules. 
Although the agencies describe the 
final requirements in this document, readers are encouraged to also read supporting materials that have been place into the public dockets for these rules. In particular, the agencies note: 
•The Final Regulatory Impact Analysis 
(RIA), provides additional technical 
information and analysis 
•The Response to Comments 
Document for Joint Rulemaking (RTC), provides a detailed summary and analysis of public comments, including comments received in response to the NODA 
•The NHTSA Final Environmental 
Impact Statement (FEIS) 
This overview of the final Phase 2 
GHG emissions and fuel efficiency 
standards includes a description of the heavy-duty truck industry and related regulatory and non-regulatory programs, 
a summary of the Phase 1 GHG emissions and fuel efficiency program, a summary of the Phase 2 standards and requirements being finalized, a summary of the costs and benefits of the Phase 2 standards, discussion of EPA and NHTSA statutory authorities, and other issues. 
A. Background 
For purposes of this Preamble (and 
consistent with all terminology used at 
proposal), the terms ‘‘heavy-duty’’ or ‘‘HD’’ are used to apply to all highway vehicles and engines that are not within the range of light-duty passenger cars, light-duty trucks, and medium-duty passenger vehicles (MDPV) covered by separate GHG and Corporate Average Fuel Economy (CAFE) standards.
21(The 
terms also do not include motorcycles). 
Thus, in this rulemaking, unless specified otherwise, the heavy-duty category incorporates all vehicles with a gross vehicle weight rating above 8,500 lbs, and the engines that power them, except for MDPVs.
22 23 24 Note also that 
the terms heavy-duty truck and heavy- duty vehicle are sometimes used interchangeably, even though commercially the term heavy-duty truck can have a narrower meaning. 
Consistent with the President’s 
direction, over the past three years as we have developed this rulemaking, the agencies have met on an on-going basis with a very large number of diverse stakeholders. This includes meetings, and in many cases site visits, with truck, trailer, and engine manufacturers; technology supplier companies and their trade associations (e.g., transmissions, drivelines, fuel systems, turbochargers, tires, catalysts, and many others); line haul and vocational trucking firms and trucking associations; the trucking industries owner-operator association; truck 
dealerships and dealers associations; trailer manufacturers and their trade association; non-governmental organizations (NGOs, including environmental NGOs, national security NGOs, and consumer advocacy NGOs); state air quality agencies; manufacturing labor unions; and many other stakeholders. In addition, EPA and NHTSA have consulted on an on-going basis with the California Air Resources Board (CARB) over the past three years as we developed the Phase 2 rule. CARB staff and managers have also participated with EPA and NHTSA in meetings with many external stakeholders, including those with vehicle OEMs and technology suppliers.
25 
EPA and NHTSA staff also 
participated in a large number of technical and policy conferences over the past three years related to the technological, economic, and environmental aspects of the heavy-duty trucking industry. The agencies also met with regulatory counterparts from several other nations who either have already or are considering establishing fuel consumption or GHG requirements, including outreach with representatives from the governments of Canada, the European Commission, Japan, and China. 
These comprehensive outreach 
actions by the agencies provided us with information to assist in our identification of potential technologies that can be used to reduce heavy-duty GHG emissions and improve fuel efficiency. The outreach has also helped the agencies to identify and understand the opportunities and challenges involved with these standards for the heavy-duty trucks, trailers, and engines detailed in this Preamble, including time needed for implementation of various technologies and potential costs and fuel savings. The scope of this outreach effort to gather input for the proposal and final rulemaking included well over 400 meetings with stakeholders. These meetings and conferences have been invaluable to the agencies. We believe they enabled us to refine the proposal in such a way as to appropriately consider all of the potential impacts and to minimize the possibility of unintended consequences in the final rules. 
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26GVWR describes the maximum load that can be 
carried by a vehicle, including the weight of the 
vehicle itself. Heavy-duty vehicles (including those 
designed for primary purposes other than towing) also have a gross combined weight rating (GCWR), which describes the maximum load that the vehicle 
can haul, including the weight of a loaded trailer and the vehicle itself. 
27Class 2b vehicles manufactured as passenger 
vehicles (Medium Duty Passenger Vehicles, MDPVs) are covered by the light-duty GHG and fuel 
economy standards and therefore are not addressed in this rulemaking. (1) Brief Overview of the Heavy-Duty 
Truck Industry 
The heavy-duty sector is diverse in 
several respects, including the types of manufacturing companies involved, the range of sizes of trucks and engines they produce, the types of work for which the trucks are designed, and the regulatory history of different subcategories of vehicles and engines. 
The current heavy-duty fleet encompasses vehicles from the ‘‘18- wheeler’’ combination tractor-trailers 
one sees on the highway to the largest pickup trucks and vans, as well as vocational vehicles covering the range between these extremes. Together, the HD sector spans a wide range of vehicles with often specialized form and function. A primary indicator of the diversity among heavy-duty trucks is the range of load-carrying capability across the industry. The heavy-duty truck sector is often subdivided by vehicle weight classifications, as defined by the vehicle’s gross vehicle weight rating (GVWR), which is a measure of the combined curb (empty) weight and cargo carrying capacity of the truck.
26Table I–1 below outlines the 
vehicle weight classifications commonly used for many years for a variety of purposes by businesses and by several Federal agencies, including the Department of Transportation, the Environmental Protection Agency, the Department of Commerce, and the Internal Revenue Service. 
TABLE I–1—V EHICLE WEIGHT CLASSIFICATION  
Class 2b 3 4 5 6 7 8 
GVWR (lb.) ........................... 8,501–10,000 10,001–14,000 14,001–16,000 16,001–19,500 19,501–26,000 26,001–33,000 >33,000  
In the framework of these vehicle weight classifications, the heavy-duty truck sector refers to ‘‘Class 2b’’ through ‘‘Class 8’’ vehicles and the engines that power those vehicles.
27 
Unlike light-duty vehicles, which are 
primarily used for transporting passengers for personal travel, heavy- duty vehicles fill much more diverse operator needs. Heavy-duty pickup trucks and vans (Classes 2b and 3) are used chiefly as work trucks and vans, and as shuttle vans, as well as for personal transportation, with an average annual mileage in the range of 15,000 miles. The rest of the heavy-duty sector is used for carrying cargo and/or performing specialized tasks. ‘‘Vocational’’ vehicles, which span Classes 2b through 8, vary widely in size, including smaller and larger van trucks, utility ‘‘bucket’’ trucks, tank trucks, refuse trucks, urban and over- the-road buses, fire trucks, flat-bed trucks, and dump trucks, among others. The annual mileage of these vehicles is as varied as their uses, but for the most part tends to fall in between heavy-duty pickups/vans and the large combination tractors, typically from 15,000 to 150,000 miles per year. 
Class 7 and 8 combination tractor- 
trailers—some equipped with sleeper cabs and some not—are primarily used for freight transportation. They are sold as tractors and operate with one or more trailers that can carry up to 50,000 lbs or more of payload, consuming significant quantities of fuel and producing significant amounts of GHG emissions. Together, Class 7 and 8 tractors and trailers account for approximately 60 percent of the heavy- duty sector’s total CO
2emissions and 
fuel consumption. Trailer designs vary significantly, reflecting the wide variety of cargo types. However, the most common types of trailers are box vans (dry and refrigerated), which are a focus of this Phase 2 rulemaking. The tractor- trailers used in combination applications can and frequently do travel more than 150,000 miles per year and can operate for 20–30 years. 
Heavy-duty vehicles differ 
significantly from light-duty vehicles in other ways. In particular, we note that heavy-duty engines are much more likely to be rebuilt. In fact, it is common for Class 8 engines to be rebuilt multiple times. Commercial heavy-duty vehicles are often resold after a few years and may be repurposed by the second or third owner. Thus issues of resale value and adaptability have historically been key concerns for purchasers. 
EPA and NHTSA have designed our 
respective standards in careful consideration of the diversity and complexity of the heavy-duty truck industry, as discussed in Section I.C. 
(2) Related Regulatory and Non- 
Regulatory Programs 
(a) History of EPA’s Heavy-Duty 
Regulatory Program and Assessments of the Impacts of Greenhouse Gases on Climate Change 
To provide a context for EPA’s 
program to reduce greenhouse gas emissions from motor vehicles, this subsection provides an overview of two important related areas. First, we summarize the history of EPA’s heavy- duty regulatory program, which 
provides a basis for the compliance structure of this rulemaking. Next we summarize EPA prior assessments of the impacts of greenhouse gases on climate change, which provides a basis for much of the analysis of the environmental benefits of this rulemaking. 
(i) History of EPA’s Heavy-Duty 
Regulatory Program 
Since the 1980s, EPA has acted 
several times to address tailpipe emissions of criteria pollutants and air toxics from heavy-duty vehicles and engines. During the last two decades these programs have primarily addressed emissions of particulate matter (PM) and the primary ozone precursors, hydrocarbons (HC) and oxides of nitrogen (NO
X). These 
programs, which have successfully achieved significant and cost-effective reductions in emissions and associated health and welfare benefits to the nation, were an important basis of the Phase 1 program. See e.g. 66 FR 5002, 
5008, and 5011–5012 (January 18, 2001) (detailing substantial public health benefits of controls of criteria pollutants from heavy-duty diesel engines, 
including bringing areas into attainment with primary (public health) PM NAAQS, or contributing substantially to such attainment); National Petrochemical Refiners Association v. EPA, 287 F. 3d 1130, 1134 (D.C. Cir. 
2002) (referring to the ‘‘dramatic reductions’’ in criteria pollutant emissions resulting from the EPA on- 
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28‘‘Endangerment and Cause or Contribute 
Findings for Greenhouse Gases Under section 
202(a) of the Clean Air Act,’’ 74 FR 66496 (December 15, 2009) (‘‘Endangerment Finding’’). highway heavy-duty engine standards, 
and upholding all of the standards). 
As required by the Clean Air Act 
(CAA), the emission standards implemented by these programs include standards that apply at the time that the vehicle or engine is sold and continue to apply in actual use. EPA’s overall program goal has always been to achieve emissions reductions from the complete vehicles that operate on our roads. The agency has often accomplished this goal for many heavy-duty truck categories by regulating heavy-duty engine emissions. A key part of this success has been the development over many years of a well- established, representative, and robust set of engine test procedures that industry and EPA now use routinely to measure emissions and determine compliance with emission standards. These test procedures in turn serve the overall compliance program that EPA implements to help ensure that emissions reductions are being achieved. By isolating the engine from the many variables involved when the engine is installed and operated in a HD vehicle, EPA has been able to accurately address the contribution of the engine alone to overall emissions. 
(ii) EPA Assessment of the Impacts of 
Greenhouse Gases on Climate Change 
In 2009, the EPA Administrator 
issued the document known as the Endangerment Finding under CAA section 202(a)(1).
28In the Endangerment 
Finding, which focused on public health and public welfare impacts within the United States, the Administrator found that elevated concentrations of GHG emissions in the atmosphere may reasonably be anticipated to endanger public health and welfare of current and future generations. See also Coalition for Responsible Regulation v. EPA, 684 F. 
3d 102, 117–123 (D.C. Cir. 2012) (upholding the endangerment finding in all respects). The following sections summarize the key information included in the Endangerment Finding. 
Climate change caused by human 
emissions of GHGs threatens public health in multiple ways. By raising average temperatures, climate change increases the likelihood of heat waves, which are associated with increased deaths and illnesses. While climate change also decreases the likelihood of cold-related mortality, evidence indicates that the increases in heat mortality will be larger than the decreases in cold mortality in the United States. Compared to a future without climate change, climate change is expected to increase ozone pollution over broad areas of the U.S., including in the largest metropolitan areas with the worst ozone problems, and thereby increase the risk of morbidity and mortality. Other public health threats also stem from projected increases in intensity or frequency of extreme weather associated with climate change, such as increased hurricane intensity, increased frequency of intense storms and heavy precipitation. Increased coastal storms and storm surges due to rising sea levels are expected to cause increased drownings and other adverse health impacts. Children, the elderly, and the poor are among the most vulnerable to these climate-related health effects. See also 79 FR 75242 (December 17, 2014) (climate change, and temperature increases in particular, likely to increase O
3(ozone) pollution 
‘‘over broad areas of the U.S., including the largest metropolitan areas with the worst O
3problems, increas[ing] the risk 
of morbidity and mortality’’). 
Climate change caused by human 
emissions of GHGs also threatens public welfare in multiple ways. Climate changes are expected to place large areas of the country at serious risk of reduced water supplies, increased water pollution, and increased occurrence of extreme events such as floods and droughts. Coastal areas are expected to face increased risks from storm and flooding damage to property, as well as adverse impacts from rising sea level, such as land loss due to inundation, erosion, wetland submergence and habitat loss. Climate change is expected to result in an increase in peak electricity demand, and extreme weather from climate change threatens energy, transportation, and water resource infrastructure. Climate change may exacerbate ongoing environmental pressures in certain settlements, particularly in Alaskan indigenous communities. Climate change also is very likely to fundamentally rearrange U.S. ecosystems over the 21st century. Though some benefits may balance adverse effects on agriculture and forestry in the next few decades, the body of evidence points towards increasing risks of net adverse impacts on U.S. food production, agriculture and forest productivity as temperature continues to rise. These impacts are global and may exacerbate problems outside the U.S. that raise humanitarian, trade, and national security issues for the U.S. See also 79 FR 75382 (December 17, 2014) (welfare effects of O
3increases due to climate change, with 
emphasis on increased wildfires). 
As outlined in Section VIII.A of the 
2009 Endangerment Finding, EPA’s 
approach to providing the technical and scientific information to inform the Administrator’s judgment regarding the question of whether GHGs endanger public health and welfare was to rely primarily upon the recent, major assessments by the U.S. Global Change Research Program (USGCRP), the Intergovernmental Panel on Climate Change (IPCC), and the National Research Council (NRC) of the National Academies. These assessments addressed the scientific issues that EPA was required to examine, were comprehensive in their coverage of the GHG and climate change issues, and underwent rigorous and exacting peer review by the expert community, as well as rigorous levels of U.S. government review. Since the administrative record concerning the Endangerment Finding closed following EPA’s 2010 Reconsideration Denial, a number of new major, peer-reviewed scientific assessments have been released. These include the IPCC’s 2012 ‘‘Special Report on Managing the Risks of Extreme Events and Disasters to Advance Climate Change Adaptation’’ (SREX) and the 2013–2014 Fifth Assessment Report (AR5), the USGCRP’s 2014 ‘‘Climate Change Impacts in the United States’’ (Climate Change Impacts), and the NRC’s 2010 ‘‘Ocean Acidification: A National Strategy to Meet the Challenges of a Changing Ocean’’ (Ocean Acidification), 2011 ‘‘Report on Climate Stabilization Targets: Emissions, Concentrations, and Impacts over Decades to Millennia’’ (Climate Stabilization Targets), 2011 ‘‘National Security Implications for U.S. Naval Forces’’ (National Security Implications), 2011 ‘‘Understanding Earth’s Deep Past: Lessons for Our Climate Future’’ (Understanding Earth’s Deep Past), 2012 ‘‘Sea Level Rise for the Coasts of California, Oregon, and Washington: Past, Present, and Future,’’ 2012 ‘‘Climate and Social Stress: Implications for Security Analysis’’ (Climate and Social Stress), and 2013 ‘‘Abrupt Impacts of Climate Change’’ (Abrupt Impacts) assessments. 
EPA has reviewed these new 
assessments and finds that the improved 
understanding of the climate system they present further strengthens the case that GHG emissions endanger public health and welfare. 
In addition, these assessments 
highlight the urgency of the situation as the concentration of CO
2in the 
atmosphere continues to rise. Absent a reduction in emissions, a recent 
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29National Research Council, Understanding 
Earth’s Deep Past, p. 1. 
30Id., p.138. 
31National Research Council, Climate 
Stabilization Targets, p. 3. 
32U.S. Global Change Research Program, Climate 
Change Impacts in the United States: The Third 
National Climate Assessment, May 2014 Available at http://nca2014.globalchange.gov/. 33ftp://aftp.cmdl.noaa.gov/products/trends/co2/
co2_ annmean_ mlo.txt. 
34http://www.esrl.noaa.gov/gmd/ccgg/trends/. 
35http://www.ncdc.noaa.gov/sotc/global/201513. 
36This is more broadly true for heavy-duty 
pickup trucks than vans because every manufacturer of heavy-duty pickup trucks also makes light-duty pickup trucks, while only some heavy-duty van manufacturers also make light-duty vans. National Research Council assessment 
projected that concentrations by the end of the century would increase to levels that the Earth has not experienced for millions of years.
29In fact, that 
assessment stated that ‘‘the magnitude and rate of the present greenhouse gas increase place the climate system in what could be one of the most severe increases in radiative forcing of the global climate system in Earth history.’’
30What this means, as stated 
in another NRC assessment, is that: 
Emissions of carbon dioxide from the 
burning of fossil fuels have ushered in a new 
epoch where human activities will largely determine the evolution of Earth’s climate. Because carbon dioxide in the atmosphere is long lived, it can effectively lock Earth and future generations into a range of impacts, some of which could become very severe. Therefore, emission reductions choices made today matter in determining impacts experienced not just over the next few decades, but in the coming centuries and millennia.
31 
Moreover, due to the time-lags 
inherent in the Earth’s climate, the 
Climate Stabilization Targets assessment notes that the full warming from any given concentration of CO
2reached will 
not be realized for several centuries. 
The most recent USGCRP ‘‘National 
Climate Assessment’’32emphasizes that 
climate change is already happening now and is happening in the United States. The assessment documents the increases in some extreme weather and climate events in recent decades, as well as the resulting damage and disruption to infrastructure and agriculture, and projects continued increases in impacts across a wide range of peoples, sectors, and ecosystems. 
These assessments underscore the 
urgency of reducing emissions now. Today’s emissions will otherwise lead to raised atmospheric concentrations for thousands of years, and raised Earth system temperatures for even longer. Emission reductions today will benefit the public health and public welfare of current and future generations. 
Finally, it should be noted that the 
concentration of carbon dioxide in the atmosphere continues to rise dramatically. In 2009, the year of the Endangerment Finding, the average concentration of carbon dioxide as measured on top of Mauna Loa was 387 parts per million.
33The average 
concentration in 2015 was 401 parts per 
million, the first time an annual average has exceeded 400 parts per million since record keeping began at Mauna Loa in 1958, and for at least the past 
800,000 years according to ice core records.
34Moreover, 2015 was the 
warmest year globally in the modern global surface temperature record, going back to 1880, breaking the record previously held by 2014; this now means that the last 15 years have been 15 of the 16 warmest years on record.
35 
(b) The EPA and NHTSA Light-Duty National GHG and Fuel Economy Program 
On May 7, 2010, EPA and NHTSA 
finalized the first-ever National Program for light-duty cars and trucks, which set GHG emissions and fuel economy standards for model years 2012–2016 (see 75 FR 25324). More recently, the agencies adopted even stricter standards for model years 2017 and later (77 FR 62624, October 15, 2012). The agencies have used the light-duty National Program as a model for the HD National Program in several respects. This is most apparent in the case of heavy-duty pickups and vans, which are similar to the light-duty trucks addressed in the light-duty National Program both technologically as well as in terms of how they are manufactured (i.e., the 
same company often makes both the vehicle and the engine, and several light-duty manufacturers also manufacture HD pickups and vans).
36 
For HD pickups and vans, there are close parallels to the light-duty program in how the agencies have developed our respective heavy-duty standards and compliance structures. However, HD pickups and vans are true work vehicles that are designed for much higher towing and payload capabilities than are light-duty pickups and vans. The technologies applied to light-duty trucks are not all applicable to heavy-duty pickups and vans at the same adoption rates, and the technologies often produce a lower percent reduction in CO
2emissions and fuel consumption 
when used in heavy-duty vehicles. Another difference between the light- duty and the heavy-duty standards is that each agency adopts heavy-duty standards based on attributes other than 
vehicle footprint, as discussed below. 
Due to the diversity of the remaining 
HD vehicles, there are fewer parallels with the structure of the light-duty program. However, the agencies have maintained the same collaboration and coordination that characterized the development of the light-duty program throughout the Phase 1 rulemaking and the continued efforts for Phase 2. Most notably, as with the light-duty program, manufacturers will continue to be able to design and build vehicles to meet a closely coordinated, harmonized national program, and to avoid unnecessarily duplicative testing and compliance burdens. In addition, the averaging, banking, and trading provisions in the HD program, although structurally different from those of the light-duty program, serve the same purpose, which is to allow manufacturers to achieve large reductions in fuel consumption and emissions while providing a broad mix of products to their customers. The agencies have also worked closely with CARB to provide harmonized national standards. 
(c) EPA’s SmartWay Program 
EPA’s voluntary SmartWay Transport 
Partnership program encourages 
businesses to take actions that reduce fuel consumption and CO
2emissions 
while cutting costs by working with the shipping, logistics, and carrier communities to identify low carbon strategies and technologies across their transportation supply chains. SmartWay provides technical information, benchmarking and tracking tools, market incentives, and partner recognition to facilitate and accelerate the adoption of these strategies. Through the SmartWay program and its related technology assessment center, EPA has worked closely with truck and trailer manufacturers and truck fleets over the past 12 years to develop test procedures to evaluate vehicle and component performance in reducing fuel consumption and has conducted testing and has established test programs to verify technologies that can achieve these reductions. SmartWay 
partners have demonstrated these new and emerging technologies in their business operations, adding to the body of technical data and information that EPA can disseminate to industry, researchers and other stakeholders. Over the last several years, EPA has developed hands-on experience testing the largest heavy-duty trucks and trailers and evaluating improvements in tire and vehicle aerodynamic performance. In developing the Phase 1 
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37See http://www.arb.ca.gov/cc/cc.htm for details 
on the California Air Resources Board climate 
change actions, including a discussion of Assembly Bill 32, and the Climate Change Scoping Plan developed by CARB, which includes details regarding CARB’s future goals for reducing GHG emissions from heavy-duty vehicles. 
38See http://www.arb.ca.gov/msprog/truckstop/
trailers/trailers.htm for a summary of CARB’s 
‘‘Tractor-Trailer Greenhouse Gas Regulation.’’ 
39See http://www.arb.ca.gov/regact/2013/
hdghg2013/hdghg2013.htm for details regarding 
CARB’s adoption of the Phase 1 standards. 40See http://www.arb.ca.gov/ba/fininfo.htm for 
detailed descriptions of CARB’s mobile source incentive programs. Note that EPA works to support CARB’s heavy-duty incentive programs through the West Coast Collaborative (http://westcoastcollaborative.org/) and the Clean Air Technology Initiative (https://www.epa.gov/cati ). 
41See EPA’s waiver of CARB’s heavy-duty tractor- 
trailer greenhouse gas regulation applicable to new 2011 through 2013 model year Class 8 tractors equipped with integrated sleeper berths (sleeper- cab tractors) and 2011 and subsequent model year dry-can and refrigerated-van trailers that are pulled by such tractors on California highways at 79 FR 46256 (August 7, 2014). program, the agencies drew from this 
testing and from the SmartWay experience. In the same way, the agencies benefitted from SmartWay in developing the Phase 2 trailer program. 
(d) DOE’s SuperTruck Initiative 
The U.S. Department of Energy 
launched its SuperTruck I initiative in 
2009. SuperTruck I was a DOE partnership with four industry teams, who at this point have either met the SuperTruck I 50 percent fuel efficiency improvement goal (relative to a 2009 best-in-class truck) or have laid the groundwork to succeed. Teams from Cummins/Peterbilt, Daimler, and Volvo exceeded the 50 percent efficiency improvement goal, with Navistar on track to exceed this target later this year. Research vehicles developed under SuperTruck I are Class 8 combination tractor-trailers that have dramatically increased fuel and freight efficiency through the use of advanced technologies. These technologies include tractor and trailer aerodynamic devices, engine waste heat recovery systems, hybrids, automated transmissions and lightweight materials. In March 2016 DOE announced SuperTruck II, which is an $80M follow-on to SuperTruck I, where DOE will continue to partner with industry teams to collaboratively fund new projects to research, develop, and demonstrate technologies to further improve heavy-truck freight efficiency— by more than 100 percent, relative to a manufacturer’s best-in-class 2009 truck. Achieving these kinds of Class 8 truck efficiency increases will require an integrated systems approach to ensure that the various components of the vehicle work well together. SuperTruck II projects will utilize a wide variety of truck and trailer technology approaches to achieve performance targets, such as further improvements in engine efficiency, drivetrain efficiency, aerodynamic drag, tire rolling resistance, and vehicle weight. 
The agencies leveraged the outcomes 
of SuperTruck I by projecting how these tractor and trailer technologies could continue to advance from this early developmental stage toward the 
prototype and production stages. For a number of the SuperTruck technologies, the agencies are projecting advancement into production, given appropriate lead time. For example, a number of the aerodynamic and transmission technologies are projected to be in widespread production by 2021, and the agencies are finalizing 2021 standards based in part on performance of these SuperTruck technologies. For other more advanced SuperTruck technologies, such as organic Rankine 
cycle waste heat recovery systems, the agencies are projecting that additional lead time is needed to ensure that these technologies will be effective and reliable in production. For these technologies, the agencies are finalizing 2027 standards whose stringency reflects a significant market adoption rate of advanced technologies, including waste heat recovery systems. Furthermore, the agencies are encouraged by DOE’s announcement of SuperTruck II. We believe that the combination of HD Phase 2 and SuperTruck II will provide both a strong motivation and a proven means for manufacturers to fully develop these technologies within the lead times we have projected. 
(e) The State of California 
California has established ambitious 
goals for reducing GHG emissions from 
heavy-duty vehicles and engines as part of an overall plan to reduce GHG emissions from the transportation sector in California.
37Heavy-duty vehicles are 
responsible for one-fifth of the total GHG emissions from transportation sources in California. In the past several years, the California Air Resources Board (CARB) has taken a number of actions to reduce GHG emissions from heavy-duty vehicles and engines. For example, in 2008, CARB adopted regulations to reduce GHG emissions from heavy-duty tractors that pull box- type trailers through improvements in 
tractor and trailer aerodynamics and the use of low rolling resistance tires.
38The 
tractor–trailer operators subject to the CARB regulation are required to use SmartWay-certified tractors and trailers, or retrofit their existing fleet with SmartWay-verified technologies, consistent with California’s state authority to regulate both new and in- use vehicles. In December 2013, CARB adopted regulations that establish its own parallel Phase 1 program with standards consistent with EPA Phase 1 standards. On December 5, 2014, California’s Office of Administrative Law approved CARB’s adoption of the Phase 1 standards, with an effective date of December 5, 2014.
39Complementary to its regulatory efforts, CARB and other California agencies are investing significant public capital through various incentive programs to accelerate fleet turnover and stimulate technology innovation within the heavy-duty vehicle market (e.g., Air Quality 
Improvement, Carl Moyer, Loan Incentives, Lower-Emission School Bus and Goods Movement Emission Reduction Programs).
40Recently, 
California Governor Jerry Brown established a target of up to 50 percent petroleum reduction by 2030. 
California has long had the unique 
ability among states to adopt its own separate new motor vehicle standards per section 209 of the Clean Air Act (CAA). Although section 209(a) of the CAA expressly preempts states from adopting and enforcing standards relating to the control of emissions from new motor vehicles or new motor vehicle engines (such as state controls for new heavy-duty engines and vehicles), CAA section 209(b) directs EPA to waive this preemption under certain conditions. Under the waiver process set out in CAA section 209(b), EPA has granted CARB a waiver for its initial heavy-duty vehicle GHG regulation.
41Even with California’s 
ability under the CAA to establish its own emission standards, EPA and CARB have worked closely together over the past several decades to largely harmonize new vehicle criteria pollutant standard programs for heavy- duty engines and heavy-duty vehicles. In the past several years EPA and NHTSA also consulted with CARB in the development of the Federal light- duty vehicle GHG and CAFE rulemakings for the 2012–2016 and 2017–2025 model years. 
As discussed above, California 
operates under state authority to establish its own new heavy-duty vehicle and engine emission standards, including standards for CO
2, methane, 
N2O, and hydrofluorocarbons. EPA 
recognizes this independent authority, and we also recognize the potential benefits for the regulated industry if the Federal Phase 2 standards could result 
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42http://www.ijc.org/en _/Air_ Quality__
Agreement. 
43‘‘Phase 2 of the Heavy-duty Vehicle and Engine 
Greenhouse Gas Emission Regulations; Pre- 
Consultation Session,’’ March 3, 2016. 
44National Research Council ‘‘Reducing the Fuel 
Consumption and Greenhouse Gas Emissions of Medium- and Heavy-Duty Vehicles, Phase Two.’’ Washington, DC, The National Academies Press. Cooperative Agreement DTNH22–12–00389. Available electronically from the National Academy Press Web site at http://www.nap.edu/catalog/18736/reducing-the-fuel-consumption-and-greenhouse-gas-emissions-of-medium-and-heavy- duty-vehicles-phase-two (last accessed May 18, 
2016). On September 24, 2016, NAS will release an 
update report, consistent with Congress’ quinquennial update requirement. in a single, National Program that would 
meet the EPA and NHTSA’s statutory requirements to set appropriate and maximum feasible standards, and also be equivalent to potential future new heavy-duty vehicle and engine GHG standards established by CARB (addressing the same model years as addressed by the final Federal Phase 2 program and requiring the same technologies). In order to further the opportunity for maintaining coordinated Federal and California standards in the Phase 2 timeframe (as well as to benefit from different technical expertise and perspective), EPA and NHTSA consulted frequently with CARB while developing the Phase 2 rule. Prior to the proposal, the agencies’ technical staff shared information on technology cost, technology effectiveness, and feasibility with the CARB staff. We also received information from CARB on these same topics. In addition, CARB staff and managers participated with EPA and NHTSA in meetings with many external stakeholders, in particular with vehicle OEMs and technology suppliers. The agencies continued significant consultation during the development of the final rules. 
EPA and NHTSA believe that through 
this information sharing and dialog we have enhanced the potential for the Phase 2 program to result in a National Program that can be adopted not only by the Federal agencies, but also by the State of California, given the strong interest from the regulated industry for a harmonized State and Federal program. In its public comments, California reiterated its support for a harmonized State and Federal program, although it identified several areas in which it believed the proposed program needed to be strengthened. 
(f) Environment and Climate Change 
Canada 
On March 13, 2013, Environment and 
Climate Change Canada (ECCC), which is EPA’s Canadian counterpart, published its own regulations to control GHG emissions from heavy-duty vehicles and engines, beginning with MY 2014. These regulations are closely aligned with EPA’s Phase 1 program to 
achieve a common set of North American standards. ECCC has expressed its intention to amend these regulations to further limit emissions of greenhouse gases from new on-road heavy-duty vehicles and their engines for post-2018 MYs. As with the development of the current regulations, ECCC is committed to continuing to work closely with EPA to maintain a common Canada–United States approach to regulating GHG emissions for post-2018 MY vehicles and engines. This approach will build on the long history of regulatory alignment between the two countries on vehicle emissions pursuant to the Canada–United States Air Quality Agreement.
42In furtherance 
of this coordination, EPA participated in a workshop hosted by ECCC on March 3, 2016 to discuss Canada’s Phase 2 program.
43 
The Government of Canada, including 
ECCC and Transport Canada, has also been of great assistance during the development of this Phase 2 rule. In particular, the Government of Canada supported aerodynamic testing, and conducted chassis dynamometer emissions testing. 
(g) Recommendations of the National 
Academy of Sciences 
In April 2010, as mandated by 
Congress in the EISA, the National Research Council (NRC) under the National Academy of Sciences (NAS) issued a report to NHTSA and to Congress evaluating medium- and heavy-duty truck fuel efficiency improvement opportunities, titled ‘‘Technologies and Approaches to Reducing the Fuel Consumption of Medium- and Heavy-duty Vehicles.’’ That NAS report was far reaching in its review of the technologies that were available and that might become available in the future to reduce fuel consumption from medium- and heavy- duty vehicles. In presenting the full range of technical opportunities, the report included technologies that may not be available until 2020 or even further into the future. The report provided not only a valuable list of off- the-shelf technologies from which the agencies drew in developing the Phase 1 program, but also provided useful information the agencies have considered when developing this second phase of regulations. 
In April 2014, the NAS issued another 
report: ‘‘Reducing the Fuel Consumption and Greenhouse Gas Emissions of Medium- and Heavy-Duty Vehicles, Phase Two, First Report.’’
44 This study outlines a number of recommendations to the U.S. Department of Transportation and NHTSA on technical and policy matters to consider when addressing the fuel efficiency of our nation’s medium- and heavy-duty vehicles. In particular, this report provided recommendations with respect to: 
•The Greenhouse Gas Emission Model 
(GEM) simulation tool used by the 
agencies to assess compliance with vehicle standards 
•Regulation of trailers 
•Natural gas-fueled engines and 
vehicles 
•Data collection on in-use operation 
The agencies are adopting many of 
these recommendations into the Phase 2 program, including recommendations relating to the GEM simulation tool and to trailers. 
B. Summary of Phase 1 Program (1) EPA Phase 1 GHG Emission 
Standards and NHTSA Phase 1 Fuel Consumption Standards 
The EPA Phase 1 mandatory GHG 
emission standards commenced in MY 2014 and include increased stringency for standards applicable to MY 2017 and later MY vehicles and engines. NHTSA’s fuel consumption standards were voluntary for MYs 2014 and 2015, due to lead time requirements in EISA, and apply on a mandatory basis thereafter. They also increase in stringency for MY 2017. Both agencies allowed voluntary early compliance starting in MY 2013 and encouraged manufacturers’ participation through credit incentives. 
Given the complexity of the heavy- 
duty industry, the agencies divided the industry into three discrete categories for purposes of setting our respective Phase 1 standards—combination tractors, heavy-duty pickups and vans, and vocational vehicles—based on the relative degree of homogeneity among trucks within each category. The Phase 1 rules also include separate standards for the engines that power combination tractors and vocational vehicles. For each regulatory category, the agencies adopted related but distinct program approaches reflecting the specific challenges in these segments. In the following paragraphs, we briefly summarize EPA’s Phase 1 GHG emission standards and NHTSA’s Phase 1 fuel consumption standards for the three regulatory categories of heavy- duty vehicles and for the engines powering vocational vehicles and 
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45For further discussion of the input the agencies 
received from NAS, see Section XII of the Phase 2 
NPRM at 80 FR 40512, July 13, 2015. 46We note although the standards’ stringency is 
predicated on use of certain technologies, and the 
agencies’ assessed the cost of the rule based on the cost of use of those technologies, the standards can be met by any means. Put another way, the rules create a performance standard, and do not mandate any particular means of achieving that level of performance. 47EPA MOVES Model, http://www3.epa.gov/
otaq/models/moves/index.htm. 
48Note that 12-passenger vans are subject to the 
light-duty standards as medium-duty passenger vehicles (MDPVs) and are not subject to this proposal. tractors. See Sections II, III, V, and VI 
for additional details on the Phase 1 standards. To respect differences in design and typical uses that drive different technology solutions, the agencies segmented each regulatory class into subcategories. The category- specific structure enabled the agencies to set standards that appropriately reflect the technology available for each regulatory subcategory of vehicles and the engines for use in each type of vehicle. The Phase 1 program also provided several flexibilities, as summarized in Section I.B.(3). 
The agencies proposed and are 
adopting Phase 2 standards based on test procedures that differ from those used for Phase 1, including the revised GEM simulation tool. Significant revisions to GEM are discussed in 
Section II and in the RIA Chapter 4, and other test procedures are discussed further in the RIA Chapter 3. The pre- proposal revisions from Phase 1 GEM reflected input from both the NAS and from industry.
45Changes since the 
proposal generally reflect comments received from industry and other key stakeholders. It is important to note that due to these test procedure changes, the Phase 1 and Phase 2 standards are not directly comparable in an absolute sense. In particular, the revisions being made to the 55 mph and 65 mph highway cruise cycles for tractors and vocational vehicles have the effect of making the cycles more challenging (albeit more representative of actual driving conditions). We are not applying these revisions to the Phase 1 program because doing so would significantly change the stringency of the Phase 1 standards, for which manufacturers have already developed engineering plans and are now producing products to meet. Moreover, the changes to GEM address a broader range of technologies not part of the projected compliance path for use in Phase 1. 
Because the numeric values of the 
Phase 2 tractor and vocational standards are not directly comparable to their respective Phase 1 standards, the Phase 1 numeric standards were not appropriate baseline values to use to determine Phase 2’s improvements. To address this situation, the agencies applied all of the new Phase 2 test procedures and GEM software to tractors and vocational vehicles equipped with Phase 1 compliant levels of technology. The agencies used the results of this approach to establish appropriate Phase 1 baseline values, which are directly comparable to the 
Phase 2 standards. For example, in this rulemaking we present Phase 2 per vehicle percent reductions versus Phase 1, and for tractors and vocational vehicles these percent reductions were all calculated versus Phase 1 compliant vehicles, where we applied the Phase 2 test procedures and GEM software to determine these Phase 1 vehicles’ results. 
(a) Class 7 and 8 Combination Tractors 
Class 7 and 8 combination tractors 
and their engines contribute the largest 
portion of the total GHG emissions and fuel consumption of the heavy-duty sector, approximately 60 percent, due to their large payloads, their high annual miles traveled, and their major role in national freight transport. These vehicles consist of a cab and engine (tractor or combination tractor) and a detachable trailer. The primary manufacturers of combination tractors in the United States are Daimler Trucks North America, Navistar, Volvo/Mack, and PACCAR. Each of the tractor manufacturers and Cummins (an independent engine manufacturer) also produce heavy-duty engines used in tractors. The Phase 1 standards require manufacturers to reduce GHG emissions and fuel consumption for these tractors and engines, which we expect them to do through improvements in aerodynamics and tires, reductions in tractor weight, reduction in idle operation, as well as engine-based efficiency improvements.
46 
The Phase 1 tractor standards differ 
depending on gross vehicle weight rating (GVWR) (i.e., whether the truck is 
Class 7 or Class 8), the height of the roof of the cab, and whether it is a ‘‘day cab’’ or a ‘‘sleeper cab.’’ The agencies created nine subcategories within the Class 7 and 8 combination tractor category reflecting combinations of these attributes. The agencies set Phase 1 standards for each of these subcategories beginning in MY 2014, with more stringent standards following in MY 2017. The standards represent an overall fuel consumption and CO
2emissions 
reduction up to 23 percent from the tractors and the engines installed in them when compared to a baseline MY 2010 tractor and engine. 
For Phase 1, tractor manufacturers 
demonstrate compliance with the tractor CO
2and fuel consumption standards 
using a vehicle simulation tool 
described in Section II. The tractor inputs to the simulation tool in Phase 1 are the aerodynamic performance, tire rolling resistance, vehicle speed limiter, automatic engine shutdown, and weight reduction. 
In addition to the Phase 1 tractor- 
based standards for CO
2, EPA adopted a 
separate standard to reduce leakage of hydrofluorocarbon (HFC) refrigerant from cabin air conditioning (A/C) systems from combination tractors, to apply to the tractor manufacturer. This HFC leakage standard is independent of the CO
2tractor standard. Manufacturers 
can choose technologies from a menu of leak-reducing technologies sufficient to comply with the standard, as opposed to using a test to measure performance. Given that HFC leakage does not relate to fuel efficiency, NHTSA did not adopt corresponding HFC standards. 
(b) Heavy-Duty Pickup Trucks and Vans 
(Class 2b and 3) 
Heavy-duty vehicles with a GVWR 
between 8,501 and 10,000 lb. are classified as Class 2b motor vehicles. Heavy-duty vehicles with a GVWR between 10,001 and 14,000 lb. are classified as Class 3 motor vehicles. Class 2b and Class 3 heavy-duty vehicles (referred to in these rules as ‘‘HD pickups and vans’’) together emit about 23 percent of today’s GHG emissions from the heavy-duty vehicle sector.
47 
The majority of HD pickups and vans 
are 3⁄4-ton and 1-ton pickup trucks, 12- 
and 15-passenger vans,48and large work 
vans that are sold by vehicle manufacturers as complete vehicles, with no secondary manufacturer making substantial modifications prior to registration and use. These vehicles can also be sold as cab-complete vehicles (i.e., incomplete vehicles that include 
complete or nearly complete cabs that are sold to secondary manufacturers). The majority of heavy-duty pickups and vans are produced by companies with major light-duty markets in the United States. Furthermore, the technologies 
available to reduce fuel consumption and GHG emissions from this segment are similar to the technologies used on light-duty pickup trucks, including both engine efficiency improvements (for gasoline and diesel engines) and vehicle efficiency improvements. For these reasons, EPA and NHTSA concluded 
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49As explained in Section XI, as part of this 
rulemaking, EPA moved the Phase 1 requirements 
for pickups and vans from 40 CFR 1037.104 into 40 CFR part 86, which is also the regulatory part that applies for light-duty vehicles. 50EPA MOVES model, http://www3.epa.gov/
otaq/models/moves/index.htm. 
51See 76 FR 57114 explaining why NHTSA’s 
authority under the Energy Independence and Safety Act includes authority to establish separate engine standards. that it was appropriate to adopt GHG 
standards, expressed as grams per mile, and fuel consumption standards, expressed as gallons per 100 miles, for HD pickups and vans based on the whole vehicle (including the engine), consistent with the way these vehicles have been regulated by EPA for criteria pollutants and also consistent with the way their light-duty counterpart vehicles are regulated by EPA and NHTSA. This complete vehicle approach adopted by both agencies for HD pickups and vans was consistent with the recommendations of the NAS Committee in its 2010 Report. 
For the light-duty GHG and fuel 
economy standards, the agencies based the emissions and fuel economy targets on vehicle footprint (the wheelbase times the average track width). For those standards, passenger cars and light trucks with larger footprints are assigned higher GHG and lower fuel economy target levels reflecting their inherent tendency to consume more fuel and emit more GHGs per mile. For HD pickups and vans, the agencies believe 
that setting standards based on vehicle attributes is appropriate, but have found that a work-based metric is a more appropriate attribute than the footprint attribute utilized in the light-duty vehicle rulemaking, given that work- based measures such as towing and payload capacities are critical elements of these vehicles’ functionality. EPA and NHTSA therefore adopted standards for HD pickups and vans based on a ‘‘work factor’’ attribute that combines their payload and towing capabilities, with an added adjustment for 4-wheel drive vehicles. 
Each manufacturer’s fleet average 
Phase 1 standard is based on production volume-weighting of target standards for all vehicles, which in turn are based on each vehicle’s work factor. These target standards are taken from a set of curves (mathematical functions), with separate curves for gasoline and diesel vehicles.
49However, both gasoline and 
diesel vehicles in this category are included in a single averaging set. EPA phased in the CO
2standards gradually 
starting in the 2014 MY, at 15–20–40– 60–100 percent of the MY 2018 standards stringency level in MYs 2014– 2015–2016–2017–2018, respectively (i.e., the 2014 standards requires only 15 
percent of the reduction required in 2018, etc.). The phase-in takes the form of a set of target curves, with increasing 
stringency in each MY. 
NHTSA allowed manufacturers to 
select one of two fuel consumption standard alternatives for MYs 2016 and later. The first alternative defined individual gasoline vehicle and diesel vehicle fuel consumption target curves that will not change for MYs 2016–2018, and are equivalent to EPA’s 67–67–67– 100 percent target curves in MYs 2016– 2017–2018–2019, respectively. The second alternative defined target curves that are equivalent to EPA’s 40–60–100 percent target curves in MYs 2016– 2017–2018, respectively. NHTSA allowed manufacturers to opt voluntarily into the NHTSA HD pickup and van program in MYs 2014 or 2015 at target curves equivalent to EPA’s target curves. If a manufacturer chose to opt in for one category, they would be required to opt in for all categories. In other words, a manufacturer would be unable to opt in for Class 2b vehicles, but opt out for Class 3 vehicles. 
EPA also adopted an alternative 
phase-in schedule for manufacturers wanting to have stable standards for model years 2016–2018. The standards for heavy-duty pickups and vans, like those for light-duty vehicles, are expressed as set of target standard curves, with increasing stringency in each model year. The Phase 1 EPA standards for 2018 (including a separate standard to control air conditioning system leakage) are estimated to represent an average per-vehicle reduction in GHG emissions of 17 percent for diesel vehicles and 12 percent for gasoline vehicles (relative to pre-control baseline vehicles). The NHTSA standard will require these vehicles to achieve up to about 15 percent reduction in fuel consumption by MY 2018 (relative to pre-control 
baseline vehicles). Manufacturers demonstrate compliance based on entire vehicle chassis certification using the same duty cycles used to demonstrate compliance with criteria pollutant standards. 
(c) Class 2b–8 Vocational Vehicles 
Class 2b–8 vocational vehicles 
include a wide variety of vehicle types, 
and serve a vast range of functions. Some examples include service for parcel delivery, refuse hauling, utility service, dump, concrete mixing, transit service, shuttle service, school bus, emergency, motor homes, and tow trucks. In Phase 1, we defined Class 2b– 8 vocational vehicles as all heavy-duty vehicles that are not included in either the heavy-duty pickup and van category or the Class 7 and 8 tractor category. EPA’s and NHTSA’s Phase 1 standards for this vocational vehicle category 
generally apply at the chassis manufacturer level. Class 2b–8 vocational vehicles and their engines emit approximately 17 percent of the GHG emissions and burn approximately 17 percent of the fuel consumed by today’s heavy-duty truck sector.
50 
The Phase 1 program for vocational 
vehicles has vehicle standards and separate engine standards, both of which differ based on the weight class of the vehicle into which the engine will be installed. The vehicle weight class groups mirror those used for the engine standards—Classes 2b–5 (light heavy- duty or LHD in EPA regulations), Classes 6 and 7 (medium heavy-duty or MHD in EPA regulations) and Class 8 (heavy heavy-duty or HHD in EPA regulations). Manufacturers demonstrate compliance with the Phase 1 vocational vehicle CO
2and fuel consumption 
standards using a vehicle simulation tool described in Section II. The Phase 1 program for vocational vehicles limited the simulation tool inputs to tire rolling resistance. The model assumes the use of a typical representative, compliant engine in the simulation, resulting in one overall value for CO
2 
emissions and one for fuel consumption. 
(d) Engine Standards 
The agencies established separate 
Phase 1 performance standards for the 
engines manufactured for use in vocational vehicles and Class 7 and 8 tractors.
51These engine standards vary 
depending on engine size linked to intended vehicle service class. EPA’s 
engine-based CO
2standards and 
NHTSA’s engine-based fuel consumption standards are being implemented using EPA’s existing test procedures and regulatory structure for criteria pollutant emissions from heavy- duty engines. EPA also established engine-based N
2O and CH 4emission 
standards in Phase 1. 
(e) Manufacturers Excluded From the 
Phase 1 Standards 
Phase 1 deferred greenhouse gas 
emissions and fuel consumption standards for any manufacturers of heavy-duty engines, manufacturers of combination tractors, and chassis manufacturers for vocational vehicles that meet the ‘‘small business’’ size criteria set by the Small Business Administration (SBA). 13 CFR 121.201 
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52These thresholds were revised in early 2016. 
See http://www.regulations.gov/#!document
Detail;D=SBA-2014-0011-0031 . 
53Note: These calendar year benefits do not 
represent the same time frame as the model year 
lifetime benefits described above, so they are not additive. 54NHTSA explained that it has greater flexibility 
in the HD program to include consideration of credits and other flexibilities in determining appropriate and feasible levels of stringency than it does in the light-duty CAFE program. Cf. 49 U.S.C. 
32902(h), which applies to light-duty CAFE but not heavy-duty fuel efficiency under 49 U.S.C. 32902(k). 55Early credits are for engines and vehicles 
certified before EPA standards became mandatory, advanced technology credits are for hybrids and/or Rankine cycle engines, and innovative technology credits are for other technologies not in the 2010 fleet whose benefits are not reflected using the Phase 1 test procedures. defines a small business by the 
maximum number of employees; for example, this is currently 1,500 for heavy-duty truck manufacturing and 1,000 for engine manufacturing.
52In 
order to utilize this exemption, qualifying small businesses must submit a declaration to the agencies. See Section I.F.(1)(b) for a summary of how Phase 2 applies for small businesses. 
The agencies stated that they would 
consider appropriate GHG and fuel consumption standards for these entities as part of a future regulatory action. This includes both U.S.-based and foreign small-volume heavy-duty manufacturers that introduce new products into the U.S. 
(2) Costs and Benefits of the Phase 1 
Program 
Overall, EPA and NHTSA estimated 
that the Phase 1 HD National Program will cost the affected industry about $8 billion, while saving vehicle owners fuel costs of nearly $50 billion over the lifetimes of MY 2014–2018 vehicles. The agencies also estimated that the combined standards will reduce CO
2 
emissions by about 270 million metric tons and save about 530 million barrels of oil over the life of MY 2014 to 2018 vehicles. The agencies estimated additional monetized benefits from CO
2 
reductions, improved energy security, reduced time spent refueling, as well as possible dis-benefits from increased driving crashes, traffic congestion, and noise. When considering all these factors, we estimated that Phase 1 of the HD National Program will yield $49 billion in net benefits to society over the lifetimes of MY 2014–2018 vehicles. 
EPA estimated the benefits of reduced 
ambient concentrations of particulate matter and ozone resulting from the Phase 1 program to range from $1.3 to $4.2 billion in 2030.
53 
In total, we estimated the combined 
Phase 1 standards will reduce GHG emissions from the U.S. heavy-duty fleet by approximately 76 million metric tons of CO
2-equivalent annually by 2030. In 
its Environmental Impact Statement for the Phase 1 rule, NHTSA also quantified and/or discussed other potential impacts of the program, such as the health and environmental impacts associated with changes in ambient exposures to toxic air pollutants and the benefits associated with avoided non- CO
2GHGs (methane, nitrous oxide, and 
HFCs). 
(3) Phase 1 Program Flexibilities 
As noted above, the agencies adopted 
numerous provisions designed to give 
manufacturers a degree of flexibility in complying with the Phase 1 standards. These provisions, which are essentially identical in structure and function in EPA’s and NHTSA’s regulations, enabled the agencies to consider overall standards that are more stringent and that will become effective sooner than we could consider with a more rigid program, one in which all of a manufacturer’s similar vehicles or engines would be required to achieve the same emissions or fuel consumption levels, and at the same time.
54 
Phase 1 included four primary types 
of flexibility: Averaging, banking, and trading (ABT) provisions; early credits; advanced technology credits (including hybrid powertrains); and innovative technology credit provisions. The ABT provisions were patterned on existing EPA and NHTSA ABT programs (including the light-duty GHG and fuel economy standards) and will allow a vehicle manufacturer to reduce CO
2 
emission and fuel consumption levels further than the level of the standard for one or more vehicles to generate ABT credits. The manufacturer can use those credits to offset higher emission or fuel consumption levels in the same averaging set, ‘‘bank’’ the credits for later use, or ‘‘trade’’ the credits to another manufacturer. As also noted above, for HD pickups and vans, we adopted a fleet averaging system very similar to the light-duty GHG and CAFE fleet averaging system. In both programs, manufacturers are allowed to carry-forward deficits for up to three years without penalty. The agencies provided in the ABT programs flexibility for situations in which a manufacturer is unable to avoid a negative credit balance at the end of the year. In such cases, manufacturers are not considered to be out of compliance unless they are unable to make up the difference in credits by the end of the third subsequent model year. 
In total, the Phase 1 program divides 
the heavy-duty sector into 14 subcategories of vehicles and 4 subcategories of engines. These subcategories are grouped into 4 vehicle averaging sets and 4 engine averaging 
sets in the ABT program. For tractors and vocational vehicles, the fleet averaging sets are: Light heavy-duty (Classes 2b–5); medium heavy-duty (Class 6–7); and heavy heavy-duty (Class 8). Complete HD pickups and vans (both spark-ignition and compression-ignition) are the final vehicle averaging set. For engines, the fleet averaging sets are spark-ignition engines, compression-ignition light heavy-duty engines, compression- ignition medium heavy-duty engines, and compression-ignition heavy heavy- duty engines. ABT allows the exchange of credits within an averaging set. This means that a Class 8 day cab tractor can exchange credits with a Class 8 sleeper tractor but not with a smaller Class 7 tractor. Also, a Class 8 vocational vehicle can exchange credits with a Class 8 tractor. However, we did not allow trading between engines and chassis (i.e. vehicles). 
In addition to ABT, the other primary 
flexibility provisions in the Phase 1 program involve opportunities to generate early credits, advanced technology credits (including for use of hybrid powertrains), and innovative technology credits.
55For the early 
credits and advanced technology credits, the agencies adopted a 1.5x multiplier, meaning that manufacturers would get 1.5 credits for each early credit and each advanced technology credit. In addition, advanced technology credits for Phase 1 can be used anywhere within the heavy-duty sector (including both vehicles and engines). 
Put another way, as a means of promoting these promising technologies, the Phase 1 rule does not restrict averaging or trading by averaging set in this instance. 
For other vehicle or engine 
technologies that can reduce CO
2and 
fuel consumption, but whose benefits are not reflected if measured using the Phase 1 test procedures, the agencies wanted to encourage the development of such innovative technologies, and therefore adopted special ‘‘innovative technology’’ credits. These innovative technology credits apply to technologies that are shown to produce emission and fuel consumption reductions that are not adequately recognized on the Phase 1 test procedures and that were not yet in widespread use in the heavy-duty sector before MY 2010. Manufacturers 
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56In this context, the term ‘‘technology-forcing’’ 
has a specific legal meaning and is used to 
distinguish standards that will effectively require manufacturers to develop new technologies (or to significantly improve technologies) from standards that can be met using off-the-shelf technology alone. See, e.g., NRDC v. EPA, 655 F. 2d 318, 328 (D.C. 
Cir. 1981). Technology-forcing standards do not require manufacturers to use any specific technologies. See also 76 FR 57130 (explaing that section 202(a)(2) allows EPA to adopt such technology-forcing standards, although it does not compell such standards). 57‘‘Prototype’’ as it is used here refers to 
technologies that have a potentially production- feasible design that is expected to meet all performance, functional, reliability, safety, manufacturing, cost and other requirements and objectives that is being tested in laboratories and on highways under a full range of operating conditions, but is not yet available in production vehicles already for sale in the market. need to quantify the reductions in fuel 
consumption and CO 2emissions that 
the technology is expected to achieve, above and beyond those achieved on the Phase 1 test procedures. As with ABT, the use of innovative technology credits is allowed only among vehicles and engines of the same defined averaging set generating the credit, as described above. The credit multiplier likewise does not apply for innovative technology credits. 
(4) Implementation of Phase 1 
Manufacturers have already begun 
complying with the Phase 1 standards. 
In some cases manufacturers voluntarily chose to comply early, before compliance was mandatory. The Phase 1 rule allowed manufacturers to generate credits for such early compliance. The market appears to be very accepting of the new technologies, and the agencies have seen no evidence 
of ‘‘pre-buy’’ effects in response to the standards. In fact sales have been higher in recent years than they were before Phase 1. Moreover, manufacturers’ compliance plans indicate intention to utilize the Phase 1 flexibilities, and we have yet to see significant non- compliance with the standards. 
(5) Litigation on Phase 1 Rule 
The D.C. Circuit rejected all 
challenges to the agencies’ Phase 1 
regulations. The court did not reach the merits of the challenges, holding that none of the petitioners had standing to bring their actions, and that a challenge to NHTSA’s denial of a rulemaking petition could only be brought in District Court. See Delta Construction v. EPA, 783 F. 3d 1291 (D.C. Cir. 2015). 
C. Summary of the Phase 2 Standards and Requirements 
The agencies are adopting new 
standards that build on and enhance existing Phase 1 standards, and are adopting as well the first-ever standards for certain trailers used in combination with heavy-duty tractors. Taken together, the Phase 2 program comprises a set of largely technology-advancing standards that will achieve greater GHG and fuel consumption savings than the Phase 1 program. As described in more detail in the following sections, the agencies are adopting these standards because, based on the information available at this time and careful consideration of all comments, we believe they best fulfill our respective statutory authorities when considered in the context of available technology, feasible reductions of emissions and fuel consumption, costs, lead time, safety, and other relevant factors. The Phase 2 standards represent a 
more technology-forcing
56approach 
than the Phase 1 approach, predicated 
on use of both off-the-shelf technologies and emerging technologies that are not yet in widespread use. The agencies are adopting standards for MY 2027 that we project will require manufacturers to make extensive use of these technologies. The standards increase in stringency incrementally beginning in MY 2018 for trailers and in MY 2021 for other segments, ensuring steady 
improvement to the MY 2027 stringency levels. For existing technologies and technologies in the final stages of development, we project that manufacturers will likely apply them to nearly all vehicles, excluding those specific vehicles with applications or uses that prevent the technology from functioning properly. We also project as one possible compliance pathway that manufacturers could apply other more advanced technologies such as hybrids and waste engine heat recovery systems, although at lower application rates than the more conventional technologies. Comments on the overall stringency of the proposed Phase 2 program were mixed. Many commenters, including most non-governmental organizations, supported more stringent standards with less lead time. Many technology and component suppliers supported more stringent standards but with the proposed lead time. Vehicle manufacturers did not support more stringent standards and emphasized the importance of lead time. To the extent these commenters provided technical information to support their comments on stringency and lead time, it is discussed in Sections II through VI. 
The standards being adopted provide 
approximately ten years of lead time for manufacturers to meet these 2027 standards, which the agencies believe is appropriate to implement the technologies industry could use to meet these standards. For some of the more advanced technologies production prototype parts are not yet available, though they are in the research stage with some demonstrations in actual vehicles.
57In the respective sections of 
Chapter 2 of the RIA, the agencies 
explain what further steps are needed to successfully and reliably commercialize these prototypes in the lead time afforded by the Phase 2 standards. Additionally, even for the more developed technologies, phasing in more stringent standards over a longer timeframe will help manufacturers to ensure better reliability of the technology and to develop packages to work in a wide range of applications. 
As discussed later, the agencies are 
also adopting new standards in MYs 2018 (trailers only), 2021, and 2024 to ensure that manufacturers make steady progress toward the 2027 standards, thereby achieving steady and feasible reductions in GHG emissions and fuel consumption in the years leading up to the MY 2027 standards. 
Providing additional lead time can 
often enable manufacturers to resolve technological challenges or to find lower cost means of meeting new regulatory standards, effectively making them more feasible in either case. See generally NRDC v. EPA, 655 F. 2d 318, 
329 (D.C. Cir. 1981). On the other hand, manufacturers and/or operators may incur additional costs if regulations require them to make changes to their products with less lead time than manufacturers would normally have when bringing a new technology to the market or expanding the application of existing technologies. After developing a new technology, manufacturers typically conduct extensive field tests to ensure its durability and reliability in actual use. Standards that accelerate technology deployment can lead to manufacturers incurring additional costs to accelerate this development work, or can lead to manufacturers beginning production before such testing can be completed. Some industry stakeholders have informed EPA that when manufacturers introduced new emission control technologies (primarily diesel particulate filters) in response to the 2007 heavy-duty engine standards they did not perform sufficient product development validation, which led to additional costs for operators when the technologies required repairs or resulted in other operational issues in use. Thus, the issues of costs, lead time, and reliability are intertwined for the 
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58For example, see the public comments of The 
International Union, Volvo Trucks North America, 
United Automobile, Aerospace and Agricultural Implement Workers of America (UAW). 5975 FR 57198. 
6049 U.S.C. 32902(k). 
61Id. 
62Center for Biological Diversity v. National 
Highway Traffic Safety Admin., 538 F.3d 1172, 1195 (9th Cir. 2008). 63As described in Section IV, although the trailer 
standards were developed using the simulation tool, the agencies are adopting a compliance structure that does not require trailer manufacturers to use it. agencies’ determination of whether 
standards are reasonable and maximum feasible, respectively. 
Another important consideration was 
the possibility of disrupting the market, which would be a risk if compliance required application of new technologies too suddenly. Several of the heavy-duty vehicle manufacturers, fleets, and commercial truck dealerships informed the agencies that for fleet purchases that are planned more than a year in advance, expectations of 
reduced reliability, increased operating costs, reduced residual value, or of large increases in purchase prices can lead the fleets to pull-ahead by several months planned future vehicle purchases by pre-buying vehicles without the newer technology. In the context of the Class 8 tractor market, where a relatively small number of large fleets typically purchase very large volumes of tractors, such actions by a small number of firms can result in large swings in sales volumes. Such market impacts would be followed by some period of reduced purchases that can lead to temporary layoffs at the factories producing the engines and vehicles, as well as at supplier factories, and disruptions at dealerships. Such market impacts also can reduce the overall environmental and fuel consumption benefits of the standards by delaying the rate at which the fleet turns over. See International Harvester v. EPA, 478 F. 
2d 615, 634 (D.C. Cir. 1973). A number of commenters stated that the 2007 EPA heavy-duty engine criteria pollutant standard precipitated pre-buy for the Class 8 tractor market.
58The agencies 
understand the potential impact that fleets pulling ahead purchases can have on American manufacturing and labor, dealerships, truck purchasers, and on the program’s environmental and fuel savings goals, and have taken steps in the design of the program to avoid such disruption (see also our discussion in RTC Section 11.7). These steps include the following: 
•Providing considerable lead time 
•Adopting standards that will result in 
significantly lower operating costs for 
vehicle owners (unlike the 2007 standard, which increased operating costs) 
•Phasing in the standards 
•Structuring the program so the 
industry will have a significant range of technology choices to be considered for compliance, rather than the one or two new technologies the OEMs pursued to comply with EPA’s 2007 criteria pollutant standard 
•Allowing manufacturers to use 
emissions averaging, banking and trading to phase in the technology even further 
As discussed in the Phase 1 final rule, NHTSA has certain statutory considerations to take into account when determining feasibility of the preferred alternative.
59EISA states that 
NHTSA (in consultation with EPA and the Secretary of Energy) will develop a commercial medium- and heavy-duty fuel efficiency program designed ‘‘to achieve the maximum feasible improvement.’’
60Although there is no 
definition of maximum feasible standards in EISA, NHTSA is directed to consider three factors when determining what the maximum feasible standards are. Those factors are, appropriateness, cost-effectiveness, and technological feasibility,
61which 
modify ‘‘feasible’’ beyond its plain meaning. 
NHTSA has the broad discretion to 
weigh and balance the aforementioned factors in order to accomplish EISA’s mandate of determining maximum feasible standards. The fact that the factors may often be at odds gives NHTSA significant discretion to decide what weight to give each of the competing factors, policies and concerns and then determine how to balance them—as long as NHTSA’s balancing does not undermine the fundamental purpose of the EISA: Energy conservation, and as long as that balancing reasonably accommodates ‘‘conflicting policies that were committed to the agency’s care by the statute.’’
62 
EPA also has significant discretion in 
assessing, weighing, and balancing the relevant statutory criteria. Section 202(a)(2) of the Clean Air Act (42 U.S.C. 7521(a)(2)) requires that the standards ‘‘take effect after such period as the Administrator finds necessary to permit the development and application of the requisite technology, giving appropriate consideration to the cost of compliance within such period.’’ This language affords EPA considerable discretion in how to weight the critical statutory factors of emission reductions, cost, and lead time (76 FR 57129–57130). Section 202(a)(2) also allows (although it does not compel) EPA to adopt technology- forcing standards. Id. at 57130. Sections II through VI of this 
Preamble explain the consideration that the agencies took into account based on careful assessment and balancing of the statutory factors under Clean Air Act section 202(a)(1) and (2), and under 49 U.S.C. 32902(k). 
(1) Carryover From Phase 1 Program and 
Compliance Changes 
Phase 2 is carrying over many of the 
compliance approaches developed for Phase 1, with certain changes as described below. Readers are referred to the regulatory text for much more detail. Note that the agencies have adapted some of these Phase 1 provisions in order to address new features of the Phase 2 program, notably provisions related to trailer compliance. The agencies have also reevaluated all of the compliance provisions to ensure that they will be effective in achieving the projected reductions without placing an undue burden on manufacturers. 
The agencies received significant 
comments from vehicle manufacturers emphasizing the potential for the structure of the compliance program to impact stringency. Although the agencies do not agree with all of these comments (which are discussed in more detail in later sections), we do agree that it is important to structure the compliance program so that the effective stringency of standards is consistent with levels established by regulation. The agencies have made appropriate improvements to the compliance structure in response to these comments. 
(a) Certification 
EPA and NHTSA are applying the 
same general certification procedures 
for Phase 2 as are currently being used for certifying to the Phase 1 standards. Tractors and vocational vehicles will continue to be certified using the vehicle simulation tool (GEM). The agencies, however, revised the Phase 1 GEM simulation tool to develop a new version, Phase 2 GEM, that more specifically reflects improvements to engines, transmissions, and drivetrains.
63Rather than the GEM 
simulation tool using default values for engines, transmissions and drivetrains, most manufacturers will enter measured or tested values as inputs reflecting performance of the actual engine, transmission and drivetrain technologies. 
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64See NRDC v. Thomas, 805 F. 2d 410, 425 (D.C. 
Cir. 1986) (upholding averaging as a reasonable and 
permissible means of implementing a statutory provision requiring technology-forcing standards). The Phase 1 certification process for 
engines used in tractors and vocational 
vehicles was based on EPA’s process for showing compliance with the heavy- duty engine criteria pollutant standards using engine dynamometer testing, and the agencies are continuing it for Phase 2. We also will continue certifying HD pickups and vans using the Phase 1 chassis dynamometer testing results and vehicle certification process, which is very similar to the light-duty vehicle certification process. The Phase 2 trailer certification process will resemble the Phase 2 tractor certification approach, but with a simplified version of Phase 2 GEM. The trailer certification process allows trailer manufacturers to use a simple equation to determine GEM- equivalent g/ton-mile emission rates without actually running GEM. 
EPA and NHTSA are also clarifying 
provisions related to confirming a manufacturer’s test data during certification (i.e., confirmatory testing) 
and verifying a manufacturer’s vehicles are being produced to perform as described in the application for certification (i.e., selective enforcement 
audits or SEAs). The EPA confirmatory testing provisions for engines, vehicles, and components are in 40 CFR 1036.235 and 1037.235. The SEA provisions are in 40 CFR 1036.301 and 1037.301– 1037.320. The NHTSA provisions are in 49 CFR 535.9(a). As we proposed, these clarifications will also apply for Phase 1 engines and vehicles. 
In response to comments, we are 
making several changes to the proposed EPA confirmatory testing provisions. First, the regulations being adopted specify that EPA will conduct triplicate tests for engine fuel maps to minimize the impact of test-to-test variability. The final regulations also state that we will consider entire fuel maps rather than individual points. Engine manufacturers objected to EPA’s proposal that individual points could be replaced based on a single test, arguing that it effectively made the vehicle standards more stringent due to point-to-point and test-to-test variability. We believe that the changes being adopted largely address these concerns. We are also applying this approach for axle and transmission maps for similar reasons. 
As described in Sections III and IV, 
EPA has also modified the SEA 
regulations for verifying aerodynamic performance. These revised regulations differ somewhat from the standard SEA regulations to address the unique challenges of measuring aerodynamic drag. In particular EPA recognizes that for coastdown testing, test-to-test variability is expected to be large relative to production variability. This differs fundamentally from traditional 
compliance testing, in which test-to-test variability is expected to be small relative to production variability. To address this difference, the modified regulations call for more repeat testing of the same vehicle, but fewer test samples. These revisions were generally supported by commenters. See Section III and IV for additional discussion. 
Some commenters suggested that the 
agencies should apply a compliance margin to confirmatory and SEA test results to account for test variability. However, other commenters supported following EPA’s past practice, which has been to base the standards on technology projections that assume manufacturers will apply compliance margins to their test results for certification. In other words, they design their products to have emissions below the standards by some small margin so that test-to-test or lab-to-lab variability would not cause them to exceed any applicable standards. Consequently, EPA has typically not set standards precisely at the lowest levels achievable, but rather at slightly higher levels— expecting manufacturers to target the lower levels to provide compliance margins for themselves. As discussed in Sections II through VI, the agencies have applied this approach to the Phase 2 standards. 
(b) Averaging, Banking and Trading 
(ABT) 
The Phase 1 ABT provisions were 
patterned on established EPA ABT programs that have proven to work well. In Phase 1, the agencies determined this flexibility would provide an opportunity for manufacturers to make necessary technological improvements and reduce the overall cost of the program without compromising overall environmental and fuel economy objectives. Commenters generally 
supported this approach for engines, pickups/vans, tractors, and vocational vehicles. Thus, we are generally continuing this Phase 1 approach with few revisions to the engine and vehicle segments. However, as described in Section IV, in response to comments, we are finalizing a much more limited averaging program for trailers that will not go into effect until 2027. We are adopting some other provisions for certain vocational vehicles, which are discussed in Section V. 
The agencies see the overall ABT 
program as playing an important role in making the technology-advancing standards feasible, by helping to address many issues of technological challenges in the context of lead time and costs. It provides manufacturers flexibilities that assist the efficient development and implementation of new technologies and therefore enable new technologies to be implemented at a more aggressive pace than without ABT. 
ABT programs are more than just add- 
on provisions included to help reduce costs. They can be, as in EPA’s Title II programs generally, an integral part of the standard setting itself. A well- designed ABT program can also provide important environmental and energy security benefits by increasing the speed at which new technologies can be implemented (which means that more benefits accrue over time than with later-commencing standards) and at the same time increase flexibility for, and reduce costs to, the regulated industry and ultimately consumers. Without ABT provisions (and other related flexibilities), standards would typically have to be numerically less stringent since the numerical standard would have to be adjusted to accommodate issues of feasibility and available lead time. See 75 FR 25412–25413. By offering ABT credits and additional flexibilities the agencies can offer progressively more stringent standards that help meet our fuel consumption reduction and GHG emission goals at a faster and more cost-effective pace.
64 
(i) Carryover of Phase 1 Credits and Credit Life 
The agencies proposed to continue 
the five-year credit life provisions from Phase 1, and not to adopt any general restriction on the use of banked Phase 1 credits in Phase 2. In other words, Phase 1 credits in MY 2019 could be used in Phase 1 or in Phase 2 in MYs 2021–2024. CARB commented in support of a more restrictive approach for Phase 1 credits, based on the potential for manufacturers to delay implementation of technology in Phase 2 by using credits generated under Phase 1. We also received comments asking the agencies to provide a path for manufacturers to generate credits for applying technologies not explicitly included in the Phase 1 program. In response to these comments, the agencies have analyzed the potential impacts of Phase 1 credits on the Phase 2 program for each sector and made appropriate adjustments in the program. For example, as described in Section II.D.(5), the agencies are adopting some restrictions on the carryover of windfall Phase 1 engine credits that result from the Phase 1 vocational engine standards. 
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6579 FR 23492, April 28, 2014 and 40 CFR 
86.1805–17. 
66NHTSA’s useful life is based on mileage and 
years of duration. Also, as described in Section III, the 
agencies are projecting that Phase 1 credit balances for tractor manufacturers will enable them to meet more stringent standards for MY 2021–2023, so the agencies have increased the stringency of these standards accordingly. 
In contrast to the Phase 1 tractor 
program, the Phase 1 vocational chassis program currently offers fewer opportunities to generate credits for potential carryover into Phase 2. To address comments related to this particular situation and also to provide a new Phase 1 incentive to voluntarily apply certain Phase 2 technologies, which are available today but currently not being adopted, the agencies are finalizing a streamlined Phase 1 off- cycle credit approval process for these Phase 2 technologies. For vocational chassis, these technologies include workday idle reduction technologies such as engine stop-start systems, automatic engine shutdown systems, shift-to-neutral at idle automatic transmissions, automated manual transmissions, and dual-clutch transmissions. The agencies are also finalizing a streamlined Phase 1 off- cycle credit approval process for Phase 2 automatic tire inflation systems (ATIS), for both tractors and vocational chassis. The purpose for offering these streamlined off-cycle approval processes for Phase 1 is to encourage more early adoption of these Phase 2 technologies during the remaining portion of the Phase 1 program (e.g., model years 2018, 
2019, 2020). Earlier adoption of these technologies would help demonstrate that these newer, but not advanced, technologies are effective, reliable and well-accepted into the marketplace by the time the agencies project that they would be needed for compliance with the Phase 2 standards. 
The agencies are also including a 
provision allowing exempt small business manufacturers of vocational chassis to opt into the Phase 1 program for the purpose of generating credits which can be used throughout the Phase 2 program, as just described. 
In conjunction with this provision 
allowing manufacturers to receive credit in Phase 1 for pulling ahead certain Phase 2 technologies, the agencies are providing an extended credit life for the Light and Medium heavy-duty 
vocational vehicle averaging sets (see next subsection) to provide additional Phase 2 transition flexibility for these vehicles. Unlike the HD Phase 1 pickup/ van and tractor programs, where the averaging sets are broad; where manufacturers have many technology choices from which to earn credits (e.g., tractor aerodynamic and idle reduction technologies, pickup/van engine and 
transmission technologies); and where we project manufacturers to have sufficient pickup/van and tractor credits to manage the transition to the Phase 2 standards, transitioning to the new Light and Medium vocational vehicle standards may be more challenging. Manufacturers selling lower volumes of these lighter vehicles may find themselves with fewer overall credits to manage the transition to the new standards, especially the 2027 standards. To facilitate this transition and better assure adequate lead time, the agencies are extending the credit life for the Light and Medium heavy-duty vehicle averaging sets (typically vehicles in Classes 2b through 7) so that all credits generated in 2018 and later will last at least until 2027. We are not doing this for the Heavy heavy-duty vocational vehicle category (typically Class 8) because tractor credits may be used within this averaging set. Because we project that manufacturers will have sufficient tractor credits, we believe that they will be able to manage the Heavy vocational transition to each set of new standards, without the extended credit life that we are finalizing for Light and Medium vocational averaging sets. Nevertheless, we will continue to monitor the manufacturers’ progress in transitioning to the Phase 2 standards for each category, and we may reconsider the need for additional transitional flexibilities, such as extending other categories’ credit lives. 
Although, as we have already noted, 
the numerical values of Phase 2 standards are not directly comparable in an absolute sense to the existing Phase 1 standards (in other words, a given vehicle would have a different g/ton- mile emission rate when evaluated using Phase 1 GEM than it would when evaluated using Phase 2 GEM), we believe that the Phase 1 and Phase 2 credits are largely equivalent. Because the standards and emission levels are included in a relative sense (as a difference), it is not necessary for the Phase 1 and Phase 2 standards to be directly equivalent in an absolute sense in order for the credits to be equivalent. 
This is best understood by examining 
the way in which credits are calculated. For example, the credit equations in 40 CFR 1037.705 and 49 CFR 535.7 calculate credits as the product of the difference between the standard and the vehicle’s emission level (g/ton-mile or gallon/1,000 ton-mile), the regulatory payload (tons), production volume, and regulatory useful life (miles). The Phase 2 payloads, production volumes, and 
useful lives for tractors, medium and heavy heavy-duty engines, or medium and heavy heavy-duty vocational 
vehicles are equivalent to those of Phase 1. However, EPA is changing the regulatory useful lives of HD pickups and vans, light heavy-duty vocational vehicles, spark-ignited engines, and light heavy-duty compression-ignition engines. Because useful life is a factor in determining the value of a credit, the agencies proposed to apply interim 
adjustment factors to ensure banked credits maintain their value in the transition from Phase 1 to Phase 2. 
For Phase 1, EPA aligned the useful 
life for GHG emissions with the useful life already in place for criteria pollutants. After the Phase 1 rules were finalized, EPA updated the useful life for criteria pollutants as part of the Tier 3 rulemaking.
65The new useful life 
implemented for Tier 3 is 150,000 miles or 15 years, whichever occurs first. This same useful life is being adopted in Phase 2 for HD pickups and vans, light heavy-duty vocational vehicles, spark- ignited engines, and light heavy-duty compression-ignition engines.
66The 
numeric value of the adjustment factor for each of these regulatory categories depends on the Phase 1 useful life. These are described in detail below in this Preamble in Sections II, V, and VI. Without these adjustment factors the changes in useful life would effectively result in a discount of banked credits that are carried forward from Phase 1 to Phase 2, which is not the intent of the changes in the useful life. With the relatively flat deterioration generally associated with CO
2, EPA does not 
believe the changes in useful life will significantly affect the feasibility of the Phase 2 standards. 
We note that the primary purpose of 
allowing manufacturers to bank credits is to provide flexibility in managing transitions to new standards. The five- year credit life is substantial, and allows credits generated in either Phase 1 or early in Phase 2 to be used for the intended purpose. The agencies believe a credit life longer than five years is unnecessary to accomplish this transition. Restrictions on credit life serve to reduce the likelihood that any manufacturer will be able to use banked credits to disrupt the heavy-duty vehicle market in any given year by effectively limiting the amount of credits that can be held. Without this limit, one manufacturer that saved enough credits over many years could achieve a significant cost advantage by using all the credits in a single year. The agencies 
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67Averaging for trailers does not begin until 2027. believe that allowing a five-year credit 
life for all credits, and as a consequence allowing use of Phase 1 credits in Phase 2, creates appropriate flexibility and appropriately facilitates a smooth transition to each new level of standards. 
(ii) Averaging Sets 
EPA has historically restricted 
averaging to some extent for its HD 
emission standards to avoid creating unfair competitive advantages or environmental risks due to credits being inconsistent. It also helps to ensure a robust and manageable compliance program. Under Phase 1, averaging, banking and trading can only occur within and between specified ‘‘averaging sets’’ (with the exception of credits generated through use of specified advanced technologies). As proposed, we will continue this regime in Phase 2, retaining the existing vehicle and engine averaging sets, and creating new trailer averaging sets. We are also continuing the averaging set restrictions from Phase 1 in Phase 2. (See Section V for certain other provisions applicable to vehicles certified to special standards.) These general averaging sets for vehicles are: 
•Complete pickups and vans 
•Other light heavy-duty vehicles 
(Classes 2b–5) 
•Medium heavy-duty vehicles (Class 
6–7) 
•Heavy heavy-duty vehicles (Class 8) 
•Long dry and refrigerated van 
trailers
67 
•Short dry and refrigerated van trailers 
We are not allowing trading between 
engines and chassis, even within the same vehicle class. Such trading would essentially result in double counting of emission credits, because the same engine technology would likely generate credits relative to both standards (and indeed, certain engine improvements are reflected exclusively in the vehicle standards the agencies are adopting). We similarly limit trading among engine categories to trades within the designated averaging sets: 
•Spark-ignition engines 
•Compression-ignition light heavy- 
duty engines 
•Compression-ignition medium heavy- 
duty engines 
•Compression-ignition heavy heavy- 
duty engines 
The agencies continue to believe that 
maintaining trading to be only within the classes listed above will provide adequate opportunities for manufacturers to make necessary technological improvements and to 
reduce the overall cost of the program without compromising overall environmental and fuel efficiency objectives, and it is therefore appropriate and reasonable under EPA’s authority and maximum feasible under NHTSA’s authority, respectively. We do not expect emissions from engines and vehicles—when restricted by weight class—to be dissimilar. We therefore expect that the lifetime vehicle performance and emissions levels will be very similar across these defined categories, and the credit calculations will fairly ensure the expected fuel consumption and GHG emission reductions. 
These restrictions have generally 
worked well for Phase 1, and we continue to believe that these averaging sets create flexibility without creating an unfair advantage for manufacturers with integrated portfolios, including engines and vehicles. See 76 FR 57240. 
(iii) Credit Deficits 
The Phase 1 regulations allow 
manufacturers to carry-forward deficits 
for up to three years. This is an important flexibility because the program is designed to address the diversity of the heavy-duty industry by allowing manufacturers to sell a mix of engines or vehicles that have very different emission levels and fuel efficiencies. Under this construct, 
manufacturers can offset sales of engines or vehicles not meeting the standards by selling others (within the same averaging set) that perform better than the standards require. However, in any given year it is possible that the actual sales mix will not balance out, and the manufacturer may be short of credits for that model year. The three- year provision allows for this possibility and creates additional compliance flexibility to accommodate it. 
(iv) Advanced Technology Credits 
At the time of the proposal, the 
agencies believed it was no longer 
appropriate to provide extra credit for any of the technologies identified as advanced technologies for Phase 1, although we requested comment on this issue. The Phase 1 advanced technology credits were adopted to promote the implementation of advanced technologies that were not included in our basis of the feasibility of the Phase 1 standards. Such technologies included hybrid powertrains, Rankine cycle waste heat recovery systems on engines, all-electric vehicles, and fuel cell vehicles (see 40 CFR 86.1819–14(k)(7), 1036.150(h), and 1037.150(p)). The Phase 2 heavy-duty engine and vehicle standards are premised on the use of 
some of these technologies, making them equivalent to other fuel-saving technologies in this context. We believe the Phase 2 standards themselves will provide sufficient incentive to develop those specific technologies. 
Although the agencies proposed to 
eliminate all advanced technology 
incentives, we remained open to targeted incentives that would address truly advanced technology. We specifically requested comment on this issue with respect to electric vehicle, plug-in hybrid, and fuel cell technologies. Although the Phase 2 standards are premised on some use of Rankine cycle waste heat recovery systems on engines and hybrid powertrains, none of these standards are based on projected utilization of these other even more-advanced technologies (e.g., all-electric vehicles, fuel cell 
vehicles). 80 FR 40158. Commenters generally supported providing credit multipliers for these advanced technologies. However, Allison supported ending the incentives for hybrids, fuel cells, and electric vehicles in Phase 2. ATA, on the other hand, commented that the agencies should preserve the advanced technology credits which provide a credit multiplier of 1.5 in order to promote the use of hybrid and electric vehicles in larger vocational vehicles and tractors. ARB supported the use of credit multipliers even more strongly and provided suggestions for values larger than 1.5 that could be used to incentivize plug-in hybrids, electric vehicles, and fuel cell vehicles. Eaton recommended the continuation of advanced technology credits for hybrid powertrains until a sufficient number are in the market. Overall, the comments indicated that there is support for such incentives among operators, suppliers, and states. Upon further consideration, the agencies are adopting advanced technology credits for these three types of advanced technologies, as shown in Table I–2 below. 
TABLE I–2—A DVANCED TECHNOLOGY  
MULTIPLIERS  
Technology Multiplier 
Plug-in hybrid electric vehicles 3.5 
All-electric vehicles ................... 4.5 
Fuel cell vehicles ...................... 5.5 
Our intention in adopting these 
multipliers is to create a meaningful incentive to those considering adopting these qualifying advanced technologies into their vehicles. The values being 
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68Letter from Michael Carter, ARB, to Gina 
McCarthy, Administrator, EPA and Mark Rosekind, 
Administrator, NHTSA, June 16, 2016. 
69Credits can be generated against these 
standards as well, but the life of credits generated for 2025 and 2026 would be five years. The pull ahead of the MY 2021 standards should more than balance out any slight decreases in benefits 
attributable to such credits. 
70The final rule (40 CFR 1036.150(p)) provides 
that for engine manufacturers choosing this 
alternative option, credits generated with MY 2018– 2024 engines can be used until MY 2030. Credits from later model years can be used for five years from generation under 40 CFR 1037.740(c). 71Compliance with this requirement would be 
evaluated at the time of certification and when end 
of year ABT reports are submitted. Manufacturers that show a net credit deficit for the averaging set at the end of the year would not meet this requirement. adopted are consistent with values 
recommended by CARB in their supplemental comments.
68CARB’s 
values were based on a cost analysis that compared the costs of these technologies to costs of other conventional technologies. Their costs analysis showed that adopting multipliers in this range would make these technologies much more competitive with the conventional technologies and could allow manufacturers to more easily generate a viable business case to develop these technologies for heavy-duty and bring them to market at a competitive price. 
Another important consideration in 
the adoption of these larger multipliers is the tendency of the heavy-duty sector to significantly lag the light-duty sector in the adoption of advanced technologies. There are many possible reasons for this, such as: 
•Heavy-duty vehicles are more 
expensive than light-duty vehicles, which makes it a greater monetary risk for purchasers to invest in unproven technologies. 
•These vehicles are work vehicles, 
which makes predictable reliability even more important than for light-duty vehicles. 
•Sales volumes are much lower for 
heavy-duty vehicles, especially for specialized vehicles. 
As a result of factors such as these, 
adoption rates for these advanced technologies in heavy-duty vehicles are essentially non-existent today and seem unlikely to grow significantly within the next decade without additional incentives. 
The agencies believe it is appropriate 
to provide such large multipliers for these very advanced technologies at least in the short term, because they have the potential to provide very large reductions in GHG emissions and fuel consumption and advance technology development substantially in the long term. However, because they are so large, we also believe that we should not necessarily allow them to continue indefinitely. Therefore, the agencies are adopting them as an interim program that will continue through MY 2027. If the agencies determine that these credit multipliers should be continued beyond MY 2027, we could do so in a future rulemaking. As discussed in Section I.C.(1)(d), the 
agencies are not specifically accounting 
for upstream emissions that might occur from production of electricity to power these advanced vehicles. This approach 
is largely consistent with the incentives offered for electric vehicles in the light- duty National Program. 77 FR 62810. For light-duty vehicles, the agencies also did not require manufacturers to account for upstream emissions during the initial years, as the technologies are being developed. While we proactively sunset this allowance for light-duty due to concerns about potential impacts from very high sales volumes, we do not have similar concerns for heavy-duty. Nevertheless, in this program we are only adopting these credit multipliers through MY 2027, and should we not promulgate a future rulemaking to extend them beyond MY 2027, these multipliers would essentially sunset in MY 2027. 
One feature of the Phase 1 advanced 
technology program that is not being continued in Phase 2 is the allowance to use advanced technology credits across averaging sets. We believe that combined with the very large multipliers being adopted, there could be too large a risk of market distortions if we allowed the use of these credits across averaging sets. 
(v) Transition Flexibility for Meeting the 
Engine Standards 
Some manufacturers commented that 
the proposed engine regulations did not offer sufficient flexibility. Although these commenters acknowledge that the tractor and vocational vehicle standards 
will separately drive engine improvements, they nonetheless maintain that the MY 2024 engine standards may constrain potential compliance paths too much. Some commented that advanced technologies (such as waste heat recovery) may need to be deployed before the technologies are fully reliable for every engine manufacturer, and may lead to the development and implementation of additional engine technologies outside of scheduled engine redesign cycles, which could cause manufacturers to incur costs which were not accounted for in the agencies’ analyses. These costs could include both product development and equipment costs for the engine manufacturer, and potential increased costs for vehicle owners 
associated with potential reliability issues in-the-field. 
The agencies have considered these 
comments carefully. See, e.g., RIA 
Section 2.3.9 and RTC Section 3.4. The agencies recognize the importance of ensuring that there is adequate lead time to develop, test, and otherwise assure reliability of the technologies projected to be needed to meet the standards and for the advanced engine technologies in particular. See Section I.C above; see also responses regarding waste heat recovery technology in RTC Section 3.4, and Response 3.4.1. The agencies are therefore adopting an alternative, optional ABT flexibility for heavy-heavy and medium-heavy engines in partial response to these comments. This optional provision would affect only the MYs 2021 and 2024 standards for these engines, not the final MY 2027 engine standards, and to the extent manufacturers elect the provision would increase fuel consumption and GHG 
reduction benefits, as explained below. 
This optional provision has three 
aspects: 
•A pull ahead of the engine standards 
to MY 2020 
•Extended credit life for engine credits 
generated against MYs 2018–2019 
Phase 1 standards, the MY 2020 pull- ahead Phase 2 engine standards, and the MYs 2021–2024 Phase 2 engine standards 
•Slightly relaxed engine standards for 
MYs 2024–2026 tractor engine standards
69 
Thus, the final rule provides the 
option of an extended credit life for the medium heavy-duty and heavy heavy- duty engines so that all credits generated in MY 2018 and later will last at least until MY 2030.
70To be eligible 
for this allowance, manufacturers would need to voluntarily certify all of their HHD and/or MHD MY 2020 engines (tractor and vocational) to MY 2021 standards.
71Manufacturers could elect 
to apply this provision separately to medium heavy-duty and heavy heavy- duty engines, since these remain separate averaging sets. Credits banked by the manufacturer in Phase 1 for model year 2018 and 2019 engines would be eligible for the extended credit life for manufacturers satisfying the pull ahead requirement. Such credits could be used in any model year 2021 through 
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72The agencies view this alternative as of 
reasonable cost with respect to the vehicle 
standards. First, where engine manufacturers and vehicle manufacturers are vertically integrated, that manufacturer would choose the alternative which is most cost advantageous. Second, where engine manufacturers and vehicle manufacturers are not vertically integrated, the agencies anticipate that engines certified to the alternative and the main standards will both be available for the vehicle manufacturer to purchase, so that the vehicle manufacturer would not need to incur any costs attributable to the alternative engine standard. 2030. Manufacturers that voluntarily 
certify their engines to MY 2021 standards early would then also be eligible for slightly less stringent engine tractor standards in MYs 2024–2026, as shown in the following table. 
TABLE I–3—O PTIONAL ABT F LEXIBILITY STANDARDS FOR HEAVY -HEAVY AND MEDIUM -HEAVY ENGINES  
Model years Medium heavy-duty—tractor Heavy heavy-duty—tractor 
EPA CO 2 
standard 
(g/bhp-hr) NHTSA fuel 
consumption 
standard 
(gal/100bhp-hr) EPA CO 2 
standard 
(g/bhp-hr) NHTSA fuel 
consumption 
standard 
(gal/100bhp-hr) 
2020–2023 ................................................................................................... 473 4.6464 447 4.3910 
2024–2026 ................................................................................................... 467 4.5874 442 4.3418 
Once having opted into this 
alternative compliance path, engine manufacturers would have to adhere to that path for the remainder of the Phase 2 program. The choice would be made when certifying MY 2020 engines. Instead of certifying engines to the final year of the Phase 1 engine standards, manufacturers electing the alternative would indicate that they are instead certifying to the MY 2021 Phase 2 engine standard. 
Because these engine manufacturers 
would be reducing emissions of engines otherwise subject to the MY 2020 Phase 1 engine standards (and because engine reductions were not reflected in the Phase 1 vehicle program), there would 
be a net benefit to the environment. These engines would not generate credits relative to the Phase 1 standards (that is, MY 2020 engines would only use or generate credits relative to the pulled ahead MY 2021 Phase 2 engines standards) which would result in net reductions of CO
2and fuel consumption 
of about 2 percent for each engine. Thus, if every engine manufacturer chooses to use this flexibility, there could be resulting reductions of an additional 12MMT of CO
2and saving of 
nearly one billion gallons of diesel fuel. 
This alternative also does not have 
adverse implications for the vehicle standards. As just noted, the vehicle standards themselves are unaffected. Thus, these voluntary standards would not reduce the GHG reductions or fuel savings of the program. Vehicle manufacturers using the alternative MYs 2024–2026 engines would need to adopt additional vehicle technology (i.e. technology beyond that projected to be needed to meet the standard) to meet the vehicle standards. This means the vehicles would still achieve the same fuel efficiency in use.
72 In sum, the agencies view this 
alternative as being positive from the 
environmental and energy conservation perspectives, and believe it will provide significant flexibility for manufacturers that may reduce their compliance costs. It also provides a hedge against potential premature introduction of advanced engine technologies, providing more lead time to assure in- 
use reliability. 
(c) Innovative Technology and Off-Cycle 
Credits 
The agencies are continuing the Phase 
1 innovative technology program (reflecting certain streamlining features as just discussed), but re-designating it as an off-cycle program for Phase 2. In other words, beginning in MY 2021 technologies that are not accounted for in the GEM simulation tool, or by compliance dynamometer testing (for engines or chassis certified vehicles) will be considered ‘‘off-cycle,’’ including those technologies that may no longer be considered innovative technologies. 
The final rules provide that in order 
for a manufacturer to receive these credits for Phase 2, the off-cycle technology will still need to meet the requirement that it was not in common use prior to MY 2010. Although we have not identified specific off-cycle technologies at this time that should be excluded, we believe it is prudent to continue this requirement to avoid the potential for manufacturers to receive windfall credits for technologies that they were already using before MY 2010, and that are therefore reflected in the Phase 2 (and possibly Phase 1) baselines. However, because the Phase 2 program will be implemented in MY 2021 and extend at least through MY 2027, the agencies and manufacturers may have difficulty in the future determining whether an off-cycle 
technology was in common use prior to MY 2010. In order to avoid this approach becoming an unnecessary hindrance to the off-cycle program, the agencies will presume that off-cycle technologies were not in common use in 2010 unless we have clear evidence to the contrary. Neither the agencies nor manufacturers will be required to demonstrate that the technology meets this 2010 criteria. Rather, the agencies will simply retain the authority to deny a request for off-cycle credits if it is clear that the technology was in common use in 2010 and thus part of the baseline. 
Manufacturers will be able to carry 
over innovative technology credits from Phase 1 into Phase 2, subject to the same 
restrictions as other credits. Manufacturers will also be able to carry over the improvement factor (not the credit value) of a technology, if certain criteria are met. The agencies will require documentation for all off-cycle requests similar to those required by EPA for its light-duty GHG program. 
Additionally, the agencies will not 
grant any off-cycle credits for crash avoidance technologies. The agencies will also require manufacturers to consider the safety of off-cycle technologies and will request a safety assessment from the manufacturer for all off-cycle technologies. 
Similar principles apply to off-cycle 
credits in this heavy-duty Phase 2 program as under the light-duty vehicle rules. Thus, technologies which are part of the basis of a Phase 2 standard would not be eligible for off-cycle credits. Their benefits have been accounted for in developing the stringency of the Phase 2 standard, as have their costs. See 77 FR 62835 (October 15, 2012). In addition, technologies which are integral or inherent to the basic vehicle design and are recognized in GEM or under the FTP (for pickups and vans), including engine, transmission, mass reduction, passive aerodynamic design, and base tires, will not be eligible for off-cycle credits. 77 FR 62836. 
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73See Section XI for additional discussion of 
natural gas engines and vehicles. Technologies integral or inherent to 
basic vehicle design are fully functioning and are thus recognized in GEM, or operate over the entirety of the FTP/HFET and therefore are adequately captured by the test procedure. 
Just as some technologies that were 
considered off-cycle for Phase 1 are being adopted as primary technologies in Phase 2 on whose performance standard stringency is calculated, the agencies may revise the regulation in a future rulemaking to create a more direct path to recognize technologies currently considered off-cycle. For example, although we are including specific provisions to recognize certain electrified accessories, recognizing others would require the manufacturer to go through the off-cycle process. However, it is quite possible that the 
agencies could gather sufficient data to allow us to adopt specific provisions in a future rulemaking to recognize other accessories in a simpler manner. Because such a change would merely represent a simpler way to receive the same credit as could be obtained under the regulations being adopted today (rather than a change in stringency), it would not require us to reconsider the standards. 
(d) Alternative Fuels and Electric 
Vehicles 
The agencies will largely continue the 
Phase 1 approach for engines and vehicles fueled by fuels other than gasoline and diesel.
73Phase 1 engine 
emission standards applied uniquely for gasoline-fueled and diesel-fueled engines. The regulations in 40 CFR part 86 implement these distinctions for alternative fuels by dividing engines into Otto-cycle and Diesel-cycle technologies based on the combustion cycle of the engine. However, as proposed, the agencies are making a small change that is described in Section II. Under this change, we will require manufacturers to divide their natural gas engines into primary intended service classes, like the current requirement for compression-ignition engines. Any alternative fuel-engine qualifying as a heavy heavy-duty engine will be subject to all the emission standards and other requirements that apply to compression-ignition engines. Note that this small change in approach will also apply with respect to EPA’s criteria pollutant program. 
We are also applying the Phase 2 
standards at the vehicle tailpipe. That is, compliance is based on vehicle fuel consumption and GHG emission reductions, and does not reflect any so- 
called lifecycle emission properties. The agencies have explained why it is reasonable that the heavy-duty standards be fuel neutral in this manner and adhere to this reasoning here. See 76 FR 57123; see also 77 FR 51705 (August 24, 2012) and 77 FR 51500 (August 27, 2012). In particular, EPA notes that there is a separate, statutorily- mandated program under the Clean Air Act which encourages use of renewable fuels in transportation fuels, including renewable fuel used in heavy-duty diesel engines. This program considers lifecycle greenhouse gas emissions compared to petroleum fuel. NHTSA notes that the fuel efficiency standards are necessarily tailpipe-based, and that a lifecycle approach would likely render it impossible to harmonize the fuel efficiency and GHG emission standards, to the great detriment of our goal of achieving a coordinated program. 77 FR 51500–51501; see also 77 FR 51705 (similar finding by EPA); see also Section I.F.(1)(a) below, Section 1.8 of the RTC, and Section XI.B. 
The agencies received mixed 
comments on this issue. Many commenters supported the proposed approach, generally agreeing with the agencies’ arguments. However, some other commenters opposed this approach. Opposing commenters generally fell into two categories: 
•Commenters concerned that 
upstream emissions of methane occurring during the production and distribution of natural gas would offset some or all of the GHG emission reductions observed at the tailpipe. 
•Commenters concerned that 
tailpipe-only standards ignore the GHG benefits of using renewable fuels. 
The agencies are not issuing rules that 
effectively would turn these rules into a fuel program, rather than an emissions reduction and fuel efficiency program. Nor will the agencies disharmonize the program by having GHG standards reflect upstream emissions having no relation to fuel efficiency. See e.g. 77 FR 
51500–51501; see also 77 FR 51705. We 
thus will continue to measure compliance at the tailpipe. Issues relating to whether to consider in the emission standards upstream emissions related to natural gas exploration and production are addressed in detail in Section XI below. It is sufficient to state here that the agencies carefully investigated the potential use of natural gas in the heavy-duty sector and the impacts of such use. We do not believe that the use of natural gas is likely to become a major fuel source for heavy- duty vehicles during the Phase 2 time frame. Thus, since we project natural gas vehicles to have little impact on 
both overall GHG emissions and fuel consumption during the Phase 2 time frame, the agencies see no need to make fundamental changes to the Phase 1 approach for natural gas engines and vehicles. 
The agencies note further that a 
consequence of the tailpipe-based approach is that the agencies will treat vehicles powered by electricity the same as in Phase 1. In Phase 1, EPA treated all electric vehicles as having zero tailpipe emissions of CO
2, CH 4, and N 2O 
(see 40 CFR 1037.150(f)). Similarly, NHTSA adopted regulations in Phase 1 that set the fuel consumption standards based on the fuel consumed by the vehicle. The agencies also did not require emission testing for electric vehicles in Phase 1. The agencies considered the potential unintended consequence of not accounting for upstream emissions from the charging of heavy-duty electric vehicles. In our reassessment for Phase 2, we have found only one all-electric heavy-duty vehicle manufacturer that has certified through 2016. As we look to the future, we project limited adoption of all-electric vehicles into the market. Therefore, we believe that this provision is still appropriate. Unlike the 2017–2025 light-duty rule, which included a cap whereby upstream emissions would be counted after a certain volume of sales (see 77 FR 62816–62822), we believe there is no need to establish a cap for heavy-duty vehicles because of the small likelihood of significant production of EV technologies in the Phase 2 timeframe. Commenters specifically addressing electric vehicles generally supported the agencies’ proposal. However, some commenters did support accounting for emissions from the generation of electricity in the broader context of supporting full life- cycle analysis. As noted above, and in more detail in Section I.F.(2)(f) as well as Section 1.8 of the RTC, the agencies are not predicating the standards on a full life-cycle approach. 
(e) Phase 1 Interim Provisions 
EPA adopted several flexibilities for 
the Phase 1 program (40 CFR 86.1819– 
14(k), 1036.150 and 1037.150) as interim provisions. Because the existing regulations do not have an end date for Phase 1, most of these provisions did not have an explicit end date. NHTSA adopted similar provisions. With few exceptions, the agencies are not continuing these provisions for Phase 2. These will generally remain in effect for the Phase 1 program. In particular, the agencies note that we are not continuing the blanket exemption for small 
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manufacturers. Instead, in Phase 2 the 
agencies are providing more targeted relief for these entities. 
(f) In-Use Standards and Recall 
Section 202(a)(1) of the CAA specifies 
that EPA is to adopt emissions 
standards that are applicable for the useful life of the vehicle and for the engine. EPA finalized in-use standards for the Phase 1 program, whereas NHTSA’s rules do not include these standards. For the Phase 2 program, EPA will carry-over its in-use provisions, and NHTSA is adopting EPA’s useful life requirements for its vehicle and engine fuel consumption standards to ensure manufacturers consider in the design process the need for fuel efficiency standards to apply for the same duration and mileage as EPA standards. If EPA determines a manufacturer fails to meet its in-use standards, civil penalties may be assessed. 
CAA section 207(c)(1) requires ‘‘the 
manufacturer’’ to remedy certain in-use problems. The remedy process is to recall the nonconforming vehicles and bring them into conformity with the standards and the certificate. The regulations for this process are in 40 CFR part 1068, subpart F. EPA is also adopting regulatory text addressing recall obligations for component manufacturers and other non-certifying manufacturers. We note that the CAA does not limit this responsibility to certificate holders, consistent with the definition of a ‘‘manufacturer’’ as ‘‘any person engaged in the manufacturing or 
assembling of new motor vehicles, new motor vehicle engines, new nonroad vehicles or new nonroad engines, or importing such vehicles or engines for resale, or who acts for and is under the control of any such person in connection with the distribution of new motor vehicles, new motor vehicle engines, new nonroad vehicles or new nonroad engines, but shall not include any dealer with respect to new motor vehicles, new motor vehicle engines, new nonroad vehicles or new nonroad engines received by him in commerce.’’ 
As discussed in Section I.E.(1) below, 
this definition was not intended to restrict the definition of ‘‘manufacturer’’ to a single person per vehicle. Under EPA regulations, we can require any person meeting the definition of manufacturer for a nonconforming vehicle to participate in a recall. However, we would normally presume the certificate holder to have the primary responsibility. 
EPA requested comment on adding 
regulatory text that would explicitly apply these provisions to tire manufacturers. Comments from the tire industry generally opposed this noting that they are not the manufacturer of the vehicle. These comments are correct that tires are not incomplete vehicles and hence that the recall authority does not apply for companies that only manufacture the tires. However, EPA remains of the view that in the event that vehicles (e.g. trailers) do not 
conform to the standards in-use due to nonconforming tires, tire manufacturers would have a role to play in remedying the problem. In this (hypothetical) situation, a tire manufacturer would not only have produced the part in question, but in the case of a trailer manufacturer or other small vehicle manufacturer, would have significantly more resources and knowledge regarding how to address (and redress) the problem. Accordingly, EPA would likely require that a component manufacturer responsible for the nonconformity assist in the recall to an extent and in a manner consistent with the provisions of CAA section 208(a). This section specifies that component and part manufacturers ‘‘shall establish and maintain records, perform tests where such testing is not otherwise reasonably available under this part and part C of this subchapter (including fees for testing), make reports and provide information the Administrator may reasonably require to determine whether the manufacturer or other person has acted or is acting in compliance with this part and part C of this subchapter and regulations thereunder, or to otherwise carry out the provision of this part and part C of this subchapter. . .’’. Any such action would be considered on a case-by-case basis, adapted to the particular circumstances at the time. 
(g) Vehicle Labeling 
EPA proposed to largely continue the 
Phase 1 engine and vehicle labeling 
requirements, but to eliminate the requirement for tractor and vocational vehicle manufacturers to list emission control on the label. The agencies consider it crucial that authorized compliance inspectors are able to identify whether a vehicle is certified, and if so whether it is in its certified condition. To facilitate this identification in Phase 1, EPA adopted labeling provisions for tractors that included several items. The Phase 1 tractor label must include the manufacturer, vehicle identifier such as the Vehicle Identification Number (VIN), vehicle family, regulatory subcategory, date of manufacture, compliance statements, and emission control system identifiers (see 40 CFR 1037.135). EPA proposed to apply 
parallel requirements for trailers. 
In Phase 1, the emission control 
system identifiers are limited to vehicle speed limiters, idle reduction technology, tire rolling resistance, some aerodynamic components, and other innovative and advanced technologies. However, the number of emission control systems for greenhouse gas emissions in Phase 2 has increased significantly for tractors and vocational vehicles. For example, all aspects of the engine transmission and drive axle; accessories; tire radius and rolling resistance; wind averaged drag; predictive cruise control; idle reduction technologies; and automatic tire inflation systems are controls which can be evaluated on-cycle in Phase 2 (i.e. these technologies’ performance can now be input to GEM), but could not be in Phase 1. Due to the complexity in determining greenhouse gas emissions in Phase 2, the agencies do not believe that we can unambiguously determine whether or not a vehicle is in a certified condition through simply comparing information that could be made available on an emission control label with the components installed on a vehicle. Therefore, EPA proposed to remove the requirement to include the emission control system identifiers required in 40 CFR 1037.135(c)(6) and in Appendix III to 40 CFR part 1037 from the emission control labels for vehicles certified to the Phase 2 standards. The agencies received comments on the emission control labels from Navistar, which supported the elimination of the emission control information from the vehicle GHG label. 
Although we are largely finalizing the 
proposed labeling requirements, we remain interested in finding a better approach for labeling. Under the agencies’ existing authorities, manufacturers must provide detailed build information for a specific vehicle upon our request. Our expectation is that this information should be available to us via email or other similar electronic communication on a same- day basis, or within 24 hours of a request at the latest. The agencies have started to explore ideas that would provide inspectors with an electronic method to identify vehicles and access on-line databases that would list all of the engine-specific and vehicle-specific emissions control system information. We believe that electronic and Internet technology exists today for using scan tools to read a bar code or radio frequency identification tag affixed to a vehicle that could then lead to secure 
on-line access to a database of manufacturers’ detailed vehicle and 
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74Anti-stockpiling provisions will generally 
prevent vehicle manufacturers from using new 
engines older than the prior model year. See Section XIII.B for a discussion of EPA requirements for installing older used engines into new vehicles. 75For the flat baseline referenec case, the agencies 
project that tractors engines will meet the Phase 1 engine standards with a small compliancee margin. The Phase 1 standards for diesel engines will be fully phased-in by MY 2017, so we use MY 2017 as the baseline engine for tractors. Note that we project that vocational engines will achieve 
additioanl overcompliance with the Phase 1 vocational engine standards. 76As noted in Section II, the numerical levels of 
the vocational engine standards also reflect an 
updated baseline in which Phase 1 vocational engines are more efficient than assumed for the proposal. In addition, the numerical levels of the tractor engine standards reflect an updated baseline to reflect the changes to the test cycle. engine build information. Our 
exploratory work on these ideas has raised questions about the level of effort that would be required to develop, implement and maintain an information technology system to provide inspectors real-time access to this information. We have also considered questions about privacy and data security. We requested comment on the concept of electronic labels and database access, including any available information on similar systems that exist today and on burden estimates and approaches that could address concerns about privacy and data security. 
Although we are not finalizing such a 
program in this rulemaking, we remain very interested in the use of electronic labels that could be used by the agencies to access vehicle information and may pursue these in a future rulemaking. Such a rulemaking would likely consider the feasibility of accessing dynamic link libraries in real-time to view each manufacturer’s build records (and perhaps pending orders). The agencies envision that this could be very useful for our inspectors by providing them access to the build information by VIN to confirm that each vehicle has the proper emission control features. 
(h) Model Year Definition 
The agencies proposed to continue 
the Phase definitions of ‘‘model year’’ 
for compliance with GHG emissions and fuel efficiency standards. However, in response to comments, the agencies are revising the definition slightly for Phase 2 tractors and vocational vehicles to match the model years of the engines installed in them. The revised definition generally sets the vehicle model year to be the calendar year of manufacture, but allows the vehicle manufacturer the option to select the prior year if the vehicle uses an engine manufactured in the prior model year.
74Because Phase 2 
vehicle standards are based in part on engine performance, some commenters stated that the engine model year should dictate the vehicle’s GHG and fuel efficiency compliance model year, and that the emissions and fuel efficiency compliance model year should be presented on the vehicle emissions label. This would allow manufacturers to market a vehicle and certify it to NHTSA’s safety standards based on the standards applicable on the date of manufacture, but certify the vehicle for GHG emissions and fuel efficiency purposes based on the engine model compliance year. For example, a 2023 model year tractor might have a 2022 model year engine in it. The tractor would be marketed as a model year 2023 tractor, certified as complying with NHTSA’s safety standards applicable at the time when certifying the vehicle, but would have an ‘‘emissions and fuel efficiency compliance model year’’ of 2022 for purposes of emissions and fuel efficiency standards. In today’s action, NHTSA and EPA are finalizing standards that allow for the use of an ‘‘emissions and fuel efficiency compliance model year.’’ This is consistent with past program practice, in which certain manufacturers have been able to reclassify tractors to the previous model year for emissions purposes when the tractors use engines from the previous model year. 
(2) Phase 2 Standards 
This section briefly summarizes the 
Phase 2 standards for each category and 
identifies the technologies that the agencies project will be needed to meet the standards. Given the large number of different regulatory categories and model years for these standards, the actual numerical standards are not listed. Readers are referred to Sections II through IV for the tables of standards. 
(a) Summary of the Engine Standards 
The agencies are continuing the basic 
Phase 1 structure for the Phase 2 engine 
standards. There will be separate standards and test cycles for tractor engines, vocational diesel engines, and vocational gasoline engines. However, as described in Section II, we are adopting a revised test cycle for tractor engines to better reflect actual in-use operation. After consideration of comments, including those specifically addressing whether the agencies should adopt an alternative with accelerated stringency targets, the agencies are adopting engine standards that can generally be characterized as more stringent than the proposed alternative. 
Specifically, for diesel tractor engines, 
the agencies are adopting standards for MY 2027 that are more stringent than the preferred alternative from the proposal, and require reductions in CO
2 
emissions and fuel consumption that are 5.1 percent better than the 2017 baseline for tractor engines.
75We are also 
adopting standards for MY 2021 and MY 2024, requiring reductions in CO 2 
emissions and fuel consumption of 1.8 to 4.2 percent better than the 2017 baseline tractor engines. For vocational diesel engines, the new standards will require reductions of 2.3, 3.6, and 4.2 percent in MYs 2021, 2024, and 2027, respectively. These levels are more stringent than the proposed standards for these same MYs, and approximately as stringent in MY 2021 and MY 2024 as the Alternative 4 standards discussed at proposal.
76 
The agencies project that these 
reductions will be maximum feasible and reasonable for diesel engines based on technological changes that will improve combustion and reduce energy losses. For most of these improvements, the agencies project (i.e., the agencies have set out a potential, but by no means mandatory, compliance path) that manufacturers will begin applying improvements to about 45 percent of their heavy-duty engines by 2021, and ultimately apply them to about 95 percent of their heavy-duty engines by 2024. However, for some of these improvements we project more limited application rates. In particular, we project a more limited use of waste exhaust heat recovery systems in 2027, projecting that about 10 percent of 
tractor engines will have turbo- compounding systems, and an additional 25 percent of tractor engines will employ Rankine-cycle waste heat recovery. We do not project that turbo- compounding or Rankine-cycle waste heat recovery technology will be utilized in vocational engines due to vocational vehicle drive cycles under which these technologies would not show significant benefit, and also due to low sales volumes, limiting the ability to invest in newer technologies for these vehicles. 
As described in Section III.D.(1)(b)(i), 
the agencies project that some engine manufacturers will be able to achieve larger reductions for at least some of their tractor engines. So in developing the tractor vehicle standards, we 
projected slightly better fuel efficiency for the average tractor engine than is 
required by the engine standards. We are projecting that similar over- compliance will occur for heavy heavy- duty vocational engines. 
For gasoline vocational engines, we 
are not adopting more stringent engine standards. Gasoline engines used in 
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77Although the agencies are adopting new engine 
standards with separate engine certification, engine 
improvements will also be reflected in the vehicle certification process. Thus, it is appropriate to also consider engine improvements in the context of the vehicle standards. vocational vehicles are generally the 
same engines as are used in the complete HD pickups and vans in the Class 2b and 3 weight categories, although the operational demands of vocational vehicles often require use of the largest, most powerful SI engines, so that some engines fitted in complete pickups and vans are not appropriate for use in vocational vehicles. Given the relatively small sales volumes for gasoline-fueled vocational vehicles, manufacturers typically cannot afford to invest significantly in developing separate technology for these vocational vehicle engines. Thus, we project that in general, vocational gasoline engines will incorporate much of the technology that will be used to meet the pickup and van chassis standards, and this will result in some real world reductions in CO
2 emissions and fuel consumption. The agencies received many comments suggesting that technologies be applied to increase the stringency of the SI engine standard, which technologies in fact are already presumed to be adopted at 100 percent to meet the MY 2016 engine standard. The commenters did not identify any additional engine technologies that are not already fully considered by the agencies in setting the MY 2016 engine standard, that could be recognized over the HD SI Engine FTP test cycle. We did, however, consider some additional technologies recommended by commenters, which can be recognized over the GEM vehicle cycles. As a result, the Phase 2 vehicle standards for gasoline-fueled vocational vehicles are predicated on adoption of engine technologies beyond what is required to meet the separate engine 
standard, those additional technologies being advanced engine friction reduction and cylinder deactivation. As described in Section V, we are projecting these technologies to improve fuel consumption over the GEM cycles by nearly one percent in MY 2021, MY 2024, and MY 2027. In other words, this improvement is reflected in the vehicle standards rather than in the engine standards. To the extent any SI engines do not incorporate the projected engine technologies, manufacturers of gasoline- fueled vocational vehicles would need to achieve equivalent reductions from some other technology to meet the GEM- based vehicle standards. The engine standards are summarized in Table I–4. 
TABLE I–4—S UMMARY OF PHASE 1 ANDPHASE 2 REQUIREMENTS FOR ENGINES IN COMBINATION TRACTORS AND  
VOCATIONAL VEHICLES  
Phase 1 program Final 2027 standards 
Covered in this category ...... Engines installed in tractors and vocational chassis. 
Share of HDV fuel consump-
tion and GHG emissions.Combination tractors and vocational vehicles account for approximately 85 percent of fuel use and GHG emis-
sions in the heavy duty truck sector. 
Per vehicle fuel consumption 
and CO 2improvement.5%–9% improvement over MY 2010 baseline, depend-
ing vehicle application. Improvements are in addition to improvements from tractor and vocational vehicle standards.4%–5% improvement over MY 2017 for diesel engines. 
Note that improvements are captured in complete ve-hicle tractor and vocational vehicle standards, so that engine improvements and the vehicle improvement shown below are not additive. 
Form of the standard ........... EPA: CO 2grams/horsepower-hour and NHTSA: Gallons of fuel/horsepower-hour. 
Example technology options 
available to help manufac-turers meet standards.Combustion, air handling, friction and emissions after- 
treatment technology improvements.Further technology improvements and increased use of 
all Phase 1 technologies, plus waste heat recovery systems for tractor engines (e.g., turbo-compound and Rankine-cycle). 
Flexibilities ............................ ABT program which allows emissions and fuel con-
sumption credits to be averaged, banked, or traded (five year credit life). Manufacturers allowed to carry- forward credit deficits for up to three model years. In-terim incentives for advanced technologies, recogni-tion of innovative (off-cycle) technologies not ac-counted for by the HD Phase 1 test procedures, and credits for certifying early.Same ABT and off-cycle program as Phase 1. Adjustment factor of 1.36 for credits carried forward 
from Phase 1 to Phase 2 for SI and LHD CI engines due to change in useful life. 
Revised multipliers for Phase 2 advanced technologies. No Phase 2 early credit multipliers. 
(b) Summary of the Tractor Standards 
As explained in Section III, the 
agencies will largely continue the 
structure of the Phase 1 tractor program, but adopt new standards and update test procedures, as summarized in Table I– 6. The tractor standards for MY 2027 will achieve up to 25 percent lower CO
2 
emissions and fuel consumption than a 2017 model year Phase 1 tractor. The agencies project that the 2027 tractor standards could be met through improvements in the: •Engine
77(including some use of 
waste heat recovery systems) 
•Transmission 
•Driveline 
•Aerodynamic design 
•Tire rolling resistance 
•Idle performance 
•Other accessories of the tractor. 
The agencies have enhanced the 
Phase 2 GEM vehicle simulation tool to 
recognize these technologies, as described in Section II.C. The agencies’ 
evaluation shows that some of these technologies are available today, but have very low adoption rates on current vehicles, while others will require some lead time for development and deployment. In addition to the proposed 
alternative for tractors, the agencies solicited comment on an alternative that reached similar ultimate stringencies, but at an accelerated pace. 
We have also determined that there is 
sufficient lead time to introduce many of these tractor and engine technologies into the fleet at a reasonable cost starting in the 2021 model year. The 
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2021 model year standards for 
combination tractors and engines will achieve up to 14 percent lower CO
2 
emissions and fuel consumption than a 2017 model year Phase 1 tractor, the 2024 model year standards will achieve up to 20 percent lower CO
2emissions and fuel consumption, and as already noted, the 2027 model year standards will achieve up to 25 percent lower CO
2 
emissions and fuel consumption. 
In addition to the CO 2emission 
standards for tractors, EPA is adopting new particulate matter (PM) standards which effectively limit which diesel 
fueled auxiliary power units (APUs) can be used as emission control devices to reduce main engine idling in tractors, as shown in Table I–5. Additional details are discussed in Section III.C.3. 
TABLE I–5—PM S TANDARDS RELATED TO DIESEL APU S 
Tractor MY PM emission 
standard 
(g/kW-hr) Expected control technology 
2018–2023 ................................................................................ 0.15 In-cylinder PM control. 
2024 .......................................................................................... 0.02 DPF. 
TABLE I–6—S UMMARY OF PHASE 1 ANDPHASE 2 REQUIREMENTS FOR CLASS 7 ANDCLASS 8 COMBINATION TRACTORS  
Phase 1 program Final 2027 standards 
Covered in this category ...... Tractors that are designed to pull trailers and move freight. 
Share of HDV fuel consump-
tion and GHG emissions.Combination tractors and their engines account for approximately sixty percent of fuel use and GHG emissions in 
the heavy duty vehicle sector. 
Per vehicle fuel consumption 
and CO 2improvement.10%–23% improvement over MY 2010 baseline, de-
pending on tractor category. Improvements are in ad-dition to improvements from engine standards.19%–25% improvement over tractors meeting the MY 
2017 standards. 
Form of the standard ........... EPA: CO 2grams/ton payload mile and NHTSA: Gallons of fuel/1,000 ton payload mile. 
Example technology options 
available to help manufac-turers meet standards.Aerodynamic drag improvements; low rolling resistance 
tires; high strength steel and aluminum weight reduc-tion; extended idle reduction; and speed limiters.Further technology improvements and increased use of 
all Phase 1 technologies, plus engine improvements, improved transmissions and axles, tire pressure sys-tems, and predictive cruise control (depending on tractor type). 
Flexibilities ............................ ABT program which allows emissions and fuel con-
sumption credits to be averaged, banked, or traded (five year credit life). Manufacturers allowed to carry- forward credit deficits for up to three model years. In-terim incentives for advanced technologies, recogni-tion of innovative (off-cycle) technologies not ac-counted for by the HD Phase 1 test procedures, and credits for certifying early.Same ABT and off-cycle program as Phase 1. Revised multipliers for Phase 2 advanced technologies. 
(c) Summary of the Trailer Standards 
The final rules contain a set of GHG 
emission and fuel consumption 
standards for manufacturers of new trailers that are used in combination with tractors. These standards will significantly reduce CO
2and fuel 
consumption from combination tractor- trailers nationwide over a period of several years. As described in Section IV, there are numerous aerodynamic and tire technologies available to manufacturers to achieve these 
standards. Many of these technologies have already been introduced into the market through EPA’s voluntary SmartWay program and California’s tractor-trailer greenhouse gas requirements. The agencies are adopting Phase 2 
standards that will phase-in beginning 
in MY 2018 and be fully phased-in by 2027. These standards are predicated on use of aerodynamic and tire improvements, with trailer OEMs making incrementally greater improvements in MYs 2021 and 2024 as standard stringency increases in each of those model years. EPA’s GHG emission 
standards will be mandatory beginning in MY 2018, while NHTSA’s fuel consumption standards will be voluntary beginning in MY 2018, and be mandatory beginning in MY 2021. In general, the trailer standards being finalized apply only for box vans, flatbeds, tankers, and container chassis. 
As described in Section XIV.D and 
Chapter 12 of the RIA, the agencies are adopting special provisions to minimize 
the impacts on small business trailer manufacturers. These provisions have been informed by and are largely consistent with recommendations from the SBAR Panel that EPA conducted pursuant to section 609(b) of the Regulatory Flexibility Act (RFA). Broadly, these provisions provide additional lead time for small business manufacturers, as well as simplified testing and compliance requirements. The agencies also are not finalizing standards for various trailer types, including most specialty types of non- box trailers. Excluding these specialty trailers also reduces the impacts on small businesses. 
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TABLE I–7—S UMMARY OF PHASE 2 REQUIREMENTS FOR TRAILERS  
Phase 1 program Final 2027 standards 
Covered in this category ......................... All lengths of dry vans, refrigerated vans, tanks, flatbeds, and container chassis hauled by low, mid, 
and high roof day and sleeper cab tractors. 
Share of HDV fuel consumption and 
GHG emissions.Trailers are modeled together with combination tractors and their engines. Together, they account for 
approximately sixty percent of fuel use and GHG emissions in the heavy duty truck sector. 
Per vehicle fuel consumption and CO 2 
improvement.N/A ......................... Between 3% and 9% improvement over MY 2018 baseline, depending on the 
trailer type. 
Form of the standard .............................. N/A ......................... EPA: CO 2grams/ton payload mile and NHTSA: Gallons/1,000 ton payload mile. 
Example technology options available to 
help manufacturers meet standards.N/A ......................... Low rolling resistance tires and tire pressure systems for most trailers, plus 
weight reduction and aerodynamic improvements such as side and rear fair-ings, gap closing devices, and undercarriage treatment for box vans ( e.g., 
dry and refrigerated). 
Flexibilities ............................................... N/A ......................... One year delay in implementation for small businesses, trailer manufacturers 
may use pre-approved aerodynamic data in lieu of additional testing, aver-aging program available in MY 2027 for manufacturers of dry and refrig-erated box vans. 
(d) Summary of the Vocational Vehicle 
Standards 
As explained in Section V, the 
agencies are adopting new vocational vehicle standards that expand upon the Phase 1 Program. These new standards reflect further subcategorization from Phase 1, with separate standards based on mode of operation: Urban, regional, and multi-purpose. The agencies are also adopting optional separate standards for emergency vehicles and other custom chassis vehicles. 
The agencies project that the 
vocational vehicle standards could be met through improvements in the engine, transmission, driveline, lower rolling resistance tires, workday idle reduction technologies, weight reduction, and some application of hybrid technology. These are described in Section V of this Preamble and in Chapter 2.9 of the RIA. These MY 2027 standards will achieve up to 24 percent lower CO
2emissions and fuel 
consumption than MY 2017 Phase 1 standards. The agencies are also making revisions to the compliance program for vocational vehicles. These include: The addition of two idle cycles that will be weighted along with the other drive cycles for each vocational vehicle; and revisions to Phase 2 GEM to recognize improvements to the engine, transmission, and driveline. 
Similar to the tractor program, we 
have determined that there is sufficient lead time to introduce many of these new technologies into the fleet starting in MY 2021. Therefore, we are adopting new standards for MY 2021 and 2024. Based on our analysis, the MY 2021 standards for vocational vehicles will achieve up to 12 percent lower CO
2 
emissions and fuel consumption than a MY 2017 Phase 1 vehicle, on average, and the MY 2024 standards will achieve up to 20 percent lower CO
2emissions 
and fuel consumption. 
In Phase 1, EPA adopted air 
conditioning (A/C) refrigerant leakage standards for tractors, as well as for heavy-duty pickups and vans, but not for vocational vehicles. For Phase 2, EPA believes that it will be feasible to apply similar A/C refrigerant leakage standards for vocational vehicles, beginning with the 2021 model year. The certification process for vocational vehicles to certify low-leakage A/C components is identical to that already required for tractors. 
TABLE I–8—S UMMARY OF PHASE 1 ANDPHASE 2 REQUIREMENTS FOR VOCATIONAL VEHICLE CHASSIS  
Phase 1 program Final 2027 standard 
Covered in this category ...... Class 2b—8 chassis that are intended for vocational services such as delivery vehicles, emergency vehicles, 
dump truck, tow trucks, cement mixer, refuse trucks, etc., except those qualified as off-highway vehicles. 
Because of sector diversity, vocational vehicle chassis are segmented into Light, Medium and Heavy Heavy-Duty 
vehicle categories and for Phase 2 each of these segments are further subdivided using three duty cycles: Re-gional, Multi-purpose, and Urban. 
Share of HDV fuel consump-
tion and GHG emissions.Vocational vehicles account for approximately 17 percent of fuel use and GHG emissions in the heavy duty truck sector categories. 
Per vehicle fuel consumption 
and CO 2improvement.2% improvement over MY 2010 baseline. Improve-
ments are in addition to improvements from engine standards.Up to 24% improvement over MY 2017 standards. 
Form of the standard ........... EPA: CO 2grams/ton payload mile and NHTSA: Gallons of fuel/1,000 ton payload mile. 
Example technology options 
available to help manufac-turers meet standards.Low rolling resistance tires ............................................. Further technology improvements and increased use of 
Phase 1 technologies, plus improved engines, trans-missions and axles, weight reduction, hybrids, and workday idle reduction systems. 
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TABLE I–8—S UMMARY OF PHASE 1 ANDPHASE 2 REQUIREMENTS FOR VOCATIONAL VEHICLE CHASSIS —Continued 
Phase 1 program Final 2027 standard 
Flexibilities ............................ ABT program which allows emissions and fuel con-
sumption credits to be averaged, banked, or traded 
(five year credit life). Manufacturers allowed to carry- forward credit deficits for up to three model years. In-terim incentives for advanced technologies, recogni-tion of innovative (off-cycle) technologies not ac-counted for by the HD Phase 1 test procedures, and credits for certifying early.Same ABT and off-cycle program as Phase 1. Adjust-
ment factor of 1.36 for credits carried forward from Phase 1 to Phase 2 due to change in useful life. 
Revised multipliers for Phase 2 advanced technologies. No Phase 2 early credit multipliers. Chassis intended for emergency vehicles, cement mix-
ers, coach buses, school buses, transit buses, refuse trucks, and motor homes may optionally use applica-tion-specific Phase 2 standards using a simplified version of GEM. 
(e) Summary of the Heavy-Duty Pickup 
and Van Standards 
The agencies are adopting new Phase 
2 GHG emission and fuel consumption standards for heavy-duty pickups and vans that will be applied in largely the 
same manner as the Phase 1 standards. These standards are based on the extensive use of most known and proven technologies, and could result in some use of mild or strong hybrid powertrain technology. These standards 
will commence in MY 2021. By 2027, these standards are projected to be 16 percent more stringent than the 2018– 2019 standards. 
TABLE I–9—S UMMARY OF PHASE 1 ANDPHASE 2 REQUIREMENTS FOR HD P ICKUPS AND VANS 
Phase 1 program Final 2027 standard 
Covered in this category ...... Class 2b and 3 complete pickup trucks and vans, including all work vans and 15-passenger vans but excluding 
12-passenger vans which are subject to light-duty standards. 
Share of HDV fuel consump-
tion and GHG emissions.HD pickups and vans account for approximately 23% of fuel use and GHG emissions in the heavy duty truck sec-
tor. 
Per vehicle fuel consumption 
and CO 2improvement.15% improvement over MY 2010 baseline for diesel ve-
hicles, and 10% improvement for gasoline vehicles.16% improvement over MY 2018–2019 standards. 
Form of the standard ........... Phase 1 standards are based upon a ‘‘work factor’’ attribute that combines truck payload and towing capabilities, 
with an added adjustment for 4-wheel drive vehicles. There are separate target curves for diesel-powered and gasoline-powered vehicles. The Phase 2 standards are based on the same approach. 
Example technology options 
available to help manufac-turers meet standards.Engine improvements, transmission improvements, aer-
odynamic drag improvements, low rolling resistance tires, weight reduction, and improved accessories.Further technology improvements and increased use of 
all Phase 1 technologies, plus engine stop-start, and powertrain hybridization (mild and strong). 
Flexibilities ............................ Two optional phase-in schedules; ABT program which 
allows emissions and fuel consumption credits to be averaged, banked, or traded (five year credit life). Manufacturers allowed to carry-forward credit deficits for up to three model years. Interim incentives for ad-vanced technologies, recognition of innovative (off- cycle) technologies not accounted for by the HD Phase 1 test procedures, and credits for certifying early.Same as Phase 1, with phase-in schedule based on 
year-over-year increase in stringency. Same ABT and off-cycle program as Phase 1. Adjustment factor of 1.25 for credits carried forward from Phase 1 to Phase 2 due to change in useful life. 
Revised multipliers for Phase 2 advanced technologies. No Phase 2 early credit multipliers. 
Similar to Phase 1, the agencies are 
adopting for Phase 2 a set of continuous 
equation-based standards for HD pickups and vans. Please refer to Section VI for a description of these standards, including associated tables and figures. 
D. Summary of the Costs and Benefits of 
the Final Rules 
This section summarizes the projected 
costs and benefits of the NHTSA fuel consumption and EPA GHG emission standards. See Sections VII through IX and the RIA for additional details about these projections. For these rules, the agencies used two 
analytical methods for the heavy-duty 
pickup and van segment by employing both DOT’s CAFE model and EPA’s MOVES model. The agencies used EPA’s MOVES model to estimate fuel consumption and emissions impacts for tractor-trailers (including the engine that powers the tractor), and vocational vehicles (including the engine that powers the vehicle). Additional calculations were performed to determine corresponding monetized program costs and benefits. For heavy- duty pickups and vans, the agencies performed separate analyses, which we refer to as ‘‘Method A’’ and ‘‘Method B.’’ In Method A, a new version of the CAFE model was used to project a pathway the industry could use to comply with each regulatory alternative and the estimated effects on fuel consumption, emissions, benefits and costs. In Method B, the CAFE model from the NPRM was used to project a pathway the industry could use to comply with each regulatory alternative, along with resultant impacts on per-vehicle costs. However, the MOVES model was used to calculate corresponding changes in total fuel consumption and annual emissions for pickups and vans in Method B. Additional calculations were performed to determine corresponding 
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monetized program costs and benefits. 
NHTSA considered Method A as its central analysis and Method B as a supplemental analysis. EPA considered the results of Method B. The agencies concluded that these methods led the agencies to the same conclusions and the same selection of these standards. See Section VII for additional discussion of these two methods. 
(1) Reference Case Against Which Costs 
and Benefits Are Calculated 
The No Action Alternatives for 
today’s analysis, alternatively referred to as the ‘‘baselines’’ or ‘‘reference cases,’’ assume that the agencies did not issue new rules regarding MD/HD fuel efficiency and GHG emissions. These are the baselines against which costs and benefits for these standards are calculated. The reference cases assume that model year 2018 engine, tractor, vocational vehicle, and HD pickup and van standards will be extended indefinitely and without change. They also assume that no new standards would be adopted for trailers. 
The agencies recognize that if these 
Phase 2 standards had not been adopted, manufacturers would nevertheless continue to introduce new heavy-duty vehicles in a competitive market that responds to a range of factors, and manufacturers might have continued to improve technologies to reduce heavy-duty vehicle fuel consumption. Thus, as described in Section VII, both agencies fully analyzed these standards and the regulatory alternatives against two reference cases. The first case uses a baseline that projects no improvement in new vehicles in the absence of new Phase 2 standards, and the second uses a more dynamic baseline that projects some significant improvements in vehicle fuel efficiency. NHTSA considered its primary analysis to be 
based on the dynamic baseline, where certain cost-effective technologies are assumed to be applied by manufacturers to improve fuel efficiency beyond the Phase 1 requirements in the absence of new Phase 2 standards. EPA considered both reference cases. The results for all of the regulatory alternatives relative to both reference cases, derived via the same methodologies discussed in this section, are presented in Section X of the Preamble. 
The agencies received limited 
comments on these reference cases. Some commenters expressed support for a flat baseline in the context of the need for the regulations, arguing that little improvement would occur without the regulations. Others supported the less dynamic baseline because they believe it more fully captures the costs. A number of commenters expressed that purchasers are willing to and do pay for fuel efficiency improving technologies, provided the cost for the technology is paid back through fuel savings within a certain period of time; this is the premise for a dynamic baseline. Some commenters thought it reasonable that the agencies consider both baselines given the uncertainty in this area. No commenters opposed the consideration of both baselines. 
The agencies have continued to 
analyze two different baselines for the final rules because we recognize that there are a number of factors that create uncertainty in projecting a baseline against which to compare the future effects of this action and the remaining alternatives. The composition of the future fleet—such as the relative position of individual manufacturers and the mix of products they each offer—cannot be predicted with certainty at this time. Additionally, the heavy-duty vehicle market is diverse, as is the range of vehicle purchasers. Heavy-duty vehicle manufacturers have reported that their customers’ purchasing decisions are influenced by their customers’ own determinations of minimum total cost of ownership, which can be unique to a particular customer’s circumstances. For example, some customers (e.g., less-than- 
truckload or package delivery operators) operate their vehicles within a limited geographic region and typically own their own vehicle maintenance and repair centers within that region. These operators tend to own their vehicles for long time periods, sometimes for the entire service life of the vehicle. Their total cost of ownership is influenced by their ability to better control their own maintenance costs, and thus they can afford to consider fuel efficiency technologies that have longer payback periods, outside of the vehicle manufacturer’s warranty period. Other customers (e.g., truckload or long-haul 
operators) tend to operate cross-country, and thus must depend upon truck dealer service centers for repair and maintenance. Some of these customers tend to own their vehicles for about four to seven years, so that they typically do not have to pay for repair and maintenance costs outside of either the manufacturer’s warranty period or some other extended warranty period. Many of these customers tend to require seeing evidence of fuel efficiency technology payback periods on the order of 18 to 24 months before seriously considering evaluating a new technology for potential adoption within their fleet (NAS 2010, Roeth et 
al. 2013, and Klemick et al. 2014). Purchasers of HD pickups and vans wanting better fuel efficiency tend to demand that fuel consumption improvements pay back within approximately one to three years, but some HD pickup and van owners accrue relatively few vehicle miles traveled per year, such that they may be less likely to adopt new fuel efficiency technologies, while other owners who use their vehicle(s) with greater intensity may be even more willing to pay for fuel efficiency improvements. Regardless of the type of customer, their determination of minimum total cost of ownership involves the customer balancing their own unique circumstances with a heavy-duty vehicle’s initial purchase price, availability of credit and lease options, expectations of vehicle reliability, resale value and fuel efficiency technology payback periods. The degree of the incentive to adopt additional fuel efficiency technologies also depends on customer expectations of future fuel prices, which directly impacts customer payback periods. Purchasing decisions are not based exclusively on payback period, but also include the considerations discussed above and in Section X.A.1. For the baseline analysis, the agencies use payback period as a proxy for all of these considerations, and therefore the payback period for the baseline analysis is shorter than the payback period industry uses as a threshold for the further consideration of a technology. See Section X.A.1 of this Preamble and Chapter 11 of the RIA for a more detailed discussion of baselines. As part of a sensitivity analysis, additional baseline scenarios were also evaluated for HD pickups and vans, including baseline payback periods of 12, 18 and 24 months. See Section VI of this Preamble and Chapter 10 of the RIA for a detailed discussion of these additional scenarios. 
(2) Costs and Benefits Projected for the 
Phase 2 Standards 
The tables below summarize the 
benefits and costs for the program in 
two ways: First, from the perspective of a program designed to improve the Nation’s energy security and to conserve energy by improving fuel efficiency and then from the perspective of a program designed to reduce GHG emissions. The individual categories of benefits and costs presented in the tables below are defined more fully and presented in more detail in Chapter 8 of the RIA. 
Lifetime fuel savings, GHG 
reductions, benefits, costs and net benefits for model years 2018 through 
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2029 vehicles as presented below. This 
is consistent with the NPRM analysis and allows readers to compare the costs and benefits of the final program with those projected for the NPRM. It also includes for modeling purposes at least three model years for each standard. Table I–10 shows benefits and costs 
for these standards from the perspective of a program designed to improve the Nation’s energy security and conserve energy by improving fuel efficiency. From this viewpoint, technology costs occur when the vehicle is purchased. Fuel savings are counted as benefits that 
occur over the lifetimes of the vehicles produced during the model years subject to the Phase 2 standards as they consume less fuel. 
TABLE I–10—L IFETIME FUELSAVINGS , GHG R EDUCTIONS , BENEFITS , COSTS , ANDNETBENEFITS FOR MODEL YEARS  
2018–2029 V EHICLES USING ANALYSIS METHOD A 
[Billions of 2013$]ab 
Category 3% discount rate 7% discount rate 
Fuel Reductions (Billion Gallons) .............................................................................................. .............. 71.1–77.7 
GHG reductions (MMT CO 2eq) .............................................................................................................. 959–1049 
Vehicle Program: Technology and Indirect Costs, Normal Profit on Additional Investments ................. 23.7 to 24.4 16.1 to 16 .6 
Additional Routine Maintenance .............................................................................................................. 1.7 to 1.7 0.9 to 0.9 
Congestion, Crashes, Fatalities and Noise from Increased Vehicle Used............................................. 3.1 to 3.2 1.8 to 1.9 
Total Costs ....................................................................................................................................... 28.5 to 29.3 18.8 to 19.4 
Fuel Savings (valued at pre-tax prices) .................................................................................................. 149.1 to 163.0 79.7 to 87.0 
Savings from Less Frequent Refueling ................................................................................................... 3.0 to 3.2 1.6 to 1.7 
Economic Benefits from Additional Vehicle Use ..................................................................................... 5.4 to 5.5 3.4 to 3.5 
Reduced Climate Damages from GHG Emissionsc............................................................................... 33.0 to 36.0 
Reduced Health Damages from Non-GHG Emissions ........................................................................... 27.1 to 30.0 14.6 to 16.1 
Increased U.S. Energy Security .............................................................................................................. 7.3 to 7.9 3.9 to 4.2 
Total Benefits .................................................................................................................................... 225 to 246 136 to 149 
Net Benefits ...................................................................................................................................... 197 to 216 117 to 129 
Notes: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
bRange reflects two reference case assumptions 1a and 1b. 
cBenefits and net benefits use the 3 percent global average SCC value applied only to CO 2emissions; GHG reductions include CO 2, CH 4, 
N2O and HFC reductions, and include benefits to other nations as well as the U.S. See Draft RIA Chapter 8.5 and Preamble Section IX.G for fur-
ther discussion. 
d‘‘Congestion, Crashes, Fatalities and Noise from Increased Vehicle Use’’ includes NHTSA’s monetized value of estimated reductions in the 
incidence of highway fatalities associated with mass reduction in HD pickup and vans, but this does not include these reductions from tractor- 
trailers or vocational vehicles. This likely results in a conservative overestimate of these costs. 
Table I–11 shows benefits and cost 
from the perspective of reducing GHG. 
As shown below in terms of MY lifetime GHG reductions, and in RIA Chapter 5 in terms of year-by-year GHG reductions, the final program is expected to reduce more GHGs over the long run than the proposed program. In general, the greater reductions can be attributed to increased market penetration and effectiveness of key technologies, based on new data and comments, leading to increases in 
stringency such as with the diesel engine standards (Section I.C.(2)(a) above). 
TABLE I–11—L IFETIME FUELSAVINGS , GHG R EDUCTIONS , BENEFITS , COSTS AND NETBENEFITS FOR MODEL YEARS  
2018–2029 V EHICLES USING ANALYSIS METHOD B 
[Billions of 2012$]ab 
Category 3% discount rate 7% discount rate 
Fuel Reductions (Billion Gallons) .............................................................................................. .............. 73–82 
GHG reductions (MMT CO 2eq) ............................................................................................................... 976–1,098 
Vehicle Program (e.g., technology and indirect costs, normal profit on additional investments) ........... ¥$26.5 to ¥$26.2 ¥$17.6 to ¥$17.4 
Additional Routine Maintenance ................................................................................................. ............. ¥$1.9 to ¥$1.9 ¥$1.0 to ¥$1.0 
Fuel Savings (valued at pre-tax prices) .................................................................................................. $149.3 to $169.1 $76.8 to $87.2 
Energy Security ....................................................................................................................................... $6.9 to $7.8 $3.5 to $4.0 
Congestion, Crashes, and Noise from Increased Vehicle Use ............................................................... ¥$3.2 to ¥$3.2 ¥$1.8 to ¥$1.8 
Savings from Less Frequent Refueling ................................................................................................... $3.4 to $4.0 $1.8 to $2.1 
Economic Benefits from Additional Vehicle Use ..................................................................................... $10.4 to $10.5 $5.7 to $5.7 
Benefits from Reduced Non-GHG Emissionsc....................................................................................... $28.3 to $31.9 $13.4 to $15.0 
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TABLE I–11—L IFETIME FUELSAVINGS , GHG R EDUCTIONS , BENEFITS , COSTS AND NETBENEFITS FOR MODEL YEARS  
2018–2029 V EHICLES USING ANALYSIS METHOD B—Continued 
[Billions of 2012$]ab 
Category 3% discount rate 7% discount rate 
Reduced Climate Damages from GHG Emissionsd............................................................................... $33.0 to $37.2 
Net Benefits ...................................................................................................................................... $200 to $229 $114 to $131 
Notes: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
bRange reflects two baseline assumptions 1a and 1b. 
cRange reflects both the two baseline assumptions 1a and 1b using the mid-point of the low and high $/ton estimates for calculating benefits. 
dBenefits and net benefits use the 3 percent average directly modeled SC–GHG values applied to direct reductions of CO 2, CH 4and N 2O 
emissions; GHG reductions include CO 2, CH 4and N 2O reductions. 
Table I–12 breaks down by vehicle 
category the benefits and costs for these standards using the Method A analytical 
approach. For additional detail on per- vehicle break-downs of costs and benefits, please see RIA Chapter 10. 
TABLE I–12—P ERVEHICLE CATEGORY LIFETIME FUELSAVINGS , GHG R EDUCTIONS , BENEFITS , COSTS AND NETBENE-
FITS FOR MODEL YEARS 2018–2029 V EHICLES USING ANALYSIS METHOD A (B ILLIONS OF 2013$), R ELATIVE TO  
BASELINE 1ba 
Key costs and benefits by vehicle category 3% discount rate 7% discount rate 
Tractors, Including Engines, and Trailers 
Fuel Reductions (Billion Gallons) .............................................................................................. .............. 50 
GHG Reductions (MMT CO 2eq) ............................................................................................................ 685 
Total Costs .................................................................................................................... ........................... 13.8 9.0 
Total Benefits ................................................................................................................. .......................... 161.0 96.8 
Net Benefits ................................................................................................................... .......................... 147.2 85.5 
Vocational Vehicles, Including Engines 
Fuel Reductions (Billion Gallons) .............................................................................................. .............. 12 
GHG Reductions (MMT CO 2eq) ............................................................................................................ 162 
Total Costs .................................................................................................................... ........................... 7.3 4.8 
Total Benefits ................................................................................................................. .......................... 37.8 22.7 
Net Benefits ................................................................................................................... .......................... 30.5 15.3 
HD Pickups and Vans 
Fuel Reductions (Billion Gallons) .............................................................................................. .............. 10 
GHG Reductions (MMT CO 2eq) ............................................................................................................ 111 
Total Costs .................................................................................................................... ........................... 7.4 5.1 
Total Benefits ................................................................................................................. .......................... 26.0 16.7 
Net Benefits ................................................................................................................... .......................... 18.6 11.6 
Notes: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE I–13—P ERVEHICLE COSTS , USING METHOD A (2013$), R ELATIVE TO BASELINE 1b 
MY 2021 MY 2024 MY 2027 
Per Vehicle Cost ($):a 
Tractors ....................................................................................................................... .......... $6,400 $9,920 $12,160 
Trailers ....................................................................................................................... ........... 850 1,000 1,070 
Vocational Vehicles ............................................................................................................ .. 1,110 2,020 2,660 
Pickups/Vans ................................................................................................................... ..... 750 760 1,340 
Note: 
aPer vehicle costs include new engine and vehicle technology only; costs associated with increased insurance, taxes and maintenance are in-
cluded in the payback period values. 
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78This EISA requirement applies to regulation of 
medium- and heavy-duty vehicles. For many years, 
and as reaffirmed by Congress in 2007, ‘‘economic practicability’’ has been among the factors EPCA requires NHTSA to consider when setting light-duty fuel economy standards at the (required) maximum feasible levels. NHTSA interprets ‘‘economic practicability’’ as a factor involving considerations broader than those likely to be involved in ‘‘cost effectiveness.’’ 
79As described in Section IX.G, the social cost of 
carbon is a metric that estimates the monetary value 
of impacts associated with marginal changes in CO 2 
emissions in a given year. TABLE I–14—P ERVEHICLE COSTS USING METHOD B R ELATIVE TO BASELINE 1a 
MY 2021 MY 2024 MY 2027 
Per Vehicle Cost ($):a 
Tractors ....................................................................................................................... .......... $6,484 $10,101 $12,442 
Trailers ....................................................................................................................... ........... 868 1,033 1,108 
Vocational Vehicles ............................................................................................................ .. 1,110 2,022 2,662 
Pickups/Vans ................................................................................................................... ..... 524 963 1,364 
Note: 
aPer vehicle costs include new engine and vehicle technology only; costs associated with increased insurance, taxes and maintenance are in-
cluded in the payback period values. 
An important metric to vehicle 
purchasers is the payback period that 
can be expected on any new purchase. In other words, there is greater willingness to pay for new technology if that new technology ‘‘pays back’’ within an acceptable period of time. The agencies make no effort to define the acceptable period of time, but seek to estimate the payback period for others to make the decision themselves. The payback period is the point at which reduced fuel expenditures outpace increased vehicle costs, including increased maintenance, insurance premiums and taxes. The payback periods for vehicles meeting the standards considered for the final year of implementation are shown in Table I–15, and are similar for both Method A and Method B. 
TABLE I–15—P AYBACK PERIODS FOR  
MY 2027 V EHICLES RELATIVE TO  
BASELINE 1a 
[Payback cccurs in the year shown; using 7% 
discounting] 
Tractors/Trailers .................... 2nd. 
Vocational Vehicles ............... 4th. 
Pickups/Vans ........................ 3rd. 
TABLE I–16—P AYBACK PERIODS FOR  
MY 2027 V EHICLES RELATIVE TO  
BASELINE 1b 
[Payback occurs in the year shown; using 7% 
discounting] 
Tractors/Trailers .................... 2nd. 
Vocational Vehicles ............... 4th. 
Pickups/Vans ........................ 3rd. 
(3) Cost Effectiveness 
These regulations implement section 
32902(k) of EISA and section 202(a)(1) and (2) of the Clean Air Act. Through the 2007 EISA, Congress directed 
NHTSA to create a medium- and heavy- duty vehicle fuel efficiency program designed to achieve the maximum feasible improvement by considering appropriateness, cost effectiveness, and technological feasibility to determine maximum feasible standards.
78The 
Clean Air Act requires that any air pollutant emission standards for heavy- duty vehicles and engines take into account the costs of any requisite technology and the lead time necessary to implement such technology. Both agencies considered overall costs, overall benefits and cost effectiveness in developing the Phase 2 standards. Although there are different ways to evaluate cost effectiveness, the essence is to consider some measure of costs relative to some measure of impacts. 
Considering that Congress enacted 
EPCA and EISA to, among other things, address the need to conserve energy, the agencies have evaluated these standards in terms of costs per gallon of fuel conserved. We also considered the similar metric of cost of technology per ton of CO
2e removed, consistent with 
the objective of CAA section 202(a)(1) and (2) to reduce emissions of air pollutants which contribute to air pollution which endangers public health and welfare. As described in the RIA, the agencies also evaluated these standards using the same approaches employed in HD Phase 1. Together, the agencies have considered the following three ratios of cost effectiveness: 
1. Total social costs per gallon of fuel 
conserved 2. Technology costs per ton of GHG 
emissions reduced (CO
2eq) 
3. Technology costs minus fuel savings 
per ton of GHG emissions reduced 
By all three of these measures, the total 
heavy-duty program will be highly cost effective. 
As discussed below, the agencies 
estimate that over the lifetime of heavy- duty vehicles produced for sale in the U.S. during model years 2018–2029, these standards will cost about $30 billion and conserve about 75 billion gallons of fuel, such that the first measure of cost effectiveness will be about 40 cents per gallon. Relative to fuel prices underlying the agencies’ analysis, the agencies have concluded that today’s standards will be cost effective. 
With respect to the second measure, 
which is useful for comparisons to other GHG rules, these standards will have overall $/ton costs similar to the HD Phase 1 rule. As Chapter 7 of the RIA shows, social costs will amount to about $30 per metric ton of GHG (CO
2eq) for 
the entire HD Phase 2 program. This compares well to both the HD Phase 1 rule, which was also estimated to cost about $30 per metric ton of GHG (without fuel savings), and to the agencies’ estimates of the social cost of carbon.
79Thus, even without 
accounting for fuel savings, these standards will be cost-effective. 
The following table include the 
overall per-unit costs of both gallons of fuel conserved and metric tons of GHG emissions abated using both a 3 percent and a 7 percent discount rate. Table I– 16 gives these values under the Method A analysis. 
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TABLE I–17—M ETHOD A C OSTPER-UNIT OF FUELSAVINGS AND GHG E MISSION REDUCTIONS BY VEHICLE CLASS 
[Relative to the dynamic baseline] 
Per-unit costs (2013$/Unit) by vehicle category 3% Discount rate 7% Discount rate 
Tractors, Including Engines, and Trailers 
Cost per Gallon of Fuel Saved .................................................................................................. .............. $0.28 $0.18 
Cost per Ton of GHG Emissions Saved ............................................................................................ ..... 20 13 
Vocational Vehicles, Including Engines 
Cost per Gallon of Fuel Saved .................................................................................................. .............. 0.61 0.40 
Cost per Ton of GHG Emissions Saved ............................................................................................ ..... 45 30 
HD Pickups and Vans 
Cost per Gallon of Fuel Saved .................................................................................................. .............. 0.76 0.52 
Cost per Ton of GHG Emissions Saved ............................................................................................ ..... 67 46 
Total Program 
Cost per Gallon of Fuel Saved .................................................................................................. .............. 0.40 0.26 
Cost per Ton of GHG Emissions Saved ............................................................................................ ..... 30 20 
When considering these values, it is 
important to emphasize two points: 
1. As is shown throughout this 
rulemaking, the Phase 2 standards 
represent the most stringent standards that are technologically feasible and reliably implementable within the lead time provided. 
2. These are not the marginal cost- 
effectiveness values. 
Without understanding these two 
points, some readers might assume that because the tractor-trailer standards are more cost-effective overall than the other standards that manufacturers would choose to over-comply with the more cost-effective tractor or trailer standards and do less for other vehicles. However, the agencies believe this is not 
a technologically feasible option. Because the tractor and trailer standards represent maximum feasible standards, they will effectively require manufacturers to deploy all available technology to meet the standards. The agencies do not project that manufacturers would be able to over- comply with the 2027 standards by a significant margin. 
The third measure deducts fuel 
savings from costs, which also is useful for comparisons to other GHG rules. As 
shown in Table I–18, the agencies have also calculated the cost per metric ton of CO
2e emission reductions including 
the savings associated with reduced fuel consumption. The calculations 
presented here include all engine- related costs but do not include benefits associated with the final program such as those associated with criteria pollutant reductions or energy security benefits (discussed in Chapter 8 of this RIA). On this basis, net costs per ton of GHG emissions reduced will be negative under these standards. This means that the value of the fuel savings will be greater than the technology costs, and there will be a net cost saving for vehicle owners. In other words, the technologies will pay for themselves (indeed, more than pay for themselves) in fuel savings. 
TABLE I–18—A NNUAL NETCOST PER METRIC TON OF CO 2eq E MISSIONS REDUCED IN THE FINAL PROGRAM VS. THE 
FLATBASELINE AND USING METHOD B FORCALENDAR YEAR2030 
[Dollar values are 2013$]a 
Calendar year Vehicle & 
maintenance 
costs 
($billions) Fuel savings 
($billions) GHG reduced 
(MMT) Net cost 
($/metric ton)b 
HDE Pickups and Vans ................................................................................... 1.6 3.9 15 0 
Vocational Vehicles ......................................................................................... 1.5 3.5 14 0 
Tractor-Trailers ................................................................................................ 2.3 16 64 0 
All Vehicles ...................................................................................................... 5.5 23 94 0 
Notes: 
aFor an explanation of analytical Methods A and B, please see the beginning of this Section I.D; for an explanation of the flat baseline, 1a, 
and dynamic baseline, 1b, please see Section X.A.1. GHG reductions include CO 2and CO 2equivalents of CH 4, and N 2O. 
bFor each category, fuel savings exceed cost so there is no net cost per ton of GHG reduced. 
In addition, while the net economic 
benefits (i.e., total benefits minus total 
costs) of these standards is not a 
traditional measure of their cost effectiveness, the agencies have concluded that the total costs of these standards are justified in part by their significant economic benefits. As discussed in the previous subsection and in Section IX, this rule will provide benefits beyond the fuel conserved and GHG emissions avoided. The rule’s net benefits is a measure that quantifies each of its various benefits in economic terms, including the economic value of the fuel it saves and the climate-related damages it avoids, and compares their 
sum to the rule’s estimated costs. The agencies estimate that these standards will result in net economic benefits exceeding $100 billion, making this a highly beneficial program. 
EPA and NHTSA received many 
comments suggesting that more 
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8076 FR 57106–57129, September 15, 2011. stringent standards were feasible 
because many cost effective technologies exist for future vehicle designs. While the agencies agree that many cost effective technologies exist, and indeed, we reflect the potential for many of those technologies to be applied in our analysis for today’s final rule, commenters who focused on the cost-effectiveness of technologies did not consistently recognize certain real- world constraints on technology implementation. Manufacturers and suppliers have limited research and development capacities, and although they have some ability to expand (by adding staff or building new facilities), the process of developing and applying new technologies is inherently constrained by time. Adequate lead time is also necessary to complete durability, reliability, and safety testing and ramp up production to levels that might be necessary to meet future standards. If the agencies fail to account for lead time needs in determining the stringency of the standards, we could create unintended consequences, such as technologies that are applied before they are ready and lead to maintenance and repair problems. In addition to cost- effectiveness, then, lead time constraints can also be highly relevant to feasibility of more stringent standards. 
E. EPA and NHTSA Statutory 
Authorities 
This section briefly summarizes the 
respective statutory authority for EPA and NHTSA to promulgate the Phase 1 and Phase 2 programs. For additional details of the agencies’ authority, see Section XV of this document as well as the Phase 1 rule.
80 
(1) EPA Authority 
Statutory authority for the emission 
standards in this rule is found in CAA section 202(a)(1) and (2) (which requires EPA to establish standards for emissions of pollutants from new motor vehicles and engines which emissions cause or contribute to air pollution which may 
reasonably be anticipated to endanger public health or welfare), and in CAA sections 202(a)(3), 202(d), 203–209, 216, and 301 (42 U.S.C. 7521 (a)(1) and (2), 7521(d), 7522–7543, 7550, and 7601). 
Title II of the CAA provides for 
comprehensive regulation of mobile sources, authorizing EPA to regulate emissions of air pollutants from all mobile source categories. When acting under Title II of the CAA, EPA considers such issues as technology effectiveness, its cost (both per vehicle, per manufacturer, and per consumer), the lead time necessary to implement the technology, and based on this the feasibility and practicability of potential standards; the impacts of potential standards on emissions reductions of both GHGs and non-GHG emissions; the impacts of standards on oil conservation and energy security; the impacts of standards on fuel savings by customers; the impacts of standards on the truck industry; other energy impacts; as well as other relevant factors such as impacts on safety. 
This action implements a specific 
provision from Title II, section 202(a). Section 202(a)(1) of the CAA states that 
‘‘the Administrator shall by regulation prescribe (and from time to time revise) . . . standards applicable to the emission of any air pollutant from any class or classes of new motor vehicles . . ., which in his judgment cause, or contribute to, air pollution which may reasonably be anticipated to endanger public health or welfare.’’ With EPA’s December 2009 final findings that certain greenhouse gases may reasonably be anticipated to endanger public health and welfare and that emissions of GHGs from section 202(a) sources cause or contribute to that endangerment, section 202(a) requires EPA to issue standards applicable to emissions of those pollutants from new motor vehicles. See Coalition for Responsible Regulation v. EPA, 684 F. 
3d at 116–125, 126–27 cert. granted by, in part Util. Air Regulatory Group v. EPA, 134 S. Ct. 418 (2013), affirmed in part and reversed in part on unrelated grounds by Util. Air Regulatory Group v. EPA, 134 S. Ct. 2427 (2014) (upholding 
EPA’s endangerment and cause and contribute findings, and further affirming EPA’s conclusion that it is legally compelled to issue standards under section 202(a) to address emission of the pollutant which endangers after making the endangerment and cause or contribute findings); see also id. at 127–29 (upholding EPA’s light-duty GHG emission standards for MYs 2012–2016 in their entirety). 
Other aspects of EPA’s legal authority, 
including its authority under section 202(a), its testing authority under section 203 of the Act, and its enforcement authorities under sections 205 and 207 of the Act are discussed fully in the Phase 1 rule, and need not be repeated here. See 76 FR 57129– 57130. 
In this final rule, EPA is establishing 
first-time CO
2emission standards for 
trailers hauled by tractors. 80 FR 40170. Certain commenters, notably the Truck Trailer Manufacturers Association (TTMA), maintained that EPA lacks authority to adopt requirements for trailer manufacturers, and that emission standards for trailers could be implemented, if at all, by requirements applicable to the entity assembling a tractor-trailer combination. The argument is that trailers by themselves are not ‘‘motor vehicles’’ as defined in section 216(2) of the Act, that trailer manufacturers therefore do not manufacture motor vehicles, and that standards for trailers can be imposed, if at all, only on ‘‘the party that joined the trailer to the tractor.’’ Comments of TTMA, p. 4; Comments of TTMA (March 31, 2016) p. 2. 
EPA also proposed a number of 
changes and clarifications for rules respecting glider kits and glider vehicles. 80 FR 40527–40530. As shown in Figure I.1, a glider kit is a tractor chassis with frame, front axle, interior and exterior cab, and brakes. 
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81As discussed in sections (c) and (d) below, 
however, manufacturers of glider kits can, and 
typically are, responsible for obtaining a certificate of conformity before shipping a glider kit. This is because they are manufacturers of motor vehicles, in this case, an incomplete vehicle. 
It is intended for self-propelled 
highway use, and becomes a glider 
vehicle when an engine, transmission, and rear axle are added. Engines are often salvaged from earlier model year vehicles, remanufactured, and installed in the glider kit. The final manufacturer of the glider vehicle, i.e. the entity that 
installs an engine, is typically a different manufacturer than the original manufacturer of the glider kit. The final rule contains emission standards for glider vehicles, but does not contain separate standards for glider kits.
81 
Many commenters to both the 
proposed rule and the NODA supported EPA’s interpretation. However, a number of commenters, including Daimler, argued that glider kits are not motor vehicles and so EPA lacks the authority to impose any rules respecting their sale or configuration. Comments of Daimler, pp. 122–23; Comments of Daimler Trucks (April 1, 2016) pp. 2–3. We respond to these comments below, with a more detailed response appearing in RTC Section 1.3.1 and 14.2. 
Under the Act, ‘‘motor vehicle’’ is 
defined as ‘‘any self-propelled vehicle designed for transporting persons or property on a street or highway.’’ CAA section 216(2). At proposal, EPA maintained that tractor-trailers are motor vehicles and that EPA therefore has the authority to promulgate emission standards for complete and incomplete vehicles—both the tractor and the trailer. 80 FR 40170. The same proposition holds for glider kits and glider vehicles. Id. at 80 FR 40528. The argument that a trailer, or a glider kit, standing alone, is not self-propelled, and therefore is not a motor vehicle, misses the key issues of authority under the Clean Air Act to promulgate emission standards for motor vehicles produced in discrete segments, and the further issue of the entities—namely ‘‘manufacturers’’—to which standards and certification requirements apply. Simply put, EPA is authorized to set emission standards for complete and incomplete motor vehicles, manufacturers of complete and incomplete motor vehicles can be required to certify to those emission standards, and there can be multiple manufacturers of a motor vehicle, each of which can be required to certify. 
(a) Standards for Complete Vehicles— 
Tractor-Trailers and Glider Vehicles 
Section 202(a)(1) authorizes EPA to 
set standards ‘‘applicable to the emission of any air pollutant from any 
. . . new motor vehicles.’’ There is no question that EPA is authorized to establish emission standards under this provision for complete new motor 
vehicles, and thus can promulgate emission standards for air pollutants emitted by tractor-trailers and by glider vehicles. 
Daimler maintained in its comments 
that although a glider vehicle is a motor vehicle, it is not a ‘‘new’’ motor vehicle because ‘‘glider vehicles, when constructed retain the identity of the donor vehicle, such that the title has already been exchanged, making the vehicles not ‘new’ under the CAA.’’ Daimler Comments p. 121; see also the similar argument in Daimler Truck Comments (April 1, 2016), p. 4. Daimler maintains that because title to the powertrain from the donor vehicle has already been transferred, the glider vehicle to which the powertrain is added cannot be ‘‘new.’’ Comments of April 1, 2016 p. 4. Daimler also notes that NHTSA considers a truck to be ‘‘newly manufactured’’ and subject to Federal Motor Vehicle Safety Standards when a new cab is used in its assembly, ‘‘unless the engine, transmission, and drive axle(s) (as a minimum) of the assembled vehicle are not new, and at least two of these components were taken from the same vehicle.’’ 49 CFR 571.7(e). Daimler urges EPA to adopt a parallel provision here. 
First, this argument appears to be 
untimely. In Phase 1, EPA already indicated that glider vehicles are new motor vehicles, at least implicitly, by 
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82Advertisement for Fitzgerald Glider kits in 
Overdrive magazine (December 2015) (emphasis 
added). 
83Fitzgerald states ‘‘All Fitzgerald glider kits will 
be titled in the state of Tennessee and you will receive a title to transfer to your state.’’ https://
www.fitzgeraldgliderkits.com/frequently-asked- questions. Last accessed July 9, 2016. 84‘‘Non-road vehicles’’ are defined differently 
than ‘‘motor vehicles’’ under the Act, but the 
difference does not appear relevant here. Non-road vehicles, like motor vehicles, must be propelled by 
an engine. See CAA section 216(11) (‘‘ ‘nonroad vehicle’ means a vehicle that is powered by a nonroad engine’’). Pursuant to this authority, EPA has promulgated many emission standards applicable to components of engineless non-road equipment, for which the equipment manufacturer must certify. adopting an interim exemption for 
them. See 76 FR 57407 (adopting 40 CFR 1037.150(j) indicating that the general prohibition against introducing a vehicle not subject to current model year standards does not apply to MY 2013 or earlier engines). Assuming the argument that glider vehicles are not new can be raised in this rulemaking, EPA notes that the Clean Air Act defines ‘‘new motor vehicle’’ as ‘‘a motor vehicle the equitable or legal title to which has never been transferred to an ultimate purchaser’’ (section 216(3)). Glider vehicles are typically marketed and sold as ‘‘brand new’’ trucks. Indeed, one prominent assembler of glider kits and glider vehicles advertises that ‘‘Fitzgerald Glider Kits offers customers the option to purchase a brand new 2016 tractor, in any configuration offered by the manufacturer . . . Fitzgerald Glider Kits has mastered the process of taking the ‘Glider Kit’ and installing the components to work seamlessly with the new truck.’’
82The 
purchaser of a ‘‘new truck’’ necessarily takes initial title to that truck.
83Daimler 
would have it that this ‘new truck’ terminology is a mere marketing ploy, but it obviously reflects reality. As shown in Figure I.1 above, the glider kit constitutes the major parts of the vehicle, lacking only the engine, transmission, and rear axle. The EPA sees nothing in the Act that compels the result that adding a used component to an otherwise new motor vehicle necessarily vitiates classification of the motor vehicle as ‘‘new.’’ See 80 FR 40528. Rather, reasonable judgments must be made, and in this case, the agency believes it reasonable that the tail need not wag the dog: Adding the engine and transmission to the otherwise-complete vehicle does not 
prevent the glider vehicle from being ‘‘new’’—as marketed. The fact that this approach is reasonable, if not mandated, is confirmed by the language of the Act’s definition of ‘‘new motor vehicle engine,’’ which includes any ‘‘engine in a new motor vehicle’’ without regard to whether or not the engine was previously used. EPA has also previously addressed the issue of used components in new engines and vehicles explicitly in regulations in the context of locomotives and locomotive engines in 40 CFR part 1033. There we defined remanufactured locomotives and locomotive engines to be ‘‘new’’ 
locomotives and locomotive engines. See 63 FR 18980; see also Summary and Analysis of Comments on Notice of Proposed Rulemaking for Emission Standards for Locomotives and Locomotive Engines (EPA–420–R–97– 101 (December 1997)) at pp. 10–14. This is a further reason that the model year of the engine is not determinative of whether a glider vehicle is ‘‘new.’’ As to the suggestion to adopt a provision parallel to the NHTSA definition, EPA notes that the NHTSA definition was developed for different purposes using statutory authority which differs from the Clean Air Act in language and intent. There consequently is no basis for requiring EPA to adopt such a definition, and doing so would impede meaningful control of both GHG emissions and criteria pollutant emissions from glider vehicles. 
(b) Standards for Incomplete Vehicles 
Section 202(a)(1) not only authorizes 
EPA to set standards ‘‘applicable to the 
emission of any air pollutant from any . . . new motor vehicles,’’ but states further that these standards are applicable ‘‘whether such vehicles . . . are designed as complete systems or incorporate devices to prevent or control such pollution.’’ The Act in fact thus not only contemplates, but in some instances, directly commands that EPA establish standards for incomplete vehicles and vehicle components. See CAA section 202(a)(6) (standards for onboard vapor recovery systems on ‘‘new light-duty vehicles,’’ and requiring installation of such systems); section 202(a)(5)(A) (standards to control emissions from refueling motor vehicles, and requiring consideration of, and possible design standards for, fueling system components); 202(k) (standards to control evaporative emissions from gasoline-fueled motor vehicles). Both TTMA and Daimler argued, in effect, that these provisions are the exceptions that prove the rule and that without this type of enumerated exception, only entire, complete vehicles can be considered to be ‘‘motor vehicles.’’ This argument is not persuasive. Congress did not indicate that these incomplete vehicle provisions were exceptions to the definition of motor vehicle. Just the opposite. Without amending the new motor vehicle definition, or otherwise indicating that these provisions were not already encompassed within Title II 
authority over ‘‘new motor vehicles’’, Congress required EPA to set standards for evaporative emissions from a portion of a motor vehicle. Congress thus indicated in these provisions: (1) That standards should apply to ‘‘vehicles’’ 
whether or not the ‘‘vehicles’’ were designed as complete systems; (2) that some standards should explicitly apply only to certain components of a vehicle that are plainly not self-propelled. Congress thus necessarily was of the view that incomplete vehicles can be motor vehicles. 
Emission standards EPA sets pursuant 
to this authority thus can be, and often are focused on emissions from the new motor vehicle, and from portions, systems, parts, or components of the vehicle. Standards thus apply not just to exhaust emissions, but to emissions from non-exhaust portions of a vehicle, or from specific vehicle components or parts. See the various evaporative emission standards for light duty vehicles in 40 CFR part 86, subpart B (e.g., 40 CFR 86.146–96 and 86.150–98 
(refueling spitback and refueling test procedures); 40 CFR 1060.101–103 and 73 FR 59114–59115 (various evaporative emission standards for small spark ignition equipment); 40 CFR 86.1813– 17(a)(2)(iii) (canister bleed evaporative emission test procedure, where testing is solely of fuel tank and evaporative canister); see also 79 FR 23507 (April 28, 2014) (incomplete heavy duty gasoline vehicles could be subject to, and required to certify compliance with, evaporative emission standards)). These standards are implemented by testing the particular vehicle component, not by whole vehicle testing, notwithstanding that the component may not be self-propelled until it is installed in the vehicle or (in the case of non-road equipment), propelled by an engine.
84 
EPA thus can set standards for all or 
just a portion of the motor vehicle notwithstanding that an incomplete motor vehicle may not yet be self- propelled. This is not to say that the Act authorizes emission standards for any part of a motor vehicle, however insignificant. Under the Act it is reasonable to consider both the significance of the components in comparison to the entire vehicle and the significance of the components for achieving emissions reductions. A vehicle that is complete except for an ignition switch can be subject to standards even though it is not self- 
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85Cf. Marine Shale Processors v. EPA, 81 F. 3d 
1371, 1383 (5th Cir. 1996) (‘‘[w]e make no comment 
on this argument: This is simply not a thimbleful case’’). 86See discussion of standards applicable to small 
SI equipment fuel systems, implemented by standards for the manufacturers of that equipment at 73 FR 59115 (‘‘In most cases, nonroad standards apply to the manufacturer of the engine or the manufacturer of the nonroad equipment. Here, the products subject to the standards (fuel lines and fuel tanks) are typically manufactured by a different manufacturer. In most cases the engine manufacturers do not produce complete fuel systems and therefore are not in a position to do all the testing and certification work necessary to cover the whole range of products that will be used. We are therefore providing an arrangement in which manufacturers of fuel-system components are in most cases subject to the standards and are subject to certification and other compliance requirements associated with the applicable standards’’). propelled. Likewise, as just noted, 
vehicle components that are significant for controlling evaporative emissions can be subject to standards even though in isolation the components are not self- propelled. However, not every individual component of a complete vehicle can be subjected to standards as 
an incomplete vehicle. To reflect these considerations, EPA is adopting provisions stating that a trailer is a vehicle ‘‘when it has a frame with one or more axles attached,’’ and a glider kit becomes a vehicle when ‘‘it includes a passenger compartment attached to a frame with one or more axles.’’ Section 1037.801 definition of ‘‘vehicle,’’ paragraphs (1)(ii) and (iii); see also Section XIII.B below. 
TTMA and Daimler each maintained 
that this claim of authority is open- ended, and can be extended to the least significant vehicle part. As noted above, EPA acknowledges that lines need to be drawn, but whether looking at the relation between the incomplete vehicle and the complete vehicle, or looking at the relation between the incomplete vehicle and the emissions control requirements, it is evident that trailers and glider kits should properly be treated as vehicles, albeit incomplete ones.
85They properly fall on the vehicle 
side of the line. When one finishes assembling a whole aggregation of parts to make a finished section of the vehicle (e.g. the trailer), that is sufficient. You 
have an entire, complete section made up of assembled parts. Everything needed to be a trailer is complete. This is not an engine block, a wheel, or a headlight. Similarly, glider kits comprise the largely assembled tractor chassis with front axles, frame, interior and exterior cab, and brakes. This is not a few assembled components; rather, it is an assembled truck with a few components missing. See CAA section 216(9) of the Act, which defines ‘‘motor vehicle or engine part manufacturer’’ as ‘‘any person engaged in the manufacturing, assembling or rebuilding of any device, system, part, component or element of design which is installed in or on motor vehicles or motor vehicle engines.’’ Trailers and glider kits are not ‘‘installed in or on’’ a motor vehicle. A trailer is half of the tractor-trailer, not some component installed on the tractor. And one would more naturally refer to the donor drivetrain being installed on the glider kit than vice versa. See Figure I.1 above. Furthermore, as discussed below, the trailer and the glider kit are significant for purposes of controlling emissions from the completed vehicle. 
Incomplete vehicle standards must, of 
course, be reasonably designed to control emissions caused by that particular vehicle segment. The standards for trailers would do so and account for the tractor-trailer combination by using a reference tractor in the trailer test procedure (and, conversely, by use of a reference trailer in the tractor test procedure). The Phase 2 rule contains no emission standards for glider kits in isolation, but the standards for glider vehicles necessarily reflect the contribution of the glider kit. 
(c) Application of Emission Standards to 
Manufacturers 
In some ways, the critical issue is to 
whom these emission standards apply. As explained in this section, the emission standards apply to manufacturers of motor vehicles, and manufacturers thus are required to test and to certify compliance to those standards. Moreover, the Act contemplates that a motor vehicle can have multiple manufacturers. With respect to the further question of which manufacturer certifies and tests in multiple manufacturer situations, EPA rules have long contained provisions establishing responsibilities where a vehicle has multiple manufacturers. We are applying those principles in the Phase 2 rules. The overarching principle is that the entity with most control over the particular vehicle segment due to producing it is usually the most appropriate entity to test and certify.
86 
EPA is implementing the trailer and glider vehicle emission standards in accord with this principle, so that the entities required to test and certify are the trailer manufacturer and, for glider kits and glider vehicles, either the manufacturer of the glider kit or glider vehicle, depending on which is more appropriate in individual circumstances. (i) Definition of Manufacturer 
Emission standards are implemented 
through regulation of the manufacturer of the new motor vehicle. See, e.g. section 206(a)(1) (certification testing of motor vehicle submitted by ‘‘a manufacturer’’); 203(a)(1) (manufacturer of new motor vehicle prohibited from introducing uncertified motor vehicles into commerce); 207(a)(1) (manufacturer of motor vehicle to provide warranty to ultimate purchaser of compliance with applicable emission standards); 207(c) (recall authority); 208(a) (recordkeeping and testing can be required of every manufacturer of new motor vehicle). 
The Act further distinguishes between 
manufacturers of motor vehicles and manufacturers of motor vehicle parts. See, e.g. section 206(a)(2) (voluntary 
emission control system verification testing); 203(a)(3)(B) (prohibition on parts manufacturers and other persons relating to defeat devices); 207(a)(2) (parts manufacturer may provide warranty certification regarding use of parts); 208(a) (recordkeeping and testing requirements for manufacturers of vehicle and engine ‘‘parts or components’’). 
Thus, the question here is whether a 
trailer manufacturer or glider kit manufacturer can be a manufacturer of a new motor vehicle and thereby become subject to the certification and related requirements for manufacturers, or must necessarily be classified as a manufacturer of a motor vehicle part or component. EPA may reasonably classify trailer manufacturers and glider kit manufacturers as motor vehicle manufacturers. 
Section 216(1) defines a 
‘‘manufacturer’’ as ‘‘any person engaged in the manufacturing or assembling of new motor vehicles, new motor vehicle engines, new nonroad vehicles or new nonroad engines, or importing such vehicles or engines for resale, or who acts for and is under the control of any such person in connection with the distribution of new motor vehicles, new motor vehicle engines, new nonroad vehicles or new nonroad engines, but shall not include any dealer with respect to new motor vehicles, new motor vehicle engines, new nonroad vehicles or new nonroad engines received by him in commerce.’’ 
It appears plain that this definition 
was not intended to restrict the definition of ‘‘manufacturer’’ to a single person per vehicle. The use of the conjunctive, specifying that a manufacturer is ‘‘any person engaged in 
the manufacturing or assembling of new motor vehicles . . . or who acts for and 
is under the control of any such person 
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87See United States v. Gonzales, 520 U.S. 1, 5, 
(1997) (‘‘Read naturally the word ‘any’ has an 
expansive meaning, that is, ‘one or some indiscriminately of whatever kind’); New York v. 
EPA, 443 F.3d 880, 884–87 (D.C. Cir. 2006). 
88‘‘The EPA should understand that vehicle 
manufacturing is a multi-stage process (regardless of the technologies on the vehicles) and that each stage of manufacturer has the incentive to properly complete manufacturing . . . [T]he EPA should continue the longstanding industry practice of allowing primary manufacturers to pass incomplete vehicles with incomplete vehicle documents to secondary manufacturers who complete the installation.’’ 
89The relative contribution of trailer controls 
depends on the types of tractors and trailers, as well 
as the tier of standards applicable; however, it can be approximately one-third of the total reduction achievable for the tractor-trailer. 90Consequently, the essential issue here is not 
whether EPA can issue and implement emission 
standards for trailers, but at what point in the implementation process those standards apply. . . .’’ (emphasis added) indicates that 
Congress anticipated that motor vehicles could have more than one manufacturer, since in at least some cases those will plainly be different people. The capacious reference to ‘‘any person engaged in the manufacturing of motor vehicles’’ likewise allows the natural inference that it could apply to multiple entities engaged in manufacturing.
87 
The provision also applies both to 
entities that manufacture and entities that assemble, and does so in such a way as to encompass multiple parties: Manufacturers ‘‘or’’ (rather than ‘and’) assemblers are included. Nor is there any obvious reason that only one person can be engaged in vehicle manufacture or vehicle assembling. 
Reading the Act to provide for 
multiple motor vehicle manufacturers reasonably reflects industry realities, and achieves important goals of the CAA. Since title II requirements are generally imposed on ‘‘manufacturers’’ it is important that the appropriate parties be included within the definition of manufacturer—‘‘any person engaged in the manufacturing or assembling of new motor vehicles.’’ Indeed, as set out in Chapter 1 of the RIA, most heavy duty vehicles are manufactured or assembled by multiple entities; see also Comments of Daimler (October 1, 2015) p. 103.
88One entity 
produces a chassis; a different entity manufactures the engine; specialized components (e.g. garbage compactors, 
cement mixers) are produced by still different entities. For tractor-trailers, one person manufactures the tractor, another the trailer, a third the engine, and another typically assembles the trailer to the tractor. Installation of various vehicle components occurs at different and varied points and by different entities, depending on ultimate desired configurations. See, e.g. Comments of Navistar (October 1, 2015), pp. 12–13. The heavy duty sector thus differs markedly from the light duty sector (and from manufacturing of light duty pickups and vans), where a single company designs the vehicle and engine (and many of the parts), and does all assembling of components into the 
finished motor vehicle. 
(ii) Controls on Manufacturers of 
Trailers 
It is reasonable to view the trailer 
manufacturer as ‘‘engaged in’’ (section 216(1)) the manufacturing or assembling of the tractor-trailer. The trailer manufacturer designs, builds, and assembles a complete and finished portion of the tractor-trailer. All components of the trailer—the tires, axles, flat bed, outsider cover, aerodynamics—are within its control and are part of its assembling process. The trailer manufacturer sets the design specifications that affect the GHG emissions attributable to pulling the trailer. It commences all work on the trailer, and when that work is complete, nothing more is to be done. The trailer is a finished product. With respect to the trailer, the trailer manufacturer is analogous to the manufacturer of the light duty vehicle, specifying, controlling, and assembling all aspects of the product from inception to completion. GHG emissions attributable to the trailer are a substantial portion of the total GHG emissions from the tractor-trailer.
89Moreover, the trailer 
manufacturer is not analogous to the manufacturer of a vehicle part or component, like a tire manufacturer, or to the manufacturer of a side skirt. The trailer is a significant, integral part of the finished motor vehicle, and is essential for the tractor-trailer to carry out its commercial purpose. See 80 FR 40170. Although it is true that another person may ultimately hitch the trailer to a tractor (which might be viewed as completing assembly of the tractor- trailer), as noted above, EPA does not believe that the fact that one person might qualify as a manufacturer, due to ‘‘assembling’’ the motor vehicle, precludes another person from qualifying as a manufacturer, due to ‘‘manufacturing’’ the motor vehicle. Given that section 216(1) does not restrict motor vehicle manufacturers to a single entity, it appears to be consistent with the facts and the Act to consider trailer manufacturers as persons engaged in the manufacture of a motor vehicle. 
This interpretation of section 216(1) is 
also reasonable in light of the various provisions noted above relating to implementation of the emissions standards—certification under section 206, prohibitions on entry into commerce under section 203, warranty 
and recall under section 207, and recordkeeping/reporting under section 208. All of these provisions are naturally applied to the entity responsible for manufacturing the trailer, which manufacturer is likewise responsible for its GHG emissions. 
TTMA maintains that if a tractor- 
trailer is a motor vehicle, then only the entity connecting the trailer to the tractor could be subject to regulation.
90 
This is not a necessary interpretation of section 216(1), as explained above. TTMA does not discuss that provision, but notes that other provisions refer to ‘‘a’’ manufacturer (or, in one instance, ‘‘the’’ manufacturer), and maintains that this shows that only a single entity can be a manufacturer. See TTMA Comment pp. 4–5, citing to sections 206(a)(1), 206(b), 207, and 203(a). This reading is not compelled by the statutory text. First, the term ‘‘manufacturer’’ in all of these provisions necessarily reflects the underlying definition in section 216(1), and therefore is not limited to a single entity, as just discussed. Second, the interpretation makes no practical sense. An end assembler of a tractor-trailer is not in a position to certify and warrant performance of the trailer, given that the end-assembler has no control over how trailers are designed, constructed, or even which trailers are attached to the tractor. It makes little sense for the entity least able to control the outcome to be responsible for that outcome. The EPA doubts that Congress compelled such an ungainly implementation mechanism, especially given that it is well known that vehicle manufacture responsibility in the heavy duty vehicle sector is divided, and given further that title II includes requirements for EPA to promulgate emission standards for portions of vehicles. 
(iii) Controls on Manufacturers of Glider 
Kits 
Application of these same principles 
indicate that a glider kit manufacturer is a manufacturer of a motor vehicle and, as an entity responsible for assuring that glider vehicles meet the Phase 2 vehicle emission standards, can be a party in the certification process as either the certificate holder or the entity which provides essential test information to the glider vehicle manufacturer. As noted above, glider kits include the entire tractor chassis, cab, tires, body, and brakes. Glider kit manufacturers thus control critical elements of the 
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91PACCAR indicated in its comments that 
manufacturers of glider kits may not know all 
details of final assembly. Provisions on delegated assembly, shipment of incomplete vehicles to secondary manufacturers, and assembly instructions for secondary vehicle manufacturers allow manufacturers of glider kits and glider vehicles to apportion responsibilities, as appropriate, including responsibility as to which entity shall be the certificate holder. See 40 CFR 1037.130, 1037.621, and 1037.622. Our point here is that both of these entities are manufacturers of the glider motor vehicle and therefore that both are 
within the Act’s requirements for certification and testing. 
92Under this provision in the Phase 2 regulations, 
the glider kit manufacturer would still have some 
responsibility to ensure that products they introduce into U.S. commerce will conform with the regulations when delivered to the ultimate purchasers. ultimate vehicle’s greenhouse gas 
emissions, in particular, all aerodynamic features and all emissions related to steer tire type. Glider kit manufacturers would therefore be the entity generating critical GEM inputs— at the least, those for aerodynamics and tires. Glider kit manufacturers also often know the final configuration of the glider vehicle, i.e. the type of engine and 
transmission which the final assembler will add to the glider kit.
91This is 
because the typical glider kit contains all necessary wiring, and it is necessary, in turn, for the glider kit manufacturer to know the end configuration in order to wire the kit properly. Thus, a manufacturer of a glider kit can reasonably be viewed as a manufacturer of a motor vehicle under the same logic as above: There can be multiple manufacturers of a motor vehicle; the glider kit manufacturer designs, builds, and assembles a substantial, complete and finished portion of the motor vehicle; and that portion contributes substantially to the GHG emissions from the ultimate glider vehicle. A glider kit is not a vehicle part; rather, it is an assembled truck with a few components missing. 
EPA rules have long provided 
provisions establishing responsibilities where there are multiple manufacturers of motor vehicles. See 40 CFR 1037.620 (responsibilities for multiple manufacturers), 40 CFR 1037.621 (delegated assembly), and 40 CFR 1037.622 (shipment of incomplete vehicles to secondary vehicle manufacturers). These provisions, in essence, allow manufacturers to determine among themselves as to which should be the certificate holder, and then assign respective responsibilities depending on that decision. The end result is that incomplete vehicles cannot be introduced into commerce without one of the manufacturers being the certificate holder. 
Under the Phase 1 rules, glider kits 
are considered to be incomplete vehicles which may be introduced into commerce to a secondary manufacturer for final assembly. See 40 CFR 1037.622(b)(1)(i) and 1037.801 (definition of ‘‘vehicle’’ and ‘‘incomplete vehicle’’) of the Phase 1 regulations (76 FR 57421). Note that 40 CFR 1037.622(b)(1)(i) was originally codified as 40 CFR 1037.620(b)(1)(i). EPA is expanding somewhat on these provisions, but in essence, as under Phase 1, glider kit and glider vehicle manufacturers could operate under delegated assembly provisions whereby the glider kit manufacturer would be the certificate holder. See 40 CFR 1037.621 of the final regulations. Glider kit manufacturers would also continue to be able to ship uncertified kits to secondary manufacturers, and the secondary manufacturer must assemble the vehicle into certifiable condition. 40 CFR 1037.622.
92 
(d) Additional Authorities Supporting EPA’s Actions 
Even if, against our view, trailers and 
glider kits are not considered to be ‘‘motor vehicles,’’ and the entities engaged in assembling trailers and glider kits are not considered to be manufacturers of motor vehicles, the Clean Air Act still provides authority for the testing requirements adopted here. Section 208 (a) of the Act authorizes EPA to require ‘‘every manufacturer of new motor vehicle or engine parts or components’’ to ‘‘perform tests where such testing is not otherwise reasonably available.’’ This testing can be required to ‘‘provide information the Administrator may reasonably require to determine whether the manufacturer . . . has acted or is acting in compliance with this part,’’ which includes showing whether or not the parts manufacturer is engaged in conduct which can cause a prohibited act. Testing would be required to show that the trailer will conform to the vehicle emission standards. In addition, testing for trailer manufacturers would be necessary here to show that the trailer manufacturer is not causing a violation of the combined tractor-trailer GHG emission standard either by manufacturing a trailer which fails to comply with the trailer emission standards, or by furnishing a trailer to the entity assembling tractor-trailers inconsistent with tractor-trailer certified condition. Testing for glider kit manufacturers is necessary to prevent a 
glider kit manufacturer furnishing a glider kit inconsistent with the tractor’s certified condition. In this regard, we note that section 203 (a)(1) of the Act not only prohibits certain acts, but also 
prohibits ‘‘the causing’’ of those acts. Furnishing a trailer not meeting the trailer standard would cause a violation of that standard, and the trailer manufacturer would be liable under section 203 (a)(1) for causing the prohibited act to occur. Similarly, a glider kit supplied in a condition inconsistent with the tractor standard would cause the manufacturer of the glider vehicle to violate the GHG emission standard, so the glider kit manufacturer would be similarly liable under section 203 (a)(1) for causing that prohibited act to occur. 
In addition, section 203 (a)(3)(B) 
prohibits use of ‘defeat devices’—which include ‘‘any part or component intended for use with, or as part of, any motor vehicle . . . where a principal effect of the part or component is to . . . defeat . . . any . . . element of design installed . . . in a motor vehicle’’ otherwise in compliance with emission standards. Manufacturing or installing a trailer not meeting the trailer emission standard could thus be a defeat device causing a violation of the emission standard. Similarly, a glider kit manufacturer furnishing a glider kit in a configuration that would not meet the tractor standard when the specified engine, transmission, and axle are installed would likewise cause a violation of the tractor emission standard. For example, providing a tractor with a coefficient of drag or tire rolling resistance level inconsistent with tractor certified condition would be a violation of the Act because it would cause the glider vehicle assembler to introduce into commerce a new tractor that is not covered by a valid certificate 
of conformity. Daimler argued in its comments that a glider kit would not be a defeat device because glider vehicles use older engines which are more fuel efficient since they are not meeting the more rigorous standards for criteria pollutant emissions. (Daimler Truck Comment, April 1, 2016, p. 5). However, the glider kit would be a defeat device with respect to the tractor vehicle standard, not the separate engine standard. A non-conforming glider kit would adversely affect compliance with the vehicle standard, as just explained. Furthermore, as explained in RTC Section 14.2, Daimler is incorrect that glider vehicles are more fuel efficient than Phase 1 2017 and later vehicles, much less Phase 2 vehicles. 
In the memorandum accompanying 
the Notice of Data Availability, EPA solicited comment on adopting additional regulations based on these 
principles. EPA has decided not to adopt those provisions, but again notes 
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93Comments from, e.g. Mondial and MEMA made 
clear that all of the donor engines installed in glider 
vehicles are rebuilt. See also http://www.truckinginfo.com/article/story/2013/04/the-return-of-the- glider.aspx (‘‘1999 to 2002-model diesels were 
known for reliability, longevity and good fuel mileage. Fitzgerald favors Detroit’s 12.7-liter Series 60 from that era, but also installs pre-EGR 14-liter Cummins and 15-liter Caterpillar diesels. All are rebuilt. . . .’’). 
94The engine rebuilding authority of section 
202(a)(3)(D) includes removal of an engine from the donor vehicle. See 40 CFR 86.004–40 and 62 FR 54702 (Oct. 21, 1997). EPA interprets this language as including installation of the removed engine into a glider kit, thereby assembling a glider vehicle. that the authorities in CAA sections 208 
and 203 support the actions EPA is taking here with respect to trailer and 
glider kit testing. 
(e) Standards for Glider Vehicles and 
Lead Time for Those Standards 
At proposal, EPA indicated that 
engines used in glider vehicles are to be certified to standards for the model year in which these vehicles are assembled. 80 FR 40528. This action is well within the agency’s legal authority. As noted above, the Act’s definition of ‘‘new motor vehicle engine,’’ includes any ‘‘engine in a new motor vehicle’’ without regard to whether or not the engine was previously used. Given the Act’s purpose of controlling emissions of air pollutants from motor vehicle engines, with special concern for pollutant emissions from heavy-duty engines (see, e.g., section 202(a)(3)(A) 
and (B)), it is reasonable to require engines placed in newly-assembled vehicles to meet the same standards as all other engines in new motor vehicles. Put another way, it is both consistent with the plain language of the Act and reasonable and equitable for the engines in ‘‘new trucks’’ (see Section I.E.(1)(a) above) to meet the emission standards for all other engines installed in new trucks. 
Daimler challenged this aspect of 
EPA’s proposal, maintaining that it amounted to regulation of vehicle rebuilding, which (according to the commenter) is beyond EPA’s authority. Comments of Daimler, p. 123; Comments of Daimler Trucks (April 1, 2016) p. 3. This comment is misplaced. The EPA has authority to regulate emissions of pollutants from engines installed in new motor vehicles. As explained in subsection (a) above, glider vehicles are new motor vehicles. As also explained above, the Act’s definition of ‘‘new motor vehicle engine’’ includes any ‘‘engine in a new motor vehicle’’ without regard to whether or not the engine was previously used. CAA section 216(3). Consequently, a previously used engine installed in a glider vehicle is within EPA’s multiple authorities. See CAA sections 202(a)(1) (GHGs), 202(a)(3)(A) and (B)(ii) (hydrocarbon, CO, PM and NO
Xfrom 
heavy-duty vehicles or engines), and 202(a)(3)(D) (pollutants from rebuilt heavy duty engines).
93 As explained in more detail in 
Section XIII.B, the final rule requires 
that as of January 1, 2017, glider kit and glider vehicle production involving engines not meeting criteria pollutant standards corresponding to the year of glider vehicle assembly be allowed at the highest annual production for any year from 2010 to 2014. See section 1037.150(t)(3). (Certain exceptions to this are explained in Section XIII.B.) The rule further requires that as of January 1, 2018, engines in glider vehicles meet criteria pollutant standards and GHG standards corresponding to the year of the glider vehicle assembly, but allowing certain small businesses to introduce into commerce vehicles with engines meeting criteria pollutant standards corresponding to the year of the engine for up to 300 vehicles per year, or up to the highest annual production volume for calendar years 2010 to 2014, whichever is less. Section 1037.150(t)(1)(ii) (again subject to various exceptions explained in Section XIII.B). Glider vehicles using these exempted engines will not be subject to the Phase 1 GHG vehicle standards, but 
will be subject to the Phase 2 vehicle standards beginning with MY 2021. As explained in Section XIII.B, there are compelling environmental reasons for taking these actions in this time frame. 
With regard to the issue of lead time, 
EPA indicated at proposal that the agency has long since justified the criteria pollutant standards for engines 
installed in glider kits. 80 FR 40528. EPA further proposed that engines installed in glider vehicles meet the emission standard for the year of glider vehicle assembly, as of January 1, 2018 and solicited comment on an earlier effective date. Id. at 40529. The agency noted that CAA section 202(a)(3)(D)
94 
requires that standards for rebuilt heavy-duty engines take effect ‘‘after a period . . . necessary to permit the development and application of the requisite control measures.’’ Here, no time is needed to develop and apply requisite control measures for criteria pollutants because compliant engines are immediately available. In fact, manufacturers of compliant engines, and dealers of trucks containing those compliant engines, commented that they are disadvantaged by manufacturing more costly compliant engines while glider vehicles avoid 
using those engines. Not only are compliant engines immediately available, but (as commenters warned) there can be risk of massive pre-buys. Moreover, EPA does not envision that glider manufacturers will actually modify the older engines to meet the applicable standards. Rather, they will either choose from the many compliant engines available today, or they will seek to qualify under other flexibilities provided in the final rule. See Section XIII.B. Given that compliant engines are immediately available, the flexibilities provided in the final rule for continued use of donor engines for traditional glider vehicle functions and by small businesses, and the need to expeditiously prevent further perpetuation of use of heavily polluting engines, EPA sees a need to begin constraining this practice on January 1, 2017. However, the final rule is merely capping glider production using higher- polluting engines in 2017 at 2010–2014 production levels, which would allow for the production of thousands of glider vehicles using these higher polluting engines, and unlimited production of glider vehicles using less polluting engines. 
Various commenters, however, argued 
that the EPA must provide four years lead-time and three-year stability pursuant to section 202(a)(3)(C) of the Act, which applies to regulations for criteria pollutant emissions from heavy duty vehicles or engines. For criteria pollutant standards, CAA section 202(a)(3)(C) establishes lead time and stability requirements for ‘‘[a]ny standard promulgated or revised under this paragraph and applicable to classes or categories of heavy duty vehicles or engines.’’ In this rule, EPA is generally requiring large manufacturers of glider vehicles to use engines that meet the standards for the model year in which a vehicle is manufactured. EPA is not promulgating new criteria pollutant standards. The NO
Xand PM standards 
that apply to heavy duty engines were promulgated in 2001. 
We are not amending these provisions 
or promulgating new criteria pollutant standards for heavy duty engines here. EPA interprets the phrase ‘‘classes or categories of heavy duty vehicles or engines’’ in CAA section 202(a)(3)(C) to refer to categories of vehicles established according to features such as their weight, functional type, (e.g. tractor, vocational vehicle, or pickup truck) or engine cycle (spark-ignition or compression-ignition), or weight class of the vehicle into which an engine is 
installed (LHD, MHD, or HHD). EPA has established several different categories 
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95Note, however, the Phase 2 GHG standards for 
tractors and vocational vehicles do not apply until 
MY 2021. 96Public Law 110–140, 121 Stat. 1492. (December 
19, 2007). 
97By delegation at 49 CFR 1.95(a). For purposes 
of this NPRM, grants of authority from EISA to the Secretary of Transportation regarding fuel efficiency will be referred to as grants of authority to NHTSA, as NHTSA has been delegated the authority to implement these programs. of heavy duty vehicles (distinguished by 
gross vehicle weight, engine-cycle, and other criteria related to the vehicles’ intended purpose) and is establishing in this rule GHG standards applicable to each category.
95By contrast, a ‘‘glider 
vehicle’’ is defined not by its weight or function but by its method of manufacture. A Class 8 tractor glider vehicle serves exactly the same function and market as a Class 8 tractor manufactured by another manufacturer. Similarly, rebuilt engines installed in glider vehicles (i.e. donor engines) are 
not distinguished by engine cycle, but rather serve the same function and market as any other HHD or MHD engine. Thus, EPA considers ‘‘glider vehicles’’ to be a description of a method of manufacturing new motor 
vehicles, not a description of a separate ‘‘class or category’’ of heavy duty vehicles or engines. Consequently, EPA is not adopting new standards for a class or category of heavy duty engines within the meaning of section 202(a)(3)(C) of the Act. 
EPA believes this approach is most 
consistent with the statutory language and the goals of the Clean Air Act. The date of promulgation of the criteria pollutant standards was 2001. There has been plenty of lead time for the criteria pollutant standards and as a result, manufacturers of glider vehicles have many options for compliant engines that are available on the market today—just as manufacturers of other new heavy- duty vehicles do. We are even providing additional compliance flexibilities to glider manufacturers in recognition of the historic practice of salvaging a small number of engines from vehicles involved in crashes. See Section XIII.B. We do not believe that Congress intended to allow changes in how motor vehicles are manufactured to be a means of avoiding existing, applicable engine standards. Obviously, any industry attempts to avoid or circumvent standards will not become apparent until the standards begin to apply. The commenters’ interpretation would effectively preclude EPA from curbing many types of avoidance, however dangerous, until at least four years from detection. 
As to Daimler’s further argument that 
the lead time provisions in section 202(3)(C) not only apply but also must trump those specifically applicable to heavy duty engine rebuilding, the usual rule of construction is that the more specific provision controls. See, e.g. HCSC-Laundry v. U.S., 450 U.S.1, 6 (1981). Daimler’s further argument that 
section 202(a)(3)(C) lead time provisions also apply to engine rebuilding because those provisions fall within the same paragraph would render the separate lead time provisions for engine rebuilding a virtual nullity. The sense of the provision is that Congress intended there to be independent lead time consideration for the distinct practice of engine rebuilding. In any case, as just explained, it is EPA’s view that section 202(a)(3)(C) does not apply here. 
(2) NHTSA Authority 
The Energy Policy and Conservation 
Act (EPCA) of 1975 mandates a 
regulatory program for motor vehicle fuel economy to meet the various facets of the need to conserve energy. In December 2007, Congress enacted the Energy Independence and Security Act (EISA), amending EPCA to require, among other things, the creation of a medium- and heavy-duty fuel efficiency program for the first time. 
Statutory authority for the fuel 
consumption standards in this final rule is found in EISA section 103, 49 U.S.C. 32902(k). This section authorizes a fuel efficiency improvement program, designed to achieve the maximum feasible improvement to be created for commercial medium- and heavy-duty on-highway vehicles and work trucks, to include appropriate test methods, measurement metrics, standards, and compliance and enforcement protocols that are appropriate, cost-effective and technologically feasible. 
NHTSA has responsibility for fuel 
economy and consumption standards, 
and assures compliance with EISA through rulemaking, including standard-setting; technical reviews, audits and studies; investigations; and enforcement of implementing regulations including penalty actions. This rule continues to fulfill the requirements of section 103 of EISA, which instructs NHTSA to create a fuel efficiency improvement program for ‘‘commercial medium- and heavy-duty on-highway vehicles and work trucks’’ by rulemaking, which is to include standards, test methods, measurement metrics, and enforcement protocols. See 49 U.S.C. 32902(k)(2). 
Congress directed that the standards, 
test methods, measurement metrics, and compliance and enforcement protocols be ‘‘appropriate, cost-effective, and technologically feasible’’ for the vehicles to be regulated, while achieving the ‘‘maximum feasible improvement’’ in fuel efficiency. NHTSA has broad discretion to balance the statutory factors in section 103 in developing fuel consumption standards to achieve the maximum feasible 
improvement. 
As discussed in the Phase 1 final rule, 
NHTSA has determined that the five year statutory limit on average fuel economy standards that applies to passengers and light trucks is not 
applicable to the HD vehicle and engine standards. As a result, the Phase 1 HD engine and vehicle standards remain in effect indefinitely at their 2018 or 2019 MY levels until amended by a future rulemaking action. As was contemplated in that rule, NHTSA is finalizing a Phase 2 rulemaking action. Therefore, the Phase 1 standards will not remain in effect at their 2018 or 2019 MY levels indefinitely; they will remain in effect until the MY Phase 2 standards begin. In accordance with section 103 of EISA, NHTSA will ensure that not less than four full MYs of regulatory lead-time and three full MYs of regulatory stability are provided for in the Phase 2 standards. 
With respect to the proposal, many 
stakeholders opined in their comments as to NHTSA’s legal authority to issue the Phase 2 medium- and heavy-duty standards (Phase 2 standards), in whole or in part. NHTSA addresses these comments in the following discussion. 
Allison Transmission, Inc. (Allison) 
questioned NHTSA’s authority to issue the Phase 2 Standards. Allison stated that the Energy Independence and Security Act of 2007 (EISA)
96directs 
NHTSA to undertake ‘‘a rulemaking 
proceeding,’’ (emphasis added) predicated on a study by the National Academy of Sciences (NAS). Allison and the Truck Trailer Manufacturers Association (TTMA) asserted that because NAS has published a study on medium- and heavy duty vehicles and NHTSA promulgated the Phase 1 medium- and heavy-duty vehicle standards (Phase 1 standards), NAS and NHTSA have fulfilled their statutory duties under EISA. Thus, Allison stated, NHTSA has no authority to issue standards beyond the Phase 1 standards. 
NHTSA maintains that EISA allows 
the agency to promulgate medium- and heavy duty fuel efficiency standards beyond the Phase 1 standards. EISA states that NHTSA:
97 
by regulation, shall determine in a 
rulemaking proceeding how to implement a commercial medium- and heavy-duty on- highway vehicle and work truck fuel 
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98Public Law 110–140, 121 Stat. 1492, Section 
108. Codified at 49 U.S.C. 32902(k)(2). 
9980 FR 40512 (July 13, 2015). 
100‘‘. . . the Secretary . . . shall determine in a 
rulemaking proceeding how to implement a 
commercial medium- and heavy-duty on-highway vehicle and work truck fuel efficiency program designed to achieve the maximum feasible improvement . . .’’ 49 U.S.C. 42902(k)(2). 
10149 U.S.C. 32902(k)(3) states that, ‘‘The 
commercial medium- and heavy-duty on-highway vehicle and work truck fuel economy standard adopted pursuant to this subsection shall provide not less than—(A) 4 full model years of regulatory lead-time; and (B) 3 full model years of regulatory stability.’’ 
102‘‘Program.’’ Merriam-Webster (2016 http://
www.merriam-webster.com/dictionary/program (last accessed July 19, 2016). 
10376 FR 57016 (September 15, 2011). 104See: 75 FR 74180 (November 30, 2010). efficiency program designed to achieve the 
maximum feasible improvement, and shall adopt and implement appropriate test methods, measurement metrics, fuel economy standards, and compliance and enforcement protocols . . . for commercial medium- and heavy-duty on-highway vehicles and work trucks.
98 
Allison equates the process by which 
Congress specified NHTSA promulgate standards—a rulemaking proceeding— to mean a limitation or constraint on NHTSA’s ability to create, amend, or update the medium- and heavy duty fuel efficiency program. NHTSA believes the charge in 49 U.S.C. 32902(k)(2) discusses ‘‘a rulemaking proceeding’’ only insofar as the statute specifies the process by which NHTSA would create a medium- and heavy-duty on-highway vehicle and work truck fuel efficiency improvement program and its associated standards. 
Allison and TTMA commented that 
EISA only refers to an initial NAS study, meaning EISA only specified that NHTSA issue one set of standards based on that study. As NHTSA stated in the NPRM, EISA requires NAS to issue updates to the initial report every five years through 2025.
99With that in 
mind, NAS issued an interim version of its first update to inform the Phase 2 NPRM. EISA’s requirement that NAS update its initial report, which examines existing and potential fuel efficiency technologies that can 
practically be integrated into medium- and heavy-duty vehicles, is consistent with the conclusion that EISA intended the medium- and heavy-duty standards to function as part of an ongoing program
100and not a single rulemaking. 
Allison also noted that the language 
in EISA discussing lead time and stability refers to a single medium- and heavy-duty on-highway vehicle and work truck fuel economy standard.
101 
NHTSA believes the language highlighted by Allison serves the purpose of noting that each medium- and heavy-duty segment standard included in its program shall have the requisite amount of lead-time and stability. As discussed in 49 U.S.C. 32902(k)(2), ‘‘[t]he Secretary may 
prescribe separate standards for different classes of vehicles . . .’’ Since NHTSA has elected to set standards for particular classes of vehicles, this language ensures each particular standard shall have the appropriate lead-time and stability required by EISA. 
TTMA asserted that NHTSA has no 
more than 24 months from the completion of the NAS study to issue regulations related to the medium- and heavy-duty program and therefore regulations issued after 2013 ‘‘lack congressional authorization.’’ This argument significantly misinterprets the Congressional purpose of this provision. Section 32902(k)(2) requires that, 24 
months after the completion of the NAS study, NHTSA begin implementing through a rulemaking proceeding a commercial medium- and heavy-duty on-highway vehicle and work truck fuel efficiency improvement program. Congress therefore authorized NHTSA to implement through rulemaking a ‘‘program,’’ which the dictionary defines as ‘‘a plan of things that are done in order to achieve a specific result.’’
102Contrary to TTMA’s 
assertion, Congress did not limit NHTSA to the establishment of one set of regulations, nor did it in any way limit NHTSA’s ability to update and revise this program. The purpose of the 24 month period was simply to ensure that NHTSA exercised this authority expeditiously after the NAS study, which NHTSA accomplished by implementing the first phase of its fuel efficiency program in 2011.
103Today’s 
rulemaking merely continues this program and clearly comports with the statutory language in 49 U.S.C. 32902(k). Further, the specific result sought by Congress in establishing the medium- and heavy-duty fuel efficiency program was a program focused on continuing fuel efficiency improvements. Specifically, Congress emphasized that the fuel efficiency program created by NHTSA be ‘‘designed to achieve the maximum feasible improvement,’’ allowing NHTSA to ensure the regulations implemented throughout the program encourage regulated entities to achieve the maximum feasible improvements. Congress did not limit, restrict, or otherwise suggest that the phrase ‘‘designed to achieve the maximum feasible improvement’’ be confined to the issuance of one set of standards. NHTSA actions are, therefore, clearly consistent with the authority conferred upon it in 49 U.S.C. 32902(k). 
POP Diesel stated that the word 
‘‘fuel’’ has not been defined by Congress, and therefore NHTSA should use its authority to define the term ‘‘fuel’’ as ‘‘fossil fuel,’’ allowing the agencies to assess fuel efficiency based on the carbon content of the fuels used in an engine or vehicle. Congress has already defined the term ‘‘fuel’’ in 49 U.S.C. 32901(a)(10) as gasoline, diesel oil, or other liquid or gaseous fuel that the Secretary decides to include. As Congress has already spoken to the definition of fuel, it would be inappropriate for the agency to redefine ‘‘fuel’’ as ‘‘fossil fuel.’’ 
Additionally, POP Diesel asserted that 
NHTSA’s metric for measuring fuel efficiency is contrary to the mandate in EISA. Specifically, POP Diesel stated that many dictionaries define ‘‘efficiency’’ as a ratio of work performed to the amount of energy used, and NHTSA’s load specific fuel consumption metric runs afoul of the plain meaning of statute the Phase 2 program implements. POP Diesel noted that Congressional debate surrounding what is now codified at 49 U.S.C. 32902(k)(2) included a discussion that envisioned NHTSA and EPA having separate regulations, despite having overlapping jurisdiction. 
NHTSA continues to believe its use of 
load specific fuel consumption is an appropriate metric for assessing fuel efficiency as mandated by Congress. 49 U.S.C. 32902(k)(2) states, as POP Diesel noted, that NHTSA shall develop a medium- and heavy-duty fuel efficiency program. The section further states that NHTSA ‘‘. . . shall adopt and implement appropriate test methods [and] measurement metrics . . . for commercial medium- and heavy-duty on-highway vehicles and work trucks.’’ In the Phase 1 rulemaking, NHTSA, aided by the National Academies of Sciences (NAS) report, assessed potential metrics for evaluating fuel efficiency. NHTSA found that fuel economy would not be an appropriate metric for medium- and heavy-duty vehicles. Instead, NHTSA chose a metric that considers the amount of fuel consumed when moving a ton of freight (i.e., performing work).
104This metric, 
delegated by Congress to NHTSA to formulate, is not precluded by the text of the statute. It is a reasonable way by which to measure fuel efficiency for a program designed to reduce fuel consumption. 
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10549 U.S.C. 42902(k)(2). 
10649 U.S.C. 30102(a)(6). 107See, e.g., 49 CFR 571.106 (Standard No. 106; 
Brake hoses); 49 CFR 571.108 (Standard No. 108; 
Lamps, reflective devices, and associated equipment); 49 CFR 571.121 (Standard No. 121; Air brake systems); 49 CFR 571.223 (Standard No. 223; Rear impact guards). 
108‘‘Vehicle.’’ Merriam-Webster (2016). http://
www.merriam-webster.com/dictionary/vehicle (last 
accessed May 20, 2016). (a) NHTSA’s Authority To Regulate 
Trailers 
As contemplated in the Phase 1 
proposed and final rules, the agencies proposed standards for trailers in the Phase 2 rulemaking. Because Phase 1 did not include standards for trailers, NHTSA did not discuss its authority for regulating them in the proposed or final rules; that authority is described here. 
NHTSA is finalizing fuel efficiency 
standards applicable to heavy-duty trailers as part of the Phase 2 program. NHTSA received several comments on the proposal relating to the agency’s statutory authority to issue standards for trailers as part of the Phase 2 program. In particular, TTMA commented that NHTSA does not have the authority to regulate trailers as part of the medium- and heavy-duty standards. TTMA took issue with NHTSA’s use of the National Traffic and Motor Vehicle Safety Act as an aid in defining an undefined term in EISA. Additionally, TTMA stated that EISA’s use of GVWR instead of gross combination weight rating (GCWR) to define the vehicles subject to these regulations was intended to exclude trailers from the regulation. 
As stated in the proposal, EISA 
directs NHTSA to ‘‘determine in a rulemaking proceeding how to implement a commercial medium- and heavy-duty on-highway vehicle and work truck fuel efficiency improvement program designed to achieve the maximum feasible improvement .... ’ ’
105EISA defines a commercial 
medium- and heavy-duty on-highway vehicle to mean ‘‘an on-highway vehicle with a GVWR of 10,000 lbs or more.’’ A ‘‘work truck’’ is defined as a vehicle between 8,500 and 10,000 lbs GVWR that is not an MDPV. These definitions do not explicitly exclude trailers, in contrast to MDPVs. Because Congress did not act to exclude trailers when defining these terms by GVWRs, despite demonstrating the ability to exclude MDPVs, it is reasonable to interpret the provision to include them. 
Both the tractor and the trailer are 
vehicles subject to regulation by NHTSA in the Phase 2 program. Although EISA does not define the term ‘‘vehicle,’’ NHTSA’s authority to regulate motor vehicles under its organic statute, the Motor Vehicle Safety Act (‘‘Safety Act’’), does. The Safety Act defines a motor vehicle as ‘‘a vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways. . . .’’
106NHTSA 
clearly has authority to regulate trailers under this Act as they are vehicles that 
are drawn by mechanical power—in this 
instance, a tractor engine—and NHTSA has exercised that authority numerous times.
107Given the absence of any 
apparent contrary intent on the part of Congress in EISA, NHTSA believes it is reasonable to interpret the term ‘‘vehicle’’ as used in the EISA definitions to have a similar meaning that includes trailers. 
Additionally, it is worth noting that 
the dictionary definition of ‘‘vehicle’’ is ‘‘a machine used to transport goods or persons from one location to another.’’
108A trailer is a machine 
designed for the purpose of transporting goods. With these foregoing considerations in mind, NHTSA interprets its authority to regulate commercial medium- and heavy-duty on-highway vehicles, including trailers. 
TTMA pointed to language in the 
Phase 1 NPRM where the agencies stated that GCWR included the weight of a loaded trailer and the vehicle itself. TTMA interprets this language to mean that standards applicable to vehicles defined by GVWR must inherently exclude trailers. The language TTMA cited is a clarification from a footnote in an introductory section describing the heavy-duty trucking industry. This statement was not a statement of NHTSA’s legal authority over medium- and heavy-duty vehicles. NHTSA continues to believe a trailer is a vehicle under EISA if its GVWR fits within the definitions in 49 U.S.C. 32901(a), and is therefore subject to NHTSA’s applicable fuel efficiency regulations. 
Finally, in a comment on the Notice 
of Data Availability, TTMA stated that because NHTSA’s statutory authority instructs the agency to develop a fuel efficiency program for medium- and heavy-duty on-highway vehicles, and trailers themselves do not consume fuel, trailers cannot be regulated for fuel efficiency. The agency disagrees with this assertion. A tractor-trailer is designed for the purpose of holding and transporting goods. While heavy-duty trailers themselves do not consume fuel, they are immobile and inoperative without a tractor providing motive power. Inherently, trailers are designed to be pulled by a tractor, which in turn affects the fuel efficiency of the tractor- trailer as a whole. As previously discussed, both a tractor and trailer are 
motor vehicles under NHTSA’s authority. Therefore it is reasonable to consider all of a tractor-trailer’s parts— the engine, the cab-chassis, and the trailer—as parts of a whole. As such they are all parts of a vehicle, and are captured within the scope of NHTSA’s statutory authority. As EPA describes above, the tractor and trailer are both incomplete without the other. Neither can fulfill the function of the vehicle without the other. For this reason, and the other reasons stated above, NHTSA interprets its authority to regulate commercial medium- and heavy-duty on-highway vehicles, including tractor- trailers, as encompassing both tractors and trailers. 
(b) NHTSA’s Authority To Regulate 
Recreational Vehicles 
NHTSA did not regulate recreational 
vehicles as part of the Phase 1 medium- and heavy-duty fuel efficiency standards, although EPA did regulate them as vocational vehicles for GHG emissions. In the Phase 1 NPRM, NHTSA interpreted ‘‘commercial medium- and heavy duty on-road vehicle’’ to mean that recreational vehicles, such as motor homes, were not to be included within the program because recreational vehicles are not commercial. Following comments to the Phase 1 proposal, NHTSA reevaluated its statutory authority and proposed that recreational vehicles be included in the Phase 2 standards, and that early compliance be allowed for manufacturers who want to certify during the Phase 1 period. 
The Recreational Vehicle Industry 
Association (RVIA) and Newell Coach Corporation (Newell) asserted that NHTSA does not have the authority to regulate recreational vehicles (RVs). RVIA and Newell stated that NHTSA’s authority under EISA is limited to 
commercial medium- and heavy-duty vehicles and that RVs are not commercial. RVIA pointed to the fact that EISA gives NHTSA fuel efficiency authority over ‘‘commercial medium- and heavy-duty vehicles’’ and ‘‘work trucks,’’ the latter of which is not prefaced with the word ‘‘commercial.’’ Because of this difference, RVIA argued that NHTSA is ignoring a limitation on its authority—that is, that NHTSA only has authority over medium- and heavy- duty vehicles that are commercial in nature. RVIA stated that RVs are not used for commercial purposes, and are therefore not subject to Phase 2. 
NHTSA’s authority to regulate 
medium- and heavy-duty vehicles under EISA extends to ‘‘commercial medium- and heavy-duty on-highway vehicles’’ 
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10949 U.S.C. 42902(k)(2). 
11049 U.S.C. 42901(a)(19). 
11149 U.S.C. 42901(a)(7). 112See ‘‘Mobile Source Strategy,’’ May 16, 2016 
from CARB. Available at: http://www.arb.ca.gov/
planning/sip/2016sip/2016mobsrc.htm and 
‘‘Proposed 2016 State Strategy for the State Implementation Plan,’’ May 17, 2016 from CARB. Available at http://www.arb.ca.gov/planning/sip/2016sip/2016sip.htm . 
113EPA received a Petition for Rulemaking to 
adopt new NO Xemission standards for on-road 
heavy-duty trucks and engines on June 3, 2016 from the South Coast Air Quality Management District, the Arizona Pima County Department of Environmental Quality, the Bay Area Air Quality Management District, the Connecticut Department of Energy and Environmental Protection Agency, the Delaware Department of Energy and Environmental Protection, the Nevada Washoe County Health District, the New Hampshire Department of Environmental Services, the New York City Department of Environmental Protection, the Akron Regional Air Quality Management District of Akron, Ohio, the Washington State Department of Ecology, and the Puget Sound Clean Air Agency. 
114US Energy Information Administration. 
Annual Energy Outlook 2015. April 2015. Page E– 8. http://www.eia.gov/forecasts/aeo/pdf/ 
0383(2015).pdf. 
11580 FR 65292 (Oct. 26, 2015). and ‘‘work truck[s].’’109If terms in the 
statute are defined, NHTSA must apply 
those definitions. Both terms highlighted by RVIA have been defined in EISA, therefore, NHTSA will use their defined meanings. ‘‘Work truck’’ means a vehicle that is rated between 8,500 and 10,000 pounds GVWR and is not an MDPV.
110‘‘Commercial medium- 
and heavy-duty on-road highway vehicle’’ means an on-highway vehicle with a gross vehicle weight rating (GVWR) of 10,000 pounds or more.
111 
Based on the definitions in EISA, recreational vehicles would be regulated as class 2b–8 vocational vehicles. Neither statutory definition requires that those vehicles encompassed be commercial in nature, instead dividing the medium- and heavy-duty segments based on weight. The definitions of ‘‘work truck’’ and ‘‘commercial medium- and heavy-duty on-highway vehicles’’ collectively encompass the on-highway motor vehicles not covered in the light duty CAFE standards. 
RVIA further stated that NHTSA’s 
current fuel efficiency regulations are not consistent with EISA and do not purport to grant NHTSA authority to regulate vehicles simply based on weight. NHTSA’s regulations at 49 CFR 523.6 define, by cross-reference the language in 49 U.S.C. 32901(a)(7) and (19), and consistent with the discussion above, include recreational vehicles. 
Finally, NHTSA notes that excluding 
recreational vehicles in Phase 2 could create illogical results, including treating similar vehicles differently, as determinations over whether a given vehicle would be covered by the program would be based upon either its intended or actual use, rather than the actual characteristics of the vehicle. Moreover, including recreational vehicles under NHTSA regulations furthers the agencies’ goal of one national program, as EPA regulations will continue to regulate recreational vehicles. NHTSA will allow early compliance for manufacturers that want to certify during the Phase 1 period. 
F. Other Issues 
In addition to establishing new Phase 
2 standards, this document addresses 
several other issues related to those standards. The agencies are adopting some regulatory provisions related to the Phase 1 program, as well as amendments related to other EPA and NHTSA regulations. These other issues are summarized briefly here and discussed in greater detail in later sections. 
(1) Opportunities for Further Oxides of 
Nitrogen (NO
X) Reductions From 
Heavy-Duty On-Highway Engines and Vehicles 
The EPA has the authority under 
section 202 of the Clean Air Act to establish, and from time to time revise, emission standards for certain air pollutants emitted from heavy-duty on- highway engines and vehicles. The emission standards that EPA has developed for heavy-duty on-highway engines have become progressively more stringent over the past 40 years, with the most recent NO
Xstandards for 
new heavy-duty on-highway engines fully phased in with the 2010 model year. NO
Xemissions standards for 
heavy-duty on-highway engines have contributed significantly to the overall reduction in the national NO
Xemissions 
inventory. Nevertheless, a need for additional NO
Xreductions remains, 
particularly in areas of the country with elevated levels of air pollution. As discussed further below, in response to EPA’s responsibilities under the Clean Air Act, the significant comments we received on this topic during the public comment period, the recent publication by the California Air Resources Board (CARB) of its May 2016 Mobile Source Strategy report and Proposed 2016 Strategy for the State implementation Plan
112and a recent Petition for 
Rulemaking,113EPA plans to further 
engage with stakeholders after the publication of this Final Rule to discuss the opportunities for developing more stringent federal standards to further reduce the level of NO
Xemissions from 
heavy-duty on-highway engines through a coordinated effort with CARB. 
NO
Xis one of the major precursors of 
tropospheric ozone (ozone), exposure to which is associated with a number of adverse respiratory and cardiovascular effects, as described in Section VIII.A.2 below. These effects are particularly pronounced among children, the elderly, and among people with lung disease such as asthma. NO
Xis also a 
major contributor to secondary PM 2.5 
formation, and exposure to PM 2.5itself 
has been linked to a number of adverse health effects (see Section VIII.A.1), such as heart attacks and premature mortality. In addition, NO
2exposure is 
linked to asthma exacerbation and possibly to asthma development in children (see Section VIII.A.3). EPA has already adopted many emission control programs that are expected to reduce ambient ozone levels. However, the U.S. Energy Information Administration’s AEO 2015 predicts that vehicles miles travelled (VMT) for heavy-duty trucks will increase in the coming years,
114 
and even with the implementation of all current state and federal regulations, some of the most populous counties in the United States are expected to have ozone air quality that exceeds the National Ambient Air Quality Standards (NAAQS) into the future. As of April 22, 2016, there were 44 ozone nonattainment areas for the 2008 ozone NAAQS composed of 216 full or partial counties, with a population of more than 120 million. These nonattainment areas are dispersed across the country, with counties in the west, northeastern United States, Texas, and several Great Lakes states. The geographic diversity of this problem necessitates action at the national level. In California, the San Joaquin Valley and the South Coast Air Basin are highly-populated areas classified as ‘‘extreme nonattainment’’ for the 2008 8-hour ozone standard, with an attainment demonstration deadline of 2031 (one year in advance of the actual 2032 attainment date). In addition, EPA lowered the level of the primary and secondary NAAQS for the 8-hour standards from 75 ppb to 70 ppb in 2015 (2015 ozone NAAQS),
115with 
plans to finalize nonattainment designations for the 2015 ozone NAAQS in October 2017. Further NO
X 
reductions would provide reductions in ambient ozone levels, helping to prevent adverse health impacts associated with ozone exposure and assisting states and local areas in attaining and maintaining the applicable ozone NAAQS. Reductions in NO
Xemissions would 
also improve air quality and provide 
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116To foster the development of the next 
generation of lower NO Xengines, in 2013, CARB 
adopted optional low-NO Xheavy-duty engine 
standards ranging from 0.10 down to 0.02 grams per 
brake horsepower-hour (g/bhp-hr). CARB also funded over $1 million to a low-NO
Xengine 
research and demonstration project at Southwest Research Institute (SwRI). 
117See ‘‘Mobile Source Strategy,’’ May 16, 2016 
from CARB. Available at: http://www.arb.ca.gov/planning/sip/2016sip/2016mobsrc.htm . 118See ‘‘Proposed 2016 State Strategy for the 
State Implementation Plan,’’ May 17, 2016 from 
CARB. Available at http://www.arb.ca.gov/planning/sip/2016sip/2016sip.htm . public health and welfare benefits 
throughout the country by (1) reducing PM formed by reactions of NO
Xin the 
atmosphere; (2) reducing concentrations of the criteria pollutant NO
2; (3) 
reducing nitrogen deposition to sensitive environments; and (4) improving visibility. 
In the past year, EPA has received 
requests from several state and local air quality districts and other organizations asking that EPA establish more stringent NO
Xstandards for heavy-duty on- 
highway engines to help reduce the public’s exposure to air pollution. In its comments, CARB estimated that heavy- duty on-highway vehicles currently contribute about one-third of all NO
X 
emissions in California. In order to achieve the 2008 ozone NAAQS, California has estimated that the state’s South Coast Air Basin will need an 80 percent reduction in NO
Xemissions by 
2031. California has the unique ability among states to adopt its own separate new motor engine and vehicle emission standards under section 209 of the CAA; however, CARB commented that EPA action to establish a new federal low- NO
Xstandard for heavy-duty trucks is 
critical, since California standards alone are not sufficient to demonstrate compliance with either the 2008 ozone NAAQS or the 2015, even more stringent ozone NAAQS. CARB has developed a comprehensive mobile source strategy which for heavy-duty on-highway vehicles includes: Lowering the emissions from the in-use fleet; establishing more stringent NO
X 
standards for new engines; and accelerating the deployment of zero and near-zero emissions technology.
116In 
September of 2015, CARB published a draft of this strategy, Mobile Source Strategy Discussion Draft, after which CARB held a public workshop and provided opportunity for public comment. On May 16, 2016, CARB issued a final Mobile Source Strategy report.
117In this report, CARB provides 
a comprehensive strategy plan for the future of mobile sources and goods movement in the State of California for how mobile sources in California can meet air quality and climate goals over the next fifteen years. Among the many programs discussed are plans for a future on-highway heavy-duty engine and vehicle NO
Xcontrol regulatory 
program for new products with 
implementation beginning in 2024. CARB states ‘‘The need for timely action by U.S. EPA to establish more stringent engine performance standards in collaboration with California efforts is essential. About 60 percent of total heavy-duty truck VMT in the South 
Coast on any given day is accrued by trucks purchased outside of California, and are exempt from California standards. U.S. EPA action to establish a federal low-NO
Xstandard for trucks is 
critical.’’ CARB lays out a time line for a California specific action for new highway heavy-duty NO
Xstandards 
with CARB action in 2017–2019 that would lead to new standards that could begin with the model year 2023. CARB also requests that the U.S. EPA work on a Federal rulemaking action in the 2017–2019 time frame which could result in standards that could begin with the model year 2024. The CARB Mobile Source Strategy document also states ‘‘Due to the preponderance of interstate trucking’s contribution to in-state VMT, federal action would be far more effective at reducing in-state emissions than a California-only standard. However, California is prepared to develop a California-only standard, if needed, to meet federal attainment targets.’’ CARB goes on to state ‘‘[C]ARB will begin development of new heavy- duty low NO
Xemission standard in 
2017 with Board action expected in 2019. ARB may also petition U.S. EPA in 2016 to establish new federal heavy- duty engine emission standards ....  I f  U.S. EPA begins the regulatory development process for a new federal heavy-duty emission standard by 2017, ARB will coordinate its regulatory development efforts with the federal regulation.’’ On May 17, 2016, CARB published its ‘‘Proposed 2016 State Strategy for the State Implementation Plan.’’
118This document contains 
CARB staff’s proposed strategy to attain the health-based federal air quality standards over the next fifteen years. With respect to future on-highway heavy-duty NO
Xstandards, the 
proposed State Implementation Plan is fully consistent with the information published by CARB in the Mobile Source Strategy report. EPA intends to work with CARB to consider the development of a new harmonized Federal and California program that would apply lower NO
Xemissions standards at the national level to heavy- 
duty on-highway engines and vehicles. 
In addition to CARB, EPA received 
compelling letters and comments from the National Association of Clean Air Agencies, the Northeast States for Coordinated Air Use Management, the Ozone Transport Commission, and the South Coast Air Quality Management District explaining the critical and urgent need to reduce NO
Xemissions 
that significantly contribute to ozone 
and fine particulate air quality problems in their represented areas. The comments describe the challenges many areas face in meeting both the 2008 and recently strengthened 2015 ozone NAAQS. These organizations point to the significant contribution of heavy- duty vehicles to NO
Xemissions in their 
areas, and call upon EPA to begin a rulemaking to require further NO
X 
controls for the heavy-duty sector as soon as possible. Commenters such as the American Lung Association, Environmental Defense Fund, Union of Concerned Scientists, the California Interfaith Power and Light, Coalition for Clean Air/California Cleaner Freight Coalition, and the Moving Forward Network similarly describe the air quality and public health need for NO
X 
reductions and request EPA to lower NO
Xemissions standards for heavy-duty 
vehicles. Taken as a whole, the numerous comments, the expected increase in heavy-duty truck VMT, and the fact that ozone challenges will remain across the country demonstrate the critical need for more stringent nationwide NO
Xemissions standards. 
Such standards are vital to improving air quality nationwide and reducing public health effects associated with exposure to ozone and secondary PM
2.5, 
especially for vulnerable populations and in highly impacted regions. 
On June 3, 2016, the EPA received a 
Petition for Rulemaking from the South Coast Air Quality Management District (California), the Pima County Department of Environmental Quality (Arizona), the Bay Area Air Quality Management District (California), the Connecticut Department of Energy and Environmental Protection Agency, the Delaware Department of Energy and Environmental Protection, the Washoe County Health District (Nevada), the New Hampshire Department of Environmental Services, the New York City Department of Environmental Protection, the Akron Regional Air Quality Management District (Ohio), the Washington State Department of Ecology, and the Puget Sound Clean Air 
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119http://4cleanair.org/sites/default/files/
resources/HD _Ultra-Low-NO X_Petition_ to_EPA- 
060316.pdf. 
120http://4cleanair.org/sites/default/files/
resources/Petition _Attachments-Ultra-Low-NO X_
Petition_ to_EPA-060316_ 0.pdf. 
121http://www.valleyair.org/recent_ news/Media_
releases/2016/PR-District-Petitions-Federal- 
Government-06-22-16.pdf. 
12266 FR 5002 (January 18, 2001). 
123See CARB’s September 2015 Draft Technology 
Assessment: Lower NO XHeavy-Duty Diesel Engines, 
and Draft Technology Assessment: Low Emission 
Natural Gas and Other Alternative Fuel Heavy-Duty Engines. 
124http://www.arb.ca.gov/research/veh- 
emissions/low-nox/low-nox.htm, 4/26/16. This low NO
Xstudy is in the process of selecting the 
emission reduction systems for final testing and it is expected that this demonstration program will be complete by the end of 2016. Agency (Washington).119 120 In a June 15, 
2016 letter to EPA, the Commonwealth 
of Massachusetts also joined this petition. On June 22, 2016, the San Joaquin Valley Air Pollution Control District (California) also submitted a petition for rulemaking to EPA.
121In 
these Petitions, the Petitioners request that EPA establish a new, lower NO
X 
emission standard for on-road heavy- duty engines. The Petitioners request that EPA implement a new standard by January 1, 2022, and that EPA establish this new standard through a Final Rulemaking issued by December 31, 2017. EPA is not formally responding to this Petition in this Final Rule, but we will do so in a future action. In the 
petitions, the Petitioners include a detailed discussion of their views and underlying data regarding the need for large scale reduction in NO
Xemissions 
from heavy-duty engines, why they believe new standards can be achieved, and their legal views on EPA’s responsibilities under the Clean Air Act. 
Since the establishment of the current 
heavy-duty on-highway standards in January of 2001,
122there has been 
continued progress in emissions control technology. EPA and CARB are currently investing in research to evaluate opportunities for further NO
X 
reductions from heavy-duty on-highway vehicles and engines. Programs and research underway at CARB, as well as a significant body of work in the technical literature, indicate that reducing NO
Xemissions significantly 
below the current on-highway standard of 0.20 grams per brake horsepower- hour (g/bhp-hr) is potentially feasible.
123 124 Opportunities for 
additional NO Xreductions include 
reducing emissions over cold start operation as well as low-speed, low- load off-cycle operation. Reductions are being accomplished through the use of improved engine management, advanced aftertreatment technologies (improvements in SCR catalyst design/ formulation), catalyst positioning, aftertreatment thermal management, and heated diesel exhaust fluid dosing. At the same time, the effect of these new technologies on cost and GHG emissions is being carefully evaluated,
124since it 
is important that any future NO Xcontrol 
technologies be considered in the context of the final Phase 2 GHG standards. During the Phase 2 program public comment period, EPA received some comments stressing the need for careful evaluation of emerging NO
X 
control technologies and urging EPA to consider the relationship between CO
2 
and NO Xbefore setting lower NO X 
standards (commenters include American Trucking Association, Caterpillar, Daimler Trucks North America, Navistar Inc., PACCAR Inc., Volvo Group, Truck and Engine Manufacturers Association, Diesel Technology Forum, National Association of Manufacturers, and National Automobile Dealers Association). EPA also received comments pointing to advances in NO
X 
emission control technologies that would lower NO
Xwithout reducing 
engine efficiency (commenters include Advanced Engine Systems Institute, Clean Energy, Manufacturers of Emission Controls Association, and Union of Concerned Scientists). EPA will continue to evaluate both opportunities and challenges associated with lowering NO
Xemissions from the 
current standards, and over the coming months we intend to engage with many stakeholders as we develop our response to the June 2016 Petitions for Rulemaking discussed above. 
EPA believes the opportunity exists to 
develop, in close coordination with CARB and other stakeholders, a new, harmonized national NO
Xreduction 
strategy for heavy-duty on-highway engines which could include the following: 
•Substantially lower NO
Xemission 
standards; 
•Improvements to emissions 
warranties; 
•Consideration of longer useful life, 
reflecting actual in-use activity; 
•Consideration of rebuilding/ 
remanufacturing practices; 
•Updated certification and in-use 
testing protocols; 
•Incentives to encourage the 
transition to next-generation cleaner technologies as soon as possible; 
•Improvements to test procedures 
and test cycles to ensure emission reductions occur in the real-world, not only over the applicable certification test cycles. Based on the air quality need, the 
requests described above, the continued progress in emissions control technology, and the June 2016 petitions for rulemaking, EPA plans to engage with a range of stakeholders to discuss the opportunities for developing more stringent federal standards to further reduce the level of NO
Xemissions from 
heavy-duty on-highway engines, after the publication of this Final Rule. Recognizing the benefits of a nationally harmonized program and given California’s unique ability under CAA section 209 to be allowed to regulate new motor vehicle and engine emission standards if certain criteria are met, EPA intends to work closely with CARB on this effort. EPA also intends to engage with truck and engine manufacturers, suppliers, state air quality agencies, NGOs, labor, the trucking industry, and the Petitioners over the next several months as we develop our formal response to the June 2016 Petitions for Rulemaking. 
(2) Issues Related to Phase 2 
(a) Natural Gas Engines and Vehicles 
This combined rulemaking by EPA 
and NHTSA is designed to regulate two 
separate characteristics of heavy duty vehicles and engines: GHGs and fuel consumption. In the case of diesel or gasoline powered vehicles, there is a one-to-one relationship between these two characteristics. For alternatively fueled vehicles, which use no petroleum, the situation is different. For example, a natural gas vehicle that achieves approximately the same fuel efficiency as a diesel powered vehicle will emit 20 percent less CO
2; and a 
natural gas vehicle with the same fuel efficiency as a gasoline vehicle will emit 30 percent less CO
2. Yet natural gas 
vehicles consume no petroleum. The agencies are continuing Phase 1 approach, which the agencies have previously concluded balances these facts by applying the gasoline and diesel CO
2standards to natural gas engines 
based on the engine type of the natural gas engine. Fuel consumption for these vehicles is then calculated according to their tailpipe CO
2emissions. In essence, 
this applies a one-to-one relationship between fuel efficiency and tailpipe CO
2 
emissions for all vehicles, including natural gas vehicles. The agencies determined that this approach will likely create a small balanced incentive for natural gas use. In other words, it created a small incentive for the use of natural gas engines that appropriately balanced concerns about the climate impact methane emissions against other factors such as the energy security 
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125Section 612(c) of the Clean Air Act requires 
EPA to review substitutes for class I and class II 
ozone-depleting substances and to determine whether such substitutes pose lower risk than other available alternatives. EPA is also required to publish lists of substitutes that it determines are acceptable and those it determines are unacceptable. See http://www3.epa.gov/ozone/snap/refrigerants/lists/index.html , last accessed on 
March 5, 2015. 
126Listed at 40 CFR part 82, subpart G. 
127GWP values cited in this final action are from 
the IPCC Fourth Assessment Report (AR4) unless stated otherwise. Where no GWP is listed in AR4, GWP values are determined consistent with the calculations and analysis presented in AR4 and referenced materials. 128To the extent that some manufacturers 
produce HD pickups and vans on the same 
production lines or in the same facilities as LD vehicles, some A/C system technology commonality between the two vehicle classes may be developing. benefits of using domestic natural gas. 
See 76 FR 57123. 
(b) Alternative Refrigerants 
In addition to use of low-leak 
components in air conditioning system 
design, manufacturers can also decrease the global warming impact of any refrigerant leakage emissions by adopting systems that use alternative, lower global warming potential (GWP) refrigerants, to replace the refrigerant most commonly used today, HFC–134a (R–134a). HFC–134a is a potent greenhouse gas with a GWP 1,430 times greater than that of CO
2. 
Under EPA’s Significant New 
Alternatives Policy (SNAP) Program,125 
EPA has found acceptable, subject to use conditions, three alternative refrigerants that have significantly lower GWPs than HFC–134a for use in A/C systems in newly manufactured light- duty vehicles: HFC–152a, CO
2(R–744), 
and HFO–1234yf.126HFC–152a has a 
GWP of 124, HFO–1234yf has a GWP of 4, and CO
2(by definition) has a GWP of 
1, as compared to HFC–134a which has a GWP of 1,430.
127CO 2is 
nonflammable, while HFO–1234yf and HFC–152a are flammable. All three are subject to use conditions requiring labeling and the use of unique fittings, and where appropriate, mitigating flammability and toxicity. Currently, the SNAP listing for HFO–1234yf is limited to newly manufactured A/C systems in light-duty vehicles, whereas HFC–152a and CO
2have been found acceptable for 
all motor vehicle air conditioning applications, including heavy-duty vehicles. 
None of these alternative refrigerants 
can simply be ‘‘dropped’’ into existing HFC–134a air conditioning systems. In 
order to account for the unique properties of each refrigerant and address use conditions required under SNAP, changes to the systems will be necessary. Typically these changes will need to occur during a vehicle redesign cycle but can also occur during a refresh. For example, because CO
2, 
when used as a refrigerant, is physically and thermodynamically very different 
from HFC–134a and operates at much higher pressures, a transition to this refrigerant would require significant hardware changes. A transition to A/C systems designed for HFO–1234yf, which is more thermodynamically similar to HFC–134a than is CO
2, 
requires less significant hardware changes that typically include installation of a thermal expansion valve and can potentially require resized condensers and evaporators, as well as changes in other components. In addition, vehicle assembly plants require re-tooling in order to handle new refrigerants safely. Thus a change in A/C refrigerants requires significant engineering, planning, and manufacturing investments. 
EPA is not aware of any significant 
development of A/C systems designed to use alternative refrigerants in heavy- duty vehicles.
128However, all three 
lower GWP alternatives are in use or under various stages of development for use in LD vehicles. Of these three refrigerants, most manufacturers of LD vehicles have identified HFO–1234yf as the most likely refrigerant to be used in that application. For that reason, EPA anticipates that HFO–1234yf will be a primary candidate for refrigerant substitution in the HD market in the future if it is listed as an acceptable substitute under SNAP for HD A/C applications. 
As mentioned above, EPA has listed 
as acceptable, subject to use conditions, two lower-GWP refrigerants, R–744 (CO
2) and HFC–152a, for use in HD 
vehicles. On April 18, 2016, EPA also proposed to list HFO–1234yf as acceptable, subject to use conditions, in A/C systems for newly manufactured MDPVs, HD pickup trucks, and complete HD vans (81 FR 22810). In that action, EPA proposed to list HFO– 1234yf as acceptable, subject to use conditions, for those vehicle types for which human health and environmental risk could be assessed using the currently available risk assessments and analysis on LD vehicles. Also in that action, EPA requested ‘‘information on development of HFO–1234yf MVAC systems for other HD vehicle types or off-road vehicles, or plans to develop these systems in the future.’’ EPA also stated ‘‘This information may be used to inform a future listing’’ (81 FR 22868). 
In another rulemaking action under 
the SNAP program, on July 20, 2015, EPA published a final rule (80 FR 42870) that will change the listing status of HFC–134a to unacceptable for use in newly manufactured LD motor vehicles beginning in MY 2021 (except as allowed under a narrowed use limit for use in newly manufactured LD vehicles destined for use in countries that do not have infrastructure in place for servicing with other acceptable refrigerants through MY 2025). In that same rule, EPA listed the refrigerant blends SP34E, R–426A, R–416A, R–406A, R–414A, R– 414B, HCFC Blend Delta, Freeze 12, GHG–X5, and HCFC Blend Lambda as unacceptable for use in newly manufactured light-duty vehicles beginning in MY 2017. EPA’s decisions were based on the availability of other substitutes that pose less overall risk to human health and the environment, when used in accordance with required use conditions. Neither the April 2016 proposed rule nor the July 2015 final rule consider a change of listing status for HFC–134a in HD vehicles. 
LD vehicle manufacturers are 
currently making investments in systems designed for lower-GWP refrigerants, both domestically and on a global basis. In support of the LD GHG rule, EPA projected a full transition of LD vehicles to lower-GWP alternatives in the United States by MY 2021. We expect the costs of transitioning to decrease over time as alternative refrigerants are adopted across all LD vehicles and trucks, in part due to increased availability of components and the continuing increases in refrigerant production capacity, as well as knowledge gained through experience. As lower-GWP alternatives become widely used in LD vehicles, some HD vehicle manufacturers may wish to also transition their vehicles. Transitioning could be advantageous for a variety of reasons, including platform standardization and company environmental stewardship policies. 
In the proposal for this Phase 2 HD 
rule, EPA proposed another action related to alternative refrigerants. EPA proposed to allow a manufacturer to be ‘‘deemed to comply’’ with the leakage standard if its A/C system used a refrigerant other than HFC–134a that was both listed as an acceptable substitute refrigerant for heavy-duty A/ C systems under SNAP, and was identified in the LD GHG regulations at 40 CFR 86.1867–12(e). 80 FR 40172. By slightly reducing the regulatory burden of compliance with the leakage standard for a manufacturer that used an alternative refrigerant, the ‘‘deemed to comply’’ provision was intended to provide a modest incentive for the use 
of such refrigerants. There were comments in support of this approach, 
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129Vehicles produced by installing a used engine 
into a new chassis are commonly referred to as 
‘‘gliders,’’ ‘‘glider kits,’’ or ‘‘glider vehicles.’’ See Section I.E.i and XIII.B. 130EPA is amending its rules applicable to 
engines installed in glider kits, which will affect emission standards not only for GHGs but for criteria pollutants as well. EPA is also clarifying its requirements for certification and revising its definitions for glider kit and glider vehicle manufacturers. NHTSA is not including glider vehicles under its Phase 2 fuel consumption standards. See Section XIII.B. including from Honeywell and 
Chemours, both of which manufacture HFO–1234yf. 
For several reasons, EPA has 
reconsidered the proposed ‘‘deemed to comply’’ provision for this rule, and instead, the Phase 2 program retains the Phase 1 requirement that manufacturers attest that they are using low-leak components, regardless of the refrigerant they use. CARB and several NGO commenters expressed concerns about the proposed ‘‘deemed to comply’’ provision, primarily citing the potential for manufacturers to revert to less leak-tight components if they were no longer required to attest to the use of low-leak A/C system components because they used a lower-GWP refrigerant. In general, we expect that the progress LD vehicle manufacturers are making toward more leak-tight A/C systems will continue and that this progress will transfer to HD A/C systems. Still, we agree that continued improvements in low-leak performance HD vehicles is an important goal, and that continuing the Phase 1 leakage requirements in the Phase 2 program should discourage manufacturers from reverting to higher-leak and potentially less expensive components. It is also important to note that there is no ‘‘deemed to comply’’ option in the parallel LD–GHG program— manufacturers must attest to meeting the leakage standard. There is no compelling reason to have a different regime for heavy duty applications. 
Although leakage of lower-GWP 
refrigerants is of less concern from a climate perspective than leakage of higher GWP refrigerants, we also agree with several commenters that expressed a concern related to the servicing of lower-GWP systems with higher-GWP refrigerants in the aftermarket. We agree that this could result due to factors such as price differentials between aftermarket refrigerants. However, as is the case for Phase 1, as a part of certification, HD manufacturers will attest both to the use of low-leak components as well as to the specific refrigerant used. Thus, in the future, a manufacturer wishing to certify a vehicle with an A/C system designed for an alternative refrigerant will attest to the use of that specific refrigerant. In that situation, any end-user servicing and recharging that A/C system with any other refrigerant would be considered tampering with an emission- related component under Title II of the CAA. For example, recharging an A/C system certified to use a lower-GWP refrigerant, such as HFO–1234yf, with 
any other refrigerant, including but not limited to HFC–134a, would be considered a violation of Title II tampering provisions. 
At the same time, EPA does not 
believe that finalizing the ‘‘deemed to comply’’ provision would have had an impact on any future transition of the HD industry to alternative refrigerants. As discussed above, two lower-GWP refrigerants are already acceptable for use in HD vehicles, and EPA has proposed to list HFO–1234yf as acceptable, subject to use conditions, for limited HD vehicle types. As also discussed above, and especially in light of the rapid expansion of alternative refrigerants that has been occurring in the LD vehicle market, similar trends may develop in the HD vehicle market, regardless of EPA’s action regarding leakage of alternative refrigerants in this final rule. 
(c) Small Business Issues 
The Regulatory Flexibility Act (RFA) 
generally requires an agency to prepare 
a regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or any other statute unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. See generally 5 U.S.C. 601–612. The RFA analysis is discussed in Section XIV. 
Pursuant to section 609(b) of the RFA, 
as amended by the Small Business Regulatory Enforcement Fairness Act (SBREFA), EPA also conducted outreach to small entities and convened a Small Business Advocacy Review Panel to obtain advice and recommendations of representatives of the small entities that potentially will be subject to the rule’s requirements. Consistent with the RFA/ SBREFA requirements, the Panel evaluated the assembled materials and small-entity comments on issues related to elements of the Initial Regulatory Flexibility Analysis (IRFA). A copy of the Panel Report was included in the docket for this rule. 
The agencies previously determined 
that the Phase 2 regulations could potentially have a significant economic impact on small entities. Specifically, the agencies identified four categories of directly regulated small businesses that could be impacted: 
•Trailer Manufacturers 
•Alternative Fuel Converters 
•Vocational Chassis Manufacturers 
•Glider Vehicle
129Assemblers To minimize these impacts the 
agencies are adopting certain regulatory 
flexibilities—both general and category- specific. In general, we are delaying new requirements for EPA GHG emission standards by one initial year and simplifying certification requirements for small businesses. Even with this one year delay, small businesses will be required to comply with EPA’s standards before NHTSA’s fuel efficiency standards are mandatory. Because of this timing, compliance with NHTSA’s regulations will not be delayed, as small business manufacturers will be accommodated through EPA’s initial one year delay. The agencies are also providing the following specific relief: 
•Trailers: Adopting simpler 
requirements for non-box trailers, which are more likely to be manufactured by small businesses; reduced reliance on emission averaging; and making third- party testing easier for certification. 
•Alternative Fuel Converters: 
Omitting recertification of a converted vehicle when the engine is converted and certified; reduced N
2O testing; and 
simplified onboard diagnostics and delaying required compliance with each new standard by one model year. 
•Vocational Chassis: Less stringent 
standards for certain vehicle categories; opportunity to generate credits under the Phase 1 program. 
•Glider Vehicle Assemblers:
130 
Exempting existing small businesses, but limiting the small business exemption to a capped level of annual production (production in excess of the capped amount will be allowed, but subject to all otherwise applicable requirements including the Phase 2 standards). Providing additional flexibility for newer engines. 
These flexibilities are described in 
more detail in Section XIV, in RIA Section 12 and in the Panel Report. Flexibilities specific to glider vehicle assemblers are described in Section XIII. 
(d) Confidentiality of Test Results and 
GEM Inputs 
The agencies received mixed 
comments regarding the question of whether GEM inputs should be made available to public. Some commenters supported making this information available, while others thought it should 
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be protected as confidential business 
information (CBI). In accordance with Federal statutes, EPA does not release information from certification applications (or other compliance reports) that we determine to be CBI under 40 CFR part 2. Consistent with section 114(c) of the CAA, EPA does not consider emission test results to be CBI after introduction into commerce of the certified engine or vehicle. (However, we have generally treated test results as protected before the introduction into commerce date). EPA has not yet made a final determination for Phase 1 or Phase 2 certification test results. Nevertheless, at this time we expect to continue this policy and consider it likely that we would not treat any test results or other GEM inputs as CBI after the introduction into commerce date as identified by the manufacturer. 
With regard to NHTSA’s treatment of 
confidential business information, manufacturers must submit a request for confidentiality with each electronic submission specifying any part of the information or data in a report that it believes should be withheld from public disclosure as trade secret or other confidential business information. A form is available through the NHTSA Web site to request confidentiality. NHTSA does not consider manufacturers to continue to have a business case for protecting pre-model report data after the vehicles contained within that report have been introduced into commerce. 
(e) Delegated Assembly and Secondary 
Manufacturers 
In EPA’s existing regulations (40 CFR 
1068.261), we allow engine manufacturers to sell or ship engines that are missing certain emission-related components if those components will be installed by the vehicle manufacturer. These provisions already apply to Phase 1 vehicles as well, providing a similar allowance for vehicle manufacturers to 
sell or ship vehicles that are missing 
certain emission-related components if 
those components will be installed by a secondary vehicle manufacturer. See 
section 1037.620. EPA has found this provision to work well and is finalizing certain amendments in this rule. See 40 CFR 1037.621. Under the amended rule, as conditions of this allowance, manufacturers will be required to: 
•Have a contractual obligation with the 
secondary manufacturer to complete 
the assembly properly and provide instructions about how to do so 
•Keep records to demonstrate 
compliance 
•Apply a temporary label to the 
incomplete vehicles •Take other reasonable steps to ensure 
the assembly is completed properly 
•Describe in its application for 
certification how it will use this allowance 
Under delegated assembly, it is the 
upstream manufacturer that holds the 
certificate and assumes primary responsibility for all compliance requirements. Our experience applying this approach has shown that holding the upstream manufacturer responsible ensures that they will exercise due diligence throughout the process. 
EPA proposed to apply this new 
section broadly. However, commenters raised valid questions about whether it is necessary to apply this formal process as broadly as proposed. In response, we have reconsidered the proposed approach and have determined that it would be appropriate to allow a less formal process with components for which market forces will make it unlikely that a secondary manufacturer would not complete assembly properly. In those cases, the certifying manufacturers will be required to provide sufficiently detailed installation instructions to the secondary manufacturers, who would then be obligated to complete assembly properly before the vehicles are delivered to the ultimate purchasers. 
One example of a case for which 
market forces could ensure that assembly is completed properly would be air conditioning leakage requirements. Purchasers will have the expectation that the systems will not leak, and a secondary manufacturer should have no incentive to not follow the certifying manufacturer’s instructions. 
As revised, § 1037.621 will require the 
formal delegated assembly process for the following technologies if they are part of the OEM’s certified configuration but not shipped with the vehicle: 
•Auxiliary power units 
•Aerodynamic devices 
•Hybrid components 
•Natural gas fuel tanks 
Certificate holders will remain 
responsible for other certified 
components, but will not automatically be required to comply with the formal delegated assembly requirements. That determination will be made case-by-case as part of the certification process. We are also explicitly making the flexibility in 40 CFR 1037.621 available for HD pickups and vans certified to the standards in 40 CFR part 86. As is currently specified in 40 CFR 1068.261, EPA will retain the authority to apply additional necessary conditions (at the time of certification) to the allowance to delegate assembly of emission to 
secondary manufacturers (when emission control equipment is not shipped with the vehicle to the secondary manufacturer, as just noted). In particular, we would likely apply such additional conditions for manufacturers that we determine to have previously not completed assembly properly. Issues of delegated assembly are addressed in more detail in Section 1.4.4 of the RTC. 
(f) Engine/Vehicle Useful Life 
We received comment on what 
policies we should adopt to address the 
situation where the engine and the vehicle are subject to emission standards over different useful-life periods. For example, a medium heavy- duty engine may power vehicles in weight classes ranging from 2b to 8, with correspondingly different regulatory useful lives for those vehicles. As provided in 40 CFR 1037.140 of the final regulations, we have structured the vehicle regulations to generally apply the same useful life for the vehicle that applies for the engines. However, these regulations also allow vehicle manufacturers to certify their vehicles to longer useful lives. The agencies see no problem with allowing vehicles to have longer useful lives than the engines. 
(g) Compliance Reports 
The agencies received comment on 
the NPRM from two environmental 
organizations requesting that the agencies make available to the public data and information that would enable the public to track trends in technology sales over time, as well as track company-specific compliance data. The commenters suggested that this should include an agency publication of an annual compliance report for the Heavy- duty Phase 2 program. The commenters requested this information to allow all stakeholders to see how individual companies, as well as the industry overall, were performing relative to their compliance obligations (see comments from ACEEE and NRDC). 
The agencies agree with this 
comment. In the context of the light- duty vehicle GHG standards, EPA has already published four annual compliance reports which has made available to the public detailed information regarding both how individual light-duty vehicle companies have been meeting their compliance obligations, as well as summary information at the light-duty fleet level. NHTSA makes the up-to-date information on the light-duty fuel economy program available through its 
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CAFE Public Information Center (http:// 
www.nhtsa.gov/CAFE_ PIC/CAFE_
PIC_Home.htm). Information includes 
manufacturer and overall fleet standards 
and CAFE performance, credit status, and civil penalty status. This information has been helpful to increase transparency to all stakeholders and to allow the public to see how companies are progressing from one year to the next with respect to their compliance requirements. It is EPA’s intention to publish a similar annual compliance report for the heavy duty GHG program, covering both the existing Phase 1 program, as well as the Phase 2 standards contained in this final rule. It is NHTSA’s intention to expand the Public Information Center to include the medium- and heavy-duty fuel efficiency program and to make up-to-date information collected in the heavy-duty fuel efficiency compliance process available publicly. Both the EPA and NHTSA compliance reports will provide available information at the vehicle subclass level for each of the four vehicle categories (i.e. Tractors, Trailers, 
Vocational, and Heavy-Duty Pickups and Vans), and EPA will provide available information for the other GHG standards, such as N
2O and refrigerant 
leak detection standards. Prior to issuing the compliance reports, EPA and NHTSA will work with regulated manufacturers to reconcile concerns over the release of claimed confidential business information, consistent with 40 CFR part 2 and 49 CFR 512. 
(3) Life Cycle Emissions 
The agencies received many 
comments expressing concerns about 
establishing the GHG and fuel consumption standards as tailpipe standards that do not account for upstream emissions or other life cycle impacts. However, many other commenters supported this approach. Comments specifically related to alternative fuels or electric vehicles are addressed in Section I.C.(1)(d) and in Section XI.B. This section addresses the issue more broadly. 
As discussed below, the agencies do 
not see how we could accurately account for life cycle emissions in our vehicle standards, nor have commenters shown that such an accounting is needed. In addition, NHTSA has already noted that the fuel efficiency standards are necessarily tailpipe-based, and that a lifecycle approach would likely render it impossible to harmonize the fuel efficiency and GHG emission standards, to the great detriment of our goal of achieving a national, harmonized program. See 76 FR 57125. It is also worth noting that EPA’s 
engine and vehicle emission standards 
and NHTSA’s vehicle fuel consumption standards (including those for light-duty vehicles) have been in place for decades as tailpipe standards. The agencies find no reasonable basis in the comments or elsewhere to change fundamentally from this longstanding approach. 
Although the final standards do not 
account for life cycle emissions, the agencies have estimated the upstream emission impact of reducing fuel consumption for heavy-duty vehicles. As shown in Section VII and VIII, these upstream emission reductions are significant and worth estimating, even with some uncertainty. However, this analysis would not be a sufficient basis for inclusion in the standards themselves. 
(a) Challenges for Addressing Life Cycle 
Emissions With Vehicle Standards 
Commenters supporting accounting 
for life cycle emissions generally did so 
in the context of one or more specific technologies. However, the agencies cannot accurately address life-cycle emissions on a technology specific basis at this time for two reasons: 
•We lack data to address each 
technology, and see no path to selectively apply a life cycle analysis to some technologies, but not to others. 
•Actual life cycle emissions are 
dependent on factors outside the scope of the rulemaking that may change in the future. 
With respect to the first reason, even 
if we were able to accurately and fully account for life cycle impacts of one technology (such as weight reduction), this would not allow us to address life cycle emissions for other technologies. For example, how would the agencies address potential differences in life cycle emissions for shifting from a manual transmission to and AMT, or the life cycle emissions of aerodynamic fairings? If we cannot factor in life cycle impacts for all technologies, how would we do it for weight reductions? Given the complexity of these rules and the number of different technologies involved, we see no way to treat the technologies equitably. Commenters do not provide the information necessary to address this challenge, nor are the agencies aware of such information. 
The second reason is just as 
problematic. This rulemaking is setting standards for vehicles under specific statutory provisions. It is not regulating manufacturing processes, distribution practices, or the locations of manufacturing facilities. And yet each of these factors could impact life cycle emissions. So while we could take a snapshot of life cycle emissions at this 
point in time for specific manufacturers, it may or may not have any relation to life cycle emissions in 2027, or for other manufacturers. Consider, for example, two component manufacturers: One that produces its components near the vehicle assembly plant, and relies on natural gas to power its factory; and a second that is located overseas and relies on coal-fired power. How would the agencies equitably (or even non- arbitrarily) factor in these differences without regulating these processes? To the extent commenters provided any information on life cycle impacts, they did not address this challenge. 
(b) Need for Life Cycle Consideration in 
the Standards 
The agencies acknowledge that a full 
and accurate accounting of life cycle emissions (if it were possible) could potentially make the Phase 2 program marginally better. However, we do not agree that this is an issue of fundamental importance. While some commenters submitted estimates of the importance of life cycle emissions for light-duty vehicles, life cycle emissions are less important for heavy-duty vehicles. Consider, for example, the difference between a passenger car and a heavy-duty tractor. If the passenger car achieves 40 mile per gallon and travels 150,000 miles in its life, it would 
consume less than 4,000 gallons of fuel in its life. On the other hand, a tractor that achieves 8 miles per gallon and travels 1,000,000 miles would consume 125,000 gallons of fuel in its life, or more than 30 times the fuel of the passenger car. Commenters provide no basis to assume the energy consumption associated with tractor production would be 30 times that of the production of a passenger car. 
(4) Amendments to the Phase 1 Program 
The agencies are revising some test 
procedures and compliance provisions 
used for Phase 1. These changes are described in Section XII. This includes both amendments specific to Phase 1, as well as amendments that apply more broadly than Phase 1, such as the revisions to the delegated assembly provisions. As a drafting matter, EPA notes that we are moving the GHG standards for Class 2b and 3 pickups and vans from 40 CFR 1037.104 to 40 CFR 86.1819–14. 
NHTSA is also amending 49 CFR part 
535 to make technical corrections to its Phase 1 program to better align with EPA’s compliance approach, standards and CO
2performance results. In general, 
these changes are intended to improve the regulatory experience for regulated 
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parties and also reduce agency 
administrative burden. More specifically, NHTSA is changing the rounding of its standards and performance values to have more significant digits. Increasing the number of significant digits for values used for compliance with NHTSA standards reduces differences in credits generated and overall credit balances for the EPA and NHTSA programs. NHTSA is also removing the petitioning process for off- road vehicles, clarifying requirements for the documentation needed for submitting innovative technology requests in accordance with 40 CFR 1037.610 and 49 CFR 535.7, and adding further detail to requirements for submitting credit allocation plans as specified in 49 CFR 535.9. Finally, NHTSA is adding the same recordkeeping requirements that EPA currently requires to facilitate in-use compliance inspections. These changes are intended to improve the regulatory experience for regulated parties and also reduce agency administrative burden. 
The agencies received few comments 
on these changes, with most supporting the proposed changes or suggesting improvements. These comments as well as the few comments opposing any of these changes are discussed in Section XII and in the RTC. 
(5) Other Amendments to EPA 
Regulations 
EPA is finalizing certain other 
changes to regulations that we proposed, which are not directly related to the HD Phase 1 or Phase 2 programs, as detailed in Section XIII. For these amendments, there are no corresponding changes in NHTSA regulations. Some of these amendments relate directly to heavy-duty highway engines, but not to the GHG programs. Others relate to nonroad engines. This latter category reflects the regulatory 
structure EPA uses for its mobile source regulations, in which regulatory provisions applying broadly to different types of mobile sources are codified in common regulatory parts such as 40 CFR part 1068. This approach creates a broad regulatory structure that regulates highway and nonroad engines, vehicles, and equipment collectively in a common program. Thus, it is appropriate to include some amendments to nonroad regulations in addition to the changes applicable only for highway engines and vehicles. 
Except as noted below, the agencies 
received relatively few significant comments on these issues. All comments are discussed in more detail in Section XIII and in the RTC. One area, for which we did receive significant comment was the issue of 
competition vehicles. As described in Section XIII, EPA is not finalizing the proposed clarification related to highway vehicles used for competition. 
(a) Standards for Engines Installed In 
Glider Kits 
EPA regulations currently allow used 
pre-2013 engines to be installed into new glider kits without meeting currently applicable standards. As described in Section XIII.B, EPA is amending its regulations to allow only engines that have been certified to meet standards for the model year in which the glider vehicle is assembled (i.e. current model year engine standards) to be installed in new glider kits, with certain exceptions. First, engines certified to earlier MY standards that are identical to the current model year standards may be used. Second, engines still within their useful life (and certain similar engines) may be used. Note that this would not allow use of the pre-2002 engines that are currently being used in most glider vehicles because they all would be outside of the 10-year useful life period. Finally, the interim small manufacturer allowance for glider vehicles will also apply for the engines used in the exempted glider kits. Comments on this issue are summarized and addressed in Section XIII.B and in RTC Section 14.2. 
(b) Nonconformance Penalty Process 
Changes 
Nonconformance penalties (NCPs) are 
monetary penalties established by regulation that allow a vehicle or engine manufacturer to sell engines that do not meet the emission standards. Manufacturers unable to comply with the applicable standard pay penalties, which are assessed on a per-engine basis. 
On September 5, 2012, EPA adopted 
final NCPs for heavy heavy-duty diesel engines that could be used by manufacturers of heavy-duty diesel engines unable to meet the current oxides of nitrogen (NO
X) emission 
standard. On December 11, 2013 the U.S. Court of Appeals for the District of Columbia Circuit issued an opinion vacating that Final Rule. It issued its mandate for this decision on April 16, 2014, ending the availability of the NCPs for the current NO
Xstandard, as 
well as vacating certain amendments to the NCP regulations due to concerns about inadequate notice. In particular, the amendments revise the text explaining how EPA determines when NCP should be made available. In the Phase 2 NPRM, EPA re-proposed most of these amendments to provide fuller notice and additional opportunity for public comment. As discussed in Section XIII, although EPA received one comment opposing these amendments, they are being finalized as proposed. 
(c) Updates to Heavy-Duty Engine 
Manufacturer In-Use Testing Requirements 
EPA and manufacturers have gained 
substantial experience with in-use testing over the last four or five years. This has led to important insights in ways that the test protocol can be adjusted to be more effective. We are accordingly making changes to the regulations in 40 CFR part 86, subparts N and T. 
(d) Extension of Certain 40 CFR Part 
1068 Provisions to Highway Vehicles and Engines 
As part of the Phase 1 GHG standards, 
we applied the exemption and importation provisions from 40 CFR part 1068, subparts C and D, to heavy- duty highway engines and vehicles. We also specified that the defect reporting provisions of 40 CFR 1068.501 were optional. In an earlier rulemaking, we applied the selective enforcement auditing under 40 CFR part 1068, subpart E (75 FR 22896, April 30, 2010). We are adopting the rest of 40 CFR part 1068 for heavy-duty highway engines and vehicles, with certain exceptions and special provisions. 
As described above, we are applying 
all the general compliance provisions of 40 CFR part 1068 to heavy-duty engines and vehicles subject to 40 CFR parts 1036 and 1037. We are also applying the recall provisions and the hearing procedures from 40 CFR part 1068 for highway motorcycles and for all vehicles subject to standards under 40 CFR part 86, subpart S. 
EPA is updating and consolidating the 
regulations related to formal and informal hearings in 40 CFR part 1068, subpart G. This will allow us to rely on a single set of regulations for all the different categories of vehicles, engines, and equipment that are subject to emission standards. We also made an effort to write these regulations for improved readability. 
We are also making a number of 
changes to part 1068 to correct errors, to add clarification, and to make adjustments based on lessons learned from implementing these regulatory provisions. 
(e) Amendments to Engine and Vehicle 
Test Procedures in 40 CFR Parts 1065 and 1066 
EPA is making several changes to our 
engine testing procedures specified in 
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40 CFR part 1065. None of these 
changes will significantly impact the stringency of any standards. 
(f) Amendments Related to Marine 
Diesel Engines in 40 CFR Parts 1042 and 1043 
EPA’s emission standards and 
certification requirements for marine diesel engines under the Clean Air Act and the act to Prevent Pollution from Ships are identified in 40 CFR parts 1042 and 1043, respectively. EPA is amending these regulations with respect to continuous NO
Xmonitoring and 
auxiliary engines, as well as making several other minor revisions. 
(g) Amendments Related to Locomotives 
in 40 CFR Part 1033 
EPA’s emission standards and 
certification requirements for locomotives under the Clean Air Act are identified in 40 CFR part 1033. EPA is making several minor revisions to these regulations. 
(6) Other Amendments to NHTSA 
Regulations 
NHTSA proposed to amend 49 CFR 
parts 512 and 537 to allow manufacturers to submit required compliance data for the Corporate Average Fuel Economy (CAFE) program electronically, rather than submitting some reports to NHTSA via paper and CDs and some reports to EPA through its VERIFY database system. NHTSA is not finalizing this proposal in this rulemaking and will consider electronic submission for CAFE reports in a future action. 
II. Vehicle Simulation and Separate 
Engine Standards for Tractors and Vocational Chassis 
A. Introduction 
This Section II. describes two 
regulatory program elements that are 
common among tractors and vocational 
chassis. In contrast, Sections III and V respectively describe the regulatory program elements that are unique to 
tractors and to vocational chassis. The common elements described here are the vehicle simulation approach to vehicle certification and the separate standards for engines. Section II.B discusses the reasons for this Phase 2 regulatory approach; namely, requiring vehicle simulation for tractor and vocational chassis certification, 
maintaining separate engine standards, and expanding and updating their related mandatory and optional test procedures. Section II.C discusses in detail the evolution and final version of the vehicle simulation computer program, which is called the Greenhouse gas Emissions Model or 
‘‘GEM.’’ Section II.C also discusses the evolution and final versions of the test procedures for determining the GEM inputs that are common for tractors and vocational chassis. Section II.D discusses in detail the separate engine standards for GHGs and fuel efficiency and their requisite test procedures. 
In this final action, the agencies have 
built on the success of the Phase 1 GEM- based approach for the certification of tractors and vocational chassis. To better recognize the real-world impact of vehicle technologies, we have expanded the number of required and optional vehicle inputs into GEM. Inputting these additional details into GEM results in more accurate representations of vehicle performance and greater opportunities to demonstrate reductions in CO
2emissions and fuel consumption. 
We are also finalizing revisions to the vehicle driving patterns that are programmed into GEM to better reflect real-world vehicle operation and the emissions reductions that result from applying GHG and fuel efficiency technologies to vehicles. As a result of these revisions, the final GEM-based vehicle certification approach necessitates new testing of engines and testing of some other vehicle components to generate the additional GEM inputs for Phase 2. More detail is provided in Section II.C. 
Based on our assessments of the 
technological feasibility; cost effectiveness; requisite lead times for implementing new and additional tractor and vocational vehicle technologies; and based on comments we received in response to our notice of proposed rulemaking and in response to our more recent notice of additional data availability, the agencies are finalizing steadily increasing stringencies of the CO
2and fuel 
consumption standards for tractors and vocational chassis for vehicle model years 2021, 2024 and 2027. See Section I or Sections III and V respectively for these numerical standards for tractors and vocational chassis. As part of our analytical process for determining the numerical values of these standards, the agencies utilized GEM. Using GEM as an integral part of our own standard-setting process helps ensure consistency 
between our technology assessments and the GEM-based certification process that we require for compliance with the Phase 2 standards. Our utilization of GEM in our standard-setting process is described further in Section II.C. 
For Phase 2 we are finalizing, as 
proposed, the same Phase 1 certification approach for all of the GHG and fuel efficiency separate engine standards for those engines installed in tractors and vocational chassis. For the separate engine standards, we will continue to require the Phase 1 engine dynamometer certification test procedures, which were adopted substantially from EPA’s existing heavy- duty engine emissions test procedures. In this action we are finalizing, as proposed, revisions to the weighting factors of the tractor engine 13-mode steady-state test cycle (i.e., the 
Supplemental Engine Test cycle or ‘‘SET’’). The SET is required for determining tractor engine CO
2 
emissions and fuel consumption. Consistent with the rationale we presented in our proposal and consistent with comments we received, these revised SET weighting factors better reflect the lower engine speed operation of modern engines, which frequently occurs at tractor cruise speeds. We used these revised weighting factors as part of our engine technology assessments of both current engine technology (i.e., our ‘‘baseline 
engine’’ technology) and future engine technology. 
Based on our assessments of the 
technological feasibility; cost effectiveness; requisite lead times for implementing new and additional engine technologies; and based on comments we received in response to our notice of proposed rulemaking and in response to our more recent notice of additional data availability, the agencies are finalizing steadily increasing stringencies of the CO
2and fuel 
consumption separate engine standards for engine model years 2021, 2024 and 2027. In addition, for each of these model years, EPA is maintaining the Phase 1 separate engine standards for CH
4and N 2O emissions—both at their 
Phase 1 numeric values. While EPA is not finalizing at this time more stringent N
2O emissions standards, as originally 
proposed, EPA may soon revisit these separate engine N
2O standards in a 
future rulemaking. All of the final Phase 2 separate engine standards are presented in Section II.D, along with our related assessments. 
B. Phase 2 Regulatory Structure 
As proposed, in this final action the 
agencies have built on the success of the 
Phase 1 GEM-based approach for the certification of tractors and vocational chassis, while also maintaining the Phase 1 separate engine standards approach to engine certification. While the regulatory structures of both Phase 1 and Phase 2 are quite similar, there are a number of new elements for Phase 2. Note that we are not applying these new 
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131Oak Ridge National Laboratory results 
docketed for the NODA: EPA–HQ–OAR–2014– 
0827–1622 and NHTSA–2014–0132–0183. Southwest Research Institute results docketed for the NODA: EPA–HQ–OAR–2014–0827–1619 and NHTSA–2014–0132–0184. 
132Ibid. Phase 2 elements for compliance with 
the Phase 1 standards. 
These modifications for Phase 2 are 
consistent with the agencies’ Phase 1 commitments to consider a range of regulatory approaches during the development of future regulatory efforts (76 FR 57133), especially for vehicles not already subject to full vehicle chassis dynamometer testing. For example, we committed to consider a more sophisticated approach to vehicle testing to more completely capture the complex interactions within the total vehicle, including the engine and powertrain performance. We also committed to consider the potential for full vehicle certification of complete tractors and vocational chassis using a chassis dynamometer test procedure. We also considered chassis dynamometer testing of complete tractors and vocational chassis as a complementary approach for validating a more complex vehicle simulation approach. We committed to consider the potential for a regulatory program for some of the trailers hauled by tractors. After considering these various approaches, the agencies proposed a 
structure in which regulated tractor and vocational chassis manufacturers would additionally enter engine and powertrain-related inputs into GEM, which was not part of in Phase 1. 
The basic structure in the proposal 
was widely supported by commenters, although some commenters supported changing certain aspects. Some commenters suggested revising GEM to recognize additional technologies, such as tire pressure monitoring systems and electronic controls that decrease fuel consumption while a vehicle is coasting. To the extent that the agencies were able to collect and receive sufficient data to support such revisions in GEM, these changes were made. See Section II.C. for details. For determining certain GEM inputs, some commenters suggested more cost-effective test procedures for separate engine and transmission testing, compared to the engine-plus-transmission powertrain test procedure that the agencies proposed. In collaboration with researchers at engine manufacturer test laboratories, at Oak Ridge National 
Laboratory and at Southwest Research Institute, the agencies completed a number of laboratory evaluations of these suggested test procedures.
131 
Based on these results, which were made available to the public for a 30- day comment period in the NODA, the agencies are finalizing these more cost- effective test procedures as options, in addition to the powertrain test procedure we proposed. We note that we are also finalizing some of these more cost-effective test procedures, the cycle average approach for all vehicle cycles, as optional for the testing of ‘‘pre-transmission’’ hybrids. In response to our request for comment, some commenters expressed support for a so- called, ‘‘cycle-average’’ approach for generating engine map data for input into GEM. This approach facilitates an 
accurate recognition of an engine’s transient performance. The agencies further refined this approach, and we made detailed information on this approach available in the NODA.
132 
Based on comments, we are finalizing this approach as mandatory for mapping engines over GEM’s transient cycle, and we are allowing this approach as optional for GEM’s 55 mph and 65 mph cycles. 
Some commenters expressed concern 
about GEM and our proposed tractor standards appropriately accounting for the performance of powertrain technologies installed in some of the largest specialty tractors. We have addressed this concern by finalizing a new ‘‘heavy-haul’’ tractor sub-category, with a unique payload and vehicle masses in GEM, which result in a unique set of numeric standards for these vehicles. This is explained in detail in Section III.D. Other commenters expressed concern about the greater complexity of GEM’s additional inputs and the appropriateness of our proposed vocational chassis standards, as applied 
to certain custom-built vocational chassis. We have addressed these concerns by finalizing a limited number of optional custom chassis standards, tailored according to a vocational chassis’ final application (e.g., school 
bus, refuse truck, cement mixer, etc.). To address the concerns about GEM’s complexity for these specialty vehicles, these optional custom chassis standards require a smaller number of GEM inputs. This is explained in detail in Section V.D. 
Some vehicle manufacturers did not 
support the agencies finalizing separate engine standards. However, as described below, the agencies continue to believe that separate engine standards are necessary and appropriate. Thus, the agencies are finalizing the basic rule structure that was proposed, but with a number of refinements. 
For trailer manufacturers, which will 
be subject to first-time standards under Phase 2, we will apply the standards using a GEM-based certification, but to do so without actually running GEM. More specifically, based on the agencies’ analysis of the results of running GEM many times and varying GEM’s trailer configurations, the agencies have developed a simple equation that replicates GEM results, based on inputting certain trailer values into the equation. Use of the equation, rather than full GEM, should significantly facilitate trailer certification. As described in Chapter 2.10.5 of the RIA, the equation has a nearly perfect correlation with GEM, so that they can be used instead of GEM, without impacting stringency. This is a result of the relative simplicity of the trailer inputs as compared to the tractor 
and vocational vehicle inputs. 
(1) Other Structures Considered 
To follow-up on the commitment to 
consider other approaches, the agencies 
spent significant time and resources before the proposal in evaluating six different options for demonstrating compliance with the proposed Phase 2 standards as shown in Figure II.1 
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As shown in Figure II.1 these six 
options include: 
1. Full vehicle simulation, where 
vehicle inputs are entered into 
simulation software. 
2. Vehicle simulation, supplemented 
with separate engine standards. 
3. Controllers-in-the-loop simulation, 
where an actual electronic transmission controller module (TCM) and an actual engine controller module (ECM) are tested in hardware. 
4. Engine-in-the-loop simulation, with 
or without a TCM, where at least the engine is tested in hardware. 
5. Vehicle simulation with 
powertrain-in-the-loop, where the engine and transmission are tested in hardware. One variation involves an engine standard. 
6. Full vehicle chassis dynamometer 
testing. 
The agencies evaluated these options 
in terms of the capital investment required of regulated manufacturers to conduct the testing and/or simulation, the cost per test, the accuracy of the simulation, and the challenges of validating the results. Other considerations included the representativeness compared to the real world behavior, maintaining existing Phase 1 certification approaches that are known to work well, enhancing the Phase 1 approaches that could use improvements, the alignment of test procedures for determining GHG and non-GHG emissions compliance, and the potential to circumvent the intent of the test procedures. The agencies presented our evaluations in the proposal, and we received comments on some of these approaches, and these comments were considered carefully in our evaluations for this final action. Notably, in this final action we are adopting a combination of these options, where some are mandatory and others are optional for certification via GEM. We have concluded that this combination of these options strikes an optimal balance between their costs, accuracy with respect to real-world performance, and robustness for ensuring compliance. In this section we present our evaluation and rationale for finalizing these Phase 2 certification approaches. 
Chassis dynamometer testing (Option 
6) is used extensively in the development and certification of light- duty vehicles. It also is used in Phase 1 to certify complete Class 2b/3 pickups and vans, as well as to certify certain incomplete vehicles (at the manufacturer’s option). The agencies considered chassis dynamometer testing more broadly as a heavy-duty fuel efficiency and GHG certification option because chassis dynamometer testing has the ability to evaluate a vehicle’s performance in a manner that most closely resembles the vehicle’s in-use performance. Nearly all of the fuel efficiency technologies can be evaluated simultaneously on a chassis dynamometer, including the vehicle systems’ interactions that depend on the behavior of the engine, transmission, and other vehicle electronic controllers. One challenge associated with the application of wide-spread heavy-duty chassis testing is the small number of heavy-duty chassis test sites that are available in North America. As discussed in RIA Chapter 3, the agencies were only able to locate 11 heavy-duty chassis test sites. However, more recently we have seen an increased interest in building new sites since issuing the Phase 1 Final Rule. For example, EPA is currently building a heavy-duty chassis dynamometer with the ability to test up to 80,000 pound vehicles at the National Vehicle and Fuel Emissions Laboratory in Ann Arbor, Michigan. 
Nevertheless, the agencies continue to 
be concerned about requiring a chassis test procedure for certifying tractors or vocational chassis due to the initial cost of a new test facility and the large number of heavy duty tractor and vocational chassis variants that could require testing. We have also concluded that for heavy-duty tractors and vocational chassis, there can be increased test-to-test variability under chassis dynamometer test conditions, versus other approaches. First, the agencies recognize that such testing 
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13303–19034 TASK 2 Report-Paper 03-Class8_ hil_
DRAFT, September 30, 2013. 
134GEM Validation, Technical Research 
Workshop, San Antonio, December 10–11, 2014. 135Oak Ridge National Laboratory results 
docketed for the NODA: EPA–HQ–OAR–2014– 0827–1622 and NHTSA–2014–0132–0183. 
Southwest Research Institute results docketed for the NODA: EPA–HQ–OAR–2014–0827–1619 and NHTSA–2014–0132–0184. 
136Eaton, Greenhouse gas emissions and fuel 
efficiency standards for medium- and heavy-duty engines and vehicles—Phase 2, 80 FED. REG. 40,137—Docket ID NOS. EPA–HQ–OAR–2014– 0827, October 1, 2015. 
137https://engines.paccar.com/technology/
research-development/. 
13803–19034 TASK 2 Report-Paper 03-Class8_ hil_
DRAFT, September 30, 2013. requires expensive, specialized 
equipment that is not widely available. The agencies estimate that it would vary from about $1.3 to $4.0 million per new test site depending on existing facilities.
133In addition, the large 
number of heavy-duty vehicle configurations would require significant amounts of testing to cover the sector. For example, for Phase 1 tractor manufacturers typically certified several thousand variants of one single tractor model. Finally, EPA’s evaluation of heavy-duty chassis dynamometer testing has shown that the variation of chassis test results is greater than light-duty testing, up to 3 percent worse, based on our sponsored testing at Southwest Research Institute.
134The agencies’ 
research identified a number of unique sources of test-to-test variability in HD chassis dynamometer testing versus other types of testing (described next). These unique sources include variations in HD tire performance and tire temperature and pressure stability; variations in human driver performance; and variations in the test facilities’ heating, ventilation and air conditioning system affecting emissions after- treatment performance (e.g., increased 
fuel consumption to maintain after- treatment temperature) and engine accessory power (e.g., engine fan 
clutching). Although the agencies are not requiring chassis dynamometer certification of tractors and vocational chassis, we believe such an approach could potentially be appropriate in the future for some heavy duty vehicles if more test facilities become available and if the agencies are able to address the large number of vehicle variants that might require testing and the unique sources of test-to-test variability. Note, as discussed in Section II.C.(4) we are finalizing a manufacturer-run complete tractor heavy-duty chassis dynamometer test program for monitoring relative trends fuel efficiency and for comparing those trends to the trends indicated via GEM simulation. While the agencies did not receive significant comment on the appropriateness of full vehicle heavy- duty chassis dynamometer testing for certification, the agencies did receive significant, mostly negative, comment on the costs versus benefits of a manufacturer-run complete tractor heavy-duty chassis dynamometer test program for data collection. These 
comments and our responses are detailed in Section II.C.(4). Another option considered for 
certification involves testing a vehicle’s 
powertrain in a modified engine dynamometer test facility, which is part of option 5 shown in Figure II.1. In this case the engine and transmission are installed together in a laboratory test facility, and a dynamometer is connected to the output shaft of the transmission. GEM or an equivalent vehicle simulation computer program is then used to control the dynamometer to simulate vehicle speeds and loads. The step-by-step test procedure considered for this option was initially developed as an option for hybrid powertrain testing for Phase 1. We are not finalizing this approach as mandatory, but we are allowing this as an option for manufacturers to generate powertrain inputs for use in GEM. For Phase 2 we generally require this test procedure for evaluating hybrid powertrains for inputs into GEM, but there are certain exceptions where engine-only test procedures may be used to certify hybrids via GEM (e.g., pre-transmission hybrids). 
A key advantage of the powertrain test 
approach is that it directly measures the effectiveness of the engine, the transmission, and the integration of these two components. Engines and transmissions are particularly challenging to simulate within a computer program like GEM because the 
engines and transmissions installed in vehicles today are actively and interactively controlled by their own sophisticated electronic controls; namely the ECM and TCM. 
We believe that the capital investment 
impact on manufacturers for powertrain testing is reasonable; especially for those who already have heavy-duty engine dynamometer test facilities. We have found that, in general, medium- duty powertrains can be tested in heavy- duty engine test cells. EPA has successfully completed such a test facility conversion at the National Vehicle and Fuel Emissions Laboratory in Ann Arbor, Michigan. Southwest Research Institute (SwRI) in San Antonio, Texas has completed a similar test cell conversion. Oak Ridge National Laboratory in Oak Ridge, Tennessee has been operating a recently constructed heavy heavy-duty powertrain dynamometer facility, and EPA currently has an interagency agreement with DOE to fund EPA powertrain testing at ORNL. The results from this testing were published for a 30-day comment period, as part of the NODA.
135Eaton Corporation has been operating a heavy-duty powertrain test 
cell and has provided the agencies with valuable test results and other comments.
136PACCAR recently 
constructed and began operation of a powertrain test cell that includes engine, transmission and axle test capabilities.
137EPA also contracted 
SwRI to evaluate North America’s capabilities (as of 2014) for powertrain testing in the heavy-duty sector and the cost of installing a new powertrain cell that meets agency requirements.
138 
Results from this 2014 survey indicated that one supplier (Eaton) already had this capability. We estimate that the upgrade costs to an existing engine test facility are on the order of $1.2 million, and a new test facility in an existing building are on the order of $1.9 million. We also estimate that current powertrain test cells that could be upgraded to measure CO
2emissions 
would cost approximately $600,000. For manufacturers or suppliers wishing to contract out such testing, SwRI estimated that a cost of $150,000 would provide about one month of powertrain testing services. Once a powertrain test cell is fully operational, we estimate that for a nominal powertrain family (i.e. one engine family tested with one 
transmission family), the cost for powertrain installation, testing, and data analysis would be about $70,000 in calendar year 2016, in 2016 dollars. Since the NPRM in July 2015, the agencies and other stakeholders have completed significant new work toward refining the powertrain test procedure itself, and these results confirm the robustness of this approach. The agencies regulations provide details of the final powertrain test procedure. See 40 CFR 1037.550. 
Furthermore, the agencies have 
worked with key transmission suppliers to develop an approach to define transmission families. Coupled with the agencies’ existing definitions of engine families (40 CFR 1036.230 and 
1037.230), we are finalizing powertrain family definitions in 40 CFR 1037.231 and axle and transmission families in 40 CFR 1037.232. 
Even though there is conclusive 
evidence that powertrain testing is a 
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139H. Zhang, J, Sanchez, M, Spears, ‘‘Alternative 
Heavy-duty Engine Test Procedure for Full Vehicle 
Certification,’’ SAE Int. J. Commer. Veh. 8(2): 2015, 
doi:10.4271/2015–01–2768. 
140G. Salemme, E.D., D. Kieffer, M. Howenstein, 
M. Hunkler, and M. Narula, An Engine and Powertrain Mapping Approach for Simulation of Vehicle CO
2Emissions. SAE Int. J. Commer. Veh, 
October 2015. 8: p. 440–450. 
141Cummins, Inc., Comments in Response to 
Greenhouse Gas Emissions and Fuel Efficiency 
Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2 (Docket ID No. EPA–HQ– 
OAR–2014–0827 and Docket ID No. NHTSA–2014– 0132). 
142Paccar, Inc., Greenhouse Gas Emissions and 
Fuel Efficiency Standards for Medium- and Heavy- Duty Engines and Vehicles; Phase 2; Proposed Rule, 80 FR 40138 (July 13, 2015); Docket I.D. No.: EPA– HQ–OAR–2014–0827 and NHTSA–2014–0132. 
143Daimler Trucks North America LLC, Detroit 
Diesel Corporation, And Mercedes-Benz USA, Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles, Phase 2, Proposed Rule, Docket ID No: EPA–HQ–OAR–2014–0827 and NHTSA–2014– 0132; 80 FR 40137 (July 13, 2015). 
144Volvo Group, Greenhouse Gas Emissions and 
Fuel Efficiency Standards for Medium- and Heavy- Duty Engines and Vehicles, Phase 2, Proposed Rule, Dockets ID No: EPA–HQ–OAR–2014–0827 and NHTSA–2014–0132;80 FR 40137 (July 13, 2015). 
145Navistar, Greenhouse Gas Emissions and Fuel 
Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles, Phase 2, Proposed Rule, Dockets ID No: EPA–HQ–OAR–2014–0827 and NHTSA–2014–0132;80 FR 40137 (July 13, 2015). technically robust and cost-effective 
approach to evaluating the CO 2and fuel 
consumption performance of powertrains, and even though there has been a clear trend toward manufacturers and other test laboratories recognizing the benefits and investing in new powertrain testing facilities, the agencies also received significant negative comment regarding the sheer amount of powertrain testing that could be required to certify the large number of unique configurations (i.e., unique 
combinations of engines and 
transmissions). While the agencies proposed to allow manufacturers to group powertrains in powertrain families, as defined by the EPA in 40 CFR 1037.231, requiring powertrain testing broadly would still likely require a large number of tests. To address these concerns, while at the same time achieving most of the advantages of powertrain testing, the agencies are also finalizing some mandatory and optional test procedures to separately evaluate engine transient performance (via the mandatory ‘‘cycle-average’’ approach for the transient cycle) and transmission efficiency performance. While neither of these test procedures capture the optimized shift logic and other benefits of deep integration of the engine and transmission controllers, which only powertrain testing can capture, these separate test procedures do capture the remaining benefits of powertrain testing. The advantage of these separate tests is that their results can be mixed and matched within GEM to represent many more combinations of engines and transmissions than a comparable number of powertrain tests. For example, separately testing three parent engines that each have two child ratings and separately efficiency testing three transmissions that each have three major calibrations requires the equivalent test time of testing 6 powertrains, but without requiring the use of a powertrain test facility. More importantly, the results of these 6 tests can be combined within GEM to certify at least 27 different powertrain families, which would otherwise have required 27 powertrain tests—more than a four- fold increase in costs. This example clearly shows how cost-effective a vehicle simulation approach to vehicle certification can be. 
Another regulatory structure option 
considered by the agencies was engine- only testing over the GEM duty cycles over a range of simulated vehicle configurations, which is part of Option 4 in Figure II.1. This is essentially a ‘‘cycle-average approach,’’ which would use GEM to generate engine duty cycles by simulating a range of transmissions 
and other vehicle variations. These engine-level duty cycles would then be programmed into a separate controller of a dynamometer connected to an engine’s output shaft. The agencies requested comment on this approach, and based on continued research that has been conducted since the proposal, and based on comments we received in response to the NODA, we are finalizing this approach as mandatory for determining the GEM inputs that characterize an engine’s transient engine performance within GEM over the ARB Transient duty cycle. We are also finalizing this approach as optional for characterizing the more steady-state engine operation in GEM over the 55 mph and 65 mph duty cycles with road grade, in lieu of steady-state engine mapping for these two cycles. We are also finalizing this approach as an option for certifying pre-transmission hybrids, in lieu of powertrain testing. We are calling this approach the ‘‘cycle- average’’ approach, which generates a cycle-average engine fuel map that is input into GEM. This map simulates an engine family’s performance over a given vehicle drive cycle, for the full range of vehicles into which that engine could be installed. Unlike the chassis dynamometer or powertrain dynamometer approaches, which could have significant test facility construction or modification costs, this engine-only approach necessitates little capital investment because engine manufacturers already have engine test facilities to both develop engines and to certify engines to meet both EPA’s non- GHG standards and the agencies’ Phase 1 fuel efficiency and GHG separate engine standards. This option has received significant attention since our notice of proposed rulemaking. EPA and others have published peer reviewed journal articles demonstrating the efficacy of this approach,
139 140 and the 
agencies have received significant comments on both the information we presented in the proposal and in the NODA. Comments have been predominantly supportive, and the comments we received tended to focus on ideas for further minor refinements of this test procedure.
136 141 142 143 144 145  At this time the agencies believe that the wealth of experimental data supporting the robustness and cost-effectiveness of the cycle-average approach, supports the agencies’ decision to finalize this test procedure as mandatory for the determination of the transient performance of engines for use in GEM (i.e., over the ARB Transient Cycle). 
The agencies also considered 
simulating the engine, transmission, and vehicle using a computer program; while having the actual transmission electronic controller connected to the computer running the vehicle simulation program, which is part of Option 3 in Figure II.1. The output of the simulation would be an engine cycle that would be used to test the engine in an engine test facility. Just as in the cycle-average approach, this procedure would not require significant capital investment in new test facilities. An additional benefit of this approach would be that the actual transmission controller would be determining the transmission gear shift points during the test, without a transmission manufacturer having to reveal their 
proprietary transmission control logic. This approach comes with some significant technical challenges, however. The computer model would have to become more complex and tailored to each new transmission and controller to make sure that the controller would operate properly when it is connected to a computer instead of an actual transmission. Some examples of the transmission specific requirements would be simulating all the Controller Area Network (CAN) communication to and from the transmission controller and the specific sensor responses both through simulation and hardware. Each vehicle manufacturer would have to be 
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responsible for connecting the 
transmission controller to the computer, which would require a detailed verification process to ensure it is operating properly while it is in fact disconnected from a real transmission. Determining full compliance with this test procedure would be a significant challenge for the regulatory agencies because the agencies would have to be able to replicate each of the manufacturer’s unique interfaces between the transmission controller and computer running GEM. The agencies did not receive any significant comments on this approach, presumably because commenters focused on the more viable options of powertrain testing and the cycle-average engine mapping approach. And because of the significant challenges noted above, the agencies did not pursue this option further between the time of proposal and this final action. However, should this approach receive more research attention in the future, such that the concerns noted above are sufficiently addressed, the agencies could consider allowing this certification approach as an option, within the context of a separate future rulemaking. 
Finally, the agencies considered full 
vehicle simulation plus separate engine standards (Option 2 in Figure II.1), which is the required approach being finalized for Phase 2. This approach is discussed in more detail in the following sections. It should be noted before concluding this subsection that the agencies do provide a regulatory path for manufacturers to apply for approval of alternative test methods that are different than those the agencies specify. See 40 CFR part 1065, subpart A. Therefore, even though we have not finalized some of the certification approaches and test procedures that we investigated, our conclusions about these procedures do not prevent a manufacturer from seeking agency approval of any of these procedures or any other alternative procedures. 
(2) Final Phase 2 Regulatory Structure 
Under the final Phase 2 structure, 
tractor and vocational chassis 
manufacturers will be required to 
provide engine, transmission, drive axle(s) and tire inputs into GEM (as well as the inputs already required under Phase 1). For Phase 1, GEM used fixed default values for all of these, which limited the types of technologies that could be recognized by GEM to show compliance with the standards. We are expanding GEM to account for a wider range of technological improvements that would otherwise need to be recognized through the more cumbersome off-cycle crediting 
approach in Phase 1. Additional technologies that will now be recognized in GEM also include lightweight thermoplastic materials, automatic tire inflation systems, tire pressure monitoring systems, advanced cruise control systems, electronic vehicle coasting controls, engine stop- start idle reduction systems, automatic engine shutdown systems, hybrids, and axle configurations that decrease the number of drive axles. The agencies are also continuing separate engine standards. As described below, we see advantages to having both engine-based and vehicle-based standards. Moreover, the advantages described here for full vehicle simulation do not necessarily correspond to disadvantages for engine testing or vice versa. 
(a) Advantages of Vehicle Simulation 
The agencies’ primary purpose in 
developing fuel efficiency and GHG 
emissions standards is to increase the use of vehicle technologies that improve fuel efficiency and decrease GHG emissions. Under the Phase 1 tractor and vocational chassis standards, there is no regulatory incentive for vehicle 
manufacturers to consider adopting new engine, transmission or axle technologies because GEM was not configured to recognize these technologies uniquely, leaving off-cycle credits as the only regulatory mechanism to recognize these technologies’ benefits. By recognizing such technologies in GEM under Phase 2, the agencies will be creating a direct regulatory incentive to improve engine, transmission, and axle technologies to improve fuel efficiency and decrease GHG emissions. In its 2014 report, NAS also recognized the benefits of full vehicle simulation and recommended that the Phase 2 rules incorporate such an approach.
160 
The new Phase 2 approach will create 
three new specific regulatory incentives. First, vehicle manufacturers will have an incentive to use the most efficient engines. Since GEM will no longer use the agency default engine in simulation, manufacturers will have their own engines recognized in GEM. Under 
Phase 1, engine manufacturers have a regulatory incentive to design efficient engines, but vehicle manufacturers do not have a similar regulatory incentive to use the most efficient engines in their vehicles. Second, the new Phase 2 approach will create incentives for both engine and vehicle manufacturers to design engines and vehicles to work together to ensure that engines actually operate as much as possible near their most efficient points. This is because Phase 2 GEM will require the vehicle manufacturers to input specific transmission, axle, and tire characteristics, thus recognizing powertrain optimization, such as engine down-speeding, and different transmission architectures and technologies, such as automated manual transmissions, automatic transmissions, and different numbers of transmission gears, transmission gear ratios, axle ratios and tire revolutions per mile. No matter how well designed, all engines have speed and load operation points with differing fuel efficiency and GHG emissions. The speed and load point with the best fuel efficiency (i.e., peak 
thermal efficiency) is commonly known as the engine’s ‘‘sweet spot.’’ The more frequently an engine operates near its sweet spot, the better the vehicle’s fuel efficiency will be. In Phase 1, a vehicle manufacturer receives no regulatory credit under GEM for designing its vehicle to operate closer to its engine’s sweet spot because Phase 1 GEM does not model the specific engine, transmission, axle, or tire revolutions per mile of the vehicle. Third, this approach will recognize improvements to the overall efficiency of the drivetrain, including the axle. The new version of GEM will recognize the benefits of different integrated axle technologies including axle lubricants (via an optional axle efficiency test), and technologies that reduce axle losses such as by enabling three-axle vehicles to deliver power to only one rear axle. This is accomplished through the simulation of axle disconnect technology (see Chapter 4.5 of the RIA). The new version of GEM also will be able to recognize the benefits of reducing energy losses within a transmission, via an optional transmission efficiency test. 
In addition to providing regulatory 
incentives to use more fuel efficient technologies, expanding GEM to recognize engine and other powertrain component improvements will provide important flexibility to vehicle manufacturers. Providing flexibility to effectively trade engine and other powertrain component improvements against the other vehicle improvements that are recognized in GEM will allow vehicle manufacturers to better optimize their vehicles to achieve the lowest cost for specific customers. Because of the improvements in GEM, GEM will recognize this deeper level of vehicle optimization. Vehicle manufacturers could use this flexibility to reduce overall compliance costs and/or address special applications where certain vehicle technologies are not preferred or 
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practical. The agencies considered in 
Phase 1 allowing the exchange of emission certification credits generated relative to the separate brake-specific engine standards and credits generated relative to the vehicle standards. However, we did not allow this in Phase 1 due in part to concerns about the equivalency of credits generated relative to different standards, with different units of measure and different test procedures. The Phase 2 approach eliminates these concerns because engine and other vehicle component improvements will be evaluated relative to the same vehicle standard in GEM. This also means that under the Phase 2 approach there is no need to consider allowing emissions credit trading between engine-generated and vehicle- generated credits because vehicle 
manufacturers are directly credited by the combination of engine and vehicle technologies they choose to install in each vehicle. Therefore, this approach eliminates one of the concerns about continuing separate engine standards, which was that a separate engine standard and a full vehicle standard were somehow mutually exclusive. That is not the case. In fact, in the next section we describe how we are continuing the separate engine standard along with recognizing engine performance at the vehicle level. The agencies acknowledge that maintaining a separate engine standard will limit flexibility in cases where a vehicle manufacturer wanted to use less efficient engines and make up for them using more efficient vehicle technologies. However, as described below, we see important advantages to maintaining a separate engine standard, and we believe they more than justify the reduced flexibility. Furthermore, in response to comments about some specialized vocational custom chassis, the agencies are finalizing a limited number of optional standards that would be met using a somewhat simplified version of GEM. Specifically, in this simplified version of GEM, which is only applicable as an option for certain custom chassis applications, the GEM inputs for the engine, transmission gears, gear ratios, gear efficiency; axle ratio, axle efficiency; and tire revolutions per mile are all fixed to default values. This simplification allows the option of certifying these custom chassis without penalty for utilizing less efficient engines, transmissions, or axles. This flexibility also addresses a comment the agencies received from Cummins that the inclusion of the specific engine in GEM limits the flexibility provided by the separate engine standards’ emissions 
averaging, banking and trading program. Cummins explained that certain applications like emergency vehicles, cement mixers and recreational vehicles oftentimes require higher-performance, less-efficient, engines, which are credit using engines under the ABT program of the separate engine standards. Because these particular vehicle applications have few other cost-effective and practical vehicle-level technologies with which to offset their use of less efficient engines, the main Phase 2 vocational chassis standards that require engine and other powertrain inputs into GEM (i.e., the standards for other than custom 
chassis vocational vehicles) could be particularly challenging for these applications. However, the optional custom chassis standards solves this issue for custom chassis applications. This approach solves two issues. First, it provides a means toward certification for these custom chassis applications, without penalty for using the engines they need. Second, this approach maintains the flexibility intended by the separate engine standards’ averaging, banking and trading program since these custom chassis applications would still be using certified engines. 
One disadvantage of recognizing 
engines and transmission in GEM is that it will increase complexity for the vehicle standards. For example, vehicle manufacturers will be required to conduct additional engine tests and to generate additional GEM inputs for compliance purposes. However, we believe that most of the burden associated with this increased complexity will be an infrequent burden of engine testing and updating information systems to track these inputs. Furthermore, the agencies are requiring that engine manufacturers certify their respective GEM inputs; namely, their own engine maps. Because there are a relatively small number of heavy-duty engine manufacturers who will be responsible for generating and complying with their declared engine maps for GEM, the overall engine testing burden to the heavy-duty vehicle industry is small. With this approach, the large number of vocational chassis manufacturers will not have to conduct any engine testing. 
Another potential disadvantage to 
GEM-based vehicle certification is that because GEM measures performance over specific duty cycles intended to represent average operation of vehicles in-use, this approach might also create an incentive to optimize powertrains and drivetrains for the best GEM 
performance rather than the best in-use performance for a particular application. This is always a concern when selecting 
duty cycles for certification, and so is not an issue unique to GEM. There will always be instances, however infrequent, where specific vehicle applications will operate differently than the duty cycles used for certification. The question is would these differences force manufacturers to optimize vehicles to the certification duty cycles in a way that decreases fuel efficiency and increases GHG emissions in-use? We believe that the certification duty cycles will not create a disincentive for manufacturers to properly optimize vehicles for customer fuel efficiency. First, the impact of the certification duty cycles versus any other real-world cycle will be relatively small because they affect only a small fraction of all vehicle technologies. 
Second, the emission averaging and fleet average provisions mean that the regulations will not require all vehicles to meet the standards. Vehicles exceeding a standard over the duty cycles because they are optimized for different in-use operation can be offset by other vehicles that perform better over the certification duty cycles. Third, vehicle manufacturers also have the ability to lower such a vehicle’s measured GHG emissions by adding technology that would improve fuel efficiency both over the certification duty cycles and in-use (and to be potentially eligible to generate off-cycle credits in doing so). These standards are not intended to be at a stringency where manufacturers will be expected to apply all technologies to all vehicles. Thus, there should be technologies available to add to vehicle configurations that initially fail to meet the Phase 2 standards. Fourth, we are further sub- categorizing the vocational vehicle segment compared to Phase 1, tripling the number of subcategories within this segment from three to nine. These nine subcategories will divide each of the three Phase 1 weight categories into three additional vehicle speed categories. Each of the three speed categories will have unique duty cycle weighting factors to recognize that different vocational chassis are configured for different vehicle speed applications. This further subdivision better recognizes technologies’ performance under the conditions for which the vocational chassis was configured to operate. This also decreases the potential of the certification duty cycles to encourage manufacturers to configure vocational chassis differently than the optimum configuration for specific customers’ applications. Similarly, for the tractor 
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category we are finalizing a new ‘‘heavy- 
haul’’ category to recognize the greater payload and vehicle mass of these tractors, as well as their limitations to effectively utilize some technologies like aerodynamic technologies. These new categories help minimize differences between GEM simulation and real-world operation. Finally, we are also recognizing seven specific vocational vehicle applications under the optional custom chassis vocational vehicle standards. 
Another disadvantage of our full 
vehicle simulation approach is the potential requirement for engine manufacturers to disclose information to vehicle manufacturers who install their engines that engine manufacturers might consider to be proprietary. Under this approach, vehicle manufacturers may need to know some additional details about engine performance long before production, both for compliance planning purposes, as well as for the actual submission of applications for certification. Moreover, vehicle manufacturers will need to know details about the engine’s performance that are generally not publicly available— specifically the detailed steady-state fuel consumption map of an engine. Some commenters expressed significant concern about the Phase 2 program forcing the disclosure of proprietary steady-state engine performance information to business competitors; especially prior to an engine being introduced into commerce. It can be argued that a sufficiently detailed steady-state engine map, such as the one required for input into GEM, can reveal proprietary engine design elements such as intake air, turbo-charger, and exhaust system design; exhaust gas recirculation strategies; fuel injection strategies; and exhaust after-treatment thermal management strategies. Conversely, the agencies also received comments requesting that all GEM inputs be made public, as a matter of transparency and public interest. 
It is unclear at this point whether 
such information is truly proprietary. In accordance with Federal statutes, EPA does not release information from certification applications (or other compliance reports) that we determine to be Confidential Business Information (CBI) under 40 CFR part 2. Consistent with section 114(c) of the CAA, EPA does not consider emission test results to be CBI after introduction into 
commerce of the certified engine or vehicle. However, we have generally treated test results as protected before a 
product’s introduction into commerce 
date. EPA has not yet made a final CBI determination for Phase 1 or Phase 2 GEM inputs. Nevertheless, at this time 
we expect to continue our current policy of non-disclosure prior to introduction into commerce, but we consider it likely that we would ultimately not treat any test results or other GEM inputs as CBI after the 
introduction into commerce date, as identified by the manufacturer. 
To further address the specific 
concern about the Phase 2 program forcing the disclosure of proprietary steady-state engine maps to business competitors, especially prior to an engine being introduced into commerce, the agencies are finalizing an option for engine manufacturers to certify only ‘‘cycle average’’ engine maps over the 55-mph and 65-mph GEM cycles and separately mandating the cycle average approach for use over the ARB Transient cycle. See Section II.B. above. The advantage to this approach is that each data point of a cycle average map represents the average emissions over an entire cycle. Therefore, the cycle average engine map approach does not reveal any potentially proprietary information about an engine’s performance at a particular steady-state point of operation. 
(b) Advantages of Separate Engine 
Standards 
For engines installed in tractors and 
vocational vehicle chassis, we are maintaining separate engine standards for fuel consumption and GHG emissions in Phase 2 for both spark- ignition (SI, generally but not exclusively gasoline-fueled) and compression-ignition (CI, generally but not exclusively diesel-fueled) engines. Moreover, we are adopting a sequence of new more stringent engine standards for CI engines for engine model years 2021, 2024 and 2027. While the vehicle standards alone are intended to provide sufficient incentive for improvements in 
engine efficiency, we continue to see important advantages to maintaining separate engine standards for both SI and CI engines. The agencies believe the advantages described below are critical to fully achieve the goals of the EPA and NHTSA standards. 
First, EPA has a robust compliance 
program based on separate engine testing. For the Phase 1 standards, we applied the existing criteria pollutant compliance program to ensure that engine efficiency in actual use reflected the improvements manufacturers claimed during certification. With engine-based standards, it is straightforward to hold engine manufacturers accountable by testing in- use engines in an engine dynamometer laboratory. If the engines exceed the standards, manufacturers can be 
required to correct the problem or perform other remedial actions. Without separate engine standards in Phase 2, addressing in-use compliance would be more subjective. Having clearly defined compliance responsibilities is important to both the agencies and to the manufacturers. 
Second, engine standards for CO
2and 
fuel efficiency force engine manufacturers to optimize engines for both fuel efficiency and control of non- CO
2emissions at the same engine 
operating points. This is of special concern for NO
Xemissions, given the 
strong counter-dependency between engine-out NO
Xemissions and fuel 
consumption. By requiring engine manufacturers to comply with both NO
X 
and CO 2standards using the same test 
procedures, the agencies ensure that manufacturers include technologies that can be optimized for both, rather than alternate, calibrations that would trade NO
Xemissions against fuel 
consumption, depending how the engine or vehicle is tested. In the past, when there was no CO
2engine standard 
and no steady-state NO Xstandard, some 
manufacturers chose this dual calibration approach instead of investing in technology that would allow them to simultaneously reduce both CO
2and NO X. 
It is worth noting that these first two 
advantages foster fair competition within the marketplace. In this respect, the separate engine standards help assure manufacturers that their competitors are not taking advantage of regulatory ambiguity. The agencies believe that the absence of separate engine standards would leave open the opportunity for a manufacturer to choose a high-risk compliance strategy by gaming the NO
X-CO 2tradeoff. 
Manufacturer concerns that competitors might take advantage of this can create a dilemma for those who wish to fully comply, but also perceive shareholder pressure to choose a high-risk compliance strategy to maintain market share. 
Finally, the existence of meaningful 
separate engine standards allows the agencies to exempt certain vehicles from some or all of the vehicle standards and requirements without forgoing the engine improvements. A good example 
of this is the off-road vehicle exemption in 40 CFR 1037.631 and 49 CFR 535.3, which exempts vehicles ‘‘intended to be used extensively in off-road environments’’ from the vehicle requirements. The engines used in such vehicles must still meet the engine standards of 40 CFR 1036.108 and 49 CFR 535.5(d). The agencies see no 
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146The specific version of GEM used to develop 
these standards, and which we propose to use for 
compliance purposes is also known as GEM 3.0. 147These attributes are recognized in Phase 1 
innovative technology provisions at 40 CFR 1037.610. reason why efficient engines cannot be 
used in such vehicles. However, without separate engine standards, there would be no way to require the engines to be efficient. The engine standards provide a similar benefit with respect to the custom chassis program discussed in Section V. 
In the past there has been some 
confusion about the Phase 1 separate engine standards somehow preventing the recognition of engine-vehicle optimization that vehicle manufacturers perform to minimize a vehicle’s overall fuel consumption. It was not the existence of separate engine standards that prevented recognition of this optimization. Rather it was that the agencies did not allow manufacturers to enter inputs into GEM that characterized unique engine performance. For Phase 2 we are requiring that manufacturers input such data because we intend for GEM to recognize this engine-vehicle optimization. The continuation of separate engine standards in Phase 2 does not undermine in any way the recognition of this optimization in GEM. 
C. Phase 2 GEM and Vehicle Component 
Test Procedures
146 
GEM was originally created for the 
certification of tractors and vocational vehicle chassis to the agencies’ Phase 1 CO
2and fuel efficiency standards. See 
76 FR 57116, 57146, and 57156–57157. For Phase 2 the agencies proposed a number of modifications to GEM, and based on public comments in response to the agencies’ proposed modifications, the agencies have further refined these modifications for this final action. 
In Phase 1 the agencies adopted a 
regulatory structure where regulated entities are required to use GEM to simulate and certify tractors and vocational vehicle chassis. This computer program is provided free of charge for unlimited use, and the program may be downloaded by anyone from EPA’s Web site: http://www3.epa.gov/otaq/climate/gem.htm. GEM mathematically combines the results of a number of performance tests of certain vehicle components, along with other pre-determined vehicle attributes and driving patterns to determine a vehicle’s characteristic levels of fuel consumption and CO
2 
emissions, for certification purposes. For Phase 1, the required inputs to GEM for tractors include vehicle aerodynamics information, tire rolling resistance, and whether or not a vehicle is equipped with certain lightweight 
high-strength steel or aluminum components, a tamper-proof speed limiter, or tamper-proof idle reduction technologies. For Phase 1, the sole input for vocational vehicles is tire rolling resistance. For Phase 1, the computer program’s inputs did not include engine test results or attributes related to a vehicle’s powertrain; namely, its transmission, drive axle(s), or tire revolutions per mile. Instead, for Phase 1 the agencies specified generic engine and powertrain attributes within GEM. For Phase 1 these are fixed and cannot be changed in GEM.
147 
Similar to other vehicle simulation 
computer programs, GEM combines various vehicle inputs with known physical laws and justified assumptions to predict vehicle performance for a 
given period of vehicle operation. GEM represents this information numerically, and this information is integrated as a function of time to calculate CO
2 
emissions and fuel consumption. Some of the justified assumptions in GEM include average energy losses due to friction between moving parts of a vehicle’s powertrain; the logical behavior of an average driver shifting from one transmission gear to the next; and speed limit assumptions such as 55 miles per hour for urban highway driving and 65 miles per hour for rural interstate highway driving. The sequence of the GEM vehicle simulation can be visualized by imagining a human driver initially sitting in a parked running tractor or vocational vehicle. The driver then proceeds to drive the vehicle over a prescribed route that includes three distinct patterns of driving: Stop-and-go city driving, urban highway driving, and rural interstate highway driving. The driver then exits the highway and brings the vehicle to a stop, with the engine still running at idle. This concludes the vehicle simulation sequence. 
Over each of the three driving 
patterns or ‘‘duty cycles,’’ GEM simulates the driver’s behavior of pressing the accelerator, coasting, or applying the brakes. GEM also simulates how the engine operates as the gears in the vehicle’s transmission are shifted and how the vehicle’s weight, aerodynamics, and tires resist the forward motion of the vehicle. GEM combines the driver behavior over the duty cycles with the various vehicle inputs and other assumptions to determine how much fuel must be consumed to move the vehicle forward at each point during the simulation. For 
Phase 2 the agencies added the effect of road grade. In GEM the effect of road grade on fuel consumption is simulated by increasing fuel consumption uphill, by the amount of fuel consumed by the engine to provide the power needed to raise the mass of the vehicle and its payload against the force of Earth’s gravity—while at the same time maintaining the duty cycle’s vehicle speed. Downhill road grades are simulated by decreasing the engine’s fuel consumption, by the amount of power returned to the vehicle by it moving in the same direction as Earth’s gravity. To maintain vehicle speed downhill, simulated brakes are sometimes applied, and the energy lost due to braking results in a certain amount of fuel consumption as well. For each of the three duty cycles, GEM totals the amount of fuel consumed and then divides that amount by the product 
of the miles travelled and tons of payload carried. The tons of payload carried are specified by the agencies for each vehicle type and weight class, and these cannot be changed in GEM. 
In addition to determining fuel 
consumption over these duty cycles, for Phase 2, GEM calculates a vehicle’s fuel consumption rate when it is stopped in traffic with the driver still operating the vehicle (i.e., ‘‘drive idle’’) and when the 
vehicle is stopped and parked with the engine still running (i.e., ‘‘parked idle’’). 
For each regulatory subcategory of tractor and vocational vehicle (e.g., sleeper cab tractor, day cab tractor, light heavy-duty urban vocational vehicle, heavy heavy-duty regional vocational vehicle, etc.), GEM applies the agencies’ prescribed weighting factors to each of the three duty cycles and to each of the two idle fuel consumption rates to represent the fraction of city driving, urban highway driving, rural highway driving, drive idle, and parked idle that is typical of each subcategory. After combining the weighted results of all the cycles and idle fuel rates, GEM then outputs a single composite result for the vehicle, expressed as both fuel consumed in gallon per 1,000 ton-miles (for NHTSA standards) and an equivalent amount of CO
2emitted in 
grams per ton-mile (for EPA standards). These are the vehicle’s GEM results that are used along with other information to demonstrate that a vehicle certificate holder (e.g., a vehicle manufacturer) 
complies with the applicable standards. This other information includes the annual sales volume of the vehicle family, plus information on emissions credits that may be generated or used as 
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148See 76 FR 57146–57147. 
149U.S. Environmental Protection Agency. ‘‘Peer 
Review of the Greenhouse Gas Emissions Model 
(GEM) and EPA’s Response to Comments.’’ EPA– 420–R–11–007. Last access on November 24, 2014 at http://www3.epa.gov/otaq/climate/documents/
420r11007.pdf. 
150See EPA’s Web site at http://www3.epa.gov/
otaq/climate/gem.htm for the Phase 1 GEM revision 
dated May 2013, made to accommodate a revision to 49 CFR 535.6(b)(3). 
151U.S. Environmental Protection Agency, GEM 
new release (GEM P2v1.1) and known issues and workarounds for GEM P2v1.0), Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2—EPA–HQ–OAR–2014–0827, August 19, 2015. 
152U.S. Environmental Protection Agency, GEM 
Power User Release for Debugging, Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2—EPA–HQ–OAR–2014–0827, January 27, 2016. 
153U.S. Environmental Protection Agency, GEM 
NODA Release, Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles— Phase 2—EPA–HQ–OAR–2014–0827, February 16, 2016. 
154U.S. Environmental Protection Agency, GEM 
Power User Release for Debugging, Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2—EPA–HQ–OAR–2014–0827, May 19, 2016. part of that vehicle family’s 
certification. 
For Phase 1 GEM’s tractor inputs 
include vehicle aerodynamics information, tire rolling resistance, and whether or not a vehicle is equipped with lightweight materials, a tamper- proof speed limiter, or tamper-proof idle reduction technologies. Other vehicle and engine characteristics in GEM were fixed as defaults that cannot be altered by the user. These defaults included tabulated data of engine fuel rate as a function of engine speed and torque (i.e., ‘‘engine fuel maps’’), 
transmissions, axle ratios, and vehicle payloads. For tractors, Phase 1 GEM simulates a tractor pulling a standard trailer. For vocational vehicles, Phase 1 GEM includes a fixed aerodynamic drag coefficient and vehicle frontal area. 
For Phase 2 new inputs are required 
and other new inputs are allowed as options. These include the outputs of new test procedures to ‘‘map’’ an engine to generate steady-state and transient, cycle-average, engine fuel rate inputs to represent the actual engine in a vehicle. As described in detail in RIA Chapter 4, certification to the Phase 2 standards will require entering new inputs into GEM to describe the vehicle’s transmission type and its number of gears and gear ratios. Manufacturers must also enter attributes that describe the vehicle’s drive axle(s) type, axle ratio and tire revolutions per mile. We are also finalizing a number of options to conduct additional component testing for the purpose of replacing some of the agencies’ ‘‘default values’’ in GEM with inputs that are based on component testing. These include optional axle and transmission power loss test procedures. We are also finalizing an optional powertrain test procedure that would replace both the required engine mapping and the agencies’ default values for a transmission and its automated shift strategy. We are also finalizing an option to generate cycle- average maps for the 55 mph and 65 mph cycles in GEM. In addition, we have made a number of improvements to the aerodynamic coast-down test procedures and associated aerodynamic data analysis techniques. While these aerodynamic test and data analysis improvements are primarily intended 
for tractors, for Phase 2 we are providing a streamlined off-cycle credit pathway for vocational vehicle aerodynamic performance to be recognized in GEM. 
As proposed, we are finalizing a 
significantly expanded number of technologies that are recognized in GEM. These include recognizing lightweight thermoplastic materials, automatic tire inflation systems, advanced cruise control systems, workday idle reduction systems, and axle configurations that decrease the number of drive axles. In response to comments and data submitted to the agencies on the Phase 2 proposal we are also finalizing inputs related to tire pressure monitoring systems and advanced electronically controlled vehicle coast systems. 
Although GEM is similar in concept 
to a number of other commercially available vehicle simulation computer programs, the applicability of GEM is unique. First, GEM was designed exclusively for manufacturers and regulated entities to certify tractor and vocational vehicle chassis to the agencies’ fuel consumption and CO
2 
emissions standards. For GEM to be effective for this purpose, the inputs to GEM include only information related to certain vehicle components and attributes that significantly impact vehicle fuel efficiency and CO
2 
emissions. For example, these include vehicle aerodynamics, tire rolling resistance, and powertrain component information. On the other hand, other attributes such as those related to a vehicle’s suspension, frame strength, or interior features are not included, where these otherwise might be included in other commercially available vehicle simulation programs that are used for other purposes. Furthermore, the simulated payload, driver behavior and duty cycles in GEM cannot be changed. Keeping these values constant helps to ensure that all vehicles are simulated and certified in the same way. However, these fixed attributes in GEM largely preclude GEM from being of much use as a research tool for exploring the effects of payload, driver behavior and different duty cycles. 
Similar to Phase 1, GEM for Phase 2 
is available free of charge for unlimited use, and the GEM source code is open source. That is, the programming source code of GEM is freely available upon request for anyone to examine, manipulate, and generally use without restriction. In contrast, commercially available vehicle simulation programs are generally not free and open source. Additional details of GEM are included in Chapter 4 of the RIA. 
GEM is a computer software program, 
and like all other software development processes the agencies periodically released a number of developmental versions of the GEM software for others to review and test during the Phase 2 rulemaking process. This type of user testing significantly helps the agencies detect and fix any problems or ‘‘bugs’’ in the GEM software. As part of Phase 1, the agencies 
conducted a peer review of GEM version 
1.0, which was the version released for the Phase 1 proposal.
148 149 In response 
to this peer review and to comments from stakeholders, EPA made changes to the version of GEM released with the Phase 1 final rule. Updates to the Phase 1 GEM were also made via Technical Amendments.
150The current version of 
Phase 1 GEM is v2.0.1, which is the version applicable for the Phase 1 standards.
150As part of the 
development of GEM for Phase 2, both a formal peer review
149and a series of 
expert reviews were conducted.
151 152 153 154  
The agencies have provided 
numerous opportunities for comment on GEM, and its iterative development. Shortly after the Phase 2 proposal’s publication in July 2015 (and before the end of the public comment period), the agencies received comments on GEM. Based on these early comments, the agencies made minor revisions to fix a few bugs in GEM and in August 2015 released an updated version of GEM to the public for additional comment, 
which also included new information on GEM road grade profiles. The agencies also extended the public comment period on the proposal, which provided at least 30 days for public comment on this slightly updated version of GEM.
153Then, in response to 
comments submitted at the close of the comment period, in early January 2016 
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155EPA–HQ–OAR–2014–0827–1621 and 
NHTSA–2014–0132–0187. 
156Memo to Docket, ‘‘Summary of Meetings and 
Conference Calls with the Truck and Engine 
Manufacturers Association to Discuss the Phase 2 
Heavy-Duty GHG Rulemaking’’, August 2016. 157Memo to Docket, ‘‘Summary of Meetings and 
Conference Calls with the Truck and Engine 
Manufacturers Association to Discuss the Phase 2 Heavy-Duty GHG Rulemaking’’, August 2016. 
158Memo to Docket, ‘‘Summary of Meetings and 
Conference Calls with Allison Transmission to Discuss the Phase 2 Heavy-Duty GHG Rulemaking’’, August 2016. 
159‘‘Heavy-Duty Phase 2 Stakeholder Meeting 
Log’’, August 2016. the agencies released a ‘‘debugging’’ 
version of GEM to a wide range of expert reviewers.
152The agencies 
provided one month for expert reviewers to provide informal feedback for debugging purposes.
152Because the 
changes for this debugging version mostly added new features to make GEM easier to use for certifying via optional test procedures, like the powertrain test, there were only minor changes to the way that GEM performed. In the March 2016 NODA, the agencies included another developmental version of GEM
153for public comment and 
provided 30 days for public comment. Based on the NREL report, which was also released as part of the NODA for public comment, the NODA version of GEM contained updated weighting factors of the duty cycles and idle cycles.
155Therefore, the outputs of GEM 
for a given vehicle configuration changed because these duty cycle weighting factors changed, but there were only minor updates to how the individual technologies were simulated in GEM. Based on comments received on the NODA, the agencies made minor changes to GEM and released another debugging version in May 2016 to manufacturers, NGOs, suppliers, and CARB staff.
154The most significant 
change to GEM for the May 2016 version was that 0.5 miles of flat road was added to the beginning and end of the 55 mph and 65 mph drive cycles in response to concerns raised by manufacturers.
156This change did not 
change the way that GEM worked, but it did change GEM results because of the change in the duty cycles. This change was made to better align GEM simulation with real-world engine operation. The agencies provided the expert reviewers with at least a 3-week period in which to review GEM and provide feedback. Details on the history of the comments the agencies received and the history of the agencies responses leading to these multiple releases of GEM can be found in Section II.C.(1). The following list summarizes the changes in GEM in response to those comments and data submitted to the agencies in response to the Phase 2 proposal, NODA and other GEM releases: 
•Revised road grade profiles for 55- 
and 65-mph cruise cycles, only minor changes since August 2015. 
•Revised idle cycles for vocational 
vehicles with new vocational cycle weightings, weightings released for 
public comment in NODA. 
•Made changes to the input file 
structures. Examples includes additions of columns for axle configuration (‘‘6×2,’’ ‘‘6×4,’’ ‘‘6×4D,’’ ‘‘4×2’’), and additions of a few more technology improvement inputs, such as ‘‘Neutral Idle,’’ ‘‘Start/Stop,’’ and ‘‘Automatic Engine Shutdown.’’ These were minor changes, all were in NODA version of GEM. 
•Made changes to the output file 
structures. Examples include an option to allow the user to select an output of detailed results on average speed, average work at the input and output of the transmission, and the numbers of shifts for each cycle (e.g., 55 mph cycle, 
65 mph cycle and the ARB Transient cycle). These were minor changes, all were in NODA version of GEM. 
•Added an input file for optional 
axle power losses (function of axle output speed and torque) and replaced a single axle efficiency value with lookup table of power loss. These were minor changes to streamline the use of GEM, all were in NODA version of GEM. 
•Modified engine torque response to 
be more realistic, with a fast response region scaled by engine displacement, and a slower torque response in the turbo-charger’s highly boosted region. These were minor changes, all were in NODA version of GEM. 
•Added least-squares regression 
models to interpret cycle-average fuel maps for all cycles. These were minor changes to streamline the use of GEM, all were in NODA version of GEM. 
•Added different fuel properties 
according to 40 CFR 1036.530. This was a fix to align GEM with regulations. 
•Improved shift strategy based on 
testing data and comments received. These were minor changes, all were in NODA version of GEM. 
•Added scaling factors for 
transmission loss and inertia, per regulatory subcategory. These were minor changes, all were in NODA version of GEM. 
•Added optional input table for 
transmission power loss data. These were minor changes to streamline the use of GEM, all were in NODA version of GEM. 
•Added minimum torque converter 
lock-up gear user input for automatic transmissions. This was a minor change to streamline the use of GEM, this change was in the NODA version of GEM. 
•Revised the default transmission 
power loss tables, based on test data. This was a minor change to streamline the use of GEM, this change was in the NODA version of GEM. 
•Added neutral idle and start/stop 
effects idle portions of the ARB Transient cycle. These were minor changes, all were in NODA version of GEM 
•Adjusted shift and torque converter 
lockup strategy. This was a minor change to streamline the use of GEM, this change was in the NODA version of GEM. 
Notwithstanding these numerous 
opportunities for public comment (as well as many informal opportunities via individual meetings), some commenters maintained that they still had not received sufficient notice to provide informed comment because each proposal represented too much of a ‘‘moving target.’’
157 158 159 The agencies 
disagree. Even at proposal, Phase 2 GEM provided nearly all of the essential features of the version we are promulgating in final form. These include: (1) The reconfiguration of the engine, transmission, and axle sub- models to reflect additional designs and to receive manufacturer inputs; and (2) the addition of road grade and idle cycles for vocational vehicles, along with revised weighting factors. Moreover, the changes the agencies have made to GEM in response to public comment indicates that those comments were highly informed by the proposal. The agencies thus do not accept the contention that commenters were not afforded sufficient information to provide meaningful comment on GEM. 
(1) Description of Modifications to GEM 
From Phase 1 to Phase 2 
As explained above, GEM is a 
computer program that was originally developed by EPA specifically for manufacturers to use to certify to the Phase 1 tractor and vocational chassis standards. GEM mathematically combines the results of vehicle component test procedures with other vehicle attributes to determine a vehicle’s certified levels of fuel consumption and CO
2emissions. Again 
as explained above, for Phase 1 the required inputs to GEM include vehicle aerodynamics information, tire rolling resistance, and whether or not a vehicle is equipped with certain lightweight 
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160National Academy of Science. ‘‘Reducing the 
Fuel Consumption and GHG Emissions of Medium- 
and Heavy-Duty Vehicles, Phase Two, First Report.’’ 2014. Recommendation 3.8. high-strength steel or aluminum 
components, a tamper-proof speed limiter, or tamper-proof idle reduction technologies for tractors. The vocational vehicle inputs to GEM for Phase 1 only included tire rolling resistance. For Phase 1 GEM’s inputs did not include engine test results or attributes related to a vehicle’s powertrain; namely, its transmission, drive axle(s), or loaded tire radius. Instead, for Phase 1 the agencies specified a generic engine and powertrain within GEM, and for Phase 1 these cannot be changed in GEM. 
For this rulemaking, GEM has been 
modified as proposed and validated against a set of experimental data that represent over 130 unique vehicle variants conducted at powertrain and chassis dynamometers with the manufacturers’ provided transmission shifting tables. In addition, GEM has been validated against different types of tests when the EPA transmission default auto-shift strategy is used, which includes powertrain dynamometer tests and two truck tests running in a real- world driving route. Detailed comparisons can be seen in Chapter 4 of the RIA. As noted above, the agencies believe that this new version of GEM is an accurate and cost-effective alternative to measuring fuel consumption and CO
2over a chassis 
dynamometer test procedure. Again as noted earlier, some of the key modifications will require additional vehicle component test procedures (both mandatory and optional) to generate additional GEM inputs. The results of which will provide additional inputs into GEM. These include a new required engine test procedure to provide engine fuel consumption inputs into GEM. We proposed to measure fuel consumption as a matrix of steady-state points, but also sought comment on a newly developed engine test procedure that captures transient engine performance for use in GEM. We are specifying a combination of these procedures for the final rule—steady- state fuel maps for the highway cruise simulations, and cycle-average maps for transient simulations. As an option, cycle average maps could be also used for the highway cruise simulation as well. See Chapter 3 of the RIA for additional discussion of the fuel mapping procedures. We are also requiring inputs that describe the vehicle’s transmission type, and its number of gears and gear ratios. We are allowing an optional powertrain test procedure that would provide inputs to override the agencies’ simulated engine and transmission in GEM. In addition, in response to comments, we will also allow manufacturers to measure 
transmission efficiency in the form of the power loss tables to replace the default values in GEM. We are finalizing the proposed requirement to input a description of the vehicle’s drive axle(s), including its type (e.g., 6×4 or 6×2) and 
axle ratio. We are also finalizing the optional axle efficiency test procedure for which we sought comment. This would allow manufacturers to override the agencies’ simulated axle in GEM. Chapter 4 of the RIA details all of these GEM related input changes. 
As noted above, we are significantly 
expanding the number of technologies that are recognized in GEM. These include recognizing lightweight thermoplastic materials, automatic tire inflation systems, advanced cruise control systems, engine stop-start idle reduction systems, and axle configurations that decrease the number of drive axles. To better reflect real- world operation, we are also revising the vehicle simulation computer program’s urban and rural highway duty cycles to include changes in road grade, and including a new duty cycle to capture the performance of technologies that reduce the amount of time a vehicle’s engine is at idle during a workday. Finally, to better recognize that vocational vehicle powertrains are configured for particular applications, we are further subdividing the vocational chassis category into three different vehicle speed categories, where GEM weights the individual duty cycles’ results of each of the speed categories differently. Section 4.2 of the RIA details all these modifications. The following sub-sections provide further details on some of these key modifications to GEM. 
(a) Simulating Engines for Vehicle 
Certification 
Before describing the Phase 2 
approach, this section first reviews how engines are simulated for vehicle certification in Phase 1. As noted earlier, GEM for Phase 1 simulates the same generic engine for any vehicle in a given regulatory subcategory with a data table of steady-state engine fuel consumption mass rates (g/s) versus a 
series of steady-state engine output shaft speeds (revolutions per minute, rpm) and loads (torque, N·m). This data table is also sometimes called a ‘‘fuel map’’ or an ‘‘engine map,’’ although the term ‘‘engine map’’ can mean other kinds of data in different contexts. The engine speeds in this map range from idle to maximum governed speed and the loads range from engine motoring (negative load) to the maximum load of an engine. When GEM executes a simulation over a vehicle duty cycle, this data table is 
linearly interpolated to find a corresponding fuel consumption mass rate at each engine speed and load that is demanded by the simulated vehicle operating over the duty cycle. The fuel consumption mass rate of the engine is then integrated over each duty cycle in 
GEM to arrive at the total mass of fuel consumed for the specific vehicle and duty cycle. Under Phase 1, manufacturers were not allowed to input their own engine fuel maps to represent their specific engines in the vehicle being simulated in GEM. Because GEM was programmed with fixed engine fuel maps for Phase 1 that all manufacturers had to use, the tables themselves did not have to exactly represent how an actual engine might operate over these three different duty cycles. 
In contrast, for Phase 2 we are 
requiring manufacturers to generate their own engine fuel maps to represent each of their engine families in GEM. This Phase 2 approach is consistent with the 2014 NAS Phase 2 First Report recommendation.
160To investigate this 
approach, before proposal we examined the results from 28 individual engine dynamometer tests. Three different engines were used to generate this data, and these engines were produced by two different engine manufacturers. One engine was tested at three different power ratings (13 liters at 410, 450 & 475 bhp) and one engine was tested at two ratings (6.7 liters at 240 and 300 bhp), and other engine with one rating (15 liters 455 bhp) service classes. For each engine and rating the steady-state engine dynamometer test procedure was conducted to generate an engine fuel map to represent that particular engine in GEM. Next, with GEM, we simulated various vehicles in which the engine could be installed. For each of the GEM duty cycles we are using, namely the urban local (ARB Transient), urban highway with road grade (55 mph), and rural highway with road grade (65 mph) duty cycles, we determined the GEM result for each vehicle configuration, and we saved the engine output shaft speed and torque information that GEM created to interpolate the steady-state engine map for each vehicle configuration We then had this same engine output shaft speed and torque information programmed into an engine dynamometer controller, and we had each engine perform the same duty cycles that GEM demanded of the 
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161Memos to Docket, ‘‘Test Procedure Review 
with Cummins, Volvo, Navistar, Paccar, Daimler 
Eaton and Allison.’’ 
162Michael Ross, Validation Testing for Phase 2 
Greenhouse Gas Test Procedures and the Greenhouse Gas Emission Model (GEM) for Medium and Heavy-Duty Engines and Powertrains, Final 
Report to EPA, Southwest Research Institute, June 2016, found in docket of this rulemaking, EPA–HQ– QAR–2014–0827. 
163Cummins NODA Comments, found in Phase 2 
Docket: ID No. EPA–HQ–OAR–2014–0817, April 1, 2016. 
164Volvo Group NODA Comments, found in 
Phase 2 Docket: ID No. EPA–HQ–OAR–2014–0817, April 1, 2016. simulated version of the engine. We 
then compared the GEM results based on GEM’s linear interpolation of the engine maps to the measured engine dynamometer results. We concluded that for the 55 mph and 65 mph duty cycles, GEM’s interpolation of the steady-state data tables was sufficiently accurate versus the measured results. This is an outcome one would reasonably expect because even with changes in road grade, the 55 mph and 65 mph duty cycles do not demand rapid changes in engine speed or load. The 55 mph and 65 mph duty cycles are nearly steady-state, as far as engine operation is concerned, just like the engine maps themselves. However, for the ARB Transient cycle, we observed a consistent bias when using the steady- state maps, where GEM consistently under-predicted fuel consumption and CO
2emissions. This low bias over the 
28 engine tests ranged from 4.2 percent low to 7.8 percent low. The mean was 5.9 percent low and the 90th percentile value was 7.1 percent low. These observations are consistent with the fact that engines generally operate less efficiently under transient conditions than under steady-state conditions. 
A number of reasons explain this 
consistent trend. For example, under rapidly changing (i.e. transient) engine 
conditions, it is generally more challenging to program an engine electronic controller to respond with optimum fuel injection rate and timing, exhaust gas recirculation valve position, variable nozzle turbocharger vane position and other set points than under steady-state conditions. Transient heat and mass transfer within the intake, exhaust, and combustion chambers also tend to increase turbulence and enhance energy loss to engine coolant during transient operation. In many cases during cold transient operation, the thermal management is triggered in order to maintain optimal performance of selective catalytic reduction devices for a diesel engine. Furthermore, because exhaust emissions control is more challenging under transient engine operation, engineering tradeoffs sometimes need to be made between fuel efficiency and transient criteria pollutant emissions control. Special calibrations are typically also required to control smoke and manage exhaust temperatures during transient operation for a transient cycle. 
To account for these effects in GEM, 
the agencies have developed and are finalizing a test procedure called ‘‘cycle average’’ mapping to account for this transient behavior (40 CFR 1036.540). 
Detailed analyses and presentation of the test procedure was published in two peer-reviewed journal articles.
139,140 A 
number of commenters likewise suggested this approach. Additionally, progress has been made on further improving this test procedure since publication, based on a large number of engine dynamometer tests conducted by a variety of laboratory test facilities.
161 
Since the proposal, further refinement of the numerical schemes used for interpreting cycle average engine fuel map was also completed. The engine dynamometer tests include a Cummins medium duty ISB engine, a Navistar heavy duty N13 engine, a Volvo heavy duty D13 engine, and a Cummins heavy duty ISX engine. All testing results indicated that the new test procedure works well for the transient ARB cycle.
162In addition, Cummins in their 
NODA comments (see the following paragraph) provided additional data supporting this approach with their ISL 450 bhp rating engine. This data corroborated earlier data showing good agreement between engine dynamometer tests and the cycle average engine mapping approach.
163 
EPA solicited comment on the cycle 
average approach at proposal. 80 FR 40193. EPA also specifically provided notice and a 30-day opportunity for public comment on the possibility of requiring use of the cycle average mapping approach for the ARB Transient cycle. This was included in the version of GEM that was made available for public comment as part of the NODA
153. In response, many 
comments were received on the cycle average approach. These include comments from Cummins
163and 
Volvo.164Cummins was very supportive 
of the cycle average approach and also supported applying this approach to the 55 mph and 65 mph cruise cycles in GEM. Volvo expressed some concern over having enough time to fully evaluate this approach. The agencies believe that one of the reasons that Volvo expressed concern over having enough time to evaluate this approach is because Volvo initially declined working with the agencies to collaboratively refine this approach. At 
the same time, a number of Volvo’s competitors chose to actively coordinate laboratory testing and technical analysis to contribute to the development of this approach. We believe these other manufacturers gained a deeper understanding of the approach earlier than Volvo because they invested time and resources to make technical contributions at earlier point in time. Nevertheless, the agencies fully welcome and appreciate Volvo’s more recent active involvement in reviewing the cycle average approach and for making a number of productive suggestions for further refinement. 
While the agencies are finalizing the 
cycle average engine mapping test procedure as mandatory for the ARB Transient cycle, for the 55 mph and 65 mph GEM drive cycles, the agencies are finalizing the same steady-state mapping procedure that the agencies originally proposed. The only difference is that we are finalizing about 85 unique steady-state map points, versus the about 143 points that were proposed. See 40 CFR 1036.535 for details. We are adopting a lower number of points because many of the originally proposed points were specified for use with the ARB Transient cycle.
139Again, as an 
option, the cycle average mapping test procedure also may be used for these two cruise speed cycles, in lieu of the steady-state mapping procedure. 
(b) Simulating Human Driver Behavior 
and Transmissions for Vehicle Certification 
GEM for Phase 1 simulates the same 
generic human driver behavior and manual transmission shifting patterns for all vehicles. The simulated driver responds to changes in the target vehicle speed of the duty cycles by changing the simulated positions of the vehicle’s accelerator pedal, brake pedal, clutch 
pedal, and gear shift lever. For simplicity, in Phase 1 the GEM driver shifted at pre-specified vehicle speeds and the manual transmission was simulated as an ideal transmission that did not have any delay time (i.e., torque 
interruption) between gear shifts and did not have any energy losses associated with clutch slip during gear shifts. 
In GEM for Phase 2 we are allowing 
manufacturers to select one of four types of transmissions to represent the transmission in the vehicle they are certifying: Manual transmission (MT), automated manual transmission (AMT), automatic transmission (AT) and dual clutch transmission (DCT). For Phase 2 the agencies proposed unique transmission shifting patters to 
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165Transportation Research Board 2014. 
‘‘Reducing the Fuel Consumption and Greenhouse 
Gas Emissions of Medium- and Heavy-Duty Vehicles, Phase Two.’’ (‘‘Phase 2 First Report’’) Washington, DC, The National Academies Press. Cooperative Agreement DTNH22–12–00389. Available electronically from the National Academy Press Web site at http://www.nap.edu/catalog.php?record_ id=12845 (last accessed 
December 2, 2014). Recommendation 3.7. represent the different types of 
automated transmissions. These shifting patterns over the steady state cruise cycles has been further modified from the proposed version to be more realistic with respect to slight variations in vehicle speed due to road grade. In particular, when going downhill, the simulated vehicle is now allowed to exceed the speed target by 3 mph before the brakes are applied. In the proposed version, the driver model applied the brakes much sooner to prevent the vehicle from exceeding the speed target. This change allows the vehicle to carry additional momentum into the next hill, much the same as real drivers would. 
In the final version of GEM, the driver 
behavior and the different transmission types are simulated in the same basic manner as in Phase 1, but each transmission type features unique transmission responses that match the transmission responses we measured during vehicle testing of these three transmission types. In general the transmission gear shifting strategy for all of the transmissions is designed to shift the transmission so that it is in the most efficient gear for the current vehicle demand, while staying within certain limits to prevent unrealistically high frequency shifting (i.e., to prevent 
‘‘short-shifting’’). Some examples of these limits are torque reserve limits (which vary as function of engine speed), minimum time-in-gear and minimum fuel efficiency benefit to shift to the next gear. Some of the differences between the transmission types include a driver ‘‘double-clutching’’ during gear shifts of the manual transmission only, and ‘‘power shifts’’ and torque converter torque multiplication, slip, and lock-up in automatic transmissions only. Refer to Chapter 4 of the RIA for a more detailed description of these different simulated driver behaviors and transmission types. 
Prior to the proposal, we considered 
an alternative approach where transmission manufacturers would provide vehicle manufacturers with detailed information about their automated transmissions’ proprietary shift strategies for representation in GEM. NAS also recommended this approach.
165The advantages of this 
approach would include a more realistic representation of a transmission in GEM and potentially the recognition of 
additional fuel efficiency improving strategies to achieve additional fuel consumption and CO
2emissions 
reductions. However, there are a number of technical and compliance disadvantages of this approach. One disadvantage is that it would require the disclosure of proprietary information because some vehicle manufacturers produce their own transmissions and also use other suppliers’ transmissions. There are technical challenges too. For example, some transmission manufacturers have upwards of 40 different shift strategies programmed into their transmission controllers. Depending on in-use driving conditions, some of which are not simulated in GEM (e.g., changing payloads, changing 
tire traction) a transmission controller 
can change its shift strategy. Representing dynamic switching between multiple proprietary shift strategies would be extremely complex to simulate in GEM. Furthermore, if the agencies were to require transmission manufacturers to provide shift strategy inputs for use in GEM, then the agencies would have to devise a compliance strategy to monitor in-use shift strategies, including a driver behavior model that could be implemented as part of an in-use shift strategy confirmatory test. This too would be very complex. If manufacturers were subject to in-use compliance requirements of their transmission shift strategies, this could lead to restricting the use of certain shift strategies in the heavy-duty sector, which would in turn potentially lead to sub-optimal vehicle configurations that do not improve fuel efficiency or adequately serve the wide range of customer needs; especially in the vocational vehicle segment. For example, if the agencies were to restrict the use of more aggressive and less fuel efficient in-use shift strategies that are used only under heavy loads and steep grades, then certain vehicle applications would need to compensate for this loss of capability through the installation of over-sized and over-powered engines that are subsequently poorly matched and less efficient under lighter load conditions. Therefore, as a policy consideration to preserve vehicle configuration choice and to preserve the full capability of heavy-duty vehicles today, the agencies are intentionally not allowing transmission manufacturers to submit detailed proprietary shift strategy information to vehicle manufacturers to input into GEM. The agencies are finalizing as proposed that vehicle manufacturers can choose from among several transmission types that the agencies have already developed, 
validated, and programmed into GEM. The vehicle manufacturers will then enter into GEM their particular transmission’s number of gears and gear ratios, optionally together with power loss tables representing their transmission’s gear friction, pumping and spin losses. If a manufacturer chooses to use the optional powertrain test procedure, however, then the agencies’ transmission types in GEM would be overridden by the actual data collected during the powertrain test, which would recognize the transmission’s unique shift strategy. (Presumably, vehicle manufacturers will choose to use the optional powertrain test procedure only if their actual transmission shift strategy is more efficient compared to its respective default shift strategy simulated by GEM.) 
(c) Simulating Axles for Vehicle 
Certification 
In GEM for Phase 1 the axle ratio of 
the primary drive axle and the energy losses assumed in the simulated axle itself were the same for all vehicles. For Phase 2 the vehicle manufacturer will be required to input into GEM the axle ratio of the primary drive axle. This input will recognize the design to operate the engine at a particular engine speed when the transmission is operating in its highest transmission gear; especially for the 55 mph and 65 mph duty cycles in GEM. This input facilitates GEM’s recognition of vehicle designs that take advantage of operating the engine at the lowest possible engine speeds. This is commonly known as ‘‘engine down-speeding,’’ and the general rule-of-thumb for heavy-duty engines is that for every 100 rpm decrease in engine speed, there can be about a 1 percent decrease in fuel consumption and CO
2emissions. 
Therefore, it is important that GEM allow this value to be input by the vehicle manufacturer. Axle ratio is also straightforward to verify during any in- use compliance audit. UCS and ACEEE commented that engine down-speeding should be recognized in the agencies’ separate engine standards, rather than in the vehicle standard. The agencies disagree with this because recognizing down-speeding at the vehicle level ensures that the powertrain configuration in-use, in the real world, will lead to the engine operating at lower speeds. In contrast, the engine 
speeds specified in the separate engine standards’ test procedures are based on the engine’s maximum torque versus speed curve (i.e., lug curve) and not on 
the configuration of the powertrain to 
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166NACFE. Executive Report—6×2 (Dead Axle) 
Tractors. November 2010. See Docket EPA–HQ– 
OAR–2014–0827. which the engine is attached in a 
vehicle. This means that even if a manufacturer manipulated the engine’s lug curve such that the separate engine standards’ test procedure led to the engine operating at lower speeds during certification, that same engine could be installed in a vehicle with a powertrain configured for the engine to operate at higher engine speeds. Therefore, recognizing down-speeding within GEM, at the vehicle level, best ensures that the agencies’ test procedures and standards lead to real-world engine down-speeding in-use. 
We proposed to use a fixed axle ratio 
energy efficiency of 95.5 percent at all speeds and loads, but requested comment on whether this pre-specified efficiency is reasonable. 80 FR 40185. In general, commenters stated that the efficiency of the axle actually varies as a function of axle ratio, axle speed, and axle input torque. Therefore, we have modified GEM to accept an input data table of power loss as a function of axle speed and axle torque. The modified version of GEM subsequently interpolates this table over each of the duty cycles to represent a more realistic axle efficiency at each point of each duty cycle. The agencies specify a default axle efficiency table in GEM for any manufacturer to use. We are also finalizing an optional axle power loss test procedure that requires the use of a dynamometer test facility (40 CFR 1037.560). With this optional test procedure, a manufacturer can create an axle efficiency table for use in lieu of the EPA default table. We requested comment on this test procedure in the proposal, and we received supportive comments. Refer to 40 CFR 1037.560 of the Phase 2 regulations, which contain this test procedure. 
Moreover, the final regulations allow 
the manufacturers to develop analytical methods to derive axle efficiency tables for untested axle configurations, based on testing of similar axles. This would be similar to the analytically derived CO
2emission calculations allowed for 
pickups and vans. However, manufacturers would be required to obtain prior approval from the agencies before using analytically derived values. In addition, the agencies could conduct confirmatory testing or require a 
selective enforcement audit for any axle configuration. See 40 CFR 1037.235. 
In addition to requiring the primary 
drive axle ratio input into GEM (and an option to input an actual axle power loss data table), we are requiring that the vehicle manufacturer input into GEM whether one or two drive axles are driven by the engine. When a heavy- duty vehicle is equipped with two rear axles where both are driven by the 
engine, this is called a ‘‘6×4’’ configuration. ‘‘6’’ refers to the total number of wheel hubs on the vehicle. In the 6×4 configuration there are two front wheel hubs for the two steer wheels and tires plus four rear wheel hubs for the four rear wheels and tires (or more commonly four sets of rear dual wheels 
and tires). ‘‘4’’ refers to the number of wheel hubs driven by the engine. These are the two rear axles that have two wheel hubs each. Compared to a 6×4 configuration, a 6×2 configuration decreases axle energy loss due to friction and oil churning in two driven axles, by driving only one axle. The decrease in fuel consumption and CO
2 
emissions associated with a 6×2 versus 6×4 axle configuration can be in the range of 2.5 percent depending on specific axles, which is modeled by the power loss table.
166Therefore, in the 
Phase 2 version of GEM, if a manufacturer simulates a 6×2 axle configuration using the default axle efficiencies, GEM decreases the overall GEM result roughly by 2.5 percent on average through the power loss table. Note that GEM will similarly decrease the overall GEM result by 2.5 percent for a 4×2 tractor or Class 8 vocational chassis configuration if it has only two wheel hubs driven. If a manufacturer does not use the default efficiencies, the benefit of 6×2 and 4×2 configurations will be reflected directly in its input tables. Note that the Phase 2 version of GEM does not have an option to simulate more than two drive axles or configurations where the front axle(s) are driven or where there are more than two rear axles. The regulations specify that such vehicles are to be simulated as 6×4 vehicles in GEM. This is consistent with how the standards were developed and the agencies believe this approach will provide the appropriate incentive for manufacturers to apply the same fuel saving technologies to these vehicles, as they would to their conventional 6×4 
vehicles. Moreover, because these configurations are manufactured for specialized vehicles that require extra traction for off-road applications, they have very low sales volume and any increased fuel consumption and CO
2 
emissions from them are not significant in comparison to the overall reductions of the Phase 2 program. Note that 40 CFR 1037.631 (for off-road vocational vehicles), which is being continued from the Phase 1 program, exempts many of these vehicles from the vehicle standards because they are limited 
mechanically to low-speed operation. 
(d) Simulating Accessories for Vehicle 
Certification 
The agencies proposed to continue 
the approach from Phase 1 whereby GEM uses a fixed power consumption value to simulate the fuel consumed for powering accessories such as steering pumps and alternators. 80 FR 40186. The final rule continues the Phase 1 approach, as proposed. However, Phase 2 GEM provides an option to provide a GEM input reflecting technology improvement inputs for the accessory loads. This allows the manufacturers to receive credit for those technologies that are not modeled in GEM. Manufacturers seeking credit for those technologies that are not modeled in GEM would generally follow the off-cycle credit program procedures in 40 CFR 1037.610. 
(e) Aerodynamics in GEM for Tractor, 
Vocational Vehicle, and Trailer Certification 
Phase 2 GEM simulates aerodynamic 
drag in using C
dA (the product of the 
drag coefficient and frontal area of the vehicle) rather than a drag coefficient (C
d). For tractors and trailers we will 
continue to use an aerodynamic bin approach similar to the one that exists in Phase 1 today, although the actual Phase 2 bins are being revised to reflect new test procedures and our projections for more aerodynamic tractors and 
trailers in the future. This approach allows manufacturers to determine C
dA 
(or delta-C dA in the case of trailers) from 
coastdown testing, scale wind tunnel testing and/or computational fluid dynamics modeling. It requires tractor manufacturers (but not trailer manufacturers) to conduct a certain minimum amount of coast-down vehicle testing to validate their methods. The regulations also provide an alternate path for trailer manufacturers to rely on testing performed by component suppliers. See 40 CFR 1037. 
The results of these tests determine 
into which bin a tractor or trailer is assigned. GEM uses the aerodynamic drag coefficient applicable to the bin, which is the same for all tractors (or trailers) within a given bin. This approach helps to account for limits in the repeatability of aerodynamic testing and it creates a compliance margin since any test result which keeps the vehicle in the same aerodynamic bin is considered compliant. For Phase 2 we are establishing new boundary values for the bins themselves and we are adding two additional tractor bins in order to recognize further advances in 
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167See Section III. for a discussion of how GEM 
will model a more advanced trailer beginning with 
the 2027 model year. 168The agencies project that more than enough 
aerodynamic component vendors will take advantage of proposed optional pre-approval process to make testing optional for trailer manufacturer. aerodynamic drag reduction beyond 
what was recognized in Phase 1. Furthermore, while Phase 1 GEM used predefined frontal areas for tractors where the manufacturers input only a C
d 
value, manufacturers will use a measured drag area (C
dA) value for each 
tractor configuration for Phase 2. See 40 CFR 1037.525. The agencies do not project that vocational vehicles will need to improve their aerodynamic performance to comply with the Phase 2 vocational chassis standards. However, the agencies are providing features in GEM for vocational vehicles to receive credit for improving the aerodynamics of vocational vehicles (see 40 CFR 1037.520(m)). 
In addition to these changes, we are 
making a number of aerodynamic drag test procedure improvements. One 
improvement is to update the ‘‘standard trailer’’ that is prescribed for use during aerodynamic drag testing of a tractor. Using the C
dA from such testing means 
the standard trailer would also be the hypothetical trailer modeled in GEM to represent a trailer paired with the tractor in actual use.
167In Phase 1, a 
non-aerodynamic 53-foot long box- shaped dry van trailer was specified as the standard trailer for tractor aerodynamic testing (see 40 CFR 1037.501(g)). For Phase 2 we are modifying this standard trailer for tractor testing to make it more similar to the trailers we expect to be produced during the Phase 2 timeframe. More specifically, we are prescribing the installation of aerodynamic trailer skirts (and low rolling resistance tires as applied in Phase 1) on the standard trailer, as discussed in further in Section III.E.2. As explained more fully in Sections III and IV, the agencies believe that tractor-trailer pairings will be optimized aerodynamically to a significant extent in-use (such as using high-roof cabs when pulling box trailers), and that this real-world optimization should be reflected in the certification testing. We are also revising the test procedures to better account for average wind yaw angle to reflect the true impact of aerodynamic features on the in-use fuel consumption and CO
2 
emissions of tractors, again as discussed in more detail in Section III below. Refer to the test procedures in 40 CFR 1037.525 through 1037.527 for further details of these aerodynamic test procedures. 
For trailer certification, the agencies 
use GEM in a different way than it is used for tractor certification. As described in Section IV, the agencies 
developed a simple equation to replicate GEM performance. The trailer standards are based on this equation, and trailer manufacturers use this GEM-based equation for certification. The only technologies recognized by this GEM- based equation for trailer certification are aerodynamic technologies, tire technologies (including tire rolling resistance and tire pressure systems), and weight reduction. Note that since the purpose of this equation is to replicate GEM performance, it can be considered as simply another form of the model using a different input interface. Thus, for simplicity, the remainder of this Section II.C. sometimes discusses GEM as being used for trailers, without regard to how manufacturers will actually input GEM variables. As with all of the standards in Phase 2, compliance is measured consistent with the same test methods used by the agencies to establish the standard. 
Similar to tractor certification, trailer 
manufacturers will use data from aerodynamic testing (e.g., coastdown 
testing, scale wind tunnel testing, computational fluid dynamics modeling, or possibly aerodynamic component testing) with the equation.
168As part of the protocol for 
generating these inputs, the agencies are specifying the configuration of a reference tractor for conducting trailer testing. Refer to Section IV of this Preamble and to 40 CFR 1037.501 of the regulations for details on the reference tractor configuration for trailer test procedures. 
Finally, GEM has been modified to 
accept an optional delta C
dA value for 
vocational chassis, to simulate aerodynamic improvements relative to pre-specified baseline defined in Chapter 4 of RIA. For example, a manufacturer that demonstrates that adding side skirts to a box truck reduces its C
dA by 0.2 m2could input that value 
into GEM for box trucks that include those skirts. See 40 CFR 1037.520(m). 
(f) Tires and Tire Inflation Systems for 
Truck and Trailer Certification 
For GEM in Phase 1 tractor and 
vocational chassis manufacturers input the tire rolling resistance of steer and drive tires directly into GEM. The agencies prescribed an internationally recognized tire rolling resistance test procedure, ISO 28580, for determining the tire rolling resistance value that is input into GEM, as described in 40 CFR 1037.520(c). For Phase 2 we will continue this same approach and the use of ISO 28580, and we are expanding these requirements to trailer tires as well. 
In addition to tire rolling resistance, 
Phase 2 vehicle manufacturers will enter into GEM the tire manufacturer’s specified revolutions per distance directly (revs/mile) for the vehicle’s drive tires. This value is commonly reported by tire manufacturers already so that vehicle speedometers can be adjusted appropriately. This input value is needed so that GEM can accurately convert simulated vehicle speed into axle speed, transmission speed, and ultimately engine speed. 
For tractors and trailers, we proposed 
to allow manufacturers to specify whether or not an automatic tire inflation system (ATIS) is installed. 80 FR 40187. Based on comments and as discussed further in Sections III, IV, and V, in the Phase 2 final rule we are adopting provisions that allow manufacturers of tractors, trailers, and vocational vehicle chassis to input a percent decrease in overall fuel consumption and CO
2emissions into 
GEM if the vehicle includes either an ATIS or a tire pressure monitoring system (TPMS). The value that can be input depends on whether a TPMS or ATIS is deployed. See 40 CFR 1037.520. 
(g) Weight Reduction for Tractor, 
Vocational Chassis and Trailer Certification 
Phase 2 GEM continues the weight 
reduction recognition approach in Phase 1, where the agencies prescribe fixed weight reductions, or ‘‘deltas,’’ for using certain lightweight materials for certain vehicle components. In Phase 1 the agencies published a list of weight reductions for using high-strength steel and aluminum materials on a part by part basis. For Phase 2 we use updated 
values for high-strength steel and aluminum parts for tractors and for trailers and we have scaled these values for use in certifying the different weight classes of vocational chassis. In addition we use a similar part by part weight reduction list for tractor parts made from thermoplastic material. We proposed to assign a fixed weight increase to natural gas fueled vehicles to reflect the weight increase of natural gas fuel tanks versus gasoline or diesel tanks, but we are not finalizing that provision based on comments. 80 FR 40187. Commenters opposing this provision generally noted that the proposed provision was not consistent with how the agencies were treating other technologies. We agree that 
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169See National Renewable Energy Laboratory 
report ‘‘EPA GHG Certification of Medium- and 
Heavy-Duty Vehicles: Development of Road Grade Profiles Representative of US Controlled Access 
Highways’’ dated May 2015 and EPA memorandum ‘‘Development of an Alternative, Nationally Representative, Activity Weighted Road Grade Profile for Use in EPA GHG Certification of Medium- and Heavy-Duty Vehicles’’ dated May 13, 2015, both available in Docket EPA–HQ–OAR– 2014–0827. This docket also includes file NREL_SyntheticAndLocalGradeProfiles.xlsx which contains numerical representations of all road grade profiles described in the NREL report. 
170NAS 2010 Report. Page 189. ‘‘A fundamental 
concern raised by the committee and those who testified during our public sessions was the tension between the need to set a uniform test cycle for regulatory purposes, and existing industry practices of seeking to minimize the fuel consumption of medium and heavy-duty vehicles designed for specific routes that may include grades, loads, work tasks or speeds inconsistent with the regulatory test cycle. This highlights the critical importance of achieving fidelity between certification values and real-world results to avoid decisions that hurt rather than help real-world fuel consumption.’’ natural gas vehicles should be treated 
consistently with other technologies and so are not adopting the proposed provision. 
For tractors, we will continue the 
same mathematical approach in GEM to assign 
1⁄3of a total weight decrease to 
a payload increase and 2⁄3of the total 
weight decrease to a vehicle mass decrease. For Phase 1, these ratios were based on the average frequency that a tractor operates at its gross combined weight rating. We will also use these ratios for trailers in Phase 2. For vocational chassis, for which Phase 1 did not address weight reduction, we will assign 
1⁄2of a total weight decrease 
to a payload increase and 1⁄2of the total 
weight decrease to a vehicle mass decrease. 
(h) GEM Duty Cycles for Tractor, 
Vocational Chassis and Trailer Certification 
In Phase 1, there are three GEM 
vehicle duty cycles that represent stop- and-go city driving (ARB Transient), urban highway driving (55 mph), and rural interstate highway driving (65 mph). In Phase 1 these cycles were time- based. That is, they were specified as a function of simulated time and the duty cycles ended once the specified time elapsed in simulation. The agencies proposed to continue to use these three drive cycles in Phase 2, but with some revisions. 80 FR 40187. We are finalizing revisions similar but not identical to those that were proposed. First, GEM will simulate these cycles on a distance-based specification, rather than on a time-based specification. A distance-based specification ensures that even if a vehicle in simulation does not always achieve the target vehicle speed, the vehicle will have to continue in simulation for a longer period to complete the duty cycle. This ensures that vehicles are evaluated over the complete distance of the duty cycle and not just the portion of the duty cycle that a vehicle completes in a given time period. A distance-based duty cycle specification also facilitates a straightforward specification of road grade as a function of distance along the duty cycle. As noted in above, for Phase 
2, the agencies have enhanced the 55 mph and 65 mph duty cycles by adding representative road grade to exercise the simulated vehicle’s engine, transmission, axle, and tires in a more realistic way. A flat road grade profile over a constant speed test does not properly simulate a transmission with respect to shifting gears, and may have the unintended consequence of enabling underpowered vehicles or excessively down-sped drivetrains to generate credits, when in actuality the engine 
does not remain down-sped in-use when the vehicle encounters road grades. The road grade profile being finalized is the same hill and valley profile for both the 55 mph and 65 mph duty cycles, and is based on statistical analysis of the United States’ national distribution of road grades. Although the final profile is different than that proposed, the agencies provided notice of the analysis that was used to generate the final profile.
169In written 
comments, we received in-use engine data from some manufacturers, and based on this information we made minor adjustments to the road grade to ensure that engines simulated in GEM operated similarly to that reported in the in-use engine data submitted to us. See Section III.E.(2)(b) of this document and Chapter 3.4.2.1 of the RIA for more details on development of the road grade profile. We believe that the enhancement of the 55 mph and 65 mph duty cycles with road grade is consistent with the NAS recommendation regarding road grade.
170 
(i) Workday Idle Operation for Vocational Chassis Certification 
In the Phase 1 program, reduction in 
idle emissions was recognized only for sleeper cab tractors, and only with respect to hoteling idle, where a driver needs power to operate heating, ventilation, air conditioning and other electrical equipment in order to use the sleeper cab to eat, rest, or conduct other business. As described in Section V, GEM for Phase 2 will recognize technologies that reduce workday idle emissions, such as automatic stop-start systems, daytime parked idle automatic engine shutdown systems, and transmissions that either automatically or inherently shift to neutral at idle while in drive. Many vocational vehicle applications operate on patterns implicating workday idle cycles, and the agencies use test procedures in GEM to account specifically for these cycles and potential idle controls. GEM will recognize these idle controls in two ways. For technologies like neutral-idle transmissions and stop-start systems that address idle that occurs during vehicle operation when the vehicle is stopped at a stop light, GEM will interpolate lower fuel rates from the engine map during the idle portions of the ARB Transient and during a separate GEM ‘‘drive idle cycle.’’ For technologies like start-stop and auto- shutdown that eliminate some of the idle that occurs when a vehicle is stopped or parked, GEM will assign a value of zero fuel rate during a separate GEM ‘‘parked idle cycle.’’ The idle cycles will be weighted along with the 65 mph, 55 mph, and ARB Transient duty cycles, according to the new vocational chassis duty cycle weighting factors. These weighting factors are different for each of the three vocational chassis speed categories for Phase 2. For tractors, only neutral idle and hotel idle will be addressed in GEM. 
(2) Experimental Validation of GEM 
The core simulation algorithms in 
GEM have not changed significantly 
since the proposal. Most of the changes since proposal focused on streamlining how manufacturers input data into GEM; revising to the drive cycles in GEM; and updating how GEM weights these different drive cycles to determine a composite fuel consumption value. These changes did not alter the fundamental way that GEM simulates varying vehicle ‘‘road load’’ and how GEM converts vehicle speed to engine speed and then interpolates engine maps to determine vehicle fuel consumption and CO
2emissions. 
Refinements to GEM since the time of 
proposal that did alter GEM’s simulation performance include modifying the default transmissions’ shift strategies and their power losses. Another key refinement was cycle 
average mapping engines for simulation of the ARB Transient cycle. Each time the agencies made such modifications to GEM, GEM’s correlation to the agencies collection of laboratory-generated engine and vehicle data was checked. Potential refinements to GEM were accepted if GEM’s correlation was improved versus this set of experimental data. If potential refinements resulted in GEM’s correlation to the experimental data 
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171K. Newman, J. Kargul, and D. Barba, 
‘‘Development and Testing of an Automatic 
Transmission Shift Schedule Algorithm for Vehicle Simulation, ‘‘SAE Int. J. Engines 8(3):2015, 
doi:10.4271/2015–01–1142. 172National Academy of Science. ‘‘Reducing the 
Fuel Consumption and GHG Emissions of Medium- 
and Heavy-Duty Vehicles, Phase Two, First 
Report.’’ 2014. Recommendation1.2. becoming worse, those potential 
changes were rejected. Chapter 4.3.2 of the RIA details the GEM validation that was performed to determine if potential changes to GEM should be accepted or rejected. The first step of the validation process involves simulating vehicles in GEM using engine fuel maps and transmission shifting strategies obtained from manufacturers and comparing GEM results to experiments conducted with the same engines and transmissions. This first step re- validates all of the non-powertrain elements of GEM, which were already validated in Phase 1. The second step is to use GEM’s default transmissions’ shift strategies in simulation
171and 
then compare GEM results to powertrain tests of several transmissions. The only difference between the first and second step is the shifting strategy and powertrain energy loss assumptions. This step facilitates tuning of GEM’s default transmission models so that they correlate well to a variety of real transmissions. The third step is to compare GEM simulations to real-world in-use recorded data from actual vehicles. This is the most challenging step because the experimental data includes real-world effects of wind, road grade, and driver behavior in traffic. The most important element of this third step is not absolute correlation, but 
rather, relative correlation, which 
demonstrates that when a technology is added to a real vehicle, the relative improvement in the real world is simulated in GEM with a high degree of correlation. 
In the first validation step, the 
agencies compared GEM to over 130 vehicle variants, consistent with the recommendation made by the NAS in their Phase 2-First Report.
172As 
described in Chapter 4 of the RIA, good agreement was observed between GEM simulations and test data over a wide range of vehicles. In general, the model simulations agreed with experimental test results within ±5 percent on an absolute basis. As pointed out in Chapter 4.3.2 of the RIA, relative accuracy is more relevant to the intent 
of this rulemaking, which is to accelerate the adoption of additional fuel efficiency improving technologies. Consistent with the intent of this rulemaking, all of the numeric standards for tractors, trailers and vocational chassis are derived from running GEM first with Phase 1 ‘‘baseline’’ technology 
packages and then with various Phase 2 technology packages. The differences between these GEM results are examined to determine final stringencies. In other words, the agencies used the same final version of GEM to establish the numeric standards as will be used by manufacturers to demonstrate compliance. Therefore, it is most important that GEM accurately reflects relative changes in emissions for 
each added technology. In other words, 
for vehicle certification purposes it is less important that GEM’s absolute value of the fuel consumption or CO
2 
emissions be accurate compared to laboratory testing of the same vehicle. The ultimate purpose of GEM is to evaluate changes or additions in 
technology, and compliance is demonstrated on a relative basis to the numeric standards that were also derived from GEM. Nevertheless, the agencies concluded that the absolute accuracy of GEM is generally within ±5 percent, as shown in Figure II.2 2. Chapter 4.3.2 of the RIA shows that relative accuracy is even better, ±2–3 
percent. 
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17340 CFR 1036.610, 1036.615, 1037.610, and 
1037.615. In addition to this successful 
validation against experimental results, 
the agencies have also conducted a peer review of the GEM source code. This peer review has been submitted to Docket number EPA–HQ–OAR–2014– 0827. 
The second validation step was to 
repeat the first step’s GEM simulations with the agencies’ default transmission shift strategies.
171It was expected that 
GEM’s absolute accuracy would decrease because these shift strategies were tuned for best average performance and for a particular transmission. Nevertheless, it was shown that relative accuracy did not suffer; therefore, the agencies deemed the GEM default shift strategies acceptable for GEM certification purposes. Further details of this validation step are presented in Chapter 4.3.2.3 of the RIA and in a SwRI final report.
162 
As explained above and in Chapter 
4.3.2.3 of the RIA, it is challenging to achieve absolute correlation between any computer simulation and real-world vehicle operation. Therefore, the agencies focused on relative comparisons. Following the SAE standard procedure SAE J1321 ‘‘Type II,’’ two trucks have been tested and these real-world results were compared to GEM simulations. In summary, the relative comparisons between GEM simulations and the real-world testing of trucks showed a 2.4 percent difference. The details of this testing and correlation analysis is presented in Chapter 4.3.2.3 of the RIA. 
In conclusion, the agencies completed 
a number of validation steps to ensure that GEM demonstrates a reasonable degree of absolute accuracy, but more importantly a high degree of relative accuracy, versus both laboratory and real-world experimental data. 
(3) Supplements to GEM Simulation 
As in Phase 1, for most tractors and 
vocational vehicles, compliance with 
the Phase 2 g/ton-mile vehicle standards could be evaluated by directly comparing the GEM result to the standard. However, in Phase 1, manufacturers incorporating innovative or advanced technologies could apply improvement factors to lower the GEM result before comparing to the standard.
173For example, a 
manufacturer incorporating a launch- assist mild hybrid that was pre- approved for a 5 percent benefit would apply a 0.95 improvement factor to its GEM results for such vehicles. In this example, a GEM result of 300 g/ton-mile 
will be reduced to 285 g/ton-mile. 
For Phase 2, the agencies largely 
continue the existing Phase 1 innovative technology approach, but we name it ‘‘off-cycle’’ to better reflect its purpose. 
(a) Off-Cycle Technology Procedures 
In Phase 1 the agencies adopted an 
emissions credit generating opportunity 
that applied to new and innovative technologies that reduce fuel consumption and CO
2emissions, which 
were not in common use with heavy- duty vehicles before model year 2010 and are not reflected over the test procedures or GEM (i.e., the benefits are 
‘‘off-cycle’’). See 76 FR 57253. As was the case in the development of Phase 1, the agencies continue this approach for technologies and concepts with CO
2 
emissions and fuel consumption reduction potential that might not be adequately captured over the Phase 2 duty cycles or are not inputs to GEM. Note, however, that the agencies now refer to these technologies as off-cycle rather than innovative. Comments were generally supportive of continuing this provision. See Section I.C(1)(c) of this document and Section 1 of the RTC for more discussion of innovative and off- cycle technologies. 
We recognize that the Phase 1 testing 
burden associated with the innovative technology credit provisions discouraged some manufacturers from applying. To streamline recognition of many technologies, default values have been integrated directly into GEM. For example, automatic tire inflation systems have fixed default values, and 
such technologies are now recognized through a post-simulation adjustment approach, discussed in Chapter 4 of the RIA. This is similar to the technology ‘‘pick list’’ from our light-duty programs. See 77 FR 62833–62835 (October 15, 2012). If manufacturers wish to receive additional credit beyond these fixed values, then the off-cycle technology credit provisions provide a regulatory path toward that additional recognition. 
Beyond the additional technologies 
that the agencies have added to GEM, the agencies also believe there are several emerging technologies that are being developed today, but will not be accounted for in GEM because we do not have enough information about these technologies to assign fixed values to them in GEM. Any credits for these technologies will need to be based on the off-cycle technology credit generation provisions. These require the assessment of real-world fuel consumption and GHG reductions that can be measured with verifiable test methods using representative operating 
conditions typical of the engine or vehicle application. 
As in Phase 1, the agencies continue 
to provide two paths for approval of the test procedure to measure the CO
2 
emissions and fuel consumption reductions of an off-cycle technology used in the HD tractor. See 40 CFR 1037.610 and 49 CFR 535.7. The first path does not require a public approval process of the test method. A manufacturer can use ‘‘pre-approved’’ test methods for HD vehicles including the A-to-B chassis testing, powertrain testing or on-road testing. A manufacturer may also use any developed test procedure which has known quantifiable benefits. A test plan detailing the testing methodology is required to be approved by the agencies prior to collecting any test data. The agencies will also continue the second path which includes a public approval process of any testing method which could have uncertain benefits (i.e., an 
unknown usage rate for a technology). Furthermore, the agencies are modifying our provisions to better clarify the documentation required to be submitted for approval aligning them with provisions in 40 CFR 86.1869–12, and NHTSA separately prohibits credits from technologies addressed by any of its crash avoidance safety rulemakings (i.e., congestion management systems). 
Sections III and V separately describe 
tractor and vocational vehicle technologies, respectively, that the agencies anticipate may qualify for these off-cycle credit provisions. 
(4) Production Vehicle Testing for 
Comparison to GEM 
As described in Section III.E.(2)(j), 
The agencies are requiring tractor manufacturers to annually chassis test five production vehicles over the GEM cycles to verify that relative reductions simulated in GEM are being achieved in 
production. See 40 CFR 1037.665. We do not expect absolute correlation between GEM results and chassis testing. GEM makes many simplifying assumptions that do not compromise its usefulness for certification, but do cause it to produce emission rates different from what would be measured during a chassis dynamometer test. Given the limits of correlation possible between GEM and chassis testing, we would not expect such testing to accurately reflect whether a vehicle was compliant with the GEM standards. Therefore, we are not applying GHG compliance liability to such testing. Rather, this testing will be for data collection and informational purposes only. The agencies will continue to evaluate in-use compliance 
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174The sole exception being the design-based 
standards for non-aero and partial aero trailers. by verifying GEM inputs and testing in- 
use engines. (Note that NTE standards for criteria pollutants may apply for some portion of the test cycles.) 
(5) Use of GEM in Establishing the 
Phase 2 Numerical Standards 
As in Phase 1, the agencies are setting 
specific numerical standards against which tractors and vocational vehicles will be certified using GEM (box trailers 
will use a GEM-based equation, and some trailers and custom chassis vocational vehicles may optionally use a non-GEM certification path). Although these standards are performance-based standards, which do not specifically require the use of any particular technologies,
174the agencies established 
these standards by evaluating specific vehicle technology packages using the final version of Phase 2 GEM. We note that that this means the final numerical standards are not directly comparable to the proposed standards, which were based on an intermediate version of GEM, rather than on the final version. 
(a) Relation to In-Use Emissions 
The purpose of this rulemaking is to 
achieve in-use emission and fuel 
consumption reductions by requiring manufacturers to demonstrate that they meet the promulgated emission standards. Thus, it is important that GEM simulations be reasonably representative of in-use operation. Testing that is unrepresentative of actual in-use operation does not necessarily tell us anything about whether any emission reductions occur. However, we recognize that certain simplifications are necessary for practical simulations. In the past, EPA has addressed this issue by including in our testing regulations a process by which EPA can work with manufacturers to adjust test procedures to make them more representative of in- use operation. For engine testing, this provision is in 40 CFR 1065.10(c)(1), where EPA requires manufacturers to notify us in cases in which they determine that the specified test procedures would result in measurements that do not represent in- use operation. 
Although we are not adopting an 
equivalent provision for GEM at this time, we expect similar principles to apply. To the extent that GEM fails to represent in-use emission, we would expect to work with manufacturers to address the issue—under the existing regulations where possible, or by promulgating a new rulemaking. We recognize that many compromises 
must be made between the practicality 
of testing/simulation and the matching of in-use operation. We have considered many aspects of the test procedures in this respect for the engines, vehicles, and emission controls of which we are currently aware. We have concluded that the procedures will generally result in emission simulations that are sufficiently representative of in-use emissions, even though not all in-use operation will occur during simulation. Nevertheless, we have identified several areas that deserve some additional discussion. 
GEM is structured to simulate a single 
vehicle weight (curb weight plus payload) per regulatory subcategory. However, we know that actual in-use weights will rarely be exactly the same as the simulated weights. Nevertheless, since the representativeness of the simulated weights (or lack thereof) is being fully considered in the setting of the standards, there would be no need to modify the procedures to account for different curb weights or payloads. 
GEM simulates vehicle emissions over 
three drive cycles plus two idle cycles, and weights the cycle results based on the type of vehicle being certified. These cycles and weightings reflect fleet average driving patterns and the 
agencies do not expect them to fully match driving patterns for individual vehicles. Thus, we would generally not consider GEM’s cycles as unrepresentative for vehicles with 
different in-use driving patterns. However, if new information became available that demonstrated that GEM’s cycles somehow did not reflect fleet average driving patterns, the agencies would consider such information in the context of the principles of representative testing, described above. 
Finally, GEM includes default values 
for axle and transmission efficiency derived from baseline technologies. However, we generally expect manufacturers to use more efficient axles and transmissions for Phase 2 vehicles. As noted above, based on comments, the agencies are allowing manufacturers to optionally input measured efficiencies to better represent these more efficient technologies. We would not consider GEM unrepresentative if manufacturers chose to use the default values rather than measure these efficiencies directly. 
(b) Relation to Powertrain Testing 
As already noted, GEM correlates very 
well with powertrain testing. To the 
extent they differ, it would be expected to be primarily related to how transmission performance is modeled in GEM. Although GEM includes a 
sophisticated model of transmissions, it cannot represent a transmission better than a powertrain test of the same transmission. Thus, the agencies consider powertrain testing to be as good as or better than GEM run using engine-only fuel maps; hence the provision in the final rules allowing results from powertrain testing to be used as a GEM input. 
In some respects, powertrain testing 
can be considered to be a reference method for this rulemaking. Because manufacturers have the option to perform powertrain testing instead of engine-only fuel mapping, the stringency of the final standards can be traced to powertrain testing. In other words, methods that can be shown to be equivalent to powertrain testing can be considered to be consistent with the testing that was used as the basis of the final Phase 2 standards. 
In a related context, it may be useful 
in the future to consider equivalency to powertrain testing as an appropriate criterion for evaluating changes to GEM to address new technologies. Consider, for example, a new technology that is not represented in GEM, but that is reflected in powertrain testing. The agencies could determine that it would be appropriate to modify GEM to reflect the technology rather than to require manufacturers to perform powertrain testing. In such a case, the agencies would not consider the modification to GEM to impact the effective stringency of the Phase 2 standards because the new version of GEM would be equivalent to performing powertrain testing. 
D. Engine Test Procedures and Engine 
Standards 
In addition to the Phase 1 GEM-based 
vehicle certification of tractors and vocational chassis, the agencies also set Phase 1 separate CO
2and fuel efficiency 
standards for the engines installed in 
tractors and vocational chassis. EPA also set Phase 1 separate engine standards for capping methane (CH
4) 
and nitrous oxide (N 2O) emissions 
(essentially capping emissions at current emission levels). Compliance with all of these Phase 1 separate engine standards is demonstrated by measuring these emissions during an engine dynamometer test procedure. For Phase 1 the agencies use the same test procedure specified for EPA’s existing heavy-duty engine emissions standards (e.g., NO
Xand PM standards). These 
Phase 1 engine standards are specified in terms of brake-specific (g/bhp-hr) fuel, CO
2, CH 4and N 2O emissions 
limits. Since the test procedure already 
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175The SET cycle is also referred to as the 
‘‘ramped-modal cycle’’ because, for criteria 
pollutants, it is performed as a continuous cycle with ramped transitions between the individual modes of the SET. 176‘‘OEM perspective—Meeting EPA/NHTSA 
GHG/Efficiency Standards’’, 7th Integer Emissions Summit USA 2014, Volvo Group North America. specified how to measure fuel 
consumption, CO 2and CH 4, few 
changes were needed to utilize the test procedure for Phase 1, the most notable change being a modification specifying how to measure N
2O. 
There are some differences in how 
these non-GHG test procedures are applied in Phase 1 and Phase 2. In EPA’s non-GHG engine emissions standards, heavy-duty engines must meet brake-specific standards for emissions of total oxides of nitrogen (NO
X), particulate mass (PM), non- 
methane hydrocarbon (NMHC), and carbon monoxide (CO). These standards must be met by all engines both over a 13-mode steady-state duty cycle called the ‘‘Supplemental Emissions Test’’ (SET)
175and over a composite of a cold- 
start and a hot-start transient duty cycle called the ‘‘Federal Test Procedure’’ (FTP). In contrast, for Phase 1 the agencies require that engines specifically installed in tractors meet fuel efficiency and CO
2standards over 
only the SET but not the composite FTP. This requirement was intended to reflect that tractor engines typically operate near steady-state conditions versus transient conditions. See 76 FR 57159. For Phase 2 the agencies are finalizing, as proposed, slight changes to the 13-modes’ weighting factors to better reflect in-use engine operation. These weighting factors apply only for determining SET fuel consumption and CO
2emissions. No changes are being 
made to the weighting factors for EPA’s non-GHG emission standards. The agencies adopted the converse for engines installed in vocational vehicles. That is, these engines must meet fuel efficiency and CO
2standards over the 
composite FTP but not the SET. This requirement was intended to reflect that vocational vehicle engines typically operate under transient conditions versus steady-state conditions (76 FR 57178). For both tractor and vocational vehicle engines in Phase 1, EPA set CH
4 
and N 2O emissions cap standards over 
the composite FTP only and not over the SET duty cycle. See Section II.D. for details on this final action’s engine test procedures for Phase 2. 
In response to the agencies’ proposed 
engine standards, we received a number of public comments. The agencies considered those comments, and the following list summarizes key changes we’ve made in response, and more detailed descriptions of these changes are presented in Chapter 2.7 of the RIA: •Recalculated the SET baseline using 
the new Phase 2 SET weighting factors. 
•Recalculated the FTP baseline, 
based on MY 2016 FTP certification 
data from Cummins, DTNA, Volvo, Navistar, Hino, Isuzu, Ford, GM and FCA. These included HHD, MHD, and LHD engines. 
•Projected how manufacturers would 
modify maximum fuel rates as a function of speed to strategically relocate SET mode points to achieve lowest SET results. 
•Projected a higher market 
penetration of WHR in 2027, versus what we proposed. 
•Decreased our projected impact of 
engine technology dis-synergies by increasing the magnitude of our so- called ‘‘dis-synergy factors;’’ accounting for these changes by increasing the research and development costs needed for this additional optimization. 
The following section first describes 
the engine test procedures used to certify engines to the Phase 2 separate engine standards. Sections that follow describe the Phase 2 CO
2, N2O and CH 4 
separate engine standards and their feasibility. 
(1) Engine Test Procedures 
(a) SET Cycle Weighting 
The SET cycle was adopted by EPA in 
2000 and modified in 2005 from a 
discrete-mode test to a ramped-modal cycle to broadly cover the most significant part of the speed and torque map for heavy-duty engines, defined by three non-idle speeds and three relative torques. The low speed is called the ‘‘A speed,’’ the intermediate speed is called the ‘‘B speed,’’ and the high speed is called the ‘‘C speed.’’ As is shown in Table II–1, the SET cumulatively weights these three speeds at 23 percent, 39 percent, and 23 percent. 
TABLE II–1—SET M ODES WEIGHTING  
FACTOR IN PHASE 1 
Speed, % Load Weighting 
factor in 
Phase 1 
(%) 
Idle ............................................ 15 
A, 100 ....................................... 8 
B, 50 ......................................... 10 
B, 75 ......................................... 10 
A, 50 ......................................... 5 
A, 75 ......................................... 5 
A, 25 ......................................... 5 
B, 100 ....................................... 9 
B, 25 ......................................... 10 
C, 100 ....................................... 8 
C, 25 ......................................... 5 
C, 75 ......................................... 5 
C, 50 ......................................... 5 
Total ...................................... 100 TABLE II–1—SET M ODES WEIGHTING  
FACTOR IN PHASE 1—Continued 
Speed, % Load Weighting 
factor in 
Phase 1 
(%) 
Cumulative A Speed ................. 23 
Cumulative B Speed ................. 39 
Cumulative C Speed ................ 23 
The C speed is typically in the range 
of 1800 rpm for current heavy heavy- 
duty engine designs. However, it is becoming much less common for engines to operate at such a high speeds in real-world driving conditions, and especially not during cruise vehicle speeds in the 55 to 65 mph vehicle speed range. This trend has been corroborated by engine manufacturers’ in-use data that has been submitted to the agencies in comments and presented at technical conferences.
176Thus, 
although the current SET represents highway operation better than the FTP cycle, it could be improved by adjusting its weighting factors to better reflect modern trends in in-use engine operation. Furthermore, the most recent trends indicate that manufacturers are configuring drivetrains to operate engines at speeds down to a range of 1050–1200 rpm at a vehicle speed of 65 mph. 
To address this trend toward in-use 
engine down-speeding, the agencies are finalizing as proposed refined SET weighting factors for the Phase 2 CO
2 
emission and fuel consumption standards. The new SET mode weightings move most of the C weighting to ‘‘A’’ speed, as shown in Table II–2. To better align with in-use data, these changes also include a reduction of the idle speed weighting factor. These new mode weightings do not apply to criteria pollutants or to the Phase 1 CO
2emission and fuel 
consumption standards. 
TABLE II–2—N EWSET M ODES  
WEIGHTING FACTOR IN PHASE 2 
Speed/% load Weighting 
factor in 
Phase 2 
(%) 
Idle ............................................ 12 
A, 100 ....................................... 9 
B, 50 ......................................... 10 
B, 75 ......................................... 10 
A, 50 ......................................... 12 
A, 75 ......................................... 12 
A, 25 ......................................... 12 
B, 100 ....................................... 9 
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TABLE II–2—N EWSET M ODES  
WEIGHTING FACTOR IN PHASE 2— 
Continued 
Speed/% load Weighting 
factor in 
Phase 2 
(%) 
B, 25 ......................................... 9 
C, 100 ....................................... 2 
C, 25 ......................................... 1 
C, 75 ......................................... 1 
C, 50 ......................................... 1 
Total ...................................... 100 
Total A Speed ........................... 45 
Total B Speed ........................... 38 
Total C Speed .......................... 5 
(b) Engine Test Provisions for SET, FTP, 
and Engine Mapping for GEM Inputs 
Although GEM does not apply 
directly to engine certification, Phase 2 will require engine manufacturers to generate and certify full load and motoring torque curves and engine fuel rate maps for input into GEM for tractor and vocational chassis manufacturers to demonstrate compliance to their respective standards. The full load and motoring torque curve procedures were previously defined in 40 CFR part 1065, and these are already required for non- GHG emissions certification. The Phase 2 final default test procedure for generating an engine map for GEM’s 55 mph and 65 mph drive cycles is the ‘‘steady-state’’ mapping procedure. However, the agencies are finalizing an option for manufacturers to use the ‘‘cycle average’’ mapping procedure for GEM’s 55 mph and 65 mph drive cycles. The test procedure for generating an engine map for GEM’s ARB Transient drive cycle is the ‘‘cycle-average’’ mapping procedure, and the agencies are not finalizing any other mapping options for the ARB Transient drive cycle. Note that if an engine manufacturer elects to conduct powertrain testing to generate inputs for 
GEM, then steady-state and cycle- average engine maps would not be required for those GEM vehicle configurations to which the powertrain test inputs would apply. The steady- state and cycle-average test procedures are specified in 40 CFR parts 1036 and 1065. The technical and confidential business information motivations for finalizing these test procedures are explained in II. B. (2), along with a summary of comments we received. 
One important consideration is the 
need to correct measured fuel consumption rates for the carbon and energy content of the test fuel. As proposed, we will continue the Phase 1 approach, which is specified in 40 CFR 1036.530. We are specifying a similar 
approach to GEM fuel maps in Phase 2. 
As proposed, the agencies are 
requiring that engine manufacturers certify fuel maps for GEM, as part of their certification to the engine standards. However, there were a number of manufacturer comments strongly questioning the particular proposed requirement that engine manufacturers provide these maps to vehicle manufacturers starting in MY 2020 for the certification of vehicles commercially marketed as MY 2021 vehicles in calendar year 2020. This is a normal engine and vehicle manufacturing process, where many vehicles may be produced with engines having an earlier model year than the commercial model year of the vehicle. For example, we expect that some MY 2021 vehicles will be produced with MY 2020 engines. Thus, we proposed to require engine manufacturers to begin providing GEM fuel maps for MY 2020 engines so that vehicle manufacturers could run GEM to certify MY 2021 vehicles with MY 2020 engines. EMA and some of its members commented that MY 2020 engines should not be subject to Phase 2 requirements, based on NHTSA’s statutory 4-year lead-time requirement and because the potential higher fuel consumption of MY 2020 (i.e., Phase 1) engine maps could force 
vehicle manufacturers to install additional technologies that were not projected by the agencies for compliance. The agencies considered these comments along with the potential cost savings for manufacturers to align the timing of both their engines’ and vehicle’s Phase 2 product plans and certification paths. The agencies also considered how this situation would repeat in MY 2024 and MY 2027 and possibly with future standards as well. Based on these considerations, we have decided that it would be more appropriate to harmonize the engine and vehicle standards, starting in MY 2021 so that vehicle manufacturers will not need fuel maps for 2020 engines. Thus, we are not finalizing the requirement to provide fuel maps for MY 2020 engines. However, we are requiring fuel maps for all MY 2021 engines, even those (e.g., small 
businesses) for which the Phase 2 engine and vehicle standards have been delayed. See 40 CFR 1036.150. 
The current engine test procedures 
also require the development of regeneration emission rate and frequency factors to determine infrequent regeneration adjustment factors (IRAFs) that account for the 
emission changes for criteria pollutants 
during an exhaust emissions control system regeneration event. In Phase 1 the agencies adopted provisions to exclude CO
2emissions and fuel 
consumption due to regeneration. However, for Phase 2, we are requiring the inclusion of CO
2emissions and fuel 
consumption due to regeneration over the FTP and SET (RMC) cycles, as determined using the IRAF provisions in 40 CFR 1065.680. While some commenters opposed this because of its potential impact on stringency, we do not believe this will significantly impact the stringency of these standards because manufacturers have already made great progress in reducing the frequency and impact of regeneration emissions since 2007. Rather, the agencies are including IRAF CO
2 
emissions for Phase 2 to prevent these emissions from increasing in the future to the point where they would otherwise become significant. Manufacturers qualitatively acknowledged the likely already small and decreasing magnitude of IRAF CO
2 
emissions in their comments. For example, EMA stated, ‘‘the rates of infrequent regenerations have been going down since the adoption of the Phase 1 standards’’ and that IRAF ‘‘contributions are minor.’’ Nevertheless, we believe it is prudent to begin accounting for regeneration emissions to discourage manufacturers from adopting criteria emissions compliance strategies that could reverse this trend. Manufacturers expressed concern about the additional test burden, but the only additional requirement would be to measure and report CO
2emissions for the same tests 
they are already performing to determine IRAFs for other pollutants. 
At the time of the proposal, we did 
not specifically adjust baseline levels to include additional IRAF emissions because we believed them to be negligible and decreasing. Commenters opposing this proposed provision provided no data to dispute this belief. We continue to believe that regeneration strategies can be engineered to maintain these negligible rates. Thus, we do not believe they are of fundamental significance for our baselines in the FRM. Highway operation includes enough high temperature operation to make active regenerations unnecessary. Furthermore, recent improvements in exhaust after-treatment catalyst formulations and exhaust temperature thermal management strategies, such as intake air throttling, minimize CO
2IRAF 
impacts during non-highway operation, where active regeneration might be required. Finally, as is discussed in Section II.D.(2), recent significant 
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efficiency improvements over the FTP 
cycle suggest that FTP emissions may actually be even lower than we have estimated in our updated FTP baselines, which would provide additional margin for manufacturers to manage any minor CO
2IRAF impacts that may occur. 
We are not including fuel 
consumption due to after-treatment regeneration in the creation of fuel maps used in GEM for vehicle compliance. We believe that the IRAF requirements for the separate SET and FTP engine standards, along with market forces that already exist to minimize regeneration events, will create sufficient incentives to reduce fuel consumption during regeneration over the entire fuel map. 
(c) Powertrain Testing 
The agencies are finalizing a 
powertrain test option to afford a robust 
mechanism to quantify the benefits of CO
2reducing technologies that are a 
part of the powertrain (conventional or hybrid), that are not captured in the GEM simulation. Among these technologies are integrated engine and transmission control and hybrid 
systems. We are finalizing a number of improvements to the test procedure in 40 CFR 1037.550. As proposed we are finalizing the requirement for Phase 2 hybrid powertrains to mapped using this powertrain test method. The agencies are also finalizing modifications to 40 CFR 1037.550 to separate out the hybrid specific testing protocols. 
To limit the amount of testing under 
this rule, powertrains can be divided into families and are tested in a limited number of simulated vehicles that will cover the range of vehicles in which the powertrain will be used. A matrix of 8 to 9 tests will be needed per vehicle cycle, to enable the use of the powertrain results broadly across all the vehicles in which the powertrain will be installed. The individual tests differ by the vehicle that is being simulated during the test. These are discussed in detail in Chapter 3.6 of the RIA. 
(i) Powertrain Test Procedure 
The agencies are expanding upon the 
test procedures defined 40 CFR 
1037.550 for Phase 1 hybrid vehicles. The Phase 2 expansion will migrate the current Phase 1 test procedure to a new 40 CFR 1037.555 and will modify the current test procedure in 40 CFR 1037.550, allowing its use for Phase 2 only. The Phase 2 modifications relative to 40 CFR 1037.550 include the addition of the rotating inertia of the driveline and tires, and the axle efficiency. This revised procedure also requires that each of the powertrain components be cooled so that the temperature of each 
of the components is kept in the normal operation range. We are extending the powertrain procedure to PHEV powertrains. 
Powertrain testing contains many of 
the same requirements as engine dynamometer testing. The main differences are where the test article connects to the dynamometer and the software that is used to command the dynamometer and operator demand setpoints. The powertrain procedure finalized in Phase 2 allows for the dynamometer(s) to be connected to the powertrain either upstream of the drive axle or at the wheel hubs. The output of the transmission is upstream of the drive axle for conventional powertrains. In addition to the transmission, a hydraulic pump or an electric motor in the case of a series hybrid may be located upstream of the drive axle for hybrid powertrains. If optional testing with the wheel hub is used, two dynamometers will be needed, one at each hub. Beyond these points, the only other difference between powertrain testing and engine testing is that for powertrains, the dynamometer and throttle setpoints are not set by fixed speed and torque targets prescribed by the cycle, but are calculated in real time by the vehicle model. The powertrain test procedure requires a forward calculating vehicle model, thus the output of the model is the dynamometer speed setpoints. The vehicle model calculates the speed target using the measured torque at the previous time step, the simulated brake force from the driver model, and the vehicle parameters (tire rolling resistance, drag area, vehicle mass, rotating mass, and axle efficiency). The operator demand that is used to change the torque from the engine is controlled such that the powertrain follows the vehicle speed target for the cycle instead of being controlled to match the torque or speed setpoints of the cycle. The emission measurement procedures and calculations are identical to engine testing. 
(ii) Engine Test Procedures for 
Replicating Powertrain Tests 
As described in Section II.B.(2)(b), the 
agencies are finalizing the proposed powertrain test option to quantify the benefits of CO
2-reducing powertrain 
technologies. This option is very similar to the cycle average mapping approach, although these powertrain test results would be used to override both the engine and transmission (and possibly axle) simulation portions of GEM, not just the engine fuel map. The agencies are requiring that any manufacturer choosing to use this option also measure 
engine speed and engine torque during the powertrain test so that the engine’s performance during the powertrain test could be replicated in a non-powertrain engine test cell. Manufacturers would be required to measure or calculate, using good engineering judgment, the engine shaft output torque, which would be close-coupled to the transmission input shaft during a powertrain test. Subsequent engine testing then could be conducted using the normal part 1065 engine test procedures as specified in 40 CFR 1037.551, and g/bhp-hr CO
2results 
could be compared to the levels the manufacturer reported during certification. Such testing could apply for both confirmatory and selective enforcement audit (SEA) testing. This would simplify both the certification and SEA testing. 
As proposed, engine manufacturers 
certifying powertrain performance (instead of or in addition to the multi- point fuel maps) will be held responsible for powertrain test results. If the engine manufacturer does not certify powertrain performance and instead certifies only the steady-state and/or cycle-average fuel maps, it will held responsible for fuel map performance rather than the powertrain test results. Engine manufacturers certifying both will be responsible for both. 
Some commenters objected to the 
potential liability for such engine-only tests. However, it appears they do not understand our intent. This provision states clearly that this approach could be used only where ‘‘the test engine’s operation represents the engine operation observed in the powertrain test.’’ Also, since the manufacturers perform all SEA testing themselves, this would be an option for the manufacturer rather than something imposed by EPA. 
Thus, this concern should be limited to the narrow circumstance in which EPA performs confirmatory engine testing of an engine that was certified using powertrain testing, follows the manufacturer’s specified engine test cycle, and ensures that the test accurately represents the engine’s performance during the powertrain test. However, it is not clear why this would be problematic. It is entirely reasonable to assume that testing the engine in this way would result in equivalent emission results. To the extent manufacturer concerns remain, each manufacturer would be free to certify their engines based on engine-only fuel maps rather than powertrain testing. 
(d) CO
2From Urea SCR Systems 
For diesel engines utilizing urea SCR 
emission control systems for NO X 
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177https://www3.epa.gov/otaq/certdata.htm#oh. 
178http://www.arb.ca.gov/msprog/onroad/cert/
mdehdehdv/2016/2016.php. reduction, the agencies will allow, but 
not require, correction of the final engine (and powertrain) fuel maps to account for the contribution of CO
2from 
the urea injected into the exhaust. This urea typically contributes 0.2 to 0.5 percent of the total CO
2emissions 
measured from the engine, and up to 1 percent at certain map points. Since current urea production methods use gaseous CO
2captured from the 
atmosphere (along with NH 3), CO 2 
emissions from urea consumption does not represent a net carbon emission. This adjustment is necessary so that fuel maps developed from CO
2 
measurements will be consistent with fuel maps from direct measurements of fuel flow rates. This adjustment is also necessary to fully align EPA’s CO
2 
standards with NHTSA’s fuel consumption standards. Failing to account for urea CO
2tailpipe emissions 
would result in reporting higher fuel consumption than what was actually consumed. Thus, we are only allowing this correction for emission tests where CO
2emissions are determined from 
direct measurement of CO 2and not from 
fuel flow measurement, which would not be impacted by CO
2from urea. 
We note that this correction will be 
voluntary for manufacturers, and we expect that some manufacturers may determine that the correction is too 
small to be of concern. The agencies will use this correction for CO
2 
measurements with any engines for which the engine manufacturer applied the correction for its fuel maps during certification. 
We are not allowing this correction 
for engine test results with respect to the engine CO
2standards. Both the Phase 1 
standards and the new standards for CO
2from diesel engines are based on 
test results that included CO 2from urea. 
In other words, these standards are consistent with using a test procedure that does not correct for CO
2from urea. (2) Engine Standards for CO 2and Fuel 
Consumption 
We are largely maintaining the 
existing Phase 1 regulatory structure for 
engine standards, which had separate standards for spark-ignition engines (such as gasoline engines) and compression-ignition engines (such as diesel engines), and for HHD, MHD and LHD engines, but we are changing how these standards will apply to alternative fuel engines as described in Section XII.A.2. 
Phase 1 applied different test cycles 
depending on whether the engine is 
used for tractors, vocational vehicles, or both, and we are continuing this approach. Tractor engines are subject to standards over the SET, while vocational engines are subject to standards over the FTP. Table II–3 shows the Phase 1 standards for diesel engines. 
TABLE II–3—P HASE 1 MY 2017 D IESEL ENGINE CO 2ANDFUELCONSUMPTION STANDARDS  
Units HHD SET MHD SET HHD FTP MHD FTP LHD FTP 
g/bhp-hr .................................................. 460 487 555 576 576 
gal/100 bhp-hr ........................................ 4.5187 4.7839 5.4519 5.6582 5.6582 
In the Phase 2 proposal we assumed 
that these numeric values of the Phase 
1 standards were the baselines for Phase 2. We applied our technology assessments to these baselines to arrive at the Phase 2 standards for MY 2021, MY 2024 and MY 2027. In other words, for the Phase 2 proposal we projected that starting in MY 2017 engines would, on average, just meet the Phase 1 standards and not over-comply. 
However, based on comments we received on how to consistently apply our new SET weighting factors in our analysis and based on recent MY 2016 engine certification data, we are updating our Phase 2 baseline assumptions for both the SET and FTP. 
First, with respect to the SET, in the 
proposal we compared our proposed Phase 2 standards, which are based on these new Phase 2 weighting factors, to the Phase 1 numeric standards, which are based on the current Phase 1 weighting factors. Because we continue to use the same 13-mode brake specific CO
2and fuel consumption numeric 
values we used for the proposal to represent the performance of a MY 2017 baseline engine, we are not projecting a different technology level in the baseline. Rather, this is simply correcting an ‘‘apples-to-oranges’’ comparison from the proposal by applying the Phase 2 weighting factors to the MY 2017 baseline engine. This 
was pointed out to us by UCS, ICCT and EDF in their public comments. While this did not impact our technology effectiveness or cost analyses, it did impact the numeric value of our baseline to which we reference the effectiveness of applying technologies to the 13 individual modes of the SET. Because the revised SET weighting factors result in somewhat lower brake 
specific CO
2and fuel consumption 
numeric results for the composite baseline SET value, this correction, in turn, lowers the numerical values of the final Phase 2 SET standards. Making this particular update did not result in a change to the relative stringency of the final Phase 2 numeric engine standards (relative to MY 2017 baseline performance), but our updated feasibility analysis did; see Section II.D.(2)(a) below). 
Second, the agencies made 
adjustments to the FTP baselines, but these adjustments were not made because of a calculation error. Rather, MY 2016 FTP certification data showed an unexpected step-change improvement in engine fuel consumption and CO
2emissions. These 
data were not available at the time of proposal, so the agencies relied upon the MY 2017 Phase 1 standard as a baseline. EDF publicly commented in response to the NODA that the more 
recent certification data revealed this new step-change. MY 2016 certification 
data submitted to the agencies
177as 
well as to ARB178show that many 
engines from many manufacturers already not only achieve the Phase 1 FTP standards, but some were also below the MY 2027 standards proposed for Phase 2. This was not the case for the SET, where most manufacturers are still not yet complying with the MY 2017 Phase 1 SET standards. In view of this situation for the FTP, the agencies are adjusting the Phase 2 FTP baseline to reflect this shift. The underlying reasons for this shift are mostly related to manufacturers optimizing their SCR thermal management strategy over the FTP in ways that we (mistakenly) thought they already had in MY 2010 (i.e., the Phase 1 baseline). As 
background, the FTP includes a cold- start, a hot-start and significant time spent at engine idle. During these portions of the FTP, the NO
XSCR 
system can cool down and lose NO X 
reducing efficiency. One simplistic strategy to maintain SCR temperature is to inefficiently consume additional fuel, such that the fuel energy is lost to the 
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179The agencies note that the CO 2and fuel 
consumption standards for Class 7 and 8 
combination tractors do not cover gasoline or LHDD engines, as those are not used in Class 7 and 8 
combination tractors. 
180Tractor engine standards apply to all tractor 
engines, without regard to the actual fuel ( e.g., diesel or natural gas) or engine-cycle classification 
(e.g., compression-ignition or spark-ignition). exhaust system in the form of heat. 
There are more sophisticated strategies to maintain SCR temperature, however, but these apparently required additional time from MY 2010 for research, development and refinement. In updating these baseline values, the agencies did consider the concerns raised by manufacturers about the potential impact of IRAFs on baseline emissions. 
As just noted, at the time of Phase 1 
we had not realized that these improvements were not already in the Phase 1 baseline. These include optimizing the use of an intake throttle to decrease excess intake air at idle and SCR catalyst reformulation to maintain SCR efficiency at lower temperatures. Based on this information, which was provided to the agencies by engine manufacturers, but only after we specifically requested this information, the agencies concluded that in Phase 1 we did not account for how much further these kinds of improvements could still impact FTP fuel consumption. Conversely, only by reviewing the new MY 2016 certification data did we realize how little SCR thermal management optimization actually occurred for the engine model years that we used to establish the Phase 1 baseline—namely MY 2009 and MY 2010 engines. Because we never accounted for this kind of improvement in our Phase 2 proposal’s stringency analysis for meeting the Phase 2 proposed FTP standards, this baseline shift does not alter our projected effectiveness and market adoption rates from the proposal. Therefore, we continue to apply the same improvements that we proposed, but we apply them to the updated FTP baseline. See Section II.D.(5) for a discussion on how this impacts carry- over of Phase 1 emission credits. 
Table II–4 shows the Phase 2 diesel 
engine final CO
2baseline emissions. 
Note that the gasoline engine CO 2 
baseline for Phase 2 is the same as the Phase 1 HD gasoline FTP standard, 627 g/bhp-hr. More detailed analyses on these Phase 2 baseline values of tractor and vocational vehicles can be found in Chapter 2.7.4 of RIA. 
TABLE II–4—P HASE 2 DIESEL ENGINE FINAL CO 2ANDFUELCONSUMPTION BASELINE EMISSIONS  
Units HHD SET MHD SET HHD FTP MHD FTP LHD FTP 
g/bhp-hr .................................................. 455 481 525 558 576 
gal/100 bhp-hr ........................................ 4.4695 4.7250 5.1572 5.4813 5.6582 
As described below, the agencies are 
adopting standards for new 
compression-ignition engines for Phase 2, commencing in MY 2021, that will require additional reductions in CO
2 
emissions and fuel consumption beyond the Phase 2 baselines. The agencies are not adopting new CO
2or fuel 
consumption engine standards for new 
heavy-duty gasoline engines. Note, however, that we are projecting some 
small improvement in gasoline engine performance that will be recognized 
over the vehicle cycles (that is, reflected in the stringency of certain of the 
vocational vehicle standards). See Section V.B.2.a below. 
For diesel engines to be installed in 
Class 7 and 8 combination tractors, the agencies are adopting the SET standards shown in Table II–5.
179The MY 2027 
SET standards for engines installed in tractors will require engine manufacturers to achieve, on average, a 5.1 percent reduction in fuel 
consumption and CO
2emissions beyond 
the Phase 2 baselines. We are also adopting SET standards in MY 2021 and MY 2024 that will require tractor engine manufacturers to achieve, on average, 1.8 percent and 4.2 percent reductions in fuel consumption and CO
2emissions, 
respectively, beyond the Phase 2 baselines. 
TABLE II–5—P HASE 2 HEAVY -DUTYTRACTOR ENGINE STANDARDS FOR ENGINES180OVER THE SET C YCLE  
Model year Standard Heavy 
heavy-duty Medium 
heavy-duty 
2021–2023 ....................................... CO 2(g/bhp-hr) ...........................................................................................
Fuel Consumption (gallon/100 bhp-hr) .....................................................447 
4.3910 473 
4.6464 
2024–2026 ....................................... CO 2(g/bhp-hr) ...........................................................................................
Fuel Consumption (gallon/100 bhp-hr) .....................................................436 
4.2829 461 
4.5285 
2027 and Later ................................ CO 2(g/bhp-hr) ...........................................................................................
Fuel Consumption (gallon/100 bhp-hr) .....................................................432 
4.2436 457 
4.4892 
For diesel engines to be installed in 
vocational chassis, the agencies are 
adopting the FTP standards shown in Table II–6. The MY 2027 FTP standards for engines installed in vocational chassis will require engine manufacturers to achieve, on average, a 4.2 percent reduction in fuel consumption and CO
2emissions beyond 
the Phase 2 baselines. We are also adopting FTP standards in MY 2021 and MY 2024 that will require vocational chassis engine manufacturers to 
achieve, on average, 2.3 percent and 3.6 percent reductions in fuel consumption and CO
2emissions, respectively, 
beyond the Phase 2 baselines. 
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181Heavy heavy-duty engine standards apply to 
all heavy heavy-duty engines, without regard to the 
actual fuel (e.g., diesel or natural gas) or engine- 
cycle classification (e.g., compression-ignition or 
spark-ignition). 
182The agencies are not adopting new CO 2or fuel 
consumption engine standards for new heavy-duty 
gasoline engines. Therefore, the Phase 2 HD gasoline FTP standard is the same as the Phase 1 HD gasoline FTP standard, 627 g/bhp-hr, 7.0552 gallon/100 bhp-hr. 
183See Section IX.M for additional information 
about payback periods. TABLE II–6—V OCATIONAL DIESEL (CI) E NGINE STANDARDS OVER THE HEAVY -DUTYFTP C YCLE  
Model year Standard Heavy 
heavy-duty181 Medium 
heavy-duty 
diesel181 Light 
heavy-duty 
diesel182 
2021–2023 ................. CO 2(g/bhp-hr) .....................................................................................
Fuel Consumption (gallon/100 bhp-hr) ................................................513 
5.0393 545 
5.3536 563 
5.5305 
2024–2026 ................. CO 2(g/bhp-hr) .....................................................................................
Fuel Consumption (gallon/100 bhp-hr) ................................................506 
4.9705 538 
5.2849 555 
5.4519 
2027 and Later .......... CO 2(g/bhp-hr) .....................................................................................
Fuel Consumption (gallon/100 bhp-hr) ................................................503 
4.9411 535 
5.2554 552 
5.4224 
(a) Feasibility of the Diesel 
(Compression-Ignition) Engine Standards 
In this section, the agencies discuss 
our assessment of the feasibility of the engine standards and the extent to which they conform to our respective statutory authorities and responsibilities. More details on the technologies discussed here can be found in RIA Chapter 2.3. The feasibility of these standards is further discussed in RIA Chapter 2.7 for tractor and vocational vehicle engines. While the projected technologies are discussed 
here separately, as is discussed at the beginning of this Section II.D, the agencies also accounted for dis- synergies between technologies. Note that Section II.D.(2)(e) discusses the potential for some manufacturers to achieve greater emission reductions by introducing new engine platforms, and how and why these reductions are reflected in the tractor and vocational vehicle standards. 
Based on the technology analysis 
described below, the agencies project that a technology path exists that will allow engine manufacturers to meet the final Phase 2 standards by 2027, and to meet the MY 2021 and 2024 standards. The agencies also project that these manufacturers will be able to meet these standards at a reasonable cost and without adverse impacts on in-use reliability. 
In general, engine performance for 
CO
2emissions and fuel consumption 
can be improved by improving the internal combustion process and by reducing energy losses. More specifically, the agencies have identified the following key means by which fuel efficiency can be improved: •Combustion optimization 
•Turbocharger design and 
optimization 
•Engine friction and other parasitic 
loss reduction 
•Exhaust after-treatment pressure 
drop reduction 
•Intake air and exhaust system 
pressure drop reduction (including EGR 
system) 
•Engine down-sizing to improve core 
engine efficiency 
•Engine down-speeding over the 
SET, and in-use, by lug curve shape optimization 
•Waste heat recovery system 
installation and optimization 
•Physics model based electronic 
controls for transient performance optimization 
The agencies are gradually phasing in 
the separate engine standards from 2021 
through 2027 so that manufacturers can gradually introduce these technology improvements. For most of these, the agencies project manufacturers could begin applying these technologies to about 45–50 percent of their heavy-duty engines by 2021, 90–95 percent by 2024, and ultimately apply them to 100 percent of their heavy-duty engines by 2027. However, for some of these improvements (such as waste heat recovery and engine downsizing) we project lower application rates in the Phase 2 time frame. This phase-in structure is consistent with the normal manner in which manufacturers introduce new technology to manage limited R&D budgets as well as to allow them to work with fleets to fully evaluate in-use reliability before a technology is applied fleet-wide. The agencies believe the phase-in schedule will allow manufacturers to complete these normal processes. See RIA 2.3.9. 
Based on our technology assessment 
described below, the engine standards appear to be consistent with the agencies’ respective statutory authorities. All of the technologies with high penetration rates above 50 percent have already been demonstrated to some extent in the field or in research laboratories, although some development work remains to be completed. We note that our feasibility 
analysis for these engine standards is not based on projecting 100 percent application for any technology until 2027. We believe that projecting less than 100 percent application is appropriate and gives us additional confidence that the 2021 and 2024 MY standards are feasible. 
Because this analysis considers 
reductions from engines meeting the Phase 1 standards, it assumes manufacturers will continue to include the same compliance margins as in Phase 1. In other words, a manufacturer currently declaring FCLs 10 g/bhp-hr above its measured emission rates (in order to account for production and test- to-test variability) will continue to do the same in Phase 2. Both the costs and benefits are determined relative to these baselines, and so are reflective of these compliance margins. 
The agencies have carefully 
considered the costs of applying these technologies, which are summarized in Section II.D.(2)(d). These costs appear to be reasonable on both a per engine basis, and when considering payback periods.
183The engine technologies are 
discussed in more detail below. Readers are encouraged to see the RIA Chapter 2.7 for additional details (and underlying references) about our 
feasibility analysis. 
(i) Combustion Optimization 
Although manufacturers are making 
significant improvements in combustion 
to meet the Phase 1 engine standards, the agencies project that even more improvement is possible after 2018. For example, improvements to fuel injection systems will allow more flexible fuel injection capability with higher injection pressure, which can provide more opportunities to improve engine fuel efficiency. Further optimization of piston bowls and injector tips will also improve engine performance and fuel efficiency. We project that a reduction of up to 1.0 percent is feasible in the 2024 model year through the use of 
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184http://www.volvotrucks.us/powertrain/d13/ . these technologies, although it will 
likely apply to only 95 percent of engines until 2027. 
Another important area of potential 
improvement is advanced engine control incorporating model based calibration to reduce losses of control during transient operation. Improvements in computing power and speed will make it possible to use much more sophisticated algorithms that are more predictive than today’s controls. Because such controls are only beneficial during transient operation, they will reduce emissions over the FTP cycle, over the ARB Transient cycle’s cycle-average mapping procedure, and during in-use operation, but this technology will not reduce emissions over the SET cycle or over the steady- state engine mapping procedure. Thus, the agencies are projecting model based control reductions only for vocational engines’ FTP standards and for projecting improvements captured by the cycle-average mapping over the ARB Transient cycle. Although this control concept is not currently available and is still under development, we project model based controls achieving a 2 percent improvement in transient emissions. Based on model based controls already in widespread use in engine laboratories for the calibration of simpler controllers and based on recent model based control development under the DOE SuperTruck partnership (e.g., DTNA’s SuperTruck engine’s model based controls), we project that such controls could be in limited production for some engine models by 2021. We believe that some vocational chassis applications would particularly benefit from these controls in-use (e.g., urban 
applications with significant in-use transient operation). Therefore, we project that a modest amount of engine models will have these controls by MY 2021. We also project that manufacturers will learn more from the in-use operation of these technology leading engines, and manufacturers will be able to improve these controls even further, such that they would 
additionally benefit other vocational applications, such as multi-purpose and regional applications. By 2027, we project that 40 percent of all vocational diesel engines will incorporate model- based controls at a 2 percent level of effectiveness. 
(ii) Turbocharging System 
Many advanced turbocharger 
technologies can be brought into 
production in the time frame between 2021 and 2027, and some of them are already in production, such as mechanical or electric turbo- compounding, more efficient variable 
geometry turbines, and Detroit Diesel’s patented asymmetric turbocharger. A turbo-compound system, like those installed on some of Volvo’s EURO VI compliant diesels and on some of DTNA’s current U.S. offerings (supplied to DTNA by a division of Cummins), extracts energy from the exhaust to provide additional power. Mechanical turbo-compounding includes a power turbine located downstream of the turbine which in turn is connected to the crankshaft to supply additional power. On-highway demonstrations of this technology began in the early 1980s. It was used first in heavy duty production in the U.S. by Detroit Diesel for their DD15 and DD16 engines and reportedly provided a 3 to 5 percent fuel consumption reduction. Results are duty cycle dependent, and require significant time at high load to realize an in-use fuel efficiency improvement. Lightly loaded vehicles on flat roads or at low vehicle speeds can expect little or no benefit. Volvo reports two to four percent fuel consumption improvement in line haul applications.
184Because of 
turbo-compound technology’s drive cycle dependent effectiveness, the agencies are only projecting a market penetration of 10 percent for all tractor engines, at slightly less than 2 percent effectiveness over the SET. The agencies are considering turbo-compound to be 
mutually exclusive with WHR because both technologies seek to extract additional usable work from the same waste heat and are unlikely to be used together. 
(iii) Engine Friction and Parasitic Losses 
The friction associated with each 
moving part in an engine results in a 
small loss of engine power. For example, frictional losses occur at bearings, in the valve train, and at the piston ring-cylinder interface. Taken together such losses represent a measurable fraction of all energy lost in an engine. For Phase 1, the agencies projected a 1–2 percent reduction in fuel consumption due to friction reduction. However, new information leads us to project that an additional 1.4 percent reduction is possible for some engines by 2021 and all engines by 2027. These reductions are possible due to improvements in bearing materials, lubricants, and new accessory designs such as variable-speed pumps. 
(iv) After-Treatment Optimization 
All heavy duty diesel engine 
manufacturers are already using diesel 
particulate filters (DPFs) to reduce particulate matter (PM) and selective 
catalytic reduction (SCR) to reduce NO
X 
emissions. The agencies see two areas in which improved after-treatment systems can also result in lower fuel consumption. First, increased SCR efficiency could allow re-optimization of combustion for better fuel consumption because the SCR would be capable of reducing higher engine-out NO
Xemissions. We don’t expect this to 
be significant, however. Manufacturers already optimize the DEF (urea) consumption and fuel consumption to achieve the lowest cost of operation; taking into account fuel consumption, DEF consumption and the prices of fuel and DEF. Therefore, if manufacturers re- optimized significantly for fuel consumption, it is possible that this would lead to higher net operating costs. This scenario is highly dependent upon fuel and DEF prices, so projecting this technology path is uncertain. Second, improved designs could reduce backpressure on the engine to lower pumping losses. If manufacturers have opportunities to lower backpressure within the size constraints of the vehicle, the agencies project that manufacturers will opt to lower after- treatment back pressure. The agencies project the combined impact of these improvements would be 0.6 percent over the SET. 
Note that this improvement is 
independent of cold-start improvements made recently by some manufacturers with respect to vocational engines. Thus, the changes being made to the FTP baseline engines do not reduce the likelihood of the benefits of re- optimizing after-treatment projected here. 
(v) Engine Intake and Exhaust Systems 
Various high efficiency air handling 
for both intake air and exhaust systems 
could be produced in the 2020 and 2024 time frame. To maximize the efficiency of such processes, induction systems may be improved by manufacturing more efficiently designed flow paths (including those associated with air cleaners, chambers, conduit, mass air flow sensors and intake manifolds) and by designing such systems for improved 
thermal control. Improved turbocharging and air handling systems will likely include higher efficiency EGR systems and intercoolers that reduce frictional pressure losses while maximizing the ability to thermally control induction air and EGR. EGR systems that often rely upon an adverse pressure gradient (exhaust manifold pressures greater than intake manifold pressures) must be reconsidered and their adverse pressure gradients 
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185See 2010 NAS Report, page 57. minimized. Other components that offer 
opportunities for improved flow efficiency include cylinder heads, ports and exhaust manifolds to further reduce pumping losses by about 1 percent over the SET. 
(vi) Engine Downsizing and Down 
Speeding 
Proper sizing of an engine is an 
important component of optimizing a vehicle for best fuel consumption. This Phase 2 rule will require reductions in road load due to aerodynamic resistance, tire rolling resistance and weight, which will result in a drop in the vehicle power demand for most operation. This drop moves the engine operating points down to a lower load zone, which can move the engine away from operating near its peak thermal efficiency (a.k.a. the ‘‘sweet spot’’). Engine downsizing combined with engine down speeding can allow the engine to move back to higher loads and a lower speed zone, thus achieving better fuel efficiency in the real world. However, because of the way engines are tested, little of the benefit of engine downsizing would be detected during engine testing (if power density remains the same) because the engine test cycles are de-normalized based on the full torque curve. Thus, the separate engine standards are not the appropriate standards for recognizing the benefits of 
engine downsizing. Nevertheless, we project that some small benefit can be measured over the engine test cycles depending on the characteristics of the engine fuel map and how the SET points are determined as a function of the engine’s lug curve. 
After the proposal we received 
comments recommending that we should recognize some level of engine down speeding within the separate engine standards. Based on this comment and some additional confidential business information that we received, we believe that engine lug curve reshaping to optimize the locations of the 13-mode points is a way that manufacturers can demonstrate some degree of engine down-speeding over the engine test. As pointed out in Chapter 2.3.8 and 2.7.5 of the RIA, down speeding via lug curve reshaping alone can provide SET reductions in the range of 0.4 percent depending on the engine map characteristics. 
(vii) Waste Heat Recovery 
More than 40 percent of all energy 
loss in an engine is lost as heat to the 
exhaust and engine coolant. For many years, manufacturers have been using turbochargers to convert some of this waste heat in the exhaust into usable mechanical power that is then used to compress the intake air. Manufacturers have also been developing a Rankine cycle-based system to extract additional heat energy from the engine. Such systems are often called waste heat recovery (WHR) systems. The possible sources of waste heat energy include the exhaust, recirculated exhaust gases, compressed charge air, and engine coolant. The basic approach with WHR is to use waste heat from one or more of these sources to evaporate a working fluid, which is passed through a turbine or equivalent expander to create mechanical or electrical power, then re- condensed. 
For the proposal, the agencies 
projected that by 2027, 15 percent of tractor engines would employ WHR systems with an effectiveness of better than three percent. We received many comments on this projection, which are discussed briefly below and in more detail in the RTC. In particular, we note that some of the comments included confidential data related to systems not yet on the market. After carefully considering all of these comments, we have revised our projections to increase the effectiveness, decrease costs, and project higher adoption rates than we proposed. 
Prior to the Phase 1 Final Rule, the 
NAS estimated the potential for WHR to reduce fuel consumption by up to 10 percent.
185However, the agencies do 
not believe such levels will be achievable within the Phase 2 time frame. There currently are no commercially available WHR systems for diesel engines, although research prototype systems are being tested by some manufacturers. American Trucking Association, Navistar, DTNA, OOIDA, Volvo, and UPS commented that because WHR is still in the prototype stage, it should not be assumed for setting the stringency of the tractor engine standards. Many of these commenters pointed to the additional design and development efforts that will be needed to reduce cost, improve packaging, reduce weight, develop controls, select an appropriate working fluid, implement expected OBD diagnostics, and achieve the necessary reliability and durability. Some stated that the technology has not been thoroughly tested or asked that more real-world data be collected before setting standards based on WHR. Some of these commenters provided confidential business information pertaining to their analysis of WHR system component costs, failure modes, and projected warranty cost 
information. 
Alternatively, a number of 
commenters including Cummins, ICCT, CARB, ACEEE, EDF, Honeywell, ARB and others stated that the agencies should increase the assumed application rate of WHR in the final rule and the overall stringency of the engine standards. They argued the agencies’ WHR technology assessment was outdated and too conservative, the fuel savings and GHG reduction estimation for WHR were too low, and the agencies’ cost estimates were based on older WHR systems where costs were confounded with hybrid component costs and that these have since been improved upon. In addition, the agencies received CBI information supporting the arguments of some of these commenters. 
Cummins stated the agencies 
underestimated the commercial viability of WHR and that we overstated the development challenges and timing in the NPRM. They said WHR can provide a 4 to 5 percent improvement in fuel consumption on tractor drive cycles and that WHR would be commercially viable and available in production as early as 2020 and will exceed the agencies’ estimates for market penetration over the period of the rule. According to Cummins, the reliability of their WHR system has improved with each generation of the technology and they have developed a smaller system footprint, improved integration with the engine and vehicle and a low-GWP working fluid, resulting in a much more compact and integrated system. They added that their system would be evaluated in extended customer testing by the end of 2015, and that results of that experience will inform further technology development and product engineering leading to expected commercial product availability in the 2020 timeframe. Furthermore, they said multiple product development cycles over the implementation timeframe of the rule would provide opportunities for further development for reduced cost and improved performance and reliability. 
Some commenters, including EDF, 
said the agencies’ assumed design had little in common with the latest designs planned for production. They cited several publications, including the NAS 
21st Century Truck Program report #3 and stated WHR effectiveness is much higher than the agencies estimated. Gentham cited an ICCT study saying that up to a 12 percent fuel consumption reduction from a 2010 baseline engine is possible with the application of advanced engine technologies and WHR. 
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186NACFE 2015 Annual Fleet Fuel Study. The agencies recognize that much 
work remains to be done, but we are 
providing significant lead time to bring WHR to market. Based on our assessment of each manufacturer’s work to date, we are confident that a commercially-viable WHR capable of reducing fuel consumption by over three percent will be available in the 2021 to 2024 time frame. Concerns about the system’s cost and complexity may remain high enough to limit the use of such systems in this time frame. Moreover, packaging constraints and lower effectiveness under transient conditions will likely limit the application of WHR systems to line-haul tractors. Refer to RIA Chapter 2.3.9 for a detailed description of these systems and their applicability. For our analysis of the engine standards, the agencies project that WHR with the Rankine technology could be used on 1 percent of tractor engines by 2021, on 5 percent by 2024, and 25 percent by 2027, with nearly all being used on sleeper cabs. We project this sharper increase in market adoption in the 2027 timeframe because we have noted that most technology adoption rate curves follow an S-shape: Slow initial adoption, then more rapid adoption, and then a leveling off as the market saturates (not always at 100 percent).
186We assumed 
an S-shape curve for WHR adoption, where we project a steeper rise in market adoption in and around the 2027 timeframe. Given our averaging, banking and trading program flexibilities and that manufacturers may choose from a range of other technologies, we believe that manufacturers will be able to meet the 2027 standards, which we based on a 25 percent WHR adoption in tractor engines. Although we project these as steps, it is more likely that manufacturers will try to gradually increase the WHR adoption in MY 2025 and MY 2026 from the 5 percent in 2024 to generate emission credits to smooth the transition to the 2027 standards. 
Commenters opposing the agencies’ 
WHR projections argued that the real- world GHG and fuel consumption savings will be less than in prototype systems. DTNA said a heat rejection increase of 30 percent to 40 percent with WHR systems will require larger radiators, resulting in more aerodynamic drag and lower fuel savings from WHR systems. DTNA cited a Volvo study showing a 2 percent loss of efficiency with the larger frontal areas needed to accommodate heat rejection from WHR systems. Daimler stated effectiveness may be lower than expected since there is large drop off in fuel savings when the tractor is not operating on a steady state cycle and the real world performance of WHR systems will be hurt by transient response issues. Daimler and ACEEE said the energy available from exhaust and other waste heat sources could diminish as tractor aerodynamics improve, thus lowering the expected fuel savings from WHR. Daimler said because of this, WHR estimated fuel savings was overestimated by the agencies. Navistar said WHR working fluids will have a significant GHG impact based on their high global warming potential. They commented that fuel and GHG reductions will be lower in the real world with the re-weighting of the RMC which results in lower engine load, and thus lower available waste heat. However, none of these commenters have access to the full range of data available to the agencies, which includes CBI. 
It is important to note that the net cost 
and effectiveness of future WHR systems depends on the sources of waste heat. Systems that extract heat from EGR gases may provide the side benefit of reducing the size of EGR coolers or eliminating them altogether. To the extent that WHR systems use exhaust heat, they increase the overall cooling system heat rejection requirement and likely require larger radiators. This could have negative impacts on cooling fan power needs and vehicle aerodynamics. Limited engine compartment space under the hood could leave insufficient room for additional radiator size increasing. Many of these issues disappear if exhaust waste heat is not recovered from the tailpipe and brought under the hood for conversion to mechanical work. In fact, it is projected that if a WHR system only utilizes heat that was originally within the engine compartment (e.g., EGR cooler heat, 
coolant heat, oil heat, etc.), then any conversion of that heat to mechanical heat actually reduces the heat rejection demand under the hood; potentially leading to smaller radiators and lower frontal area, which would actually lead toward improved aerodynamic performance. Refer to RIA Chapter 2.3.9 for more discussion. 
Several commenters stated that costs 
are highly uncertain for WHR technology, but argued that the agencies’ assumption of a $10,523 cost in 2027 are likely significantly lower than reality. Volvo estimated a cost of $21,700 for WHR systems. Volvo said that in addition to hardware cost being underestimated, the agencies had not 
properly accounted for other costs such as the R&D needed to bring the technology into production within a 
vehicle. Volvo said they would lose $17,920 per unit R&D alone, excluding other costs such as materials and administrative expenses. Daimler said that costs almost always inflate as the complexity of real world requirements drive up need for more robust designs, sensors, controls, control hardware, and complete vehicle integration. They added that development costs will be large and must be amortized over limited volumes. Furthermore, OOIDA said the industry experience with such complex systems is that maintenance, repair, and down-time cost can be much greater than the initial purchase cost. ATA and OOIDA said that potential downtime associated with an unproven technology is a significant concern for the industry. 
On the other hand, some commenters 
argued that the agencies had actually overestimated WHR costs in the proposal. These commenters generally argued that engineering improvements to the WHR systems that will go into production in the Phase 2 time frame would lower costs, in particular by reducing components. The agencies largely agree with these commenters and we have revised our analysis to reflect these cost savings. See RIA 2.11.2.15 for additional discussion. 
(viii) Technology Packages for Diesel 
Engines Installed in Tractors 
This Section (a)(viii) describes 
technology packages that the agencies project could be applied to Phase 1 tractor engines to meet the Phase 2 SET separate engine standards. Section II.D.(2)(e) also describes additional improvements that the agencies project some engine manufacturers will be able to apply to their engines. 
We received comments on the tractor 
engine standards in response to the proposal and in response to the NODA. These comments can be grouped into 
two general themes. One theme expressed by ARB, non-governmental environmentally focused organizations, Cummins and some technology suppliers like Honeywell, recommended higher engine stringencies, up to 10–15 percent in some comments. Another theme, generally expressed by vertically integrated engine and vehicle manufacturers supported either no Phase 2 engine standards at all, or they supported the proposal’s standards, but none of these commenters supported standards that were more stringent than what we proposed. An example of the contrast between these two themes can be shown in one report submitted to the docket and another submission rebutting the statements made in the 
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187Environmental Defense Fund, Greenhouse Gas 
Emission and Fuel Efficiency Standards for 
Medium-Duty and Heavy-Duty Engines and Vehicles—Phase 2—Notice of Data Availability,’’ Docket: ID No. EPA–HQ–OAR–2014–0817, October 1, 2015. 
188Daimler Trucks North America, Navistar, Inc, 
Paccar Inc, and Volvo Group,’’ Greenhouse Gas Emission and Fuel Efficiency Standards for Medium-Duty and Heavy-Duty Engines and Vehicles—Phase 2—Notice of Data Availability,’’ 
Docket: ID No. EPA–HQ–OAR–2014–0817, April 1, 2016. 189Navistar, Inc., Greenhouse Gas Emission and 
Fuel Efficiency Standards for Medium-Duty and 
Heavy-Duty Engines and Vehicles—Phase 2— Notice of Data Availability,’’ Docket: ID No. EPA– HQ–OAR–2014–0817, April 1, 2016. 
190Daimler Trucks North America LLC, Detroit 
Diesel Corporation, Greenhouse Gas Emission and Fuel Efficiency Standards for Medium-Duty and Heavy-Duty Engines and Vehicles—Phase 2— Notice of Data Availability,’’ Docket: ID No. EPA– HQ–OAR–2014–0817, April 1, 2016. 191California Air Resources Board (CARB), 
Greenhouse Gas Emissions and Fuel Efficiency 
Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2 (Docket ID No. EPA–HQ– 
OAR–2014–0827 and Docket ID No. NHTSA–2014– 0132). 
192As used in the agencies’ analyses, dis-synergy 
factors less than one reflect dis-synergy between technologies that reduce the overall effectiveness, while dis-synergy factors greater than one would indicate synergy that improves the overall effectiveness. report. The report was submitted to the 
agencies by the Environmental Defense Fund (EDF).
187On the other hand, four 
vertically integrated engine and vehicle manufacturers, DTNA, Navistar, Paccar, and Volvo, submitted a rebuttal to EDF’s findings.
188Some of these individual 
vehicle manufacturers also provided 
their own comments on EDF’s report.
189 190 Cummins also provided 
comments and recommended stringencies somewhere between EDF’s recommendations and the integrated manufacturers’ rebuttal. Cummins recommended achieving reductions by 2030 in the range of 9–15 percent. CARB’s recommendation from their comments
191is 7.1 percent in 2024. 
The agencies carefully considered this 
wide range of views, and based on the best data available, the agencies modified some of our technology projections between the proposal and the final rule. 
Table II–5 lists our projected 
technologies together with our projected effectiveness and market adoption rates 
for tractor engines. The reduction values shown as ’’SET reduction’’ are relative to our Phase 2 baseline values, as shown in Table II–7. It should be pointed out that the reductions in Table II–7 are based on the Phase 2 final SET weighting factors, shown in Table II–2. RIA Chapter 2.7.5 details the reasoning supporting our projection of improvements attributable to this fleet average technology package. 
TABLE II–7—P ROJECTED TRACTOR ENGINE TECHNOLOGIES AND REDUCTION  
SET mode SET weighted 
reduction (%) 
2020–2027 Market 
penetration 
(2021) 
(%) Market 
penetration 
(2024) 
(%) Market 
penetration 
(2027) 
(%) 
Turbo compound with clutch ........................................................................... 1.9 5 10 10 
WHR (Rankine cycle) ...................................................................................... 3.6 1 5 25 
Parasitic/Friction (Cyl Kits, pumps, FIE), lubrication ....................................... 1.5 45 95 100 
After-treatment (lower dP) ............................................................................... 0.6 30 95 100 
EGR/Intake & exhaust manifolds/Turbo/VVT/Ports ......................................... 1.1 45 95 100 
Combustion/FI/Control ..................................................................................... 1.1 45 95 100 
Downsizing ....................................................................................................... 0.3 10 20 30 
Overall reductions (%) 
Weighted reduction (%) ................................................................................... ...................... .. 1.7 4.0 4.8 
Down speeding optimization on SET .............................................................. ........................ 0.1 0.2 0.3 
Total % reduction ..................................................................................... ........................ 1.8 4.2 5.1 
The weighted reductions shown in 
this table have been combined using the 
‘‘P-formula,’’ which has been augmented to account for technology dis-synergies that occur when combining multiple technologies. A 0.85 dis-synergy factor was used for 2021, and a 0.90 dis-synergy factor was used for 2024 and 2027.
192RIA Chapter 
2.7.4 provides details on the ‘‘P- formula’’ and an explanation for how the dis-synergy factors were determined. Some commenters argued that use of a single dis-synergy factor for all technologies is inappropriate. While we agree that it would be preferable to have a more detailed analysis of the dis- synergy between each pair or group of technologies, we do not have the information necessary to conduct such an analysis. In the absence of such information, the simple single value approach is a reasonable approximation. Moreover, we note that the degree of dis-synergy is sufficiently small to make the impact of any errors on the resulting standards negligible. 
Figure II.3 2018 HHD Figure II.4 are 
the samples of the HHD engine fuel maps used for the agencies’ MY 2018 baseline engine and MY 2027 sleeper 
cab engine for tractors. As can be seen from these two figures, the torque curve shapes are different. This is because engine down speeding optimization for the SET is taken into consideration, where the engine peak torque is increased and the engine speed is shifted to lower speed. All maps used by GEM for all vehicles are shown in Chapter 2.7 of the RIA. 
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(ix) Technology Packages for Diesel 
Engines Installed in Vocational Vehicles 
For diesel engines (and other 
compression-ignition engines) used in vocational vehicles, the MY 2021 standards will require engine manufacturers to achieve, on average, a 2.3 percent reduction in fuel consumption and CO
2emissions beyond 
the Phase 2 FTP baselines. Beginning in 
MY 2024, the agencies are requiring a 3.6 percent reduction in fuel consumption and CO
2emissions beyond 
the Phase 2 FTP baselines for all diesel 
engines including LHD, MHD, and HHD, and beginning in MY 2027 this increases to 4.2 percent, on average. The agencies have based these FTP 
standards on the performance of reduced parasitic and friction losses, improved after-treatment, combustion optimization, superchargers and 
variable geometry turbochargers, physics model-based controls, improved EGR pressure drop, and variable valve timing (only in LHD and MHD engines). 
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ER25OC16.003</GPH>mstockstill on DSK3G9T082PROD with RULES2Figure 11.3 2018 HHD Baseline Engine Fuel Map. 
Figure 11.4 2027 HHD Engine Fuel Map for a Sleeper Cab Tractor Vehicle. 73561 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
The percent reduction for the MY 2021, 
MY 2024, and MY 2027 standards is based on the combination of technology effectiveness and the respective market adoption rates projected. 
Most of the potential engine 
technologies discussed previously for tractor engines can also be applied to vocational engines. However, neither of the waste heat technologies, Rankine cycle nor turbo-compound, are likely to be applied to vocational engines because they are less effective under transient operation, which is weighted more heavily for all of the vocational sub-categories. Given the projected cost and complexity of such systems, we believe that for the Phase 2 time frame manufacturers will focus their WHR development work on tractor applications (which will have better payback for operators), rather than on vocational applications. In addition, the benefits due to engine downsizing, which can be realized in some tractor engines, may not be realized at all in in the vocational sector, again because this control technology produces few benefits under transient operation. 
One of the most effective technologies 
for vocational engines is the optimization of transient controls with physics model based control, which would replace current look-up table based controls. These are described more in detail in Chapter 2.3 of the RIA. We project that more advanced transient controls, including different levels of model based control, discussed in Chapter 2.3 of the RIA, would continue to progress and become more broadly applicable throughout the Phase 2 timeframe. 
Other effective technologies include 
parasitic load/friction reduction, as well as improvements to combustion, air handling systems, turbochargers, and after-treatment systems. Table II–8 below lists those potential technologies together with the agencies’ projected market penetration rates for vocational engines. Again, similar to tractor engines, the technology reduction and market penetration rates are estimated by combining manufacturer-submitted confidential business information, together with estimates reflecting the agencies’ judgment, which is informed by historical trends in the market adoption of other fuel efficiency improving technologies. The reduction values shown as ‘‘percent reduction’’ are relative to the Phase 2 FTP baselines, which are shown in Table II– 3. The overall reductions combine the technology reduction values with their market adoption rates. The same set of the dis-synergy factors as the tractor are used for MY 2021, 2024, and 2027. 
TABLE II–8—P ROJECTED VOCATIONAL ENGINE TECHNOLOGIES AND REDUCTION  
Technology Percent 
reduction 
2020–2027 Market 
penetration 
2021 
(%) Market 
penetration 
2024 
(%) Market 
penetration 
2027 
(%) 
Model based control ........................................................................................ 2.0 25 30 40 
Parasitic/Friction .............................................................................................. 1.5 60 90 100 
EGR/Air/VVT/Turbo ......................................................................................... 1.0 60 90 100 
Improved AT .................................................................................................... 0.5 30 60 100 
Combustion Optimization ................................................................................. 1.0 60 90 100 
Weighted reduction (%)-L/M/HHD ................................................................... ........................ 2.3 3.6 4.2 
Figure II.5 is a sample of a 2018 
baseline engine fuel map for a MHD 
vocational engine. 
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(x) Summary of the Agencies’ Analysis 
of the Feasibility of the Diesel Engine Standards 
The HD Phase 2 standards are based 
on projected adoption rates for technologies that the agencies regard as the maximum feasible for purposes of EISA section 32902 (k) and appropriate under CAA section 202(a) based on the technologies discussed above and in RIA Chapter 2. The agencies believe these technologies can be adopted at the estimated rates for these standards within the lead time provided, as discussed in RIA Chapter 2.7. The 2021 and 2024 MY standards are phase-in standards on the path to the 2027 MY standards, and these earlier standards were developed using less aggressive application rates and therefore have lower technology package costs than the 2027 MY standards. 
As described in Section II.D.(2)(d) 
below, the costs to comply with these standards are estimated to range from $275 to $1,579 per engine. This is slightly higher than the costs for Phase 1, which were estimated to be $234 to $1,091 per engine. Although the agencies did not separately determine fuel savings or emission reductions due to the engine standards apart from the vehicle program, it is expected that the fuel savings will be significantly larger than these costs, and the emission reductions will be roughly proportional to the technology costs when compared to the corresponding vehicle program reductions and costs. Thus, we regard these standards as cost-effective. This is true even without considering payback period. The phase-in 2021 and 2024 MY standards are less stringent and less costly than the 2027 MY standards. Given that the agencies believe these standards are technologically feasible, are highly cost effective, and highly cost effective when accounting for the fuel savings, and have no apparent adverse potential impacts (e.g., there are no 
projected negative impacts on safety or vehicle utility), they appear to represent a reasonable choice under section 202(a) of the CAA and the maximum feasible under NHTSA’s EISA authority at 49 U.S.C. 32902(k)(2). 
(b) Basis for Continuing the Phase 1 
Spark-Ignited Engine Standard 
For gasoline vocational engines, we 
are not adopting more stringent engine standards. Today most SI-powered vocational vehicles are sold as incomplete vehicles by a vertically integrated chassis manufacturer, where the incomplete chassis shares most of the same technology as equivalent complete pickups or vans, including the powertrain. Another, even less common way that SI-powered vocational vehicles are built is by a non-integrated chassis manufacturer purchasing an engine from a company that also produces complete and/or incomplete HD pickup trucks and vans. Gasoline engines used in vocational vehicles are generally the same engines as are used in the complete HD pickups and vans in the Class 2b and 3 weight categories, although the operational demands of vocational vehicles often require use of the largest, most powerful SI engines, so that some engines fitted in complete pickups and vans are not appropriate for use in vocational vehicles. Given the relatively small sales volumes for gasoline-fueled vocational vehicles, manufacturers typically cannot afford to invest significantly in developing separate technology for these engines. 
The agencies received many 
comments suggesting that technologies be applied to increase the stringency of the SI engine standard. These comments were essentially misplaced, since the agencies already had premised the Phase 1 SI MY 2016 FTP engine standards on 100 percent adoption of these technologies. The commenters thus did not identify any additional engine technologies that the agencies did not already consider and account for in setting the MY 2016 FTP engine standard. Therefore, the Phase 1 SI engine FTP standard for these engines will remain in place. However, as noted above, projected engine improvements are being reflected in the stringency of the vehicle standard for the vehicle in which the engine will be installed. In part this is because the GEM cycles result in very different engine operation than what occurs when an engine is run over the engine FTP cycle. We believe that certain technologies will show a fuel consumption and CO
2emissions 
reduction during GEM cycles that do not occur over the engine FTP. We received comments on engine technologies that can be recognized over the GEM vehicle cycles. As a result, the Phase 2 gasoline-fueled vocational vehicle standards are predicated on adoption of advanced engine friction reduction and cylinder deactivation. To the extent any SI engines do not incorporate the projected engine technologies, manufacturers of SI- powered vocational vehicles would need to achieve equivalent reductions from some other vehicle technology to meet the vehicle standards. See Section V.C of this Preamble for a description of how we applied these technologies to develop the vocational vehicle standards. See Section VI.C of this Preamble for a description of the SI 
engine technologies that have been considered in developing the HD pickup truck and van standards. 
(c) Engine Improvements Projected for 
Vehicles Over the GEM Duty Cycles 
As part of the certification process for 
the Phase 2 vehicle standards, tractor and vocational vehicle manufacturers will need to represent their vehicles’ actual engines in GEM. Although the vehicle standards recognize the same engine technologies as the separate engine standards, each have different test procedures for demonstrating compliance. As explained earlier in Section II.D.(1), compliance with the tractor separate engine standards is 
determined from a composite of the Supplemental Engine Test (SET) procedure’s 13 steady-state operating points. Compliance with the vocational vehicle separate engine standards is 
determined over the Federal Test Procedure’s (FTP) transient engine duty cycle. In contrast, compliance with the vehicle standards is determined using GEM, which calculates composite results over a combination of 55 mph, 65 mph, ARB Transient and idle vehicle cycles. Each of these duty cycles emphasize different engine operating points; therefore, they can each recognize certain technologies differently. Hence, these engine improvements can be readily recognized in GEM and appropriately reflected in the stringency of the vehicle standards. It is important to note, however, that the tractor vehicle standards presented in Section III project that some (but not all) tractor engines will achieve greater reductions than required by the engine standards. This was reflected in the agencies’ feasibility analysis using projected engine fuel maps that represent engines having fuel efficiency better than what is required by the engine standards. Similarly, the vocational vehicle standards in presented in Section V project that the average vocational engine will achieve greater reductions than required by the engine standards. These additional reductions are recognized by GEM and 
are reflected in the stringency of the respective vehicle standards. 
Our first step in aligning our engine 
technology assessment at both the engine and vehicle levels was to separately identify how each technology impacts performance at each of the 13 individual test points of the SET steady- state engine duty cycle. For example, engine friction reduction technology is expected to have the greatest impact at the highest engine speeds, where frictional energy losses are the greatest. 
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As another example, turbocharger 
technology is generally optimized for best efficiency at steady-state cruise vehicle speed. For an engine, this is near its lower peak-torque speed and at a moderately high load that still offers sufficient torque reserve to climb modest road grades without frequent transmission gear shifting. The agencies also considered the combination of certain technologies causing dis- synergies with respect to engine efficiency at each of these test points. See RIA Chapter 2.3 and 2.7 for further details. Chapter 2.8 and 2.9 of the RIA details how the engine fuel maps are created for both tractor and vocational vehicles used for GEM as the default engine fuel maps. 
(d) Engine Technology Package Costs for 
Tractor and Vocational Engines (and Vehicles) 
As described in Chapters 2 and 7 of 
the RIA, the agencies estimated costs for each of the engine technologies discussed here. All costs are presented relative to engines projected to at least comply with the model year 2017 standards—i.e., relative to our Phase 2 
baseline engines. Note that we are not presenting any costs for gasoline engines (SI engines) in this section because we are not changing the SI engine standards. However, we are including a cost for additional engine technology as part of the vocational vehicle analysis in Section V.C.2.(e) (and appropriately so, since those engine improvements are reflected in the stringency of the vocational vehicle 
standard). Our engine cost estimates include a 
separate analysis of the incremental part 
costs, research and development activities, and additional equipment. 
Our general approach used elsewhere in this action (for HD pickup trucks, gasoline engines, Class 7 and 8 tractors, and Class 2b–8 vocational vehicles) estimates a direct manufacturing cost for a part and marks it up based on a factor to account for indirect costs. See also 75 FR 25376. We believe that approach is appropriate when compliance with the standards is achieved generally by installing new parts and systems purchased from a supplier. In such a case, the supplier is conducting the bulk of the research and development on the new parts and systems and including those costs in the purchase price paid by the original equipment manufacturer. Consequently, the indirect costs incurred by the original equipment manufacturer need not reflect significant cost to cover research and development since the bulk of that effort is already completed. For the MHD and HHD diesel engine segment, however, the agencies believe that OEMs will incur costs not associated with the purchase of parts or systems from suppliers or even the production of the parts and systems, but rather the development of the new technology by the original equipment manufacturer itself. Therefore, the agencies have directly estimated additional indirect costs to account for these development costs. The agencies used the same approach in the Phase 1 HD rule. EPA commonly uses this approach in cases where significant investments in 
research and development can lead to an emission control approach that requires no new hardware. For example, combustion optimization may significantly reduce emissions and cost a manufacturer millions of dollars to develop but would lead to an engine that is no more expensive to produce. Using a bill of materials approach would suggest that the cost of the emissions control was zero reflecting no new hardware and ignoring the millions of dollars spent to develop the improved combustion system. Details of the cost analysis are included in the RIA Chapter 2.7. To reiterate, we have used this different approach because the MHD and HHD diesel engines are expected to comply in part via technology changes that are not reflected in new hardware but rather reflect knowledge gained through laboratory and real world testing that allows for improvements in control system calibrations—changes that are more difficult to reflect through direct costs with indirect cost multipliers. Note that these engines are also expected to incur new hardware costs as shown in Table II–9 through Table II–12. EPA also developed the incremental piece cost for the components to meet each of the 2021 and 2024 standards. The costs shown in Table II–13 include a low complexity ICM of 1.15 and assume the flat-portion of the learning curve is applicable to each technology. 
(i) Tractor Engine Package Costs 
TABLE II–9—MY 2021 T RACTOR DIESEL ENGINE COMPONENT COSTS INCLUSIVE OF INDIRECT COSTMARKUPS AND  
ADOPTION RATES  
[2013$] 
Medium HD Heavy HD 
After-treatment system (improved effectiveness SCR, dosing, DPF) ............................................................... ...... $7 $7 
Valve Actuation ................................................................................................................ ........................................ 84 84 
Cylinder Head (flow optimized, increased firing pressure, improved thermal management) ................................. 3 3 
Turbocharger (improved efficiency) ............................................................................................. ............................ 9 9 
Turbo Compounding .............................................................................................................. .................................. 51 51 
EGR Cooler (improved efficiency) ............................................................................................... ............................ 2 2 
Water Pump (optimized, variable vane, variable speed) .......................................................................... .............. 44 44 
Oil Pump (optimized) ........................................................................................................... .................................... 2 2 
Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) .................................. 2 2 
Fuel Rail (higher working pressure) ............................................................................................ ............................ 5 5 
Fuel Injector (optimized, improved multiple event control, higher working pressure) ............................................ 5 5 
Piston (reduced friction skirt, ring and pin) .................................................................................. ........................... 1 1 
Valve train (reduced friction, roller tappet) .................................................................................. ............................ 39 39 
Waste Heat Recovery ............................................................................................................ .................................. 71 71 
‘‘Right sized’’ engine ......................................................................................................... ....................................... ¥41 ¥41 
Total .......................................................................................................................... ........................................ 284 284 
Note: ‘‘Right sized’’ diesel engine is a smaller, less costly engine than the engine it replaces. 
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TABLE II–10—MY 2024 T RACTOR DIESEL ENGINE COMPONENT COSTS INCLUSIVE OF INDIRECT COSTMARKUPS AND  
ADOPTION RATES  
[2013$] 
Medium HD Heavy HD 
After-treatment system (improved effectiveness SCR, dosing, DPF) ............................................................... ...... $14 $14 
Valve Actuation ................................................................................................................ ........................................ 169 169 
Cylinder Head (flow optimized, increased firing pressure, improved thermal management) ................................. 6 6 
Turbocharger (improved efficiency) ............................................................................................. ............................ 17 17 
Turbo Compounding .............................................................................................................. .................................. 93 93 
EGR Cooler (improved efficiency) ............................................................................................... ............................ 3 3 
Water Pump (optimized, variable vane, variable speed) .......................................................................... .............. 85 85 
Oil Pump (optimized) ........................................................................................................... .................................... 4 4 
Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) .................................. 4 4 
Fuel Rail (higher working pressure) ............................................................................................ ............................ 9 9 
Fuel Injector (optimized, improved multiple event control, higher working pressure) ............................................ 10 10 
Piston (reduced friction skirt, ring and pin) .................................................................................. ........................... 3 3 
Valve train (reduced friction, roller tappet) .................................................................................. ............................ 77 77 
Waste Heat Recovery ............................................................................................................ .................................. 298 298 
‘‘Right sized’’ engine ......................................................................................................... ....................................... ¥82 ¥82 
Total .......................................................................................................................... ........................................ 712 712 
Note: ‘‘Right sized’’ diesel engine is a smaller, less costly engine than the engine it replaces. 
TABLE II–11—MY 2027 T RACTOR DIESEL ENGINE COMPONENT COSTS INCLUSIVE OF INDIRECT COSTMARKUPS AND  
ADOPTION RATES  
[2013$] 
Medium HD Heavy HD 
After-treatment system (improved effectiveness SCR, dosing, DPF) ............................................................... ...... $15 $15 
Valve Actuation ................................................................................................................ ........................................ 172 172 
Cylinder Head (flow optimized, increased firing pressure, improved thermal management) ................................. 6 6 
Turbocharger (improved efficiency) ............................................................................................. ............................ 17 17 
Turbo Compounding .............................................................................................................. .................................. 89 89 
EGR Cooler (improved efficiency) ............................................................................................... ............................ 3 3 
Water Pump (optimized, variable vane, variable speed) .......................................................................... .............. 85 85 
Oil Pump (optimized) ........................................................................................................... .................................... 4 4 
Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) .................................. 4 4 
Fuel Rail (higher working pressure) ............................................................................................ ............................ 9 9 
Fuel Injector (optimized, improved multiple event control, higher working pressure) ............................................ 10 10 
Piston (reduced friction skirt, ring and pin) .................................................................................. ........................... 3 3 
Valve train (reduced friction, roller tappet) .................................................................................. ............................ 77 77 
Waste Heat Recovery ............................................................................................................ .................................. 1,208 1,208 
‘‘Right sized’’ engine ......................................................................................................... ....................................... ¥123 ¥123 
Total .......................................................................................................................... ........................................ 1,579 1,579 
Note: ‘‘Right sized’’ diesel engine is a smaller, less costly engine than the engine it replaces. 
(ii) Vocational Diesel Engine Package 
Costs 
TABLE II–12—MY 2021 V OCATIONAL DIESEL ENGINE COMPONENT COSTS INCLUSIVE OF INDIRECT COSTMARKUPS AND  
ADOPTION RATES  
[2013$] 
Light HD Medium HD Heavy HD 
After-treatment system (improved effectiveness SCR, dosing, DPF) ......................................... $8 $8 $8 
Valve Actuation ................................................................................................................ ............ 93 93 93 
Cylinder Head (flow optimized, increased firing pressure, improved thermal management) ..... 6 3 3 
Turbocharger (improved efficiency) ............................................................................................. 10 10 10 
EGR Cooler (improved efficiency) ............................................................................................... 2 2 2 
Water Pump (optimized, variable vane, variable speed) ............................................................ 58 58 58 
Oil Pump (optimized) ........................................................................................................... ........ 3 3 3 
Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) ...... 3 3 3 
Fuel Rail (higher working pressure) ............................................................................................ 8 6 6 
Fuel Injector (optimized, improved multiple event control, higher working pressure) ................ 8 6 6 
Piston (reduced friction skirt, ring and pin) ................................................................................. 1 1 1 
Valve train (reduced friction, roller tappet) .................................................................................. 70 52 52 
Model Based Controls ........................................................................................................... ...... 29 29 29 
Total .......................................................................................................................... ............ 298 275 275 
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TABLE II–13—MY 2024 V OCATIONAL DIESEL ENGINE COMPONENT COSTS INCLUSIVE OF INDIRECT COSTMARKUPS AND  
ADOPTION RATES  
[2013$] 
Light HD Medium HD Heavy HD 
After-treatment system (improved effectiveness SCR, dosing, DPF) ......................................... $14 $14 $14 
Valve Actuation ................................................................................................................ ............ 160 160 160 
Cylinder Head (flow optimized, increased firing pressure, improved thermal management) ..... 10 6 6 
Turbocharger (improved efficiency) ............................................................................................. 16 16 16 
EGR Cooler (improved efficiency) ............................................................................................... 3 3 3 
Water Pump (optimized, variable vane, variable speed) ............................................................ 81 81 81 
Oil Pump (optimized) ........................................................................................................... ........ 4 4 4 
Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) ...... 4 4 4 
Fuel Rail (higher working pressure) ............................................................................................ 11 9 9 
Fuel Injector (optimized, improved multiple event control, higher working pressure) ................ 13 10 10 
Piston (reduced friction skirt, ring and pin) ................................................................................. 2 2 2 
Valve train (reduced friction, roller tappet) .................................................................................. 97 73 73 
Model Based Controls ........................................................................................................... ...... 32 32 32 
Total .......................................................................................................................... ............ 446 413 413 
TABLE II–14—MY 2027 V OCATIONAL DIESEL ENGINE COMPONENT COSTS INCLUSIVE OF INDIRECT COSTMARKUPS AND  
ADOPTION RATES  
[2013$] 
Light HD Medium HD Heavy HD 
After-treatment system (improved effectiveness SCR, dosing, DPF) ......................................... $15 $15 $15 
Valve Actuation ................................................................................................................ ............ 172 172 172 
Cylinder Head (flow optimized, increased firing pressure, improved thermal management) ..... 10 6 6 
Turbocharger (improved efficiency) ............................................................................................. 17 17 17 
EGR Cooler (improved efficiency) ............................................................................................... 3 3 3 
Water Pump (optimized, variable vane, variable speed) ............................................................ 85 85 85 
Oil Pump (optimized) ........................................................................................................... ........ 4 4 4 
Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) ...... 4 4 4 
Fuel Rail (higher working pressure) ............................................................................................ 11 9 9 
Fuel Injector (optimized, improved multiple event control, higher working pressure) ................ 14 10 10 
Piston (reduced friction skirt, ring and pin) ................................................................................. 3 3 3 
Valve train (reduced friction, roller tappet) .................................................................................. 102 77 77 
Model Based Controls ........................................................................................................... ...... 41 41 41 
Total .......................................................................................................................... ............ 481 446 446 
(e) Feasibility of Additional Engine 
Improvements 
While the agencies’ technological 
feasibility analysis for the engine standards focuses on what is achievable for existing engine platforms, we 
recognize that it could be possible to achieve greater reductions by designing entirely new engine platforms. Unlike existing platforms, which are limited with respect to peak cylinder pressures (precluding certain efficiency improvements), new platforms can be designed to have higher cylinder pressure than today’s engines. New designs are also better able to incorporate recent improvements in materials and manufacturing, as well as other technological developments. Considered together, it is likely that a new engine platform could be about 2 percent better than engines using older platforms. Moreover, the agencies have seen CBI data that suggests improvement of more than 3 percent are possible. However, because designing and producing a new engine platform requires hundreds of millions of dollars in capital investment and significant lead time for research and development, it would not be appropriate to project that each engine manufacturer could complete a complete redesign of all of its engines within the Phase 2 time frame. Unlike light-duty, heavy-duty sales volumes are not large enough to support short redesign cycles. As a result, it can take 20 years for a manufacturer to generate the necessary return on the investment associated with an engine redesign. Forcing a manufacturer to redesign its engines prematurely could easily result in significant financial strain on a company. 
On the other hand, how far the 
various manufacturers are into their design cycles suggests that one or more manufacturers will probably introduce a new engine platform during the Phase 2 time frame. This would not enable other 
engine manufacturers to meet more stringent standards, and thus it would not be an appropriate basis to justify more stringent engine standards (and certainly not engine standards reflecting 100 percent use of technologies premised on existence of new platforms). However, the availability of some more efficient engines on the market will provide the opportunity for vehicle manufacturers to lower their 
average fuel consumption as measured by GEM. Vehicle manufacturers can use a mix of newer and older engine designs to achieve an average engine performance significantly better than what is required by the engine standards. Thus, the vehicle standards can reflect engine platform improvements (which are amenable to measurement in GEM), without necessarily forcing each manufacturer to achieve these additional reductions, 
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which may be achievable only for new 
engine platforms. 
As discussed in Section III.D.(1)(b)(i), 
the agencies project that at least one engine manufacturer (and possibly more) will have completed a redesign for tractor engines by 2027. Accordingly, we project that 50 percent of tractor engines in 2027 will be redesigned engines and be 1.6 percent more efficient than required by the engine standards, so the average engine would be 0.8 percent better. However, we could have projected the same overall improvement by projecting 25 percent of engine getting 3.2 percent better. Based on the CBI information available to us, we believe projecting a 0.8 percent improvement is reasonable, but may be somewhat conservative. 
Adding this 0.8 percent improvement 
to the 5.1 percent reduction required by 
the standards means we project the average 2027 tractor engine would be 5.9 percent better than Phase 1. Because engine improvements for tractors are applied separately for day cabs and sleeper cabs in the vehicle program, we estimated separate improvements for them here. Specifically, we project a 5.4 percent reduction for day cabs and a 6.4 percent reduction in fuel consumption in sleeper cabs beyond Phase 1. It is important to also note that manufacturers that do not achieve this level would be able to make up for the difference by applying one of the many other tractor vehicle technologies to a greater extent than we project, or to achieve greater reductions by optimizing technology efficiency 
further. We are not including the cost of developing these new engines in our cost analysis because we believe these engines are going to be developed due to market forces (i.e., the new platform, 
already contemplated) rather than due to this rulemaking. 
We are making a similar new engine 
platform projection for vocational vehicles. This is because many of tractor and vocational engines, such as HHD, would likely share the same engine hardware with the exception of WHR. In addition, the model based control discussed in Chapter 2.3 of the RIA could integrate engines better with transmissions on the vehicle side. We believe manufacturers will first focus their efforts on improving tractor engines but still believe that the 2027 vocational engine will be significantly better than required by the engine standards. 
(3) EPA Engine Standards for N
2O 
EPA will continue to apply the Phase 
1 N 2O engine standard of 0.10 g/bhp-hr 
and a 0.02 g/bhp-hr default 
deterioration factor to the Phase 2 program. EPA adopted the cap standard for N
2O as an engine-based standard 
because the agency believes that emissions of this GHG are 
technologically related solely to the engine, fuel, and emissions after- treatment systems, and the agency is not aware of any influence of vehicle-based technologies on these emissions. Note that NHTSA did not adopt standards for N
2O because these emissions do not impact fuel consumption in a significant way. 
In the proposal we considered 
reducing both the standard and deterioration factor to 0.05 and 0.01 g/ bhp-hr respectively because engines certified in model year 2014 were generally meeting the proposed standard. We also explained the process behind N
2O formation in urea SCR after- 
treatment systems and how that process could be optimized to elicit additional N
2O reductions. 80 FR 40203. While we 
have seen some reductions and a few increases in engine family certified N
2O 
levels across the 2014, 2015, and 2016 model years, the majority have remained unchanged. 
While we still believe that further 
optimization of SCR systems is possible to reduce N
2O emissions, as 
demonstrated for some engine families, we do not know to what extent further optimization can be achieved given the tradeoffs required to meet the Phase 2 CO
2standards. These tradeoffs 
potentially include advancing fuel injection timing to reduce CO
2 
emissions resulting in an increase in NO
Xemissions at the engine outlet 
before the after-treatment, increasing the needed NO
Xreduction efficiency of the 
SCR system. We will continue to assess N
2O emissions as SCR technology 
evolves and CO 2emission reductions 
phase in, and we will revisit the standard at a later date to further control N
2O emission. This will likely be 
included in the upcoming rule to consider more stringent NO
Xstandards. 
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0.14 
0.12 
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~ 
"' s 0.08 
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"' ·e w 
0 0.06 
N z 
0.04 
0.02 
0.16 
0.14 0.12 
~ t 0.1 
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0 0.06 
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0.04 
0.02 Phase 1 Standard: 0.10 g/hp·hr = 0.187 g/hp-hr 
Note: Phase 1 OF of 0.02 g/hp-hr included in emission results. 
Diesel Fuel unless noted. 
NG =Natural Gas Fuel 
NG NG NG 
NG 
I 
Figure 11.6 EPA 2014 Certification Database N20 Emission Results for 24 Engines. 
Phase 1 Standard: 0.10 g/hp-hr 
Note: Phase 1 OF of 0.02 g/hp-hr included in emission results. 
Diesel Fuel unless noted. 
NG = Natural Gas Fuel 
NG NG NG 
NGNG 
Figure 11.7 EPA 2015 Certification Database N20 Emission Results for 24 Engines. 73568 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
(4) EPA Engine Standards for Methane 
EPA will continue to apply the Phase 
1 methane engine standards to the Phase 
2 program. EPA adopted the cap standards for CH
4(along with N 2O 
standards) as engine-based standards because the agency believes that emissions of this GHG are technologically related solely to the engine, fuel, and emissions after- 
treatment systems, and the agency is not aware of any influence of vehicle-based technologies on these emissions. We are applying these cap standards against the FTP duty-cycle because the FTP cycle is the most stringent with respect to emissions of these pollutants and we do not believe that a reduction is stringency from the current Phase 1 standards is warranted. Note that NHTSA did not adopt standards for CH
4 
(or N 2O) because these emissions do not 
impact fuel consumption in a significant way. 
EPA continues to believe that 
manufacturers of most engine technologies will be able to comply with the Phase 1 CH
4standard with no 
technological improvements. We note that we are not aware of any new technologies that would have allowed us to adopt more stringent standards at 
this time. 
(5) Compliance Provisions and 
Flexibilities for Engine Standards 
The agencies are continuing most of 
the Phase 1 compliance provisions and flexibilities for the Phase 2 engine standards. 
(a) Averaging, Banking, and Trading 
The agencies’ general approach to 
averaging is discussed in Section I. We 
did not propose to offer any new or special credits to engine manufacturers to comply with any of the separate engine standards. Except for early credits, the agencies are retaining all Phase 1 credit flexibilities and 
limitations to continue for use in the Phase 2 engine program. 
As discussed below and as proposed, 
EPA is changing the useful life for LHD engines for GHG emissions from the current 10 years/110,000 miles to 15 years/150,000 miles to be consistent with the useful life of criteria pollutants recently updated in EPA’s Tier 3 rule. In order to ensure that banked credits maintain their value in the transition from Phase 1 to Phase 2, EPA and NHTSA are adopting the proposed adjustment factor of 1.36 (i.e., 150,000 mile ÷ 110,000 miles) for credits that are 
carried forward from Phase 1 to the MY 
2021 and later Phase 2 standards. Without this adjustment factor the change in useful life would have effectively resulted in a discount of banked credits that are carried forward from Phase 1 to Phase 2, which is not the intent of the change in the useful 
life. See Sections V and VI for additional discussion of similar adjustments of vehicle-based credits. 
Finally, the agencies are limiting the 
carryover of certain Phase 1 engine credits into the Phase 2 program. As described in Section II.D.(2) the agencies made adjustments to the FTP baselines, to address the unexpected step-change improvement in engine fuel consumption and CO
2emissions. The 
underlying reasons for this shift are mostly related to manufacturers optimizing their SCR thermal management strategy over the FTP in ways that we (mistakenly) thought they already had in MY 2010 (i.e., the Phase 
1 baseline). At the time of Phase 1 we had not realized that these improvements were not already in the Phase 1 baseline. This issue does not apply for SET emissions, and thus only significantly impacts engines certified 
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193See 40 CFR 1036.108. exclusively to the FTP standards (rather 
than both FTP and SET standards). To prevent manufacturers from diluting the Phase 2 engine program with credits generated relative to this incorrect baseline, we are not allowing engine credits generated against the Phase 1 FTP standards to be carried over into the Phase 2 program. 
(b) Changing Global Warming Potential 
(GWP) Values in the Credit Program for CH
4and N 2O 
The Phase 1 rule included a 
compliance flexibility that allowed heavy-duty manufacturers and conversion companies to comply with the respective methane or nitrous oxide standards by means of over-complying with CO
2standards (40 CFR 
1036.705(d)). The heavy-duty rules allow averaging only between vehicles or engines of the same designated type (referred to as an ‘‘averaging set’’ in the rules). Specifically, the Phase 1 heavy- duty rulemaking added a CO
2credits 
program which allowed heavy-duty engine manufacturers to average and bank emission credits to comply with the methane and nitrous oxide requirements after adjusting the CO
2 
emission credits based on the relative GWP equivalents. To establish the GWP equivalents used by the CO
2credits 
program, the Phase 1 rule incorporated the IPCC Fourth Assessment Report GWP values of 25 for CH
4and 298 for 
N2O, which are assessed over a 100 year 
lifetime. 
EPA will continue this provision for 
Phase 2. However, since the Phase 1 rule was finalized, a new IPCC report has been released (the Fifth Assessment Report), with new GWP estimates. This caused us to look again at the relative GWP equivalency of methane and nitrous oxide and to seek comment on whether the methane and nitrous oxide GWPs used to establish the equivalency 
value for the CO
2Credit program should 
be updated to those established by IPCC in its Fifth Assessment Report. 80 FR 40206. The Fifth Assessment Report provides four 100 year GWP values for methane ranging from 28 to 36 and two 100 year GWP values for nitrous oxide, either 265 or 298. 
EPA is updating the GWP value to 
convert CO
2credits for use against the 
methane standard. We are using a GWP of 34 for the value of methane reductions relative to CO
2reductions. 
(The GWP remains 298 for N 2O). The 
use of this new methane GWP will not begin until MY 2021, when the Phase 2 engine standards begin. This provides sufficient lead time for both the agencies and manufacturers to update systems, and also ensures that manufacturers would be able make any necessary 
design changes. The choice of when to commence use of this GWP value for our engines standards does not prejudice the choice of other GWP values for use in regulations and other purposes in the near term. Further discussion is found in Section XI.D.2.a. 
(c) In-Use Compliance and Useful Life 
Consistent with section 202(a)(1) and 
202(d) of the CAA, for Phase 1, EPA 
established in-use standards for heavy- duty engines. Based on our assessment of testing variability and other relevant factors, we established in-use standards by adding a 3 percent adjustment factor to the full useful life CO
2emissions and 
fuel consumption results measured in the EPA certification process to address measurement variability inherent in comparing results among different laboratories and different engines. See 40 CFR part 1036. The agencies are not changing this for Phase 2 SET and FTP engine standard compliance. 
In Phase 1, EPA set the useful life for 
engines and vehicles with respect to GHG emissions equal to the respective useful life periods for criteria pollutants. In April 2014, as part of the Tier 3 light- duty vehicle final rule, EPA extended the regulatory useful life period for criteria pollutants to 150,000 miles or 15 years, whichever comes first, for Class 2b and 3 pickup trucks and vans and some light-duty trucks (79 FR 23414, April 28, 2014). As proposed, EPA is applying the same useful life of 150,000 miles or 15 years for the Phase 2 GHG standards for engines primarily intended for use in vocational vehicles with a GVWR at or below 19,500 lbs. NHTSA will use the same useful life values as EPA for all heavy-duty vehicles. 
As proposed, we will continue the 
regulatory allowance in 40 CFR 1036.150(g) that allows engine manufacturers to use assigned 
deterioration factors (DFs) for most engines without performing their own durability emission tests or engineering analysis. However, the engines will still be required to meet the standards in actual use without regard to whether the manufacturer used the assigned DFs. This allowance is being continued as an interim provision and may be discontinued for later phases of standards as more information becomes known. Manufacturers are allowed to use an assigned additive DF of 0.0 g/ bhp-hr for CO
2emissions from any 
conventional engine (i.e., an engine not 
including advanced or off-cycle technologies). Upon request, we could allow the assigned DF for CO
2emissions 
from engines including advanced or off- cycle technologies, but only if we 
determine that it would be consistent with good engineering judgment. We believe that we have enough information about in-use CO
2emissions 
from conventional engines to conclude that they will not increase as the engines age. However, we lack such information about the more advanced technologies. For technologies such as WHR that are considered advanced in the context of Phase 1, but would be treated as a more ordinary technology by the end of Phase 2, we plan to work with manufacturers to determine if using the assigned zero DF would be appropriate. 
(d) Alternate CO
2Standards 
In the Phase 1 rulemaking, the 
agencies allowed certification to 
alternate CO 2engine standards in model 
years 2014 through 2016. This flexibility 
was intended to address the special case of needed lead time to implement new standards for a previously unregulated pollutant. Since that special case does not apply for Phase 2, we are not adopting a similar flexibility in this rulemaking. 
(e) Approach to Standards and 
Compliance Provisions for Natural Gas Engines 
EPA is also making certain clarifying 
changes to its rules regarding classification of natural gas engines. This relates to standards for all emissions, both greenhouse gases and criteria pollutants. These clarifying changes are intended to reflect the status quo, and therefore should not have any associated costs. 
EPA emission standards have always 
applied differently for gasoline-fueled and diesel-fueled engines. The regulations in 40 CFR part 86 implement these distinctions by dividing engines into Otto-cycle and Diesel-cycle technologies. This approach led EPA to categorize natural gas engines according to their design history. A diesel engine converted to run on natural gas was classified as a diesel-cycle engine; a gasoline engine converted to run on natural gas was classified as an Otto-cycle engine. 
The Phase 1 rule described our plan 
to transition to a different approach, consistent with EPA’s non-road programs, in which we divide engines into compression-ignition and spark- ignition technologies based only on the thermodynamic operating characteristics of the engines.
193 
However, the Phase 1 rule included a provision allowing us to continue with 
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194Section 202(a)(2), applicable to emissions of 
greenhouse gases, does not mandate a specific 
period of lead time, but EPA sees no reason for a different compliance date here for GHGs and 
criteria pollutants. This is also true with respect to the closed crankcase emissions discussed in the following subsection. Also, as explained in section I.E.i.e, EPA interprets the phrase ‘‘classes or categories of heavy duty vehicles or engines’’ in CAA section 202(a)(3)(C) to refer to categories of vehicles established according to features such as their engine cycle (spark-ignition or compression- ignition).l. the historic approach on an interim 
basis. 
Under the existing EPA regulatory 
definitions of ‘‘compression-ignition’’ and ‘‘spark-ignition,’’ a natural gas engine would generally be considered 
compression-ignition if it operates with lean air-fuel mixtures and uses a pilot injection of diesel fuel to initiate combustion, and would generally be considered spark-ignition if it operates with stoichiometric air-fuel mixtures and uses a spark plug to initiate combustion. 
EPA’s basic premise here is that 
natural gas engines performing similar in-use functions as diesel engines should be subject to similar regulatory requirements. The compression-ignition emission standards and testing requirements reflect the operating characteristics for the full range of heavy-duty vehicles, including substantial operation in long-haul service characteristic of tractors. The spark-ignition emission standards and 
testing requirements do not include some of those provisions related to use in long-haul service or other applications where diesel engines predominate, such as steady-state testing, Not-to-Exceed standards, and extended useful life. We believe it would be inappropriate to apply the spark-ignition standards and requirements to natural gas engines that are being used in applications mostly served by diesel engines today. We therefore proposed to replace the interim provision described above with a differentiated approach to certification of natural gas engines across all of the EPA standards—for both GHGs and criteria pollutants. 80 FR 40207. Under the proposed amendment, we would require manufacturers to divide all their 
natural gas engines into primary intended service classes, as we already require for compression-ignition engines, whether or not the engine has features that otherwise could (in theory) 
result in classification as SI under the current rules. We proposed that any natural gas engine qualifying as a medium heavy-duty engine (19,500 to 
33,000 lbs. GVWR) or a heavy heavy- duty engine (over 33,000 lbs. GVWR) would be subject to all the emission standards and other requirements that apply to compression-ignition engines. However, based on comments, we are finalizing this change only for heavy heavy-duty engines. Commenters identified medium heavy-duty applications in which SI alternative fuel engines compete significantly with gasoline engines, which is not consistent with the premise of the proposal. Thus, we are not finalizing the proposed change for medium heavy- duty engines. 
Table II–15 describes the provisions 
that apply differently for compression- ignition and spark-ignition engines: 
TABLE II–15—R EGULATORY PROVISIONS THATAREDIFFERENT FOR COMPRESSION -IGNITION AND SPARK -IGNITION  
ENGINES  
Provision Compression-ignition Spark-ignition 
Transient duty cycle ....................... 40 CFR part 86, Appendix I, paragraph (f)(2) cycle; divide by 
1.12 to de-normalize.40 CFR part 86, Appendix I, paragraph 
(f)(1) cycle. 
Ramped-modal test (SET) ............. yes ........................................................................................ .... no. 
NTE standards ............................... yes ................................................................................ ............ no. 
Smoke standard ............................. yes ................................................................................. ........... no. 
Manufacturer-run in-use testing ..... yes ........................................................................................ .... no. 
ABT—pollutants ............................. NO X, PM .................................................................................. NO X, NMHC. 
ABT—transient conversion factor .. 6.5 ........................................................................................... . 6.3. 
ABT—averaging set ....................... Separate averaging sets for light, medium, and heavy HDDE One averaging set for all SI engines. 
Useful life ....................................... 110,000 miles for light HDDE,a185,000 miles for medium 
HDDE, 435,000 miles for heavy HDDE.110,000 miles.a 
Warranty ........................................ 50,000 miles for light HDDE, 100,000 miles for medium 
HDDE, 100,000 miles for heavy HDDE.50,000 miles. 
Detailed AECD description ............ yes ....................................................................................... ..... no. 
Test engine selection ..................... highest injected fuel volume .................................................... most likely to exceed emission standards. 
Note: 
aAs proposed, useful life for light heavy-duty diesel and spark ignition engines is being increased to 150,000 miles for GHG emissions, but re-
mains at 110,000 for criteria pollutant emissions. 
The onboard diagnostic requirements 
already differentiate requirements by 
fuel type, so there is no need for those provisions to change based on the considerations of this section. 
We are not aware of any currently 
certified engines that will change from compression-ignition to spark-ignition under this approach. Nonetheless, because these proposed changes could result in a change in standards for engines currently under development, we believe it is appropriate to provide additional lead time. We will therefore continue to apply the existing interim provision through model year 2020.
194 Starting in model year 2021, all the 
provisions will apply as described above for heavy heavy-duty engines. Manufacturers will not be permitted to certify any engine families using carryover emission data if a particular engine model switched from compression-ignition to spark-ignition, or vice versa. However, as noted above, in practice these vehicles are already being certified as CI engines, so we view 
these changes as clarifications ratifying the current status quo. 
These provisions will apply equally to 
engines fueled by any fuel other than gasoline or ethanol, should such engines be produced in the future. Given the current and historic market for vehicles above 33,000 lbs. GVWR, the agencies believe any alternative-fueled vehicles in this weight range will be competing primarily with diesel vehicles and should be subject to the same requirements as them. See Sections XI and XII for additional discussion of natural gas fueled engines. 
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195See 40 CFR 86.008–10(c). 196The statistical formula for standard error, 
which is a well-accepted measure of uncertainty, is 
the standard deviation times the reciprocal of the square root of the sample size. For a sample size of three, the reciprocal of the square root of three is approximately 0.58, which results in a 42% reduction in uncertainty, versus a sample size of one. 197Note that this +1.0 percent compliance margin 
built into the standards, or any other future determination of test procedure uncertainty, does not impact the agencies’ technology feasibility or cost-benefit analyses for this rulemaking. 
198The on-highway Class 7 and 8 combination 
tractor-trailers constitute the vast majority of this regulatory category. A small fraction of combination tractors are used in off-road applications and are regulated differently, as described in Section III.C. (f) Crankcase Emissions From Natural 
Gas Engines 
EPA proposed to require that all 
natural gas-fueled engines have closed crankcases, rather than continuing the provision that allows venting to the atmosphere all crankcase emissions from all compression-ignition engines. 80 FR 40208. However, EPA is not finalizing the proposed requirement at this time. 
Open crankcases have been allowed 
as long as these vented crankcase emissions are measured and accounted for as part of an engine’s tailpipe emissions. This allowance has historically been in place to address the technical limitations related to recirculating diesel-fueled engines’ crankcase emissions, which have high PM emissions, back into the engine’s air intake. High PM emissions vented into the intake of an engine can foul turbocharger compressors and after cooler heat exchangers. In contrast, historically EPA has mandated closed crankcase technology on all gasoline fueled engines and all natural gas spark- ignition engines.
195The inherently low 
PM emissions from these engines posed no technical barrier to a closed crankcase mandate. However, after considering the comments on this issue, we now believe that there are practical reasons why we should not close natural gas crankcases without also requiring closed crankcases for other compression-ignition engines. Because current natural gas engines are generally produced from diesel engine designs that are not designed to operate with closed crankcases, we have concerns that sealing the crankcase on the natural gas versions will require substantial development effort, and the seals may not function properly. Thus, we expect to update our regulations for crankcase emissions from all compression ignition engines at the same time in a future rulemaking. 
(g) Compliance Margins 
Some commenters suggested that the 
agencies should apply a compliance 
margin to confirmatory and SEA test results to account for variability of engine maps and emission tests. However, EPA’s past practice has been to base the standards on technology projections that assume manufacturers will apply compliance margins to their test results for certification. In other words, they design their products to have emissions below the standards by some small margin so that test-to-test or lab-to-lab variability would not cause them to exceed any applicable 
standards. Consequently, EPA has typically not set standards precisely at the lowest levels achievable, but rather at slightly higher levels—expecting manufacturers to target the lower levels to provide compliance margins for themselves. The agencies have applied this approach to the Phase 2 standards. Thus, the feasibility and cost analyses reflect the expectation that manufacturers will target lower values to provide compliance margins. 
The agencies have also improved the 
engine test procedures and compliance provisions to reduce the agencies’ and the manufacturers’ uncertainty of engine test results. For example, in the agencies’ confirmatory test procedures we are requiring that the agencies use 
the average of at least three tests (i.e., the arithmetic mean of a sample size of at least three test results) for determining the values of confirmatory test results for any GEM engine fuel maps. We are only doing this for GEM engine fuel maps because these are relatively new tests, compared to Phase 1 testing or EPA’s other emissions standards. Therefore, this provision does not apply to any other emissions testing. For all other emissions testing besides GEM engine fuel maps the agencies’ maintain our usual convention of utilizing a sample size of one for confirmatory testing. For GEM engine fuel mapping this at least triples the test burden for the agencies to conduct confirmatory testing, but it also decreases confirmatory test result uncertainty by at least 42 percent.
196 
Based on improvements like this one, and others described in Section 1.4 of the RTC, we believe that SET, FTP and GEM’s steady-state, cycle-average and powertrain test results will have an overall uncertainty of +/¥1.0 percent. To further protect against falsely high emissions results or false failures due to this remaining level of test procedure uncertainty, we have included a +1 percent compliance margin into our stringency analyses of the engine standards and the GEM fuel map inputs used to determine the tractor and vocational vehicle standards. In other words we set Phase 2 engine and vehicle standards 1 percent less stringent than if we had not considered this test procedure uncertainty. In addition to the test procedure 
improvements and the +1 percent margin we incorporated into our standards, the agencies are also committed to a process of continuous improvement of test procedures to further reduce test result uncertainty. To contribute to this effort, in mid-2016 EPA committed $250,000 to fund research to further evaluate individual sources of engine mapping test procedure uncertainty. This work will occur at SwRI. Should the results of this work or other similar future work indicate test procedure improvements that would further reduce test result uncertainty, the agencies will incorporate these improvements through appropriate guidance or through technical amendments to the regulations via a notice and comment rulemaking. If we determine in the future through the SwRI work or other work that such improvements eliminate the need to require the agencies to conduct triplicate confirmatory testing of GEM engine fuel maps, we will promulgate technical amendments to the regulations to remove this requirement. If we determine in the future through the SwRI work or other work that the +1.0 percent we factored into our stringency analysis was inappropriately low or high, we will promulgate technical amendments to the regulations to address any inappropriate impact this +1.0 percent had on the stringency of the engine and vehicle standards.
197In addition, 
whenever the agencies determine whether or not confirmatory test results are statistically significantly different from manufacturers’ declared values, the agencies will use good engineering judgment to appropriately factor into such determinations the results of this SwRI work and/or any other future work that quantifies our test procedures’ uncertainty. 
III. Class 7 and 8 Combination Tractors 
Class 7 and 8 combination tractors- 
trailers contribute the largest portion of 
the total GHG emissions and fuel consumption of the heavy-duty sector, approximately 60 percent, due to their large payloads, their high annual miles traveled, and their major role in national freight transport.
198These vehicles 
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199‘‘Tractor’’ is defined in 49 CFR 571.3 to mean 
‘‘a truck designed primarily for drawing other motor 
vehicles and not so constructed as to carry a load other than a part of the weight of the vehicle and 
the load so drawn.’’ 
200Adapted from Figure 4.1. Class 8 Truck Energy 
Audit, Technology Roadmap for the 21st Century Truck Program: A Government-Industry Research 
Partnership, 21CT–001, December 2000. consist of a cab and engine (tractor or 
combination tractor) and a trailer.199In 
general, reducing GHG emissions and fuel consumption for these vehicles will involve improvements to all aspects of the vehicle. 
As we found during the development 
in Phase 1 and as continues to be true in the industry today, the heavy-duty combination tractor-trailer industry consists of separate tractor manufacturers and trailer manufacturers. We are not aware of any manufacturer that typically assembles both the finished truck and the trailer and introduces the combination into commerce for sale to a buyer. There are also large differences in the kinds of manufacturers involved with producing tractors and trailers. For HD highway tractors and their engines, a relatively 
limited number of manufacturers produce the vast majority of these products. The trailer manufacturing 
industry is quite different, and includes a large number of companies, many of which are relatively small in size and production volume. Setting standards for the products involved—tractors and trailers—requires recognition of the large differences between these manufacturing industries, which can then warrant consideration of different regulatory approaches. Thus, although tractor-trailers operate essentially as a unit from both a commercial standpoint and for purposes of fuel efficiency and CO
2emissions, the agencies have 
developed separate standards for each. 
Based on these industry 
characteristics, EPA and NHTSA believe that the most appropriate regulatory approach for combination tractors and trailers is to establish standards for 
tractors separately from trailers. As discussed below in Section IV, the agencies are also adopting standards for 
certain types of trailers. 
A. Summary of the Phase 1 Tractor 
Program 
The design of each tractor’s cab and 
drivetrain determines the amount of 
power that the engine must produce in moving the truck and its payload down the road. As illustrated in Figure III–1, the loads that require additional power from the engine include air resistance (aerodynamics), tire rolling resistance, and parasitic losses (including accessory loads and friction in the drivetrain). The importance of the engine design is that it determines the basic GHG emissions and fuel consumption performance for the variety of demands placed on the vehicle, regardless of the characteristics of the cab in which it is installed. 
Accordingly, for Class 7 and 8 
combination tractors, the agencies adopted two sets of Phase 1 tractor standards for fuel consumption and CO
2 
emissions. The CO 2emission and fuel 
consumption reductions related to engine technologies are recognized in the engine standards. For vehicle- related emissions and fuel consumption, tractor manufacturers are required to meet vehicle-based standards. Compliance with the vehicle standard must be determined using the GEM vehicle simulation tool. The Phase 1 tractor standards were 
based on several key attributes related to GHG emissions and fuel consumption that reasonably represent the many differences in utility and performance among these vehicles. Attribute-based standards in general recognize the variety of functions performed by vehicles and engines, which in turn can affect the kind of technology that is available to control emissions and reduce fuel consumption, or its effectiveness. Attributes that characterize differences in the design of vehicles, as well as differences in how the vehicles will be employed in-use, can be key factors in evaluating technological improvements for reducing CO
2emissions and fuel 
consumption. Developing an appropriate attribute-based standard can also avoid interfering with the ability of the market to offer a variety of products to meet the customer’s demand. The Phase 1 tractor standards differ depending on GVWR (i.e., whether the 
truck is Class 7 or Class 8), the height of the roof of the cab, and whether it is a ‘‘day cab’’ or a ‘‘sleeper cab.’’ These later two attributes are important 
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201Manufacturers may have voluntarily opted-in 
to the NHTSA fuel consumption standards in model 
years 2014 or 2015. Once a manufacturer opts into the NHTSA program it must stay in the program for all optional MYs. 202National Academy of Science. ‘‘Technologies 
and Approaches to Reducing the Fuel Consumption 
of Medium- and Heavy-Duty Vehicles.’’ 2010. Recommendation 8–4 stated ‘‘Simulation modeling should be used with component test data and additional tested inputs from powertrain tests, which could lower the cost and administrative burden yet achieve the needed accuracy of results.’’ 
203See 76 FR 57138 for Phase 1 discussion. See 
40 CFR 1037.801 for Phase 2 heavy-haul tractor regulatory definition. because the height of the roof, designed 
to correspond to the height of the trailer, significantly affects air resistance, and a sleeper cab generally corresponds to the opportunity for extended duration idle emission and fuel consumption improvements. Based on these attributes, the agencies created nine subcategories within the Class 7 and 8 combination tractor category. The Phase 1 rules set standards for each of them. Phase 1 standards began with the 2014 model year and were followed with more stringent standards following in model year 2017.
201The standards 
represent an overall fuel consumption and CO
2emissions reduction up to 23 
percent from the tractors and the engines installed in them when compared to a baseline 2010 model year tractor and engine without idle shutdown technology. Although the EPA and NHTSA standards are expressed differently (grams of CO
2per 
ton-mile and gallons per 1,000 ton-mile respectively), the standards are equivalent. 
In Phase 1, the agencies allowed 
manufacturers to certify certain types of combination tractors as vocational vehicles. These are tractors that do not typically operate at highway speeds, or would otherwise not benefit from efficiency improvements designed for line-haul tractors (although standards still apply to the engines installed in these vehicles). The agencies created a subcategory of ‘‘vocational tractors,’’ or referred to as ‘‘special purpose tractors’’ in 40 CFR part 1037, because real world operation of these tractors is better represented by our Phase 1 vocational vehicle duty cycle than the tractor duty cycles. Vocational tractors are subject to the standards for vocational vehicles rather than the combination tractor standards. In addition, specific vocational tractors and heavy-duty vocational vehicles primarily designed to perform work off-road or having tires installed with a maximum speed rating at or below 55 mph are exempted from the Phase 1 standards. 
In Phase 1, the agencies also 
established separate performance standards for the engines manufactured for use in these tractors. EPA’s engine- based CO
2standards and NHTSA’s 
engine-based fuel consumption standards are being implemented using EPA’s existing test procedures and regulatory structure for criteria pollutant emissions from medium- and heavy- duty engines. These engine standards vary depending on engine size linked to intended vehicle service class (which are the same service classes used for many years for EPA’s criteria pollutant standards). 
Manufacturers demonstrate 
compliance with the Phase 1 tractor standards using the GEM simulation tool. As explained in Section II above, GEM is a customized vehicle simulation model which is the preferred approach to demonstrating compliance testing for combination tractors rather than chassis dynamometer testing used in light-duty vehicle compliance. As discussed in the development of HD Phase 1 and recommended by the NAS 2010 study, a simulation tool is the preferred approach for HD tractor compliance because of the extremely large number of vehicle configurations.
202The GEM 
compliance tool was developed by EPA 
and is an accurate and cost-effective alternative to measuring emissions and fuel consumption while operating the vehicle on a chassis dynamometer. Instead of using a chassis dynamometer as an indirect way to evaluate real world operation and performance, various characteristics of the vehicle are measured and these measurements are used as inputs to the model. For HD Phase 1, these characteristics relate to key technologies appropriate for this category of truck including aerodynamic features, weight reductions, tire rolling resistance, the presence of idle-reducing technology, and vehicle speed limiters. The model also assumes the use of a representative typical engine in compliance with the separate, applicable Phase 1 engine standard. Using these inputs, the model is used to quantify the overall performance of the vehicle in terms of CO
2emissions and 
fuel consumption. CO 2emission 
reduction and fuel consumption technologies not measured by the model must be evaluated separately, and the HD Phase 1 rules establish mechanisms allowing credit for such ‘‘off-cycle’’ technologies. 
In addition to the final Phase 1 
tractor-based standards for CO
2, EPA 
adopted a separate standard to reduce leakage of HFC refrigerant from cabin air conditioning (A/C) systems from combination tractors that apply to the tractor manufacturer. This HFC leakage standard is independent of the CO
2 
tractor standard. Manufacturers can choose technologies from a menu of 
leak-reducing technologies sufficient to comply with the standard, as opposed to using a test to measure performance. 
The Phase 1 program also provided 
several flexibilities to advance the goals of the overall program while providing alternative pathways to achieve compliance. The primary flexibility is the averaging, banking, and trading program which allows emissions and fuel consumption credits to be averaged within an averaging set, banked for up to five years, or traded among manufacturers. Manufacturers with credit deficits were allowed to carry- forward credit deficits for up to three model years, similar to the LD GHG and CAFE carry-back credits. Phase 1 also included several interim provisions, such as incentives for advanced technologies and provisions to obtain credits for innovative technologies (called off-cycle in the Phase 2 program) not accounted for by the HD Phase 1 version of GEM or for certifying early. 
B. Overview of the Phase 2 Tractor 
Program and Key Changes From the Proposal 
The HD Phase 2 program is similar in 
many respects to the Phase 1 approach. The agencies are keeping the Phase 1 attribute-based regulatory structure in terms of dividing the tractor category 
into the same nine subcategories based on the tractor’s GVWR, cab configuration, and roof height. This structure is working well in the implementation of Phase 1. EMA and Daimler supported this approach again in their comments to the Phase 2 NPRM. The one area where the agencies are changing the regulatory structure is related to heavy-haul tractors. As noted above, the Phase 1 regulations include a set of provisions that allow vocational tractors to be treated as vocational vehicles. However, because the agencies are including the powertrain as part of the technology basis for the tractor and vocational vehicle standards in Phase 2, we are classifying a certain set of these vocational tractors as heavy-haul tractors and subjecting them to a separate tractor standard that reflects their unique powertrain requirements and limitations in application of technologies to reduce fuel consumption and CO
2emissions.203The 
agencies are adopting some revisions to the proposed Phase 2 criteria used to define heavy-haul tractors in response 
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204Fuel consumption is calculated from CO 2 
using the conversion factor of 10,180 grams of CO 2 
per gallon for diesel fuel. 205This is necessarily an EPA-only provision 
since it relates to control of criteria pollutant 
emissions from a type of non-road engine, not to fuel efficiency. 
206U.S. EPA. Development of Emission Rates for 
Heavy-Duty Vehicles in the Motor Vehicle Emissions Simulator MOVES 2010. EPA–420–B– 12–049. August 2012. to comments, as discussed below in 
Section III.C.4. 
The agencies will retain much of the 
certification and compliance structure developed in Phase 1. The Phase 2 tractor CO
2emissions and fuel 
consumption standards, as in Phase 1, will be aligned.
204The agencies will 
also continue to have separate engine and vehicle standards to drive technology improvements in both areas. The reasoning behind maintaining separate standards is discussed above in Section II.B.2. As in Phase 1, the manufacturers will certify tractors using the GEM simulation tool and evaluate the performance of subsystems through testing (the results of this testing to be used as inputs to the GEM simulation tool). Other aspects of the HD Phase 2 certification and compliance program also mirror the Phase 1 program, such as maintaining a single reporting structure to satisfy both agencies, requiring limited data at the beginning of the model year for certification, and determining compliance based on end of year reports. In the Phase 1 program, manufacturers participating in the ABT program provided 90 day and 270 day reports after the end of the model year. For the Phase 2 program, the agencies proposed that manufacturers would only be required to submit one end of the year report, which would have simplified reporting. Manufacturers provided comments opposing this approach. After further consideration, the agencies are adopting an approach in Phase 2 that mirrors the Phase 1 approach with a 90 day preliminary report and a 270 day final report, with the manufacturer having the option to request a waiver of the 90 day report based on positive credit balances. 
Even though many aspects of the HD 
Phase 2 program are similar to Phase 1, there are some key differences. While Phase 1 focused on reducing CO
2 
emissions and fuel consumption in tractors through the application of existing (‘‘off-the-shelf’’) technologies, the HD Phase 2 standards seek additional reductions through increased use of existing technologies and the development and deployment of more advanced technologies. The agencies received numerous comments on the proposed Phase 2 technology assessments in terms of the baseline, the technology effectiveness, the market adoption rate projections, and the technology costs. The agencies have made changes reflecting our assessment of these comments, as described in 
Section III.D. 
To evaluate the effectiveness of a 
more comprehensive set of technologies in Phase 2, the agencies are including several additional inputs to the Phase 2 GEM. The set of inputs includes the Phase 1 inputs plus parameters to assess the performance of the engine, transmission, and driveline. Specific inputs for, among others, predictive cruise control, automatic tire inflation systems, and 6x2 axles will now be required. The final Phase 2 program includes some changes to the proposed Phase 2 technology inputs to GEM. These changes from proposal include the use of cycle-averaged fuel maps for use when evaluating a vehicle over the transient cycle, optional transmission efficiency inputs, optional axle efficiency inputs, an increase in the types of idle reduction technologies recognized in GEM, and the ability to recognize the effectiveness of tire pressure monitoring systems, neutral coast, and neutral idle. As in Phase 1, in Phase 2 manufacturers will conduct component testing to obtain the values for these technologies (should they choose to use them), then the testing values will be input into the GEM simulation tool. See Section III.D.1 below. To effectively assess performance of the technologies, the agencies are adopting a revised version of the road grade profiles proposed for Phase 2. Finally, the agencies are adopting Phase 2 regulations with clarified selective enforcement and confirmatory testing requirements for the GEM inputs that differ from the Phase 2 NPRM based on the comments received. 
The key aerodynamic assessment 
areas that the agencies proposed to change in Phase 2 relative to Phase 1 were the use of a more aerodynamic reference trailer, the inclusion of the impact of wind on the tractor, and changes to the aerodynamic test procedures. We are adopting these changes in Phase 2 with some further revisions from those proposed for Phase 2 based on comments. To reflect the evolving trailer market, the agencies are adopting as proposed the addition of trailer skirts (an aerodynamic improving device) to the reference trailer (i.e. the 
trailer used during testing to determine the relative aerodynamic performance of the tractor). The agencies are also adopting the proposed aerodynamic certification test procedure that captures the impact of wind average drag on tractor aerodynamic performance. However, the agencies are specifying in 
the final rule the use of a single surrogate yaw angle instead of a full yaw sweep to reduce the aerodynamic 
testing burden based on further assessment of the EPA aerodynamic data and comments received on the NPRM. Finally, the agencies are adopting aerodynamic test procedure and data analysis changes from the Phase 2 proposal to further reduce the variability of aerodynamic test results. Detailed discussion of the aerodynamic 
test procedures is included in Section III.E.2. 
Another key change to the final rule 
is the adoption of more stringent particulate matter (PM) standards for auxiliary power units (APU) installed in new tractors.
205In the Phase 2 NPRM, 
EPA sought comment on the need for and feasibility of new PM standards for these engines because APUs can be used in lieu of operating the main engine during extended idle operations to provide climate control and power to the driver. See 80 FR 40213. APUs can reduce fuel consumption, NO
X, HC, 
CH 4, and CO 2emissions when 
compared to main engine idling.206 
However, a potential unintended consequence of reducing CO
2emissions 
from combination tractors through the use of APUs during extended idle operation is an increase in PM emissions. EPA is adopting requirements for APUs installed in new tractors to meet lower PM standards starting in 2018, with a more stringent PM standard starting in 2024. Please see Section III.C.3 for more details. 
The agencies are also ending some of 
the interim provisions developed in Phase 1 to reflect the maturity of the program and the reduced need and justification for some of the Phase 1 flexibilities. Further discussions on all of these matters are covered in the following sections. 
C. Phase 2 Tractor Standards 
EPA is adopting CO
2standards and 
NHTSA is adopting fuel consumption 
standards for new Class 7 and 8 combination tractors in Phase 2 that are more stringent than Phase 1. In addition, EPA is continuing the HFC standards for the air conditioning systems that were adopted in Phase 1. EPA is also adopting new standards to further control emissions of particulate matter (PM) from auxiliary power units (APU) installed in new tractors that will prevent an unintended consequence of 
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207Since the HD Phase 1 tractor standards fully 
phase-in by the MY 2017, this is the logical baseline 
year. increasing PM emissions during long 
duration idling. 
This section describes these standards 
in detail. 
(1) Final Fuel Consumption and CO 2 
Standards 
The Phase 2 fuel consumption and 
CO 2standards for the tractor cab are 
shown below in Table III–1. These 
standards will achieve reductions of up to 25 percent compared to the 2017 
model year baseline level when fully phased in for the 2027 MY.
207The 
standards for Class 7 are described as 
‘‘Day Cabs’’ because we are not aware of any Class 7 sleeper cabs in the market today; however, the agencies require any Class 7 tractor, regardless of cab configuration, meet the standards described as ‘‘Class 7 Day Cab.’’ The agencies’ analyses, as discussed 
briefly below and in more detail later in 
this Preamble and in the RIA Chapter 2.4 and 2.8, indicate that these standards are the maximum feasible (within the meaning of 49 U.S.C. 32902(k)) and are appropriate under each agency’s respective statutory authorities. 
TABLE III–1—P HASE 2 HEAVY -DUTYCOMBINATION TRACTOR EPA E MISSIONS STANDARDS (g CO 2/TON-MILE) AND 
NHTSA F UELCONSUMPTION STANDARDS (GAL/1,000 TON-MILE) 
Day cab Sleeper cab Heavy-haul 
Class 7 Class 8 Class 8 Class 8 
2021 Model Year CO 2Grams per Ton-Mile 
Low Roof .......................................................................................................... 105.5 80.5 72.3 52.4 
Mid Roof .......................................................................................................... 113.2 85.4 78.0 ........................
High Roof ......................................................................................................... 113.5 85.6 75.7 ........................
2021 Model Year Gallons of Fuel per 1,000 Ton-Mile 
Low Roof .......................................................................................................... 10.36346 7.90 766 7.10216 5.14735 
Mid Roof .......................................................................................................... 11.11984 8.38 900 7.66208 ........................
High Roof ......................................................................................................... 11.14931 8.40 864 7.43615 ........................
2024 Model Year CO 2Grams per Ton-Mile 
Low Roof .......................................................................................................... 99.8 76.2 68.0 50.2 
Mid Roof .......................................................................................................... 107.1 80.9 73.5 ........................
High Roof ......................................................................................................... 106.6 80.4 70.7 ........................
2024 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile 
Low Roof .......................................................................................................... 9.80354 7.485 27 6.67976 4.93124 
Mid Roof .......................................................................................................... 10.52063 7.94 695 7.22004 ........................
High Roof ......................................................................................................... 10.47151 7.89 784 6.94499 ........................
2027 Model Year CO 2Grams per Ton-Milea 
Low Roof .......................................................................................................... 96.2 73.4 64.1 48.3 
Mid Roof .......................................................................................................... 103.4 78.0 69.6 ........................
High Roof ......................................................................................................... 100.0 75.7 64.3 ........................
2027 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile 
Low Roof .......................................................................................................... 9.44990 7.210 22 6.29666 4.74460 
Mid Roof .......................................................................................................... 10.15717 7.66 208 6.83694 ........................
High Roof ......................................................................................................... 9.82318 7.436 15 6.31631 ........................
Note: 
aThe 2027 MY high roof tractor standards include a 0.3 m2reduction in CdA as described in Section III.E.2.a.vii. 
As the agencies noted in the Preamble 
to the proposed standards, the HD Phase 2 CO
2and fuel consumption standards 
are not directly comparable to the Phase 1 standards. 80 FR 40212. This is because the agencies are adopting several test procedure changes to more accurately reflect real world operation. With respect to tractors, these changes will result in the following differences. First, the same vehicle evaluated using the HD Phase 2 version of GEM will obtain higher (i.e. less favorable) CO
2 
and fuel consumption values because the Phase 2 drive cycles include road grade. Road grade, which (of course) exists in the real-world, requires the engine to operate at higher horsepower levels to maintain speed while climbing a hill. Even though the engine saves fuel on a downhill section, the overall impact increases CO
2emissions and fuel consumption. The second of the key differences between the CO
2and fuel 
consumption values in Phase 1 and Phase 2 is due to changes in the evaluation of aerodynamics. Vehicles are exposed to wind when in use which increases the drag of the vehicle and in turn increases the power required to move the vehicle down the road. To more appropriately reflect the in-use aerodynamic performance of tractor- 
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208U.S. EPA. Development of Emission Rates for 
Heavy-Duty Vehicles in the Motor Vehicle 
Emissions Simulator MOVES 2010. EPA–420–B– 12–049. August 2012. trailers, the agencies are adopting a 
wind averaged coefficient of drag instead of the no-wind (zero yaw) value used in Phase 1. The final key difference between Phase 1 and the Phase 2 program includes a more realistic and improved simulation of the transmission in GEM, which could increase CO
2and fuel consumption 
relative to Phase 1. 
The agencies are adopting Phase 2 
CO 2emissions and fuel consumption 
standards for the combination tractors that reflect reductions that can be achieved through improvements in the tractor’s powertrain, aerodynamics, tires, and other vehicle systems. The agencies have analyzed the feasibility of achieving the CO
2and fuel consumption 
standards, and have identified means of achieving these standards that are technically feasible in the lead time afforded, economically practicable and cost-effective. EPA and NHTSA present the estimated costs and benefits of these standards in Section III.D.1. In developing these standards for Class 7 and 8 tractors, the agencies have evaluated the following: 
•The current levels of emissions and 
fuel consumption 
•the types of technologies that could be 
utilized by tractor and engine 
manufacturers to reduce emissions and fuel consumption from tractors and associated engines 
•the necessary lead time 
•the associated costs for the industry 
•fuel savings for the consumer 
•the magnitude of the CO
2and fuel 
savings that may be achieved 
The technologies on whose 
performance the final tractor standards 
are predicated include: improvements in the engine, transmission, driveline, aerodynamic design, tire rolling resistance, other accessories of the tractor, and extended idle reduction technologies. These technologies, and other accessories of the tractor, are described in RIA Chapter 2.4 and 2.8. The agencies’ evaluation shows that some of these technologies are available today, but have very low adoption rates on current vehicles, while others will require some lead time for development. EPA and NHTSA also present the estimated costs and benefits of the Class 7 and 8 combination tractor standards in RIA Chapter 2.8 and 2.12, explaining as well the basis for the agencies’ stringency level. 
As explained below in Section III.D, 
EPA and NHTSA have determined that there will be sufficient lead time to introduce various tractor and engine technologies into the fleet starting in the 2021 model year and fully phasing in by the 2027 model year. This is consistent 
with NHTSA’s statutory requirement to provide four full model years of regulatory lead time for standards. As was adopted in Phase 1, the agencies are adopting provisions for Phase 2 that allow manufacturers to generate and use credits from Class 7 and 8 combination tractors to show compliance with the standards. This is discussed further in Section III.F. 
Based on our analysis, the 2027 model 
year standards for combination tractors and engines represent up to a 25 percent reduction in CO
2emissions and fuel 
consumption over a 2017 model year baseline tractor, as detailed in Section III.D.1. In considering the feasibility of vehicles to comply with these standards over their useful lives, EPA also considered the potential for CO
2 
emissions to increase during the regulatory useful life of the product. As we discuss in Phase 1 and separately in the context of deterioration factor (DF) testing, we have concluded that CO
2 
emissions are likely to stay the same or actually decrease in-use compared to new certified configurations for the projected technologies. In general, engine and vehicle friction decreases as products wear, leading to reduced parasitic losses and consequent lower CO
2emissions. Similarly, tire rolling 
resistance falls as tires wear due to the 
reduction in tread depth. In the case of aerodynamic components, we project no change in performance through the regulatory life of the vehicle since there is essentially no change in their physical form as vehicles age. Similarly, weight reduction elements such as aluminum wheels are not projected to increase in mass through time, and hence, we can conclude will not deteriorate with regard to CO
2emissions 
performance in-use. Given all of these considerations, the agencies are confident in projecting that the tractor standards today will be technically feasible throughout the regulatory useful life of the program. 
(2) Non-CO
2GHG Emission Standards 
for Tractors 
EPA is also continuing the Phase 1 
standards to control non-CO 2GHG 
emissions from Class 7 and 8 
combination tractors. 
(a) N 2O and CH 4Emissions 
The final Phase 2 heavy-duty engine 
standards for both N 2O and CH 4as well 
as details of these standards are 
included in the discussion in Section II.D.3 and II.D.4. EPA requested comment, but did not receive any comments (or otherwise obtain any new information) indicating that there were appropriate controls for these non-CO
2 
GHG emissions for the tractors manufacturers. Nor does EPA believe there are any technologies available to set vehicle standards. Therefore, EPA is not adopting any additional controls for N
2O or CH 4emissions beyond those in 
the HD Phase 2 engine standards for the tractor category. 
(b) HFC Emissions 
Manufacturers can reduce 
hydrofluorocarbon (HFC) emissions 
from air conditioning (A/C) leakage emissions in two ways. First, they can utilize leak-tight A/C system components. Second, manufacturers can largely eliminate the global warming impact of leakage emissions by adopting systems that use an alternative, low- Global Warming Potential (GWP) refrigerant, to replace the commonly used R–134a refrigerant. EPA is maintaining the A/C leakage standards adopted in HD Phase 1 (see 40 CFR 1037.115). EPA believes the Phase 1 use of leak-tight components is at an appropriate level of stringency while maintaining the flexibility to produce the wide variety of A/C system configurations required in the tractor category. Please see Section I.F.(1)(b) for a discussion related to alternative refrigerants. 
(3) EPA’s PM Emission Standards for 
APUs Installed in New Tractors 
Auxiliary power units (APUs) can be 
used in lieu of operating the main engine during extended idle operations to provide climate control and additional hotel power for the driver. As noted above, APUs can reduce fuel consumption, NO
X, HC, CH 4, and CO 2 
emissions by a meaningful amount when compared to main engine idling.
208However, a potential 
unintended consequence of reducing CO
2emissions from combination 
tractors through the use of APUs during extended idle operation is an increase in diesel PM emissions. Engines currently being used to power APUs have been subject to the Nonroad Tier 4 p.m. standards (40 CFR 1039.101), which are less stringent in this power category than the heavy-duty on-highway standards (40 CFR 86.007–11) on a brake-specific basis. In the NPRM, EPA sought comment on the need for and appropriateness of further reducing PM emissions from APUs used as part of a compliance strategy for Phase 2, and suggested the basis for possible new PM 
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standards to avoid these unintended 
consequence. 80 FR 40213. 
After considering the numerous 
comments submitted on this issue and our consideration of feasibility of PM controls, EPA is adopting a new PM standard of 0.02 g/kW–hr that applies exclusively to APUs installed in MY 2024 and later new tractors. EPA is also amending the Phase 1 GHG standards to provide that as of January 1, 2018 and 
through MY 2020, a tractor can receive credit for use of an AESS with an APU installed at the factory only if the APU engine is certified under 40 CFR part 1039 with a deteriorated emission level for PM that is at or below 0.15 g/kW– hr. For MY 2021 through 2023, this same emission level applies as a standard for all new tractors with an APU installed. Starting in MY 2024, any APU installed in a new tractor must be 
certified to a PM emission standard of 0.02 g/kW–hr over the full useful life as specified in 40 CFR 1039.699. Engine manufacturers may alternatively meet the APU standard by certifying their engines under 40 CFR part 1039 with a Family Emission Limit for PM at or below 0.02 g/kW–hr. APUs installed on MY 2024 and later tractors must have a label stating that the APU meets the PM requirements of 40 CFR 1039.699. Tractor manufacturers will be subject to a prohibition against selling new MY 2024 and later tractors with APUs that are not certified to the specified standards, and manufacturers will similarly be subject to a prohibition 
against selling new MY 2021 through 2023 tractors with APUs that do not meet the specified emission levels. This applies for both new and used APUs 
installed in such new tractors. Manufacturers of new nonroad engines and new APUs may continue to produce and sell their products for uses other than installation in new tractors without violating these prohibitions. However, nonroad engine manufacturers and APU manufacturers would be liable if they are found to have caused a tractor manufacturer to violate this prohibition, such as by mislabeling an APU as compliant with this standard. Note also that the PM standard for APUs applies for new tractors, whether or not the engine and APU are new; conversely, the PM standard does not apply for APU retrofits on tractors that are no longer new, even if the engine and APU are new. 
TABLE III–2—PM S TANDARDS FOR TRACTORS USING APU S 
Tractor MY PM emission 
standard 
(g/kW–hr) Expected control technology 
MY 2021–2023a......................................................................... 0.15 In-cylinder PM control. 
MY 2024 and later ...................................................................... 0.02 Diesel Particulate Filter. 
Note: 
aAPUs installed on new tractors built January 1, 2018 and later, through model year 2020, must have engines that meet the same 0.15 g/kW– 
hr emission level if they rely on AESS for demonstrating compliance with emission standards. 
We discuss below the principal 
comments we received on whether to 
adopt a standard to control PM emissions from APUs used for tractor idle emission control, the basis for the amended standards, and how EPA envisions the standards operating in practice. 
Among the comments we received 
were those from the American Lung Association, National Association of Clean Air Agencies, Northeast States for Coordinated Air Use Management, Environmental Defense Fund, Natural Resources Defense Council, Environmental Law and Policy Center, Coalition for Clean Air/California Cleaner Freight Coalition, Moving Forward Network, Ozone Transport Commission, and the Center for Biological Diversity that urged EPA to amend the standards for PM emissions from these engines in order to reduce PM emission increases resulting from increased APU use. Bendix commented that EPA should consider the full vehicle emissions and fuel consumption, including the APU, to create a more accurate comparison when considering alternatives to diesel powered APUs. California’s ARB supported the development of a federal rule that requires DPFs on APUs, similar 
to the requirements already in place in California because diesel PM poses a 
large public health risk. 
In contrast, EMA commented that 
EPA should not impose any new emission requirements on APU engines because they already meet the Tier 4 nonroad standards and argued further that this rulemaking is not the proper forum for amending nonroad engine emission standards. Ingersoll Rand commented that they have significant concerns with regard to a nationwide requirement for use of DPFs in diesel- powered APUs, and strongly urged EPA not to impose such a perceived burden on the trucking industry. Ingersoll Rand’s concerns are that the additional cost would push owners away from diesel-powered APUs to battery- powered APUs that, according to Ingersoll Rand, are not yet mature enough to serve as a replacement for diesel-powered APUs. Ingersoll Rand believes that high-capacity battery- powered APUs will eventually become a commercially available and cost- effective alternative to diesel-powered APUs. Ingersoll Rand stated that, although Thermo King has been dedicating resources to research and development in this area for some time, 
mandating this technology today would significantly decrease consumer choice, competitiveness in the APU marketplace, and driver comfort and safety. ATA is concerned that efforts to 
place additional emissions controls, and therefore additional costs, on APUs by making PM standards more stringent will discourage the use of this fuel efficient technology. EPA considered Ingersoll Rand’s comments in developing a phased-in approach to the new PM standards for new tractors using APUs to, having the principal standard apply commencing with MY 2024 tractors in order to provide sufficient lead time. 
Following is discussion of our 
analysis of this issue in light of the information we received and of our decision to establish a new PM standard for these units. 
(a) PM Emissions Impact Without 
Additional Controls 
EPA conducted an analysis using 
MOVES, which evaluates the potential impact on PM emissions due to an increase in APU adoption rates. In this analysis, EPA assumed that PM emission rates from current technology APUs would be unchanged in the future. We estimated an average in-use APU emission rate of 0.96 grams PM per hour from three in-use APUs (model years 2006 and 2011), measured in 
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209U.S. EPA. Updates to MOVES for Emissions 
Analysis of Greenhouse Gas Emissions and Fuel 
Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2 FRM. Docket Number EPA–HQ–OAR–2014–0827. July 2016. 210California Air Resources Board. Idle Reduction 
Technologies for Sleeper Berth Trucks. Last viewed 
on September 19, 2014 at http://www.arb.ca.gov/ msprog/cabcomfort/cabcomfort.htm. 
211California Air Resources Board. 
§ 2485(c)(3)(A)(1). 212California Air Resources Board. Executive 
Order DE–12–006. Last viewed on June 21, 2016 at 
http://www.arb.ca.gov/diesel/verdev/pdf/executive_orders/de-12-006.pdf . different load conditions.209We 
determined that a typical 2010 model 
year or newer tractor that uses its main engine to idle emits 0.32 grams PM per hour, based on a similar analysis of in- use idling of emissions from 2010 model year and newer tractors.
12Thus, the use 
of an APU would lead to a potential increase in PM of as much as 0.64 grams per hour. The results from these MOVES runs 
are shown below in Table III–3. These 
results show that an increase in use of APUs could lead to an overall increase in PM emissions if no additional PM emission standards were put in place. Column three labeled ‘‘Final Phase 2 GHG Program PM
2.5Emission Impact 
without Further PM Control (tons)’’ shows the incremental increase in PM
2.5 
without further regulation of APU PM 2.5 emissions, assuming the rate of APU use 
on which the final CO 2standard is 
premised. These PM emission impacts represent an increase of approximately three percent of the HD sector PM emissions. We note further that the pollutant at issue is diesel PM, which is associated with myriad serious health effects, including premature mortality. See Section VIII.A.6 below. 
TABLE III–3—P ROJECTED IMPACT OF INCREASED ADOPTION OF APU SI NPHASE 2 
CY Baseline HD 
vehicle PM 2.5 
emissions 
(tons) Final phase 2 
GHG program 
PM 2.5aemission 
impact without 
further PM 
control 
(tons)b 
2040 ........................................................................................................................... .................................. 20,939 464 
2050 ........................................................................................................................... .................................. 22,995 534 
Note: 
aPositive numbers mean emissions would increase from baseline to control case. 
bThe impacts shown include all PM 2.5impacts from the rule including impacts from increased tire wear and brake wear that results from the 
slight increase in VMT projected as a result of this rule. 
(b) Feasibility of PM Emission 
Reductions 
As EPA discussed in the NPRM, there 
are DPFs in the marketplace today that can reduce PM emissions from APUs. 80 FR 40213. Since January 1, 2008, California ARB has restricted the idling of sleeper cab tractors during periods of sleep and rest.
210The regulations apply 
additional requirements to diesel-fueled APUs on tractors equipped with 2007 model year or newer main engines. Truck owners in California must either: (1) Fit the APU with an ARB verified Level 3 particulate control device that achieves 85 percent reduction in particulate matter; or (2) have the APU exhaust plumbed into the vehicle’s exhaust system upstream of the particulate matter aftertreatment device.
211Currently ARB has identified 
four control devices that have been verified to meet the Level 3 p.m. requirements. These devices include HUSS Umwelttechnik GmbH’s FS–MK Series Diesel Particulate filters, Impco Ecotrans Technologies’ ClearSky Diesel 
Particulate Filter, Thermo King’s Electric Regenerative Diesel Particulate Filter, and Proventia’s Electronically Heated Diesel Particulate Filter. In addition, ARB has approved a Cummins integrated diesel-fueled APU and several fuel-fired heaters produced by 
Espar and Webasto. 
EPA received comments from 
Daimler, Idle Smart, MECA, and Proventia addressing the feasibility of PM reductions from APU engines. Daimler stated that they supply APUs that currently meet ARB’s PM emission requirements and encouraged EPA to simply adopt ARB’s regulations. Proventia commented that they have produced an ARB-approved actively regenerating DPF to fit the Thermo King Tripac APU since 2012 and that it is proven, reliable, and commercially available. Idle Smart commented that their start-stop idle reduction solution emits less PM emissions than a diesel APU without a DPF. MECA commented that a particulate filter in this application would be a wall flow device and, due to the relatively cold exhaust temperature of these small engines, the filters would need to use either all active or a combination of passive and active regeneration to periodically clean the soot from the filter. MECA stated that active regeneration could be achieved through the use of a fuel burner or electric heather upstream of the filter. MECA also stated that ARB’s regulations demonstrate that it is feasible to control PM from small APU engines and that the technology has been available since 2008. California’s Clean Idle program 
requires that diesel-powered APUs be 
fitted with a verified DPF. In some cases, limits are put on the PM emission level at the engine outlet (upstream of the DPF). For example, the ThermoKing APU approval utilizing a Yanmar engine requires that engine is certified to a PM level of 0.2 g/kW-hr or less (upstream of the DPF).
212Implementation of the 
California program and the subsequent approval of Level 3 verified devices has led to the certification of engines utilized in APUs whose PM emissions at the engine outlet are well below the 0.4 g/kW-hr nonroad Tier 4 final standard for this size engine in 40 CFR part 1039. For example, the Yanmar TK270M engine that is used in combination with ThermoKing’s electronic regenerative diesel particulate filter, which is certified under the EPA designated engine family GYDXL0.57NUA, is certified with a PM level of 0.09 g/kW- hr. The addition of a DPF affords at least an additional 85 percent reduction from the engine outlet certified value, or less than 0.014 g/kW-hr. 
EPA believes that these comments 
confirm our discussion at proposal that PM standards reflecting performance of a diesel particulate filter are technically feasible. 
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213As discussed below, a DPF could be installed 
by the APU manufacturer, the engine manufacturer, 
the tractor manufacturer, or a fourth entity, with certification and labelling responsibilities differing depending on which entity does the installation. 214California Air Resources Board. Staff Report: 
Initial Statement of Reasons; Notice of Public Hearing to Consider Requirements to Reduce Idling Emissions From New and In-Use Trucks, Beginning in 2008. September 1, 2005. Page 38. Last viewed on October 20, 2014 at http://www.arb.ca.gov/regact/hdvidle/isor.pdf . 
215Proventia. Tripac Filter Kits. Last accessed on 
October 21, 2014 at http://www.proventiafilters.com/purchase.html . 216U.S. DOT/NHTSA. Commercial Medium- and 
Heavy-Duty Truck Fuel Efficiency Technology Cost Study. May 2015. Page 71. (c) Benefits of Further PM Controls 
Using MOVES, EPA evaluated the 
impact of requiring further PM control 
from APUs nationwide. As shown in Table III–3 and Table III–4, EPA projects that the HD Phase 2 program without additional PM controls would increase PM
2.5emissions by 464 tons in 2040 and 
534 tons in 2050. The annual impact of the final program to further control PM 
is projected to lead to a reduction of PM
2.5emissions nationwide by 927 tons 
in 2040 and by 1,114 tons in 2050, as shown in Table III–4 the column labeled ‘‘Net Impact on National PM
2.5Emission 
with Further PM Control of APUs (tons).’’ Note that these requirements 
will reduce PM emissions from APUs assumed in the baseline for MY 2018 and later, as well as the additional APUs 
that are projected to be used as a result of the Phase 2 standards. This results in projected reductions that exceed the projected increase in PM emissions that would have occurred with the new Phase 2 GHG standards but without these newly promulgated APU standards. 
TABLE III–4—P ROJECTED IMPACT OF FURTHER CONTROL ON PM 2.5EMISSIONSa 
CY Baseline national 
heavy-duty 
vehicle PM 2.5 
emissions 
(tons) HD Phase 2 
program national 
PM 2.5emissions 
without further 
PM control 
(tons) HD Phase 2 
program national 
PM 2.5emissions 
with further 
PM control 
(tons) Net impact on 
national PM 2.5 
emission with 
further PM 
control of APUs 
(tons) 
2040 ......................................................................................... 20,939 21,403 20,476 ¥927 
2050 ......................................................................................... 22,995 23,529 22,416 ¥1,114 
Note: 
aThe impacts shown include all PM 2.5impacts from the rule including impacts from increased tire wear and brake wear that results from the 
slight increase in VMT projected as a result of this rule. 
(d) PM Emission Reduction Technology 
Costs 
EPA does not project any cost for 
meeting the requirement, commencing on January 1, 2018, that tractor manufacturers using APUs as part of a compliance path to meeting the Phase 1 GHG standards only receive credit in GEM for use of the APU if they use an APU with an engine with deteriorated PM emissions at or below 0.15 g/kW-hr. The same conclusion applies for MY 2021, when we adopt the PM emission level of 0.15 g/kW-hr as an emission standard, not only as a qualifying condition for using AESS for demonstrating compliance with the CO
2 
standard. First, EPA projects that the 2018–2023 requirements can be achieved at zero cost because several engines are already meeting them today with in-cylinder controls. Second, this is only one of many potential compliance pathways for tractors meeting the Phase 1 standards. We nonetheless are providing extra lead time by tying this provision to calendar year 2018, rather than model year 2018, 
to allow manufacturers time for confirming emission levels and otherwise complying with administrative requirements. 
PM emission reductions from APU 
engines beginning in MY 2024 would most likely be achieved through installation of a diesel particulate filter (DPF).
213In the NPRM, EPA discussed 
several sources for DPF cost estimates. The three sources included the federal 
Nonroad Diesel Tier 4 rule, ARB, and Proventia. EPA developed long-term cost projections for catalyzed diesel particulate filters (DPF) as part of the 
Nonroad Diesel Tier 4 rulemaking. In that rulemaking, EPA estimated the DPF costs would add $580 to the cost of 150 horsepower engines (69 FR 39126, June 29, 2004). On the other hand, ARB estimated the cost of retrofitting a diesel powered APU with a PM trap to be $2,000 in 2005.
214Proventia is charging 
customers $2,240 for electronically heated DPF for retrofitting existing APUs.
215 
EPA requested comment on DPF costs 
in the NPRM and received comments from MECA, Proventia, and Ingersoll Rand. MECA agreed with EPA’s range of DPF costs discussed in the NPRM. Proventia stated that the $2,240 end user price cited in the NPRM is for an aftermarket retrofit device. Proventia estimated that the direct manufacturing cost of materials and manufacturing (which is less than the retail price equivalent) for quantities exceeding 10,000 annually would be $975 for an actively regenerating device. The basis for this estimate is Proventia’s current production cost in the quantity of 50 units of $1069. Proventia stated that EPA’s estimate of $580 for a 150hp engine is likely to be for a catalyzed 
passively regenerating DPF because those engines have higher exhaust temperatures. Proventia also stated that a cost of an actively regenerating DPF is significantly higher than for passively regenerating devices. Ingersoll Rand commented that Thermo King currently offers a DPF option on its line of diesel- powered APUs and the incremental price of the DPF option can be as high as $3,500. ATA commented that adding a DPF to an APU increases the cost of the device by up to 20 percent. Daimler provided DPF costs as CBI. 
EPA considered the comments and 
more closely evaluated NHTSA’s contracted TetraTech cost report which found the total retail price of a diesel- powered APU that includes a DPF to be $10,000.
216Based on all of this 
information, EPA is projecting the retail price increment of an actively regenerating DPF installed in an APU to be $2,000. This cost is incremental to the diesel-powered APU technology costs beginning in 2024 MY. 
EPA regards these costs as reasonable. 
First, the PM standard is necessary to 
avoid an unintended consequence of GHG idle control. The standard adopted is also appropriate for APUs used in on- highway applications, since it is comparable to the heavy-duty on- highway standard after considering rounding conventions (the PM standard for a tractor’s main engine is 0.01 g/hp- hr as specified in 40 CFR 86.007– 11(a)(1)(iv))). The standard is also voluntary in the sense that tractor 
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217This valuation is undoubtedly conservative 
because it reflects exposure to PM 2.5generally, 
rather than to the form of PM here: Diesel exhaust 
particulate, a likely human carcinogen. See section VIII.A.6.b. Due to underlying analytical limitations, PM
2.5-related benefit per ton values are only 
estimated out to the year 2030. For the criteria pollutant benefits analysis in this rulemaking, we make a conservative assumption that 2030 values apply to all emission reductions in years that extend beyond 2030. We assume benefit-per-ton values grow larger in the future due to income growth and a larger future population. 
218As noted above, the 2018 provision is a 
compliance constraint, not a standard. manufacturers can use other types of 
idle reducing technologies, or choose a Phase 2 compliance path not involving idle control. The agencies have developed technology packages for determining the final Phase 2 tractor GHG and fuel consumption standards that are predicated on lower penetration 
rates of diesel APUs than in the NPRM and have included several additional idle reducing technologies, making it more likely that alternative compliance paths are readily available. APU manufacturers (and manufacturers of APU engines) also can market their product to any entities other than MY 2024 and later new tractors without meeting the DPF-based PM standard. Our review of the costs of these standards thus indicates that they will be reasonable. 
It is also worth noting that the 
reductions also have monetized benefits far greater than the costs of the standard. Section IX.H.1 of this Preamble discusses the economic value of reductions in criteria pollutants. In this analysis, EPA estimates the economic value of the human health benefits associated with the resulting reductions in PM
2.5exposure using what are known 
as ‘‘benefit per ton’’ values. The benefit per ton values estimate the benefits of reducing incidence of specific PM
2.5- 
related health impacts, including reduction in both premature mortality and premature morbidity from on-road mobile sources. The estimate of benefits from reducing one ton of direct PM
2.5 
from on-road mobile sources in 2030 using a three percent discount rate range is between $490,000 and $1,100,000 (2013$) and is between $440,000 and $990,000 (2013$) using a seven percent discount rate.
217The estimated cost per 
ton for the new APU standards in 2040 is $101,717. 
(e) Other Considerations 
EPA considered the lead time of the 
new PM standards for APUs installed in 
new tractors. The 2018 provision restricting GEM credit for use of APUs is not a new standard, but rather a compliance constraint. There should be ample time for tractor manufacturers to consider how to obtain APUs certified to the designated deteriorated PM 
emissions level should they wish to receive GEM credit for use of APUs. As noted in (d) above, we concluded that 
the reasonable feasible lead time is to implement these provisions on January 1, 2018 because the manufacturer’s contemplating use of APUs in conjunction with a Phase 1 compliance strategy using AESS would need time to adapt their certification systems, which we believe requires lead time of at least several months. 
In MY 2021, tractor manufacturers 
will be subject to a prohibition against selling new MY 2021 through 2023 tractors with APUs that do not meet those specified PM emission levels. For the reasons just given, there is ample time to meet this requirement. 
The diesel particulate filter-based 
standard for APUs installed in new tractors begins in MY 2024. This allows several years for the development and application of diesel particulate filters to these APUs. We have concluded that, given the timing of the PM emission standards finalized in this document and the availability of the technologies, APUs can be designed to meet the new standards with the lead time provided (and, again, noting that tractor manufacturers have available compliance pathways available not involving APUs). 
In terms of safety, EPA considered the 
fact that diesel particulate filters are a known technology. DPFs have been installed on a subset of diesel powered APUs since the beginning of the California requirements and have been used with on-highway diesel engines since the sale of MY 2007 engines. We are unaware of any safety issues with this technology. We are adopting these APU requirements because they allow for reduced fuel consumption; this also leads to a positive impact with respect to energy. 
(f) Implementation of the Standard 
EPA has a choice as to whether to 
adopt these provisions as a tractor 
vehicle standard or as a standard for the non-road engine in the APU. Under either approach, EPA is required to consider issues of technical feasibility, cost, safety, energy, and lead time. EPA has addressed all of these factors above, and finds the 2018, 2021, and 2024 provisions, and associated lead time, to be justified.
218 
The final rule applies most directly to 
tractor manufacturers. However, other entities potentially affected are the manufacturer of the APU, the manufacturer of the engine installed in 
the APU, and a different entity (if any) separately installing a DPF on the APU engine. At present, all engines used in APUs must certify to the PM standard in 40 CFR 1039.101, and must label the engine accordingly (see 40 CFR 1039.135). The provisions we are adopting for MY 2024 require that any APU engine being certified to the 0.02 g/kW-hr PM standard have a label indicating that the APU or engine is so certified. This puts any entity receiving that engine on notice that the APU (and its engine) can be used in a new tractor. Conversely, the absence of such a label indicates that the engine cannot be so used. Consequently, if a tractor manufacturer receives an APU without the supplemental label, it can only use the APU in a new tractor if it installs a DPF or otherwise retrofits the APU engine to meet the PM standard. 
The APU certification provisions in 
40 CFR 1039.699 are simplified to account for the fact that the APU manufacturer would generally be adding emission control hardware without modifying the engine from its certified configuration. Note that engine manufacturers, tractor manufacturers or others installing the emission control hardware may also certify to the 0.02 g/ kW-hr standard. Since the prohibition applies to the tractor manufacturer, we would not expect the delegated assembly provisions of 40 CFR 1037.621 or the secondary vehicle manufacturer provisions of 40 CFR 1037.622 to apply for APU manufacturers. 
As described above, we are aware that 
the PM standards as adopted would not prevent a situation in which tractors are retrofitted with diesel APUs after they are no longer new, without meeting the PM standards described above. We believe that vehicle manufacturers will strongly desire to apply the benefit of AESS with low-PM diesel APUs to help them meet CO
2standards for any 
installations where a diesel APU is a viable or likely option for in-use tractors. We will consider addressing this possible gap in the program with a standard for new APUs installed on new 
or used tractors. Such a standard would be issued exclusively under our authority to regulate nonroad engines as described in Clean Air Act section 213 (a)(4). If we adopt such a standard, we will also consider whether to adopt that same requirement for new APUs installed in other motor vehicles, and for other nonroad installations generally. 
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219See 40 CFR 1037.630. (4) Special Purpose Tractors and Heavy- 
Haul Tractors 
The agencies proposed and are 
adopting provisions in Phase 2 to set standards for a new subcategory of heavy-haul tractors. In addition and as noted above, in Phase 1 the agencies adopted provisions to allow tractor manufacturers to reclassify certain tractors as vocational vehicles, also called Special Purpose Tractors.
219The 
agencies proposed and are adopting provisions in Phase 2 to continue to allow manufacturers to exclude certain vocational-types of tractors (Special Purpose Tractors) from the combination tractor standards and instead be subject to the vocational vehicle standards. However, the agencies are making changes to the proposed Phase 2 Special Purpose Tractors and heavy-haul tractors in response to comments, as discussed below. 
(a) Heavy-Haul Tractors 
For Phase 2, the agencies proposed 
and are adopting an additional 
subcategory to the tractor category for heavy-haul tractors that are designed to haul much heavier loads than conventional tractors. The agencies recognize the need for manufacturers to build these types of vehicles for specific applications and also recognize that such heavy-haul tractors are not fully represented by the way GEM simulates conventional tractors. We believe the appropriate way to prevent effectively penalizing these vehicles is to set separate standards recognizing a heavy- haul vehicle’s unique needs, which include the need for a higher horsepower engine and different transmissions. In addition drivetrain technologies such as 6x2 axles, may not be capable of handling the heavier loads. The agencies are adopting this change in Phase 2 because, unlike in Phase 1, the engine, transmission, and drivetrain technologies are included in the technology packages used to determine the stringency of the tractor standards and are included as manufacturer inputs in GEM. The agencies also recognize that certain technologies used to determine the stringency of the Phase 2 tractor standards are less applicable to the heavy-haul tractors designed for the U.S. market. For example, heavy-haul tractors in the U.S. are not typically used in the same manner as long-haul tractors with extended highway driving, and therefore will experience less benefit from aerodynamics. This means that the agencies are adopting a standard that reflects individualized 
performance of these technologies in particular applications, in this case, heavy-haul tractors, and further, have a means of reliably assessing individualized performance of these technologies at certification. 
The typical tractor is designed in the 
U.S. with a Gross Combined Weight Rating (GCWR) of approximately 80,000 pounds due to the effective weight limit on the federal highway system, except in states with preexisting higher weight limits. The agencies proposed in Phase 2 to consider tractors with a GCWR over 120,000 pounds as heavy-haul tractors. Based on comments received during the development of HD Phase 1 (76 FR 57136–57138) and because we did not propose in Phase 2 a sales limit for heavy-haul as we have for the vocational tractors in Phase 1, the agencies also believed it would be appropriate to further define the heavy- haul vehicle characteristics to differentiate these vehicles from the vehicles in the other nine tractor subcategories. The two additional requirements in the Phase 2 proposal included a total gear reduction greater than or equal to 57:1 and a frame Resisting Bending Moment (RBM) greater than or equal to 2,000,000 in-lbs per rail or rail and liner combination. Heavy-haul tractors typically require the large gear reduction to provide the torque necessary to start the vehicle moving. These vehicles also typically require frame rails with extra strength to ensure the ability to haul heavy loads. We requested comment on the proposed heavy-haul tractor specifications, including whether Gross Vehicle Weight Rating (GVWR) or Gross Axle Weight Rating (GAWR) would be a more appropriate metric to differentiate between a heavy-haul tractor and a typical tractor. 
We received comments from several 
manufacturers about the proposed heavy-haul subcategory. None of the commenters were averse to creating such a subcategory, and many manufacturers directly supported such an action. Navistar supported creating a new heavy-haul subcategory maintaining that this type of vehicle is specified uniquely and is not designed for standard trailers. Volvo supported 
this addition since heavy-haul tractors require large engines and increased cooling capacity and most heavy-haul rigs have some requirement for off-road access to pick up machinery, bulk goods, and unusual loads. 
We received comments from several 
manufacturers about the criteria proposed to define the heavy-haul tractor subcategory. Allison commented that for heavy-haul tractors equipped 
with an automatic transmission, the gear reduction ratio should be greater than or equal to 24.9:1 because an automatic transmission with a torque converter provides a torque multiplying effect and better launch capability. EMA and other manufacturers commented that the proposed specifications for heavy-haul tractors do not allow the relevant vehicles to meet the proposed total gear reduction ratio of 57:1 or greater. EMA commented that the Allison 7-speed 4700 transmission and the Eaton 9LL products both are specifically designed for heavy-haul operations, could meet a 53:1 specification, but not a 57:1 ratio. PACCAR also commented that an automatic transmission torque converter ratio should be included in the Total Reduction ratio calculation to properly incorporate the slip and first gear ratio combination that is inherent in an automatic transmission. EMA, PACCAR, and Volvo recommended that the agencies should change the rear axle ratio for the baseline vehicle to attain the 53:1 total reduction ratio because the proposed baseline heavy-haul vehicle did not meet the proposed total reduction ratio. Daimler commented that the agencies should remove both the frame resistance bending moment requirement and the gear reduction requirement. 
EMA and some of the manufacturers 
commented that the agencies should revise the definition of heavy-haul tractor to be ‘‘equal to or greater than 120,000 pounds GCWR’’ rather than ‘‘greater than 120,000 pounds GCWR.’’ They stated that the specifications for the heavy-haul market start with and include 120,000 pounds GCWR. Daimler suggested that the minimum GCWR be set at 105,000 pounds to better catch the large number of Canadian vehicles that are heavy-haul. Daimler stated that this broader weight definition catches a very small number of US vehicles (0.1 to 0.9 percent of the vehicles, depending on other factors) but catches the large number of Canadian vehicles that Daimler considers to be heavy-haul. 
Volvo commented that there are 
multiple types of heavy-haul tractors, each with their own specific characteristics based on operational considerations: High-roof highway sleeper tractors pulling box vans at or above 120,000 pounds GCWR (e.g. long 
combination vehicles) that run regional and long-haul operations and can benefit from the same technologies as high-roof sleepers with 80,000 pound GCWR and should be credited for the higher payload; low- and mid-roof 
sleepers that primarily run long-haul routes (e.g. pulling low-boy trailers and 
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220Memo to Docket. Heavy Class 8 Discussion 
with Environment and Climate Change Canada. July 
2016. Docket EPA–HQ–OAR–2014–0827. 221As a part of the end of the year compliance 
process, EPA and NHTSA verify manufacturer’s 
production reports to avoid any abuse of the vocational tractor allowance. 
222See existing 40 CFR 1037.630 (a)(1)(i) through 
(iii). heavy equipment); low-roof day cab 
tractors running regional and shorter routes (e.g. bulk haul); and then what 
the industry typically refers to as heavy- haul that are extremely high GCWR and can haul above 300 metric tons and sometimes run in multiple tractor configurations that provide for one or more tractor(s) pulling and one or more tractor(s) pushing. 
In part to follow up on the comments 
made by manufacturers, EPA held discussions with Environment and 
Climate Change Canada (ECCC) after the NPRM was released regarding the Special Purpose tractors and heavy-haul tractors.
220In our discussions, ECCC 
emphasized that the highway weight limitations in Canada are much greater than those in the U.S. Where the U.S. federal highways have limits of 80,000 pounds GCW, Canadian provinces have weight limits up to 140,000 pounds. This difference could potentially limit emission reductions that could be achieved if ECCC were to fully harmonize with the U.S.’s HD Phase 2 standards because a significant portion of the tractors sold in Canada have GCWR greater than 120,000 pounds, the proposed limit for heavy-haul tractors. 
For the FRM, EPA and NHTSA are 
revising the heavy-haul tractor provisions to balance the certainty that vehicles are regulated in an appropriate subcategory along with the potential to better harmonize the U.S. and Canadian regulations. Based on our assessment, the tractors with GCWR greater than or equal to 120,000 pounds truly represent heavy-haul applications in the U.S. Therefore, we are adopting criteria only based on GCWR, not the proposed RBM or total gear reduction ratios. The agencies are adopting Phase 2 heavy- haul standards for this subset of vehicles, similar to the standards proposed for Phase 2 and detailed below in Section III.D.1. 
In Canada, due to their differences in 
weight and dimension requirements, it is primarily tractors with a GCWR of equal to or greater than 140,000 pounds that are truly heavy-haul vehicles. This leaves a set of tractors sold in Canada with a GCWR between 120,000 and 140,000 pounds that are used in ways that are similar to the way tractors with a GCWR less than 120,000 pounds (the typical Class 8 tractor) are used in the U.S. These tractors sold in Canada could benefit from the deployment of additional GHG-reducing technologies beyond what is being required for heavy-haul tractors in the U.S., such as aerodynamic and idle reduction improvements. Most manufacturers tend to rely on U.S. certificates as their evidence of conformity for products sold into Canada to reduce compliance burden. Therefore, in Phase 2 the agencies are adopting provisions that allow the manufacturers the option to meet standards that reflect the appropriate technology improvements, along with the powertrain requirements that go along with higher GCWR. While these heavy Class 8 tractor standards will be optional for tractors sold into the U.S. market, we expect that Canada will consider adopting these as mandatory requirements as part of their regulatory development and consultation process. Given the unique circumstances in the Canadian fleet, we believe that there is a reasonable basis for considering such an approach for Canadian tractors. As such, the agencies have coordinated these requirements with ECCC. The agencies are only adopting optional heavy Class 8 standards for MY 2021 at this time. The expectation is that ECCC will develop their own heavy-duty GHG regulations to harmonize with this Phase 2 rulemaking through its own domestic regulatory process. We expect that ECCC will include a mandate that heavy Class 8 tractors be certified to the MY 2021 heavy Class 8 tractor standards, but could also specify more stringent standards for later years for these vehicles. We plan to coordinate with ECCC to incorporate any needed future changes in a timely manner. Details of these optional standards are included in Section III.D.1. 
(b) Special Purpose Tractors 
During the development of Phase 1, 
the agencies received comments from 
several stakeholders supporting an approach for an alternative treatment of a subset of tractors because they were designed to operate at lower speeds, in stop and go traffic, and sometimes operate off-road or at higher weights than the typical line-haul tractor. These types of applications have limited potential for improvements in aerodynamic performance to reduce CO
2 
emissions and fuel consumption. Therefore, we adopted provisions to allow these special purpose tractors to certify as vocational vehicles (or vocational tractors). Consistent with our approach in Phase 1, the agencies still believe that these vocational tractors are operated differently than line-haul tractors and therefore fit more appropriately into the vocational vehicle category. However, we need to continue to ensure that only tractors that are truly vocational tractors are classified as such.
221As adopted in 
Phase 1, a Phase 2 vehicle determined 
by the manufacturer to be a HHD vocational tractor will fall into one of the HHD vocational vehicle subcategories and be regulated as a vocational vehicle. Similarly, MHD tractors which the manufacturer chooses to reclassify as vocational tractors will be regulated as MHD vocational vehicles. Specifically, the agencies adopted in Phase 1 provisions in EPA’s 40 CFR 1037.630 and NHTSA’s regulation at 49 CFR 523.2 to only allow the following three types of vocational tractors to be eligible for reclassification by the manufacturer: Low-roof tractors intended for intra-city pickup and delivery, such as those that deliver bottled beverages to retail stores; tractors intended for off-road operation (including mixed service operation), such as those with reinforced frames and increased ground clearance; and tractors with a GCWR over 120,000 pounds.
222 
In the Phase 2 proposal, the agencies 
proposed to remove the third type of vocational tractors, heavy-haul tractors with a GCWR over 120,000 pounds, from the Phase 2 Special Purpose Tractor category and set unique standard for heavy-haul tractors. 80 FR 40214. The agencies requested comment on the Special Purpose Tractor criteria and received comments from the manufacturers. EMA and PACCAR commented there is a group of special purpose tractors with a gross combination weight rating over 120,000 pounds that fall in between the proposed regulatory categories for heavy-haul tractors and Class 8 tractors that need to be accounted for in a separate and distinct manner. They stated that such vehicles are still appropriately categorized as Special Purpose Tractors and should be included at the manufacturer’s option in the vocational tractor family, even though they may not meet the proposed total gear reduction requirement or the frame rail requirements. PACCAR and Volvo also requested a modification to the definition to include ‘‘equal to 120,000 GCWR.’’ 
Volvo provided a list of recommended 
Special Purpose Tractor criteria. Volvo stated that these characteristics differentiate these vehicles from line haul operation, especially in terms of fuel economy as well as the significant added costs for these features. Volvo’s 
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223U.S. EPA. Memo to Docket: Special Purpose 
Tractor Production Volumes. Docket EPA–HQ– 
OAR–2014–0827. recommended criteria included GCWR 
greater than 120,000 pounds or any three of the following vehicles specifications: Configuration other than 4x2, 6x2, or 6x4; greater than 14,600 pounds front axle load rating; greater than 46,000 pounds rear axle load rating; greater than or equal to 3.00:1 overall axle reduction in transmission high range; greater than 57.00:1 overall axle reduction in transmission low range; frame rails with a resistance bending moment greater than or equal to 2,000,000 in-lbs., greater than or equal to 20 degree approach angle; or greater than or equal to 14 inch ground clearance. 
The heavy-haul tractor standards that 
the agencies are adopting in Phase 2 apply to tractors with a GCWR greater than or equal to 120,000 pounds. As stated above, the agencies are adopting heavy-haul tractor criteria based only on GCWR, and are not adopting the proposed criteria of RBM or total gear reduction. With these Phase 2 changes to the proposed heavy-haul tractor definition, all tractors that would have been considered as Special Purpose Tractors in Phase 1 due to the GCWR criteria listed in EPA’s 40 CFR 1037.630 and NHTSA’s regulation at 49 CFR 523.2 will now qualify as heavy-haul tractors in Phase 2. Therefore, we no longer believe that it is necessary for heavy-haul tractors to be treated as Special Purpose Tractors. The agencies also reviewed Volvo’s suggested criteria and concluded that the Phase 1 approach and Special Purpose Tractor criteria are working well; therefore, we do not see the need to adopt more 
restrictive criteria. Consequently, the agencies are adopting in Phase 2 provisions in EPA’s 40 CFR 1037.630 and NHTSA’s regulation at 49 CFR 523.2 to only allow the following two types of vocational tractors to be eligible for reclassification to Special Purpose Tractors by the manufacturer: 
(1) Low-roof tractors intended for 
intra-city pickup and delivery, such as those that deliver bottled beverages to retail stores. 
(2) Tractors intended for off-road 
operation (including mixed service operation), such as those with reinforced frames and increased ground clearance. 
These provisions apply only for 
purposes of Phase 2. The agencies are not amending the Phase 1 provisions for special purposes tractors. 
Volvo also requested that the agencies 
add a Vocational Heavy-Haul Tractor subcategory that allows for a heavy-haul tractor which benefits from the utilization of a powertrain optimized to meet the vocational operational requirements of this segment, a 
technology package corresponding to those operational characteristics, and with a corresponding duty cycle and, most importantly, a payload representative of heavy-haul operation. The agencies considered this request and analyzed the expected technology package differences between the vocational and tractor program. As described in Section III.D.1, the agencies are only adopting technologies in the heavy-haul tractor category that would be applicable to the operation of these vehicles. For example, we are not adopting standards that are premised on any improvements to aerodynamics or extended idle reduction. Therefore, we concluded that there is no need to develop another vocational subcategory to account for heavy-haul tractors. 
Because the difference between some 
vocational tractors and line-haul tractors is potentially somewhat subjective, and because of concerns about relative stringency, we also adopted in Phase 1 and proposed to continue in Phase 2 a rolling three year sales limit of 21,000 vocational tractors per manufacturer consistent with past production volumes of such vehicles to limit the use of this provision. We proposed in Phase 2 to carry-over the existing three year sales limit with the recognition that heavy-haul tractors would no longer be permitted to be treated as vocational vehicles (suggesting a lower volume cap could be appropriate) but that the heavy-duty market has improved since the development of the HD Phase 1 rule (suggesting the need for a higher sales cap). The agencies requested comment on whether the proposed sales volume limit is set at an appropriate level looking into the future. 80 FR 40214. 
Several of the manufacturers 
commented that it would be reasonable to remove the sales cap limit. Allison stated that this limitation may have been reasonable in the initial years of the program as a precaution against unreasonably assigning too many tractors to the vocational vehicle category. However in Phase 2, Allison recommended that the agencies should remove the cap for three reasons: (1) Vehicle configurations change over time; (2) the Phase 2 vocational program drives technology improvements of powertrains; and (3) Phase 2 better represents the diversity of vocational vehicle uses that would allow for better alignment of vehicles with duty cycles that most represent their real world operation. Daimler stated that they think that with the addition of heavy-haul tractor standards, there will be less need 
for a sales volume limit on special purpose tractors. In Volvo Group’s opinion, the proposed volume limit is 
overly constraining and burdensome and should be removed. Volvo stated that given the recent product lineup overhauls across the industry they do not believe that there are many models still on the market that are sold in large numbers into both highway tractor and vocational tractor segments, nor is there sufficient reason that any OEM cannot identify specific vehicle attributes in order to classify a tractor as suitable solely for highway use, or for on/off- road use. Volvo Group suggested that the agencies remove the vocational tractor volume restrictions and employ a guideline based on specific vehicle characteristics. 
The agencies evaluated the sales cap 
limit proposed for special purpose tractors and the comments addressing the issue of a sales cap. EPA calculated the number of vocational tractors certified in MY 2014 and MY 2015. The number of tractors ranged between approximately 2,600 and 6,200 per year per manufacturer that certified special purpose tractors, but one manufacturer did not use this provision at all.
223It is 
apparent that none of the manufacturers are utilizing this provision near the maximum allowable level in Phase 1 (a rolling three year sales limit of 21,000). We also believe that there is more incentive for manufacturers to use the special purpose tractor provisions in Phase 1 because the relative difference in stringency between the tractor and vocational programs is much greater in Phase 1 than it will be in Phase 2. Upon further consideration, we concluded that there is significantly less incentive for the manufacturers to reclassify tractors that are not truly special purpose tractors as vocational vehicles as a pathway to a less stringent standard in Phase 2 primarily since the Phase 2 vocational vehicle program stringency is similar to the stringency of the tractor program. In addition, the Phase 2 vocational vehicle compliance program and standards better represent the duty cycles expected of these vehicles and are predicated on performance of similar sets of vehicle technologies, except for aerodynamic technologies, as the primary tractor program. Therefore, we are adopting Phase 2 special purpose tractor provisions without a sales cap, but will continue to monitor during the Phase 2 implementation. 
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224See 40 CFR 1037.150(c). 
225A dromedary is a box, deck, or plate mounted 
behind the tractor cab and forward of the fifth 
wheel on the frame of the power unit of a tractor- trailer combination to carry freight. 226See section I.E. 1 for descriptions of glider 
vehicles and glider kits. (5) Small Tractor Manufacturer 
Provisions 
In Phase 1, EPA determined that 
manufacturers that met the small business criteria specified in 13 CFR 121.201 for ‘‘Heavy Duty Truck Manufacturing’’ should not be subject to the initial phase of greenhouse gas emissions standards in 40 CFR 1037.106.
224The regulations required 
that qualifying manufacturers notify the Designated Compliance Officer each model year before introducing the exempted vehicles into commerce. The manufacturers are also required to label the vehicles to identify them as excluded vehicles. EPA and NHTSA proposed to eliminate this small business provision for tractor manufacturers in the Phase 2 program. As stated in the NPRM, the agencies are aware of two second stage manufacturers building custom sleeper cab tractors. In the proposal we stated that we could treat these vehicles in one of two ways. First, the vehicles may be considered as dromedary vehicles and therefore treated as vocational vehicles.
225Or the agencies could 
provide provisions that stated if a manufacturer changed the cab, but not 
the frontal area of the vehicle, then it could retain the aerodynamic bin of the original tractor. 80 FR 40214. 
The agencies received comments on 
the second stage manufacturer options for small manufacturers discussed in the proposal. American Reliance Industries (ARI) raised concerns related to the proposed alternative methods for excluding or exempting second stage manufacturers performing cab sleeper modifications. ARI is concerned that treating these vehicles as vocational vehicles may mean that other regulations related to vocational vehicles would become applicable and have unanticipated adverse results and that the vehicles would not be certified as vocational vehicles when originally certified by an OEM. ARI commented that if EPA and NHTSA adopt a frontal area approach for second stage manufacturers making cab sleeper modifications, that the section be revised to ensure greater clarity as to the intention and effect of this section. In building a custom sleeper cab, ARI stated that they may use wind fairings, fuel tank fairings, roof fairings, and side extenders that can modify the frontal area of the tractor in height and width as compared to the frontal area of the vehicle used to obtain the original 
certification. ARI also commented that depending on the custom cab sleeper modification, ARI may replace an aerodynamic fairing from the tractor in order to provide better aerodynamic results in light of the cab sleeper modification. ARI does not want to be precluded from continuing to provide these benefits to clients. ARI encourages the agencies to take a similar approach to small business exemption under the Phase 1 regulation in the Phase 2 regulation. 
Daimler commented on the agencies’ 
two proposed approaches for second stage manufacturers that build custom sleepers. Daimler’s main concern is to clarify that where the primary manufacturer has certified a vehicle as a day cab, the second stage manufacturer’s actions do not draw the primary manufacturer into noncompliance. Daimler stated that in many cases, they do not know that a vehicle will be altered by a second stage manufacturer. Daimler did not have a preference on the way that the agencies proposed to regulate these secondary vehicle manufacturers, as long as the primary vehicle manufacturers could continue to sell vehicles with the expectation that anyone changing them from the compliant state in which it was built would certify those changes. 
In response to these comments, EPA 
is clarifying in 40 CFR 1037.622 that small businesses may modify tractors as long as they do not modify the front of the vehicle and so long as the sleeper compartment is no more than 102 inches wide or 162 inches in height. As an interim provision, to allow for a better transition to Phase 2, EPA is finalizing a more flexible compliance path in 40 CFR 1037.150(r). This option allows small manufacturers to convert a low or mid roof tractor to a high roof configuration without recertification, provided it is for the purpose of building a custom sleeper tractor or for conversion to a natural gas tractor. Although this more flexible allowance to convert low and mid roof tractors to high roof tractors is being adopted as an interim provision, we have not established an end date at this time. We expect to reevaluate as manufacturers begin to make use of and may decide to revise it in the future, potentially deciding to make it a permanent allowance. To be eligible for this option, the secondary manufacturer must be a small manufacturer and the original low or mid roof tractor must be covered by a valid certificate of conformity. The modifications may not increase the 
frontal area of the tractor beyond the frontal area of the equivalent high roof tractor paired with a standard box van. 
With respect to Daimler’s comment, 40 CFR 1037.130 only applies to vehicles sold in an uncertified condition and does not apply to vehicles sold in a certified condition. 
(6) Glider Vehicles 
As described in Section XIII.B, EPA is 
adopting new provisions related to 
glider vehicles, including glider tractors.
226NHTSA did not propose 
such changes. Glider vehicles and glider kits were also treated differently under NHTSA and EPA regulations prior to 
this rulemaking. They are exempt from NHTSA’s Phase 1 fuel consumption standards. For EPA purposes, the CO
2 
provisions of Phase 1 exempted glider vehicles and glider kits produced by small businesses but did not include such a blanket exemption for other glider kits. Thus, some gliders and glider kits are already subject to the Phase 1 requirement to obtain a vehicle certificate prior to introduction into commerce as a new vehicle. 80 FR 40528. 
In the NPRM, EPA proposed to revise 
the provisions applicable to glider vehicles so that the engines used in these vehicles would need to meet the standards for the year of the new glider vehicle. EPA’s resolution of issues relating to glider vehicles, including glider tractors, and glider kits, is discussed fully in Section XIII.B and RTC Section 14.2. 
Similarly, NHTSA considered 
including glider vehicles under its Phase 2 program. After assessing the impact glider vehicles have on the tractor segment, NHTSA has elected not to include glider vehicles in its Phase 2 program. NHTSA may reconsider fuel efficiency regulations for glider vehicles in a future rulemaking. 
As discussed in the NPRM, NHTSA 
would like to reiterate its safety authority over gliders—notably, that it has become increasingly aware of potential noncompliance with its regulations applicable to gliders. While there are instances in which NHTSA regulations allow gliders to use a ‘‘donor VIN’’ from a ‘‘donor tractor,’’ NHTSA has learned of manufacturers that are creating glider vehicles that are new vehicles under 49 CFR 571.7(e); however, the manufacturers are not certifying them and obtaining a new VIN as required. NHTSA plans to pursue enforcement actions as applicable against noncompliant manufacturers. In addition to enforcement actions, NHTSA may 
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227Reinhart, T.E. (June 2015). Commercial 
Medium- and Heavy-Duty Truck Fuel Efficiency 
Technology Study—Report #1. (Report No. DOT HS 812 146). Washington, DC: National Highway Traffic Safety Administration. 
228U.S. Department of Energy. SuperTruck 
Initiative. Information available at http://energy.gov/eere/vehicles/vehicle-technologies- office. 
229Committee to Assess Fuel Economy 
Technologies for Medium- and Heavy-Duty 
Vehicles; National Research Council; Transportation Research Board (2010). Technologies and Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty Vehicles. (‘‘The 2010 NAS Report’’) Washington, DC, The National Academies Press. 
230TIAX, LLC. ‘‘Assessment of Fuel Economy 
Technologies for Medium- and Heavy-Duty Vehicles,’’ Final Report to National Academy of Sciences, November 19, 2009. 
231NESCCAF, ICCT, Southwest Research 
Institute, and TIAX. Reducing Heavy-Duty Long Haul Combination Truck Fuel Consumption and CO
2Emissions. October 2009. 
232ICF International. ‘‘Investigation of Costs for 
Strategies to Reduce Greenhouse Gas Emissions for Heavy-Duty On-Road Vehicles.’’ July 2010. Docket Number EPA–HQ–OAR–2010–0162–0283. consider amending 49 CFR 571.7(e) and 
related regulations as necessary. NHTSA believes manufacturers may not be using this regulation as originally intended. 
We believe that the agencies having 
different policies for glider kits and glider vehicles under the Phase 2 program will not result in problematic disharmony between the NHTSA and EPA programs, because of the small number of vehicles that will be involved. EPA believes that its changes will result in the glider market returning to the pre-2007 levels, in which fewer than 1,000 glider vehicles will be produced in most years. Only non- exempt glider vehicles will be subject to different requirements under the NHTSA and EPA regulations. However, we believe that this is unlikely to exceed a few hundred vehicles in any year, which will be few enough not to result in any meaningful disharmony between the two agencies. 
(7) Useful Life and Deterioration Factors 
Section 202(a)(1) of the CAA specifies 
that EPA is to adopt emissions 
standards that are applicable for the useful life of the vehicle. The in-use Phase 2 standards that EPA is adopting will apply to individual vehicles and engines, just as EPA adopted for Phase 1. NHTSA is also adopting the same 
useful life mileage and years as EPA for Phase 2. 
EPA is also not adopting any changes 
to the existing provisions that require that the useful life for tractors with respect to CO
2emissions be equal to the 
respective useful life periods for criteria pollutants, as shown below in Table III– 5. See 40 CFR 1037.106(e). EPA does not expect degradation of the technologies evaluated for Phase 2 in terms of CO
2 
emissions, therefore we did not adopt any changes to the regulations describing compliance with GHG pollutants with regards to deterioration. See 40 CFR 1037.241. 
TABLE III–5—T RACTOR USEFUL LIFE 
PERIODS  
Years Miles 
Class 7 Tractors ........... 10 185,000 
Class 8 Tractors ........... 10 435,000 
D. Feasibility of the Final Phase 2 Tractor Standards 
This section describes the agencies’ 
technical feasibility and cost analysis. Further detail on all of these technologies can be found in the RIA Chapter 2. 
Class 7 and 8 tractors are used in 
combination with trailers to transport freight. The variation in the design of 
these tractors and their typical uses drive different technology solutions for each regulatory subcategory. As noted above, the agencies are continuing the Phase 1 provisions that treat vocational tractors as vocational vehicles instead of as combination tractors, as noted in Section III.C.4. The focus of this section is on the feasibility of final standards for combination tractors including the heavy-haul tractors, but not the vocational tractors. 
EPA and NHTSA collected 
information on the cost and effectiveness of fuel consumption and CO
2emission reducing technologies 
from several sources, including new information collected since the NPRM was promulgated. The primary sources of pre-proposal information were the Southwest Research Institute evaluation of heavy-duty vehicle fuel efficiency and costs for NHTSA,
227the Department 
of Energy’s SuperTruck Program,228 
2010 National Academy of Sciences report of Technologies and Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty Vehicles,
229 
TIAX’s assessment of technologies to support the NAS panel report,
230the 
analysis conducted by the Northeast States Center for a Clean Air Future, International Council on Clean Transportation, Southwest Research Institute and TIAX for reducing fuel consumption of heavy-duty long haul combination tractors (the NESCCAF/ ICCT study),
231and the technology cost 
analysis conducted by ICF for EPA.232 
Some additional information and data were also provided in comments. 
Commenters generally supported the 
agencies’ projection that manufacturers can reduce CO
2emissions and fuel 
consumption of combination tractors through use of many technologies, including engine, drivetrain, aerodynamic, tire, extended idle, and weight reduction technologies. The agencies’ determination of the feasibility of the final HD Phase 2 standards is based on our updated projection of the use of these technologies and an updated assessment of their effectiveness. We will also discuss other technologies that could potentially be used, such as vehicle speed limiters, although we are not basing the final standards on their use for the model years covered by this rule, for various reasons discussed below. 
(1) Projected Technology Effectiveness 
and Cost 
EPA and NHTSA project that CO
2 
emissions and fuel consumption reductions can be feasibly and cost- effectively met through technological improvements in several areas. The agencies evaluated each technology and estimated the most appropriate adoption rate of technology into each tractor subcategory. The next sections describe the baseline vehicle configuration, the effectiveness of the individual technologies, the costs of the technologies, the projected adoption rates of the technologies into the regulatory subcategories, and finally the derivation of these standards. 
Based on information available at the 
time of the NPRM, the agencies proposed Phase 2 standards that projected by 2027, all high-roof tractors would have aerodynamic performance equal to or better today’s SmartWay performance—which represents the best of today’s technology. This would equate to having 40 percent of new high roof sleeper cabs in 2027 complying with the current best practices and 60 percent of the new high-roof sleeper cab tractors sold in 2027 having better aerodynamic performance than the best tractors available today. For tire rolling resistance, we premised the proposed standards on the assumption that nearly all tires in 2027 would have rolling resistance equal to or superior to tires meeting today’s SmartWay designation. 
At proposal, the agencies assumed the 2027 MY engines would achieve an additional 4 percent improvement over Phase 1 engines and we projected 15 percent adoption of waste heat recovery (WHR) and many other advanced engine technologies. In addition, we proposed standards that projected improvements to nearly all of today’s transmissions, incorporation of extended idle reduction technologies on 90 percent of sleeper cabs, and significant adoption of 
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233CBD is mistaken that section 202(a)(2) 
mandates technology-forcing standards, although it 
allows them. See generally 74 FR 49464–465 (Sept. 28, 2009). other types of technologies such as 
predictive cruise control and automatic tire inflation systems. 
The agencies also discussed several 
other alternatives in the proposal. When considering alternatives, it is necessary to evaluate the impact of a regulation in terms of CO
2emission reductions, fuel 
consumption reductions, and technology costs. However, it is also necessary to consider other aspects, such as manufacturers’ research and development resources, the impact on purchase price, and the impact on purchasers. Manufacturers are limited in their ability to develop and implement new technologies due to their human resources and budget constraints. This has a direct impact on the amount of lead time that is required to meet any new standards. From the owner/operator perspective, heavy-duty vehicles are a capital investment for firms and individuals so large increases in the upfront cost could impact buying patterns. Though the dollar value of the lifetime fuel savings will far exceed the upfront technology costs, purchasers often discount future fuel savings for a number of reasons, as discussed in more detail in Section IX.A. Tractor purchasers are often uncertain regarding the amount of fuel savings that can be expected for their specific operation due to the diversity of the heavy-duty tractor market. Although a nationwide perspective that averages out this uncertainty is appropriate for rulemaking analysis, individual operators must consider their potentially narrow operation. In addition, purchasers often put a premium on reliability (because downtime is costly in terms of towing, repair, late deliveries, and lost revenue) and may perceive any new technology as a potential risk with respect to reliability. Another factor that purchasers consider is the impact of a new technology on the resale market, which can also be impacted by uncertainty. 
The agencies solicited comment on all 
of these issues and again noted the possibility of adopting, in a final action, standards that are more accelerated than those in Alternative 3, notably what we termed at proposal, Alternative 4 which would have involved a three year pull ahead of the proposed 2027 standards. 80 FR 40211. The agencies also assumed in the NPRM that both the proposed standards and Alternative 4 could be accomplished with all changes being made during manufacturers’ normal product design cycles. However, we noted that doing so would be more 
challenging for Alternative 4 and may require accelerated research and development outside of design cycles 
with attendant increased costs. Commenters were encouraged in the NPRM to address all aspects of feasibility analysis, including costs, the likelihood of developing the technology to achieve sufficient relaibility within 
the lead time, and the extent to which the market could utilize the technology. 
The agencies received several general 
comments on the overall stringency of the proposed Phase 2 standards. Several entities encouraged the agencies to adopt more stringent tractor standards, including adoption of Alternative 4. They pointed out that DOE’s SuperTruck program demonstrated over 40 percent improvement over 2010 levels, including 10.7 mpg by Cummins- Peterbuilt and 12.2 mpg by Daimler. CBD stated that the technology forcing nature of Clean Air Act section 202(a)(2)
233and EPCA/EISA requires 
more aggressive assumptions regarding technology adoption. UCS commented that the tractor standards could be strengthened by another six percent in 2024 and seven percent in 2027 to reflect the full range of improvements to the powertrain and engine. ICCT stated that its analysis indicates that the technology potential is higher and costs are lower than the agencies’ assessments in the NPRM. CARB stated that Alternative 4 is technologically feasible and will result in more emission and fuel consumption reductions. CARB continued to state that the increased cost due to accelerated implementation is minimal, about $1,000 per vehicle purportedly according to the NPRM. 
In contrast to the commenters that 
called for more stringent standards than those proposed, several other commenters cautioned the agencies from adopting final standards that are more stringent than those proposed. Diesel Technology Forum commented that the agencies should proceed with caution on technologies that are not in wide use that have not demonstrated reliability or commercial availability. The International Foodservice Distributors Association is concerned about Alternative 4 in terms of reliability, commenting that it would require their members to purchase unproven and unreliable equipment in order for OEMs to meet the requirements. OOIDA commented if owners fear a reduction in reliability, increased operating costs, reduced residual value, or large increases in purchase prices, they will adjust their 
purchase plans. 
PACCAR commented about the 
importance of lead time because their customers need time to determine if a technology meets their specific needs in their specific application and need assurance that a technology will be reliable in use. PACCAR also stated that the timing provided in the NPRM Alternative 3 provides the ‘‘greatest likelihood for a successful program.’’ Volvo commented that SuperTruck demonstration vehicles serve only the purpose of demonstration but are not proven with respect to cost, reliability, and durability. Volvo stated that the purpose of SuperTruck was narrow in applicability of matched tractor-trailers and that it did not result in a cost effective tractor because each project cost between $40 and $80 million to produce a single vehicle. Volvo also commented that not all SuperTruck technologies should be forced into all applications and duty cycles and if they are a pre-buy (or no-buy) could result. 
The agencies considered all of the 
general comments associated with the proposed Alternative 3 and Alternative 4 tractor standards. We believe there is merit in many of the detailed comments received regarding technologies. These are discussed in detail in the following sections. Instead of merely choosing from among the proposed alternatives, the agencies have developed a set of final tractor standards that reflect our reevaluation of the ability to pull ahead certain technologies, the limitations in adoption rates and/or effectiveness of other technologies, and consideration of additional technologies. In general, the final Phase 2 tractor standards are similar in overall stringency as the levels proposed in Alternative 3, but have been determined using new technology packages that reflect consideration of all of the technology comments, and in some respects reflect greater stringency than the proposed Alternative 3. 
As can be seen from the comments, 
there is uncertainty and a wide range of opinions regarding the extent to which these technologies can be applied to heavy-duty tractors. Vehicle manufacturers tended to take the conservative position for each technology and argue that the agencies 
should not project effectiveness or adoption rates beyond that which is certain. Many other commenters took a more optimistic view and argued for the agencies to assume that each potential technology will be highly effective in most applications. However the agencies believe the most likely outcome will be that some technologies 
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234North American Council for Freight 
Efficiency. Confidence Report:Idle Reduction 
Solutions. 2014. Page 13. 235NACFE. Confidence Report: Programmable 
Engine Parameters. February 2015. Page 23. will work out better than expected 
while others will be slightly more challenging than projected. Thus, the agencies have tended to make balanced projections for the various technologies, although some may be slightly optimistic while others are somewhat conservative. We believe the overall effect of this approach will be standards that achieve large reductions with minimal risks to the industry. 
(a) Tractor Baselines for Costs and 
Effectiveness 
The fuel efficiency and CO
2emissions 
of combination tractors vary depending on the configuration of the tractor. Many aspects of the tractor impact its performance, including the engine, transmission, drive axle, aerodynamics, and rolling resistance. For each subcategory, the agencies selected a theoretical tractor to represent the average 2017 model year tractor that meets the Phase 1 standards (see 76 FR 57212, September 15, 2011). These tractors are used as baselines from which to evaluate costs and effectiveness of additional technologies and standards. 
As noted earlier, the Phase 1 2017 
model year tractor standards (based on Phase 1 GEM and test procedures) and the baseline 2017 model year tractor results (using Phase 2 GEM and test procedures) are not directly comparable. The same set of aerodynamic and tire rolling resistance technologies were used in both setting the Phase 1 standards and determining the baseline of the Phase 2 tractors. However, there are several aspects that differ. First, a new version of GEM was developed and validated to provide additional capabilities, including more refined modeling of transmissions and engines. Second, the determination of the HD Phase 2 C
dA value takes into account a 
revised test procedure, a new standard 
reference trailer, and wind averaged drag as discussed below in Section III.E. In addition, the HD Phase 2 version of GEM includes road grade in the 55 mph and 65 mph highway cycles, as discussed below in Section III.E. 
The agencies used the same adoption 
rates of tire rolling resistance for the Phase 2 baseline as we used to set the Phase 1 2017 MY standards. See 76 FR 57211. The tire rolling resistance level assumed to meet the 2017 MY Phase 1 standard high roof sleeper cab is considered to be a weighted average of 10 percent pre-Phase 1 baseline rolling resistance, 70 percent Level 1, and 20 percent Level 2. The tire rolling resistance to meet the 2017MY Phase 1 standards for the high roof day cab, low roof sleeper cab, and mid roof sleeper cab includes 30 percent pre-Phase 1 
baseline level, 60 percent Level 1 and 10 percent Level 2. Finally, the low and mid roof day cab 2017 MY standards were premised on a weighted average rolling resistance consisting of 40 percent baseline, 50 percent Level 1, and 10 percent Level 2. The agencies did not receive comments on the tire packages used to develop the Phase 2 baseline in the NPRM. 
The agencies sought comment on the 
baseline vehicle attributes described in the NPRM. The agencies received comments related to the baseline adoption rate of automatic engine shutdown systems (AESS) and the baseline aerodynamics assessment. In the proposal, the agencies noted that the manufacturers were not using tamper- proof AESS to comply with the Phase 1 
standards so the agencies reverted back to the baseline APU adoption rate of 30 percent used in the Phase 1 baseline. EMA and TRALA commented that the agencies confused the use of an APU with the use of tamper-proof idle technologies in assessing the baseline for the proposed Phase 2 standards. They stated that a 30 percent penetration rate of APUs is not the same as a 30 percent penetration rate of tamper-proof idle systems. ATA and Volvo also commented that the assumption that 30 percent of 2017 sleeper tractors will utilize the tamper- proof automatic engine shutdown is too high. EMA and PACCAR commented that virtually all tractors in the field have an automatic shutdown programmed in their engine; however, less than one percent of vehicles sold in recent years have tamper-proof AESS that are triggered in less than five minutes and cannot be reprogrammed for 1.259 million miles. In response to these comments, the agencies reassessed the baseline idle reduction adoption rates. The latest NACFE confidence report found that 9 percent of tractors had auxiliary power units and 96 percent of vehicles are equipped with adjustable automatic engine shutdown systems.
234Therefore, the agencies are 
projecting that 9 percent of sleeper cabs will contain an adjustable AESS and APU, while the other 87 percent will only have an adjustable AESS. Additional discussion on adjustable AESS is included in Section III.D.1.b. 
The Phase 2 baseline in the NPRM 
was determined based on the aerodynamic bin adoption rates used to determine the Phase 1 MY 2017 tractor standards. Volvo, EMA, and other manufacturers also commented that the 
aerodynamic drag baseline for 2017 tractors included in the NPRM was too aerodynamically efficient. EMA commented that some of the best aerodynamic tractors available were tested by the agencies and then declared to be the baseline. According to the manufacturers, the average tractor—the true baseline—is a full bin worse than these best tractors. While the agencies agree with the commenters that it is important to develop an accurate baseline so that the appropriate aerodynamic technology package effectiveness and costs can be evaluated in determining the final Phase 2 standards, there appears to be some confusion regarding the NPRM baseline aerodynamic assessment. The Phase 2 baseline in the NPRM was determined based on the aerodynamic bin adoption rates used to determine the Phase 1 MY 2017 tractor standards (see 76 FR 57211). The baseline was not determined by or declared to be the average results of the vehicles tested, as some commenters maintained. The vehicles that were tested prior to the NPRM were used to develop the proposed aerodynamic bin structure for Phase 2. In both the NPRM and this final rulemaking, we developed the Phase 2 bins such that there is an alignment between the Phase 1 and Phase 2 aerodynamic bins after taking into consideration the changes in aerodynamic test procedures and reference trailers required in Phase 2. The Phase 2 bins were developed so that tractors that performed as a Bin III in Phase 1 would also perform as Bin III tractors in Phase 2. Additional details regarding how the agencies refined the aerodynamic bin values for Phase 2 for the final rule can be found in Section III.E.2.a. The baseline aerodynamic value for the Phase 2 final rulemaking 
was determined in the same manner as the NPRM, using the adoption rates of the bins used to determine the Phase 1 standards, but reflect the final Phase 2 bin C
dA values. 
In the NPRM, we used a transmission 
top gear ratio of 0.73 and drive axle ratio of 3.70 in the baseline 2017 MY tractor. UCS commented that the baseline axle ratio is too high. The agencies determined the rear axle ratio and final drive ratio in the baseline tractor based on axle market information shared by Meritor,
235one of the primary suppliers 
of heavy-duty axles, and confidential business information provided by Daimler. Our assessment of this information found that a rear axle ratio 
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236Ostrander, Robert, et.al. (Meritor). 
Understanding the Effects of Engine Downspeeding 
on Drivetrain Components. 2014. Page 2. of 3.70 and a top gear ratio of 0.73 
(equivalent to a final drive ratio of 2.70) is a commonly spec’d tractor. Meritor’s white paper on downspeeding stated that final drive ratios of less than 2.64 are considered to be ‘‘downsped.’’
236 
The agencies recognize that there is a significant range in final drive ratios that will be utilized by tractors built in 2017 MY, we do not believe that the 
average (i.e., baseline) tractor in 2017 
MY will downsped (i.e., have a final 
drive ratio of less than 2.64). Therefore, 
the agencies are maintaining the proposed top gear ratio and drive axle ratio for the assessment of the baseline tractor performance. The agencies are using the specific 
attributes of each tractor subcategory as 
are listed below in Table III–6 for the Phase 2 baselines. Using these values, the agencies assessed the CO
2emissions 
and fuel consumption performance of the baseline tractors using the Phase 2 GEM. The results of these simulations are shown below in Table III–7. 
TABLE III–6—GEM I NPUTS FOR THE BASELINE CLASS 7 AND8 TRACTOR  
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Engine 
2017 MY 11L 
Engine 350 
HP 2017 MY 11L 
Engine 350 
HP 2017 MY 11L 
Engine 350 
HP 2017 MY 15L 
Engine 455 
HP 2017 MY 15L 
Engine 455 
HP 2017 MY 15L 
Engine 455 
HP 2017 MY 15L 
Engine 455 
HP 2017 MY 15L 
Engine 455 
HP 2017 MY 15L 
Engine 455 
HP 
Aerodynamics (C dA in m2) 
5.41 6.48 6.38 5.41 6.48 6.38 5.41 6.48 5.90 
Steer Tires (CRR in kg/metric ton) 
6.99 6.99 6.87 6.99 6.99 6.87 6.87 6.87 6.54 
Drive Tires (CRR in kg/metric ton) 
7.38 7.38 7.26 7.38 7.38 7.26 7.26 7.26 6.92 
Extended Idle Reduction—Adjustable AESS with no Idle Red Tech Adoption Rate @1% Effectiveness 
N/A N/A N/A N/A N/A N/A 87% 87% 87% 
Extended Idle Reduction—Adjustable AESS with Diesel APU Adoption Rate @3% Effectiveness 
N/A N/A N/A N/A N/A N/A 9% 9% 9% 
Transmission = 10 Speed Manual Transmission 
Gear Ratios = 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73 
Drive Axle Configuration = 4 × 2 Drive Axle Configuration = 6 × 4 
Tire Revs/Mile = 512 
Drive Axle Ratio = 3.70 
TABLE III–7—C LASS 7 AND8 TRACTOR BASELINE CO 2EMISSIONS AND FUELCONSUMPTION  
Class 7 Class 8 
Day Cab Day Cab Sleeper Cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
CO 2(grams CO 2/ton-mile) ........... 119.1 127.2 129.7 91.3 96.6 98.2 84.0 90.2 87.8 
Fuel Consumption (gal/1,000 ton- 
mile) .......................................... 11.69941 12.49509 12.74067 8.96857 9.48919 9.64637 8.25147 8.86051 8.62475 
The agencies also received comments 
related to the baseline heavy-haul 
tractor parameters. Volvo did not agree that certain segments of the heavy-haul population are appropriately represented by the baseline in the NPRM. Volvo stated that these types of vehicles typically utilize an 18-speed transmission, since they require the very close gear ratios and nearly all heavy- haul tractors have deeper drive axle ratios than the agencies have assumed 
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237U.S. Department of Energy. See SuperTruck 
Report to Congress. http://energy.gov/eere/vehicles/ 
downloads/vehicle-technologies-office-report-
adoption-new-fuel-efficient-technologies . 238These GEM default values could be 
superseded on a case-by-case basis based on an 
appropriate off-cycle credit demonstration. (3.55). PACCAR commented the 14.4 
first gear of the 18-speed transmission coupled with the 3.73 rear axle ratio is an example of a significant sales volume combination that meets their recommended 53:1 Total Reduction ratio. Upon further consideration, the 
agencies find the suggestion that the baseline heavy-haul tractor is better represented by an 18-speed manual transmission to be persuasive. We therefore revised the baseline heavy- haul tractor configuration, as shown in Table III–8. 
The baseline 2017 MY heavy-haul 
tractor will emit 56.9 grams of CO
2per 
ton-mile and consume 5.59 gallons of fuel per 1,000 ton-mile. 
TABLE III–8—H EAVY -HAULTRACTOR  
BASELINE CONFIGURATION  
Baseline heavy-haul tractor configuration 
Engine = 2017 MY 15L Engine with 600 HP. 
Aerodynamics (C dA in m2) = 5.00. 
Steer Tires (CRR in kg/metric ton) = 7.0. 
Drive Tires (CRR in kg/metric ton) = 7.4. 
Transmission = 18 speed Manual Trans-
mission 
Gear ratio = 14.4, 12.29, 8.51, 7.26, 6.05, 
5.16, 4.38, 3.74, 3.2, 2.73, 2.28, 1.94, 
1.62, 1.38, 1.17, 1.00, 0.86, 0.73. 
Drive axle Ratio = 3.73. 
All Technology Improvement Factors = 0%. 
The fuel consumption and CO 2 
emissions in this ‘‘flat’’ baseline 
described above remains the same over time with no assumed improvements after 2017, absent a Phase 2 regulation. An alternative baseline was also evaluated by the agencies in which there is a continuing uptake of technologies in the tractor market that reduce fuel consumption and CO
2 
emissions absent a Phase 2 regulation. This alternative baseline, referred to as the ‘‘dynamic’’ baseline, was developed to estimate the potential effect of market pressures and non-regulatory government initiatives to improve tractor fuel consumption. The dynamic baseline assumes that the significant level of research funded and conducted by the Federal government, industry, academia and other organizations will, in the future, result in the adoption of some technologies beyond the levels required to comply with Phase 1 standards. One example of such research is the Department of Energy Super Truck program
237which has a 
goal of demonstrating cost-effective 
measures to improve the efficiency of Class 8 long-haul freight trucks by 50 percent by 2015. The dynamic baseline also assumes that manufacturers will not cease offering fuel efficiency improving technologies that currently have significant market penetration, such as automated manual transmissions. The baselines (one for each of the nine tractor types) are characterized by fuel consumption and CO
2emissions that gradually decrease 
between 2019 and 2028. In 2028, the fuel consumption for the alternative tractor baselines is approximately 4.0 percent lower than those shown in Table III–7. This results from the assumed introduction of aerodynamic technologies such as down exhaust, underbody airflow treatment in addition to tires with lower rolling resistance. The assumed introduction of these technologies reduces the C
dA of the 
baseline tractors and CRR of the tractor tires. To take one example, the C
dA for 
baseline high roof sleeper cabs in Table III–6 is 5.90 m
2in 2017. In 2028, the 
CdA of a high roof sleeper cab would be 
assumed to still be 5.90 m2in the flat 
baseline case outlined above. Alternatively, in the dynamic baseline, the C
dA for high roof sleeper cabs is 5.61 
m2in 2028 due to assumed market 
penetration of technologies absent the Phase 2 regulation. The dynamic baseline analysis is discussed in more detail in RIA Chapter 11. 
(b) Tractor Technology Effectiveness 
The agencies’ assessment of the 
technology effectiveness was developed 
through the use of the GEM in coordination with modeling conducted by Southwest Research Institute. The agencies developed these standards through a three-step process, similar to the approach used in Phase 1. First, the agencies developed estimates of technology performance characteristics and effectiveness in terms of reducing CO
2emissions and fuel consumption for 
each technology, as described below. Each technology is associated with an input parameter which in turn is used as an input to the Phase 2 GEM simulation tool. There are two types of GEM input parameters. The first type requires a manufacturer to measure aspects of the technology. These aspects are used as inputs to GEM which then models the technology’s effectiveness (i.e. the effectiveness for that technology is the GEM output). Aerodynamics, tire 
rolling resistance, engine fuel maps, axle ratio, the optional axle efficiency, and optional transmission efficiencies are examples of this first type of GEM input. The second type of GEM input only requires a manufacturer to install the technology onto the vehicle and does not require any testing to determine the GEM input. The agencies determined and specify in the regulations (see 40 CFR 1037.520) the effectiveness of this second type of GEM input. The agencies also define the technologies that qualify to be eligible for these GEM technology inputs in the regulations (see 40 CFR 1037.660 and 1037.801). Examples of these technology inputs include transmission type, idle reduction technologies, tire pressure 
systems, vehicle speed limiters, weight reduction, intelligent controls, and other accessories. The performance levels for the range of Class 7 and 8 tractor aerodynamic packages and vehicle technologies are described below in Table III–10.
238All percentage 
improvements noted below are relative to the 2017 MY baseline tractor. 
As discussed in Section I.C.1.a, we 
assume manufacturers will incorporate appropriate compliance margins for all measured GEM inputs. In other words, they will declare values slightly higher than their measured values. As discussed in Section II.D.5, compliance margins associated with fuel maps are likely to be approximately one percent. For aerodynamic inputs, we believe the bin structure will eliminate the need for C
dA compliance margins for most 
vehicles. However, for vehicles with measured C
dA values very near the 
upper bin boundary, manufacturers will likely choose to certify some of them to the next higher bin values (as a number of commenters noted). For tire rolling resistance, our feasibility rests on the Phase 1 standards, consistent with our expectation that manufacturers will to continue to incorporate the compliance margins they considered necessary for Phase 1. With respect to optional axle and/or transmission power loss maps, we believe manufacturers will need very small compliance margins. These power loss procedures require high precision so measurement uncertainty will likely be on the order of 0.1 percent of the transmitted power. All of these margins are reflected in our projections of the emission levels that will be technologically feasible. 
The agencies then determined the 
adoption rates feasible for each 
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239See RIA Chapter 2.8.4.1 for the analysis of the 
engine technologies and the associated fuel maps. 240Daimler Truck North America. SuperTruck 
Program Vehicle Project Review. June 19, 2014. technology in each model year, as 
described in Section III.D.1.c. Then as described in Section III.D.1.f, the agencies combined the technology performance levels with a projected technology adoption rate to determine the GEM inputs used to set the stringency of these standards. The agencies input these parameters into Phase 2 GEM and used the output to determine the final CO
2emissions and 
fuel consumption levels. 
(i) Engine Improvements 
There are several technologies that 
could be used to improve the efficiency 
of diesel engines used in tractors. These technologies include friction reduction, combustion system optimization, and waste heat recovery using the Rankine cycle. Details of the engine technologies, adoption rates, and overall fuel consumption and CO
2emission 
reductions are included in Section II.D. 
The Phase 2 engine standards will lead 
each manufacturer to achieve reductions of 1.8 percent in 2021 MY, 4.2 percent in 2024 MY, and 5.1 percent in 2027 MY. For the final Phase 2 rule, we recognize that it could be possible to achieve greater reductions than those included in the engine standard by designing entirely new engine platforms. See Section II.D.2.e. Unlike existing platforms, which are limited with respect to peak cylinder pressures (precluding certain efficiency improvements), new platforms can be designed to have higher cylinder pressure than today’s engines. New designs are also better able to incorporate recent improvements in materials and manufacturing, as well as other technological developments. Considered together, it is likely that a new engine platform could be about 2 percent better than engines using older platforms. Moreover, the agencies have seen CBI data that suggests improvement of more than 3 percent are 
possible. As discussed in Section II.D.2.e above, how far the various manufacturers are into their design cycles suggests that one or more manufacturers will probably introduce a new engine platform during the Phase 2 time frame. Thus, we project that 50 percent of tractor engines produced in 2027 MY will be redesigned engines (i.e. engines reflecting redesigned engine platforms, again based on existing engine platform redesign schedules within the industry). This means the average 2027 MY tractor engine would be 5.4 and 6.4 percent better than Phase 1 for day and sleeper cabs respectively.
239This reflects an average 
0.8 percent improvement beyond what 
is required to meet the engine standards. 
As noted in Section II.D.2.e, it is 
import to note that these new platforms will be developed based on normal market forces rather than as a result of this rulemaking. Some engine manufacturers have developed new platforms with the last ten years, and we do not expect these engines to be replaced within the Phase 2 time frame. However, other engines have not been fundamentally redesigned recently and will be due for replacement by 2027. Because these new platforms will occur because of market forces rather than this rulemaking, these reductions are in some ways windfalls for vehicle manufacturers. Thus, we have not included the cost of these new platforms 
as part of our rulemaking analysis. 
We have factored these levels into our 
analysis of the vehicle efficiency levels that will be achievable in MY 2027. These additional engine improvements will result in vehicles having lower GEM results. Thus, they make more stringent vehicle standards feasible, and the final standards are structured so that these improved engines are not able to generate windfall credits against the engine standards, but rather that their projected performance is reflected in the stringency of the final tractor vehicle standard. It is important to also note that manufacturers that do not achieve this level of engine reduction would be able to make up the difference by applying one of the many other available and cost-effective tractor technologies to a greater extent or more effectively, so that there are multiple technology paths for meeting the final standards. In other words, a manufacturer that does not invest in updating engine platforms in the Phase 2 time frame is likely to be able to invest in improving other vehicle technologies. (Note that these same reductions cannot be assumed as part of the engine standards because engine manufacturers will not have this same flexibility). These reductions from the engine will show up in the fuel maps used in GEM to set the Phase 2 tractor stringencies. 
(ii) Aerodynamics 
There are opportunities to reduce 
aerodynamic drag from the tractor by 
further optimization of body components, but it is sometimes difficult to assess the benefit of individual aerodynamic features. Therefore, reducing aerodynamic drag requires optimizing of the entire system. The potential areas to reduce drag 
include all sides of the truck—front, sides, top, rear and bottom. The grill, bumper, and hood can be designed to minimize the pressure created by the front of the truck. Technologies such as aerodynamic mirrors and fuel tank fairings can reduce the surface area perpendicular to the wind and provide a smooth surface to minimize disruptions of the air flow. Roof fairings provide a transition to move the air smoothly over the tractor and trailer. Side extenders can minimize the air entrapped in the gap between the tractor and trailer. Lastly, underbelly treatments can manage the flow of air underneath the tractor. DOE has partnered with the heavy-duty industry to demonstrate high roof sleeper cab tractor and box trailer combinations that achieve a 50 percent improvement in freight efficiency evaluated as a 65,000 pound vehicle operating on the highway under somewhat controlled circumstances. However, these demonstration vehicles developed in SuperTruck are not necessarily designed to handle the rigors of daily use over actual in-use roads. For example, they generally have very limited ground clearance that would likely preclude operation in snow, and would be very susceptible to damage from potholes or other road hazards. Nevertheless, this SuperTruck program has led to significant advancements in the aerodynamics of combination tractor- trailers. While the agencies cannot simply apply the SuperTruck program achievements directly into the Phase 2 program because of the significant differences in the limited purpose of SuperTruck and the plenary applicability of a regulation to all operating conditions and duty cycles, it is helpful to assess the achievements and evaluate how the technologies could be applied into mass production into a variety of real world applications while maintaining performance throughout the full useful life of the vehicle. A manufacturer’s SuperTruck demonstration vehicle achieved approximately a seven percent freight efficiency improvement over a 2009 MY 
baseline vehicle due to improvements in tractor aerodynamics and approximately 16 percent overall for the tractor-trailer combination.
240The seven percent 
freight efficiency improvement due to tractor aerodynamics equates to roughly a 14 percent reduction in C
dA from a 
2010 MY baseline vehicle. The 2010 NAS Report on heavy-duty trucks found that there are achievable aerodynamic 
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241See TIAX, Note 230, Page 4–40. 
242Delgado, Oscar. N. Lutsey. Advanced Tractor- 
Trailer Efficiency Technology Potential in the 
2020–2030 Timeframe. April 2015. Docket EPA– HQ–OAR–2014–0827. 243U.S. EPA. ‘‘US EPA Low Rolling Resistance 
Tire Testing Activities’’ presentation to SAE 
Government-Industry Meeting. January 22, 2016. Values represent the ISO 28580 2 meter drum results because these align with the test method used to certify tractors to the GHG and fuel consumption standards. 
244Delgado, Oscar. N. Lutsey. Advanced Tractor- 
Trailer Efficiency Technology Potential in the 2020–2030 Timeframe. April 2015. Docket EPA– HQ–OAR–2014–0827. improvements which yield 3 to 4 
percent fuel consumption reduction or six to eight percent reduction in Cd values, beyond a baseline reflecting performance of technologies used in today’s SmartWay trucks.
241 
The Phase 2 aerodynamic packages 
are categorized as Bin I, Bin II, Bin III, Bin IV, Bin V, Bin VI, or Bin VII based on the wind averaged drag aerodynamic performance determined through testing conducted by the manufacturer. Bin I represents the least aerodynamic tractors, while Bins V–VII would be more aerodynamic than any tractor on the road today. A more complete description of these aerodynamic packages is included in Chapter 2.8.2.2 of the RIA. In general, the C
dA values for 
each package and tractor subcategory were developed through EPA’s coastdown testing of tractor-trailer combinations, the 2010 NAS report, and SAE papers. 
The agencies received comments on 
our aerodynamic technology assessment. A de F Limited commented that wheel covers improve the aerodynamics of tractors and trailers, though the results may be lost in the noise when evaluated on tractors and trailers separately. Daimler commented that they found in their SuperTruck work that there are diminishing opportunities for tractor aerodynamics improvements and there may be impediments to some due to the need to access the back of cab and reliability concerns. AIR CTI commented that they have built a truck with aerodynamic technologies such as a front spoiler that automatically deploys at vehicle speeds over 30 mph, aerodynamic mirrors, and wheel covers over the rear wheels. ICCT found in their workshop that opportunities exist for high roof line haul tractor aerodynamic improvements that could lead to a three to nine percent improvement in fuel consumption over a 2010 baseline.
242The HD 
manufacturers and EMA raised significant concerns with regard to the proposed aerodynamic assessment for Phase 2. They stated that even the best anticipated future-technology SuperTruck tractor configurations with a Phase 2 reference trailer likely would only qualify for the proposed Phase 2 Bin IV or possibly Bin V, leaving Bins V, VI and VII largely infeasible and unachievable. 
The agencies’ assessment is that the 
most aerodynamic tractor tested by EPA in 2015 achieved Bin IV performance. 
See RIA Chapter 3.2.1.2. This vehicle did not include all of the possible aerodynamic technologies, such as wheel covers or active aerodynamics like a grill shutter or front air dam. Upon further analysis of simulation modeling of a SuperTruck tractor with a Phase 2 reference trailer with skirts, we agree with the manufacturers that a SuperTruck tractor technology package would only achieve the Bin V level of C
dA, as discussed above and in RIA 
Chapter 2.8.2.2. Therefore, the agencies’ assessment is that Bin V is achievable with known aerodynamic technologies, as discussed in RIA Chapter 2.4.2.1 and 
2.8.2.2, but agree with the manufacturers that Bins VI and VII have less known technology paths. The agencies are including definitions of Bins VI and VII performance in the Phase 2 regulations with the understanding that aerodynamics will continue to improve over the next ten years until the full phase-in of the Phase 2 program and to provide a value to be input to GEM should they do so. However, we considered the comments and discuss the adoption rates of the more aerodynamic bins in Section III.D.1.c.i, which ultimately concludes that the standards should be predicated only on performance of aerodynamic technologies reflecting up to Bin V. 
As discussed in Section III.E.2, the 
agencies are increasing the number of aerodynamic bins for low and mid roof tractors from the two levels adopted in Phase 1 to seven levels in Phase 2. The agencies adopted an increase in the number of bins for these tractors to reflect the actual range of aerodynamic technologies effective in low and mid roof tractor applications. The aerodynamic improvements to the bumper, hood, windshield, mirrors, and doors are developed for the high roof tractor application and then carried over into the low and mid roof applications. 
(iii) Tire Rolling Resistance 
A tire’s rolling resistance is a function 
of the tread compound material, the 
architecture and materials of the casing, tread design, the tire manufacturing process, and its operating conditions (surface, inflation pressure, speed, temperature, etc.). Differences in rolling resistance of up to 50 percent have been identified for tires designed to equip the same vehicle. Since 2007, SmartWay designated tractors have had steer tires with rolling resistance coefficients of less than 6.5 kg/metric ton for the steer tire and less than 6.6 kg/metric ton for the drive tire.
243Low rolling resistance 
(LRR) drive tires are currently offered in 
both dual assembly and wide-based single configurations. Wide based single tires can offer rolling resistance reduction along with improved aerodynamics and weight reduction. The rolling resistance coefficient target for the Phase 2 NPRM was developed from SmartWay’s tire testing to develop the SmartWay certification and testing a selection of tractor tires as part of the Phase 1 and Phase 2 programs. Even though the coefficient of tire rolling resistance comes in a range of values, to analyze this range, the tire performance was evaluated at four levels for both steer and drive tires, as determined by the agencies. The four levels in the Phase 2 proposal included the baseline (average) from 2010, Level I and Level 2 from Phase 1, and Level 3 that achieves an additional 25 percent improvement over Level 2. The Level 1 rolling resistance performance represents the threshold used to develop SmartWay designated tires for long haul tractors. The Level 2 threshold represents an incremental step for improvements beyond today’s SmartWay level and represents the best in class rolling resistance of the tires we tested for Phase 1. The Level 3 values in the NPRM represented the long-term rolling resistance value that the agencies predicts could be achieved in the 2025 timeframe. Given the multiple year phase-in of the standards, the agencies expect that tire manufacturers will continue to respond to demand for more efficient tires and will offer increasing numbers of tire models with rolling resistance values significantly better than today’s typical low rolling resistance tires. 
ICCT found in their workshop that 
opportunities exist for improvements in rolling resistance for tractor tires that could lead to a two to six percent improvement in fuel consumption when compared to a 2010 baseline tractor.
244 
A fuel consumption improvement in this range would require a six to 18 percent improvement in the tractor tire rolling resistance levels. Michelin commented that the proposed values for the drive tires seem reasonable, though the 4.5 kg/ton level would require significantly higher adoption rate of 
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245U.S. EPA. Memo to Docket. Coefficient of 
Rolling Resistance and Coefficient of Drag 
Certification Data for Tractors. See Docket EPA– HQ–OAR–2014–0827. 
246Bridgestone Tires. Real Questions, Real 
Answers. http://www.bridgestonetrucktires.com/us _
eng/real/magazines/ra_ special-edit_ 4/ra_ special4_
fuel-tires.asp 
247‘‘Factors Affecting Truck Fuel Economy,’’ 
Goodyear, Radial Truck and Retread Service Manual. Accessed February 16, 2010 at http://www.
goodyear.com/truck/pdf/radialretserv/Retread _S9_
V.pdf. 
248American Trucking Association. Tire Pressure 
Monitoring and Inflation Maintenance. June 2010. Page 3. Last accessed on December 15, 2014 at http://www.trucking.org/ATA%20Docs/About/Organization/TMC/Documents/Position%20Papers/Study%20Group%20Information%20Reports/Tire%20Pressure%20Monitoring%20and%20Inflation%20Maintenance%E2%80%94TMC%20I.R.%202010–2.pdf. 
249TMC Future Truck Committee Presentation 
‘‘FMCSA Tire Pressure Monitoring Field Operational Test Results,’’ February 8, 2011. 
250North American Council for Freight 
Efficiency, ‘‘Tire Pressure Systems,’’ 2013. 25180 FR at 40173. 
25280 FR 40278. 
25380 FR at 40258. 
254California Air Resources Board. Draft 
Technology Assessment: Engine/Powerplant and 
Drivetrain Optimization and Vehicle Efficiency. June 2015. Page III–3. Report is available at www.arb.ca.gov. 
255Delgado, Oscar. N. Lutsey. Advanced Tractor- 
Trailer Efficiency Technology Potential in the 2020–2030 Timeframe. April 2015. Docket EPA– HQ–OAR–2014–0827. new generation wide base single tires. 
Michelin also stated that the value of 4.3 kg/ton target for steer tires is highly unlikely based on current evolution and that research shows that 5.0 kg/ton would be more likely. 
The agencies have evaluated this 
comment and find it persuasive. The agencies analyzed the 2014MY certification data for tractors between the NPRM and final rulemaking. We found that the lowest rolling resistance value submitted for 2014 MY GHG and fuel efficiency certification for tractors was 4.9 and 5.1 kg/metric ton for the steer and drive tires respectively, while the highest rolling resistance tire had a CRR of 9.8 kg/metric ton.
245We have 
accordingly increased the coefficient of rolling resistance for Level 3 tires in the final rule based on the comments and the certification data. 
(iv) Tire Pressure Monitoring and 
Automatic Tire Inflation Systems 
Proper tire inflation is critical to 
maintaining proper stress distribution in the tire, which reduces heat loss and rolling resistance. Tires with low inflation pressure exhibit a larger footprint on the road, more sidewall flexing and tread shearing, and therefore, have greater rolling resistance than a tire operating at its optimal inflation pressure. Bridgestone tested the effect of inflation pressure and found a 2 percent variation in fuel consumption over a 40 psi range.
246 
Generally, a 10 psi reduction in overall tire inflation results in about a one percent reduction in fuel economy.
247 
To achieve the intended fuel efficiency benefits of low rolling resistance tires, it is critical that tires are maintained at the proper inflation pressure. 
Proper tire inflation pressure can be 
maintained with a rigorous tire inspection and maintenance program or with the use of tire pressure and inflation systems. According to a study 
conducted by FMCSA in 2003, about 1 in 5 tractors/trucks is operating with 1 or more tires underinflated by at least 20 psi.
248A 2011 FMCSA study estimated under inflation accounts for one service call per year and increases tire procurement costs 10 to 13 percent. The study found that total operating costs can increase by $600 to $800 per year due to under inflation.
249A recent study 
by The North American Council on Freight Efficiency, found that openness to the use of tire pressure monitoring systems is increasing. It also found that reliability and durability of commercially available tire pressure systems are good and early issues with the systems have been addressed.
250 
These automatic tire inflation systems (ATIS) monitor tire pressure and also automatically keep tires inflated to a specific level. The agencies proposed to provide a one percent CO
2and fuel 
consumption reduction value for tractors with automatic tire inflation systems installed. 
Tire pressure monitoring systems 
(TPMS) notify the operator of tire pressure, but require the operator to manually inflate the tires to the optimum pressure. Because of the dependence on the operator’s action, the agencies did not propose an emission reduction value for tire pressure monitoring systems. Instead, we requested comment on this approach and sought data from those that support a reduction value be assigned to tire pressure monitoring systems. 80 FR 40218. 
Many commenters including OOIDA, 
ATA, the truck manufacturers, RMA, UPS, Bendix, Doran, First Industries, NADA, and others suggested that the agencies should recognize TPMS as a technology in GEM, with the effectiveness value set at an equal level as ATIS. On the other hand, ARB generally supported the use of ATIS but not TPMS because it requires action from the driver. Many stakeholders stated that TPMS offers similar benefit, but at a lower cost, so is more acceptable in the market. UPS commented that they prefer TPMS because TPMS gives the truck owner an affirmative indication that there is a tire pressure problem, so it can be fixed, whereas the ATIS does not and they are concerned that ATIS simply keeps adding tire pressure automatically, wasting energy, and the truck owner may never know it. Bendix believes that both ATIS and TPMS should be 
available in the market in the Phase 2 timeframe for tractors. RMA cited a NHTSA study of LD vehicles of model years 2004–2007 and found that the presence of a TPMS system led to a 55.6 percent reduction in the likelihood that a vehicle would have one tire that is significantly underinflated (25 percent or greater).
251RMA also stated that 
NHTSA found TPMS to be effective in reducing moderate under inflation (at least 10 percent, but under 25 percent), which was reduced by 35.3 percent.
252 
RMA’s comments also stated for light trucks and vans, the effectiveness rates were even higher, with TPMS reducing severe under inflation by 61.2 percent and moderate under inflation by 37.7 percent. RMA commented that NHTSA found that in 2011, the TPMS systems save $511 million in fuel costs across the vehicle fleet.
253Navistar said the 
driver alert with TPMS is simpler and sufficient to ensure tire inflation in commercial applications. Navistar also commented that in heavy duty, a professional driver has both the incentive and the knowledge to keep tires adequately inflated, neither of which may necessarily be the case with light duty. Doran Manufacturing cited FMCSA studies on TPMS in 2006 that found TPMS were accurate at assessing tire pressure, in 2007 found acceptable durability of TPMS, and in 2011 found that TPMS or ATIS in fleet studies showed a 1.4 percent improvement in fuel economy. ARB’s technology assessment found ATIS benefit at one percent.
254ICCT found in their 
workshop that opportunities exist for ATIS that could lead to a 0.5 to two percent improvement in fuel consumption.
255AIR CTI discussed the 
consequences of improper inflation pressures on tire life, safety, stopping distance, vehicle vibration, and damage to the roads. AIR CTI commented that their Central Tire Inflation system controls tire pressure from controls on the dash and is commonly used in logging and other off-road transportation. 
After consideration of the comments, 
the agencies found them persuasive and are adopting provisions in Phase 2 GEM that allow manufacturers flexibility to 
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256See the draft RIA Chapter 2.4.8 for details. 257See the 2010 NAS Report at 128. 
258The one exception being the design standards 
for certain non-aero trailers. See Section IV below. show compliance with the CO 2and fuel 
consumption standards using various 
technologies, including the flexibility to adopt ATIS or TPMS (see 40 CFR 1037.520). This reflects a change from the Phase 2 NPRM, where only ATIS (not TPMS) was a GEM input. The agencies believe that sufficient incentive exists for truck operators to address low tire pressure conditions if they are notified that they exist through a TPMS. 
The agencies also considered the 
comments to determine the effectiveness of TPMS and ATIS. The agencies conducted a further review of the FCMSA study cited by commenters and we interpret the results of the study to indicate that overall a combination of TPMS and ATIS in the field achieved 1.4 percent reduction. However, it did not separate the results from each technology, and therefore did not indicate that TPMS and ATIS achieved the same levels of reduction. Therefore, we set the effectiveness of TPMS slightly lower than ATIS to reflect that operators will be required to take some action to insure that the proper inflation pressure is maintained. The input values to the Phase 2 GEM are set to 1.2 percent reduction in CO
2emissions and 
fuel consumption for ATIS and 1.0 percent reduction for TPMS. In other words, if a manufacturer installs an ATIS onto a vehicle, then they will enter 1.2 percent into the Tire Pressure System value in their GEM input file. If a manufacturer installs a TPMS, then they will input 1.0 percent into the Tire Pressure System value in GEM. 
EPA proposed a definition of ATIS in 
40 CFR 1037.801 to qualify it as a technology input to GEM. The proposed definition stated that ‘‘Automatic tire inflation system means a system installed on a vehicle to keep each tire inflated to within 10 percent of the target value with no operator input.’’ The agencies received comment about this definition. Meritor suggested adopting the historical industry definition of ATIS as ‘‘Automatic Tire Inflation Systems maintain tire pressure at a single preset level and are pneumatically or electronically activated. These systems eliminate the need to manually inflate tires.’’ Meritor is concerned with the proposed definition of ATIS that required the system must ‘‘keep each tire inflated to within 10 percent’’ to qualify as a technology input to GEM. Meritor commented that the proposed definition is not consistent with the manner in which these systems are used in practice. Meritor stated that an ATIS assures that tires will always be running 
at the recommended cold tire inflation pressure. The agencies are adopting changes to reflect the appropriate 
definition of ATIS in the final rule (see 40 CFR 1037.801). 
(v) Idle Reduction 
Auxiliary power units (APU), fuel 
operated heaters (FOH), battery 
supplied air conditioning, and thermal storage systems are among the technologies available today to reduce fuel consumption and CO
2emissions 
from extended idling (or hoteling). Each of these technologies reduces fuel consumption during idling relative to a truck without this equipment. In Phase 1 and in the Phase 2 NPRM, the agencies took an approach whereby tractor manufacturers could input an idle reduction value into GEM only if a vehicle included a tamper-proof automatic engine shutdown system (AESS) programmed to shut down the engine after five minutes or less. This approach allows the manufacturers to use AESS as one of the technologies (in combination with other technologies such as aerodynamics or low rolling resistance tires) to demonstrate compliance with the CO
2emission and 
fuel consumption standards. The agencies also included several override provisions for the AESS and a discounted GEM input value for an expiring AESS or a system that allowed a specified number of hours of idling per year (see 40 CFR 1037.660). 
The agencies did not differentiate 
between the various idle reduction technologies in terms of effectiveness because we adopted in Phase 1 and proposed in Phase 2 a conservative effectiveness level to recognize that some vehicles may be sold with only an AESS but may then install an idle reduction technology after it leaves the factory (76 FR 57207). The effectiveness for AESS in Phase 1 and proposed in Phase 2 was determined by comparing the idle fuel consumption of the main engine at approximately 0.8 gallons per hour to the fuel consumption of a diesel powered APU that consumes 
approximately 0.2 gallons per hour. This difference equates to a five percent reduction in overall CO
2emissions and 
fuel consumption of a Class 8 sleeper cab. A diesel powered APU was selected for determining the effectiveness and cost because it was a conservative estimate. Diesel powered APUs have the highest fuel consumption and cost of the idle reduction technologies considered.
256The agencies proposed 
that a tamper-proof AESS would receive a five percent CO
2emissions and fuel 
consumption reduction in GEM for vehicles that included this technology. This value is in line with the TIAX 
assessment which found a five percent reduction in overall fuel consumption to be achievable.
257The agencies 
requested comments on the proposed approach. 
The agencies received a number of 
comments regarding ‘‘mandating APU’’ or ‘‘mandating AESS.’’ There is a misconception of the proposed Phase 2 program where stakeholders thought that the agencies were mandating use of APUs. This is incorrect. The tractor standards are performance standards. The agencies merely projected an 
adoption rate of up to 90 percent for tamper-proof AESS in our analysis for determining the stringency level of the proposed standard. As stated above, we did not propose to differentiate between the various idle reduction technologies in terms of effectiveness and only used the diesel powered APU in terms of determining the cost and effectiveness of a potential standard. Also, because the standards are performance standards, the agencies are not mandating any specific fuel consumption or GHG emission reducing technology. For each standard, we developed one potential technology 
pathway to demonstrate the feasibility of the standards, but manufacturers will be free to choose other paths.
258 
The agencies received a significant 
number of comments about idle reduction for sleeper cabs, including recommendations to the agencies to assess the emission reduction for a variety of idle reduction technologies instead of just a tamper-proof AESS. ATA, NADA, and others commented that fleets have a variety of choices available in providing the driver power and comfort in-lieu of idling including use of APUs, FOHs, stop-start (main engine turns on only to recharge the battery after several hours), shore power, battery stand-by, stand-alone anti-idling infrastructure establishments, slip-seat operations, and hotel accommodations. Convoy Solutions stated that IdleAir’s electrified parking spaces are an important bridge technology to more electrified solutions. IdleAir commented it may be possible to recognize off board behavior at the OEM level as a buyer of a new truck could enter into a contract with an EPS provider prior to accepting delivery. ATA and First Industries support efficiency credits for idling reduction options installed by fleets either at the OEM point-of-sale or installed in the after-market. 
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259Delgado, Oscar. N. Lutsey. Advanced Tractor- 
Trailer Efficiency Technology Potential in the 
2020–2030 Timeframe. April 2015. Docket EPA– HQ–OAR–2014–0827. 260North American Council for Freight 
Efficiency. Confidence Report: Programmable Engine Parameters. February 2015. Page 48. 261Gaines, L., A. Vyas, J. Anderson. Estimation of 
Fuel Use by Idling Commercial Trucks. January 2006. The agencies also received comments 
regarding the level of effectiveness of 
idle reduction technologies. ICCT found in their workshop that opportunities exist for line haul tractor idle reduction improvements that could lead to a four to seven percent improvement in fuel consumption.
259MEMA recommended 
that the agencies modify the projected 
effectiveness level based on the merit of the individual idle control technology. MEMA’s recommendation for effectiveness levels based on the fuel consumption and GHG emissions of each technology ranged from 7.7 g/ton- mile for fuel cell APU, 6 g/ton-mile for diesel APU, and 9 g/ton-mile for batter air conditioning systems, fuel operated heater, and combinations of technologies. MEMA supports the agencies’ proposal that, in order to qualify for the use of an idle reduction technology in GEM, it is mandatory that the truck be equipped with an AESS. MEMA also commented that in the Phase 1 RIA, the agencies assumed a Class 8 sleeper cab spends 1,800 hours in extended idle per year and travels about 250 days per year. MEMA recommends that the agencies use 2,500 annual hours for APUs and 1,250 annual hours for FOHs to better reflect real-world application and experiences. Additionally, MEMA recommends that 0.87 gallon/hour fuel consumed by the main engine during idle be used in the calculations for credit. 
The agencies also received a 
significant number of comments about idle reduction encouraging the agencies to consider recognizing adjustable AESS instead of only a tamper-proof AESS. ATA commented that most fleets already purchase ‘‘programmable’’ idle shutdown timers to limit idling due to the national patchwork of anti-idling laws currently in place. ATA continued to say that these timers are typically set for a given period of time throughout the initial fleet’s ownership period. ATA also stated as witnessed under Phase I, fleets are unwilling to purchase hard-programmed, tamper-proof AESS given their need for flexibility regarding their resale of used equipment on the secondary market. Caterpillar also noted that fleets do not purchase tamper- resistant automatic engine shutdown systems; therefore, AESS should not be part of the stringency setting, unless the agencies also consider programmable versions of AESS. PACCAR, Volvo and EMA request the agencies to consider partial credit for AESS that are programmed to a 5-minute or sooner 
shutdown but are not tamper-resistant to changes by an owner. Daimler and Navistar also commented that the agencies should consider adjustable AESS as a technology input to GEM. Daimler found that less than one percent of the adjustable AESS systems set at or below 5 minutes that were installed in customer tractors were deactivated or reprogrammed to a value longer than 5 minutes. PACCAR viewed the proposed tamper-proof AESS for 1.259 million miles as unrealistic and not reflecting current market conditions. 
While the agencies do not necessarily 
believe that customer reluctance in the initial years of Phase 1 should be considered insurmountable, we do agree with commenters that the agencies should allow adjustable AESS to be a technology input to GEM and should differentiate effectiveness based on the idle reduction technology installed by the tractor manufacturer. We will still apply the Phase 1 requirement that the AESS be programmed to 5 minutes or less at the factory to qualify as a 
technology input in GEM (see 40 CFR 1037.660), but for Phase 2 will allow a variety of both tamper-proof and adjustable systems to qualify for some reduction (i.e. to be recognized by 
GEM). Any changes made subsequent to the factory but prior to delivery to the purchaser, must be accounted for in the manufacturer’s end of year reports. 
The agencies developed effectiveness 
levels for the extended idle technologies from literature, SmartWay work, and the 2010 NAS report. The agencies also reviewed the NACFE report on programmable engine parameters which included a fleet survey on how often the fleets change programmable parameters, such as automatic engine shutdown timers.
260The survey found that 
approximately 70 percent of these fleets never changed the setting. The agencies developed the effectiveness levels to reflect that there is some greater uncertainty of adjustable AESS systems, therefore the effectiveness values are discounted from the values determined for tamper-proof AESS. A detailed discussion regarding the comments and the associated calculations to determine the effectiveness of each of the idle reduction technologies are included in RIA Chapter 2.4.8.1.1. In summary, the effectiveness for each type of idle reduction technology is included in Table III–9. TABLE III–9—I DLEREDUCTION  
TECHNOLOGY EFFECTIVENESS  
Idle Reduction Technology Idle reduction 
value in GEM 
(%) 
Tamper-Proof AESS ............. 4 
Tamper-Proof AESS w/Die-
sel APU ............................. 4 
Tamper-Proof AESS w/Bat-
tery APU ............................ 6 
Tamper-Proof AESS w/Auto-
matic Stop-Start ................ 3 
Tamper-Proof AESS w/FOH 
Cold, Main Engine Warm .. 3 
Adjustable AESS w/Diesel 
APU ................................... 3 
Adjustable AESS w/Battery 
APU ................................... 5 
Adjustable AESS w/Auto-
matic Stop-Start ................ 3 
Adjustable AESS w/FOH 
Cold, Main Engine Warm .. 2 
Adjustable AESS pro-
grammed to 5 minutes ...... 1 
In addition to extended idling (or 
hoteling) by sleeper cabs, the agencies 
discussed work day idle by day cabs in the Phase 2 NPRM. 80 FR 40217. Day cab tractors often idle while cargo is loaded or unloaded, as well as during the frequent stops that are inherent with driving in urban traffic conditions near cargo destinations. Prior to issuing the Phase 2 NPRM, the agencies reviewed literature to quantify the amount of idling which is conducted outside of hoteling operations. One study, conducted by Argonne National Laboratory, identified several different types of trucks which might idle for extended amounts of time during the work day.
261Idling may occur during 
the delivery process, queuing at loading docks or border crossings, during power take off operations, or to provide comfort during the work day. However, the study provided only ‘‘rough estimates’’ of the idle time and energy use for these vehicles. At the time of the Phase 2 NPRM, the agencies were not able to appropriately develop a baseline of workday idling for day cabs and identify the percent of this idling which could be reduced through the use of AESS. We welcomed comment and data on quantifying the effectiveness of AESS on day cabs. We further requested comment on the possibility of adapting the idle-only duty cycle for vocational vehicles to certain day cab tractors, and also considered the possibility of neutral idle technology for tractors using torque-converter automatic 
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262Manual transmissions require the driver to 
shift the gears and manually engage and disengage 
the clutch. Automatic transmissions shift gears through computer controls and typically include a torque converter. An AMT operates similar to a manual transmission, except that an automated 
clutch actuator disengages and engages the drivetrain instead of a human driver. An AMT does not include a clutch pedal controllable by the driver or a torque converter. 
263See TIAX, Note 230, above at 4–70. transmissions and stop-start for any 
tractor. Id. 
The agencies received a significant 
number of comments regarding day cab idle reduction. CARB commented that the agencies should include idle reduction technologies for day cabs, similar to the proposed vocational vehicle approach. CARB stated that even if the first owners do not see significant emission reductions, many of the day cab tractors are used in port and drayage applications in their second life where they would see significant reductions. CARB suggested that the GEM composite weighting factor for idle should be between 5 and 10 percent. Bendix would like to see the vocational vehicle idle reduction approach extended to day cab tractors based on their data which found that there are many applications of day cab tractors that spend a significant portion of their day’s drive time at idle, especially pick- up and delivery type applications and a growing number of fleets that run hub and spoke type operations. MEMA supported extending neutral idle and stop-start technologies to day cab tractors. MEMA recommends that the agencies set the effectiveness of day cabs idle reduction technologies at a value equal to 35 percent of the effectiveness associated with a comparable technology in a Class 8 sleeper cab. Allison stated that agencies should include automatic neutral in all tractors. Allison stated that automatic neutral is standard with the Allison TC10 and is available with the Allison 3000 and 4000 Series transmissions. 
Daimler commented that they have 
not validated that stop-start strategies are viable for Class 7 and 8 applications and considers it premature for the agencies to project that stop-start strategies are viable for this class of engines. Daimler stated that lubrication of critical bearing surfaces is lacking or severely compromised during engine start up due to the lack of lubricating oil pressure and this lack of lubrication leads to metal to metal contact, wear, and ultimately failure. In addition, Daimler commented that firing pressures inherent to compression ignition engines further exacerbate wear as compared to, for example, spark ignition engines where stop-start technology is being increasingly applied. Daimler also stated that these known problems, coupled with the extremely long million mile plus service life expectations for this heavier class of heavy-duty engines, together pose a development challenge that is significantly more challenging than that 
posed to spark ignition engines in passenger cars. Daimler further stated that heat soak of temperature critical 
parts and temporary disruption of their lubrication/cooling systems will have to be understood and possible degradations handled through modifications at either component or system basis, the extent of which is not yet fully quantified. Daimler also stated that similarly, on the turbocharger side, the larger speed swings will shorten turbocharger wheel life, which is increasingly challenged in vocational applications that are characteristically more transient as compared to the relatively steady operation nature of line haul. 
The agencies considered the 
comments, both supporting and raising concerns over idle reduction in day cabs. The agencies determined that neutral idle for automatic transmissions is an appropriate technology for use in tractors. Therefore, the agencies are adopting provisions in Phase 2 to recognize neutral-idle in automatic transmissions as an input to GEM. Our analysis shows that neutral idle effectiveness is approximately 0.8 to one percent over the composite day cab tractor cycles, as shown in RIA Chapter 2.8.2.6.2. The agencies will also include neutral idle as a GEM input for sleeper cabs, though the effectiveness is very low. The agencies are predicating the standards for day cabs based on a technology package that includes neutral idle. 
In terms of stop-start technologies in 
tractors, the agencies are not including it as a technology input to GEM because we believe the technology, as applied to tractors, needs further development. If this technology is developed in the future for tractors, then manufacturers may consider applying for off-cycle technology credits. Since the agencies are not predicating the Phase 2 standards on adoption of start-stop technologies, the agencies are also not including this technology as a GEM input. 
(vi) Transmissions 
As discussed in the 2010 NAS report, 
automatic (AT) and automated manual 
transmissions (AMT) may offer the ability to improve vehicle fuel consumption by optimizing gear selection compared to an average driver.
262However, as also noted in the report and in the supporting TIAX report, the improvement is very dependent on the driver of the truck, such that reductions ranged from zero to eight percent.
263Well-trained drivers 
would be expected to perform as well or even better than an automated transmission since the driver can see the road ahead and anticipate a changing stoplight or other road condition that neither an automatic nor automated manual transmission can anticipate. However, less well-trained drivers that shift too frequently or not frequently enough to maintain optimum engine operating conditions could be expected to realize improved in-use fuel consumption by switching from a manual transmission to an automatic or automated manual transmission. As transmissions continue to evolve, dual clutch transmissions (DCTs) are now being used in the European heavy-duty vehicle market. DCTs operate similar to AMTs, but with two clutches so that the transmission can maintain engine speed during a shift which improves fuel efficiency. 
The benefits for automated manual, 
automatic, and dual clutch transmissions were developed from literature, from simulation modeling conducted by Southwest Research Institute, and powertrain testing conducted at Oak Ridge National Laboratory. The proposed Phase 2 benefit of these transmissions in GEM was set at a two percent improvement over a manual transmission due to the automation of the gear shifting. 80 FR 40217. 
Allison Transmission commented that 
their real world studies indicate that automatic transmissions perform as well or better than AMTs or DCTs in terms of GHG and fuel efficiency impact. Allison commented that their ATs can exceed the 2 percent level estimated at proposal, but believe it is a reasonable level to apply this level of effectiveness for ATs and AMTs. Allison stated that automatic transmissions in tractors have neutral at stop capability, first gear lockup operation, load-based and grade- based shift algorithms and acceleration rate management that contribute to the overall fuel efficiency of ATs in tractors. Allison also commented that although DCTs should logically perform better than the MT baseline, there was no record information to support that assumption. Volvo commented that fuel 
consumption with their I-Shift DCT is the same as the I-Shift AMT. PACCAR recommends that the agencies take a more detailed approach to assessing transmission advances and revise the 
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264Lutsey, Nic. T. Langer, S. Khan. Stakeholder 
Workshop on Tractor-Trailer Efficiency Technology 
in the 2015–2030 Timeframe. August 2014. Docket EPA–HQ–OAR–2014–0827. 
265Delgado, Oscar. N. Lutsey. Advanced Tractor- 
Trailer Efficiency Technology Potential in the 2020–2030 Timeframe. April 2015. Docket EPA– HQ–OAR–2014–0827. 
266Stoltz, T. and Dorobantu, M. Transmission 
Potential to Contribute to CO 2Reduction: 2020 and 
Beyond Line Haul Perspective. ACEEE/ICCT Workshop on Emerging Technologies for Heavy- Duty Fuel Efficiency. July 2014. 
267North American Council for Freight 
Efficiency. Confidence Report: Electronically Controlled Transmissions. December 2014. 268Memorandum to the Docket ‘‘Effectiveness of 
Technology to Increase Transmission Efficiency.’’ July 2016. agencies’ estimate to reflect technologies 
that are already under true consideration for use in production powertrains. 
UCS commented that as much as 1.3 
to 2.0 percent savings from tractor- trailers could be added to the proposed stringency to reflect the true potential from tractor-trailers from powertrain optimization, particularly since every major manufacturer already offers at least one ‘‘integrated powertrain’’ option in its long-haul fleet. ICCT referred to two studies related to tractor-trailer technologies in their comments.
264 265 In 
their stakeholder workshop, they found that the effectiveness of automated manual transmissions ranged between two and three percent. They also cited another finding that highlighted opportunities to improve transmission efficiency, including direct drive, which would provide about two percent fuel consumption reduction.
266 
The agencies’ assessment of the 
comments is that Allison, ICCT, and Volvo support the proposed two percent effectiveness for AT and AMT transmission types. In addition, the agencies reviewed the NACFE report on electronically controlled transmissions (AT, AMT, and DCT).
267This report had 
similar findings as those noted above in the NAS 2010 report. Electronically controlled transmissions were found to be more fuel efficient than manual transmissions, though the amount varied significantly. The report also stated that fleets found that electronically controlled transmissions also reduced the fuel efficiency variability between drivers. Therefore after considering the comments related to effectiveness and additional reports, the agencies are adopting as proposed a two percent effectiveness for AMT. As discussed in RIA 2.8.2.5, the agencies conducted powertrain testing at Oak Ridge National Laboratory to compare the fuel efficiency of an AMT to an AT. Based on the results, the agencies expect that automatic transmissions designed for long haul operation and automated manual transmissions will perform similarly and have similar effectiveness 
when compared to a manual transmission. 
The benefit of the AMT’s automatic 
shifting compared to a manual transmission is recognized in Phase 2 GEM by simulating the MT as an AMT and increasing the emission results from the simulation by two percent. For ATs, the agencies developed the default automatic transmission inputs to GEM to represent a typical heavy-duty automatic transmission, which is less efficient than the TC10 (the transmission tested at Oak Ridge National Lab). The agencies selected more conservative default transmission losses in GEM so that we would not provide a false efficiency improvement for the less efficient automatic transmissions that exist in the market today. Under the regulations in this rulemaking, manufacturers that certify using the TC10 transmission would need to either conduct the optional transmission gear efficiency testing or powertrain testing to recognize the effectiveness of this type of automatic transmission in GEM. In our technology packages developed to set the Phase 2 standard stringencies, the agencies used a two percent effectiveness for automatic transmissions with neutral idle under the assumption that either powertrain or transmission gear efficiency tests would be conducted. The compliance costs for this type of testing (which crosses over both the vocational and tractor programs) are included as noted in RIA Chapter 7.2.1.2. 
The agencies agree with PACCAR that 
we should consider future transmission advances. There are three certification pathways for manufacturers to assess benefits of future transmissions; that is, to generate a value reflecting greater improvement than the two percent GEM input. The first is an optional powertrain test (40 CFR 1037.550), the second is an optional transmission efficiency test (40 CFR 1037.565), and the third is off-cycle credits (40 CFR 1037.610). 
The agencies acknowledge UCS’s 
comment about increasing the stringency of the tractor program due to the opportunity to further improve powertrain optimization through powertrain testing. For the Phase 2 final 
rule, we have made several changes that capture much of the improvement potential highlighted by UCS. First, the required use of a cycle average fuel map in lieu of a steady state fuel map for evaluating the transient cycle in GEM will recognize improvements to transient fuel control of the engine. The agencies are including the impact of improved transient fuel control in the 
engine fuel maps used to derive the final standards. Second, the optional transmission efficiency test will recognize the benefits of improved gear efficiencies. The agencies have built some improvements in transmission gear efficiency into the technology package used to derive the final standards. This leaves only the optimization of the transmission shift strategy, which would need to be captured on a powertrain test. The agencies believe that the opportunity of shift strategy optimization is less for tractors than for other types of vocational vehicles because a significant portion of the tractor drive cycles are at highway speeds with limited transmission shifting. Therefore, we 
have not included the powertrain optimization portion only recognized through powertrain testing into the standard setting for the final rule. 
The agencies also proposed standards 
that considered the efficiency benefit of transmissions that operate with top gear direct drive instead of overdrive. In the proposal, we estimated that direct drive had two percent higher gear efficiency than an overdrive gear. 80 FR 40229. The benefit of direct drive was recognized through the transmission gear ratio inputs to GEM. Direct drive leads to greater reductions of CO
2 
emissions and fuel consumption during highway operation, but virtually none in transient operation. The agencies did not receive any negative comments regarding the efficiency difference between direct drive and overdrive; therefore, we continued to include the default transmission gear efficiency advantage of two percent for a gear with a direct drive ratio in the version of GEM adopted for the final Phase 2 rules. 
The agencies are also adopting in 
Phase 2 an optional transmission efficiency test (40 CFR 1037.565) for generating an input to GEM that overrides the default efficiency of each gear based on the results of the test. Although optional, the transmission efficiency test will allow manufacturers to reduce the CO
2emissions and fuel 
consumption by designing better transmissions with lower friction due to better gear design and/or mandatory use of better lubricants. The agencies project that transmission efficiency could improve one percent over the 2017 baseline transmission in Phase 2. Our assessment was based on comments received and discussions with transmission manufacturers.
268 
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269See the 2010 NAS Report, Note 229, page 67. 
270Green, D.A., et. al. ‘‘The Effect of Engine, Axle, 
and Transmission Lubricant, and Operating 
Conditions on Heavy Duty Diesel Fuel Economy. Part 1: Measurements.’’ SAE 2011–01–2129. SAE International Journal of Fuels and Lubricants. January 2012. 
271Memorandum to the Docket ‘‘Effectiveness of 
Technology to Increase Axle Efficiency.’’ July 2016. 272North American Council for Freight 
Efficiency. ‘‘Confidence Findings on the Potential of 
6x2 Axles.’’ 2014. Page 16. 
273Ibid. 
274Reinhart, T.E. (June 2015). Commercial 
Medium- and Heavy-Duty Truck Fuel Efficiency 
Technology Study—Report #1. (Report No. DOT HS 812 146). Washington, DC: National Highway Traffic Safety Administration. 
275Lutsey, Nic. T. Langer, S. Khan. Stakeholder 
Workshop on Tractor-Trailer Efficiency Technology in the 2015–2030 Timeframe. August 2014. Docket EPA–HQ–OAR–2014–0827. 
276Delgado, Oscar. N. Lutsey. Advanced Tractor- 
Trailer Efficiency Technology Potential in the 2020–2030 Timeframe. April 2015. Docket EPA– HQ–OAR–2014–0827. (vii) Drivetrain and Engine 
Downspeeding 
Downspeeding: As tractor 
manufacturers continue to reduce the losses due to vehicle loads, such as aerodynamic drag and rolling resistance, 
the amount of power required to move the vehicle decreases. In addition, engine manufacturers continue to improve the power density of heavy- duty engines through means such as reducing the engine friction due to smaller surface area. These two changes lead to the ability for truck purchasers to select lower displacement engines while maintaining the previous level of performance. Engine downsizing could be more effective if it is combined with the downspeeding assuming increased brake mean effective pressure does not affect durability. The increased efficiency of the vehicle moves the operating points down to a lower load zone on a fuel map, which often moves the engine away from its sweet spot to a less efficient zone. In order to compensate for this loss, downspeeding allows the engine to run at a lower engine speed and move back to higher load zones, and thus can slightly improve fuel efficiency. Reducing the engine size allows the vehicle operating points to move back to the sweet spot, thus further improving fuel efficiency. Engine downsizing can be accounted for as a vehicle technology through the use of the engine’s fuel map in GEM in combination with the vehicle’s transmission gear ratios, drive axle ratio, and tire diameter. The agencies evaluated the impact of downspeeding in setting the stringencies by modeling different rear axle ratios in GEM. As shown in RIA Chapter 2.8.2.7, a decrease in final drive ratio from 2.6 to 2.3 will lead to a 2.5 percent reduction in tractor CO
2emissions and fuel 
consumption. The reshaping of the torque curve of an engine to increase the low speed torque and reduce the speed at which maximum torque occurs, will impact the CO
2emissions and fuel 
consumption on the engine test cycles, but will also have a small impact on the vehicle fuel consumption. Higher torque at lower engine speeds will allow the transmission to operate in top gear for a longer period of the time which will reduce the number of downshifts over a cycle and in turn means that the engine speed is lower on average. This benefit will show up in GEM. Additional information on engine downspeeding can be found in RIA Chapter 2.3.8. 
Low Friction Axle and Wheel Bearing 
Lubricants: The 2010 NAS report 
assessed low friction lubricants for the drivetrain as providing a one percent improvement in fuel consumption based on fleet testing.
269A field trial of 
European medium-duty trucks found an average fuel consumption improvement of 1.8 percent using SAE 5W–30 engine oil, SAE 75W90 axle oil and SAE 75W80 transmission oil when compared to SAE 15W40 engine oil and SAE 90W axle oil, and SAE 80W transmission oil.
270The light-duty 2012–16 MY 
vehicle rule and the pickup truck portion of this program estimate that low friction lubricants can have an effectiveness value between zero and one percent compared to traditional lubricants. In the Phase 2 proposal, the agencies proposed the reduction in friction due to low viscosity axle lubricants of 0.5 percent. 80 FR 40217. 
Lubrizol commented that high 
performing lubricants should play a role in Phase 2. Lubrizol also supports the axle test procedures to further recognize axle efficiency improvements. PACCAR recommended eliminating the rear axle efficiency test and provide credits based on calculated values. 
The agencies’ assessment of axle 
improvements found that axles built in the Phase 2 timeline could be 2 percent more efficient than a 2017 baseline axle.
271In lieu of a fixed value for low 
friction axle lubricants (i.e. in lieu of a 
specified GEM input), the agencies are adopting an axle efficiency test procedure (40 CFR 1037.560), as discussed in the NPRM. 80 FR 40185. The axle efficiency test will be optional, but will allow manufacturers to recognize in GEM reductions in CO
2 
emissions and fuel consumption through improved axle gear designs and/or mandatory use of low friction lubricants. The agencies are not providing an alternate path to recognize better lubricants without axle testing. 
Axle Configuration: Most tractors 
today have three axles—a steer axle and two rear drive axles, and are commonly referred to as 6x4 tractors. Manufacturers offer 6x2 tractors that include one rear drive axle and one rear non-driving axle. The 6x2 tractors offer three distinct benefits. First, the non- driving rear axle does not have internal friction and therefore reduces the overall parasitic losses in the drivetrain. In addition, the 6x2 configuration typically weighs approximately 300 to 400 lbs less than a 6x4 configuration.
272 
Finally, the 6x2 typically costs less or is 
cost neutral when compared to a 6x4 tractor. Sources cite the effectiveness of 6x2 axles at between one and three percent.
273 274 The NACFE report found 
in OEM evaluations of 6x2 axles that the effectiveness ranged between 1.6 and 2.2 percent. NACFE also evaluated 6x2 axle tests conducted by several fleets and found the effectiveness in the range of 2.2 to 4.6 percent. Similarly, with the increased use of double and triple trailers, which reduce the weight on the tractor axles when compared to a single trailer, manufacturers offer 4x2 axle configurations. The 4x2 axle configuration would have as good as or better fuel efficiency performance than a 6x2. The agencies proposed to apply a 2.5 percent improvement in vehicle efficiency to 6x4 and 4x2 axle configurations. 80 FR 40217–218. 
Meritor stated in their comments that 
their internal testing and real world testing supported the 2.5 percent efficiency proposed by the agencies for 6x2 axles. Meritor suggested the need to better define a ‘‘disengageable tandem’’ when the agencies discussed what we called axle disconnect in the NPRM. Meritor recommends that a fuel efficiency benefit of 2.0 percent be assigned to the disengageable tandem for the 55 mph and 65 mph drive cycles to account for the more limited use. 
ICCT referred to two studies related to 
tractor-trailer technologies in their comments.
275 276 In their stakeholder 
workshop, they found that the effectiveness of 6x2 axles ranged between one and 2.5 percent. 
The agencies’ assessments of these 
technologies show that the reductions are in the range of two to three percent. For the final rule, the agencies are simulating 6x2, 4x2, and disengageable axles within GEM based on the manufacturer input of the axle configuration instead of providing a fixed value for the reduction. This approach is more technically sound because it will take into account future changes in axle efficiency. See RIA 
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277See the RIA Chapter 2.4 for details. 278Delgado, Oscar. N. Lutsey. Advanced Tractor- 
Trailer Efficiency Technology Potential in the 
2020–2030 Timeframe. April 2015. Docket EPA– HQ–OAR–2014–0827. 279California Air Resources Board. Letter from 
Michael Carter to Matthew Spears dated December 3, 2014. Solar Control: Heavy-Duty Vehicles White Paper. Docket EPA–HA–OAR–2014–0827. Chapter 4 for additional details 
regarding GEM. 
(viii) Accessories and Other 
Technologies 
Accessory Improvements: Parasitic 
losses from the engine come from many systems, including the water pump, oil pump, and power steering pump. Reductions in parasitic losses are one of the areas being developed under the DOE SuperTruck program. As presented in the DOE Merit reviews, Navistar stated that they demonstrated a 0.45 percent reduction in fuel consumption through water pump improvements and 0.3 percent through oil pump improvements compared to a current engine. In addition, Navistar showed a 0.9 percent benefit for a variable speed water pump and variable displacement oil pump. Detroit Diesel reports a 0.5 percent benefit coming from improved water pump efficiency.
277It should be 
noted that water pump improvements include both pump efficiency improvement and variable speed or on/ off controls. Lube pump improvements are primarily achieved using variable displacement pumps and may also include efficiency improvement. All of these results shown in this paragraph are demonstrated through the DOE SuperTruck program at a single operating point on the engine map, and therefore the overall expected reduction of these technologies is less than the single point result. The agencies proposed that compared to 2017 MY air conditioners, air conditioners with improved efficiency compressors will reduce CO
2emissions by 0.5 percent. 
Improvements in accessories, such as power steering, can lead to an efficiency improvement of one percent over the 2017 MY baseline. 80 FR 40218. 
Navistar commented that the 
proposed ‘‘electrically powered pumps for engine cooling’’ be revised to include ‘‘electronically controlled variable speed coolant pumps’’ to align with the Preamble descriptions and 
technology under development as part of the SuperTruck program. Navistar commented that shifting to fully electronic pump creates reliability concerns and adds additional complexity due to the size of the necessary pumps (2+ horsepower) and that the increased power load will require a larger alternator and upgraded wiring. Navistar suggested that in addition to a fully electric pump, Dual Displacement power steering should also be included as an accessory improvement because this technology reduces parasitic loads by applying power proportional to steering demand. 
ZF TRW Commercial Steering commented that they are developing a power steering pump that uses a secondary chamber deactivation during highway cruise operations that reduce the pump drive torque by 30 to 40 percent. Navistar also commented that 
the effectiveness for an electrified air conditioning compressor is understated in the NPRM. Navistar’s estimates are closer to 1.5 percent when in use which will be during the use of air conditioning and during defrost; therefore, the effective benefit should be one percent. Daimler commented that the proposed high efficiency air conditioning effectiveness should be refined and that other opportunities to reduce losses, such as blend air systems, should be considered. In response to the comments, the agencies evaluated a set of accessories that can be designed to reduce accessory losses. Due to the complexity in determining what qualifies as an efficient accessory, we are maintaining the proposed language for accessories for tractors which provides defined effectiveness values for only electric air conditioning compressors and electric power steering pumps and coolant pumps. Manufacturers have the option to apply for off-cycle credits for the other types and designs of high efficiency accessories. 
Intelligent Controls: Skilled drivers 
know how to control a vehicle to obtain maximum fuel efficiency by, among other things, considering road terrain. For example, the driver may allow the vehicle to slow down below the target speed on an uphill and allow it to go over the target speed when going downhill, to essentially smooth out the engine demand. Electronic controls can be developed to essentially mimic this activity. The agencies proposed to provide a two percent reduction in fuel consumption and CO
2emissions for 
vehicles configured with intelligent controls, such as predictive cruise control. 80 FR 40218. ICCT found in their workshop that opportunities exist for road load optimization through predictive cruise, GPS, and driver feedback that could lead to a zero to five percent improvement in fuel consumption.
278Daimler commented 
that eCoast should also be recognized as an intelligent control within GEM. Eaton offers similar technology, known as Neutral Coast Mode. Neutral coast is an electronic feature that places an automated transmission in neutral on downhill grades which allows the engine speed to go idle speed. A fuel savings is recognized due to the difference in engine operating conditions due to the reduced load on the engine due to the transmission. 
Based on literature information, 
intelligent controls such as predictive cruise control will reduce CO
2 
emissions by two percent, and the agencies are assuming this level of improvement in considering the level of the tractor standard. In addition, the agencies’ review of literature and confidential business information provided based on the SuperTruck demonstration vehicles indicates that neutral coasting will reduce fuel consumption and CO
2emissions by 1.5 
percent. 
Solar Load Management: The 
agencies received a letter from the California Air Resources Board prior to the proposal requesting consideration of including technologies that reduce solar heating of the cab (to reduce air conditioning loads) in setting the Phase 2 tractor standards. Solar reflective paints and solar control glazing technologies are discussed in RIA Chapter 2.4.9.3. The agencies requested comment on the Air Resources Board’s letter and recommendations.
279The 
agencies received some clarifications from ARB on our evaluation of solar technologies and some CBI from Daimler, but not a sufficient amount of information to evaluate the baseline level of solar control that exists in the heavy-duty market today, determine the effectiveness of each of the solar technologies, or to develop a definition of what qualifies as a solar control technology that could be used in the regulations. Therefore, the agencies would consider solar control to be a technology that manufacturers may consider pursuing through the off-cycle credit program. As such, the agencies did not include solar load management technologies in the technology packages used in setting the final Phase 2 tractor standard stringencies. 
(ix) Weight Reduction 
Reductions in vehicle mass lower fuel 
consumption and GHG emissions by 
decreasing the overall vehicle mass that is moved down the road. Weight reductions also increase vehicle payload capability which can allow additional tons to be carried by fewer trucks consuming less fuel and producing 
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280American Iron and Steel Institute. ‘‘A Cost 
Benefit Analysis Report to the North American 
Steel Industry on Improved Material and Powertrain Architectures for 21st Century ‘‘Trucks.’’ 
281See the 2010 NAS Report, Note 229, page 128. lower emissions on a ton-mile basis. We 
treated such weight reduction in two ways in Phase 1 to account for the fact that combination tractor-trailers weigh- out approximately one-third of the time and cube-out approximately two-thirds of the time. Therefore in Phase 1 and also as finalized for Phase 2, one-third of the weight reduction will be added payload in the denominator while two- thirds of the weight reduction is subtracted from the overall weight of the vehicle in GEM. See 76 FR 57153. 
In Phase 1, we reflected mass 
reductions for specific technology substitutions (e.g., installing aluminum 
wheels instead of steel wheels). These substitutions were included where we could with confidence verify the mass reduction information provided by the manufacturer. The weight reductions were developed from tire manufacturer information, the Aluminum Association, the Department of Energy, SABIC and TIAX. The agencies proposed to expand the list of weight reduction components which can be input into GEM in order to provide the manufacturers with additional means to comply via GEM with the combination tractor standards and to further encourage reductions in vehicle weight. As in Phase 1, we recognize that there may be additional potential for weight reduction in new high strength steel components which combine the reduction due to the material substitution along with improvements in redesign, as evidenced by the studies done for light-duty vehicles.
280The 
agencies however do not agree with all of the recommendations in this report. See Section I.C.1 and RTC Section 1 for a discussion on lifecycle emissions. In the development of the high strength steel component weights, we are only assuming a reduction from material substitution and no weight reduction from redesign, since we do not have any data specific to redesign of heavy-duty components nor do we have a regulatory mechanism to differentiate between material substitution and improved design. Additional weight reduction would be evaluated as a potential off- cycle credit. As described in Section III.E.2 below, the agencies discuss the weight reduction component comments received and are adopting an expanded list of weight reduction options which 
could be input into the GEM by the manufacturers to reduce their certified CO
2emission and fuel consumption 
levels. 
(x) Vehicle Speed Limiter 
Fuel consumption and GHG 
emissions increase proportional to the 
square of vehicle speed. Therefore, lowering vehicle speeds can significantly reduce fuel consumption and GHG emissions. A vehicle speed limiter (VSL), which limits the vehicle’s maximum speed, is another technology option for compliance that is already utilized today by some fleets (though the typical maximum speed setting is often higher than 65 mph). 
CARB recommended not giving any 
credit for VSLs because the available data do not fully support whether VSLs result in real-world fuel consumption and GHG reductions. CARB referenced Oakridge National Laboratory’s Transportation Energy Data Book, Table 5.11 that shows CO
2emissions decrease 
with increased speed. CARB also stated that the draft GEM model appears to offer up to 22 percent credit for use of VSL set to 45 mph, which they consider to be unreasonably high. Before 
including VSLs as a technology, CARB staff suggests that EPA and NHTSA should thoroughly evaluate whether they would result in real-world CO
2and 
fuel consumption benefits. 
The agencies conducted in-use tractor 
testing at different speeds and in turn used this data to validate the GEM simulations of VSL, as discussed in more detail in RIA Chapter 4. The agencies are confident that GEM appropriately recognizes the impact of VSL on CO
2emissions and fuel 
consumption. The agencies have limited the range of inputs to the VSL in Phase 2 GEM to a minimum of 55 mph to align with the regulations in 40 CFR 1037.631 that provide exemptions for vocational vehicles intended for off-road use. A 55 mph VSL installed on a typical day cab tractor would reduce the composite grams of CO
2emitted per ton-mile by 
seven percent. Similarly, a 55 mph VSL on a sleeper cab would reduce the composite grams of CO
2per ton-mile 
emitted by 10 percent. Please see RIA Chapter 2.8 for additional detail of technology impacts. 
(xi) Hybrid Powertrains 
In Phase 2, hybrid powertrains are 
generally considered a conventional 
rather than innovative technology, especially for vocational vehicles. However, hybrid powertrain development in Class 7 and 8 tractors has been limited to a few manufacturer demonstration vehicles to date. One of the key benefit opportunities for fuel consumption reduction with hybrids is less fuel consumption when a vehicle is 
idling, but the standard is already premised on use of extended idle reduction so use of hybrid technology will duplicate many of the same emission reductions attributable to extended idle reduction. NAS estimated that hybrid systems would cost approximately $25,000 per tractor in the 2015 through the 2020 time frame and provide a potential fuel consumption reduction of ten percent, of which six percent is idle reduction that can be achieved (less expensively) through the use of other idle reduction technologies.
281The limited reduction 
potential outside of idle reduction for Class 8 sleeper cab tractors is due to the mostly highway operation and limited start-stop operation. Due to the high cost and limited benefit during the model years at issue in this action, the agencies did not include hybrids in assessing stringency of the proposed tractor standard. 
In addition to the high cost and 
limited utility of hybrids for many tractor drive cycles noted above, the agencies believe that hybrid powertrains systems for tractors may not be sufficiently developed and the necessary manufacturing capacity put in place to base a standard on any significant volume of hybrid tractors. Unlike hybrids for vocational vehicles and light-duty vehicles, the agencies are not aware of any full hybrid systems currently developed for long haul tractor applications. To date, hybrid systems for tractors have been primarily focused on extended idle shutdown technologies and not on the broader energy storage and recovery systems necessary to achieve reductions over typical tractor drive cycles. The Phase 2 sleeper cab tractor standards instead reflect the potential for extended idle shutdown technologies. Further, as highlighted by the 2010 NAS report, the agencies do believe that full hybrid powertrains may have the potential in the longer term to provide significant improvements in long haul tractor fuel efficiency and to greenhouse gas emission reductions. With respect to day cab tractors, the types of tractors that would receive the benefit from hybrid powertrains would be those such as beverage delivery tractors which could be treated as vocational vehicles through the Special Purpose Tractor 
provisions (40 CFR 1037.630). 
Several stakeholders commented on 
hybrid powertrain development for tractor applications. Allison agreed with the agencies’ overall assessment of hybrids in tractors, as discussed in the 
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NPRM. Bendix agreed that hybrid 
systems for tractors have not been focused on. Bendix believed that mild hybrid systems should be included in GEM for credit, including stop-start and electrification of accessories. Daimler commented that in SuperTruck, a tractor that was tested on line haul-type highway routes, the hybrid system provided little benefit beyond what eCoast achieved because it competes with hybrids for energy that might be lost on hills. Overall, Daimler’s view was that hybrid systems proved too costly relative to their benefit. Eaton stated that hybrids have not penetrated the commercial trucking landscape, primarily due to the costs but that there may be potential in the future for hybrids in tractor applications driven by improved aerodynamics and lower rolling resistance tires because it would lead to longer coasting times and higher braking loads, therefore greater regeneration opportunities. PACCAR commented that their history with hybrid technology was a niche market application appealing to ‘‘green’’ companies as long as incentives offset the cost of the technology. PACCAR stated that the low sales volumes were not based on performance, but rather on the combination of the payback of the high initial cost based on the limited number of gallons saved in low mileage pick up-and-delivery applications and on the concern over resale value, since at some point in the vehicle’s life the battery must be replaced at a significant cost to the owner. 
After considering the comments, the 
agencies are continuing the Phase 1 approach of not including hybrid powertrains in our feasibility analysis for Phase 2. Because the technology for tractor applications is still under development we cannot confidently assess the effectiveness of this technology at this point in time. In addition, due to the high cost, limited benefit during highway driving, and lacking any existing systems or manufacturing base, we cannot conclude that such technology will be available for tractors in the 2021–2027 timeframe. However, manufacturers will be able to use powertrain testing to capture the performance of a hybrid system in GEM if systems are developed in the Phase 2 timeframe, so this technology remains a potential compliance option (without requiring an off-cycle demonstration). 
(xii) Operational Management 
The 2010 NAS report noted many 
operational opportunities to reduce fuel 
consumption, such as driver training and route optimization. The agencies have included discussion of several of these strategies in RIA Chapter 2, but are not using these approaches or technologies in the Phase 2 standard setting process. The agencies are looking to other resources, such as EPA’s SmartWay Transport Partnership and regulations that could potentially be promulgated by the Federal Highway Administration and the Federal Motor Carrier Safety Administration, to continue to encourage the development and utilization of these approaches. In addition, the agencies have also declined to base standard stringencies on technologies which are largely to chiefly driver-dependent, and evaluate such potential improvements through the off-cycle credit mechanism. See, e.g., 77 FR 62838/3 (Oct. 12, 2012). 
(xiii) Consideration of Phase 1 Credits in Phase 2 Stringency Setting 
The agencies requested comment 
regarding the treatment of Phase 1 credits, as discussed in Section I.C.1.b. See 80 FR 40251. As examples, the agencies discussed limiting the use of Phase 1 credits in Phase 2 and factoring credit balances into the 2021 standards. Daimler commented that allowing Phase 1 credits in Phase 2 is necessary to smooth the transition into a new program that is very complex and that HD manufacturers cannot change over an entire product portfolio at one time. The agencies evaluated the status of Phase 1 credit balances in 2015 by sector. For tractors, we found that manufacturers are generating significant credits, and that it appears that many of the credits result from their use of an optional provision for calculating aerodynamic drag. However, we also believe that manufacturers will generate fewer credits in MY 2017 and later when the final Phase 1 standards begin. Still, the agencies believe that manufacturers will have significant credit balances available to them for MYs 2021–2023, and that much of these balances would be the result of the test procedure provisions rather than pull ahead of any technology. Based on confidential product plans for MYs 2017 and later, we expect this total windfall amount to be three percent of the MY 2021 standards or more. Therefore, the agencies are factoring in a total credit amount equivalent to this three percent credit (i.e. three years times 1 percent 
per year). Thus, we are increasing the stringency of the CO
2and fuel 
consumption tractor standards for MYs 2021–2023 by 1 percent to reflect these credits. 
(xiv) Summary of Technology 
Performance 
Table III–10 describes the 
performance levels for the range of Class 7 and 8 tractor vehicle technologies. 
TABLE III–10—P HASE 2 TECHNOLOGY INPUTS  
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Engine 
2021MY 
11L Engine 
350 HP 2021MY 
11L Engine 
350 HP 2021MY 
11L Engine 
350 HP 2021MY 
15L Engine 
455 HP 2021MY 
15L Engine 
455 HP 2021MY 
15L Engine 
455 HP 2021MY 
15L Engine 
455 HP 2021MY 
15L Engine 
455 HP 2021MY 
15L Engine 
455 HP 
Aerodynamics (C dA in m2) 
Bin I ........................................... 6.00 7.00 7.45 6.00 7.00 7.45 6.00 7.00 7.15 
Bin II .......................................... 5.60 6.65 6.85 5.60 6.65 6.85 5.60 6.65 6.55 
Bin III ......................................... 5.15 6.25 6.25 5.15 6.25 6.25 5.15 6.25 5.95 
Bin IV ......................................... 4.75 5.85 5.70 4.75 5.85 5.70 4.75 5.85 5.40 
Bin V .......................................... 4.40 5.50 5.20 4.40 5.50 5.20 4.40 5.50 4.90 
Bin VI ......................................... 4.10 5.20 4.70 4.10 5.20 4.70 4.10 5.20 4.40 
Bin VII ........................................ 3.80 4.90 4.20 3.80 4.90 4.20 3.80 4.90 3.90 
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TABLE III–10—P HASE 2 TECHNOLOGY INPUTS —Continued 
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
2021MY 
11L Engine 
350 HP 2021MY 
11L Engine 
350 HP 2021MY 
11L Engine 
350 HP 2021MY 
15L Engine 
455 HP 2021MY 
15L Engine 
455 HP 2021MY 
15L Engine 
455 HP 2021MY 
15L Engine 
455 HP 2021MY 
15L Engine 
455 HP 2021MY 
15L Engine 
455 HP 
Steer Tires (CRR in kg/metric ton) 
Base .......................................... 7.8 7.8 7.8 7.8 7.8 7.8 7.8 7.8 7.8 
Level 1 ....................................... 6.6 6.6 6.6 6.6 6.6 6.6 6.6 6.6 6.6 
Level 2 ....................................... 5.7 5.7 5.7 5.7 5.7 5.7 5.7 5.7 5.7 
Level 3 ....................................... 4.9 4.9 4.9 4.9 4.9 4.9 4.9 4.9 4.9 
Drive Tires (CRR in kg/metric ton) 
Base .......................................... 8.1 8.1 8.1 8.1 8.1 8.1 8.1 8.1 8.1 
Level 1 ....................................... 6.9 6.9 6.9 6.9 6.9 6.9 6.9 6.9 6.9 
Level 2 ....................................... 6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0 
Level 3 ....................................... 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 
Idle Reduction (% reduction) 
Tamper Proof AESS ................. N/A N/A N/A N/A N/A N/A 4 4 4 
Tamper Proof AESS with Diesel 
APU ....................................... N/A N/A N/A N/A N/A N/A 4 4 4 
Tamper Proof AESS with Bat-
tery APU ................................ N/A N/A N/A N/A N/A N/A 6 6 6 
Tamper Proof AESS with Auto-
matic Stop-Start ..................... N/A N/A N/A N/A N/A N/A 3 3 3 
Tamper Proof AESS with FOH N/A N/A N/A N/A N/A N/A 3 3 3 
Adjustable AESS ....................... N/A N/A N/A N/A N/A N/A 1 1 1 
Adjustable AESS with Diesel 
APU ....................................... N/A N/A N/A N/A N/A N/A 3 3 3 
Adjustable AESS with Battery 
APU ....................................... N/A N/A N/A N/A N/A N/A 5 5 5 
Adjustable AESS with Auto-
matic Stop-Start ..................... N/A N/A N/A N/A N/A N/A 5 5 5 
Adjustable AESS with FOH ...... N/A N/A N/A N/A N/A N/A 2 2 2 
Transmission (% reduction) 
Manual ....................................... 0 0 0 0 0 0 0 0 0 
AMT ........................................... 2 2 2 2 2 2 2 2 2 
Auto ........................................... 2 2 2 2 2 2 2 2 2 
Dual Clutch ................................ 2 2 2 2 2 2 2 2 2 
Top Gear Direct Drive ............... 2 2 2 2 2 2 2 2 2 
Trans Efficiency ......................... 1 1 1 1 1 1 1 1 1 
Neutral Idle ................................ Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM 
Driveline (% reduction) 
Axle Efficiency ........................... 2 2 2 2 2 2 2 2 2 
6x2, 6x4 Axle Disconnect or 
4x2 Axle ................................. N/A N/A N/A Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM 
Downspeed ............................... Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM Modeled in 
GEM 
Accessory Improvements (% reduction) 
A/C Efficiency ............................ 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 
Electric Access .......................... 1 1 1 1 1 1 1 1 1 
Other Technologies (% reduction) 
Predictive Cruise Control .......... 2 2 2 2 2 2 2 2 2 
Automated Tire Inflation System 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 
Tire Pressure Monitoring Sys-
tem ......................................... 1 1 1 1 1 1 1 1 1 
Neutral Coast ............................ 1.5 1.5 1.5 1.5 1.5 1.5 1.5 1.5 1.5 
Note: 
‘‘Modeled in GEM’’ means that a manufacturer will input information into GEM, such as ‘‘Yes or No’’ for neutral idle, and GEM will simulate that condition. The val-
ues listed in the table above as percentages reflect a post-processing done within GEM after the simulation runs the drive cycl es. 
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(c) Tractor Technology Adoption Rates 
As explained above, tractor 
manufacturers often introduce major 
product changes together, as a package. In this manner the manufacturers can optimize their available resources, including engineering, development, manufacturing and marketing activities to create a product with multiple new features. Since Phase 1 began, this approach also has allowed manufacturers to consolidate testing and certification requirements. In addition, manufacturers recognize that a truck design will need to remain competitive over the intended life of the design and meet future regulatory requirements. In some limited cases, manufacturers may implement an individual technology outside of a vehicle’s redesign cycle. 
With respect to the levels of 
technology adoption used to develop the HD Phase 2 standards, NHTSA and EPA established technology adoption constraints. The first type of constraint was established based on the application of fuel consumption and CO
2emission reduction technologies 
into the different types of tractors. For example, extended idle reduction technologies are limited to Class 8 sleeper cabs using the reasonable assumption that day cabs are not used for overnight hoteling. Day cabs typically idle for shorter durations throughout the day. 
A second type of constraint was 
applied to most other technologies and limited their adoption based on factors reflecting the real world operating conditions that some combination tractors encounter (so that the standards are not based on use of technologies which do not provide in-use benefit). This second type of constraint was applied to the aerodynamic, tire, powertrain, vehicle speed limiter technologies, and other technologies. NHTSA and EPA believe that within each of these individual vehicle categories there are particular applications where the use of the identified technologies will be either ineffective or not technically feasible. For example, the agencies are not predicating these standards on the use of full aerodynamic vehicle treatments on 100 percent of tractors because we know that in some applications (for example, gravel trucks engaged in local delivery) the added weight of the aerodynamic technologies will increase fuel consumption and hence CO
2 
emissions to a greater degree than the reduction that will be accomplished from the more aerodynamic nature of the tractor. General considerations of needed lead time also play a significant role in the agencies’ determination of 
technology adoption rates. 
In the development of the standards, 
we generally focused initially on what technology could be adopted in 2027 MY after ten years of lead time, consistent with the general principles discussed above. Based on our detailed discussions with manufacturers and technology suppliers, we can project that the vast majority of technologies will be fully developed and in widespread use by 2027 MY. (One notable exception to this is Rankine cycle waste heat recovery, which we project to be less widespread in 2027). Having identified what could be achieved in 2027 MY, we projected technology steps for 2021 MY and 2024 MY to reflect the gradual development and deployment of these technologies. 
This is also consistent with how 
manufacturers will likely approach complying with these standards. In general, we would expect a manufacturer to first identify technology packages that would allow them to meet the 2027 MY standards, then to structure a development plan to make steady progress toward the 2027 MY standards. To some extent, it was easier to project the technology for 2027 MY, because it represents a maximum feasible adoption of most technologies. The agencies’ projections for MYs 2021 and 2024 are less certain because they reflect choices manufacturers would likely make to reach the 2027 levels. As such, we have more confidence that the 
levels of our MYs 2021 and 2024 standards are appropriate than we do that each manufacturer will follow our specific technology development path in 2021 MY or 2024 MY. 
Table III–13, Table III–14, and Table 
III–15 specify the adoption rates that EPA and NHTSA used to develop these standards. 
(i) Aerodynamics Adoption Rate 
The impact of aerodynamics on a 
tractor-trailer’s efficiency increases with 
vehicle speed. Therefore, the usage pattern of the vehicle will determine the benefit of various aerodynamic technologies. Sleeper cabs are often used in line haul applications and drive the majority of their miles on the highway travelling at speeds greater than 55 mph. The industry has focused aerodynamic technology development, including SmartWay tractors, on these types of trucks. Therefore the agencies proposed standards that reflect the most aggressive aerodynamic technology application rates to this regulatory subcategory, along with the high roof day cabs. 80 FR 40227. All of the major manufacturers today offer at least one SmartWay sleeper cab tractor model, 
which is represented as Bin III aerodynamic performance. The agencies requested comment on the proposed aerodynamic assessment. 
The agencies received significant 
comment from the manufacturers regarding our assessment of aerodynamics in the most aerodynamic bins for high roof sleeper cabs. EMA commented that the assumptions that Class 7 and Class 8 high-roof vehicles will achieve a 35 percent penetration rate into Bin V, a 20 percent penetration rate into Bin VI, and a 5 percent penetration rate into Bin VII by 2027 are over-stated and unreasonable. Volvo and EMA commented that it is impossible to achieve the targeted aerodynamic drag reductions that ultimately are predicated on 60 percent of tractors achieving aero bins V, VI, and VII. According to their analysis, the manufacturers stated that it is not possible to achieve these low drag levels with any tractor design coupled to the non-aerodynamic test trailer prescribed in this proposal. Caterpillar commented that given the proposed aerodynamic testing procedures, the Phase 2 test trailer, and the lack of any audit margin for these highly variable test processes, it is infeasible to design tractors that can achieve bin V, and so would not be able to achieve bins VI and VII. Caterpillar also stated that none of the vehicles developed within the Department of Energy’s SuperTruck program are capable of meeting the proposed aerodynamic targets. 
In Phase 1, the agencies determined 
the stringency of the tractor standards through the use of a mix of aerodynamic bins in the technology packages. For example, we included 10 percent Bin II, 70 percent Bin III, and 20 percent Bin IV in the high roof sleeper cab tractor standard. The weighted average aerodynamic performance of this technology package is equivalent to Bin III. 76 FR 57211. In consideration of the comments, the agencies have adjusted the aerodynamic adoption rate for Class 8 high roof sleeper cabs used to set the final standards in 2021, 2024, and 2027 MYs (i.e., the degree of technology 
adoption on which the stringency of the standard is premised). Upon further analysis of simulation modeling of a SuperTruck tractor with a Phase 2 reference trailer with skirts, we agree with the manufacturers that a SuperTruck tractor technology package would only achieve the Bin V level of C
dA, as discussed above and in RIA 
Chapter 2.8.2.2. Consequently, as noted above, the final standards are not 
premised on any adoption of Bin VI and VII technologies. Accordingly, we 
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282U.S. Department of Energy. Transportation 
Energy Data Book, Edition 28–2009. Table 5.7. 283U.S. EPA. Memo to Docket. Coefficient of 
Rolling Resistance and Coefficient of Drag 
Certification Data for Tractors. See Docket EPA– HQ–OAR–2014–0827. determined the adoption rates in the 
technology packages developed for the final rule using a similar approach as Phase 1—spanning three aerodynamic bins and not setting adoption rates in the most aerodynamic bin(s)—to reflect that there are some vehicles whose operation limits the applicability of some aerodynamic technologies. We set the MY 2027 high roof sleeper cab tractor standards using a technology package that included 20 percent of Bin III, 30 percent Bin IV, and 50 percent Bin V reflecting our assessment of the fraction of high roof sleeper cab tractors that we project could successfully apply these aerodynamic packages with this amount of lead time. The weighted average of this set of adoption rates is equivalent to a tractor aerodynamic performance near the border between Bin IV and Bin V. We believe that there is sufficient lead time to develop aerodynamic tractors that can move the entire high roof sleeper cab aerodynamic performance to be as good as or better than today’s SmartWay designated tractors. 
The agencies phased-in the 
aerodynamic technology adoption rates within the technology packages used to determine the MY 2021 and 2024 standards so that manufacturers can gradually introduce these technologies. The changes required for Bin V performance reflect the kinds of improvements projected in the Department of Energy’s SuperTruck program. That program has demonstrated tractor-trailers in 2015 with significant aerodynamic technologies. For the final rule, the agencies are projecting that truck manufacturers will be able to begin implementing some of these aerodynamic technologies on high roof tractors as early as 2021 MY on a limited scale. For example, in the 2021 MY technology package, the agencies have assumed that 10 percent of high roof sleeper cabs will have aerodynamics better than today’s best tractors. This phase-in structure is consistent with the normal manner in which manufacturers introduce new technology to manage limited research and development budgets as well as to allow them to work with fleets to fully evaluate in-use reliability before a technology is applied fleet-wide. The agencies believe the phase-in schedule will allow manufacturers to complete these normal processes. Overall, while the agencies are now projecting slightly less benefit from aerodynamic improvements than we did in the NPRM, the actual aerodynamic technologies being projected are very similar to what was projected at the 
time of NPRM (however, these vehicles fall into Bin V in the final rule, instead of Bin VI and VII in the NPRM). Importantly, our averaging, banking and trading provisions provide manufacturers with the flexibility (and incentive) to implement these technologies over time even though the standard changes in a single step. 
The agencies also received comment 
regarding our aerodynamic assessment of the other tractor subcategories. Daimler commented that due to their shorter length, day cabs are more difficult to make aerodynamic than sleeper cabs, and that the bin boundaries and adoption rates should reflect this. EMA commented that the assumed aerodynamic performance improvements to be achieved by day cab and mid and low-roof vehicles are over- estimated by at least one bin. Daimler commented that the agencies should adjust the average bin down in recognition of the fact that mid/low-roof vehicles should have lower penetration rates of aerodynamic vehicles to reflect market needs, reflecting these vehicles’ use in rough environments or in hauling non-aerodynamic trailers. 
Aerodynamic improvements through 
new tractor designs and the development of new aerodynamic components is an inherently slow and iterative process. The agencies recognize that there are tractor applications that require on/off-road capability and other truck functions which restrict the type of aerodynamic equipment applicable. We also recognize that these types of trucks spend less time at highway 
speeds where aerodynamic technologies have the greatest benefit. The 2002 VIUS data ranks trucks by major use.
282The 
heavy trucks usage indicates that up to 35 percent of the trucks may be used in on/off-road applications or heavier applications. The uses include construction (16 percent), agriculture (12 percent), waste management (5 percent), and mining (2 percent). Therefore, the agencies analyzed the technologies to evaluate the potential restrictions that will prevent 100 percent adoption of more advanced aerodynamic technologies for all of the tractor regulatory subcategories and developed standards with new penetration rates reflecting that these vehicles spend less time at highway speeds. For the final rule, the agencies evaluated the certification data to assess how the aerodynamic performance of high roof day cabs compare to high roof sleeper cabs. In 2014, the high roof day cabs on average are certified to one bin lower than the high roof sleeper cabs.
283 
Consistent with the public comments, and the certification data, the aerodynamic adoption rates used to develop the final Phase 2 standards for the high roof day cab regulatory subcategories are less aggressive than for the Class 8 sleeper cab high roof tractors. In addition, the agencies are also accordingly reducing the adoption rates in the highest bins for low and mid roof tractors to follow the changes made to the high roof subcategories because we neither proposed nor expect the aerodynamics of a low or mid roof tractor to be better than a high roof tractor. 
(ii) Low Rolling Resistance Tire 
Adoption Rate 
For the tire manufacturers to further 
reduce tire rolling resistance, the manufacturers must consider several performance criteria that affect tire selection. The characteristics of a tire also influence durability, traction control, vehicle handling, comfort, and retreadability. A single performance parameter can easily be enhanced, but an optimal balance of all the criteria will require improvements in materials and tread design at a higher cost, as estimated by the agencies. Tire design requires balancing performance, since changes in design may change different performance characteristics in opposing directions. Similar to the discussion regarding lesser aerodynamic technology application in tractor segments other than sleeper cab high roof, the agencies believe that the proposed standards should not be premised on 100 percent application of Level 3 tires in all tractor segments given the potential interference with vehicle utility that could result. 80 FR 40223. 
Several stakeholders commented 
about the level of rolling resistance used in setting the proposed level of tractor stringencies because the agencies used a single level for all tractor subcategories. ATA, First Industries, National Association of Manufacturers, PACCAR, Navistar and Daimler commented that the agencies erred by using the same rolling resistance for all types of day and sleeper cab tractors. They stated that the tire stringency levels should account for fleet and class variations and different duty-cycle needs. Caterpillar stated that tires need to meet demands of all conditions, including 
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284Memo to Docket. Coefficient of Rolling 
Resistance and Coefficient of Drag Certification Data 
for Tractors. Docket EPA–HQ–OAR–2014–0827. unpaved roads, sloped loading docks 
which are frequently not treated in winter conditions. Caterpillar also stated that tire casings must have adequate durability to allow for as many as five retreads. NADA commented current LRRT tractor adoption rates are low and are not expected to increase significantly any time soon unless significant improvements in design are forthcoming and that there is no realistic means of ensuring that customers (or subsequent owners) will continue to use LRR tires. OOIDA commented that the LRR tire may be beneficial on flat terrain, but may pose a safety concern in many geographical regions. OOIDA also stated that a LRR tire achieves much of its potential fuel savings benefit by reducing the very component of friction or resistance that a truck driver may rely upon. PACCAR commented that customers with low- and mid-roof configurations typically operate more in urban areas where tires must withstand the abuse of curbs and other obstacles or in more on/off road conditions that are typical for flatbed, tanker, and low-boy operations, which use the low and mid-roof configuration vehicles. PACCAR stated that the tires for low and mid roof tractors vehicles are designed with additional side wall protection and generally have a higher coefficient of rolling resistance. Volvo commented with respect to tractor penetration and stringency setting the agencies show penetration of Level 3 tires starting in MY 2021. Volvo stated that they continue to hear customer feedback that low rolling resistance tires often lack adequate traction under many of the demanding conditions that trucks and tractors experience, such as snow and off-road. Schneider commented that fleet uses low rolling resistance tires on dual wheels for the majority of the standard fleet while using wide-based single tires for weight sensitive portions of the fleet. Schneider commented that regulations should not force the use of wide based single tires based solely on rolling resistance advantages without considering the overall performance because it may increase waste, the number of scrapped tire casings and landfill requirements. The commenter’s view is that LRR dual tires are very comparable to wide based single tires (WBS) tires in fuel efficiency while providing better overall operating and economic efficiency. 
For the final rulemaking, the agencies 
evaluated the tire rolling resistance levels in the Phase 1 certification data.
284We found that high roof sleeper 
cabs are certified today with steer tire 
rolling resistance levels that ranged between 4.9 and 7.6 kg/ton and with drive tires ranging between 5.1 and 9.8 kg/ton. In the same analysis, we found that high roof day cabs are certified with rolling resistance levels ranging between 4.9 and 9.0 kg/ton for steer tires and between 5.1 and 9.8 kg/ton for drive tires. This range spans the baseline through Level 3 rolling resistance performance levels. Therefore, for the final rule we took an approach similar to the one taken in Phase 1 and proposed in Phase 2 that considers adoption rates across a wide range of tire rolling resistance levels to recognize that operators may have different needs. 76 FR 57211 and 80 FR 40227. The 
adoption rates for the technology packages used to determine the MY 2027 standards for each high roof tractor subcategory are shown in Table III–15. 
In our analysis of the Phase 1 
certification data, we found that the drive tires on low and mid roof sleeper cab tractors on average had 10 to 17 percent higher rolling resistance than the high roof sleeper cabs. But we found only a minor difference in rolling resistance of the steer tires between the tractor subcategories. Based on comments received and further consideration of our own analysis of the difference in tire rolling resistance levels that exist today in the certification data, the agencies are adopting Phase 2 standards using a technology pathway that utilizes higher rolling resistance levels for low and mid roof tractors than the levels used to set the high roof tractor standards. This is also consistent with the approach that we took in setting the Phase 1 tractor standards. 76 FR 57211. In addition, the final rule reflects a reduction in Level 3 adoption rates for low and mid roof tractors from 25 percent in MY 2027 used at proposal (80 FR 40227) to zero percent adoption rate. The technology packages developed for the low and mid roof tractors used to determine the stringency of the MY 2027 standards in the final rule do not include any adoption rate of Level 3 drive tires to recognize the special needs of these applications, consistent with the comments noted above raising concerns about applications that limit the use of low rolling resistance tires. 
The agencies phased-in the low 
rolling resistance tire adoption rates within the technology packages used to determine the MY 2021 and 2024 standards so that manufacturers can 
gradually introduce these technologies. In addition, the levels of rolling resistance used in all of the technology packages are achievable with either dual or wide based single tires, so the agencies are not forcing one technology over another. The adoption rates for the technology packages used to determine the MY 2021, 2024, and 2027 standards for each tractor subcategory are shown in Table III–13, Table III–14, and Table III–15. 
(iii) Tire Pressure Monitoring and 
Automatic Tire Inflation System (ATIS) Adoption Rate 
The agencies used a 20 percent 
adoption rate of ATIS in MY 2021 and a 40 percent adoption rate in setting the proposed Phase 2 MY 2024 and 2027 tractor standards. 80 FR 40227. 
ATA commented that as of 2012, 
roughly one percent of tractors used ATIS. Caterpillar and First Industries stated that the agencies should not force ATIS into the market by assuming any penetration rate. EMA commented that the assumption that 40 percent of all Class 7 and 8 vehicles will utilize automated tire inflation systems lacked support and failed to account for the prevalence of tire inflation monitoring systems. NADA stated that they can support a 40 percent tractor adoption rate for MY 2027 if TPMS are considered. Volvo commented that given the poor reliability of past ATIS systems, they are skeptical of supplier’s claims of current or future reliability improvements to these systems. Volvo stated that fleets are even more skeptical than truck OEMs, as an ATIS air leak results in increased fuel consumption due to a compressor cycling more frequently and also in potentially significant downtime of the vehicle. Volvo also commented that to incentivize truck operators to maintain 
tire pressure on vehicles equipped with a TPMS system, fleets have the ability to monitor fuel consumption remotely, including the ability to identify causes for increased fuel consumption which would be expected to motivate drivers to properly maintain tire pressure on TPMS equipped vehicles. 
The agencies find the comments 
related to a greater acceptance of TPMS in the tractor market to be persuasive. However, available information indicates that it is feasible to utilize either TPMS or ATIS to reduce the prevalence on underinflated tires in-use on all tractors. As a result, we are finalizing tractor standards that are predicated on the performance of a mix of TPMS and ATIS adoption rates in all tractor subcategories. The agencies are 
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285The agencies are retaining the HD Phase 1 
AESS override provisions included in 40 CFR 
1037.660(b) for driver safety. 286North American Council for Freight 
Efficiency. Confidence Report: Idle-Reduction Solutions. 2014. Page 13. using adoption rates of 30 percent of 
ATIS and 70 percent of TPMS in the technology packages used in setting the final Phase 2 MY 2027 tractor standards. This represents a lower adoption rate of ATIS than used in the NPRM, but the agencies have added additional adoption rate of TPMS because none of the comments or available information disputed the ability to use it on all tractors. The agencies have developed technology packages for setting the 2021 and 2024 MY standards which reflect a phase in of adoption rates of each of these technologies. In 2021 MY, the adoption rates consist of 20 percent TPMS and 20 percent ATIS. In 2024 MY, the adoption rates are 50 percent TPMS and 25 percent ATIS. 
(iv) Idle Reduction Technology 
Adoption Rate 
Idle reduction technologies provide 
significant reductions in fuel consumption and CO
2emissions for 
Class 8 sleeper cabs and are available on the market today. There are several different technologies available to reduce idling. These include APUs, diesel fired heaters, and battery powered units. Our discussions with manufacturers prior to the Phase 2 NPRM indicated that idle technologies are sometimes installed in the factory, but that it is also a common practice to have the units installed after the sale of the truck. We want to continue to incentivize this practice and to do so in a manner that the emission reductions associated with idle reduction technology occur in use. We proposed to continue the Phase 1 approach into Phase 2 where we recognize only idle emission reduction technologies that include a tamper-proof automatic engine shutoff system (AESS) with some override provisions.
285However, we 
welcomed comment on other approaches that will appropriately quantify the reductions that will be experienced in the real world. 80 FR 40224. 
We used an overall 90 percent 
adoption rate of tamper-proof AESS for Class 8 sleeper cabs in setting the proposed MY 2024 and 2027 standards. Id. The agencies stated in the Phase 2 NPRM that we were unaware of reasons why AESS with extended idle reduction technologies could not be applied to this high fraction of tractors with a sleeper cab, except those deemed a vocational tractor, in the available lead time. EMA, Volvo, Daimler, and Navistar 
commented that the agencies should 
consider that customers are not accepting the tamper-proof AESS in Phase 1, therefore the adoption rates included in the proposal were too high and that resale concerns remain a significant issue for customers. PACCAR and EMA commented that the proposed 90 percent penetration rate of tamper- proof AESS is unachievable. Many comments also focused on the need for adjustable AESS. OOIDA commented that 90 percent APU adoption is unreasonable and that the 400 pound weight exemption for APUs is not provided in California, Washington DC, Hawaii, Kentucky, Massachusetts, North Carolina, and Rhode Island. OOIDA also raised concerns about situations where an AESS could have negative consequences—such as team drivers where the co-driver was left asleep in the berth while the truck was shut off, or drivers with certain medical conditions, or pets. 
The agencies find the comments 
regarding the concerns for using 90 percent adoption rates of tamper-proof 
AESS to be persuasive. For the final rule, the agencies developed a menu of idle reduction technologies that include both tamper-proof and adjustable AESS (as discussed in Section III.D.1.b) that are recognized at different levels of effectiveness in GEM. As discussed in the discussion of tractor baselines (Section III.D.1.a), the latest NACFE confidence report found that 96 percent of HD vehicles are equipped with adjustable automatic engine shutdown systems.
286Therefore, the agencies built 
this level of idle reduction into the baseline for sleeper cab tractors. Due to the high percentage acceptance of adjustable AESS today, the agencies project that by 2027 MY it is feasible for 100 percent of sleeper cabs to contain some type of AESS and idle reduction technology to meet the hoteling needs of the driver. However, we recognize that there are a variety of idle reduction technologies that meet the various needs of specific customers and not all customers will select diesel powered APUs due to the cost or weight concerns highlighted in the comments. Therefore, we developed an idle reduction technology package for each MY that reflects this variety. The idle reduction packages developed for the final rule contain lower AESS adoption rates than used at proposal. The AESS used during the NPRM assumed that it also included a diesel powered APU in terms of determining the effectiveness and costs. 
In the final rule, the idle reduction technology mix actually has an overall lower cost (even after increasing the diesel APU technology cost estimate for the final rule) than would have been developed for the final rule. In addition, the stringency of the tractor standards are not affected because the higher penetration rate of other idle reduction technologies, which are not quite as effective, but will be deployed more. We developed the technology package to set the 2027 MY sleeper cab tractor standards that includes 15 percent adoption rate of adjustable AESS only, 40 percent of adjustable AESS with a diesel powered APU, 15 percent adjustable AESS with a battery APU, 15 percent adjustable AESS with automatic stop/start, and 15 percent adjustable AESS with a fuel operated heater. We continued the same approach of phasing in different technology packages for the 2021 and 2024 MY standards, though we included some type of idle reduction on 100 percent of the sleeper cab tractors. The 2021 MY technology package had a higher adoption rate of adjustable AESS with no other idle reduction technology and lower adoption rates of adjustable AESS with other idle reduction technologies. Details on the idle reduction technology adoption rates for the MY 2021 and 2024 standards are included in Table III–13 and Table III–14. 
(v) Transmission Adoption Rates 
The agencies’ proposed standards 
included a 55, 80, and 90 percent 
adoption rate of automatic, automated manual, and dual clutch transmissions in MYs 2021, 2024, and 2027 respectively. 80 FR 40225–7. The agencies did not receive any comments regarding these proposed transmission adoption rates, and have not found any 
other information suggesting a change in approach. Therefore, we are including the same level of adoption rates in setting the final rule standards. The MY 2021 and 2024 standards are likewise premised on the same adoption rates of these transmission technologies as at proposal. 
The agencies have added neutral idle 
as a technology input to GEM for Phase 2 in the final rulemaking. The TC10 that was tested by the agencies for the final rule included this technology. Therefore, we projected that neutral idle would be included in all of the automatic transmissions and therefore the adoption rates of neutral idle match the adoption rates of the automatic transmission in each of the MYs. 
Transmissions with direct drive as the 
top gear and numerically lower axles are 
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better suited for applications with 
primarily highway driving with flat or low rolling hills. Therefore, this technology is not appropriate for use in 100 percent of tractors. The agencies proposed standards reflected the projection that 50 percent of the tractors would have direct drive in top gear in MYs 2024 and 2027. 80 FR 40226–7. The agencies did not receive any comments regarding the adoption rates of transmissions with direct drive in those MYs. We therefore are including the same level of adoption rates in setting the final rule standards for MYs 2024 and 2027. Transmissions with direct drive top gears exist in the market today, therefore, the agencies determined it is feasible to also include this technology in the package for 
setting the 2021 MY standards. For the final rule, the agencies included a 20 percent adoption rate of direct drive in the 2021 MY technology package. 
The agencies received comments 
supporting establishing a transmission efficiency test that measures the 
efficiency of each transmission gear and could be input into GEM. In the final rule, the agencies are adopting Phase 2 standards that project that 20, 40, and 70 percent of the AMT and DCT transmissions will be tested and achieve a fuel consumption and CO
2emissions 
reduction of one percent in MYs 2021, 2024, and 2027, respectively. 
The adoption rates for the technology 
packages used to determine the MY 2021, 2024, and 2027 standards for each 
tractor subcategory are shown in Table III–13, Table III–14, and Table III–15. 
(vi) Engine Downspeeding Adoption 
Rates 
The agencies proposed to include 
lower final drive ratios in setting the Phase 2 standards to account for engine downspeeding. In the NPRM, we used a transmission top gear ratio of 0.73 and baseline drive axle ratio of 3.70 in 2017 going down to a rear axle ratio of 3.55 in 2021 MY, 3.36 in 2024 MY, and 3.20 
in 2027 MY. 80 FR 40228–30. 
UCS commented that downspeeding 
was only partially captured as proposed. The agencies also received additional information from vehicle manufacturers and axle manufacturers that we believe supports using lower numerical drive axle ratios in setting the final Phase 2 standards for sleeper cabs that spend more time on the highway than day cabs, directionally consistent with the UCS comment. For the final rules, the agencies have used 3.70 in the baseline and 3.16 for sleeper cabs and 3.21 for day cabs in MY 2027 to account for continued downspeeding opportunities. The final drive ratios used for setting the other model years are shown in Table III–11. These values represent the 
‘‘average’’ tractor in each of the MYs, but there will be a range of final drive ratios that contain more aggressive engine downspeeding on some tractors and less aggressive on others. 
TABLE III–11—F INAL DRIVE RATIO FOR TRACTOR TECHNOLOGY PACKAGES  
Model year Rear axle 
ratio Transmission 
top gear 
ratio Final drive 
ratio 
Sleeper Cabs 
2018 ........................................................................................................................... .................. 3.70 0.73 2.70 
2021 ........................................................................................................................... .................. 3.31 0.73 2.42 
2024 ........................................................................................................................... .................. 3.26 0.73 2.38 
2027 ........................................................................................................................... .................. 3.16 0.73 2.31 
Day Cabs 
2018 ........................................................................................................................... .................. 3.70 0.73 2.70 
2021 ........................................................................................................................... .................. 3.36 0.73 2.45 
2024 ........................................................................................................................... .................. 3.31 0.73 2.42 
2027 ........................................................................................................................... .................. 3.21 0.73 2.34 
(vii) Drivetrain Adoption Rates 
The agencies’ proposed standards 
included 6x2 axle adoption rates in high 
roof tractors of 20 percent in 2021 MY and 60 percent in MYs 2024 and 2027. Because 6x2 axle configurations could raise concerns of traction, the agencies proposed standards that reflected lower adoption rates of 6x2 axles in low and mid roof tractors recognizing that these tractors may require some unique capabilities. The agencies proposed standards for low and mid roof tractors that included 6x2 axle adoption rates of 10 percent in MY 2021 and 20 percent in MYs 2024 and 2027. 80 FR 40225– 7. 
ATA and others commented that 
limitations to a high penetration rate of 6x2 axles include curb cuts, other uneven terrain features that could expose the truck to traction issues, lower residual values, traction issues, 
driver dissatisfaction, tire wear, and the legality of their use. The commenters stated that recent surveys indicate current market penetration rates of new line-haul 6x2 tractor sales are only in the range of two percent, according to a NACFE confidence report. The commenters also stated that while 
recent improvements in traction control systems can automatically shift weight for short periods of time from the non- driving axle to the driving axle during low-traction events, concerns remain over the impacts to highways caused by such shifting of weight between axles. EMA, ATA, OOIDA, Volvo, Daimler, PACCAR, First Industries, National Association of Manufacturers, Caterpillar, and others discussed that 6x2 axles are not legal in all U.S. states and Canadian provinces. Caterpillar and Daimler also stated the agencies should 
not assume more than 5 percent penetration rates of 6x2 through 2027. EMA forecasts a 6x2 penetration rate of less than 5 percent. 
Upon further consideration, the 
agencies have reduced the adoption rate of 6x2 axles and projected a 30 percent adoption rate in the technology package used to determine the Phase 2 2027 MY standards. The 2021 MY standards include an adoption rate of 15 percent and the 2024 MY standards include an adoption rate of 25 percent 6x2 axles. This adoption rate represents a combination of liftable 6x2 axles (which as noted in ATA’s comments are allowed in all states but Utah, and Utah is expected to revise their law) and 4x2 axles. In addition, it is worth 
recognizing that state regulations related to 6x2 axles could change significantly 
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287North American Council for Freight 
Efficiency. ‘‘Confidence Findings on the Potential of 
6x2 Axles.’’ 2014. Page 16. 288Ibid. 
288The agencies note that because a VSL value 
can be input into GEM, its benefits can be directly assessed with the model and off cycle credit 
applications therefore are not necessary even though the standard is not based on performance of 
VSLs (i.e. VSL is an on-cycle technology). over the next ten years. It is also worth 
noting that the issue related to the legality of 6x2 axles was not mentioned 
as a barrier to adoption by fleets in the NACFE Confidence Report on 6x2 axles.
287 
In the NPRM, the agencies projected 
that 20 percent of 2021 MY and 40 percent of the 2024 and 2027 MY axles would use low friction axle lubricants. 80 FR 40225–7. In the final rule, we are requiring that manufacturers conduct an axle efficiency test if they want to include the benefit of low friction lubricant or other axle design improvements when certifying in GEM. The axle efficiency test will be optional, 
but will allow manufacturers to reduce CO
2emissions and fuel consumption if 
the manufacturers have improved axle gear designs and/or mandatory use of low friction lubricants. The agencies’ assessment of axle improvements found that 80 percent of the axles built in MY 2027 could be two percent more efficient than a 2017 baseline axle. Because it will take time for axle 
manufacturers to make improvements across the majority of their product offerings, the agencies phased in the amount of axle efficiency improvements in the technology packages in setting the 2021 and 2024 MY standards to include 
30 and 65 percent adoption rates, respectively. 
(viii) Accessories and Other Technology 
Adoption Rates 
In the NPRM, the agencies projected 
adoption rates as show in Table III–12. 80 FR 40227. The agencies are adopting the same level of adoption rates for setting the final Phase 2 standards because we did not receive any comments or new data to support a change in the adoption rates used in the proposal. 
TABLE III–12—A DOPTION RATES USED IN THE TRACTOR TECHNOLOGY PACKAGES IN THE NPRM 
Model year Predictive 
cruise control 
(%) Electrified 
accessories 
(%) Higher efficiency 
air conditioning 
(%) 
2021 ......................................................................................................... 20 10 10 
2024 ......................................................................................................... 40 20 20 
2027 ......................................................................................................... 40 30 30 
(ix) Weight Reduction Technology 
Adoption Rates 
In the NPRM, the agencies proposed 
to allow manufacturers to use tractor weight reduction to comply with the standards. 80 FR 40223. A number of organizations commented generally in favor of the inclusion of light weight components for compliance, including the Aluminum Association, Meritor, American Die Casting Association, and the American Chemistry Council saying light-weight materials are durable and their use in heavy-duty vehicles can reduce weight and fuel consumption. 
Unlike in HD Phase 1, the agencies 
proposed the 2021 through 2027 model year tractor standards without using weight reduction as a technology to demonstrate the feasibility of the standards. The ICCT stated that the agencies should include light weight components in setting the stringency of the standards, citing an ICCT tractor and trailer study showing specific light weight benefits for tractor components. Meritor argued that weight reduction should not be included in setting stringency, given the high cost to benefit ratio for weight reduction. 
The agencies view weight reduction 
as a technology with a high cost that offers a small benefit in the tractor sector. For example, our estimate of a 
400 pound weight reduction will cost $2,050 (2012$) in 2021 MY, but offers a 0.3 percent reduction in fuel consumption and CO
2emissions. The 
agencies are excluding the use of weight reduction components for the tractor stringency calculation due to the high cost associated with this technology. As noted above, Meritor in their comments expressed agreement with this approach. 
(x) Vehicle Speed Limiter Adoption 
Rate 
Consistent with Phase 1, we proposed 
to continue the approach where vehicle speed limiters may be used as a technology to meet the Phase 2 standard. See 80 FR 40224. In setting the Phase 2 proposed standard, however, we assumed a zero percent adoption rate of vehicle speed limiters. Although we expect there will be some use of VSL, currently it is used when the fleet involved decides it is feasible and practicable and increases the overall efficiency of the freight system for that fleet operator. To date, the compliance data provided by manufacturers indicate that none of the tractor configurations include a tamper- proof VSL setting less than 65 mph. 
At this point the agencies are not in 
a position to determine in how many additional situations use of a VSL will result in similar benefits to overall efficiency or how many customers will be willing to accept a tamper-proof VSL setting. Although we believe vehicle speed limiters are a simple, easy to implement, and inexpensive 
technology, we want to leave the use of vehicle speed limiters to the truck purchaser. In doing so, we are providing another means of meeting the standard that can lower compliance costs and provide a more optimal vehicle solution 
for some truck fleets or owners. For example, a local beverage distributor may operate trucks in a distribution network of primarily local roads. Under those conditions, aerodynamic fairings used to reduce aerodynamic drag provide little benefit due to the low vehicle speed while adding additional mass to the vehicle. A vehicle manufacturer could choose to install a VSL set at an optimized speed for its intended application and use this technology to assist in complying with our program all at a lower cost to the ultimate tractor purchaser.
288 
We welcomed comment on whether 
the use of a VSL would require a fleet to deploy additional tractors, but did not receive responsive comment. ARB stated that if EPA and NHTSA decide to give credit in Phase 2 GEMs for VSLs, VSL benefit should also be reflected in the standard’s stringency. Daimler supported the approach of not including VSLs in setting the stringency because of the resistance in the market to accept tamperproof VSLs. OOIDA commented that the agencies must consider the significant negative consequences of VSLs, such as safety impact from 
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differential speeds between light duty 
vehicles and trucks. 
After considering the comments, we 
still could not make a determination 
regarding the reasonableness of setting a standard based on a particular VSL adoption rate, for the same reasons articulated at proposal. Therefore, the agencies are not premising these final 
Phase 2 standards on use of VSL, and instead will continue to rely on the industry to select VSL when circumstances are appropriate for its use (in which case there is an input in GEM reflecting VSL efficiency). (d) Summary of the Adoption Rates Used To Determine the Final Phase 2 Tractor Standards 
Table III–13 through Table III–16 
provide the adoption rates of each 
technology broken down by weight class, cab configuration, and roof height. 
TABLE III–13—T ECHNOLOGY ADOPTION RATES FOR CLASS 7 AND8 TRACTORS FOR DETERMINING THE 2021 MY 
STANDARDS  
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Engine 
2021 MY 
11L engine 
350 HP 2021 MY 
11L engine 
350 HP 2021 MY 
11L engine 
350 HP 2021 MY 
15L engine 
455 HP 2021 MY 
15L engine 
455 HP 2021 MY 
15L engine 
455 HP 2021 MY 
15L engine 
455 HP 2021 MY 
15L engine 
455 HP 2021 MY 
15L engine 
455 HP 
Aerodynamics 
Bin I ........................................... 10% 10% 0% 10% 10% 0% 0% 10% 0% 
Bin II .......................................... 10% 10% 0% 10% 10% 0% 20% 10% 0% 
Bin III ......................................... 70% 70% 60% 70% 70% 60% 60% 70% 60% 
Bin IV ......................................... 10% 10% 35% 10% 10% 35% 20% 10% 30% 
Bin V .......................................... 0% 0% 5% 0% 0% 5% 0% 0% 10% 
Bin VI ......................................... 0% 0% 0% 0% 0% 0% 0% 0% 0% 
Bin VII ........................................ 0% 0% 0% 0% 0% 0% 0% 0% 0% 
Steer Tires 
Base .......................................... 5% 5% 5% 5% 5% 5% 5% 5% 5% 
Level 1 ....................................... 35% 35% 35% 35% 35% 35% 35% 35% 35% 
Level 2 ....................................... 50% 50% 50% 50% 50% 50% 50% 50% 50% 
Level 3 ....................................... 10% 10% 10% 10% 10% 10% 10% 10% 10% 
Drive Tires 
Base .......................................... 15% 15% 5% 15% 15% 5% 15% 15% 5% 
Level 1 ....................................... 35% 35% 35% 35% 35% 35% 35% 35% 35% 
Level 2 ....................................... 50% 50% 50% 50% 50% 50% 50% 50% 50% 
Level 3 ....................................... 0% 0% 10% 0% 0% 10% 0% 0% 10% 
Idle Reduction 
Tamper Proof AESS ................. N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with Diesel 
APU ....................................... N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with Bat-
tery APU ................................ N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with Auto-
matic Stop-Start ..................... N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with FOH N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Adjustable AESS ....................... N/A N/A N/A N/A N/A N/A 40% 40% 40% 
Adjustable AESS with Diesel 
APU ....................................... N/A N/A N/A N/A N/A N/A 30% 30% 30% 
Adjustable AESS with Battery 
APU ....................................... N/A N/A N/A N/A N/A N/A 10% 10% 10% 
Adjustable AESS with Auto-
matic Stop-Start ..................... N/A N/A N/A N/A N/A N/A 10% 10% 10% 
Adjustable AESS with FOH ...... N/A N/A N/A N/A N/A N/A 10% 10% 10% 
Transmission 
Manual ....................................... 0% 0% 0% 0% 0% 0% 0% 0% 0% 
AMT ........................................... 40% 40% 40% 40% 40% 40% 40% 40% 40% 
Auto ........................................... 10% 10% 10% 10% 10% 10% 10% 10% 10% 
Dual Clutch ................................ 5% 5% 5% 5% 5% 5% 5% 5% 5% 
Top Gear Direct Drive ............... 20% 20% 20% 20% 20% 20% 20% 20% 20% 
Trans. Efficiency ........................ 20% 20% 20% 20% 20% 20% 20% 20% 20% 
Neutral Idle ................................ 10% 10% 10% 10% 10% 10% 10% 10% 10% 
Driveline 
Axle Efficiency ........................... 30% 30% 30% 30% 30% 30% 30% 30% 30% 
6x2, 6x4 Axle Disconnect or 
4x2 Axle ................................. N/A N/A N/A 15% 15% 15% 15% 15% 15% 
Downspeed (Rear Axle Ratio) .. 3.36 3.36 3.36 3.36 3.36 3.36 3.31 3.31 3.31 
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TABLE III–13—T ECHNOLOGY ADOPTION RATES FOR CLASS 7 AND8 TRACTORS FOR DETERMINING THE 2021 MY 
STANDARDS —Continued 
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Accessory Improvements 
A/C Efficiency ............................ 10% 10% 10% 10% 10% 10% 10% 10% 10% 
Electric Access .......................... 10% 10% 10% 10% 10% 10% 10% 10% 10% 
Other Technologies 
Predictive Cruise Control .......... 20% 20% 20% 20% 20% 20% 20% 20% 20% 
Automated Tire Inflation System 20% 20% 20% 20% 20% 20% 20% 20% 20% 
Tire Pressure Monitoring Sys-
tem ......................................... 20% 20% 20% 20% 20% 20% 20% 20% 20% 
Neutral Coast ............................ 0% 0% 0% 0% 0% 0% 0% 0% 0% 
TABLE III–14—T ECHNOLOGY ADOPTION RATES FOR CLASS 7 AND8 TRACTORS FOR DETERMINING THE 2024 MY 
STANDARDS  
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Engine 
2024 MY 
11L engine 
350 HP 2024 MY 
11L engine 
350 HP 2024 MY 
11L engine 
350 HP 2024 MY 
15L engine 
455 HP 2024 MY 
15L engine 
455 HP 2024 MY 
15L engine 
455 HP 2024 MY 
15L engine 
455 HP 2024 MY 
15L engine 
455 HP 2024 MY 
15L engine 
455 HP 
Aerodynamics 
Bin I ........................................... 0% 0% 0% 0% 0% 0% 0% 0% 0% 
Bin II .......................................... 20% 20% 0% 20% 20% 0% 20% 20% 0% 
Bin III ......................................... 60% 60% 40% 60% 60% 40% 60% 60% 40% 
Bin IV ......................................... 20% 20% 40% 20% 20% 40% 20% 20% 40% 
Bin V .......................................... 0% 0% 20% 0% 0% 20% 0% 0% 20% 
Bin VI ......................................... 0% 0% 0% 0% 0% 0% 0% 0% 0% 
Bin VII ........................................ 0% 0% 0% 0% 0% 0% 0% 0% 0% 
Steer Tires 
Base .......................................... 5% 5% 5% 5% 5% 5% 5% 5% 5% 
Level 1 ....................................... 25% 25% 15% 25% 25% 15% 25% 25% 15% 
Level 2 ....................................... 55% 55% 60% 55% 55% 60% 55% 55% 60% 
Level 3 ....................................... 15% 15% 20% 15% 15% 20% 15% 15% 20% 
Drive Tires 
Base .......................................... 10% 10% 5% 10% 10% 5% 10% 10% 5% 
Level 1 ....................................... 25% 25% 15% 25% 25% 15% 25% 25% 15% 
Level 2 ....................................... 65% 65% 60% 65% 65% 60% 65% 65% 60% 
Level 3 ....................................... 0% 0% 20% 0% 0% 20% 0% 0% 20% 
Idle Reduction 
Tamper Proof AESS ................. N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with Diesel 
APU ....................................... N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with Bat-
tery APU ................................ N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with Auto-
matic Stop-Start ..................... N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with FOH N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Adjustable AESS ....................... N/A N/A N/A N/A N/A N/A 30% 30% 30% 
Adjustable AESS with Diesel 
APU ....................................... N/A N/A N/A N/A N/A N/A 40% 40% 40% 
Adjustable AESS with Battery 
APU ....................................... N/A N/A N/A N/A N/A N/A 10% 10% 10% 
Adjustable AESS with Auto-
matic Stop-Start ..................... N/A N/A N/A N/A N/A N/A 10% 10% 10% 
Adjustable AESS with FOH ...... N/A N/A N/A N/A N/A N/A 10% 10% 10% 
Transmission 
Manual ....................................... 0% 0% 0% 0% 0% 0% 0% 0% 0% 
AMT ........................................... 50% 50% 50% 50% 50% 50% 50% 50% 50% 
Auto ........................................... 20% 20% 20% 20% 20% 20% 20% 20% 20% 
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TABLE III–14—T ECHNOLOGY ADOPTION RATES FOR CLASS 7 AND8 TRACTORS FOR DETERMINING THE 2024 MY 
STANDARDS —Continued 
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Dual Clutch ................................ 10% 10% 10% 10% 10% 10% 10% 10% 10% 
Top Gear Direct Drive ............... 50% 50% 50% 50% 50% 50% 50% 50% 50% 
Trans. Efficiency ........................ 40% 40% 40% 40% 40% 40% 40% 40% 40% 
Neutral Idle ................................ 20% 20% 20% 20% 20% 20% 20% 20% 20% 
Driveline 
Axle Efficiency ........................... 65% 65% 65% 65% 65% 65% 65% 65% 65% 
6x2, 6x4 Axle Disconnect or 
4x2 Axle ................................. N/A N/A N/A 25% 25% 25% 25% 25% 25% 
Downspeed (Rear Axle Ratio) .. 3.31 3.31 3.31 3.31 3.31 3.31 3.26 3.26 3.26 
Accessory Improvements 
A/C Efficiency ............................ 20% 20% 20% 20% 20% 20% 20% 20% 20% 
Electric Access. ......................... 20% 20% 20% 20% 20% 20% 20% 20% 20% 
Other Technologies 
Predictive Cruise Control .......... 40% 40% 40% 40% 40% 40% 40% 40% 40% 
Automated Tire Inflation System 25% 25% 25% 25% 25% 25% 25% 25% 25% 
Tire Pressure Monitoring Sys-
tem ......................................... 50% 50% 50% 50% 50% 50% 50% 50% 50% 
Neutral Coast ............................ 0% 0% 0% 0% 0% 0% 0% 0% 0% 
TABLE III–15—T ECHNOLOGY ADOPTION RATES FOR CLASS 7 AND8 TRACTORS FOR DETERMINING THE 2027 MY 
STANDARDS  
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Engine 
2027 MY 
11L Engine 
350 HP 2027 MY 
11L Engine 
350 HP 2027 MY 
11L Engine 
350 HP 2027 MY 
15L Engine 
455 HP 2027 MY 
15L Engine 
455 HP 2027 MY 
15L Engine 
455 HP 2027 MY 
15L Engine 
455 HP 2027 MY 
15L Engine 
455 HP 2027 MY 
15L Engine 
455 HP 
Aerodynamics 
Bin I ........................................... 0% 0% 0% 0% 0% 0% 0% 0% 0% 
Bin II .......................................... 20% 20% 0% 20% 20% 0% 20% 20% 0% 
Bin III ......................................... 50% 50% 30% 50% 60% 30% 40% 50% 20% 
Bin IV ......................................... 30% 30% 30% 30% 20% 30% 40% 30% 30% 
Bin V .......................................... 0% 0% 40% 0% 0% 40% 0% 0% 50% 
Bin VI ......................................... 0% 0% 0% 0% 0% 0% 0% 0% 0% 
Bin VII ........................................ 0% 0% 0% 0% 0% 0% 0% 0% 0% 
Steer Tires 
Base .......................................... 5% 5% 5% 5% 5% 5% 5% 5% 5% 
Level 1 ....................................... 20% 20% 10% 20% 20% 10% 20% 20% 10% 
Level 2 ....................................... 50% 50% 50% 50% 50% 50% 50% 50% 50% 
Level 3 ....................................... 25% 25% 35% 25% 25% 35% 25% 25% 35% 
Drive Tires 
Base .......................................... 5% 5% 5% 5% 5% 5% 5% 5% 5% 
Level 1 ....................................... 10% 10% 10% 10% 10% 10% 10% 10% 10% 
Level 2 ....................................... 85% 85% 50% 85% 85% 50% 85% 85% 50% 
Level 3 ....................................... 0% 0% 35% 0% 0% 35% 0% 0% 35% 
Idle Reduction 
Tamper Proof AESS ................. N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with Diesel 
APU ....................................... N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with Bat-
tery APU ................................ N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with Auto-
matic Stop-Start ..................... N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Tamper Proof AESS with FOH N/A N/A N/A N/A N/A N/A 0% 0% 0% 
Adjustable AESS ....................... N/A N/A N/A N/A N/A N/A 15% 15% 15% 
Adjustable AESS with Diesel 
APU ....................................... N/A N/A N/A N/A N/A N/A 40% 40% 40% 
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289Since aerodynamic improvements are not part 
of the technology package, the agencies likewise are 
not adopting any aero bin structure for the heavy- haul tractor subcategory. TABLE III–15—T ECHNOLOGY ADOPTION RATES FOR CLASS 7 AND8 TRACTORS FOR DETERMINING THE 2027 MY 
STANDARDS —Continued 
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Engine 
Adjustable AESS with Battery 
APU ....................................... N/A N/A N/A N/A N/A N/A 15% 15% 15% 
Adjustable AESS with Auto-
matic Stop-Start ..................... N/A N/A N/A N/A N/A N/A 15% 15% 15% 
Adjustable AESS with FOH ...... N/A N/A N/A N/A N/A N/A 15% 15% 15% 
Transmission 
Manual ....................................... 0% 0% 0% 0% 0% 0% 0% 0% 0% 
AMT ........................................... 50% 50% 50% 50% 50% 50% 50% 50% 50% 
Auto ........................................... 30% 30% 30% 30% 30% 30% 30% 30% 30% 
Dual Clutch ................................ 10% 10% 10% 10% 10% 10% 10% 10% 10% 
Top Gear Direct Drive ............... 50% 50% 50% 50% 50% 50% 50% 50% 50% 
Trans. Efficiency ........................ 70% 70% 70% 70% 70% 70% 70% 70% 70% 
Neutral Idle ................................ 30% 30% 30% 30% 30% 30% 30% 30% 30% 
Driveline 
Axle Efficiency ........................... 80% 80% 80% 80% 80% 80% 80% 80% 80% 
6×2, 6×4 Axle Disconnect or 
4×2 Axle ................................. N/A N/A N/A 30% 30% 30% 30% 30% 30% 
Downspeed (Rear Axle Ratio) .. 3.21 3.21 3.21 3.21 3.21 3.21 3.16 3.16 3.16 
Accessory Improvements 
A/C Efficiency ............................ 30% 30% 30% 30% 30% 30% 30% 30% 30% 
Electric Access .......................... 30% 30% 30% 30% 30% 30% 30% 30% 30% 
Other Technologies 
Predictive Cruise Control .......... 40% 40% 40% 40% 40% 40% 40% 40% 40% 
Automated Tire Inflation System 30% 30% 30% 30% 30% 30% 30% 30% 30% 
Tire Pressure Monitoring Sys-
tem ......................................... 70% 70% 70% 70% 70% 70% 70% 70% 70% 
Neutral Coast ............................ 0% 0% 0% 0% 0% 0% 0% 0% 0% 
(e) Adoption Rates Used To Set the 
Heavy-Haul Tractor Standards 
The agencies recognize that certain 
technologies used to determine the stringency of the Phase 2 tractor standards are less applicable to heavy- haul tractors. Heavy-haul tractors are not typically used in the same manner as long-haul tractors with extended highway driving, and therefore will experience less benefit from aerodynamics. Aerodynamic technologies are very effective at 
reducing the fuel consumption and GHG emissions of tractors, but only when traveling at highway speeds. At lower speeds, the aerodynamic technologies may have a detrimental impact due to the potential of added weight. The agencies therefore proposed not considering the use of aerodynamic technologies in the development of the Phase 2 heavy-haul tractor standards. Moreover, because aerodynamics will not play a role in the heavy-haul standards, the agencies proposed to combine all of the heavy-haul tractor cab configurations (day and sleeper) and roof heights (low, mid, and high) into a single heavy-haul tractor subcategory. We welcomed comment on this approach. 80 FR 40233. 
The agencies received comments 
regarding the applicability of aerodynamic technologies on heavy- haul vehicles. Daimler commented that heavy-haul vehicles are designed to meet high cooling needs, therefore have large radiators and grilles, and are not designed primarily for hauling standard trailers on the highway. Daimler also stated that these vehicles are designed to operate off-road or on difficult terrain, which also limits the application of aerodynamic fairings, and that requiring aerodynamic improvements on these vehicles, may compromise the vehicles’ work. EMA supported the agencies’ proposed approach of not requiring the use of aerodynamic technologies as a component of the proposed Phase 2 heavy-haul tractor standards. EMA stated that those vehicles are already quite heavy (by virtue of need), are designed to meet high-cooling needs (thus having, for example, large grilles), and generally are not designed for hauling standard trailers on highways. 
EMA also stated that those vehicles are often designed to be capable of operation off-road or on difficult terrain. Volvo supported the addition of a heavy-haul subcategory since heavy- haul tractors require large engines and 
increased cooling capacity that limits aerodynamic improvements. Volvo also stated the most heavy-haul rigs have some requirement for off-road access to pick up machinery, bulk goods, and unusual loads that also inhibit aerodynamic improvements. These comments largely echo the agencies’ own concerns voiced at proposal. After considering these comments, the agencies are using a technology package that does not use aerodynamic improvements in setting the Phase 2 heavy-haul tractor standards, as we proposed.
289 
Certain powertrain and drivetrain 
components are also impacted during the design of a heavy-haul tractor, 
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including the transmission, axles, and 
the engine. Heavy-haul tractors typically require transmissions with 13 or 18 speeds to provide the ratio spread to ensure that the tractor is able to start pulling the load from a stop. Downspeed powertrains are typically not an option for heavy-haul operations because these vehicles require more torque to move the vehicle because of 
the heavier load. Finally, due to the loading requirements of the vehicle, it is not likely that a 6x2 axle configuration can be used in heavy-haul applications. We requested comments on all aspects of our heavy-haul tractor technology packages. 80 FR 40233. 
We received comments from 
stakeholders about the application of technologies other than aerodynamics for heavy-haul tractors. Daimler commented that the low rolling resistance levels in the NPRM are overly aggressive because heavy-haul tractors 
require unusually high traction and stopping power. Daimler agreed with the agencies’ assessment in the NPRM that did not include weight reduction because these vehicles require strong frames and axles to carry heavy loads. Volvo commented that heavy-haul tractors would not likely be able to utilize current SmartWay tires; would see no benefit from predictive cruise; sometimes utilize an auxiliary transmission for further reduction or closer ratios; and nearly all heavy-haul tractors have deeper drive axle ratios than the agencies assumed in the NPRM. After considering these comments and the information 
regarding the tire rolling resistance improvement opportunities, discussed in Section III.D.1.b.iii, the agencies have adjusted the adoption rate of low rolling resistance tires. Consistent with the changes made in the final rule for the 
adoption of low rolling resistance tires in low and mid roof tractors, the agencies did not project any adoption of Level 3 tires for heavy-haul tractors in the final rule. 
Allison commented that AMTs in the 
NPRM receive a 1.8 percent credit in GEM for heavy-haul tractors, yet there is no similar credit for ATs. Allison commented that since ATs offer similar, if not greater, benefits, they should also receive credit and that neutral-idle recognition should be available. The final version of Phase 2 GEM treats ATs and AMTs the same for heavy-haul tractors as for the other tractors. 
The agencies used the following 
heavy-haul tractor adoption rates for developing the final Phase 2 2021, 2024, and 2027 MY standards, as shown in Table III–16. 
TABLE III–16—A PPLICATION RATES FOR HEAVY -HAULTRACTOR STANDARDS  
[Heavy-haul tractor application rates] 
Engine 2021 MY 2024 MY 2027 MY 
2021 MY 15L engine 
with 600 HP with 2% 
reduction over 2018 MY 2024 MY 15L engine 
with 600 HP with 4.2% 
reduction over 2018 MY 2027 MY 15L engine 
with 600 HP with 5.4% 
reduction over 2018 MY 
Aerodynamics—0% 
Steer Tires 
Phase 1 Baseline: 15% 10% 5% 
Level I ................................................................................... 35% 30% 10% 
Level 2 .................................................................................. 50% 60% 85% 
Level 3 .................................................................................. 0% 0% 0% 
Drive Tires 
Phase 1 Baseline: 15% 10% 5% 
Level I ................................................................................... 35% 30% 10% 
Level 2 .................................................................................. 50% 60% 85% 
Level 3 .................................................................................. 0% 0% 0% 
Transmission 
AMT ............................................................................................. 40% 50% 50% 
Automatic with Neutral Idle .......................................................... 10% 20% 20% 
DCT .............................................................................................. 5% 10% 10% 
Other Technologies 
6×2 Axle ....................................................................................... 0% 0% 0% 
Transmission Efficiency ............................................................... 20% 40% 70% 
Axle Efficiency ............................................................................. 30% 65% 80% 
Predictive Cruise Control ............................................................. 20% 40% 40% 
Accessory Improvements ............................................................ 10% 20% 20% 
Air Conditioner Efficiency Improvements .................................... 10% 20% 20% 
Automatic Tire Inflation Systems ................................................. 20% 25% 30% 
Tire Pressure Monitoring System ................................................ 20% 50% 70% 
The agencies are also adopting in 
Phase 2 provisions that allow the 
manufacturers to meet an optional heavy Class 8 tractor standard that reflects both aerodynamic improvements, along with the powertrain requirements that go along with higher GCWR. Table III–17 reflects the adoption rates for each of the technologies for each of the subcategories in MY 2021. The technology packages closely reflect those in the primary Class 8 tractor program. The exceptions include less aggressive targets for low rolling 
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resistance tires, no 6x2 axle adoption rates, and no downspeeding due to the 
heavier loads of these vehicles. 
TABLE III–17—A DOPTION RATES USEDTODEVELOP THE 2021 MY O PTIONAL HEAVY CLASS 8 TRACTOR STANDARDS  
[Optional heavy class 8 tractor application rates—2021 MY] 
Engine Low/mid roof 
day cab High roof day 
cab Low/mid roof 
sleeper cab High roof 
sleeper cab 
2021 MY 
15L Engine 
with 600 HP 2021 MY 
15L Engine 
with 600 HP 2021 MY 
15L Engine 
with 600 HP 2021 MY 
15L Engine 
with 600 HP 
Aerodynamics 
Bin I .................................................................................................................. 10% 0% 10% 0% 
Bin II ................................................................................................................. 10% 0% 10% 0% 
Bin III ................................................................................................................ 70% 60% 70% 60% 
Bin IV ............................................................................................................... 10% 35% 10% 30% 
Bin V ................................................................................................................ 0% 5% 0% 1 0% 
Bin VI ............................................................................................................... 0% 0% 0% 0 % 
Bin VII .............................................................................................................. 0% 0% 0% 0 % 
Steer Tires 
Phase 1 Baseline 10% 5% 10% 5% 
Level I .............................................................................................................. 25% 35% 25% 35% 
Level 2 ............................................................................................................. 65% 60% 65% 60% 
Level 3 ............................................................................................................. 0% 0% 0% 0%  
Drive Tires 
Phase 1 Baseline 20% 10% 20% 10% 
Level I .............................................................................................................. 40% 30% 40% 30% 
Level 2 ............................................................................................................. 40% 60% 40% 60% 
Level 3 ............................................................................................................. 0% 0% 0% 0%  
Transmission 
AMT ................................................................................................................. 40% 40% 40%  40% 
Automatic with Neutral Idle .............................................................................. 10% 10% 10% 10% 
DCT .................................................................................................................. 5% 5% 5% 5 % 
Other Technologies 
Adjustable AESS w/Diesel APU ...................................................................... N/A N/A 30% 30% 
Adjustable AESS w/Battery APU ..................................................................... N/A N/A 10% 10% 
Adjustable AESS w/Automatic Stop-Start ....................................................... N/A N/A 10% 10% 
Adjustable AESS w/FOH Cold, Main Engine Warm ....................................... N/A N/A 10% 10% 
Adjustable AESS programmed to 5 minutes ................................................... N/A N/A 40% 40% 
Transmission Efficiency ................................................................................... 20% 20% 20% 20% 
Axle Efficiency ................................................................................................. 30% 30% 30% 30% 
Predictive Cruise Control ................................................................................. 20% 20% 20% 20% 
Accessory Improvements ................................................................................ 10% 10% 10% 10% 
Air Conditioner Efficiency Improvements ......................................................... 10% 10% 10% 10% 
Automatic Tire Inflation Systems ..................................................................... 20% 20% 20% 20% 
Tire Pressure Monitoring System .................................................................... 20% 20% 20% 20% 
(f) Derivation of the Final Phase 2 
Tractor Standards 
The agencies used the technology 
effectiveness inputs and technology adoption rates to develop GEM inputs to derive the HD Phase 2 fuel consumption and CO
2emissions standards for each 
subcategory of Class 7 and 8 combination tractors. Note that we have analyzed one technology pathway for 
each level of stringency, but 
manufacturers will be free to use any combination of technology to meet the standards, as well as the flexibility of 
averaging, banking and trading, to meet the standard on average. The agencies derived a scenario tractor for each subcategory by weighting the individual GEM input parameters included in Table III–7 with the adoption rates in Table III–8 through Table III–10. For example, the C
dA value for a 2021 MY 
Class 8 Sleeper Cab High Roof scenario case was derived as 60 percent times 5.95 plus 30 percent times 5.40 plus 10 
percent times 4.90, which is equal to a C
dA of 5.68 m2. Similar calculations 
were made for tire rolling resistance, 
transmission types, idle reduction, and other technologies. The agencies developed fuel maps that achieved the CO
2emissions and fuel consumption 
reductions described in Section III.D.1.b. The agencies then ran GEM with a single set of vehicle inputs, as shown in Table III–18 through Table III– 21, to derive the final standards for each subcategory. Additional detail is 
provided in the RIA Chapter 2.8.4. 
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TABLE III–18—GEM I NPUTS FOR THE 2021 MY C LASS 7 AND8 TRACTOR STANDARD SETTING  
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Engine 
2021 MY 11L 
Engine 350 
HP 2021 MY 11L 
Engine 350 
HP 2021 MY 11L 
Engine 350 
HP 2021 MY 15L 
Engine 455 
HP 2021 MY 15L 
Engine 455 
HP 2021 MY 15L 
Engine 455 
HP 2021 MY 15L 
Engine 455 
HP 2021 MY 15L 
Engine 455 
HP 2021 MY 15L 
Engine 455 
HP 
Aerodynamics (C dA in m2) 
5.24 6.33 6.01 5.24 6.33 6.01 5.24 6.33 5.68 
Steer Tires (CRR in kg/metric ton) 
6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0 
Drive Tires (CRR in kg/metric ton) 
6.6 6.6 6.3 6.6 6.6 6.3 6.6 6.6 6.3 
Extended Idle Reduction Weighted Effectiveness 
N/A N/A N/A N/A N/A N/A 2.3% 2.3% 2.3% 
Transmission = 10 speed Manual Transmission 
Gear Ratios = 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73 
Drive Axle Ratio = 3.36 for day cabs, 3.31 for sleeper cabs 
6x2 Axle Weighted Effectiveness 
N/A N/A N/A 0.3% 0.3% 0.3% 0.3% 0.3% 0.3% 
Transmission Type Weighted Effectiveness = 1.1% 
Neutral Idle Weighted Effectiveness 
0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.02% 0.02% 0.02% 
Direct Drive Weighted Effectiveness = 0.4% 
Transmission Efficiency Weighted Effectiveness = 0.2% 
Axle Efficiency Improvement = 0.6% 
Air Conditioner Efficiency Improvements = 0.1% 
Accessory Improvements = 0.1% 
Predictive Cruise Control = 0.4% 
Automatic Tire Inflation Systems = 0.3% 
Tire Pressure Monitoring System = 0.2% 
Phase 1 Credit Carry-over = 1% 
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TABLE III–19—GEM I NPUTS FOR THE 2024 MY C LASS 7 AND8 TRACTOR STANDARD SETTING  
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Engine 
2024 MY 11L 
Engine 350 
HP 2024 MY 11L 
Engine 350 
HP 2024 MY 11L 
Engine 350 
HP 2024 MY 15L 
Engine 455 
HP 2024 MY 15L 
Engine 455 
HP 2024 MY 15L 
Engine 455 
HP 2024 MY 15L 
Engine 455 
HP 2024 MY 15L 
Engine 455 
HP 2024 MY 15L 
Engine 455 
HP 
Aerodynamics (C dA in m2) 
5.16 6.25 5.82 5.16 6.25 5.82 5.16 6.25 5.52 
Steer Tires (CRR in kg/metric ton) 
5.9 5.9 5.8 5.9 5.9 5.8 5.9 5.9 5.8 
Drive Tires (CRR in kg/metric ton) 
6.4 6.4 6.0 6.4 6.4 6.0 6.4 6.4 6.0 
Extended Idle Reduction Weighted Effectiveness 
N/A N/A N/A N/A N/A N/A 2.5% 2.5% 2.5% 
Transmission = 10 speed Manual Transmission 
Gear Ratios = 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73 
Drive Axle Ratio = 3.31 for day cabs, 3.26 for sleeper cabs 
6x2 Axle Weighted Effectiveness 
N/A N/A N/A 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 
Transmission Type Weighted Effectiveness = 1.6% 
Neutral Idle Weighted Effectiveness 
0.2% 0.2% 0.2% 0.2% 0.2% 0.2% 0.03% 0.03% 0.03% 
Direct Drive Weighted Effectiveness = 1.0% 
Transmission Efficiency Weighted Effectiveness = 0.4% 
Axle Efficiency Improvement = 1.3% 
Air Conditioner Efficiency Improvements = 0.1% 
Accessory Improvements = 0.2% 
Predictive Cruise Control = 0.8% 
Automatic Tire Inflation 
Tire Pressure Monitoring System = 0.5% 
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TABLE III–20—GEM I NPUTS FOR THE 2027 MY C LASS 7 AND8 TRACTOR STANDARD SETTING  
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof 
Engine 
2027 MY 11L 
Engine 350 
HP 2027 MY 11L 
Engine 350 
HP 2027 MY 11L 
Engine 350 
HP 2027 MY 15L 
Engine 455 
HP 2027 MY 15L 
Engine 455 
HP 2027 MY 15L 
Engine 455 
HP 2027 MY 15L 
Engine 455 
HP 2027 MY 15L 
Engine 455 
HP 2027 MY 15L 
Engine 455 
HP 
Aerodynamics (C dA in m2) 
5.12 6.21 5.67 5.12 6.21 5.67 5.08 6.21 5.26 
Steer Tires (CRR in kg/metric ton) 
5.8 5.8 5.6 5.8 5.8 5.6 5.8 5.8 5.6 
Drive Tires (CRR in kg/metric ton) 
6.2 6.2 5.8 6.2 6.2 5.8 6.2 6.2 5.8 
Extended Idle Reduction Weighted Effectiveness 
N/A N/A N/A N/A N/A N/A 3% 3% 3% 
Transmission = 10 speed Manual Transmission 
Gear Ratios = 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73 
Drive Axle Ratio = 3.21 for day cabs, 3.16 for sleeper cabs 
6x2 Axle Weighted Effectiveness 
N/A N/A N/A 0.6% 0.6% 0.6% 0.6% 0.6% 0.6% 
Transmission Type Weighted Effectiveness = 1.6% 
Neutral Idle Weighted Effectiveness 
0.2% 0.2% 0.2% 0.2% 0.2% 0.2% 0.03% 0.03% 0.03% 
Direct Drive Weighted Effectiveness = 1.0% 
Transmission Efficiency Weighted Effectiveness = 0.7% 
Axle Efficiency Improvement = 1.6% 
Air Conditioner Efficiency Improvements = 0.3% 
Accessory Improvements = 0.2% 
Predictive Cruise Control = 0.8% 
Automatic Tire Inflation Systems = 0.4% 
Tire Pressure Monitoring System = 0.7% 
TABLE III–21—GEM I NPUTS FOR 2021, 2024 AND2027 MY H EAVY -HAULTRACTOR STANDARDS  
2021 MY 2024 MY 2027 MY 
Engine = 2021 MY 15L Engine with 600 HP ..... Engine = 2024 MY 15L Engine with 600 HP .. Engine = 2027 MY 15L Engine with 600 HP. 
Aerodynamics (C dA in m2) = 5.00 
Steer Tires (CRR in kg/metric ton) = 6.2 ........... Steer Tires (CRR in kg/metric ton) = 6.0 ......... Steer Tires (CRR in kg/metric ton) = 5.8. 
Drive Tires (CRR in kg/metric ton) = 6.6 ........... Drive Tires (CRR in kg/metric ton) = 6.4 ......... Drive Tires (CRR in kg/metric ton) = 6.2. 
Transmission = 18 speed Manual Transmission Transmission = 18 speed Manual Trans-
mission.Transmission = 18 speed Manual Trans-
mission. 
Drive axle Ratio = 3.70 ...................................... Drive axle Ratio = 3.70 .................................... Drive axle Ratio = 3.70. 
6x2 Axle Weighted Effectiveness = 0% ............. 6x2 Axle Weighted Effectiveness = 0% .......... 6x2 Axle Weighted Effectiveness = 0%. 
Transmission benefit = 1.1% .............................. Transmission benefit = 1.8% ........................... Transmission benefit = 1.8%. 
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TABLE III–21—GEM I NPUTS FOR 2021, 2024 AND2027 MY H EAVY -HAULTRACTOR STANDARDS —Continued 
2021 MY 2024 MY 2027 MY 
Transmission Efficiency = 0.2% ......................... Transmission Efficiency = 0.4% ...................... Transmission Efficiency = 0.7%. 
Axle Efficiency = 0.3% ....................................... Axle Efficiency = 0.7% ..................................... Axle Efficiency = 1.6%. 
Predictive Cruise Control = 0.4% ....................... Predictive Cruise Control = 0.8% .................... Predictive Cruise Control = 0.8%. 
Accessory Improvements = 0.1% ...................... Accessory Improvements = 0.2% .................... Accessory Improvements = 0. 3%. 
Air Conditioner Efficiency Improvements = 0.1% Air Conditioner Efficiency Improvements = 
0.1%.Air Conditioner Efficiency Improvements = 
0.2%. 
Automatic Tire Inflation Systems = 0.3% ........... Automatic Tire Inflation Systems = 0.3% ........ Automatic Tire Inflation Systems = 0.4%. 
Tire Pressure Monitoring System = 0.2% .......... Tire Pressure Monitoring System = 0.5% ....... Tire Pressure Monitoring System = 0.7%. 
The agencies ran GEM with a single 
set of vehicle inputs, as shown in Table 
III–22, to derive the optional standards for each subcategory of the Heavy Class 
8 tractors (see Section III.C.(4)(a)). 
TABLE III–22—GEM I NPUTS FOR 2021 MY O PTIONAL HEAVY CLASS 8 TRACTOR STANDARDS  
[Heavy Class 8 GEM inputs for 2021 MY] 
Day cab Sleeper cab 
Low roof Mid roof High roof Low roof Mid roof High roof 
2021 MY 15L Engine 600 HP 
Aerodynamics (CdA in m2) 
5.2 6.3 6.0 5.2 6.3 5.7 
Steer Tires (CRR in kg/metric ton) 
6.1 6.1 6.1 6.1 6.1 6.1 
Drive Tires (CRR in kg/metric ton) 
6.8 6.8 6.5 6.8 6.8 6.5 
Extended Idle Reduction Weighted Effectiveness 
N/A N/A N/A 2.3% 2.3% 2.3% 
Transmission = 18 speed Manual Transmission 
Drive Axle Ratio = 3.73 
Transmission Type Weighted Effectiveness = 1.1% 
Neutral Idle Weighted Effectiveness 
0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 
Direct Drive Weighted Effectiveness = 0.4% 
Transmission Efficiency Weighted Effectiveness = 0.2% 
Axle Efficiency Improvement = 0.6% 
Air Conditioner Efficiency Improvements = 0.1% 
Accessory Improvements = 0.1% 
Predictive Cruise Control = 0.4% 
Automatic Tire Inflation Systems = 0.3% 
Tire Pressure Monitoring System = 0.2% 
The level of the final Phase 2 2027 
model year standards, and the phase-in 
standards in model years 2021 and 2024 for each subcategory, is shown in Table 
III–23. 
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TABLE III–23—F INAL PHASE 2 2021, 2024, AND2027 M ODEL YEARTRACTOR STANDARDS  
Day cab Sleeper cab Heavy-haul 
Class 7 Class 8 Class 8 Class 8 
2021 Model Year CO 2Grams per Ton-Mile 
Low Roof .......................................................................................................... 105.5 80.5 72.3 52.4 
Mid Roof .......................................................................................................... 113.2 85.4 78.0 
High Roof ......................................................................................................... 113.5 85.6 75.7 
2021 Model Year Gallons of Fuel per 1,000 Ton-Mile 
Low Roof .......................................................................................................... 10.36346 7.90 766 7.10216 5.14735 
Mid Roof .......................................................................................................... 11.11984 8.38 900 7.66208 
High Roof ......................................................................................................... 11.14931 8.40 864 7.43615 
2024 Model Year CO 2Grams per Ton-Mile 
Low Roof .......................................................................................................... 99.8 76.2 68.0 50.2 
Mid Roof .......................................................................................................... 107.1 80.9 73.5 
High Roof ......................................................................................................... 106.6 80.4 70.7 
2024 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile 
Low Roof .......................................................................................................... 9.80354 7.485 27 6.67976 4.93124 
Mid Roof .......................................................................................................... 10.52063 7.94 695 7.22004 
High Roof ......................................................................................................... 10.47151 7.89 784 6.94499 
2027 Model Year CO 2Grams per Ton-Milea 
Low Roof .......................................................................................................... 96.2 73.4 64.1 48.3 
Mid Roof .......................................................................................................... 103.4 78.0 69.6 
High Roof ......................................................................................................... 100.0 75.7 64.3 
2027 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile 
Low Roof .......................................................................................................... 9.44990 7.210 22 6.29666 4.74460 
Mid Roof .......................................................................................................... 10.15717 7.66 208 6.83694 
High Roof ......................................................................................................... 9.82318 7.436 15 6.31631 
Note: 
aThe 2027 MY high roof tractor standards include a 0.3 m2reduction in C dA as described in Section III.E.2.a.vii. 
The level of the Phase 2 2027 model 
year optional Heavy Class 8 standards is 
shown in Table III–24. 
TABLE III–24—P HASE 2 OPTIONAL HEAVY CLASS 8 STANDARDS  
[Optional heavy Class 8 tractor standards] 
Low roof day cab Mid roof day cab High roof day cab Low roof sleeper cab Mid roof sleeper cab High roof sleeper cab 
2021 Model Year CO 2Standards (Grams per Ton-Mile) 
51.8 54.1 54.1 45.3 47.9 46.9 
2021 MY and Later Fuel Consumption (Gallons of Fuel per 1,000 Ton-Mile) 
5.08841 5.31434 5.31434 4.44990 4.70530 4.60707 
(g) Technology Costs of the Final Phase 
2 Tractor Standards 
A summary of the technology package 
costs is included in Table III–15 through Table III–17 for MYs 2021, 2024, and 2027, respectively, with additional details available in the RIA Chapter 2.12. 
The agencies received several 
comments related to the APU, tire, and aerodynamic technology costs used by 
the agencies at proposal. As noted in Section III.C.3 above, ATA, First Industries, and Daimler commented that APU costs are substantially higher than the figures in the proposal. PACCAR commented that the cost of a diesel or battery-based APU is $8,570 to $11,263. EMA commented that the direct per- chassis cost of a diesel APU is approximately $8,500–$10,100 and approximately $11,300 for battery/ electric APUs. Volvo commented that APU prices can vary between $9,500 and $11,000 depending on the type. Schneider commented that an electronic APU will have an initial cost of at least $5,000 and engine powered APUs are 2 to 3 times the electric costs. 
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290U.S. DOT/NHTSA. Commercial Medium- and 
Heavy-Duty Truck Fuel Efficiency Technology Cost 
Study. May 2015. Page 71. 291Truckinginfo. TMC Survey Reveals 
Misinformed View of Fuel-Efficient Tires. March 2015. 292North American Council for Freight 
Efficiency. Confidence Findings on the Potential of 6x2 Axles. 2014. EPA considered the comments and 
more closely evaluated NHTSA’s 
contracted TetraTech cost report found the retail price of a diesel-powered APU with a DPF to be $10,000.
290The 
agencies used a retail price of a diesel- powered APU to be $8,000 without a DPF and $10,000 with a DPF in the cost analysis for this final rulemaking. 
ATA and First Industries commented 
that the LRR tire costs calculations appear to be based on calculations on 1999 data indexed for inflation. Michelin’s comments stated that they estimate the cost of low rolling resistance tires to be about $25 per tire. ATA commented that the industry commonly sees a 40 percent reduction in useful life and a 20 percent reduction in casing life resulting from low rolling resistance tires. ATA and First Industries commented that the LRR tire costs do not account for reduced tire life resulting in fewer retreads. Schneider commented that WBS tire costs must include additional service costs, cost of reduced tire life, and increased replacement tire costs due to recaps not available, and reduced resale value. Volvo also commented that heavy-duty fleets expect to retread tires as many as five times and have concerns that tire casing durability may be compromised with low rolling resistance tires. Volvo stressed that retreading saves cost and about two thirds of the oil required to produce a new tire. 
We have estimated the cost of lower 
rolling resistance tires based on an estimate from TetraTech of $30 (retail, 2013$). We also have applied a ‘‘medium’’ complexity markup value for the more advanced low rolling resistance tires. We expect that, when replaced, the lower rolling resistance tires would be replaced by equivalent performing tires throughout the vehicle lifetime. As such, the incremental increases in costs for lower rolling resistance tires would be incurred throughout the vehicle lifetime at intervals consistent with current tire replacement intervals. A recent study conducted by ATA’s Technology and Maintenance Council found through surveys of 51 fleets that low rolling resistance tires and wide base single tires lasted longer than standard tractor tires.
291Due to the uncertainty 
regarding the life expectancy of the LRR tires, we maintained the current tire replacement intervals in our cost analysis. 
ATA and First Industries commented 
that the estimated costs of future aerodynamic devices appear low given the historical nature of the proposed changes. ATA and First Industries also commented that the agencies should describe in detail the component packages they expect to satisfy each bin level, cost breakdowns of these individual components, and how this technology will be modified over time to maintain compliance with increasingly stringency levels. The agencies included the technology cost of aerodynamic improvements, such as wheel covers and active grill shutters, in RIA Chapter 2.11. 
The agencies also received comments 
associated with other costs that should be considered related to the technologies, specifically 6x2 axle configurations, tire pressure monitoring and inflation system, and APUs. ATA and First Industries commented that the agencies should include additional tire wear and negative residual values associated with 6x2 axles. Schneider commented that 6x2 axle configurations cost should include loss on resale value, increased tire wear, and cost for electronic technology to improve traction. ATA and First Industries commented that the cost estimates for tire inflation systems and TPMS must include warranty limitations, useful life, maintenance and replacement costs, as well as costs of false warnings and increased operation of the air compressor. Doran cited a FMCSA study that found TPMS and ATIS reduce road calls for damaged tires and reduced number of tire replacements and did not introduce unscheduled maintenance. Schneider commented that an electronic APU will have maintenance of $500 per year and engine powered APUs must also include maintenance costs. Caterpillar requested that the agencies take a total cost of ownership approach when considering the technology feasibility and adoption rates. 
With respect to costs, all of the 
agencies’ technology cost analyses include both direct and indirect costs. Indirect costs include items such as warranty. In terms of maintenance, the presence of tire inflation management systems, should serve to improve tire maintenance intervals and perhaps reduce vehicle downtime due to tire issues; they may also carry with them some increased maintenance costs to ensure that the tire inflation systems themselves remain in proper operation. For the analysis, we have considered these two competing factors to cancel each other out. The agencies also considered the maintenance impact of 6x2 axles. As noted in the NACFE Confidence Report on 6x2 axles, the industry expects an overall reduction in maintenance costs and labor for vehicles with a 6x2 configuration as compared to a 6x4 configuration.
292Among other 
savings, the reduction in number of parts, such as the interaxle drive shaft, will reduce the number of lubrication procedures needed and reduce the overall quantity of differential fluid needed at change intervals. The agencies have taken an approach to the maintenance costs for the 6x2 technology where we believe that the overall impact will be zero. The agencies added maintenance costs for diesel powered APUs, battery powered APUs, and diesel fired heaters into the cost analysis for the final rulemaking, as described in RIA Chapter 7.2.3. In response to Caterpillar’s comment, the agencies considered the total cost of ownership during the payback calculations, included in RIA Chapter 7 of the final rule. The payback calculations include the hardware costs of the new technologies and their associated fixed costs, increased insurance, taxes, and maintenance. The agencies found that for each category of vehicle—tractor/trailers, vocational vehicles, and HD pickups and vans— included in the Phase 2 rule that the fuel savings significantly exceed the costs associated with the technologies over the lifetime of the vehicles. 
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TABLE III–25—C LASS 7 AND8 TRACTOR TECHNOLOGY INCREMENTAL COSTS IN THE 2021 M ODEL YEARabFINAL 
STANDARD VS . THEFLATBASELINE  
[2013$ per vehicle] 
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low/mid roof High roof Low/mid roof High roof Low roof Mid roof High roof 
Enginec........................ $284 $284 $284 $284 $284 $284 $284 
Aerodynamics .............. 164 299 164 299 119 119 349 
Tires ............................. 39 9 61 16 61 56 16 
Tire inflation system ..... 259 259 300 300 300 300 300 
Transmission ................ 4,096 4,096 4,096 4,096 4,096 4,096 4,096 
Axle Efficiency .............. 71 71 101 101 101 101 101 
Idle reduction ............... 0 0 0 0 1,998 1,998 1,909 
Air conditioning ............ 17 17 17 17 17 17 17 
Other vehicle tech-
nologies .................... 204 204 204 204 204 204 204 
Total ...................... 5,134 5,240 5,228 5,317 7,181 7,175 7,276 
Notes: 
aCosts shown are for the 2021 model year and are incremental to the costs of a baseline tractor meeting the Phase 1 standards. These costs 
include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis 
and how it impacts technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.12). 
bNote that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the 
indicated tractor classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.12 in particular). 
cEngine costs are for a heavy HD diesel engine meant for a combination tractor. The engine costs in this table are equal to the engine costs 
associated with the separate engine standard because both include the same set of engine technologies (see Section II.D.2.d.i).  
TABLE III–26—C LASS 7 AND8 TRACTOR TECHNOLOGY INCREMENTAL COSTS IN THE 2024 M ODEL YEARabPREFERRED  
ALTERNATIVE VS . THEFLATBASELINE  
[2013$ per vehicle] 
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low/mid roof High roof Low/mid roof High roof Low roof Mid roof High roof 
Enginec........................ $712 $712 $712 $712 $712 $712 $712 
Aerodynamics .............. 264 465 264 465 217 217 467 
Tires ............................. 40 12 65 20 65 65 20 
Tire inflation system ..... 383 383 477 477 477 477 477 
Transmission ................ 6,092 6,092 6,092 6,092 6,092 6,092 6,092 
Axle Efficiency .............. 139 139 185 185 185 185 185 
Idle reduction ............... 0 0 0 0 2,946 2,946 2,946 
Air conditioning ............ 32 32 32 32 32 32 32 
Other vehicle tech-
nologies .................... 374 374 374 374 374 374 374 
Total ...................... 8,037 8,210 8,201 8,358 11,100 11,100 11,306 
Notes: 
aCosts shown are for the 2024 model year and are incremental to the costs of a baseline tractor meeting the Phase 1 standards. These costs 
include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it impacts technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.12). 
bNote that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the 
indicated tractor classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.12). 
cEngine costs are for a heavy HD diesel engine meant for a combination tractor. The engine costs in this table are equal to the engine costs 
associated with the separate engine standard because both include the same set of engine technologies (see Section II.D.2.d.i).  
TABLE III–27—C LASS 7 AND8 TRACTOR TECHNOLOGY INCREMENTAL COSTS IN THE 2027 M ODEL YEARabPREFERRED  
ALTERNATIVE VS . THEFLATBASELINE  
[2013$ per vehicle] 
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low/mid roof High roof Low/mid roof High roof Low roof Mid roof High roof 
Enginec........................ $1,579 $1,579 $1,579 $1,579 $1,579 $1,579 $1,579 
Aerodynamics .............. 453 547 453 547 415 415 639 
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TABLE III–27—C LASS 7 AND8 TRACTOR TECHNOLOGY INCREMENTAL COSTS IN THE 2027 M ODEL YEARabPREFERRED  
ALTERNATIVE VS . THEFLATBASELINE —Continued 
[2013$ per vehicle] 
Class 7 Class 8 
Day cab Day cab Sleeper cab 
Low/mid roof High roof Low/mid roof High roof Low roof Mid roof High roof 
Tires ............................. 43 12 70 20 70 70 20 
Tire inflation system ..... 469 469 594 594 594 594 594 
Transmission ................ 7,098 7,098 7,098 7,098 7,098 7,098 7,098 
Axle Efficiency .............. 168 168 220 220 220 220 220 
Idle reduction ............... 0 0 0 0 3,134 3,173 3,173 
Air conditioning ............ 45 45 45 45 45 45 45 
Other vehicle tech-
nologies .................... 380 380 380 380 380 380 380 
Total ...................... 10,235 10,298 10,439 10,483 13,535 13,574 13,749 
Notes: 
aCosts shown are for the 2027 model year and are incremental to the costs of a baseline tractor meeting the Phase 1 standards. These costs 
include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis 
and how it impacts technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.12). 
bNote that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the 
indicated tractor classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.12 in particular). 
cEngine costs are for a heavy HD diesel engine meant for a combination tractor. The engine costs in this table are equal to the engine costs 
associated with the separate engine standard because both include the same set of engine technologies (see Section II.D.2.d.i).  
The technology costs associated with 
the heavy-haul tractor standards are 
shown below in Table III–28. 
TABLE III–28—H EAVY -HAULTRACTOR TECHNOLOGY INCREMENTAL COSTS IN THE 2021, 2024, AND2027 M ODEL YEARab 
PREFERRED ALTERNATIVE VS . THEFLATBASELINE  
[2013$ per vehicle] 
2021 MY 2024 MY 2027 MY 
Enginec............................................................................................................................... ......... $284 $712 $1,579 
Tires .......................................................................................................................... ................... 61 65 70 
Tire inflation system .......................................................................................................... ........... 300 477 594 
Transmission ................................................................................................................... ............. 4,096 6,092 7,098 
Axle Efficiency ................................................................................................................ ............. 101 185 220 
Air conditioning ............................................................................................................... ............. 17 32 45 
Other vehicle technologies ..................................................................................................... ..... 204 374 380 
Total .......................................................................................................................... ............ 5,063 7,937 9,986 
Notes: 
aCosts shown are for the specified model year and are incremental to the costs of a baseline tractor meeting the Phase 1 standards. These 
costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this 
analysis and how it impacts technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.12). 
bNote that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the 
indicated tractor classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.12 in particular). 
cEngine costs are for a heavy HD diesel engine meant for a combination tractor. 
(2) Consistency of the Tractor Standards 
With the Agencies’ Legal Authority 
The HD Phase 2 standards are based 
on adoption rates for technologies that the agencies regard as the maximum feasible for purposes of EISA Section 32902(k) and appropriate under CAA section 202(a) for the reasons given in Section III.D.1(b) through (d) above; see also RIA Chapter 2.8. The agencies believe these technologies can be adopted at the estimated rates for these standards within the lead time provided, as discussed above and in RIA 
Chapter 2.8. The 2021 and 2024 MY standards are phase-in standards on the path to the 2027 MY standards and were developed using less aggressive application rates and therefore have lower technology package costs than the 2027 MY standards. Moreover, we project the cost of these technologies will be rapidly recovered by operators due to the associated fuel savings, as shown in the payback analysis included in Section IX below. The cost per tractor to meet the 2027 MY standards is projected to range between $10,200 and $13,700 (which includes the cost of the engine standards). See Table III–25 above. Much or all of this will be recovered in the form of fuel savings during the first two years of ownership. The agencies note that while the projected costs per vehicle are significantly greater than the costs projected for Phase 1, we still consider that cost to be reasonable, especially given the relatively short payback 
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293See RIA Chapter 7.2.4. 
294Auto Remarketing. Length of Ownership 
Returning to More Normal Levels; New 
Registrations Continue Slow Climb. April 1, 2013. Last accessed on February 26, 2015 at http://
www.autoremarketing.com/trends/length- ownership-returning-more-normal-levels-new- registrations-continue-slow-climb. 295North American Council for Freight 
Efficiency. Barriers to Increased Adoption of Fuel 
Efficiency Technologies in Freight Trucking. July 2013. Page 24. 
296See RIA Chapter 7.2.5 and Memo to Docket 
‘‘Tractor-Trailer Cost per Ton Values.’’ July 2016. EPA–HQ–OAR–2014–0827. 297If using a cost effectiveness metric that treats 
fuel savings as a negative cost, net costs per ton of GHG emissions reduced or per gallon of avoided fuel consumption will be negative under these standards. period. In this regard the agencies note 
that the estimated payback period for tractors of less than two years,
293is 
itself shorter than the estimated payback period for light duty trucks in the 2017– 2025 light duty greenhouse gas standards. That period was slightly over three years, see 77 FR 62926–62927, 
which EPA found to be a highly reasonable given the usual period of ownership of light trucks is typically five years.
294The same is true here. 
Ownership of new tractors is customarily four to six years, meaning that the greenhouse gas and fuel consumption technologies pay for themselves early on and the purchaser sees overall savings in succeeding years—while still owning the vehicle.
295 
The agencies note further that the costs for each subcategory are relatively proportionate; that is, costs of any single tractor subcategory are not disproportionately higher (or lower) than any other. Although the rule is technology-forcing (especially with respect to aerodynamic and drivetrain efficiency improvements), the agencies believe that manufacturers retain leeway to develop alternative compliance paths, increasing the likelihood of the standards’ successful implementation. The agencies also regard these reductions as cost-effective, even without considering payback period. 
The agencies estimate the cost per metric ton of CO
2eq reduction without 
considering fuel savings to be $36 for 
tractor-trailers in 2030 which compares favorably with the levels of cost effectiveness the agencies found to be reasonable for light duty trucks.
296 297  
See 77 FR 62922. The phase-in 2021 and 
2024 MY standards are less stringent and less costly than the 2027 MY standards and hence likewise reasonable. For these reasons, and because the agencies have carefully considered lead time and shown that lead time is adequate, EPA believes they are also reasonable under Section 202(a) of the CAA. Given that the agencies believe these standards are technically feasible, are highly cost effective, and even more highly cost effective when accounting for the fuel savings, and have no apparent adverse potential impacts (e.g., there are no projected 
negative impacts on safety or vehicle utility, and EPA has taken steps to avoid adverse collateral consequences from use of APUs without filter-based particulate controls), these standards represent a reasonable choice under Section 202(a)(2) of the CAA and the maximum feasible under NHTSA’s EISA authority at 49 U.S.C. 32902(k)(2). (3) Alternative Tractor Standards 
Considered 
The agencies developed and 
considered other alternative levels of stringency for the Phase 2 program. The results of the analysis of these alternatives are discussed below in Section X of the Preamble. For tractors, the agencies developed the following alternatives as shown in Table III–29. The agencies are not adopting standards reflecting Alternative 2, because as already described, technically feasible standards are available that provide for greater emission reductions and reduced fuel consumption than provided under Alternative 2. The agencies are not adopting standards reflecting Alternative 4 or Alternative 5 in their entirety because we do not believe to be feasible considering lead time and other relevant factors. However, we note that the tractor standards are predicated on the adoption of engine technology beyond what was projected in Alternative 4 of the NPRM. In addition, the final rule stringency includes additional technologies for tractors that were not considered in any of the alternatives analyzed in the NPRM— axle efficiency, transmission efficiency, adjustable automatic engine shutdown systems, and tire pressure monitoring systems. 
TABLE III–29—S UMMARY OF ALTERNATIVES CONSIDERED FOR THE FINAL RULEMAKING  
Alternatives 1a and 1b No action alternatives 
Alternative 2 .................................... Less Stringent than the Preferred Alternative applying off-the-shelf technolog ies. 
Preferred Alternative ....................... Final Phase 2 standards, fully phased-in by 2027 MY. 
Alternative 4 .................................... Alternative presented in the NPRM that pulls ahead the proposed 2027 MY standards to 2024 MY. 
Alternative 5 .................................... Alternative based on very high market adoption of advanced technologies. 
E. Phase 2 Compliance Provisions for 
Tractors 
In HD Phase 1, the agencies 
developed an entirely new program to assess the CO
2emissions and fuel 
consumption of tractors. The agencies are carrying over many aspects of the Phase 1 compliance approach, but we are also adopting changes to enhance several aspects of the compliance program. The sections below highlight the key areas that are the same and those that are different. (1) HD Phase 2 Compliance Provisions 
That Remain the Same 
The overall Phase 2 regulatory 
structure is discussed in more detail above in Section II. This section discusses tractor-specific compliance provisions. 
(a) Application and Certification Process 
For the Phase 2 final rule, the 
agencies are keeping many aspects of 
the HD Phase 1 tractor compliance program. For example, the agencies will continue to use GEM (as revised for Phase 2), in coordination with additional component testing by 
manufacturers to determine the inputs, to determine compliance with the fuel efficiency and CO
2standards. Another 
aspect that we are carrying over is the overall compliance approach. EMA’s 
and the HD manufacturers’ comments supported the continued use of GEM and did not support chassis-based certification. 
In Phase 1 and as finalized in Phase 
2, the general compliance process in terms of the pre-model year, during the model year, and post model year activities remains unchanged. The manufacturers will be required to apply 
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for certification through a single source, 
EPA, with limited sets of data and GEM results (see 40 CFR 1037.205). EPA will issue certificates upon approval based on information submitted through the VERIFY database (see 40 CFR 1037.255). In Phase 1, EPA and NHTSA jointly review and approve innovative technology requests, i.e. performance of 
any technology whose performance is not measured by the GEM simulation tool and is not in widespread use in the 2010 MY. For Phase 2, the agencies are adopting a similar process for allowing credits for off-cycle technologies that are not measured by the GEM simulation tool, although the revised GEM now recognizes many more technologies than the Phase 1 version of GEM, notably drivetrain and transmission improvements, so fewer technologies 
would be candidates for off-cycle credits (see Section I.B.v. for a more detailed discussion of off-cycle requests). During the model year, the manufacturers will continue to generate certification data and conduct GEM runs on each of the vehicle configurations it builds. After the model year ends, the manufacturers will submit end of year reports to EPA that include the GEM results for all of the configurations it builds, along with credit/deficit balances if applicable (see 40 CFR 1037.250 and 1037.730). EPA and NHTSA will jointly coordinate on any enforcement action required. 
(b) Compliance Requirements 
As proposed in Phase 2, the agencies 
did not adopt any provisions in the final 
Phase 2 rules that significantly change the following Phase 1 provisions: 
•Useful life of tractors (40 CFR 
1037.105(e) and 1037.106(e)) although 
added for NHTSA in Phase 2 (49 CFR 535.5) 
•Emission-related warranty 
requirements (40 CFR 1037.120) 
•Maintenance instructions, allowable 
maintenance, and amending maintenance instructions (40 CFR 1037.125 and 137.220) 
•Deterioration factors (40 CFR 
1037.205(l) and 1037.241(c)) 
•Vehicle family, subfamily, and 
configurations (40 CFR 1037.230), except for the addition of a heavy- haul family in Phase 2 
(c) Drive Cycle Speed Targets and Weightings 
In Phase 1, the agencies adopted three 
drive cycles used in GEM to evaluate the fuel consumption and CO
2 
emissions from various vehicle configurations. One of the cycles is the Transient mode of the California ARB Heavy Heavy-Duty Truck 5 Mode cycle. It is intended to broadly cover urban driving. The other two cycles represent 
highway driving at 55 mph and 65 mph. 
The agencies proposed to maintain 
the existing Phase 1 drive cycle speed traces and weightings in Phase 2. In the Phase 2 proposal sleeper cab weightings would remain 5 percent of the Transient cycle, 9 percent of the 55 mph cycle, and 86 percent of the 65 mph cycle. The day cabs would be weighted based on 19 percent of the transient cycle, 17 percent of the 55 mph cycle, and 64 percent of the 65 mph cycle (see proposed 40 CFR 1037.510(c) and 80 FR 40242). In response to the Phase 2 NPRM, the American Trucking Associations (ATA) submitted comments based on spot speed records throughout the month of May 2015. This study found that Class 8 trucks operated at speeds of 55 mph or less 57 percent of the time. United Parcel Service (UPS) stated that their Class 8 tractor-trailers average 54 miles per hour in part because they use vehicle speed limiters in their fleet. UPS also shared ATA’s comments on the spot speed records. Daimler stated that they did not see a benefit of increasing the amount of low speed operation for tractors, unless the EPA–NREL work supported the need for a change. 
The agencies considered these 
comments along with the information that was used to derive the drive cycle weightings in Phase 1. The agencies did not receive any new drive cycle weighting data for tractors from the EPA–NREL work. The agencies believe that the study cited by ATA includes weightings of speed records, which represent the fraction of time spent at a 
given speed. However, our drive cycle weightings represent the fraction of vehicle miles traveled (VMT). The agencies used the vehicle speed information provided in the ATA comments and translated the weightings to VMT. Based on our assessment shown in RIA Chapter 3.4.3, their findings produce weightings that are approximately 74 percent of the vehicle miles traveled are at speeds greater than 55 mph and 26 percent less than 55 mph. In addition, the study cited by ATA represents ‘‘Class 8 trucks’’ which would include day cab tractors, sleeper cab tractors, and heavy heavy-duty vocational trucks. Based on this 
assessment, the agencies do not believe this new information is significantly different than the drive cycle weightings that were proposed. Therefore, we are adopting the drive cycle weightings for tractors that we adopted for Phase 1 and proposed for Phase 2. 
Both in the Phase 1 program and as 
proposed in the Phase 2 program, the 55 mph and 65 mph drive cycles used in GEM assume a constant target speed with downshifting occurring if road incline causes a predetermined drop in vehicle speed. In real-world vehicle operation, traffic conditions and other factors may cause periodic operation at lower (e.g. creep) or variable vehicle 
speeds. In the Phase 2 NPRM, the agencies requested comment on the need to include segments of lower or variable speed operation in the nominally 55 mph and 65 mph drive cycles used in GEM and how this may or may not impact the strategies manufacturers would develop. 80 FR 80242. 
In response, ACEEE commented that 
NREL found that constant speeds on positive and negative grades misrepresent the real world operation of HD trucks because there is a strong correlation between road grade and average speed. Daimler commented that for regulatory purposes using a constant speed cycle with representative road grade is appropriate, noting as well that some manufacturers use a constant speed cycle in their internal development processes and have found it correlates well to real world operation. They also highlight the concern that it would be extremely difficult to develop traffic patterns that represent a national average. However, Daimler also stated in their comments that they do see a benefit of allowing increased variability in the vehicle speeds in the 55 and 65 mph cycles, for evaluating the effectiveness of technologies such as predictive cruise control. 
After considering these comments and 
evaluating the final Phase 2 version of GEM, the agencies are adopting in the Phase 2 final rules constant target speed for the 55 mph and 65 mph cycles, as adopted in Phase 1. One key difference in Phase 2 is the addition of road grade in these cruise cycles, as discussed below in Section III.E.2. The addition of road grade to the cruise cycles brings the GEM simulation of vehicles over the drive cycles closer to the real world operation described by ACEEE and Daimler. Even though the cruise cycles will continue to have constant target speeds (55 mph or 65 mph), the vehicle may slow down from the target speed of the cycle on an uphill stretch of road due to the addition of road grade in the Phase 2 cycles. If the vehicle does slow down, the transmission shift logic built into GEM will downshift the transmission to limit the amount of further vehicle deceleration. Similarly, on the downhill portions of the cycles, the driver control logic built into GEM will allow the vehicle to exceed the 
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298ICF International. Investigation of Costs for 
Strategies to Reduce Greenhouse Gas Emissions for 
Heavy-Duty On-road Vehicles. July 2010. Pages 4–15. Docket Number EPA–HQ–OAR–2010–0162– 0044. 299M.J. Bradley & Associates. Setting the Stage for 
Regulation of Heavy-Duty Vehicle Fuel Economy 
and GHG Emissions: Issues and Opportunities. February 2009. Page 35. Analysis based on 1992 Truck Inventory and Use Survey data, where the survey data allowed developing the distribution of loads instead of merely the average loads. 300The U.S. Federal Highway Administration. 
Development of Truck Payload Equivalent Factor. 
Table 11. Last viewed on March 9, 2010 at http:// 
ops.fhwa.dot.gov/freight/freight_ analysis/faf/faf2 _
reports/reports9/s510 _11_12_tables.htm. target speed by 3 mph prior to braking 
the vehicle. 
(d) Empty Weight and Payload 
The total weight of the tractor-trailer 
combination is the sum of the tractor 
curb weight, the trailer curb weight, and the payload. The total weight of a vehicle is important because it in part determines the impact of technologies, such as rolling resistance, on GHG emissions and fuel consumption. In Phase 2, we proposed to carry over the total weight of the tractor-trailer combination used in GEM for Phase 1. The agencies developed the tractor curb weight inputs for Phase 2 from actual tractor weights measured in two of EPA’s Phase 1 test programs. The trailer curb weight inputs were derived from actual trailer weight measurements conducted by EPA and from weight data provided to ICF International by the trailer manufacturers.
298We welcomed 
comment on the tractor weights we proposed. 
Daimler commented that there is a 
large spread of weights within a subcategory given the variety of different features that a vehicle might incorporate in order to perform its task. The agencies’ proposed curb weights for tractors may be higher than Daimler’s vehicles but in Daimler’s opinion align with some of their competitors’ vehicles, and therefore are reasonable. Based on no negative comment or newer data, the agencies are adopting the Phase 1 tractor curb weights, as proposed. 
There is a further issue of what 
payload weight to assign during compliance testing. In use, trucks operate at different weights at different 
times during their operations. The greatest freight transport efficiency (the amount of fuel required to move a ton of payload)—would be achieved by operating trucks at the maximum load for which they are designed all of the time. However, this may not always be practicable. Delivery logistics may dictate partial loading. Some payloads, such as potato chips, may fill the trailer before it reaches the vehicle’s maximum weight limit. Or full loads simply may not be available commercially. M.J. Bradley analyzed the Truck Inventory and Use Survey and found that approximately 9 percent of combination tractor miles travelled empty, 61 percent are ‘‘cubed-out’’ (the trailer volume is full before the weight limit is reached), and 30 percent are ‘‘weighed out’’ (operating weight equals 80,000 lbs which is the gross vehicle weight limit on the Federal Interstate Highway System or greater than 80,000 lbs for vehicles traveling on roads outside of the interstate system).
299 
The amount of payload that a tractor 
can carry depends on the category (or GVWR and GCWR) of the vehicle. For example, a typical Class 7 tractor can 
carry less payload than a Class 8 tractor. For Phase 1, the agencies used the Federal Highway Administration Truck Payload Equivalent Factors using Vehicle Inventory and Use Survey (VIUS) and Vehicle Travel Information System data to determine the payloads. FHWA’s results indicated that the average payload of a Class 8 vehicle ranged from 36,247 to 40,089 lbs, depending on the average distance travelled per day.
300The same study shows that Class 7 vehicles carried between 18,674 and 34,210 lbs of payload also depending on average distance travelled per day. Based on these data, the agencies proposed to continue to prescribe a fixed payload of 25,000 lbs for Class 7 tractors and 38,000 lbs for Class 8 tractors for certification testing for Phase 2. The agencies also proposed to continue to use a common payload for Class 8 day cabs and sleeper cabs as a predefined GEM input because the data available do not distinguish among Class 8 tractor types. These payload values represent a heavily loaded trailer, but not maximum GVWR, since as described above the majority of tractors ‘‘cube-out’’ rather than ‘‘weigh-out.’’ 
The agencies requested comments and 
data to support changes to our proposed payloads for Phase 2. 80 FR 40242. Daimler commented that the payload weight is even more difficult to determine because weights change based on economic conditions, such as when carriers continue to try to reduce their dead volume and increase their weight per load. Daimler suggested that the agencies might consider increasing the proposed payloads, but did not provide data. In the absence of newer data or other compelling comments, the agencies continue to believe that it is appropriate to continue using the Phase 1 tractor payloads for all of the Class 7 and 8 tractors, as proposed, except for heavy-haul. 
Details of the predefined weights by 
regulatory subcategory, as shown in Table III–30, are included in RIA Chapter 3. 
TABLE III–30—F INAL COMBINATION TRACTOR WEIGHT INPUTS  
Model type Regulatory subcategory Tractor tare 
weight 
(lbs) Trailer 
weight 
(lbs) Payload 
(lbs) Total 
weight 
(lbs) 
Class 8 .............................................. Sleeper Cab High Roof .................... 19,000 13,500 38,000 70,500 
Class 8 .............................................. Sleeper Cab Mid Roof ..................... 18,750 10,000 38,000 66,750 
Class 8 .............................................. Sleeper Cab Low Roof ..................... 18,500 10,500 38,000 67,000 
Class 8 .............................................. Day Cab High Roof .......................... 17,500 13,500 38,000 69,000 
Class 8 .............................................. Day Cab Mid Roof ........................... 17,100 10,000 38,000 65,100 
Class 8 .............................................. Day Cab Low Roof ........................... 17,000 10,500 38,000 65,500 
Class 7 .............................................. Day Cab High Roof .......................... 11,500 13,500 25,000 50,000 
Class 7 .............................................. Day Cab Mid Roof ........................... 11,100 10,000 25,000 46,100 
Class 7 .............................................. Day Cab Low Roof ........................... 11,000 10,500 25,000 46,500 
Class 8 .............................................. Heavy-Haul ....................................... 19,000 13,500 86,000 118, 500 
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301Southwest Research Institute. ‘‘Heavy Duty 
Class 8 Truck Coastdown and Constant Speed 
Testing.’’ April 2015. (e) Tire Testing 
In Phase 1, manufacturers are 
required to input their tire rolling 
resistance coefficient into GEM. Also in Phase 1, the agencies adopted the provisions in ISO 28580 to determine the rolling resistance of tires. As described in 40 CFR 1037.520(c), the agencies require that at least three tires for each tire design are to be tested at least one time. Our assessment of the Phase 1 program to date indicates that these requirements reasonably balance the need for precision, repeatability, and testing burden. Therefore we proposed to carry over the Phase 1 testing provisions for tire rolling resistance into Phase 2. 80 FR 40243. We welcomed comments regarding the tire testing provisions, but did not receive any. Therefore, based on the same reasoning presented at proposal, we are adopting the Phase 1 tire testing provisions in Phase 2. 
In Phase 1, the agencies received 
comments from stakeholders highlighting a need to develop a reference lab and alignment tires for the HD sector. The agencies discussed the lab-to-lab comparison conducted in the Phase 1 EPA tire test program (80 FR 40243, citing to 76 FR 57184). The agencies reviewed the rolling resistance data from the tires that were tested at both the STL and Smithers laboratories to assess inter-laboratory and test machine variability. The agencies conducted statistical analysis of the data to gain better understanding of lab-to- lab correlation and developed an adjustment factor for data measured at each of the test labs. Based on these results, the agencies believe the lab-to- lab variation for the STL and Smithers laboratories will have very small effect on measured rolling resistance values. Based on the test data, the agencies judge for the HD Phase 2 program to continue to use the current levels of variability, and the agencies therefore proposed to allow the use of either Smithers or STL laboratories for determining the tire rolling resistance value. The agencies requested comment on the need to establish a reference machine for the HD sector and whether tire testing facilities are interested in and willing to commit to developing a reference machine. The agencies did not receive any comments on the issue. Therefore, again based on the reasoning presented at proposal, we are adopting the Phase 1 testing approach for Phase 2. (2) Key Differences in HD Phase 2 
Compliance Provisions 
The agencies are adopting certain 
provisions in Phase 2 that are significantly different from Phase 1. Details regarding some of these key changes such as aerodynamic assessments, road grade in the drive cycles, weight reduction, GEM inputs, emission control labels, and chassis dynamometer testing are provided in this subsection. 
(a) Aerodynamic Assessment 
In Phase 1, the manufacturers conduct 
aerodynamic testing to establish the 
appropriate bin and GEM input for determining compliance with the CO
2 
and fuel consumption standards. The agencies proposed to continue this general approach in HD Phase 2, but to make several enhancements to the aerodynamic assessment of tractors. As discussed below, we proposed some modifications to the aerodynamic test procedures—the addition of wind averaged drag in the aerodynamic assessment, the addition of trailer skirts to the standard trailer used to determine aerodynamic performance of tractors and revisions to the aerodynamic bins. As discussed in more detail in the following subsections, we are adopting many of the proposed Phase 2 aerodynamic test procedures, but with some additional revisions to the test procedures. These procedures are then appropriately reflected in the final Phase 2 aerodynamic bins. 
(i) Phase 1 Aerodynamic Test 
Procedures 
The aerodynamic drag of a vehicle is 
determined by the vehicle’s coefficient of drag (Cd), frontal area, air density and speed. Quantifying tractor aerodynamics as an input to the GEM presents technical challenges because of the proliferation of tractor configurations and subtle variations in measured aerodynamic values among various test procedures. In Phase 1, Class 7 and 8 tractor aerodynamic results are developed by manufacturers using a range of techniques, including wind tunnel testing, computational fluid dynamics, and constant speed tests. 
We continue to believe a broad 
approach allowing manufacturers to use these multiple test procedures to demonstrate aerodynamic performance of its tractor fleet is appropriate given that no single test procedure is superior in all aspects to other approaches. However, we also recognize the need for consistency and a level playing field in evaluating aerodynamic performance. To address the consistency and level playing field concerns, NHTSA and EPA 
adopted in Phase 1, while working with industry, an approach that identified a reference aerodynamic test method (coastdown) and a procedure to align results from other aerodynamic test procedures with the reference method by applying a correction factor (F
alt-aero ) 
to results from alternative methods. The 
Phase 1 regulations require manufacturers to use good engineering judgment in developing their corrections and specify some minimum testing requirements. 
(ii) Reference Aerodynamic Method in 
Phase 2 
Based on feedback received during 
the development of Phase 1, we understood even before the Phase 2 NPRM was issued that there was interest from some manufacturers to change the reference method in Phase 2 from coastdown to constant speed testing. EPA conducted an aerodynamic test program at Southwest Research Institute to evaluate both methods in terms of cost of testing, testing time, testing facility requirements, and repeatability of results. Details of the analysis and results are included in RIA Chapter 3.2. The results showed that the enhanced coastdown test procedures and analysis produced results with acceptable repeatability and at a lower cost than the constant speed testing. Based on the results of this testing, the agencies proposed to continue to use the enhanced coastdown procedure for the reference method in Phase 2.
30180 FR 
40244. However, we welcomed comment on the need to change the reference method for the Phase 2 final rule to constant speed testing, including comparisons of aerodynamic test results using both the coastdown and constant speed test procedures. In addition, we welcomed comments on and suggested revisions to the constant speed test procedure specifications set forth in the proposal in Chapter 3.2.2.2 of the draft RIA and 40 CFR 1037.533 in the proposed regulations (40 CFR 1037.534 in the final regulations). 
Several stakeholders provided 
comments both in favor and against the use of coastdown as the reference aero method for Phase 2 for tractors. CARB does not support the constant speed test as the reference method until it can be demonstrated to be superior to the coastdown methods. Their concerns included the cost associated with vehicle modifications required in test preparation (such as the torque meters 
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302Memo to Docket. Aerodynamic Subteam 
Meetings with EMA. July 2016. Docket EPA–HQ– 
OAR–2014–0827. on the wheel hubs). Daimler did not 
support a change to constant speed testing for the reference method and stated that more time is needed to determine if constant speed testing would be a better alternative. Navistar supports the coastdown as the reference method and does not believe constant speed testing should be adopted even as an alternative, unless significant further work is conducted. EMA stated that they could not support the adoption of constant speed testing as the reference method in Phase 2 because there is insufficient time in the process to properly study whether constant speed is equivalent to or better than coastdown testing. Further, EMA recommended that constant speed testing be included only as a potential alternative to be phased in at a future date if appropriate. Volvo opposed a change in the aerodynamic reference test method to constant speed at this time due to insufficient time to fully evaluate the new test method. 
Exa supported the use of constant 
speed testing as a reference method because it is a real-world measurement with the ability to evaluate wind- averaged drag. Exa also cited some concerns that coastdown is limited to near zero wind yaw angle and does not accurately represent the aerodynamics experienced on the road. MEMA supported including the constant speed test based on research that has demonstrated that it is reliable relative to coastdown tests and is required in European aerodynamic test protocols. SABIC commented that constant speed testing may help isolate the aerodynamic drag from vibration, mechanical, and friction encountered at low speeds. SABIC also cited research that suggested constant speed testing may provide better repeatability than coastdown tests, and suggested that the U.S. may be able to promote harmonization with the required European constant speed testing. 
After consideration of the comments, 
the agencies are continuing to use the Phase 1 approach of setting coastdown testing as the reference method for tractor aerodynamic assessment in Phase 2. After developing revised coastdown test procedures and data analysis methods for the final rule, we have concluded that coastdown testing continues to produce acceptable repeatability and can be conducted at a lower cost than constant speed testing. However, we are finalizing some revisions to the Phase 2 coastdown test procedures in response to comments and discussed below. The agencies are 
also continuing to allow alternative test methods to be used to determine the aerodynamic performance of tractors in 
Phase 2, as long as the results are correlated back to the reference method using a correlation factor (Falt-aero). Additional details are included in the Falt-aero discussion below. 
(iii) Coastdown Test Procedure Changes 
for Phase 2 
The agencies worked closely with the 
tractor manufacturers between the Phase 
2 NPRM and final rulemaking to develop robust coastdown test procedures that are technically sound.
302EPA also continued to test 
additional tractors after the proposal to better inform the test procedure development. Based on this work, the agencies are adopting aerodynamic test procedures that have been improved from those proposed for Phase 2. The details of these procedures and their development are included in RIA Chapter 3.2. Below is a summary of the changes to the coastdown test procedures and data analysis method for the final rule. 
The coastdown test procedure 
changes include the tested speed range, the calibration of the equipment, and specification of yaw and air speed measurements. The agencies proposed two test speed ranges for coastdown testing—70 to 60 mph and 25 to 15 mph. EPA’s evaluation of the C
dA 
values in relation to yaw angle showed that the 25 to 15 mph low-speed range specified in the NPRM test procedures produced yaw curves that were flatter than expected and flatter than demonstrated using other test methods, such as wind tunnels and CFD. Upon further analysis, EPA found that by reducing the low-speed range to even lower speeds, the yaw curve results were more representative. The best speed range to alleviate this concern is a 15 to 5 mph low speed range; however, requiring this would significantly reduce the number of available days for testing in a given year because it would lead to a wind speed limit of 3 mph. Therefore, the agencies are adopting a low speed range of 20 to 10 mph to balance the yaw curve representativeness with the real world testing implications. Along with this test speed change, the component of the wind speed parallel to the road or track will be limited to less than or equal to 6 mph. The agencies are adopting Phase 2 coastdown test procedures that specify the yaw measurement method resolution and accuracy requirements similar to those proposed for constant speed testing. The calibration of the yaw 
and air speed equipment will be conducted in a point-by-point manner for each run. 
The coastdown data analysis changes 
include the analysis of low speed pairs and filtering methods, adjustments for rear axle losses and rolling resistance, and determination of the final C
dA value 
for coastdown. EPA found that the method proposed to analyze the coastdown results of paired runs leads to an unexpected yaw curve asymmetry. Upon further evaluation, EPA found that the yaw curve asymmetry is mitigated by averaging the road load force and air speed from every two opposite direction low-speed segments and using the average with each of the high speed segments in the data analysis. Therefore, the agencies are adopting this method for the Phase 2 final rules. The filtering of the air speed, yaw, vehicle speed, and track wind speed is necessary to remove outliers and replace the data with the moving median value to reduce the variability of coastdown test results. The agencies are specifying this filtering method in the final rules. Coastdown testing measures all of the losses associated with the vehicle, including aerodynamics, rolling resistance, and axle spin losses. To isolate the aerodynamic C
dA, it is 
important to remove the losses associated with drive axle and tire rolling resistance. For the final Phase 2 rules, the agencies are adopting the SAE J2452 test procedures that require manufacturers to measure the speed dependence of the tire rolling resistance for each of the steer, drive, and trailer tire models used on the article undergoing a coastdown test. The agencies are also requiring that manufacturers measure the speed dependence of the drive axle spin losses for the drive axle model used in the article undergoing a coastdown test using a subset of the rear axle efficiency test procedure being adopted in Phase 2. 
The agencies have also developed a 
process of identifying and removing coastdown test result outliers for the final rules. First, the median yaw angle of the data is determined. All results outside of a range of plus or minus 1 yaw degree are removed. Then the mean C
dA value of the remaining data points 
is determined. C dA values that lie 
outside of plus or minus two standard deviations from the C
dA mean are 
removed. At least 24 data points are needed after removal of outliers for the results to be valid. Finally, the mean C
dA and mean effective yaw angle are 
calculated from the remaining points. 
These values are then used to adjust to reflect a 4.5 degree yaw angle result 
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303Falt-aero is an experimentally determined factor 
that represents the ratio of coastdown results to 
results from the alternative method. The agencies allow other functional forms of the relationship consistent with good engineering judgment. 304See Section III.E.(2)(a)(ix) for details on the 
SEA requirements. 30540 CFR 1037.532 ‘‘Using computational fluid 
dynamics to calculate drag area (C dA).’’ based on an alternate method yaw curve 
results. 
(iv) Improving Correlation of 
Coastdowns With Alternative Methods (F
alt-aero ) 
As already noted, the agencies 
adopted in Phase 1 a coastdown procedure as the reference method (see 40 CFR 1066.310) and defined a process for manufacturers to align drag results from each of their own alternative test methods to the reference method results using F
alt-aero (see 40 CFR 1037.525).303 
Manufacturers are able to use any aerodynamic evaluation method in demonstrating a vehicle’s aerodynamic performance as long as they obtain our prior approval and the method is aligned to the reference method. The agencies proposed to continue to use this alignment method approach in Phase 2 to maintain the testing flexibility that manufacturers have today. However, the agencies proposed to increase the rigor in determining the F
alt-aero for Phase 2, including enhancing 
the minimum testing requirements. Beginning in MY 2021, we proposed that the manufacturers would be required to determine a new F
alt-aero for 
each of their tractor models for each aerodynamic test method. In Phase 1, manufacturers are required to determine their F
alt-aero using only a high roof 
sleeper cab with a full aerodynamics package (see 40 CFR 1037.521(a)(2) and proposed 40 CFR 1037.525(b)(2)). In Phase 2, we proposed that manufacturers would be required to determine a unique F
alt-aero value for 
each major model of their high roof day cabs and high roof sleeper cabs. In Phase 2, we proposed that manufacturers may carry over the F
alt-aero value until a model changeover 
or based on the agencies’ discretion to require up to six new F
alt-aero  
determinations each year. We requested comment on the amount of testing required to accurately develop a F
alt-aero  
value and the burden associated with it. See 80 FR 40244. 
The agencies received comments with 
regard to the need of F
alt-aero and the 
burden of determining it. Exa Corporation (a supplier of CFD software) commented that it is not clear that the F
alt-aero factor would alleviate challenges 
associated with their expectation that the absolute drag values will differ substantially between different test methods and different facilities. Exa suggested that the agencies require a certification procedure for an alternate tool that includes a broad validation suite including different types of vehicles from aerodynamic sleeper to less aerodynamic day cabs. The HD vehicle manufacturers strongly recommended that the agencies reduce the number of coastdown tests that must be conducted each year. Navistar commented that only one F
alt-aero should 
be required for Phase 2. Navistar’s testing of their ProStar sleeper and day cabs found that the F
alt-aero only differed 
within less than one percent using the same test facility. Navistar also commented that the data in the Phase 2 NPRM draft RIA show that three different sleepers show F
alt-aero values 
within 0.4 percent. EMA commented that only one F
alt-aero value should be 
required, as supported by the values shown in the Phase 2 Draft RIA where the F
alt-aero values were 1.09 +/¥0.02 for 
three tested vehicles. EMA also commented that the proposed requirements would be time-consuming, costly, and an unreasonable burden. Daimler supported EMA’s comments. The HD vehicle manufacturers also submitted data to the agencies that show the F
alt-aero values were within a range of 
one percent. Volvo shared data with the agencies that support that F
alt-aero is 
highly consistent for varying truck models when correcting the test data under the conditions and methods that the industry has recommended. Volvo therefore concluded that multiple F
alt-aero values are not necessary for 
Phase 2. PACCAR provided results from three tractor models showing the spread of F
alt-aero is less than 0.3 percent. 
The agencies determined the F alt-aero  
values for all of the tractors tested using different aerodynamic methods for Phase 2 using the aerodynamic test procedures and data analysis finalized for Phase 2. As shown in further detail in RIA Chapter 3.2.1, the F
alt-aero values 
ranged between 1.13 and 1.20 for a 
single CFD software. Therefore, the agencies concluded that a single F
alt-aero  
value is not sufficient for determining the correlation of test methods for all tractors. Furthermore, based on the comments and further refinement of our selective enforcement audit (SEA) provisions in the Phase 2 final rule, we are adopting provisions that require manufacturers to determine F
alt-aero for a 
minimum of one day cab and one sleeper cab in MYs 2021, 2024, and 2027.
304While this significantly reduces 
the test burden from the levels proposed, it also only represents a minimum requirement. The agencies believe that the improvements to the 
SEA requirements for aerodynamics will further encourage the manufacturers to ensure that they are accurately reflecting the Falt-aero for their entire tractor fleet and that they may do additional F
alt-aero  
determinations beyond the minimum requirement in Phase 2. Without confidence in their F
alt-aero values, 
manufacturers would risk SEA failures that could halt vehicle production. Even without failing the SEA overall, failing 
individual vehicles would lead to increased SEA testing. Thus, the SEA requirements will create a stronger incentive for manufacturers to use good engineering judgment for F
alt-aero values. 
The agencies also received comments 
from HD manufacturers stressing that coastdown testing does not produce C
dA 
values at zero yaw as assumed. Even at calm test conditions, the resulting yaw angle is something greater than zero degrees. The agencies evaluated our aerodynamic test data and agree with the manufacturers. Therefore, we are adopting Phase 2 provisions that use the effective yaw angle from coastdown testing to determine the F
alt-aero value 
(see 40 CFR 1037.525). See RIA Chapter 3.2.2 for additional detail. 
(v) Computational Fluid Dynamics 
The agencies considered refinements 
to the computational fluid dynamics 
(CFD) modeling method to determine the aerodynamic performance of tractors in the NPRM. Specifically, we are considering whether the conditions for performing the analysis require greater specificity (e.g., wind speed and 
direction inclusion, turbulence intensity criteria value) or if turbulence model and mesh deformation should be required, rather than ‘‘if applicable,’’ for all CFD analysis.
305The agencies 
welcomed comment on the proposed revisions. 
Daimler and EMA recommended that 
the agencies should raise the test speed for CFD from the proposed 55 mph to 65 mph to be consistent with GEM and the sleeper cab tractor weighting of 86 percent. Daimler supported the agencies’ other proposed revisions to CFD test procedures. 
The agencies agree with the suggested 
comment to include consistency between the test methods and are adopting CFD provisions that include a test speed of 65 mph, along with the other proposed revisions. The agencies finalized these changes through incorporation of the SAE J2966 CFD guidelines with exceptions and clarifications to keep other aspects of 
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306See 2010 NAS Report, page 95. 
307See 2010 NAS Report, Finding 2–4 on page 39. 
Also see 2014 NAS Report, Recommendation 3.5. 
308See 2010 NAS Report. Page 95. 309See 40 CFR 1037.501(g). 
310See Memo to Docket, Amy Kopin. ‘‘Truck and 
Trailer Roof Match Analysis.’’ August 2010. 
311California Air Resources Board. Tractor-Trailer 
Greenhouse Gas regulation. Last viewed on the CFD simulations consistent with 
Phase 1. 
(vi) Wind Averaged Drag Determination 
In Phase 1, EPA and NHTSA 
recognized that wind conditions, most 
notably wind direction, have a greater impact on real world CO
2emissions and 
fuel consumption of heavy-duty trucks than of light-duty vehicles.
306As noted 
in the NAS report, the wind average drag coefficient is about 15 percent higher than the zero degree coefficient of drag.
307In addition, the agencies 
received comments in Phase 1 that supported the use of wind averaged drag results for the aerodynamic determination. The agencies considered adopting the use of a wind averaged drag coefficient in the Phase 1 regulatory program, but ultimately decided to finalize drag values which represent zero yaw (i.e., representing 
wind from directly in front of the vehicle, not from the side) instead. We took this approach recognizing that the reference method is coastdown testing and it is not capable of determining wind averaged yaw.
308Wind tunnels 
and CFD are currently the only tools to accurately assess the influence of wind speed and direction on a truck’s aerodynamic performance. The agencies recognized, as NAS did, that the results of using the zero yaw approach may result in fuel consumption predictions that are offset slightly from real world performance levels, not unlike the offset we see today between fuel economy test results in the CAFE program and actual fuel economy performance observed in- use. 
As the tractor manufacturers continue 
to refine the aerodynamics of tractors, we believe that continuing the zero yaw approach into Phase 2 would potentially impact the overall technology effectiveness or change the kinds of technology decisions made by the tractor manufacturers in developing equipment to meet our HD Phase 2 standards. Therefore, we proposed and are adopting aerodynamic test procedures that take into account the wind averaged drag performance of tractors. The agencies proposed to account for this change in aerodynamic test procedure by appropriately adjusting the aerodynamic bins to reflect a wind averaged drag result instead of a zero yaw result. 
The agencies proposed and are 
adopting provisions that require manufacturers to adjust their C
dA values to represent a zero yaw value from coastdown and add the C
dA impact of 
the wind averaged drag. The impact of wind averaged drag relative to a zero yaw condition can only be measured in a wind tunnel or with CFD. This requirement commences in MY 2021. 
All stakeholders that commented on 
wind averaged drag supported its use over zero yaw. ACEEE supports the shift to the use of wind averaged drag in Phase 2. Exa supported the use of wind averaged drag because it is a better predictor of real world fuel economy. Michelin supported wind average drag assessments for a realistic and complete assessment of aerodynamic performance and would prevent the unintended consequence of incentivizing improvements that are better at zero wind conditions but sacrifice cross- wind performance. SABIC Innovative Plastics commented that it is imperative that wind effects be part of the standard due to the real-world impact of wind. Plastics Industry Trade Association supported wind average drag to better simulate real life conditions. 
PACCAR and Daimler recommended 
the use of a surrogate angle of 4.5° in 
lieu of the nine angles required for a full wind averaged draft evaluation for CFD evaluated at 65 mph. PACCAR and Daimler provided data to support the use of a single angle. PACCAR also stated that there is significant CFD burden associated with the use of a nine angle yaw sweep. According to PACCAR in a given year, this would add approximately 4,000 additional simulations to their certification burden. EMA and other tractor manufacturers supported the single surrogate angle of 4.5° as being equivalent to the full yaw 
sweep result generated with SAE J1252. 
As discussed in further detail in RIA 
Chapter 3.2.1.1.3, our data support that 4.5° results are a good surrogate for full 
wind averaged drag results for wind tunnel and CFD assessments. Therefore, we are adopting the 4.5° surrogate angle 
in Phase 2. 
The agencies require that 
manufacturers use the following equation to make the necessary adjustments to a coastdown result to obtain the C
dAwavalue: 
CdAwa= C dAeffective yaw angle, coastdown * 
(CdA4.5°/CdAeffective yaw angle ) 
If the manufacturer has a C dA value 
from either a wind tunnel or CFD, then they will use the following equation to obtain the C
dA wad value: 
CdAwa= C dA4.5°* F alt-aero  
Because the agencies are adopting a 
4.5° surrogate angle, the agencies are not 
adopting the proposed provisions that manufacturers have the option of determining the offset between zero yaw and wind averaged yaw either through testing or by using the EPA-defined default offset. 
(vii) Standard Trailer Definition 
Similar to the approach the agencies 
adopted in Phase 1, NHTSA and EPA 
are adopting provisions such that the tractor performance in GEM is judged assuming the tractor is pulling a standardized trailer.
309The agencies 
believe that an assessment of the tractor fuel consumption and CO
2emissions 
should be conducted using a tractor- trailer combination, as tractors are invariably used in combination with trailers and this is their essential commercial purpose. Trailers, of course, also influence the extent of carbon emissions from the tractor (and vice- versa). We believe that using a standardized trailer best reflects the impact of the overall weight of the tractor-trailer and the aerodynamic technologies in actual use, and consequent real-world performance, where tractors are designed and used with a trailer. EPA research confirms what one intuits: Tractor-trailer pairings are almost always optimized, but this does not indicate that a tractor always uses the same trailer. EPA conducted an evaluation of over 4,000 tractor-trailer combinations using live traffic cameras in 2010.
310The results showed that 
approximately 95 percent of the tractors were matched with the standard trailer specified (high roof tractor with dry van trailer, mid roof tractor with tanker trailer, and low roof with flatbed trailer). Therefore, the agencies are continuing the Phase 1 approach into Phase 2 GEM to use a predefined typical trailer in assessing overall performance for test purposes. As such, the high roof tractors will be paired with a standard dry van trailer; the mid roof tractors will be paired with a tanker trailer; and the low roof tractors will be paired with a flatbed trailer. 
However, the agencies proposed a 
change to the definition of the standard dry van reference trailer used by tractor manufacturers to determine the aerodynamic performance of high roof tractors in Phase 2. We believe this is necessary to reflect the aerodynamic improvements experienced by the trailer fleet over the last several years due to influences from the California Air Resources Board mandate
311and EPA’s 
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September 4, 2014 at http://www.arb.ca.gov/
msprog/truckstop/trailers/trailers.htm. 
312Ben Sharpe (ICCT) and Mike Roeth (North 
American Council for Freight Efficiency), ‘‘Costs and Adoption Rates of Fuel-Saving Technologies for Trailer in the North American On-Road Freight Sector,’’ Feb 2014. 
313Frost & Sullivan, ‘‘Strategic Analysis of North 
American Semi-trailer Advanced Technology Market,’’ Feb 2013. 
314See RIA Chapter 2.10.2.1.3. SmartWay Transport Partnership. The 
standard dry van trailer used in Phase 1 to assess the aerodynamic performance of high roof tractors is a 53 foot box trailer without any aerodynamic devices. In the development of Phase 2, the agencies evaluated the increase in adoption rates 
of trailer side skirts and boat tails in the market over the last several years and have seen a marked increase. We estimate that approximately 50 percent of the new trailers sold in 2018 will have trailer side skirts.
312 313 As the 
agencies look towards these tractor standards in the 2021 and beyond timeframe, we believe that it is appropriate to update the standard box trailer definition. In 2021–2027, we believe the trailer fleet will be a mix of trailers with no aerodynamics, trailers with skirts, and trailers with advanced aero; with the advanced aero being a very limited subset of the new trailers sold each year. Consequently, overall, we believe a trailer with a skirt will be the most representative of the trailer fleet for the duration of the regulation timeframe, and plausibly beyond. EPA has conducted extensive aerodynamic testing to quantify the impact on the coefficient of drag of a high roof tractor due to the addition of a trailer skirt. Details of the test program and the results can be found in RIA Chapter 3.2. The results of the test program indicate that on average, the impact of a trailer skirt matching the definition of the skirt specified in 40 CFR 1037.501(g)(1) is approximately eight percent reduction in drag area. 
We proposed a definition of the 
standard dry van trailer in Phase 2—the trailer assumed during the certification process to be paired with a high roof tractor—that includes a trailer skirt starting in 2021 model year. 80 FR 40245. Even though the agencies proposed that new dry van trailer standards begin in 2018 MY, we did not propose to update the standard trailer in the tractor certification process until 2021 MY, to align with the new tractor standards. If we were to revise the standardized trailer definition for Phase 1, then we would have needed to revise the Phase 1 tractor standards. The details of the trailer skirt definition are included in 40 CFR 1037.501(g)(1). We requested comment on our HD Phase 2 
standard trailer configuration. We also welcomed comments on suggestions for alternative ways to define the standard trailer, such as developing a certified computer aided drawing (CAD) model. 
The agencies received support in 
comments for adopting a reference trailer with skirts. Daimler supported the addition of side skirts to the Phase 2 reference trailer and stated that it aligns with their internal development process. Daimler also suggested that if the agencies believe there will be significant adoption of trailers with boat tails, then the agencies could update the C
dA bin value input to GEM and reduce 
it by 0.5 m2to reflect the actual on-road 
aerodynamics load without changing the standard trailer. The Plastics Industry Trade Association stated that the proposed reference trailer is representative of trailer aerodynamic improvements likely to emerge during Phase 2. Navistar suggested that the standard trailer should be more aerodynamic to reflect trailers that will be used during the life of Phase 2 tractors. ACEEE supports the use of a more aerodynamic reference trailer in Phase 2, however, they suggest an even more aerodynamic reference trailer be required that is closer to the aerodynamic packages projected to be installed on new trailers in 2027. ACEEE and UCS suggested that Phase 2 should facilitate the transition of promoting more tractor-trailer integration. ACEEE recommended providing manufacturers the option to test tractors with advanced trailers; correct the test result appropriately to account for the benefit provided by the trailer alone to promote integration of aerodynamically advanced tractors and trailers. UCS raised concerns that because tractors and trailers are interchangeable and that there is no guarantee that the Phase 2 tractors will pull the newest trailers, therefore, the agencies should not revise the standard trailer over the course of the rule. 
The agencies re-evaluated the 
proposal to include trailer skirts on the Phase 2 reference trailer with consideration of the comments. Based on testing conducted to support the trailer portion of Phase 2, we found that on average a boat tail added to a dry van trailer with skirts reduces wind averaged C
dA by 0.6 m2.314We still 
project that the bulk of trailers that will 
be in operation during the life of tractors produced early in Phase 2 will be represented by the aerodynamic performance of a trailer with skirts. Therefore, we are adopting the reference trailer as proposed. However, we also 
want to recognize that the trailer fleet will continue to evolve over the lifetime of tractors built and certified to Phase 2, especially from MY 2027 and later. We recognize that if we do not account for reduced aerodynamic loads in the real world, then we may not be appropriately evaluating the tractor powertrain. We considered changing the standard trailer in MY 2027; however, this would lead to significant testing burden for the manufacturers because they would have to determine new C
dA 
values for their entire fleet of tractors. Instead, we are adopting Phase 2 GEM that beginning in MY 2027 will take the C
dA input for each vehicle and reduce 
it by 0.3 m2to reflect the lower 
aerodynamic loads that are a mix of trailers with skirts and trailers with skirts and boat tails. This change has been accounted for in both the baseline and standard setting of the CO
2 
emissions and fuel consumption values. 
With respect to ACEEE’s 
recommendation for the agencies to facilitate the transition to more integrated tractor-trailers, such as those demonstrated with SuperTruck, the agencies believe this would require a significant change in tractor-trailer logistics to encourage more matching of specific tractors to specific trailers in operation. We believe that this would be most appropriately handled through the Off-Cycle Credit program. 
(viii) Aerodynamic Bins 
The agencies proposed to continue 
the approach where the manufacturer 
would determine a tractor’s aerodynamic drag force through testing, determine the appropriate predefined aerodynamic bin, and then input the predefined C
dA value for that bin into 
the GEM. 80 FR 40245. The agencies’ Phase 2 aerodynamic bins reflect three changes to the Phase 1 bins—the 
incorporation of wind averaged drag, the addition of trailer skirts to the standard box trailer used to determine the aerodynamic performance of high roof tractors (as just explained above), and the addition of bins to reflect the continued improvement of tractor aerodynamics in the future. Because of each of these changes, the aerodynamic bins for Phase 2 are not directly comparable to the Phase 1 bins. 
HD Phase 1 included five 
aerodynamic bins to cover the spectrum of aerodynamic performance of high roof tractors. Since the development of the Phase 1 rules, the manufacturers have continued to invest in aerodynamic improvements for tractors. This continued evolution of aerodynamic performance, both in 
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315Memo to Docket. Aerodynamic Subteam 
Meetings with EMA. July 2016. Docket EPA–HQ– 
OAR–2014–0827. production and in the research stage as 
part of the SuperTruck program, has consequently led the agencies to propose two additional aerodynamic technology bins (Bins VI and VII) for high roof tractors. 
In both HD Phase 1 and Phase 2, 
aerodynamic Bin I through Bin V represent tractors sharing similar levels of technology. The first high roof aerodynamic category, Bin I, is designed to represent tractor bodies which prioritize appearance or special duty capabilities over aerodynamics. These Bin I tractors incorporate few, if any, aerodynamic features and may have several features that detract from aerodynamics, such as bug deflectors, custom sunshades, B-pillar exhaust stacks, and others. The second high roof aerodynamics category is Bin II, which roughly represents the aerodynamic performance of the average new tractor sold in 2010. The agencies developed this bin to incorporate conventional tractors that capitalize on a generally aerodynamic shape and avoid classic features that increase drag. High roof tractors within Bin III build on the basic aerodynamics of Bin II tractors with added components to reduce drag in the most significant areas on the tractor, such as integral roof fairings, side extending gap reducers, fuel tank fairings, and streamlined grill/hood/ mirrors/bumpers, similar to 2013 model year SmartWay tractors. The Bin IV aerodynamic category for high roof tractors builds upon the Bin III tractor body with additional aerodynamic treatments such as underbody airflow treatment, down exhaust, and lowered ride height, among other technologies. HD Phase 1 Bin V tractors incorporate advanced technologies which are currently in the prototype stage of development, such as advanced gap reduction, rearview cameras to replace mirrors, wheel system streamlining, and advanced body designs. For HD Phase 2, the agencies proposed to segment the aerodynamic performance of these advanced technologies into Bins V through VII. 
In Phase 1, the agencies adopted only 
two aerodynamic bins for low and mid roof tractors. The agencies limited the number of bins to reflect the actual range of aerodynamic technologies effective in low and mid roof tractor 
applications. High roof tractors are consistently paired with box trailer designs, and therefore manufacturers can design the tractor aerodynamics as a tractor-trailer unit and target specific areas like the gap between the tractor and trailer. In addition, the high roof tractors tend to spend more time at high speed operation which increases the impact of aerodynamics on fuel consumption and GHG emissions. On the other hand, low and mid roof tractors are designed to pull variable trailer loads and shapes. They may pull trailers such as flat bed, low boy, tankers, or bulk carriers. The loads on flat bed trailers can range from rectangular cartons with tarps, to a single roll of steel, to a front loader. Due to these variables, manufacturers do not design unique low and mid roof tractor aerodynamics but instead use derivatives from their high roof tractor designs. The aerodynamic improvements to the bumper, hood, windshield, mirrors, and doors are developed for the high roof tractor application and then carried over into the low and mid roof applications. As mentioned above, the types of designs that will move high roof tractors from a Bin III to Bins IV through V include features such as gap reducers and integral roof fairings which will not be appropriate on low and mid roof tractors. 
As Phase 2 looks to further improve 
the aerodynamics for high roof sleeper cabs, we believe it is also appropriate to expand the number of bins for low and mid roof tractors too. For Phase 2, the agencies proposed to differentiate the aerodynamic performance for low and mid roof applications with four bins, instead of two, in response to feedback received from manufacturers of low and mid roof tractors related to the limited opportunity to incorporate certain aerodynamic technologies in their compliance plan. However, upon further discussions with EMA, it became evident to the agencies that the most straightforward approach would be to include the same number of low and mid roof aero bins as we have for high roof tractors.
315Therefore, we are 
adopting seven aero bins for low and 
mid roof tractors in Phase 2. In addition, we proposed and are adopting provisions that allow low and mid roof tractor aerodynamic bins to be determined based on the aerodynamic bin of an equivalent high roof tractor, as shown below in Table III–31. 
TABLE III–31—P HASE 2 REVISIONS TO  
40 CFR 1037.520(b)(3) 
High roof bin Low and mid 
roof bin 
Bin I ........................... Bin I. 
Bin II .......................... Bin II. 
Bin III ......................... Bin III. 
Bin IV ........................ Bin IV. 
Bin V ......................... Bin V. 
Bin VI ........................ Bin VI. 
Bin VII ....................... Bin VII. 
The agencies developed new high roof 
tractor aerodynamic bins for Phase 2 that reflect the change from zero yaw to wind averaged drag, the more aerodynamic reference trailer, and the addition of two bins. Details regarding the derivation of the high roof bins are included in RIA Chapter 3.2.1.2. The high roof bin values being adopted in 
the HD Phase 2 final rulemaking differ from those proposed due to the coastdown and other aerodynamic test procedures changes discussed above in Section III.E.2.a. However, as explained above in Section III.D.1, in both the NPRM and this final rulemaking, we developed the Phase 2 bins such that there is an alignment between the Phase 1 and Phase 2 aerodynamic bins after taking into consideration the changes in aerodynamic test procedures and reference trailers required in Phase 2. The Phase 2 bins were developed so that a tractor that performed as a Bin III in Phase 1 would also perform as a Bin III tractor in Phase 2. The high roof tractor bins are defined in Table III–32. The final revisions to the low and mid roof tractor bins reflect the addition of five new aerodynamic bins and are listed in Table III–33. 
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316Southwest Research Institute. ‘‘Heavy Duty 
Class 8 Truck Coastdown and Constant Speed 
Testing.’’ April 2015. TABLE III–32—P HASE 2 AERODYNAMIC INPUT DEFINITIONS TO GEM FORHIGHROOFTRACTORS  
Class 7 Class 8 
Day cab Day cab Sleeper cab 
High roof High roof High roof 
Aerodynamic Test Results (C dAwadin m2) 
Bin I .......................................................................................................................... .................... ≥7.2 ≥7.2 ≥6.9 
Bin II ......................................................................................................................... .................... 6.6–7.1 6.6–7.1 6.3–6.8 
Bin III ........................................................................................................................ .................... 6.0–6.5 6.0–6.5 5.7–6.2 
Bin IV ......................................................................................................................... .................. 5.5–5.9 5.5–5.9 5.2–5.6 
Bin V .......................................................................................................................... .................. 5.0–5.4 5.0–5.4 4.7–5.1 
Bin VI ......................................................................................................................... .................. 4.5–4.9 4.5–4.9 4.2–4.6 
Bin VII ........................................................................................................................ .................. ≤4.4 ≤4.4 ≤4.1 
Aerodynamic Input to GEM (C dAwadin m2) 
Bin I .......................................................................................................................... .................... 7.45 7.45 7.15 
Bin II ......................................................................................................................... .................... 6.85 6.85 6.55 
Bin III ........................................................................................................................ .................... 6.25 6.25 5.95 
Bin IV ......................................................................................................................... .................. 5.70 5.70 5.40 
Bin V .......................................................................................................................... .................. 5.20 5.20 4.90 
Bin VI ......................................................................................................................... .................. 4.70 4.70 4.40 
Bin VII ........................................................................................................................ .................. 4.20 4.20 3.90 
TABLE III–33—P HASE 2 AERODYNAMIC INPUT DEFINITIONS TO GEM FORLOW AND MIDROOFTRACTORS  
Class 7 Class 8 
Day cab Day cab Sleeper Cab 
Low roof Mid roof Low roof Mid roof Low roof Mid roof 
Aerodynamic Test Results (C dA in m2) 
Bin I .......................................................... ≥5.4 ≥5.9 ≥5.4 ≥5.9 ≥5.4 ≥5.9 
Bin II ......................................................... 4.9–5.3 5.5–5.8 4.9–5.3 5.5–5.8 4.9–5.3 5.5–5.8 
Bin III ........................................................ 4.5–4.8 5.1–5.4 4.5–4.8 5.1–5.4 4.5–4.8 5.1–5.4 
Bin IV ....................................................... 4.1–4.4 4.7–5.0 4.1–4.4 4.7–5.0 4.1–4.4 4.7–5.0 
Bin V ........................................................ 3.8–4.0 4.4–4.6 3.8–4.0 4.4–4.6 3.8–4.0 4.4–4.6 
Bin VI ....................................................... 3.5–3.7 4.1–4.3 3.5–3.7 4.1–4.3 3.5–3.7 4.1–4.3 
Bin VII ...................................................... ≤3.4 ≤4.0 ≤3.4 ≤4.0 ≤3.4 ≤4.0 
Aerodynamic Input to GEM (C dA in m2) 
Bin I .......................................................... 6.00 7.00 6.00 7.00 6.00 7.00 
Bin II ......................................................... 5.60 6.65 5.60 6.65 5.60 6.65 
Bin III ........................................................ 5.15 6.25 5.15 6.25 5.15 6.25 
Bin IV ....................................................... 4.75 5.85 4.75 5.85 4.75 5.85 
Bin V ........................................................ 4.40 5.50 4.40 5.50 4.40 5.50 
Bin VI ....................................................... 4.10 5.20 4.10 5.20 4.10 5.20 
Bin VII ...................................................... 3.80 4.90 3.80 4.90 3.80 4.90 
(ix) Selective Enforcement Audits (SEA) 
and Confirmatory Testing for Aerodynamics 
EPA has long required manufacturers 
to perform SEAs to verify that actual production engines and vehicles conform to their certificates. Before this rulemaking, the regulations in 40 CFR 1037.301 provided generally for SEAs for Phase 1 vehicles, but did not provide specific descriptions of how such testing would be conducted for coastdowns. In Phase 1, we adopted interim provisions in 40 CFR 1037.150(k) that accounted for coastdown measurement variability by allowing a compliance demonstration 
based on in-use test results if the drag area was at or below the maximum drag area allowed for the bin above the bin to which the vehicle was certified. Since adoption of Phase 1, EPA has conducted in-use aerodynamic testing and found that uncertainty associated with coastdown testing is less than anticipated.
316In addition, as noted 
earlier in this Section III.E.(2)(a), we 
proposed and are adopting additional enhancements in the Phase 2 coastdown procedures to continue to reduce the 
variability of coastdown results, including the impact of environmental conditions. Therefore, we are sunsetting the provision in 40 CFR 1037.150(k) at the end of the Phase 1 program (after the 2020 model year). In the NPRM, we proposed a conventional approach to conducting SEAs with respect to aerodynamics. See 80 FR at 40156 and proposed section 1037.301. We requested comment on whether or not we should factor in a test variability compliance margin into the aerodynamic test procedure, and 
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317As specified in 40 CFR 1037.305, bin 
boundaries for this determination are expressed to 
two decimal places and adjusted for rounding 
effects. therefore requested data on 
aerodynamic test variability. 
The agencies received comments from 
manufacturers arguing for the agencies to establish compliance margins that would allow actual production vehicles to exceed the standards by some fixed amount. These comments included specific requests for an aerodynamic compliance margin. We also received comments from UCS supporting the elimination of the aerodynamic compliance margin. As explained in Section I.C.1, although EPA sometimes provides interim compliance margins to facilitate the initial implementation of new programs, we generally do not consider such an approach to be an appropriate long-term policy. Nevertheless, EPA recognizes that compliance testing relying on coastdowns to evaluate aerodynamic parameters differs fundamentally from traditional compliance testing, in which test-to-test variability is normally expected to be small relative to production variability. With coastdown testing, however, test-to-test variability is expected to be larger relative to production variability. In response to comments addressing this difference, EPA developed a different structure for conducting SEAs to evaluate tractor C
dA s and solicited supplemental comments 
on it. See 81 FR 10825. This new structure reflects an approach that would be consistent with the following principles: 
•Test-to-test variability for 
individual coastdown runs can be high, so compliance determinations should be based on average values from multiple runs. 
•Coastdown testing of a single 
vehicle is expensive and time consuming, so testing should focus more on repeat tests for the same vehicle than on tests for multiple vehicles. However, manufacturers should not be required to conduct more than 100 valid coastdown runs on any single vehicle. 
•Compliance determinations should 
be based on whether or not the true value for the C
dA falls within the bin to 
which the vehicle was certified, rather than on whether or not the true value 
for the C
dA exceeds the value measured 
for certification. 
•Given the limited ability to 
eliminate uncertainty, compliance determinations should consider the statistical confidence that a true value lies outside a bin. Commenters were generally very 
supportive of these principles and the 
proposed structure. 
We believe the structure being 
finalized appropriately balances EPA’s need to provide strong incentives for manufacturers to act in good faith with manufacturers’ need to avoid compliance actions based on inaccurate testing. Our current assessment is that, where a manufacturer acts in good faith when certifying and uses good engineering judgment throughout the process, false failures for individual vehicles would be rare and false failures for a family would not occur. 
Under this approach, EPA would 
select a production vehicle for coastdown testing, and the manufacturer would be required to perform up to 100 valid coastdown runs to demonstrate whether or not the vehicle was certified to the correct bin. The coastdown results must be adjusted to a yaw angle of 4.5° using an alternate 
aerodynamic method. EPA will address uncertainty in the measurement using a confidence interval around the mean C
dA value, where the confidence 
interval will be calculated from the standard deviation of the C
dA values (s) 
and the number of runs (n) according to the following equation: 
For example, the result of the testing 
could be a C dA value of 5.90 ± 0.09, 
which would fall entirely within Bin III 
for high roof sleeper cabs.317If the 
vehicle had been certified to Bin III or lower, this would be considered a passing test. If it had been certified to Bin IV or higher, this would be considered a failing test. For each vehicle that fails, the manufacturer would be required to test two additional vehicles up to a maximum of 11 vehicles. Manufacturers would have the option to select the same vehicle configuration, or they could choose to have EPA select another configuration within the family. It is appropriate to allow manufacturers the opportunity to retest the same failed configurations because they would only do so where there had reasonable confidence that the failure did not accurately reflect the true value. The regulations require that 
manufacturers continue testing until the 
results are clearly either above or below the applicable bin boundary (i.e., the 
confidence interval does not cross the boundary), or until 100 runs are completed. By making the confidence interval a function of the number of runs, it will generally become smaller as 
additional runs are completed, so that it would be increasingly likely to have a clear result as additional runs are completed. Nevertheless, there may be some cases where the results are close enough to the bin boundary that the confidence interval still crosses the boundary after 100 runs, meaning the true C
dA value could be slightly above 
or slightly below the bin boundary. The regulations will treat these results as passing. 
It is important to note that, although 
SEAs are directed by EPA, the actual testing is conducted by the manufacturer at their chosen facilities. This minimizes many potential causes of test variability, such as differences in test trailers, test tracks, or instrumentation. Thus confidence intervals need only reflect true test-to- test variability. Also, manufacturers generally rent facilities for coastdown testing as needed, which means EPA will need to provide some advance notice to allow the manufacturer to reserve the appropriate facility. 
In selecting the original configuration 
and subsequent selections, EPA would likely consider vehicles with measured C
dA values near the top of the bin since 
they could be most the likely to be mis- certified based on inaccurate results. However, EPA could select any configuration. For subsequent testing if the first vehicle fails, manufacturers would be allowed to retest the same configuration (but not the same exact vehicle). EPA believes this would not decrease the risk of failure for subsequent vehicles, but could allow a manufacturer the opportunity to show its design was actually compliant. 
With respect to confirmatory testing, 
which is testing EPA conducts during certification rather than during production, EPA has generally 
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318Oakridge National Laboratory. Transportation 
Energy Book, Edition 33. Table 5.10 Effect of 
Terrain on Class 8 Truck Fuel Economy. 2014. Last accessed on September 19, 2014 at http://cta.ornl.gov/data/Chapter5.shtml. 
319Ibid. 
320Reinhart, T. (February 2016). Commercial 
Medium- and Heavy-Duty (MD/HD) Truck Fuel Efficiency Technology Study—Report #2. Washington, DC: National Highway Traffic Safety Administration. EPA–HQ–OAR–2014–0827–1623. 321National Academy of Science. ‘‘Reducing the 
Fuel Consumption and GHG Emissions of Medium- 
and Heavy-Duty Vehicles, Phase Two, First Report.’’ 2014. Recommendation S.3 (3.6). 
322See NREL Report ‘‘EPA Road Grade profiles’’ 
for DOE–EPA Interagency Agreement to Refine Drive Cycles for GHG Certification of Medium- and Heavy-Duty Vehicles, IA Number DW–89– 92402501. 323Southwest Research Institute. ‘‘GEM 
Validation,’’ Technical Research Workshop 
supporting EPA and NHTSA Phase 2 Standards for MD/HD Greenhouse Gas and Fuel Efficiency— December 10 and 11, 2014. Can be accessed at http://www3.epa.gov/otaq/climate/regs-heavy- duty.htm. considered its test results to be the 
official test results. However, we recognize that we need to treat confirmation of a manufacturer’s F
alt-aero  
differently because small changes in its value would be spread over an entire family. Therefore, EPA is adopting an interim provision that would apply the SEA confidence interval approach for confirmatory testing with respect to F
alt-aero . EPA would also attempt to use 
the same test trailers, test locations, and instrumentation that the manufacturer. Nevertheless, we expect to revisit this issue in the future. 
(b) Road Grade in the Drive Cycles 
Road grade can have a significant 
impact on the overall fuel economy of 
a heavy-duty vehicle. Table III–34 shows the results from a real world evaluation of heavy-duty tractor-trailers conducted by Oak Ridge National Lab.
318The study found that the impact 
of a mild upslope of one to four percent led to a decrease in average fuel economy from 7.33 mpg to 4.35 mpg. These results are as expected because vehicles consume more fuel while driving on an upslope than driving on a flat road because the vehicle needs to exert additional power to overcome the grade resistance force.
319The amount of 
extra fuel increases with increases in road gradient. On downgrades, vehicles consume less fuel than on a flat road. However, as shown in the fuel consumption results in Table III–34, the amount of increase in fuel consumption on an upslope is greater than the amount of decrease in fuel consumption on a downslope which leads to a net increase in fuel consumption. As an example, the data show that a vehicle would use 0.3 gallons per mile more fuel in a severe upslope than on flat terrain, but only save 0.1 gallons of fuel per mile on a severe downslope. In another study, Southwest Research Institute modeling found that the addition of road grade to a drive cycle has an 8 to 10 percent negative impact on fuel economy.
320 TABLE III–34—F UELCONSUMPTION  
RELATIVE TO ROADGRADE  
Type of terrain Average 
fuel 
economy 
(miles per 
gallon) Average 
fuel 
consumption 
(gallons per 
mile) 
Severe upslope (>4%) .. 2.90 0.34 
Mild upslope (1% to 4%) 4.35 0.23 
Flat terrain (1% to 1%) .. 7.33 0.14 
Mild downslope (¥4% 
to ¥1%) ..................... 15.11 0.07 
Severe downslope 
(≤4%) ......................... 23.50 0.04 
In Phase 1, the agencies did not 
include road grade. However, we 
believe it is important to include road grade in Phase 2 to properly assess the value of technologies, such as downspeeding and the integration of the engine and transmission, which were not technologies included in the technology basis for Phase 1 and are not directly assessed by GEM in its Phase 1 iteration. The addition of road grade to the drive cycles is consistent with the NAS recommendation in the 2014 Phase 2 First Report.
321 
The U.S. Department of Energy and 
EPA partnered to support a project to develop the appropriate road grade profiles for the 55 mph and 65 mph highway cruise duty cycles that will be used in the certification of heavy-duty vehicles to the Phase 2 final GHG emission and fuel efficiency standards. The National Renewable Energy Laboratory (NREL) was contracted to do this work and has developed a database of activity-weighted percent road grades representative of U.S. limited-access highways. To this end, NREL used high- accuracy road grade data and county- specific vehicle miles traveled data. A report documenting this NREL work is in the public docket for these final rules.
322 
In the Phase 2 proposal, the agencies 
developed an interim road grade profile and provided information in the docket on two NREL-derived road grade profiles. The agencies proposed the inclusion of an interim road grade profile, in both the 55 mph and 65 mph cycles. The grade profile was developed by Southwest Research Institute on a 12.5 mile stretch of restricted-access highway during on-road tests conducted for EPA’s validation of the Phase 2 version of GEM.
323The agencies also 
included an additional road grade 
profile as part of the Notice of Data Availability (81 FR at 10825). The agencies sought comment on all of the road grade profiles. 
Cummins supported the development 
of road grade and stated that the proposed road grade with ±2 percent 
did not reflect their assessment of the distribution of North American roads with a distribution of road grades of ±6 percent. ACEEE supported inclusion of road grade. Daimler, Navistar, EMA, Volvo, and Eaton commented that the road grade profile presented in the NODA were too steep and did not represent real world driving. Their primary concern was related to the fraction of time the engine spent at full load for various vehicle configurations. 
According to the manufacturers, the road grade cycle presented in GEM in the NODA spent too high of a fraction of time at full load. 
After considering the road grade 
profile comments and using the NREL database, the agencies have independently developed a road grade profile for the final rules for use in the 55 mph and 65 mph highway cruise duty cycles for the Phase 2 final rulemaking. While based on the same road grade database generated by NREL for U.S. restricted-access highways, its design is predicated on a different approach. The development of this profile is documented in the RIA Chapter 3.4.2.1. The road grade in the final rules includes a stretch with zero percent grade and lower peak grades than the profile presented in the NODA. The minimum grade in the final cycle is –5 percent and the maximum grade is 5 percent. The cycle spends 46 percent of the distance in grades of ± 0.5 
percent. Overall, the cycle spends approximately 66 percent of the time in relatively flat terrain with road gradients of ± 1 percent. A detailed discussion of 
the road grade profile is included in RIA Chapter 3.4.2.1. 
(c) Heavy-Haul Provisions 
The agencies proposed that heavy- 
haul tractors demonstrate compliance 
with the standards using the day cab drive cycle weightings of 19 percent transient cycle, 17 percent 55 mph cycle, and 64 percent 65 mph cycle. We also proposed that GEM simulates the heavy-haul tractors with a payload of 43 
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324North American Council for Freight 
Efficiency. ‘‘Confidence Findings on the Potential of 
6x2 Axles.’’ 2014. Page 16. tons and a total tractor, trailer, and 
payload weight of 118,500 lbs. In addition, we proposed that the engines installed in heavy-haul tractors meet the tractor engine standards included in 40 CFR 1036.108. We welcomed comments on these specifications. 
Volvo does not agree with the 
proposal that the engine installed in a heavy-haul tractor must meet the tractor engine standard defined in 40 CFR 1036.108. As discussed below in Section III.E.2.i, we have modified 40 CFR 1037.601(a)(1) in this final rulemaking to remove the prohibition of using vocational engines in tractors. 
(d) Weight Reduction 
In Phase 1, the agencies adopted 
regulations that provided manufacturers 
with the ability to use GEM to measure emission reduction and reductions in fuel consumption resulting from use of high strength steel and aluminum components for weight reduction, and to do so without the burden of entering the curb weight of every tractor produced. We treated such weight reduction in two ways in Phase 1 to account for the fact that combination tractor-trailers weigh-out approximately one-third of the time and cube-out approximately two-thirds of the time. Therefore, one-third of the weight reduction is added payload in the denominator while two-thirds of the weight reduction is subtracted from the overall weight of the vehicle in GEM. See 76 FR 57153. The agencies also allowed manufacturers to petition for off-cycle credits for components not measured in GEM. 
NHTSA and EPA proposed to carry 
the Phase 1 treatment of weight reduction into Phase 2. That is, these types of weight reduction, although not part of the agencies’ technology packages for the final standards, can still be recognized in GEM up to a point. In addition, the agencies proposed to add additional thermoplastic components to the weight reduction table. The thermoplastic component weight reduction values were developed in coordination with SABIC, a thermoplastic component supplier. Also, in Phase 2, we proposed to recognize the potential weight reduction opportunities in the powertrain and drivetrain systems as part of the vehicle inputs into GEM. Therefore, we believe it is appropriate to also recognize the weight reduction associated with both smaller engines and 6x2 axles.
324We 
welcomed comments on all aspects of weight reduction. 80 FR 40249. 
Several organizations suggested 
changes to specific weights proposed in the NPRM. The Aluminum Association cited several additional advancements in the aluminum industry and stated that the proposed table is appropriate when these components are considered for substitution on an individual basis. Aluminum Association also asked the agencies to add a 500 pound weight reduction for switching from steel to aluminum tractor cabs, among other components. Meritor supported the inclusion and expansion of the weight reduction technologies in the NPRM. Meritor suggested the aluminum carriers illustrate consistent weight reductions of 60 pounds for the rear-front-drive axle, 35 pounds for the rear-rear-drive axle and therefore 95 pounds for the tandem. Based on their data, Meritor recommends that a 42 pound weight savings be credited per tractor for using High-Strength steel drums on the steer (non-drive) axle and 74 pound per vehicle for 6x4 drive axle applications. Meritor anticipates the availability of an aluminum version of a brake bracket in the timeframe of the regulation which will provide a calculated per vehicle weight savings of 36 pounds for a 6x4 configuration. Meritor believes that weight savings should be credited for the use of single-piece drivelines in excess of 86″ because today, most 
drivelines in excess of 86″ are two piece. 
American Iron and Steel Institute commented that light weight values for high strength steel should be adjusted upward in the FRM, citing light duty vehicle weight reduction approaches using high strength steel and saying these improvements should apply to the heavy-duty sector as well. Daimler commented that increased credit should be given to hoods and fairings for the difference between steel and thermoplastic, but no specific values were provided. PACCAR recommends that the agencies broaden the definition of ‘‘composite’’ to include materials other than thermoplastics, including thermoplastics, thermosets, and fiber reinforced plastics. 
Some organizations commented 
against including some or all light- weight components for compliance with the tractor standards. American Iron and Steel Institute commented against the inclusion of any light-weight components as a compliance mechanism for tractors unless improved technical data to support the weight saving values are used. Daimler commented that the weight reduction values for engines less than 15 liters are arbitrary. Allison commented that the agencies should establish weight penalties for components that increase weight, and they used the example of MT/AMT with countershaft architectures. 
We have expanded the list of weight 
reduction technologies for some steel and aluminum components for the final rule based on information provided in the comments. We did not adopt weight reduction values for some components, such as an axle carrier, because we are not confident that this is not double counting the weight reduction of the axles already provided in the regulations. We also did not adopt weight reduction values for technologies still in development, such as aluminum brake brackets. The agencies are not finalizing a weight penalty for any components since this would require detailed information on conventional and light-weight tractor components to establish a baseline and the weight reduction potential for each component. In addition, we are not broadening the definition of composite at this time to include materials other than thermoplastics because the specific weight reduction values in the table are specific to thermoplastics. We are adopting the values listed in Table III– 35 and Table III–36 and making them available upon promulgation of the final Phase 2 rules (i.e., available even under 
Phase 1). Additional weight reduction would be evaluated as a potential off- cycle credit. 
TABLE III–35—P HASE 2 W EIGHT REDUCTION TECHNOLOGIES FOR TRACTORS  
Weight reduction technology Weight reduction 
Wide-Based Single Drive Tire with: 
Steel Wheel ............................................................................................................................................................. 84 lbs. per wheel/tire set. 
Aluminum Wheel/Aluminum Alloy Wheel ................................................................................................................ 147 lbs. per wheel/tire set. 
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325Kenworth. ‘‘Kenworth T680 with PACCAR 
MX–13 Engine Lowers Costs for Oregon Open-Deck 
Carrier.’’ Last viewed on December 16, 2014 at http://www.kenworth.com/news/news-releases/2013/december/t680-cotc.aspx. TABLE III–35—P HASE 2 W EIGHT REDUCTION TECHNOLOGIES FOR TRACTORS —Continued 
Weight reduction technology Weight reduction 
Wide-Based Single Trailer Tire with: 
Steel Wheel ............................................................................................................................................................. 84 lbs. per wheel/tire set. 
Aluminum Wheel/Aluminum Alloy Wheel ................................................................................................................ 131 lbs. per wheel/tire set. 
Steer Tire or Dual Wide Drive Tire with: 
High Strength Steel Wheel ...................................................................................................................................... 8 lbs. per wheel. 
Aluminum Wheel/Aluminum Alloy Wheel ................................................................................................................ 25 lbs. per wheel. 
Weight reduction technologies Steel 
(lb.) Aluminum 
weight 
reduction 
(lb.) High 
strength 
steel weight 
reduction 
(lb.) Thermoplastic 
weight 
reduction 
(lb.) 
Door (per door) ................................................................................................ ................ ........ 20 6 ........................
Roof (per vehicle) ............................................................................................ ................. ....... 60 18 ........................
Cab rear wall (per vehicle) .............................................................................. ...................... .. 49 16 ........................
Cab floor (per vehicle) ..................................................................................... ................... ..... 56 18 ........................
Hood (per vehicle) ........................................................................................... .................. ...... 55 17 ........................
Hood Support Structure (per vehicle) .............................................................. ........................ 15 3 ........................
Hood and Front Fender (per vehicle) .............................................................. ........................ ...... .................. ........................ 65 
Day Cab Roof Fairing (per vehicle) ................................................................. ........................ .... .................... ........................ 18 
Sleeper Cab Roof Fairing (per vehicle) ........................................................... ........................ 75 20 40 
Aerodynamic Side Extender (per vehicle) ....................................................... ........................ ......... ............... ........................ 10 
Fairing Support Structure (per vehicle) ........................................................... ........................ 35 6 ........................
Instrument Panel Support Structure (per vehicle) ........................................... ........................ 5 1 ........ ................
Brake Drums—Drive (per 4) ............................................................................ ........................ 140 74 ........................
Brake Drums—Non Drive (per 2) .................................................................... ........................ 60 42 ........................
Frame Rails (per vehicle) ................................................................................ ...................... .. 440 87 ........................
Crossmember—Cab (per vehicle) ................................................................... ........................ 15 5 .. ......................
Crossmember—Suspension (per vehicle) ....................................................... ........................ 25 6 ....... .................
Crossmember—Non Suspension ( per 3) ....................................................... ........................ 15 5 ........ ................
Fifth Wheel (per vehicle) ................................................................................. ..................... ... 100 25 ........................
Radiator Support (per vehicle) ........................................................................ ........................ 20 6 ........................
Fuel Tank Support Structure (per vehicle) ...................................................... ........................ 40 12 .. ......................
Steps (per vehicle) ........................................................................................... ................. ....... 35 6 ........................
Bumper (per vehicle) ....................................................................................... .................... .... 33 10 ........................
Shackles (per vehicle) ..................................................................................... .................... .... 10 3 ........................
Front Axle (per vehicle) ................................................................................... .................... .... 60 15 ........................
Suspension Brackets, Hangers (per vehicle) .................................................. ........................ 100 30 .... ....................
Transmission Case (per vehicle) ..................................................................... ........................ 50 12 ........................
Clutch Housing (per vehicle) ........................................................................... ........................ 40 10 ........................
Drive Axle Hubs (per 4) ................................................................................... ..................... ... 80 20 ........................
Non Drive Front Hubs (per 2) .......................................................................... ........................ 40 5 ........................
Single Piece Driveline (for drivelines longer than 86″) ................................... 43 63 43 ........................
Driveshaft (per vehicle) .................................................................................... ................... ..... 20 5 ........................
Transmission/Clutch Shift Levers (per vehicle) ............................................... ........................ 20 4 ..... ...................
TABLE III–36—P HASE 2 W EIGHT RE-
DUCTION VALUES FOR OTHER COM-
PONENTS  
Weight reduction technology Weight 
reduction 
(lb) 
6x2 axle configuration in tractors 300 
4x2 axle configuration in Class 8 
tractors .................................... 300 
Tractor engine with displacement 
less than 14.0L .......................325300 
(e) GEM Inputs 
The agencies proposed to continue to 
require the Phase 1 GEM inputs for tractors in Phase 2. These inputs 
include the following: 
•Steer tire rolling resistance, 
•Drive tire rolling resistance, 
•Coefficient of Drag Area, 
•Idle reduction, 
•Weight reduction, and 
•Vehicle Speed Limiter. 
As discussed above in Section II.C 
and III.D, there are several additional inputs that we are adopting for Phase 2. The majority of these new inputs are the same as proposed, with the addition of two new optional inputs to account for transmission and axle efficiency improvements in response to comments. The new GEM inputs for Phase 2 include the following: 
•Engine information including 
manufacturer, model, combustion type, fuel type, family name, and calibration identification, •Engine steady state and cycle 
average fuel maps, 
•Engine full-load torque curve, 
•Engine motoring curve, 
•Transmission information including 
manufacturer and model, 
•Transmission type, 
•Transmission gear ratios, 
•Transmission loss map (optional), 
•Drive axle(s) ratio, 
•Axle power loss map (optional), 
•Tire size (revolutions per mile) for 
drive tires, and 
•Other technology inputs. 
(f) Vehicle Speed Limiter Provisions 
The agencies received comments 
during the development of Phase 1 that the Clean Air Act provisions to prevent tampering (CAA section 203(a)(3)(A)) of vehicle speed limiters and extended idle reduction technologies would prohibit 
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their use for demonstrating compliance 
with the Phase 1 standards. In Phase 1, the agencies adopted provisions to allow for discounted credits for idle reduction technologies that allowed for override conditions and expiring engine shutdown systems (see 40 CFR 1037.660). Similarly, the agencies adopted provisions to allow for ‘‘soft top’’ speeds and expiring vehicle speed limiters, and we did not propose to change those provisions (see 40 CFR 1037.640). However, as we developed Phase 2, we understood that the concerns still exist that the ability for a tractor manufacturer to reflect the use of a VSL in its compliance determination may be constrained by the demand for flexibility in the use of VSLs by the customers. The agencies welcomed suggestions on how to close the gap between the provisions that would be acceptable to the industry while maintaining our need to ensure that modifications do not violate section 203(a)(3)(A). We requested comment on potential approaches which would enable a feedback mechanism between the vehicle owner/fleet that would provide the agencies the assurance that the benefits of the VSLs will be seen in use but would also provide the vehicle owner/fleet the flexibility they may need during in-use operation. More generally, in our discussions with several trucking fleets and with the American Trucking Associations, an interest was expressed by the fleets if there was a means by which they could participate in the emissions credit transactions that are currently limited to the directly regulated truck manufacturers. VSLs were an example technology that fleets and individual owners can order for a new build truck, and for which, from the fleets’ perspective, the truck manufacturers receive emission credits. The agencies did not have a specific suggestion in the Phase 2 NPRM or a position on the request from the American Trucking Association and its members, but we requested comment on whether or not it is appropriate to allow owners to participate in the overall compliance process for the directly regulated parties, if such a thing is allowed under the two agencies’ respective statutes, and what regulatory provisions would be needed to incorporate such an approach. 80 FR 40250. 
The agencies received comments 
regarding VSLs. ATA commented that the agencies should recognize in GEM VSLs set at speeds less than the speed limit mandated if a rule is adopted by NHTSA and FMCSA. ATA also suggested that the agencies should explore ways of incorporating the in-use benefits being derived from VSLs, such as allowing manufacturers to accept a purchaser’s commitment to establish a maximum limited speed, as opposed to the tamper-proof option, when acknowledged and affirmed on a vehicle’s purchase agreement. ATA also suggested that the agencies allow manufacturers to adjust VSLs at the end of a vehicle’s lease or trade-in and allow the creation of deficits or credits if such adjustments affect the initial VSL effectiveness that was generated and allow trucking companies to adjust maximum speeds if company policies change during the ownership cycle with corresponding adjustment to manufacturer credits. CARB stated it is not clear what fleet owners would do with Phase 2 credits and allowing fleet owners to garner such credits would unnecessarily complicate implementation and enforcement of the Phase 2 program. As a result, CARB staff recommends not including owners in emission credit transactions for VSL installation. Daimler suggested that they report in their 270 day end of year report the number of VSLs that remain active. Daimler recommends that the agencies provide in GEM reduced effectiveness for non-regulatory VSLs in proportion to the fraction of non- regulatory ones that remained unaltered, based upon their study of their database. Volvo commented that approximately 15 percent of tractors built over 2013– 2015 were shipped with their programmable road speed limiters set at less than 65 mph from the factory and 47 percent were reported in use with the same setting, even during a period of very low fuel prices. Volvo Group requests that the agencies consider providing an effectiveness value in GEM for reprogrammable speed limiters set at the factory at, or below 65 mph. UPS commented that instead of tamperproof VSLs, they would support a regulatory approach in which the fleet owner can adjust speed settings, but only if certified personnel make these changes and their activities within the ECIVIs are trackable and fully accountable to proper authorities. 
The agencies considered the 
comments and the compliance burden associated with the suggestions. The agencies also considered DOT’s upcoming actions with respect to mandatory vehicle speed limiters for heavy-duty trucks. The existing Phase 1 VSL flexibilities provide opportunities for manufacturers to use VSL as a technology in GEM while still allowing the settings to change after an ‘‘expiration’’ time determined by the manufacturer. At this time, we believe 
that the Phase 1 flexibilities sufficiently balance the desire to encourage technologies that reduce GHG emissions and fuel consumption while minimizing the compliance burden of trying to accommodate changes throughout the useful life of the vehicle. Therefore, the agencies are not adopting any new VSL provisions for Phase 2 and the Phase 1 provisions will continue (see 40 CFR 1037.640). 
(g) Emission Control Labels 
The agencies consider it crucial that 
authorized compliance inspectors are 
able to identify whether a vehicle is certified, and if so whether it is in its certified condition. To facilitate this identification in Phase 1, EPA adopted labeling provisions for tractors that included several items. The Phase 1 tractor label must include the manufacturer, vehicle identifier such as the Vehicle Identification Number (VIN), vehicle family, regulatory subcategory, date of manufacture, compliance statements, and emission control system identifiers (see 40 CFR 1037.135). In Phase 1, the emission control system identifiers are limited to vehicle speed limiters, idle reduction technology, tire rolling resistance, some aerodynamic components, and other innovative and advanced technologies. 
The number of emission control 
systems for greenhouse gas emissions in Phase 2 has increased significantly. For example, all aspects of the engine transmission and drive axle; accessories; tire radius and rolling resistance; wind averaged drag; predictive cruise control; idle reduction technologies; and automatic tire inflation systems are controls that can be evaluated on-cycle in Phase 2 (i.e. these technologies’ 
performance can now be input to GEM), but could not be in Phase 1. Due to the complexity in determining greenhouse gas emissions as in Phase 2, the agencies do not believe that we can unambiguously determine whether or not a vehicle is in a certified condition through simply comparing information that could be made available on an emission control label with the components installed on a vehicle. 
Therefore, EPA proposed to remove the requirement to include the emission control system identifiers required in 40 CFR 1037.135(c)(6) and in Appendix III to 40 CFR part 1037 from the emission control labels for vehicles certified to the Phase 2 standards. However, the agencies requested comment on the appropriate content that would properly balance the need to limit label content with the interest in providing the most useful information for inspectors to 
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confirm that vehicles have been 
properly built. The agencies received comments on the emission control labels. Navistar supported the elimination of the emission control information from the vehicle GHG label. After considering the comments, EPA is finalizing the proposed tractor labeling requirements. Nevertheless, as described below we remain interested in finding a better approach for labeling. 
Under the agencies’ existing 
authorities, manufacturers must provide detailed build information for a specific vehicle upon our request. Our expectation is that this information should be available to us via email or other similar electronic communication on a same-day basis, or within 24 hours of a request at most. The agencies have started to explore ideas that would provide inspectors with an electronic method to identify vehicles and access on-line databases that would list all of the engine-specific and vehicle-specific emissions control system information. We believe that electronic and Internet technology exists today for using scan tools to read a bar code or radio frequency identification tag affixed to a vehicle that could then lead to secure on-line access to a database of manufacturers’ detailed vehicle and engine build information. Our exploratory work on these ideas has raised questions about the level of effort that would be required to develop, implement and maintain an information technology system to provide inspectors real-time access to this information. We have also considered questions about privacy and data security. We requested comment on the concept of electronic labels and database access, including any available information on similar systems that exist today and on burden estimates and approaches that could address concerns about privacy and data security. Based on new information that we receive, we stated in the NPRM that we may consider initiating a separate rulemaking effort to propose and request comment on implementing such an approach. 
(h) End of Year Reports 
In the Phase 1 program, 
manufacturers participating in the ABT 
program provided 90 day and 270 day reports to EPA and NHTSA after the end of the model year. The agencies adopted two reports for the initial program to help manufacturers become familiar with the reporting process. For the HD Phase 2 program, the agencies proposed to simplify reporting such that manufacturers would only be required to submit the final report 90 days after the end of the model year with the potential to obtain approval for a delay 
up to 30 days. We requested comments on this approach. EMA, PACCAR, Navistar, Daimler, and Cummins recommended keeping the 270 day report to allow sufficient time after the production period is completed. We are accordingly keeping both the 90 day and 270 day reports, with the ability of the agencies to waive the 90 day report. 
(i) Other Compliance Provisions 
In Phase 2, the agencies are adopting 
provisions to evaluate the performance 
of the engine, transmission, and drivetrain in determining compliance with the Phase 2 tractor standards. With the inclusion of the engine’s performance in the vehicle compliance, EPA proposed to modify the prohibition to introducing into U.S. commerce a tractor containing an engine not certified for use in tractor (see proposed 40 CFR 1037.601(a)(1)). During development of the Phase 2 NPRM, we no longer saw the need to prohibit the use of vocational engines in tractors because the performance of the engine would be appropriately reflected in GEM. We welcomed comments on removing this prohibition. 
The agencies received comments 
supporting the proposed approach. PACCAR supports removing the prohibition on the installation of vocational engines into tractors where these engines are appropriate for the customer’s application. Daimler agreed with the proposal that with the engine properly represented in GEM, there is less need for the prohibition on vocational-only certified engines in tractors and that the true in-vehicle emissions are represented by the full- vehicle standard. Accordingly, we are modifying 40 CFR 1037.601(a)(1) in this final rulemaking to remove the prohibition of using vocational engines in tractors. 
The agencies also proposed to change 
the compliance process for 
manufacturers seeking to use the off- road exclusion. During the Phase 1 program, manufacturers realized that contacting the agencies in advance of the model year was necessary to determine whether vehicles would qualify for exemption and need approved certificates of conformity. The agencies found that the petition process allowed at the end of the model year was not necessary and that an informal approval during the precertification period was more effective. Therefore, NHTSA proposed to remove its off-road petitioning process in 49 CFR 535.8 and EPA proposed to add requirements for informal approvals in 40 CFR 1037.610. The agencies did not receive any comments regarding the petition 
process. We are adopting the Phase 2 provisions as proposed. 
In Phase 1 and as proposed in Phase 
2, the agencies allow manufacturers to certify vehicles into a higher service class. No credits can be generated from vehicles certified to the higher service class, but any deficit produced must be offset by credits generated from other vehicles within the higher service class. Though the agencies did not propose any changes, we received comments on the treatment of 4x2 tractors. EMA and the manufacturers suggest that tractors with a 4x2 axle configuration and a heavy heavy-duty engine should be classified as a Class 8 tractor regardless of GVWR and be included in the Class 8 averaging set. Navistar and EMA stated that these vehicles are typically purchased to pull multiple trailers, even though the GVWR is less than 33,000 pounds. In the agencies’ assessment, we agree with the manufacturers that these vehicles resemble Class 8 work and due to the higher useful life requirements, we are adopting provisions into the Phase 2 regulations that gives all manufacturers the option to classify Class 7 tractors with 4x2 axle configurations as Class 8 tractors. 
(j) Chassis Dynamometer Testing 
Requirement 
The agencies foresee the need to 
continue to track the progress of the Phase 2 program throughout its implementation. As discussed in Section II, the agencies expect to evaluate the overall performance of tractors with the GEM results provided by manufacturers through the end of year reports. However, we also need to continue to have confidence in our simulation tool, GEM, as the vehicle technologies continue to evolve. Therefore, EPA proposed that the manufacturers conduct annual chassis 
dynamometer testing of three sleeper cab tractors and two day cab tractors and provide the data and the GEM result from each of these tractor configurations to EPA (see 40 CFR 1037.665). 80 FR 40251. We requested comment on the costs and efficacy of this data submission requirement. 
In response, the agencies received 
mixed comments supporting and raising concerns about the proposed chassis test requirements. ACEEE and ICCT supported the proposal to conduct annual chassis testing to verify the relative reductions simulated in GEM and suggested that the results be provided to the public. UCS supported the proposal, similar to ACEEE and ICCT, with the additional suggestion to conduct an over the road testing of 
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select vehicles under real world 
conditions. EMA, Daimler, Volvo, PACCAR, and Navistar commented that they support auditing, but the proposed chassis testing is burdensome with few facilities available and will not achieve the agencies’ stated goal of validating GEM’s measure trends in the real world. Daimler and Navistar also stated that chassis dyno testing cannot replicate the real-world conditions for many technologies, such as tire pressure monitoring systems, intelligent coasting on grades, predictively adjusting vehicle speed on hills, adapting ride height at speed, using advanced cooling system controls, etc. Volvo raised concerns about the chassis test results due to driver variability, accessory loads, and the need to simulate road loads that comprise around 90 percent of the vehicle load in tractor cycles. Volvo and Daimler noted that without separate tests to quantify the aerodynamics and rolling resistance, which accounts for a significant majority of the vehicle losses, the chassis test essentially only evaluates the powertrain and therefore recommended powertrain testing for this purpose over a chassis test. The manufacturer’s suggested that EPA conduct the testing or work collaboratively to develop an in-use research program. Navistar commented that if the provision remains for the final rule, then it be limited to one vehicle in 2021, 2024, and 2027 model year. Navistar also suggested that the final requirements do not include the proposed measurement of gaseous emissions due to the additional cost burden. 
After consideration of the comments, 
the agencies are requiring tractor manufacturers to annually chassis test five production vehicles over the GEM cycles to verify that relative reductions simulated in GEM are being achieved in actual production. See 40 CFR 1037.665. We do not expect absolute correlation between GEM results and chassis testing. GEM makes many simplifying assumptions that do not compromise its usefulness for certification, but do cause it to produce emission rates different from what would be measured during a chassis dynamometer test. Given the limits of correlation possible between GEM and chassis testing, we would not expect such testing to accurately reflect whether a vehicle was compliant with the GEM standards. Therefore, we are not applying compliance liability to such testing. Rather, this testing will be for informational purposes only. However, we do expect there to be correlation in a relative sense. Vehicle to vehicle differences showing a 10 percent improvement in GEM should 
show a similar percent improvement with chassis dynamometer testing. Nevertheless, manufacturers will not be subject to recall or other compliance actions if chassis testing did not agree with the GEM results on a relative basis. Rather, the agencies will continue to evaluate in-use compliance by verifying GEM inputs and testing in-use engines. (Note that NTE standards for criteria pollutants may apply for some portion of the test cycles.) 
EPA believes this chassis test program 
is necessary because of our experience implementing regulations for heavy- duty engines. In the past, manufacturers have designed engines that have much lower emissions on the duty cycles than occur during actual use. The recent experience with Volkswagen is an unfortunate instance. By using this 
simple test program, we hope to be able to identify such issues earlier and to dissuade any attempts to design solely to the certification test. We also expect the results of this testing to help inform the need for any further changes to GEM. 
As already noted in Section II.B.(1), it 
can be expensive to build chassis test cells for certification. However, EPA has structured this pilot-scale program to minimize the costs. First, this chassis testing will not need to comply with the same requirements as will apply for official certification testing. This will allow testing to be performed in developmental test cells with simple portable analyzers. Second, since the program will require only five tests per year, manufacturers without their own chassis testing facility will be able to contract with a third party to perform the testing. Finally, EPA is applying this testing to only those manufacturers with annual production in excess of 20,000 vehicles. 
F. Flexibility Provisions 
EPA and NHTSA are adopting two 
flexibility provisions specifically for 
heavy-duty tractor manufacturers in Phase 2. These are an averaging, banking and trading program for CO
2 
emissions and fuel consumption credits, as well as provisions for credits for off- cycle technologies which are not included as inputs to the GEM. Credits generated under these provisions can only be used within the same averaging set that generated the credit. 
The agencies are also modifying 
several Phase 1 interim provisions, as described below. (1) Averaging, Banking, and Trading 
(ABT) Program 
Averaging, banking, and trading of 
emission credits have been an important part of many EPA mobile source programs under CAA Title II, and the NHTSA light-duty CAFE program. The agencies also included this flexibility in the HD Phase 1 program. ABT provisions are useful because they can help to address many potential issues of technological feasibility and lead-time, as well as considerations of cost. They provide manufacturers flexibilities that assist in the efficient development and implementation of new technologies and therefore enable new technologies to be implemented at a more aggressive pace than without ABT. A well- designed ABT program can also provide important environmental and energy security benefits by increasing the speed at which new technologies can be implemented. Between MYs 2013 and 2014 all four tractor manufacturers are taking advantage of the ABT provisions in the Phase 1 program. NHTSA and EPA proposed to carry-over the Phase 1 ABT provisions for tractors into Phase 2, and are adopting these provisions. 
The agencies proposed and are 
adopting for Phase 2 the five year credit life and three year deficit carry-over provisions from Phase 1 (40 CFR 1037.740(c) and 1037.745). Please see additional discussion in Section I.C.1.b.i. Although we did not propose any additional restrictions on the use of Phase 1 credits, we requested comment on this issue. In the NPRM, we stated that early indications suggest that positive market reception to the Phase 1 technologies could lead to manufacturers accumulating credits surpluses that could be quite large at the beginning of the Phase 2 program. 80 FR 40251. For the final rule, the agencies assessed the level of credits that the tractor manufacturers are accruing. As discussed above in Section III.D, the agencies adjusted the 2021 MY standards to reflect the accumulation of credits. 
(2) Off-Cycle Technology Credits 
In Phase 1, the agencies adopted an 
emissions and fuel consumption credit 
generating opportunity that applied to innovative technologies that reduce fuel consumption and CO
2emissions. These 
technologies were required to not be in common use with heavy-duty vehicles before the 2010MY and not reflected in the GEM simulation tool (i.e., the 
benefits are ‘‘off-cycle’’). See 76 FR 57253. The agencies proposed to essentially continue this program in Phase 2. However, we are calling the 
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program an off-cycle credit program 
rather than an innovative technology program (although there is little, if any, difference in practice). In other words, beginning in 2021 MY all technologies that are not accounted for in the GEM test procedure (including powertrain testing) could be considered off-cycle, including those technologies that may have been considered innovative technologies in Phase 1 of the program. The agencies proposed to maintain the requirement that, in order for a manufacturer to receive credits for Phase 2, the off-cycle technology would still need to meet the requirement that it was not in common use prior to MY 2010. However, the final provisions will not require manufacturers to make such a demonstration. Rather, the agencies will merely retain the authority to deny a request if we determine that a technology was in common use in 2010 and was thus part of the Phase 1 baseline (and thus also the Phase 2 baseline). For additional information on the treatment of off-cycle technologies see Section I.C.1.c. as well as the discussion of off-cycle credits in each of the Phase 2 standard chapters. 
(3) Post Useful Life Modifications 
Under 40 CFR part 1037, it is 
generally prohibited for any person to 
remove or render inoperative any emission control device installed to comply with the requirements of part 1037. However, in 40 CFR 1037.655 EPA clarifies that certain vehicle modifications are allowed after a vehicle reaches the end of its regulatory useful life. This section applies for all vehicles subject to 40 CFR part 1037 and will thus apply for trailers regulated in Phase 2. EPA proposed to continue this provision and requested comment on it. 80 FR 40252. 
This section states (as examples) that 
it is generally allowable to remove tractor roof fairings after the end of the vehicle’s useful life if the vehicle will no longer be used primarily to pull box trailers, or to remove other fairings if the vehicle will no longer be used significantly on highways with vehicle speed of 55 miles per hour or higher. More generally, this section clarifies 
that owners may modify a vehicle for the purpose of reducing emissions, provided they have a reasonable technical basis for knowing that such modification will not increase emissions of any other pollutant. This essentially requires the owner to have information that will lead an engineer or other person familiar with engine and vehicle design and function to reasonably believe that the modifications will not increase emissions of any regulated pollutant. Thus, this provision does not 
provide a blanket allowance for modifications after the useful life. 
This section also makes clear that no 
person may ever disable a vehicle speed limiter prior to its expiration point, or remove aerodynamic fairings from tractors that are used primarily to pull box trailers on highways. It is also clear that this allowance does not apply with respect to engine modifications or recalibrations. 
This section does not apply with 
respect to modifications that occur within the useful life period, other than to note that many such modifications to the vehicle during the useful life and to the engine at any time are presumed to violate section 202(a)(3)(A) of the Act. EPA notes, however, that this is merely a presumption, and it does not prohibit modifications during the useful life where the owner clearly has a reasonable technical basis for knowing that the modifications would not cause the vehicle to exceed any applicable standard. 
The agencies did not receive 
comments opposing the proposed regulation, and is adopting it as proposed. 
(4) Other Interim Provisions 
In HD Phase 1, EPA adopted 
provisions to delay the full onboard 
diagnostics (OBD) requirements for heavy-duty hybrid powertrains until the 2016 and 2017 model years (see 40 CFR 86.010–18(q)). In discussions with manufacturers during the development of Phase 2, the agencies have learned that meeting the on-board diagnostic requirements for criteria pollutant engine certification continues to be a potential impediment to adoption of hybrid systems. See Section XIII.A.1 for a discussion of regulatory changes to reduce the non-GHG certification burden for engines paired with hybrid powertrain systems. 
The Phase 1 advanced technology 
credits were adopted to promote the implementation of advanced technologies, such as hybrid powertrains, Rankine cycle engines, all- electric vehicles, and fuel cell vehicles (see 40 CFR 1037.150(p)). As the agencies stated in the Phase 1 final rule, the Phase 1 standards were not premised on the use of advanced technologies but we expected these advanced technologies to be an important part of the Phase 2 rulemaking (76 FR 57133, September 15, 2011). The HD Phase 2 heavy-duty engine and tractor standards are premised on the use of Rankine-cycle engines; therefore, the agencies believe it is no longer appropriate to provide extra credit for this technology. While 
the agencies have not premised the HD Phase 2 tractor standards on hybrid powertrains, fuel cells, or electric vehicles, we also foresee some limited use of these technologies in 2021 and beyond. We proposed in Phase 2 to not provide advanced technology credits in Phase 2 for any technology, but received many comments supporting the need for such incentive. As described in Section I.C.1.b, the agencies are finalizing credit multipliers for plug-in battery electric hybrids, all-electric, and fuel cell vehicles. 
(5) Phase 1 Flexibilities Not Adopted for 
Phase 2 
In Phase 1, the agencies adopted an 
early credit mechanism to create incentives for manufacturers to introduce more efficient engines and vehicles earlier than they otherwise would have planned to do (see 40 CFR 1037.150(a)). The agencies did not propose to extend this flexibility to Phase 2 because the ABT program from Phase 1 will be available to manufacturers in 2020 model year and this will displace the need for early credits. However, the agencies are adopting provisions in the final Phase 2 rule that provide early credit opportunities for a limited set of technologies (see 40 CFR 1037.150(y)(2); see also 40 CFR 1037.150(y)(1) and (3) 
providing early credit flexibilities to certain vocational vehicles). 
IV. Trailers 
As mentioned in Section III, trailers 
pulled by Class 7 and 8 tractors 
(together considered ‘‘tractor-trailers’’) account for approximately 60 percent of the heavy-duty sector’s total CO
2 
emissions and fuel consumption. Because neither trailers nor the tractors that pull them are useful by themselves, it is the combination of the tractor and the trailer that forms the useful vehicle. Although trailers do not directly generate exhaust emissions or consume fuels (except for the refrigeration units on refrigerated trailers), their designs and operation nevertheless contribute substantially to the CO
2emissions and 
diesel fuel consumption of the tractors pulling them. See also Section I.E above. 
The agencies are finalizing standards 
for trailers specifically designed to be drawn by Class 7 and 8 tractors when coupled to the tractor’s fifth wheel. Although many other vehicles are known commercially as trailers, this trailer program does not apply to those that are pulled by vehicles other than tractors, and those that are coupled to vehicles exclusively by pintle hooks or hitches instead of a fifth wheel. These 
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standards are expressed in terms of CO 2 
emissions and fuel consumption, and as 
described in more detail in Section IV.C.(2), apply to specific trailer subcategories. In general, the final standards are based on the same technology as the proposed standards— primarily better tires (including tire pressure management) for all regulated trailers and aerodynamic improvements for box vans (dry and refrigerated). Most of the changes from the proposal are intended to simplify and clarify the implementation of these standards. See Section IV.B. for an overview of the final program, and the rest of this Section IV for more detailed discussions. 
This rulemaking establishes the first 
EPA regulations covering trailer manufacturers for CO
2emissions (or any 
other emissions), and the first fuel consumption regulations by NHTSA for these manufacturers. The agencies have designed this program to be a unified national program, so that when a trailer model complies with EPA’s standards it will also comply with NHTSA’s standards, and vice versa. 
A. The Trailer Industry (1) Industry Characterization 
The trailer industry encompasses a 
wide variety of trailer applications and 
designs. Among these are box vans (dry and refrigerated vans of various sizes) and ‘‘non-box’’ trailers, including platform (e.g., lowboys, flatbeds), tanks, 
container chassis, bulk, dump, grain, and many specialized types of trailers, such as car carriers, pole trailers, and logging trailers. Most trailers are designed for predominant use on paved streets, roads, and highways. A relatively small number of trailers are designed with unique capabilities and features for dedicated use in off-road applications. 
The trailer manufacturing industry is 
very competitive, and manufacturers are highly responsive to their customers’ diverse demands. The wide range of trailer designs and features reflects the broad variety of customer needs, chief among them typically being the ability to maximize the amount of freight the trailer can transport. Other design goals reflect the numerous, more specialized customer needs. 
Box vans (i.e., dry and refrigerated) 
are the most common type of trailer and are made in many different lengths, generally ranging from 28 feet to 53 feet. While all have a rectangular shape, they can vary widely in basic construction design (internal volume and weight), materials (steel, fiberglass composites, aluminum, and wood) and the number and configuration of axles (usually two axles closely spaced, but number and spacing of axles can be greater). Box van designs may also include additional features, such as one or more side doors, out-swinging or roll-up rear doors, side or rear lift gates, and numerous types of undercarriage accessories (such as access ramps, dolly storage, spare tire storage, or mechanical lifts). 
Non-box trailers are often uniquely 
designed to transport a specific type of freight. Platform trailers carry cargo that may not be easily contained within or loaded into/unloaded from a box van, such as large, non-uniform equipment or machine components. Tank trailers are often sealed or pressurized enclosures designed to carry liquids, gases or bulk, dry solids and semi- solids. There are also a number of other specialized trailers such as grain, dump, livestock trailers, or logging. 
Chapter 1 of the RIA includes a more 
thorough characterization of the trailer industry. The agencies have considered the variety of trailer designs and applications in developing the CO
2 
emissions and fuel consumption standards for trailers. As is described later in this Section IV, the agencies have excluded most types of specialized trailers from the Phase 2 regulations. 
(2) Context for the Trailer Provisions 
(a) Summary of Trailer Consideration in 
Phase 1 
In the Phase 1 program, the agencies 
did not regulate trailers, but discussed how we might do so in the future (see 76 FR 57362). In proposing the Phase 1 program, the agencies solicited general comments on controlling CO
2emissions 
and fuel consumption through future trailer regulations (see 75 FR 74345– 74351). The agencies considered those comments in developing today’s rules. 
(b) SmartWay Program 
For several years, EPA’s voluntary 
SmartWay Transport Partnership 
program has been encouraging businesses to take actions that reduce fuel consumption and CO
2emissions 
while cutting costs. The SmartWay program works with the shipping, logistics, and carrier communities to identify cleaner strategies and technologies for moving goods across their transportation supply chains. It is a voluntary, market-based program that provides carbon footprint and other air emissions performance information to partners who submit annual partner reports. SmartWay Partners commit to assessing, tracking, and improving environmental performance over time, by adopting fuel-saving practices and technologies. SmartWay also provides 
technical assistance, provides recognition incentives and encourages the use of best practices that enable companies to readily incorporate fuel and emission reduction strategies into their freight supply chains. 
Annually, SmartWay trucking fleet 
partners report type and amount of fuel consumption, tons of goods moved, type and model year of equipment used, miles driven, speed profiles and other data. Using EPA MOVES model emission factors and other EPA resources, SmartWay’s assessment and tracking tools convert this information to an objective ranking of a company’s environmental efficiency, enabling each participating company to benchmark performance relative to its competitors. Logistics companies, multimodal firms and shippers use this information to calculate their corporate emissions from goods movement, which can be included in annual carbon reporting protocols and sustainability reports. 
EPA’s SmartWay program has 
accelerated the availability and market penetration of advanced, fuel efficient technologies and operational practices. In conjunction with the SmartWay Partnership Program, EPA established a testing, verification, and designation program, the SmartWay Technology Program, to help freight companies identify the equipment, technologies, and strategies that save fuel and lower emissions. SmartWay verifies the performance of aerodynamic equipment, low rolling resistance tires and other technologies and maintains lists of verified technologies on its Web site. Trailer aerodynamic technologies are grouped in performance bins that represent one percent, four percent, five percent or nine percent fuel savings relative to a typical long-haul tractor- trailer at 65-mph cruise conditions. As a shorthand description and to encourage saving fuel with multiple available technologies, EPA established criteria to describe tractors and trailers as SmartWay designated if they are equipped with specific technologies. Historically, a 53-foot dry van trailer equipped with verified aerodynamic devices totaling at least five percent fuel savings, and SmartWay verified tires, qualifies as a ‘‘SmartWay Designated Trailer.’’ In 2014, EPA expanded the program to include the aerodynamic bin for nine percent or more fuel savings and these trailers when also equipped with verified tires qualify as ‘‘SmartWay Designated Elite Trailer.’’ The 2014 updates also expanded the use of aerodynamic technologies and 
SmartWay-designated trailer eligibility to include 53-foot refrigerated van 
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326SAE International, Fuel Consumption Test 
Procedure—Type II. SAE Standard J1321. Revised 
2012–02–06. Available at: http://standards.sae.org/ j1321_ 201202/. 
327SAE International. Wind Tunnel Test 
Procedure for Trucks and Buses. SAE Standard J1252. Revised 2012–07–16. Available at: http://standards.sae.org/j1252_ 201207/. 
328SAE International, Guidelines for 
Aerodynamic Assessment of Medium and Heavy Commercial Ground Vehicles Using Computational Fluid Dynamics. SAE Standard J2966. Issued 2013– 09–17. Available at: http://standards.sae.org/j2966_201309/. 
329McCallen, R., et al. Progress in Reducing 
Aerodynamic Drag for Higher Efficiency of Heavy Duty Trucks (Class 7–8). SAE Technical Paper. 1999–01–2238. 330In December 2013, ARB adopted regulations 
that establish its own parallel Phase 1 program with standards consistent with the EPA Phase 1 tractor standards. On December 5, 2014 California’s Office of Administrative Law approved ARB’s adoption of the Phase 1 standards, with an effective date of December 5, 2014. 
331See EPA’s waiver of CARB’s heavy-duty 
tractor-trailer greenhouse gas regulation applicable to new 2011 through 2013 model year Class 8 tractors equipped with integrated sleeper berths (sleeper-cab tractors) and 2011 and subsequent model year dry-can and refrigerated-van trailers that are pulled by such tractors on California highways at 79 FR 46256 (August 7, 2014). 
33249 CFR 571.223 and 571.224. trailers in addition to 53-foot dry van 
trailers. 
The SmartWay Technology Program 
continues to improve the industry understanding of technologies, test methods and quality of data fleet stakeholders need to achieve fuel savings and environmental goals. EPA bases its SmartWay verification protocols on common industry test methods with additional criteria to achieve performance objectives and cost effective industry acceptance. Historically, SmartWay’s aerodynamic equipment verification protocol was based on the TMC type II and SAE J1321 test procedures, which measures fuel consumption as test vehicles drive laps around a test track. Under SmartWay’s 2014 updates, EPA expanded the aerodynamic technology verification program to allow additional testing options. The updates included a new, more stringent 2014 track test protocol based on industry updates to the TMC RP 1102 (2014) and SAE’s 2012 update to its SAE J1321 test method
326as well 
as protocols for wind tunnel and coastdown methods. The SmartWay program is also reviewing computational fluid dynamics (CFD) approaches for verification. These new protocols are based on stakeholder input, the latest industry standards (i.e., 2012 versions of the SAE fuel consumption and wind tunnel test
327 
methods and 2013 CFD guidance328), 
EPA’s own testing and research, and lessons learned from years of communications with manufacturers, testing organizations and trucking companies. Wind tunnel, coastdown, and CFD testing produce values for aerodynamic drag improvements in terms of coefficient of drag (C
D), which 
is then related to projected fuel savings using a mathematical curve.
329 
The SmartWay Technology Program 
verifies tires based on test data submitted by tire manufacturers demonstrating the coefficient of rolling resistance (C
RR) of their tires using 
either the SAE J1269 or ISO 28580 test methods. These verified tires have rolling resistance targets for each axle position on the tractor and trailer. SmartWay-verified trailer tires achieve a C
RRof 5.1 kg/metric ton or less on the 
ISO28580 test method. Compared to popular tires used in 2007, an operator who replaces the trailer tires with SmartWay-verified tires can expect fuel consumption savings of one percent or more at a 65-mph cruise. Operators who apply SmartWay-verified tires on both the trailer and tractor can achieve three 
percent fuel consumption savings at 65- mph. As most van trailers and many other trailer types are manufactured with SmartWay verified tires, fleets have confidence in maintaining their fuel performance thru the use of and flexibility to choose other SmartWay verified tires. 
Over the last decade, the trucking 
industry has achieved measureable fuel consumption benefits by adding aerodynamic features and low rolling resistance tires to their trailers. To date, SmartWay has verified over 70 aerodynamic technologies, including ten packages from five manufacturers that have received the Elite performance level. The SmartWay Transport Partnership program has worked with over 3,000 partners, the majority of which are trucking fleets, and broadly throughout the supply-chain industry, since 2004. These relationships, combined with the Technology Program’s extensive involvement testing and technology development has provided EPA with significant experience in freight fuel efficiency. Furthermore, the more than 10-year duration of the voluntary SmartWay Transport Partnership has resulted in significant fleet and manufacturer experience with innovating and 
deploying technologies that reduce CO
2 
emissions and fuel consumption. 
(c) California Tractor-Trailer 
Greenhouse Gas Regulation 
The state of California passed the 
Global Warming Solutions Act of 2006 (Assembly Bill 32, or AB32), enacting the state’s 2020 greenhouse gas emissions reduction goal into law. Pursuant to this Act, the California Air Resource Board (CARB) was required to begin developing early actions to reduce GHG emissions. As a part of a larger effort to comply with AB32, the California Air Resource Board issued a regulation entitled ‘‘Heavy-Duty Greenhouse Gas Emission Reduction Regulation’’ in December 2008. 
This regulation reduces GHG 
emissions by requiring improvement in the efficiency of heavy-duty tractors and 53 feet or longer dry and refrigerated box trailers that operate in California.
330 
The program is being phased in between 
2010 and 2020. Small fleets have been allowed special compliance opportunities to phase in the retrofits of their existing trailer fleets through 2017. The regulation requires affected trailer fleet owners to either use SmartWay- verified aerodynamic technologies and SmartWay-verified tires or retread tires. The efficiency improvements are achieved through the use of aerodynamic equipment and low rolling resistance tires on both the tractor and trailer. EPA has granted a waiver for this California program.
331 
(d) NHTSA Safety-Related Regulations for Trailers and Tires 
NHTSA regulates new trailer safety 
through regulations. Table IV–1 lists the current regulations in place related to trailers. Trailer manufacturers continue to be required to meet current safety regulations for the trailers they produce. FMVSS Nos. 223 and 224
332require 
installation of rear guard protection on 
trailers. The definition of rear extremity of the trailer in 223 limits installation of rear fairings to a specified zone behind the trailer. 
TABLE IV–1—C URRENT NHTSA S TAT-
UTES AND REGULATIONS RELATED  
TOTRAILERS  
Reference Title 
49 CFR part 565 Vehicle Identification 
Number (VIN) Require-
ments. 
49 CFR part 566 Manufacturer Identifica-
tion. 
49 CFR part 567 Certification. 
49 CFR part 568 Vehicles Manufactured in 
Two or More Stages. 
49 CFR part 569 Regrooved Tires. 
49 CFR part 571 Federal Motor Vehicle 
Safety Standards. 
49 CFR part 573 Defect and Noncompli-
ance Responsibility and Reports. 
49 CFR part 574 Tire Identification and 
Recordkeeping. 
49 CFR part 575 Consumer Information. 
49 CFR part 576 Record Retention. 
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33323 CFR 658.9. 
33423 CFR part 658. 33580 FR 43663 (footnote 3) (July 23, 2015). 
33680 FR 78417 (December 16, 2015). NHTSA recognizes that regulatory 
and market factors that result in changes 
in trailer weight can potentially have safety ramifications, both positive and negative. NHTSA believes that the appropriate perspective is to evaluate the regulation and market factors in their entirety. One such factor is that incentives in the Phase 2 regulation could result in an average decrease in trailer weight. Since removing weight from trailers allows more cargo to be carried, fewer trips are needed to move the same amount of cargo, and fewer crashes—including fatal crashes—could occur. Fleets and other customers have a natural incentive to request lighter- weight trailers. From the trailer owners’ perspective, reducing trailer weight not only allows them to increase cargo when they are near capacity, but also reduces fuel consumption whether the trailer is fully loaded or not. In pre- proposal meetings with trailer manufacturers, companies said that customers are requesting lighter-weight components when possible and manufacturers are installing them. 
To further incentivize a shift to lighter 
weight materials, the Phase 2 program provides two compliance mechanisms, both of which are discussed later in this Preamble (Section IV.D.(1)(d) and Section IV.E.(5)(d), respectively). The first is a list of weight reductions from which manufacturers can select. The list identifies specific lighter-weight components, such as side posts, roof bows, and flooring. Manufacturers using these lighter-weight components achieve fuel consumption and GHG reductions that count toward their compliance calculations. The NPRM identified twelve components, ranging from lighter-weight landing gear (which receives credit for 50 pounds of weight reduction) to aluminum upper coupler assemblies (which receive credit for 430 pounds). See proposed section 1037.515 at 80 FR 40627. In addition, for a lighter-weight component or technology that is not on the list of specific components, the program provides for manufacturers to use the ‘‘off-cycle’’ process to recognize the weight reduction (Section IV.E.(5)(d)). Through these mechanisms, the program provides significant flexibility and incentives for trailer light-weighting. 
NHTSA also recognizes that the 
aerodynamic devices that we expect may be adopted to meet the Phase 2 trailer standards inherently add weight to trailers. In comments on the NPRM, TTMA stated that they believe that this weight increase will result in added trips and increased numbers of fatal 
crashes. By its analysis, this additional weight—which TTMA estimates to be 250 pounds per trailer, will cause some 
trucks to exceed the trailer weight limits, necessitating additional truck trips to transport freight that could not be moved by the ‘‘weighed-out’’ trucks. By TTMA’s analysis, these added trips would cause an additional 184 million truck miles per year and would result in 246 crashes and 7 extra fatal crashes, using an assumed crash rate of 134 collisions per 100 million VMT and a 3 percent fatality rate per crash. The agencies evaluated TTMA’s estimate of additional fatalities and disagree with some of the assumptions made in the analysis. For example, the fatality rate used was developed in a study conducted for Idaho and is higher than the national average. According to FMCSA’s 2014 annual report for ‘‘Large Truck and Bus Crash Facts’’ indicates there are less than 1.67 fatalities per 100 million vehicle miles traveled (VMT) by combination trucks in the U.S. for 2014. When multiplied by an estimated 184 million additional truck miles due to weighed-out trucks, the result is an increase of about 3 fatalities, or 2.7 fatal crashes. 
Overall, the potential positive safety 
implications of weight reduction efforts 
could partially or fully offset safety concerns from added weight of aerodynamic devices. In fact, for this reason, we believe that the Phase 2 trailer program could produce a net safety benefit in the long run due to the potentially greater amount of cargo that could be carried on each truck as a result of trailer weight reduction. 
(e) Additional DOT Regulations Related 
to Trailers 
In addition to NHTSA’s regulations, 
DOT’s Federal Highway Administration (FHWA) regulates the weight and dimensions of motor vehicles on the National Network.
333FHWA’s 
regulations limit states from setting truck size and weight limits beyond certain ranges for vehicles used on the National Network. Specifically, vehicle weight and truck tractor-semitrailer length and width are limited by FHWA.
334EPA and NHTSA do not 
anticipate any conflicts between FHWA’s regulations and those established in this rulemaking. 
Utility Trailer Manufacturing Co. 
(Utility) commented that reducing existing restrictions on trailer size and weight could help encourage the transition to new technologies and trailer designs. However, these size and weight restrictions are under the jurisdiction of FHWA, and are largely controlled by the weight limits 
established by Congress in 1956 and 1974, the size limits established in the Surface Transportation Assistance Act of 1982, and the size and weight limits established in the Intermodal Surface Transportation Efficiency Act of 1991. Changes to these restrictions would require a broader process involving Congress and federal and state agencies, and is beyond the scope of the Phase 2 trailer program. 
Wabash National Corporation 
(Wabash) stated that the agencies should seek to ensure that today’s action harmonizes with safety regulations applicable to trailers. Specifically, Wabash highlighted NHTSA’s work on rear impact guard standards and ongoing examination of side impact guards. Wabash stated new or revised requirements for impact guards could increase trailer weight. The agencies have analyzed the issues in the present rulemaking while fully considering NHTSA’s safety regulations and rulemakings pertaining to trailers. The subject of a possible side guard requirement is in a research stage. As discussed in a July 2015 document, NHTSA is in the process of evaluating issues relating to side guards and will issue a decision on them at a later date.
335In December 2015, NHTSA 
issued a notice of proposed rulemaking proposing to adopt requirements of Transport Canada’s standard for underride guards.
336NHTSA is 
currently assessing next steps on that proposal, and includes as part of its analysis consideration of impacts of any decisions on the fuel efficiency of the vehicles. With respect to Wabash’s comment regarding the additional weight from aerodynamic devices, as discussed in the previous subsection, the agencies believe potential compliance paths incorporating lightweighting could offset the additional weight of aerodynamic devices in whole or in part. 
B. Overview of the Phase 2 Trailer 
Program and Key Changes From the Proposal 
The HD Phase 2 program represents 
the first time CO
2emission and fuel 
consumption standards have been established for manufacturers of new trailers. As was proposed (80 FR 40257), the final standards will phase in gradually, beginning in MY 2018. New regulated trailers built on or after 
January 1, 2018 need to be certified to 
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337For an explanation of how EPA defines 
‘‘model year’’ for purposes of the trailer program, 
see Section IV.E.(1)(a). the new CO 2emissions standards.337 
NHTSA fuel consumption standards are 
voluntary until MY 2021. 
EPA and NHTSA proposed a trailer 
program, using appropriate aspects of the Phase 1 tractor program as a guide, including optional averaging provisions (i.e. optional averaging across a 
manufacturer’s trailer fleet) as a flexibility for trailer manufacturers to meet the proposed standards. The comments from the trailer industry were nearly unanimous in opposing averaging. Commenters cited the highly competitive nature of the industry, combined with a wide range of product diversity among companies. Commenters believe that these two factors could result in a program that unfairly benefits the few larger 
companies with diverse offerings and would be impossible to implement for the many companies with limited product diversity. Additionally, compared to other industry sectors, trailer manufacturers noted that they often have little control over what kinds of trailer models their customers demand and thus limited ability to manage the mix and volume of different products. Specifically, Wabash and Utility stated that the dynamic and customer-driven nature of the industry, with many customer-specific requirements for each trailer order, makes it impossible for a manufacturer to predict what products they will produce in a given year. Utility stated that an averaging program will put manufacturers in the position of having to decide which customers receive trailers with aerodynamic devices and which receive trailers without devices. Utility added that averaging may force manufacturers to absorb the cost of aerodynamic devices, or it could cause customers to go to another manufacturer with sufficient credits to fill an order without using aerodynamic devices. Truck Trailer Manufacturers Association (TTMA) also submitted comments asking the agencies not to adopt averaging provisions. In contrast, Great Dane stated that averaging is an option manufacturers may need and recommended its inclusion in the final rule. The International Council on Clean Transportation (ICCT) said that they generally favor averaging since it gives manufacturers maximum flexibility in meeting standards while allowing for the technology deployment path that best matches a company’s business strategy. In order to balance the advantage of 
an averaging program in allowing for introduction of the most reasonably stringent standards for trailers with the concerns articulated by manufacturers, the final program accordingly limits the option for trailer manufacturers to apply averaging exclusively to MYs 2027 and later for full-aero box vans only. We believe this delay provides box van manufacturers sufficient time to develop, evaluate and market new technologies and to become familiar with the compliance process and possible benefits of averaging. This will also allow customers to become more familiar with the technologies and to recognize their benefits. See Section IV.E.(5)(b) for more details on the trailer averaging program. In the earlier years of the program, when the program does not provide for averaging, the program does provide each manufacturer with a limited ‘‘allowance’’ of trailers that do not need to meet the standards. See Section IV.E.(5)(a) below. 
The agencies proposed standards for 
dry and refrigerated box vans that were performance-based, and that were predicated on a high adoption of aerodynamic technologies, lower rolling resistance (LRR) tires and automatic tire inflation systems (ATIS). We designed the compliance approach for these performance-based standards so that manufacturers would have a degree of choice among aerodynamic, tire, tire pressure, and weight-reduction technologies and could combine them as they wished to achieve the standards. See 80 FR 40257. This final program maintains this flexible approach, adding provisions that include options for using tire pressure monitoring systems (TPMS) and innovative weight- reduction technologies as part of manufacturer compliance strategies. Section IV.E.(2) below discusses the trailer compliance provisions. 
We proposed ‘‘partial-aero’’ criteria 
for box vans with work-performing equipment that impeded use of aerodynamic technologies and we proposed that those ‘‘partial-aero’’ box vans would not have to adopt the most stringent standards in MY 2027; instead, they would maintain the MY 2024 standards. We also proposed design- based tire standards for non-box trailers that required adoption of LRR tires and ATIS. Finally, in recognition that some specialized box van designs are not very compatible with the aerodynamic technologies, the agencies established ‘‘non-aero’’ criteria for box vans. Box vans meeting the ‘‘non-aero’’ criteria will be subject to the same requirements as the non-box trailers. 80 FR 40259. The proposed program was designed 
to include nearly all trailer types, with 
a limited number of exemptions or exclusions that we believed indicated off-road, heavy-haul or non-freight transporting operation. TTMA and the American Trucking Associations (ATA) provided comments suggesting that additional trailer types should be excluded from the program based on these trailers’ typical operational characteristics. The agencies considered the suggestions of these commenters and of several individual trailer manufacturers, and we recognize that many trailers in the proposed non-box subcategory have unique physical characteristics for specialized operations that may make use of lower rolling resistance (LRR) tires and/or tire pressure systems difficult or infeasible. Instead of focusing on trailer characteristics that indicated off- highway or specialty use, the agencies 
have identified three specific types of non-box trailers that represent the majority of non-box trailers that are designed for and mostly used in on-road applications: Tank trailers, flatbed trailers, and container chassis. Because of their predominant on-road usage, the tire technologies adopted in this trailer program will be consistently effective for these non-box trailer types. Consequently, the final program as it applies to non-box trailers is limited to tanks, flatbeds, and container chassis. All other non-box trailers, about half of the non-box trailers produced, are excluded from the Phase 2 trailer program, with no regulatory requirements. See Section IV.C.(1) for the regulatory definitions of the trailers included in this program. 
Wabash commented that partial-aero 
vans should be exempt in MY 2021 rather than MY 2027 as proposed, citing the need for multiple devices to meet the later standards. The agencies reconsidered the proposed partial-aero standards in light of this comment and recognize that it would likely be difficult for most manufacturers to meet the proposed MY 2024 standards without the use of multiple devices, and yet partial-aero trailers, by definition, are restricted from using multiple devices. For these reasons, the agencies redesigned the partial-aero standards such that trailers with qualifying work- performing equipment can meet standards that would be achievable with the use of a single aerodynamic device throughout the program, similar to the MY 2018 standards. The partial-aero standards do, however, increase in stringency slightly in MY 2021 to reflect 
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the broader use of improved lower 
rolling resistance tires. 
The agencies also considered 
comments from manufacturers that were concerned about the cost and, availability of ATIS for the trailer industry. Wabash, Owner Operator Independent Drivers Association (OOIDA), the Rubber Manufacturers Association (RMA), American Trucking Associations (ATA), and Bendix asked that TPMS be allowed for trailer tire compliance in addition to ATIS. OOIDA said that operators prefer less expensive and easier to operate TPMS to ATIS. Wabash expressed concern that ATIS suppliers would not be able to meet demand should ATIS be required as a compliance mechanism for all trailers, especially in the early years of the program. Great Dane stated that their customers are not seeing consistent benefit of ATIS. ATA commented that trailer manufacturers should be allowed to use TPMS for compliance because they are increasingly effective, and some trailers used in heavy-haul applications would need an additional ATIS air compressor, which adds cost and weight that can be avoided by the use of TPMS. The California Air Resources Board supported the agencies’ proposal to allow only ATIS for compliance since TPMS require action on the part of the driver to re-inflate affected tires and thus the benefit of the systems is dependent on driver behavior. 
The agencies agree that TPMS 
generally promote proper tire inflation and that including these lower-cost systems as a compliance option will increase acceptance of the technologies. The final trailer program provides for manufacturers to install either TPMS or ATIS as a part of compliance. For full- and partial-aero trailers, the standards are performance standards, and the GEM-based compliance equation (described below) provides ATIS a slightly greater credit than it does for TPMS, to account for the greater uncertainty about TPM system effectiveness due to the inherent user- interaction required with systems that simply monitor tire pressure. These performance standards are based on the use of ATIS and the numerical values of these standards reflect the 0.2 percent increase in stringency. See Section 
IV.D.(1)(c) for additional information. 
For non-aero box vans and non-box 
trailers, the standards are design standards, met directly by installation of specified technologies, not by using the compliance equation. As long as a manufacturer of these trailers installs either a TPMS or an ATIS (as well as lower rolling resistance tires meeting the specified threshold), the trailer will comply, and either technology applies 
equally. We project that most design- based tire standards will be met with the less expensive TPMS, but trailers with ATIS will also comply. The effectiveness values adopted for ATI and TPMS in the trailer program are consistent with those in the tractor and vocational vehicle programs. 
The agencies generated the proposed 
standards with use of EPA’s Greenhouse gas Emissions Model (GEM) vehicle simulation tool, but for compliance we created a GEM-based equation that trailer manufacturers would use for compliance. See Section IV.E.(2)(a). We made several improvements to GEM based on public comment, and these improvements impacted the results of the model. We have re-created a compliance equation for trailers based on the updated model and are adopting the new equation as the means for trailer manufacturers to certify their trailers in Phase 2. 
The agencies also proposed an 
aerodynamic device testing compliance path that would allow device manufacturers to submit performance test data directly to EPA for pre- approval. 80 FR 40280. We designed this alternative to reduce the test burden of trailer manufacturers by allowing them to install devices with pre- approved data and to eliminate the need to perform their own testing of the devices. Based on public comment, the agencies are adopting the aerodynamic device testing alternative in the final trailer program and are updating several of the provisions related to submission and verification of test data on those devices. See Section IV.E.(3)(b)(v). 
The agencies considered five 
alternative programs in the proposal and extensively evaluated what were termed Alternative 3 and Alternative 4 in our feasibility analysis. 80 FR 40273. The final stringency of both alternatives was identical and each included three-year stages of increasing stringency. However, Alternative 4 represented an 
accelerated timeline that reached its final stringency in MY 2024. Alternative 3 included an additional three years to meet its final stringency in MY 2027. Alternative 5 was proposed in four stages, but would have a required much greater application rate of the most advanced aerodynamic devices, including aerodynamic technologies on non-box trailers. The agencies believed this alternative was infeasible for this newly-regulated industry and did not extensively evaluate it. 
Public comment from the trailer 
industry unanimously opposed the accelerated timeline of the proposed Alternative 4. TTMA recommended that the agencies adopt no mandatory 
requirements, and instead rely on a voluntary program for trailers. OOIDA supported standards less stringent than either Alternatives 3 or 4. Great Dane said that adoption of standards more stringent than Alternative 3 would considerably increase the probability of negative effects on stakeholders. Wabash questioned whether, under the accelerated timeline of Alternative 4, current technologies could be produced for all applications for which they would be needed, and with sufficient reliability. The International Food Service Delivery Association, the Truck Trade Association, and Schneider also opposed Alternative 4 for similar reasons. STEMCO, California Air Resources Board (CARB), ICCT, and American Council for an Energy- Efficient Economy (ACEEE) supported Alternative 4. The Environmental Defense Fund (EDF) supported Alterative 5, but with an accelerated schedule, saying technologies will be available to meet the Alternative 5 standards by 2024. 
The final standards adopted for the 
Phase 2 trailer program have the same four-stage implementation schedule as the proposed Alternative 3, with standards phasing in for MYs 2018, 2021, 2024, and 2027 (NHTSA standards apply beginning in MY 2021). We received comments regarding adjustments to technology adoption rates in our baseline reference cases which the agencies found to be persuasive, and the resulting adjustments are described in Section IV.D.(2)(c). Additionally, the technology effectiveness values and projected adoption rates for each of the four stages of the program were updated in response to comments, to reflect new 
test data, and to account for a program without averaging. 
C. Phase 2 Trailer Standards 
These final rules establish, for the first 
time, a set of CO
2emission and fuel 
consumption standards for 
manufacturers of new trailers that phase in over a period of nine years and continue to reduce CO
2emissions and 
fuel consumption in the years to follow. These standards are expressed as overall CO
2emissions and fuel consumption 
performance standards, considering the trailer as an integral part of the tractor- trailer vehicle. 
The agencies believe that the trailer 
standards finalized here will implement our respective statutory obligations. That is, we believe that this set of standards represents the maximum feasible alternative within the meaning of section 32902(k) of EISA, and are 
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338Most long trailers are 53 feet in length; we are 
adopting a cut-point of 50 feet to avoid an 
unintended incentive for an OEM to slightly shorten a trailer design in order to avoid the new regulatory requirements. 339Memorandum to Docket EPA–HQ–OAR– 
2014–0827: Evaluation of 50-Foot Trailer Length Demarcation to Distinguish between Long and Short Box Vans. July 18, 2016. appropriate under EPA’s CAA authority 
(sections 202(a)(1) and (2)). 
These standards have the same 
implementation schedule as the proposed Alternative 3, with standards phasing in for MYs 2018, 2021, 2024, and 2027. In our consideration of the full range of comments, the agencies have adjusted elements of the proposed Alternative 3 in ways that address some of these comments, as discussed in Section 0 below. As discussed in Section IV.E.(5)(b), the option to apply averaging to meet these standards will be available starting with MY 2027, but will not be available in earlier model years. 
The agencies did not propose and are 
not establishing standards for CO
2 
emissions and fuel consumption from the transport refrigeration units (TRUs) used on refrigerated box trailers. Also, EPA is not establishing standards for hydrofluorocarbon (HFC) emissions from TRUs. See Section IV.C.(3) below. 
(1) Trailer Designs Covered by the 
Trailer Program 
As described previously, the trailer 
industry produces many different trailer designs for many different applications. The agencies are introducing standards for a majority of these trailers that phase in from MY 2018 through MY 2027; the NHTSA fuel consumption standards are voluntary until MY 2021. The regulatory definitions of the trailers covered by this 
program are summarized below and are found in 40 CFR 1037.801 and 49 CFR 571.3. 
(a) Box Vans 
Box vans are trailers with enclosed 
cargo space that is permanently attached 
to the chassis, with fixed sides, nose and roof. Trailers with sides or roofs consisting of curtains or other removable panels are not considered box vans in this program. Box vans with self-contained HVAC systems are considered ‘‘refrigerated vans.’’ This definition includes systems that provide cooling, heating or both. Box vans without HVAC systems are considered ‘‘dry vans.’’ 
This rulemaking establishes separate 
standards for box vans based on length. Box vans of length greater than 50 feet are considered ‘‘long box vans.’’
338All 
vans 50 feet and shorter are considered ‘‘short box vans.’’ The agencies requested comment on the proposed 50- foot demarcation between ‘‘long’’ and ‘‘short’’ box vans (80 FR 40258). CARB and the Union of Concerned Scientists (UCS) commented on this issue, requesting that the demarcation be changed to 47 feet, such that 48-foot vans would be covered under the long box subcategory. CARB suggested that the performance of aerodynamic technologies such as skirts and boat tails on a 48-foot van would be more similar to the performance of the same technologies on a 53-foot van than on the 28-foot van used to evaluate short box performance. CARB also stated that 48-foot trailers are not pulled in tandem and thus have the potential to adopt rear devices for additional reductions. 
The agencies agree that 48-foot vans 
are aerodynamically similar to longer vans and that 28-foot trailers are often used in tandem, reducing the opportunity for rear aerodynamic features. However, the agencies believe that the use of 48-foot vans is more 
similar to that of shorter trailers than to that of the long-haul vans that make up most the long box subcategory. Trailer manufacturers have indicated that 48- foot vans are mostly used in short-haul operations (e.g., local food service 
delivery) and consequently they travel less frequently at speeds at which aerodynamic technologies can be most beneficial. Also, 48-foot vans make up a relatively small fraction of long box vans.
339The agencies thus do not 
believe that standards predicated on the use of more effective aerodynamic technologies on 48-foot vans will provide a substantial enough additional reduction in CO
2emissions and fuel 
consumption to justify more stringent standards for those trailers. For these reasons, the agencies are maintaining the proposed 50-foot demarcation between long and short box vans and are basing the standards for each van size category accordingly. 
The trailer program identifies certain 
types of work-performing equipment manufacturers may install on box vans that may inhibit the use of aerodynamic technologies and thus impede the trailers’ ability to meet standards predicated on adoption of aerodynamic technologies. For this program, we consider such trailer equipment to consist of a rear lift gate or rear hinged ramp and any of the following side features: A side lift gate, a side-mounted pull-out platform, steps for side-door access, a drop-deck design, or a belly box or boxes that occupy at least half the length of both sides of the trailer between the centerline of the landing gear and the leading edge of the front 
wheels. See 40 CFR 1037.107(a)(1) and 49 CFR 571.3. 
The agencies have also considered 
how ‘‘roll-up’’ or ‘‘overhead’’ rear trailer doors might inhibit the use of rear aerodynamic devices. TTMA, ATA, Great Dane, and Utility stated that roll- up doors are work-performing devices that can inhibit rear aerodynamic technologies. However, the agencies are aware of several existing aerodynamic devices designed to be installed near the rear of a trailer that can function regardless of the type of rear door. Also, in their comments, STEMCO indicated that additional rear aerodynamic technologies would be less likely to enter the market if the trailer program were to include roll-up doors on the list of work-performing devices above and the industry didn’t demand an aerodynamic product to work with roll- up doors. The agencies recognize there may currently be limited availability of rear aerodynamic technologies for roll- up door trailers, yet we also understand that innovations and improvements continue for all trailer aerodynamic technologies. For this reason, the final trailer program includes an interim provision—through MY 2023—for box vans with roll-up doors to qualify for non-aero and partial-aero standards (as defined immediately below), by treating such doors as work-performing devices equivalent to rear lift gates. For MY 2024 and later, roll-up doors will not qualify as a work-performing device in this way; however, we expect that manufacturers of trailers with roll-up doors will comply using combinations of new rear aerodynamic technologies, in conjunction with improved trailer side and gap-reducing technologies as appropriate. See 40 CFR 1037.150. 
As presented in Section IV.C.(2) 
below, the agencies are adopting separate standards for each of the same nine box van subcategories introduced in the proposal (80 FR 40256) and for the non-box category discussed below. Full-aero long box dry vans and full- aero long box refrigerated vans are those that are over 50 feet in length and that do not have any of the work-performing equipment discussed immediately above. Similarly, full-aero short box dry vans and full-aero short box refrigerated 
vans are 50 feet and shorter without any work-performing equipment. We expect these trailers to be capable of meeting the most stringent standards in the trailer program. 
Long box dry vans and long box 
refrigerated vans that have work- performing equipment either on the underside or on the rear of the trailer that would limit a manufacturer’s ability 
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to install aerodynamic technologies may 
be designated as partial-aero vans for their given subcategory. The partial-aero standards are based on adoption of tire technologies and a single aerodynamic device throughout the program. Long box dry and refrigerated vans that have work-performing equipment on the underside and rear of the trailer may be 
designated non-aero box vans. Non-aero box vans are a single subcategory that have design-based tire standards. 
For short vans, the standards are 
never predicated on the use of rear devices, since many 28-foot trailers are often pulled in tandem. However, we are not aware of any current legislative or regulatory initiatives that would allow tandem trailers longer than 33 feet in length, and therefore we believe that short vans of length 35 feet and longer are unlikely to be pulled in tandem in the timeframe of these rules. We are adopting separate criteria for partial- and non-aero designation for short vans based on a length threshold of 35 feet. If vans 35 feet or longer have work- performing equipment on the underside of the trailer, we expect manufacturers can install rear devices to meet the full- aero standards, but they have the option to designate these trailers as partial-aero dry or refrigerated short vans with reduced standards that can be met with tire technologies and a single aerodynamic device. If vans 35 feet and longer have work performing equipment on the underside and rear, manufacturers may designate them as non-aero box vans. 
Short vans that are less than 35 feet 
in length are more likely to be pulled in tandem, making most rear aerodynamic devices infeasible. Since gap reducers alone are not sufficiently effective to replace a skirt and the shortest trailers are not expected to install rear devices, both dry and refrigerated vans that are shorter than 35 feet with work- performing equipment on the underside of the trailer may be designated non- aero box vans that can comply with tire technologies only. In addition, refrigerated vans that are shorter than 35 feet cannot install gap reducers because of the TRU. Consequently, all refrigerated vans shorter than 35 feet, irrespective of work-performing equipment, can be designated partial- aero short refrigerated vans whose standards can be met with skirts and tire technologies. See 40 CFR 1037.107(a)(1) and 49 CFR 571.3. Because the types of work-performing equipment identified here generally add significant cost and weight to a trailer, we believe that the reduced standards available for trailers 
using this equipment are unlikely to provide an incentive for manufacturers to install them simply as a way to avoid 
the full aero standards. 
(b) Non-Box Trailers 
All trailers that do not meet the 
definition of box vans are considered 
non-box trailers in the trailer program. Several commenters requested a clearer distinction of the trailers that are included in the program. In response, the agencies are limiting the non-box trailer standards to three trailer types 
that have distinct physical characteristics and are most often driven on-highway: Tank trailers, flatbed trailers, and container chassis. Non-box trailers that do not meet the definitions below are excluded from the trailer program, as discussed in the following section. 
Tank trailers are defined for the trailer 
program as enclosed trailers designed to transport liquids or gases. For example, DOT 406, DOT 407, and DOT 412 tanks would fit this definition. These non-box trailers can be pressurized or designed for atmospheric pressure. Tanks that are infrequently used in transport and primarily function as storage vessels for liquids or gases (e.g., frac tanks) are not 
included in our definition of tank trailers and are excluded from the program. 
Flatbed trailers for purposes of the 
trailer program are platform trailers with a single, continuous load-bearing surface that runs from the rear of the trailer to at least the trailer’s kingpin. Flatbed trailers are designed to accommodate side-loading cargo, and this definition includes trailers that use bulkheads, one or more walls, curtains, straps or other devices to restrain or protect cargo while underway. Note that drop deck and lowboy platform trailers are not considered continuous load- 
bearing surfaces. 
Finally, in the trailer program, 
container chassis are trailers designed to transport temporary containers. The standards apply to all lengths of container chassis, including expandable versions. The regulations do not apply to the containers being transported, unless they are permanently mounted on the chassis. 
(c) Excluded Trailers 
As in the proposal (80 FR 40259), the 
final trailer program completely 
excludes certain trailer types. However, in response to comments and an improved understanding of the industry, the agencies have changed our approach to excluding some trailer types. 
In the proposal, we focused on 
excluding trailers based on characteristics that tended to indicate predominant operation in off-highway 
applications. The American Trucking Associations (ATA) and the Truck Trailer Manufacturers Association (TTMA) provided comments suggesting that additional trailer types should be excluded from the program based on the trailers’ typical operational characteristics, generally because of these trailers’ limited on-highway operation. Also, Wabash requested that the program specify clearer criteria for excluding or exempting trailers. 
The agencies considered all of the 
suggestions of the commenters, and we now believe that a different approach to excluding some trailer types is more appropriate. We recognize that many trailer types in the proposed non-box subcategory have many unique physical characteristics and are designed for specialized operations and it would be difficult to create a comprehensive list of traits that indicated off-road use. This wide array of trailer types would have made the proposed approach difficult to implement for both trailer manufacturers and for the agencies, since the usage patterns of many specialty trailer types can vary greatly. Some of these uses, especially off- highway applications, may make use of the proposed tire technologies for compliance difficult or infeasible and may limit their effectiveness. Additionally, the agencies are aware that many manufacturers that build these specialty non-box trailers are small businesses (fewer than 1000 employees), and they would incur a disproportionately large financial burden compared to larger manufacturers if they were subject to the standards. 
For these reasons, instead of focusing 
our approach to excluding trailer types on trailer characteristics that indicated predominant off-highway use, the final program excludes all non-box trailer types except for three specific types that we believe are designed for and mostly used in on-road applications. These types are tanks, flatbeds, and container chassis, as defined in the previous sub- section. We now consider this approach to be much clearer and more straightforward to implement than the proposed approach. Manufacturers of these types of trailers can easily obtain 
and install LRR tires and tire pressure systems, and achieve the most consistent benefit from use of these technologies. The trailer program excludes all trailers that do not meet the criteria outlined in Section IV.C.(1)(b) above, and specified in 40 CFR 1037.5 and in 49 CFR 535.3(e). 
The final rule also excludes certain 
types of trailers based on design 
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340Secondary manufacturers who purchase 
incomplete trailers and complete their construction to serve as trailers are subject to the requirements 
of 40 CFR 1037.620 and 49 CFR 535.5(e). 341These stages are consistent with NHTSA’s 
stability requirements under EISA. characteristics, consistent with the 
proposed rule. More precisely, these excluded trailer types are sub-types of otherwise regulated trailer types, such as certain types of box vans. First, the rule excludes trailers intended to haul very heavy loads, as indicated by the number of axles. Specifically, the rules exclude all trailers with four or more axles, and trailers less than 35 feet long with three axles. For example, a 53-foot box van with four axles would be excluded. Also, we agree with Utility that spread-axle trailers may be more susceptible to tire scrubbing, and the program accordingly excludes trailers with an axle spread of at least 120 inches between adjacent axle centerlines. The axle spread exclusion does not apply to trailers with adjustable axles that have the ability to be spaced less than 120 inches apart. Finally, the rules exclude trailers intended for temporary or permanent residence, office space, or other work space, such as campers, mobile homes, and carnival trailers.
340 
Manufacturers of excluded trailers 
have no reporting or other regulatory requirements under the trailer program. See 40 CFR 1037.5 and 49 CFR 535.3 for complete definitions of the trailer types that the program excludes. However, where the criteria for exclusion identified above may be unclear for specific trailer models, manufacturers are encouraged to ask the agencies to make a determination before production begins. 
(2) Fuel Consumption and CO
2 
Standards 
As described previously in Section I, 
it is the combination of the tractor and the trailer that form the useful vehicle, 
and trailer designs substantially affect the CO
2emissions and fuel 
consumption of the tractors pulling them. Note that although the agencies are adopting new CO
2and fuel 
consumption standards for trailers separately from tractors, we set the numerical level of the trailer standards (see Section IV.D. below) based on operation with ‘‘standard’’ reference tractors in recognition of their interrelatedness. In other words, the regulatory standards refer to the simulated emissions and fuel consumption of a standard tractor pulling the trailer being certified. 
Unlike the other sectors covered by 
this Phase 2 rulemaking, trailer manufacturers do not have experience certifying under the Phase 1 program (or under EPA’s criteria pollutant program). Moreover, a large fraction of the trailer industry is composed of small businesses and even the largest trailer manufacturers do not have the same resources available to them as do manufacturers in some of the other heavy-duty sectors. The standards and compliance regime for trailers have been developed with this in mind, and we are confident these standards can be achieved and demonstrated by manufacturers who lack prior experience implementing such standards. 
The agencies designed this trailer 
program to ensure a gradual progression of both stringency and compliance requirements in order to limit the impact on this newly-regulated industry. The agencies are adopting progressively more stringent standards in three-year stages leading up to the MY 2027,
341and are including several 
options to reduce compliance burden in the early years as the industry gains experience with the program (see Section IV.E.). EPA will initiate its program in MY 2018 with standards for long box dry and refrigerated vans, which standards can be met with common tire technologies and SmartWay-verified aerodynamic devices and standards for the other regulated trailers based on tire technologies only. In this early stage, we expect that manufacturers of trailers in the other trailer subcategories will meet their standards by using tire technologies only. NHTSA’s regulations will be voluntary until MY 2021 as described in Section IV.C.(2). 
Standards for the next stages, which 
begin in MY 2021, gradually increase in stringency for each subcategory, including the introduction of standards for short box vans that we expect will be met by applying both aerodynamic and tire technologies. The standards for partial-aero box vans are less stringent than those for full-aero box vans, reflecting that the standards for partial- aero vans are based on adoption of a single aerodynamic device throughout the program. This is in contrast to the proposed standards for partial-aero vans that were identical to the standards for full-aero vans through MY 2026. 
Table IV–2 and Table IV–3 below 
present the CO
2and fuel consumption 
standards, beginning in MY 2018 that the agencies are adopting for full- and partial-aero box vans, respectively. The standards are expressed in grams of CO
2 
per ton-mile and gallons of fuel per 1,000 ton-miles to reflect the load- carrying capacity of the trailers. 
TABLE IV–2—T RAILER CO 2ANDFUELCONSUMPTION STANDARDS FOR FULL-AEROBOXVANS 
Model year Subcategory Dry van Refrigerated van 
Length Long Short Long Short 
2018–2020 ............................ EPA Standard .............................................. 81.3 125.4 83.0 129.1 
(CO 2Grams per Ton-Mile) 
Voluntary NHTSA Standard ......................... 7.98625 12.31827 8.15324 12.68173 
(Gallons per 1,000 Ton-Mile) 
2021–2023 ............................ EPA Standard .............................................. 78.9 123.7 80.6 127.5 
(CO 2Grams per Ton-Mile) 
NHTSA Standard ......................................... 7.75049 12.15128 7.91749 12.52456 
(Gallons per 1,000 Ton-Mile) 
2024–2026 ............................ EPA Standard .............................................. 77.2 120.9 78.9 124.7 
(CO 2Grams per Ton-Mile) 
NHTSA Standard ......................................... 7.58350 11.87623 7.75049 12.24951 
(Gallons per 1,000 Ton-Mile) 
2027+ .................................... EPA Standard .............................................. 75.7 119.4 77.4 123.2 
(CO 2Grams per Ton-Mile) 
NHTSA Standard ......................................... 7.43615 11.72888 7.60314 12.10216 
(Gallons per 1,000 Ton-Mile) 
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342Under the proposal, the regulations would not 
be extended to equipment using a substitute 
refrigerant when that use of the refrigerant has been exempted from the venting prohibition, as listed in 40 CFR 82.154(a). TABLE IV–3—T RAILER CO 2ANDFUELCONSUMPTION STANDARDS FOR PARTIAL -AEROBOXVANS 
Model year Subcategory Dry van Refrigerated van 
Length Long Short Long Short 
2018–2020 ............................ EPA Standard .............................................. 81.3 125.4 83.0 129.1 
(CO 2Grams per Ton-Mile) 
Voluntary NHTSA Standard ......................... 7.98625 12.31827 8.15324 12.68173 
(Gallons per 1,000 Ton-Mile) 
2021+ .................................... EPA Standard .............................................. 80.6 123.7 82.3 127.5 
(CO 2Grams per Ton-Mile) 
NHTSA Standard ......................................... 7.91749 12.15128 8.08448 12.52456 
(Gallons per 1,000 Ton-Mile) 
The agencies are not adopting CO 2or 
fuel consumption standards predicated 
on aerodynamic improvements for non- box trailers or non-aero box vans at any stage of this program. Instead, we are adopting design standards that require manufacturers of these trailers to adopt specific tire technologies and thus to 
comply without aerodynamic devices. This approach significantly limits the compliance burden for these manufacturers, especially if they do not also manufacture box vans subject to the aerodynamic requirements. The 
agencies are adopting these design standards in two stages. In MY 2018, the non-box trailer standards require manufacturers to use tires meeting a rolling resistance of 6.0 kg/ton or better and to install tire pressure systems. In MY 2021, non-box trailers will also 
need tire pressure systems and LRR tires at 5.1 kg/ton (the current SmartWay- verification threshold) or better. The standards require non-aero box vans, which we believe are largely at a baseline rolling resistance 6.0 kg/ton 
today, to install tire pressure monitoring systems and tires at a rolling resistance of 5.1 kg/ton in MY 2018 and 4.7 kg/ton in MY 2021 and later (there are no further increases in standard stringency for these trailers after MY 2021). For non-box trailers and non-aero box vans, manufacturers may install either TPMS or ATIS for compliance. 
Table IV–4 summarizes the two stages 
of these design standards. 
TABLE IV–4—D ESIGN -BASED TIRESTANDARDS FOR NON-BOXTRAILERS AND NON-AEROBOXVANS 
Model year Tire technology Non-box trailers Non-aero box 
vans 
2018–2020 .................................... Tire Rolling Resistance Level (kg/ton) ............................................ ..... 6.0 5.1 
Tire Pressure System .......................................................................... TPMS or ATIS TPMS or ATIS 
2021+ ............................................ Tire Rolling Resistance Level (kg/ton) ........................................ ......... 5.1 4.7 
Tire Pressure System .......................................................................... TPMS or ATIS TPMS or ATIS 
The agencies project that the 
standards for the entire class of regulated trailers, when fully implemented in MY 2027, will achieve fuel consumption and CO
2emissions 
reductions of two to nine percent relative to mostly market-driven adoption absent a national regulatory program (see Section IV.D.(2)). Because of the rapid pace of technological improvement in recent years and the lead time of nearly a decade, the agencies expect that both trailer designs and bolt-on CO
2- and fuel consumption- 
reducing technologies will advance well beyond the performance of their present-day counterparts. Regardless, we expect that the MY 2027 standards for full-aero box vans could be met with high-performing aerodynamic and tire technologies largely available in the marketplace today. A description of technologies that the agencies considered in developing these rules is provided in Section IV.D., with additional details in RIA Chapter 2.10. (3) Non-CO
2GHG Emissions From 
Trailers 
In addition to the impact of trailer 
design on the CO 2emissions of tractor- 
trailer vehicles, EPA recognizes that 
refrigerated trailers can also be a source of emissions of HFCs. Specifically, HFC refrigerants that are used in transport refrigeration units (TRUs) have the potential to leak into the atmosphere. 
In their comments, CARB said they 
believed that EPA underestimated the potential for TRU refrigerant leakage, and requested that EPA (1) initiate a 
TRU refrigerant ‘‘usage monitoring program’’ to support future evaluations of leakage; (2) create incentives for low- and zero-emission (e.g., cryogenic) 
TRUs; and (3) for EPA’s SNAP program to phase out the main TRU refrigerant (R404a) when viable alternatives are available. EPA did not propose any action related to TRUs in this rule, and CARB did not provide sufficient information for EPA to introduce new regulatory requirements for TRUs at this time. In general, however, EPA will continue to monitor the state of TRU technology and operation, and may pursue appropriate action if warranted 
in the future. 
We also note that EPA has separately 
proposed a regulation under Title VI of the CAA, specifically section 608. See 80 FR 69457 (November 9, 2015). This proposal would extend existing regulations on ozone depleting refrigerants to many alternative refrigerants, such as HFCs, which are the most common refrigerants used in TRUs.
342If finalized as proposed, EPA 
would require that appliances like TRUs be subject to the applicable requirements of 40 CFR subpart F, including requirements for servicing by a certified technician using certified recovery equipment and for recordkeeping by technicians disposing of such appliances with a charge size between five and fifty pounds, which 
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343The Clean Air Act (42 U.S.C. 7671) uses the 
term ‘‘appliance’’ to refer to TRUs and other similar 
equipment. 344NHTSA adopted a similar voluntary approach 
in the first years of Phase 1 (see 76 FR 57106). 345Reinhart, T.E. (June 2015). Commercial 
Medium- and Heavy-Duty Truck Fuel Efficiency Technology Study—Report #1. (Report No. DOT HS 812 146). Washington, DC: National Highway Traffic Safety Administration. 
346Committee to Assess Fuel Economy 
Technologies for Medium- and Heavy-Duty Vehicles; National Research Council; Transportation Research Board (2010). Technologies and Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty Vehicles. (‘‘The NAS Report’’) Washington, DC, The National Academies Press. Available electronically from the National Academy Press Web site at http:// 
www.nap.edu/catalog.php?record_ id=12845. 
347TIAX, LLC. ‘‘Assessment of Fuel Economy 
Technologies for Medium- and Heavy-Duty Vehicles,’’ Final Report to National Academy of Sciences, November 19, 2009. would include TRUs, to help ensure 
that the refrigerant is not vented.343 
(4) Lead-Time Considerations 
As mentioned earlier, although the 
agencies did not include standards for trailers in Phase 1, box van manufacturers have been gaining experience with CO
2- and fuel 
consumption-reducing technologies over the past several years, and the agencies expect that trend to continue, due in part to EPA’s SmartWay program and California’s Tractor-Trailer Greenhouse Gas Regulation. Most manufacturers of 53-foot box vans have some experience installing these aerodynamic and tire technologies for customers. Manufacturers of trailers other than 53-foot box vans do not have the benefit of programs such as SmartWay to provide a reliable evaluation and promotion of aerodynamic technologies for those trailers and therefore have less experience with those technologies. However, all trailer manufacturers have experience installing tires and the installation process does not change with the use of lower rolling resistance tires. Some manufacturers may not have direct experience with tire pressure systems, but we observe that they are mechanically fairly simple and can be incorporated into trailer production lines without significant process changes. 
EPA is adopting CO
2emission 
standards for long box vans for MY 2018 that represent stringency levels similar to the current performance level needed for SmartWay’s verification and those required for the current California regulation. These standards can be met by adopting off-the-shelf aerodynamic and tire technologies available today. The agencies are adopting less stringent requirements for manufacturers of other highway trailer subcategories beginning in MY 2018 that can be met without use of aerodynamic technologies. Given that these technologies are readily available and are already familiar to the industry, the agencies believe, for both cases, that manufacturers have sufficient lead time to adopt these technologies and to implement the simplified compliance provisions introduced below and described fully in Section IV.E. 
NHTSA’s direction under EISA is to 
allow four model years of lead-time for new fuel consumption standards, regardless of the stringency level or availability of flexibilities. Therefore, NHTSA’s fuel consumption requirements are not mandatory until 
MY 2021. Prior to MY 2021, trailer manufacturers could voluntarily participate in NHTSA’s program, noting that once they made such a choice, they will need to stay in the program for all succeeding model years.
344 
We believe there are technology 
pathways available today that manufacturers could use to comply with the standards when they are fully implemented in MY 2027. The agencies designed each three-year stage of the program as a gradual progression of stringency that provides sufficient lead- time for all affected trailer manufacturers to evaluate and adopt CO
2- and fuel consumption-reducing 
technologies or design trailers to meet these standards while meeting their customers’ needs. The agencies believe that the burdens of installing and marketing these CO
2- and fuel 
consumption-reducing technologies at the stringency levels of this program are not limiting factors in determining necessary lead-time for manufacturers of these trailers. Instead, we expect that the first-time compliance and, in some cases, performance testing, will be more challenging obstacles for this newly regulated industry. For these reasons, the standards phase in over a period of nine years, with flexibilities to minimize the compliance and testing burdens especially in the early years of the program (see Section IV.E.). We are adopting provisions for manufacturers to use a GEM-based compliance equation in lieu of the GEM vehicle simulation tool, which will reduce the 
number of resources required to learn and implement the model. We are also finalizing compliance provisions that allow trailer manufacturers to use pre- approved aerodynamic test data from aerodynamic device manufacturers, which could eliminate a trailer manufacturer’s test burden for compliance. As explained above, non- aero box vans and non-box trailers, which make up almost 20 percent of the regulated trailers, are subject to straightforward design-based tire standards throughout the program that require that they install qualified LRR tires and tire pressure systems with simplified compliance requirements. See Section IV.E. for a full description of the trailer compliance program. 
The Rubber Manufacturers 
Association (RMA) expressed concern that the proposed program would not provide sufficient lead time for the development and production of LRR tire designs for some off-road applications. As discussed above, the final program now excludes all trailer types that would generally be used in off-road applications, including all non-box trailers except tanks, flatbeds, and container chassis. Therefore, trailer types designed for off-road use do not have LRR tire requirements, and the final program should significantly reduce RMA’s concerns about available lead time for special tire development. Additionally, we have adjusted the tire performance requirements for the LRR tires of the non-box trailer design standards. 
D. Feasibility of the Trailer Standards 
As discussed below, the agencies’ 
determination is that the standards 
presented in Section IV.C.(2), are the maximum feasible and appropriate under the agencies’ respective authorities, considering lead time, cost, and other factors. We summarize our analyses in this section, and describe them in more detail in RIA Chapter 2.10. 
Our analysis of the feasibility of the 
CO
2and fuel consumption standards is 
based on technology cost and effectiveness values collected from several sources. Our assessment of the trailer program is based on information from: 
—Southwest Research Institute 
evaluation of heavy-duty vehicle fuel 
efficiency and costs for NHTSA,
345 
—2010 National Academy of Sciences 
report of Technologies and Approaches to Reducing the Fuel Consumption of Medium- and Heavy- Duty Vehicles,
346 
—TIAX’s assessment of technologies to 
support the NAS panel report,347 
—The analysis conducted by the 
Northeast States Center for a Clean Air Future, International Council on Clean Transportation, Southwest Research Institute and TIAX for reducing fuel consumption of heavy- 
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348NESCCAF, ICCT, Southwest Research 
Institute, and TIAX. Reducing Heavy-Duty Long 
Haul Combination Truck Fuel Consumption and CO
2Emissions. October 2009. 
349ICF International. ‘‘Investigation of Costs for 
Strategies to Reduce Greenhouse Gas Emissions for Heavy-Duty On-Road Vehicles.’’ July 2010. Docket Number EPA–HQ–OAR–2010–0162–0283. 350For example, aerodynamic devices on a 48 
foot box van will perform somewhat better than on a 28 foot box van, so our analysis likely underestimates the benefits of these technologies. See Chapter 2.10.2.1.2.6 of the RIA and Memorandum to Docket EPA–HQ–OAR–2014– 0827. ’’ duty long haul combination tractors 
(the NESCCAF/ICCT study),348 
—The technology cost analysis 
conducted by ICF for EPA,349and 
—Testing conducted by EPA. 
As an initial step in our analysis, we 
identified the extent to which fuel consumption- and CO
2-reducing 
technologies are in use today. The technologies include those that reduce aerodynamic drag at the front, back, and underside of trailers, tires with lower rolling resistance, tire pressure technologies, and weight reduction through component substitution. For our feasibility analysis, we identified a set of technologies to represent the range of those likely to be used in the time frame of the rule. The agencies developed the CO
2and fuel 
consumption standards for each stage of the program by combining the projected effectiveness of trailer technologies and the projected adoption rates for each trailer type. It should be noted that the 
agencies need not and did not attempt to predict the exact future pathway of the industry’s response to the new performance standards for box vans. Rather, we demonstrated one example compliance pathway that could reasonably occur, taking into account cost of the standards (including costs of compliance testing and certification), and needed lead time. More details regarding our analysis can be found in Chapter 2.10 of the RIA. 
(1) Technological Basis of the Standards 
Trailer manufacturers can design a 
trailer to reduce fuel consumption and 
CO
2emissions by addressing the 
trailer’s aerodynamic drag, tire rolling resistance, and weight. Accordingly, the agencies investigated aerodynamic technologies (e.g., skirts and tails), low 
rolling resistance tires, tire pressure systems, and materials that could be used to reduce trailer weight. A description of these technologies, including their expected performance, can be found in Chapter 2.10.2 of the RIA. For box vans, the analysis below presents one possible set of technology designs by which trailer manufacturers could reasonably achieve the standards. However, in practice, trailer manufacturers could choose different technologies, versions of technologies, and combinations of technologies that meet the business needs of their customers while complying with this 
program. 
To minimize complexity, a single van 
is used to represent each box van trailer subcategory in compliance and in our feasibility analysis. Within the short box dry and refrigerated van subcategories (50-foot and shorter), the largest fraction of those trailers are 28 feet in length. Similarly, 53-foot vans make up the majority of the long box dry and refrigerated vans. Consequently, a 28- foot dry van is used to represent all lengths of short dry vans and a 53-foot dry van represents all lengths of long dry vans in this analysis and for compliance. Similar lengths represent the short and long refrigerated van subcategories. This means that manufacturers do not need to analyze the performance of devices for each 
trailer length in each subcategory. This approach provides a conservative estimate of CO
2emissions and fuel 
consumption reductions for the longer vans within a given length subcategory,
350but the agencies believe 
that the need to avoid an overly complex compliance program, reinforced by most of the industry comments, justifies this approach. 
(a) Aerodynamic Technologies 
For box vans under these rules, 
aerodynamic performance of tractor- 
trailers is evaluated using a vehicle’s aerodynamic drag area, C
dA. However, 
unlike the tractor program, the performance of trailer technologies is quantified using changes in C
dA (or 
‘‘delta C dA’’) rather than absolute 
values. This delta C dA classification 
methodology, which measures improvement in performance relative to a baseline, is similar to the SmartWay technology verification program with which most long box van manufacturers are already familiar. The one difference is that, although EPA’s SmartWay aerodynamic verification program uses a relative improvement, the metric is a percent fuel savings, whereas the compliance program for Phase 2 uses change in drag area, delta C
dA. Chapter 
2.10.2.1.1 of the RIA provides a comparison of the SmartWay and Phase 2 metrics. 
The agencies proposed to use a delta 
C
dA measured at zero-yaw (head-on 
wind) in the trailer aerodynamic test procedures (80 FR 40277). However, comments from several stakeholders including ACEEE, CARB, ICCT, RMA, 
STEMCO, and Utility suggested that measurements that account for cross- wind provide a more appropriate measure of the benefits these technologies would experience in the real world, especially for technologies that are effective when the wind is at an angle. The agencies evaluated our own aerodynamic test data, including data collected to justify use of wind-average results in the proposed tractor program, and we recognize that the drag coefficient increases under cross-wind conditions likely seen in real-world operation. Since wind-averaging will account for this, and more appropriately capture aerodynamic benefits from many devices, including several small- scale devices, we are adopting a wind- averaged approach for aerodynamic testing in the trailer program. See Section IV.E.(3)(b)(ii) below and Chapter 2.10.2.1.2 of the RIA for a summary of yaw-angle effect as observed in our aerodynamic testing. The feasibility analysis that follows was performed using wind-averaged delta C
dA values. 
(i) Aerodynamic Technologies for Non- Box Trailers 
The agencies are aware that some side 
skirts have been adapted for the non-box trailers considered in this rule (e.g., tank 
trailers, flatbeds, and container chassis). CARB submitted comments noting that some of these technologies have shown potential for large reductions in drag. At this time, however, we are unable to sufficiently assess the degree of CO
2and 
fuel consumption improvement that could generally be achieved across this segment of the industry and the associated costs of these technologies. In the case of each of the general non-box trailer types included in the trailer program, the range of physical trailer designs, including the areas where aerodynamic devices would be installed, is great, and technologies to date tend to be designed for narrow applications. This lack of basic information about the applicability of future technologies for these trailer types also inhibits our ability to estimate costs, either of the specific 
future designs themselves or of the size of the market for any particular product. As a result, we expect that standards predicated on aerodynamic technologies for these trailer types could result in relatively little emission and fuel consumption improvement at relatively high costs. We will continue to monitor this segment of the trailer industry in this regard and may consider further action in the future. 
The agencies proposed to adopt 
design-based tire standards (i.e. 
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351Although, as noted above, compliance testing 
(where required) uses either a 28 foot van or 53 foot 
van to simplify the compliance process. 352This is in contrast to the tractor program 
where manufacturers obtain absolute C dA values in 
tractor aerodynamic testing. The tractor results are corrected to coastdown values before applying them to bins and obtaining a bin-average value as a compliance input. Trailers measure a delta C
dA and 
do not have a correction to a reference method (see Section IV.E.(3)(b)). The lower threshold approach adopted for the trailer compliance inputs limits the chance of over-predicting performance when a reference method correction is not applied. standards not predicated on any 
aerodynamic technology, and for which neither GEM nor the GEM-based equation is required) for these trailers to eliminate the need for performance testing and to reduce the overall compliance burden for these manufacturers. 80 FR 40257. The data 
submitted and adoption rates suggested by CARB would not provide a large enough reduction in CO
2and fuel 
consumption from non-box trailer aerodynamics to justify the increased burden on these manufacturers. In addition, we believe that there is not currently sufficient information to develop aerodynamic performance standards on these relatively new and untried technologies. Consequently, we are adopting design-based tire technology standards for non-box trailers, as proposed. Non-box trailer manufacturers may include aerodynamic improvements in their future trailer designs, but non-box trailer aerodynamic devices cannot be used for compliance at any point in the Phase 2 program. 
(ii) Aerodynamic Technologies for Box 
Vans 
EPA collected aerodynamic test data 
for several tractor-trailer configurations equipped with technologies similar to common SmartWay-verified technologies. As mentioned previously, SmartWay-verified technologies are evaluated on 53-foot dry vans. However, the CO
2- and fuel consumption-reducing 
potential of some aerodynamic technologies demonstrated on 53-foot dry vans can be translated to refrigerated vans and box trailers of other lengths. Some fleets have opted to add trailer skirts to their refrigerated vans and 28-foot trailers and our testing included dry vans of length 53-foot, 48- foot, 33-foot, and 28-foot.
351 
In order to evaluate performance and 
cost of the aerodynamic technologies, the agencies identified ‘‘packages’’ of individual or combined technologies that are being sold today on box trailers. The agencies also identified distinct performance levels (i.e., bins) for these 
technology packages based on EPA’s aerodynamic testing. All technology packages that produce similar improvements in drag would be categorized as meeting the same bin level of performance. The agencies recognize that there are other technology options that have similar performance to those that we analyzed. We chose the technologies presented here based on their current adoption 
rates and availability of test data. 
The agencies are adopting a regulatory 
structure for box trailers with seven bins to evaluate aerodynamic performance. Note that these bins are slightly different than those proposed. We adjusted the aerodynamic bins to reflect additional data and the use of wind- averaged results. The most notable difference is that we expanded the width of the lower bins. The NPRM Bins III, IV and V were reduced to two bins. Bins V, VI, and VII are identical to the highest bins from the NPRM (NPRM bins VI, VII, and VIII). See Chapter 2.10.2.1.3 of the RIA for a complete description of the development of these bins. 
In the final trailer program, Bin I 
represents a base trailer with no aerodynamic technologies added and a delta C
dA of zero. Bin II is intended to 
capture aerodynamic devices that achieve small reductions in CO
2and 
fuel consumption. Some gap reducers may achieve Bin II on long dry vans, and most individual devices (e.g., skirts 
or tails) will achieve this bin for short box vans. We expect a majority of single aerodynamic devices to perform in the range of Bins III through IV for long box vans. Combinations of devices are expected to meet Bin III for short vans and Bin V or Bin VI levels of performance for long vans. Bin VI represents the more optimized combinations of technologies on long vans. The agencies observed one device combination that met Bin VI in our aerodynamic testing and did not observe any combinations that meet Bin VII. This final level is designed to represent aerodynamic improvements that may become available in the future, including aerodynamic devices yet to be designed or approaches that incorporate changes to the design of trailer bodies. The agencies believe there is ample lead time to optimize additional existing Bin V combinations such that they can also meet Bin VI by MY 2027. However, none of the standards are predicated on the performance of Bin VII aerodynamic improvements. See Table IV–14 and accompanying text. 
Table IV–5 illustrates the bin 
structure that the agencies are adopting as the basis for box vans to demonstrate compliance. The agencies believe these 
bins apply to all box vans (dry and refrigerated vans of various lengths). Although the underlying test data from EPA’s aerodynamic testing program reflect some variation due to differences in test methods, as well as differences in trailer and aerodynamic device models, the agencies believe that each of these bins covers a wide enough range of delta C
dAs to account for the 
uncertainty. See RIA Chapter 2.10 for 
more information. 
When manufacturers obtain test 
results, they would check the range 
shown in Table IV–5 for the measured C
dA value and use the corresponding 
input value for compliance. Note that these are wind-averaged results, as described in Chapter 2.10 of the RIA and below in Section IV.E.(3)(b)(ii). Also, the input is a threshold and not an average of the bin range. Consequently, the compliance results will be a conservative estimate of the performance of most technologies that achieve a given bin.
352 
TABLE IV–5—T ECHNOLOGY BINS 
USEDTOEVALUATE TRAILER BENE-
FITS AND COSTS  
Bin Delta C dA 
Measured 
value Input value for 
compliance 
Bin I .......... <0.10 .............. 0.0 
Bin II ......... 0.10–0.39 ....... 0.1 
Bin III ........ 0.40–0.69 ....... 0.4 
Bin IV ........ 0.70–0.99 ....... 0.7 
Bin V ......... 1.00–1.39 ....... 1.0 
Bin VI ........ 1.4–1.79 ......... 1.4 
Bin VII ....... ≥1.80 .............. 1.8 
To develop the standards for box 
trailers, the agencies assessed the CO 2 
emissions and fuel consumption impacts of the aerodynamic bins using an equation based on the GEM vehicle simulation tool. See Section II and Section IV.E. (1) for more information about GEM and Chapter 2.10.5 of the RIA for our development of the GEM- based equation. Within GEM, and reflected in the results of the equation, the aerodynamic performance of each box van subcategory is evaluated by subtracting the delta C
dA shown in 
Table IV–5 from the C dA value 
representing a specific standard tractor pulling a trailer with no CO
2- or fuel 
consumption-reducing technologies (i.e., a ‘‘no-control’’ trailer). In other 
words, the tractor-trailer is simulated with improvements to the baseline trailer. The agencies chose to model the no-control long box dry van using a C
dA 
value of 6.0 m2(the mean wind- 
averaged C dA from EPA’s wind tunnel 
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353Letter, Truck Trailer Manufacturers 
Association to EPA. Received on October 16, 2014. 
Docket EPA–HQ–OAR–2014–0827–0146. testing). The single, short box dry vans 
showed lower C dA values compared to 
its 53-foot counterpart in EPA’s wind tunnel testing with an average of 5.6 m
2. 
The agencies did not test any refrigerated vans, but we assumed a refrigerated van’s TRU would behave similar to a gap reducer. Our test results in Chapter 2.10.2.1.3 did not show gap reducer technologies to have a significant effect on C
dA and the 
agencies accordingly assigned the same default C
dA to refrigerated and dry box 
vans in GEM. Note that the trailer subcategories that have design standards 
(i.e., non-box and non-aero box trailers) 
do not have numerical standards to meet, and do not have defaults in GEM. Table IV–6 illustrates the no-control drag areas (C
dA) associated with each 
trailer subcategory. 
TABLE IV–6—D EFAULT AERODYNAMIC  
DRAG AREA(CdA) V ALUES ASSOCI -
ATED WITH EACH (NO-CONTROL ) 
TRAILER MODELED IN GEM 
Trailer subcategory C dA (M2) 
Long Dry Van ....................... 6.0 
Short Dry Van ....................... 5.6 
Long Ref. Van ...................... 6.0 
Short Ref. Van ...................... 5.6 
Current ‘‘boat tail’’ devices, applied to 
the rear of a trailer with rear swing doors, are typically designed to collapse flat as the trailer rear doors are opened. If the tail structure can remain in the collapsed configuration when the doors are closed, the benefit of the device is lost. We requested comment on whether we should require that trailer manufacturers using such devices for compliance with these standards only use designs that automatically deploy when the vehicle is in motion. STEMCO commented that automatic deployment should not be required, since those systems are more expensive, and in their view, not necessary for the Phase 2 program. STEMCO believes that, since there is a strong economic incentive for operators to ensure that the devices are correctly deployed in order to achieve the greatest fuel cost payback, a regulatory requirement related to deployment is not needed. We generally agree, and have not included such a requirement in the final trailer program. For this analysis, we consider all boat tails to be properly deployed. 
The agencies are aware that physical 
characteristics of some box trailers influence the technologies that can be applied. For instance, the TRUs on refrigerated vans are located at the front of the trailer, which prevents the use of current gap-reducers, either by occupying the space that a front-end fairing would use, or by blocking air flow that the TRU needs for cooling purposes. Similarly, drop deck dry vans have lowered floors between the landing gear and the trailer axles that limit the ability to use side skirts. We discuss another example, roll-up rear doors, in Section IV.C.(1)(a) above. The agencies considered the availability and limitations of aerodynamic technologies for each trailer type evaluated in our feasibility analysis of the standards. 
(b) Tire Rolling Resistance 
Similar to the Phase 2 tractor and 
vocational vehicle programs, the 
agencies are adopting standards based on adoption of lower rolling resistance tires. While some box vans continue to be sold with tires of higher rolling resistances, the agencies believe most box van tires currently achieve a tire C
RRof 6.0 kg/ton or better. Feedback 
from several box trailer manufacturers indicates that the standard tires offered on their new trailers are SmartWay- verified tires (i.e., C
RRof 5.1 kg/ton or 
better). An informal survey of members from the Truck Trailer Manufacturers Association (TTMA) in 2014 indicates about 85 percent of box vans sold at that time had SmartWay tires.
353 
The agencies evaluated two levels of 
tire performance for box vans beyond the baseline trailer tire rolling resistance level (TRRL) of 6.0 kg/ton. The first performance level was set at the criteria for SmartWay-verification for trailer tires, 5.1 kg/ton, which is a 15 percent reduction in C
RRfrom the baseline. As 
mentioned previously, several tire models available today achieve rolling resistance values well below the present SmartWay threshold. Given the multiple year phase-in of the standards, the agencies expect that tire manufacturers will continue to respond to demand for more efficient tires and will offer increasing numbers of tire models with rolling resistance values significantly better than today’s typical LRR tires. In this context, we believe it is reasonable to expect a large fraction of the trailer industry could adopt tires with rolling resistances at a second performance level that will achieve an additional reduction in rolling resistance, especially in the later stages of the program. The agencies project the C
RR 
for this second level of performance to be a value of 4.7 kg/ton (a 22 percent reduction from the baseline tire). 
The vast majority of box van miles 
occur on-road, and current LRR tire designs are appropriate and effective for 
those applications. We note that current designs of LRR tires may not be appropriate for some non-box trailer types, including those that operate significantly in off-road conditions. We expect that the tire manufacturing industry will continue to expand their offerings of tire designs to additional applications. Regardless, by limiting the non-box trailer types covered by the final trailer program to those generally used in on-highway applications (tanks, flatbeds, and container chassis), the program avoids most of these potential situations. 
We received comment from Michelin 
supporting the use of 6.0 kg/ton as the box trailer tire rolling resistance baseline, but they expressed concern that the SmartWay threshold of 5.1 kg/ ton does not apply for non-box trailers, and could compromise their operation. Similarly, the Rubber Manufacturers Association indicated that a baseline of 6.0 kg/ton does not apply to non-box trailers. The agencies agree that the baseline tires for non-box trailers should have a higher rolling resistance, but we did not receive any comments that included C
RRdata. For the analysis for 
the final rules, the agencies revised the baseline C
RRto a value of 6.5 kg/ton for 
non-box trailer manufacturers. The updated non-box trailer designs standards require LRR tires of 6.0 kg/ton in the first stage of the program and 5.1 kg/ton in the later years. Nowhere in the final program do we require Level 4 tires for non-box trailers. 
The agencies evaluated four tire 
rolling resistance levels, summarized in Table IV–7, in the feasibility analysis of the following sections. It should be noted that these levels are targets for setting the stringency of the box van performance standards and rolling 
resistance thresholds for the non-box design standards. For compliance, box van manufacturers have the option to use tires with any rolling resistance and are not be limited to these TRRLs. 
TABLE IV–7—S UMMARY OF TRAILER  
TIREROLLING RESISTANCE LEVELS  
EVALUATED  
Tire rolling resistance level C RR(kg/ton) 
Level 1 (Non-Box Baseline) 6.5 
Level 2 (Box Van Baseline ) 6.0 
Level 3 .................................. 5.1 
Level 4 .................................. 4.7 
(c) Tire Pressure Systems 
Tire pressure monitoring systems 
(TPMS) and automatic tire inflation systems (ATIS) are designed to address under-inflated tires. Both systems alert 
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354See Chapter 2.10.2.3 of the RIA. 355Scarcelli, Jamie. ‘‘Fuel Efficiency for Trailers’’ 
Presented at ACEEE/ICCT Workshop: Emerging 
Technologies for Heavy-Duty Vehicle Fuel Efficiency, Wabash National Corporation. July 22, 2014. 
356‘‘Weight Reduction: A Glance at Clean Freight 
Strategies,’’ EPA SmartWay. EPA420F09–043. Available at: http://permanent.access.gpo.gov/gpo38937/EPA420F09-043.pdf. 
357Memorandum dated June 2015 regarding 
confidential weight reduction information obtained 
during SBREFA Panel. Docket EPA–HQ–OAR– 2014–0827. 
358Randall Scheps, Aluminum Association, ‘‘The 
Aluminum Advantage: Exploring Commercial Vehicles Applications,’’ presented in Ann Arbor, Michigan, June 18, 2009. drivers if a tire’s pressure drops below 
its set point. TPMS are simpler and merely monitor tire pressure. Thus, they require user-interaction to reinflate to the appropriate pressure. Today’s ATIS, on the other hand, typically take advantage of trailers’ air brake systems to supply air back into the tires (continuously or on demand) until a selected pressure is achieved. In the event of a slow leak, ATIS have the added benefit of maintaining enough pressure to allow the driver to get to a safe stopping area. See Chapter 2.10.2.3 of the RIA for more on tire pressure systems. 
The agencies proposed that ATIS be 
the only tire pressure system allowed to be used to meet the standards, since TPMS require action on the part of the operator. Our position at the time of the proposal was that TPMS could not sufficiently guarantee proper inflation. 80 FR 40262. However, some commenters stated that TPMS are effective in encouraging proper tire pressure maintenance, and should also be eligible as a compliance option. Commenters did not provide specific data about the overall effectiveness of TPMS. However, we are aware of the emergence of TPMS that use telematics to automatically report tire pressure data to a central contact. It is also our understanding that there is a growing recognition among fleet and individual operators of the potential value that these systems can provide to operators, so long as the operator and/or a central fleet contact take action to address cases of low tire pressures indicated by the systems. These factors have led the agencies to reconsider our approach to TPMS. As described in Section IV.B. above, we now believe that TPMS provides overall fuel consumption and CO
2reductions, and the final program 
recognizes the option of TPMS as part of the compliance path for all covered trailers. 
NHTSA and EPA recognize the role of 
proper tire inflation in maintaining optimum tire rolling resistance during normal trailer operation. Rather than require performance testing of tire pressure systems, the agencies recognize the benefits of these systems, and the program applies default reduction values for manufacturers that incorporate ATIS or TPMS into their trailer designs. Based on information available today, we believe that most tire pressure technologies and systems in typical use perform similarly. 
We proposed to assign a 1.5 percent 
reduction in CO
2and fuel consumption 
for all trailers that implement ATIS, based on information available at that time.
354We did not receive any 
comments directly addressing the 
proposed reduction value. However, the agencies believed it was appropriate to align the effectiveness of tire pressure systems for tractors, trailers and vocational vehicles, and the agencies are adopting a 1.2 percent reduction for ATIS for each of these vehicle categories. As just noted, we are also adopting provisions that recognize a CO
2and fuel consumption reduction for 
TPMS. The agencies believe that sufficient incentive exists for truck operators to address low tire pressure conditions if they are notified that they exist through a TPMS (for example, for reasons of personal safety as well as fuel savings). However, we recognize the dependence on operator action for TPMS, and we are adopting a reduction of 1.0 percent for these systems. We have concluded that the use of these systems can consistently ensure that tire pressure and tire rolling resistance are maintained. Sections III.D.(1)(b) and V.C.(1)(a) also discuss the overall Phase 2 program’s treatment of both types of tire pressure systems for tractors and vocational vehicles, respectively. 
We selected the standards for most 
box vans with the expectation that a high rate of adoption of ATIS will occur during all years of the phase-in of the program, and that manufacturers of non- aero vans, and non-box trailers will install either TPMS or ATIS, as well as LRR tires, to comply with the design- based tire standards. 
In the performance-based compliance 
approach to full- and partial-aero box vans, the program incorporates a small 
discount in the value of TPMS in the compliance equation as compared to ATIS, to reflect the inherent user interaction required for TPMS to be effective. In the design-based compliance approach for non-aero vans and non-box trailers, manufacturers may comply by using either TPMS or ATIS, which in that case are valued equally. See Section IV.D.(2)(d) below for discussion of our estimates of the degree of adoption of tire pressure systems prior to and at various points in the phase-in of the proposed program. 
(d) Weight Reduction 
As proposed, the trailer program 
provides manufacturers the option of 
complying through the substitution of specified lighter-weight components that can be clearly isolated from the trailer as a whole. In the proposal, the agencies identified several conventional components with lighter-weight substitutes that are currently available (e.g., substituting conventional dual 
tires mounted on steel wheels with 
wide-based single tires mounted on aluminum wheels). 80 FR 40262. Several commenters provided additional component suggestions, with information about their typical associated weight reductions. The component substitutions we have included in the final program, and the weight savings that we are associating with each component, are presented in the RIA Chapter 2.10.2.4 and 40 CFR 1037.515. The agencies have identified 12 common trailer components for which lighter weight options are currently available (see 40 CFR 1037.515).
355 356 357 358 Manufacturers 
that adopt these technologies and choose to use them as part of their compliance strategy sum the associated weight reductions and apply those values in the GEM-based compliance equation (see Section IV.E.(2)(a)). We believe that the initial cost of these component substitutions is currently substantial enough that only a relatively small segment of the industry has adopted these technologies today. 
There is no clear ‘‘baseline’’ for 
current trailer weight against which lower-weight designs could be compared for regulatory purposes. For this reason, the agencies do not believe it is appropriate or fair across the industry to apply overall weight reductions toward compliance using a universal baseline trailer. However, the agencies do believe it is appropriate to give a manufacturer credit for overall weight reduction achieved in their own product line. In the final program, we are clarifying that manufacturers of box trailers with significant weight reductions have the option of using our off-cycle credit process to compare overall weight reduction of future trailers using an appropriate baseline from their own production. This process allows manufacturers to do a comparison of their new trailer to a previous model to quantify the weight reduction improvements. Manufacturers wishing to go this route should contact 
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359Memorandum to Docket EPA–HQ–OAR– 
2014–0827, ‘‘Evaluation of Weight Reduction Distribution in Response to Public Comments from 
Wabash National Corporation,’’ June 18, 2016. EPA in advance to discuss appropriate 
test procedures. More information about the off-cycle process can be found in Section IV.E.(5)(d) and in 40 CFR 1037.610 or 49 CFR 535.7. Note that non-box trailers and non-aero box vans have design standards that are limited to adoption of lower rolling resistance tires and tire pressure systems, and do not include weight reduction as part of their simplified compliance demonstration. 
The agencies recognize that when 
weight reduction is applied to a trailer, some operators will replace that saved weight with additional payload. To account for this in the average vehicle represented by EPA’s GEM vehicle simulation tool, it is assumed that one- third of any weight reduction will be applied to the payload. Wabash suggested that the agencies reconsider the distribution of weight between payload and trailer weight when modeling weight reduction, expressing concern that the reduction was not receiving appropriate credit in the program. Although the simulated vehicle in GEM only receives 
2⁄3of the 
weight reduction applied, the model calculates CO
2emissions and fuel 
consumption on a per-ton-mile basis by dividing by the payload, which now includes the extra one-third from weight reduction. Dividing by a larger payload results in lower CO
2and fuel 
consumption values.359 
For 53-foot vans simulated in GEM 
(and thus, for the GEM-based equation), it takes a weight reduction of nearly 1,000 pounds before a one percent fuel savings is achieved. The impact of the same 1000 pounds is slightly greater for shorter vans, due to their lower overall weight, but the effectiveness of weight reduction is still relatively low compared to the effectiveness of many aerodynamic technologies. In addition, large material substitutions can be costly. The agencies thus believe that few trailer manufacturers will apply weight reduction solely as a means of achieving reduced fuel consumption and CO
2emissions. Therefore, we are 
adopting standards that could be met without reducing weight—that is, the feasible compliance path set out by the agencies for this program does not assume weight reduction as a compliance avenue. However, as discussed here, the final program includes the option for box trailer manufacturers to apply weight reduction to some of their trailers as part of their compliance strategy. 
(2) Effectiveness, Adoption Rates, and 
Costs of Technologies for the Trailer Standards 
The agencies evaluated the 
technologies above as they apply to each of the trailer subcategories. The next sections describe the effectiveness, adoption rates and costs associated with these technologies. The effectiveness and adoption rate projections were used to derive these standards. 
(a) No-Control Default Tractor-Trailer 
Vehicles in GEM (Box Van Standards Only) 
The regulatory purpose of EPA’s 
heavy-duty vehicle compliance tool, GEM, is to combine the effects of trailer technologies through simulation so that they can be expressed as g/ton-mile and gal/1000 ton-mile and thus avoid the need for direct testing of each trailer being certified. All of the standards for box vans (with the exception of non- aero box vans, which have design standards) use an equation derived from GEM to demonstrate compliance. The trailer program has separate performance standards for each box van subcategory (again, with the exception of non-aero box vans) and each of these subcategories is modeled as a tractor- trailer combination that we believe reflects the average physical characteristics and use pattern of vans in that subcategory. Long vans are pulled by sleeper cab tractors and use the long-haul drive cycle weightings. Short vans are pulled by day cabs and have the short-haul drive cycle weightings. Short vans also have a lighter payload and overall vehicle weight compared to their longer counterparts. 
Table IV–8 highlights the relevant 
vehicle characteristics for the no-control default of each subcategory (i.e., zero 
CO
2- or fuel consumption reducing 
technologies installed). Baseline trailer tires are used, and the drag area, which is a function of the aerodynamic characteristics of both the tractor and trailer, is set to the values shown previously in Table IV–6. Weight reduction and tire pressure systems are not applied in these default vehicles. Chapter 2.10 of the RIA provides a detailed description of the development of these default tractor-trailers. Note that the agencies proposed to use Class 8 tractors for all default tractor-trailer vehicles. However, we are adopting the final standards based on 4x2 Class 7 tractors for short box vans. 
TABLE IV–8—C HARACTERISTICS OF THE NO-CONTROL DEFAULT TRACTOR -TRAILER VEHICLES IN GEM 
Dry van Refrigerated van 
Trailer length Long Short Long Short 
Standard Tractor: 
Class ........................................... Class 8 .......................... Class 7 .......................... Class 8 .......................... Class 7. 
Cab Type .................................... Sleeper .......................... Day ................................ Sleeper ........ .................. Day. 
Roof Height ................................ High ............................... High ............................... High .......... ..................... High. 
Axle Configuration ...................... 6 x 4 .............................. 4 x 2 .............................. 6 x 4 .............................. 4 x 2. 
Engine ........................................ 2018 MY 15L, 455 HP .. 2018 MY 11L, 350 HP .. 2018 MY 15L, 455 HP .. 2018 MY 11L, 350 H P. 
Steer Tire RR (kg/ton) ................ 6.54 ............................... 6.54 ............................... 6.54 ............... ................ 6.54. 
Drive Tire RR (kg/ton) ................ 6.92 ............................... 6.92 ............................... 6.92 ............... ................ 6.92. 
Drag Area, C dA (m2) .................. 6.0 ................................. 5.6 ................................. 6.0 ................................. 5.6. 
Number of Trailer Axles ............. 2 .................................... 1 .................................... 2 ................ .................... 1. 
Trailer Tire RR (kg/ton) .............. 6.00 ............................... 6.00 ............................... 6.00 ............... ................ 6.00. 
Total Weight (kg) ........................ 31978 ............................ 18306 ............................ 33778 ............... ............. 20106. 
Payload (tons) ............................ 19 .................................. 10 .................................. 19 ........... ....................... 10. 
Tire Pressure System Use ......... 0 .................................... 0 .................................... 0 ................... ................. 0. 
Weight Reduction (lb) ................. 0 .................................... 0 .................................... 0 .............. ...................... 0. 
Drive Cycle Weightings: 
65-MPH Cruise ........................... 86% ............................... 64% ............................... 86% ................ ............... 64%. 
55-MPH Cruise ........................... 9% ................................. 17% ............................... 9% ................ ................. 17%. 
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TABLE IV–8—C HARACTERISTICS OF THE NO-CONTROL DEFAULT TRACTOR -TRAILER VEHICLES IN GEM—Continued 
Dry van Refrigerated van 
Trailer length Long Short Long Short 
Transient Driving ........................ 5% ................................. 19% ............................... 5% ............... .................. 19%. 
(b) Effectiveness of Technologies 
As already noted, the agencies 
recognize trailer improvements via four 
performance parameters: Aerodynamic drag reduction, tire rolling resistance 
reduction, the adoption of tire pressure systems, and weight-reducing strategies. Table IV–9 summarizes the performance levels the agencies evaluated for each of these parameters based on the technology characteristics outlined in Section IV.D.(1). 
TABLE IV–9—P ERFORMANCE PARAMETERS FOR THE TRAILER PROGRAM  
Aerodynamics (Delta C dA, m2): 
Bin I ................................................................................................... 0.0. 
Bin II .................................................................................................. 0.1. 
Bin III ................................................................................................. 0.4. 
Bin IV ................................................................................................. 0.7. 
Bin V .................................................................................................. 1.0. 
Bin VI ................................................................................................. 1.4. 
Bin VII ................................................................................................ 1.8. 
Tire Rolling Resistance (C RR, kg/ton): 
Tire Level 1 ....................................................................................... 6.5. 
Tire Level 2 ....................................................................................... 6.0. 
Tire Level 3 ....................................................................................... 5.1. 
Tire Level 4 ....................................................................................... 4.7. 
Tire Inflation System (% reduction): 
ATIS ................................................................................................... 1.2. 
TPMS ................................................................................................. 1.0. 
Weight Reduction (lb): 
Weight ............................................................................................... 1/3 added to payload, remaining reduces overall vehicle weight. 
These performance parameters have 
different effects on each trailer 
subcategory due to differences in the simulated trailer characteristics. Table IV–10 shows the agencies’ estimates of the effectiveness of each parameter for the four box van types. Each technology was evaluated using the baseline parameter values for the other technology categories. For example, each aerodynamic bin was evaluated using the baseline tire (6.0 kg/ton) and the baseline weight reduction option (zero pounds). The table shows that aerodynamic improvements offer the largest potential for CO
2emissions and 
fuel consumption reductions, making them relatively effective technologies. 
TABLE IV–10—E FFECTIVENESS (PERCENT CO 2EMISSIONS AND FUELCONSUMPTION ) OFTECHNOLOGIES FOR BOXVANS 
IN THE TRAILER PROGRAM  
Aerodynamics Delta CdA (m2) Dry van Refrigerated van 
Long 
(%) Short 
(%) Long 
(%) Short 
(%) 
Bin I ............................................................ 0.0 0 0 0 0 
Bin II ........................................................... 0.1 1 1 1 1 
Bin III .......................................................... 0.4 3 3 3 3 
Bin IV ......................................................... 0.7 5 5 5 5 
Bin V .......................................................... 1.0 7 7 7 7 
Bin VI ......................................................... 1.4 9 10 9 10 
Bin VII ........................................................ 1.8 12 13 12 13 
Tire Rolling Resistance CRR(kg/ton) Dry van Refrigerated van 
Long Short Long Short 
Level 1 ....................................................... 6.5 ........................ ........................ ............. ........... ........................
Level 2 ....................................................... 6.0 0 0 0 0 
Level 3 ....................................................... 5.1 ¥2 ¥1 ¥2 ¥1 
Level 4 ....................................................... 4.7 ¥3 ¥2 ¥3 ¥2 
Weight Reduction Weight (lb) Dry van Refrigerated van 
Long Short Long Short 
Baseline ..................................................... 0 0 0 0 0 
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360Letter, Truck Trailer Manufacturers 
Association to EPA. Received on October 16, 2014. 
Docket EPA–HQ–OAR–2014–0827–0146. TABLE IV–10—E FFECTIVENESS (PERCENT CO 2EMISSIONS AND FUELCONSUMPTION ) OFTECHNOLOGIES FOR BOXVANS 
IN THE TRAILER PROGRAM —Continued 
Aerodynamics Delta CdA (m2) Dry van Refrigerated van 
Long 
(%) Short 
(%) Long 
(%) Short 
(%) 
Option 1 ..................................................... 100 0 0 0 0 
Option 2 ..................................................... 500 1 1 1 1 
Option 3 ..................................................... 1000 1 2 1 2 
Option 4 ..................................................... 2000 2 4 2 4 
(c) Baseline Tractor-Trailer To Evaluate 
Benefits and Costs 
In order to evaluate the benefits and 
costs of the final standards for each of the ten subcategories, it is necessary to establish a reference point for comparison. As mentioned previously, the technologies described in Section IV.D.(1) exist in the market today, and their adoption is driven by available fuel savings as well as by the voluntary SmartWay Partnership and California’s tractor-trailer requirements. For these rules, the agencies identified baseline tractor-trailers for each trailer subcategory based on the technology adoption rates we project would exist in MY 2018 if this trailer program was not implemented. 
CARB’s comments noted the informal 
survey of TTMA members provided in letter from TTMA to EPA in 2014 regarding current adoption rates of several technologies. CARB suggested 
that our proposed baseline adoption rates did not reflect the data in that letter.
360We have reassessed available data and we believe that higher baseline 
rates are more appropriate, and have made corresponding changes in our analysis. First, we created a separate baseline for box vans that qualify as full- aero, box vans that qualify as partial- aero, and box vans that qualify as non- aero. Because of the challenges of installing effective aerodynamic devices, market forces are not likely to significantly drive adoption of CO
2- and 
fuel-consumption reducing technologies 
for trailers with work performing equipment (e.g., lift gates), and we are 
projecting zero adoption of the technologies in the baselines for partial- and non-aero box vans before the start of this program. Similarly, we assume that there will be zero adoption of these technologies for non-box trailers in the baseline. We updated the baseline tire rolling resistance level for non-box trailers to reflect the lower 6.5 kg/ton value in response to RMA’s comment that these trailers have different operational characteristics and should not have the same baseline tires as box 
vans (see Section IV.D.(1)(b) above). 
TTMA’s survey indicated that 35 
percent of long vans and less than 2 percent of vans under 53-foot in length include aerodynamic devices, and over 80 percent have adopted lower rolling resistance tires. The agencies believe the trailers for which manufacturers have adopted these technologies are likely to be trailers that would qualify as ‘‘full- aero’’ vans, and we adjusted our baselines to reflect these values. Our baseline assumes that aerodynamics would increase to 40 percent adoption for full-aero long vans (dry and refrigerated) and 5 percent for full-aero short vans by 2018 without the Phase 2 standards. We also assume adoption of lower rolling resistance tires (Level 1) will increase to 90 percent and ATIS to 45 percent in the baseline. We held these adoption rates constant throughout the timeframe of the rules. Table IV–11 summarizes the updated baseline trailers for each trailer subcategory. 
TABLE IV–11—E STIMATED ADOPTION RATES AND AVERAGE PERFORMANCE PARAMETERS FOR THE FLATBASELINE  
TRAILERS FOR MY 2018 ANDLATER  
Technology Long vans Short vans All partial-aero, 
non-aero vans All non-box trailers 
Aerodynamics: 
Bin I .......................................................................... 55% 95% 100% 100% 
Bin II ......................................................................... ................................ 5% 
Bin III ........................................................................ 40% 
Bin IV ........................................................................ 5% 
Bin V.
Bin VI.
Bin VII.
Average Delta C dA (m2)a.................................. 0.2 0.0 0.0 0.0 
Tire Rolling Resistance: 
Level 1 ...................................................................... ................................ .................. .............. ................................ 100% 
Level 2 ...................................................................... 10% 10% 100% 
Level 3 ...................................................................... 90% 90% 
Level 4.
Average C RR(kg/ton)a....................................... 5.2 5.2 6.0 6.5 
Tire Pressure Systems: 
ATIS .......................................................................... 45% 30% 
TPMS.
Average Pressure System Reduction (%)a...... 0.5% 0.3% 0.0% 0.0% 
Weight Reduction: 
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361Daimler Truck North America. SuperTruck 
Program Vehicle Project Review. June 19, 2014. 
Docket EPA–HQ–OAR–2014–0827. TABLE IV–11—E STIMATED ADOPTION RATES AND AVERAGE PERFORMANCE PARAMETERS FOR THE FLATBASELINE  
TRAILERS FOR MY 2018 ANDLATER —Continued 
Technology Long vans Short vans All partial-aero, 
non-aero vans All non-box trailers 
Weight (lb)b.
Notes: 
A blank cell indicates a zero value. 
aCombines adoption rates with performance levels shown in Table IV–9. 
bWeight reduction was not projected for the baseline trailers. 
Also shown in Table IV–11 are 
average aerodynamic performance (delta 
CdA), average tire rolling resistance 
(CRR), and average reductions due to use 
of tire pressure systems and weight reduction for each reference trailer. These values indicate the performance of theoretical average tractor-trailers that the agencies project would be in use in 2018 if no federal regulations were in place for trailer CO
2and fuel 
consumption. The average tractor-trailer vehicles serve as baselines for each trailer subcategory. 
Because the agencies cannot be 
certain about future trends, we also considered a second baseline. This 
dynamic baseline reflects the possibility that, absent a Phase 2 regulation, there would be continuing adoption of aerodynamic technologies in the long box trailer market after 2018 that reduce fuel consumption and CO
2emissions. 
This case assumes the research funded 
and conducted by the federal government, industry, academia and other organizations would, after 2018, result in the adoption of additional aerodynamic technologies beyond the levels required to comply with existing regulatory and voluntary programs. One example of such research is the Department of Energy SuperTruck 
program which has a goal of demonstrating cost-effective measures to improve the efficiency of Class 8 long- haul freight trucks by 50 percent by 2015.
361This baseline assumes that by 
2040, 75 percent of new full-aero long 
vans would be equipped with SmartWay-verified aerodynamic devices. The agencies project that the lower rolling resistance tires and ATIS adoption would remain constant. Table IV–12 shows the agencies’ projected adoption rates of technologies in the dynamic baseline. 
TABLE IV–12—P ROJECTED ADOPTION RATES AND AVERAGE PERFORMANCE PARAMETERS FOR THE DYNAMIC BASELINE  
FORLONG DRY AND REFRIGERATED VANS 
[All other trailers are the same as Table IV–11] 
Technology Long dry and refrigerated 
Model year 2018 2021 2024 2027 2040 
Aerodynamics: 
Bin I ............................................................................... 55% 50% 45% 40% 20% 
Bin II.
Bin III ............................................................................. 40% 45% 50% 55% 75% 
Bin IV ............................................................................ 5% 5% 5% 5% 5% 
Bin V.
Bin VI.
Bin VII.
Average Delta C dA (m2)a...................................... 0.2 0.3 0.3 0.3 0.4 
Tire Rolling Resistance: 
Level 1.
Level 2 .......................................................................... 10% 10% 10% 10% 10% 
Level 3 .......................................................................... 90% 90% 90% 90% 90% 
Level 4.
Average C RR(kg/ton)a........................................... 5.2 5.2 5.2 5.2 5.2 
Tire Pressure Systems: 
ATIS .............................................................................. 45% 45% 45% 45% 45% 
TPMS.
Average Pressure System Reduction (%)a.......... 0.5% 0.5% 0.5% 0.5% 0.5% 
Weight Reduction (lbs): 
Weightb.
Notes: 
A blank cell indicates a zero value. 
aCombines adoption rates with performance levels shown in Table IV–9. 
bWeight reduction was not projected for the baseline trailers. 
The agencies applied the vehicle 
attributes from Table IV–8 and the 
average performance values from Table IV–11 in the Phase 2 GEM vehicle simulation to calculate the CO
2 
emissions and fuel consumption performance of the baseline tractor- trailers. The results of these simulations are shown in Table IV–13. We used 
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362No averaging is allowed for partial-aero box 
van reduced standards, or the design-based 
standards for non-aero box vans and non-box trailers. these CO 2and fuel consumption values 
to calculate the relative improvements 
that will occur over time with a regulatory program. Note that the large difference between the per ton-mile values for long and short trailers is due primarily to the large difference in assumed payload (19 tons compared to 10 tons) and the small difference between dry and refrigerated vans of the same length are due to differences in vehicle weight because of the 1800 pounds added to the simulated refrigerated vans to account for the TRU (see the vehicle characteristics of the simulated tractor-trailers Table IV–8). The alternative baseline shown in Table IV–12 mainly impacts the long-term projections of benefits beyond 2027, which are analyzed in Chapters 5–7 of the RIA. 
TABLE IV–13—CO 2EMISSIONS AND FUELCONSUMPTION RESULTS FOR THE BASELINE TRACTOR -TRAILERS  
Full-aero 
dry van Full-aero 
refrigerated van Partial-aero 
dry van Partial-aero 
refrigerated van 
Length Long Short Long Short Long Short Long Short 
CO 2Emissions (g/ton-mile) ............................. 83.2 126.5 84.9 130.3 86.1 128.5 87.9 132.4 
Fuel Consumption (gal/1000 ton-miles) ........... 8.17289 12.42633 8.33988 12.79961 8.45776 12.62279 8.63458 13.00589 
(d) Projected Technology Adoption Rates for the Trailer Standards 
The agencies developed their 
performance and design standards based on projected adoption rates of certain technologies. This section describes how these adoption rates were applied for each of the trailer subcategories. 
(i) Aerodynamic and Tire Technologies 
for Full- and Partial-Aero Box Vans 
As described in Section 0, the 
agencies evaluated several alternatives for the trailer program. Based on our analysis and comments received, the agencies are adopting standards consistent with the agencies’ respective statutory authorities. The agencies proposed alternatives that were based on the use of averaging and the technology adoption rates for those alternatives at proposal reflected the use of averaging. As noted in Section IV.B., we received nearly unanimous, persuasive comments from the trailer industry opposing averaging and the agencies reconsidered the use of averaging in the early years of the program. The agencies designed the trailer program to have no averaging in MY 2018 through MY 2026. In those years, all box vans sold must meet the standards using any combination of available technologies. In MY 2027, when the trailer manufacturers are more comfortable with compliance and the industry is more familiar with the technologies, trailer manufacturers will have the option to use averaging to meet the standards. See Section IV.E.(5)(b) below for additional information about averaging. 
Table IV–14 and Table IV–15 present 
sets of assumed adoption rates for aerodynamic, tire, and tire pressure technologies that a manufacturer could apply to meet the box van standards. Since averaging would not be allowed for MY 2018–MY 2026, the adoption rates consist of the combination of a single aerodynamic bin (not reflecting any averaging of aerodynamic controls), tire rolling resistance level, and tire pressure system. As mentioned previously, manufacturers can choose other combinations to meet the standards. Chapter 2.10 of the RIA shows several examples of alternative compliance pathways. 
The adoption rates in Table IV–14 
begin with all full-aero long box vans achieving current SmartWay-level aerodynamics (Bin III) in MY 2018 with a stepwise progression to achieving Bin V in 2024. The adoption rates for full- aero short box vans in Table IV–15 assume no adoption of aerodynamic devices in MY 2018, adoption of single aero devices in MY 2021, and combinations of devices by MY 2024. Although the shorter lengths of these trailers can restrict the design of aerodynamic technologies that fully match the SmartWay-like performance levels of long boxes, we nevertheless expect that trailer and device manufacturers will continue to innovate skirt, under-body, rear, and gap- reducing devices and combinations to achieve improved aerodynamic performance on these shorter trailers. 
The adoption rates in MY 2018–MY 
2026 are projected to be 100 percent for each technology, instead of an industry average seen in other vehicle sectors in the Phase 2 program. Since we are not considering averaging during those years, each set of adoption rates is one example of how an individual trailer in each subcategory could comply. Through MY 2026, the standards are based on technologies that exist today. We evaluated one technology in our aerodynamic test programs that met Bin VI levels of performance for long vans, suggesting that this bin can be met with combinations of existing aerodynamic technologies, but none of our tested technologies that met Bin IV levels of performance for short vans. We could not justify standards based on 100 
percent adoption of those levels of performance as a final step in our progression of stringency. However, the industry has made great progress toward improving trailer aerodynamics in recent years and are continuing to optimize these technologies. Although we are not projecting fundamentally new technologies for trailers, we do 
believe aerodynamic performance will evolve in the trailer industry as a result of this rulemaking. Based on the recent rate of improvement, the agencies believe that there is ample lead time to optimize additional existing Bin V and Bin III combinations such that they can also meet Bins VI and IV by MY 2027 and it is reasonable to project that more than half of these full-aero capable trailers will have aerodynamic improvements greater than what is possible with today’s technologies. Our projected aerodynamic improvements in MYs 2027 and later reflect this performance potential. 
The MY 2027 full-aero box van 
standards are based on an averaging program.
362We cannot predict what 
technologies or trailer designs may be adapted to meet this level of aerodynamic performance, but an averaging program incentivizes manufacturers to develop advanced designs with the benefit that not all trailers in their production have to meet the same level of performance. The gradual increase in assumed adoption of aerodynamic technologies throughout the phase-in to the MY 2027 standards recognizes that even though many of the technologies are available today and technologically feasible throughout the phase-in period, adoption of more advanced technologies will likely take time. The adoption rates we are 
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projecting in the interim years and the 
standards that we developed from these rates represent steady and reasonable 
improvement in aerodynamic performance. 
We expect manufacturers of all box 
vans will adopt tires such as SmartWay- verified trailer tires (Level 3) to meet the standards in MY 2018 and will adopt tires with even lower rolling resistance tires (represented as Level 4) as they 
become available by MY 2021 and later years and as fleet experience with these 
tires develops. 
In establishing standard stringency, 
the agencies are also assuming that all box vans will adopt ATIS throughout the program, though manufacturers have the option to install TPMS if they would prefer to make up the difference in effectiveness using other technologies. 
As mentioned previously, the agencies did not include weight reduction in their technology adoption projections, but certain types of weight reduction could be used as part of a compliance pathway, as discussed in Section IV.D.(1)(d) IV.D.(1)(d) above. 
TABLE IV–14—P ROJECTED ADOPTION RATES AND AVERAGE PERFORMANCE PARAMETERS FOR FULL-AEROLONG BOX 
VANS 
Technology Long box dry & refrigerated vans 
Model year 2018 2021 2024 2027 
Aerodynamic Technologies: 
Bin I.
Bin II.
Bin III ........................................................................................................ 100% 
Bin IV ........................................................................................................ ................. ....... 100% 
Bin V ......................................................................................................... ................. ....... ........................ 100% 30% 
Bin VI ........................................................................................................ ................. ....... ........................ ........................ 70% 
Bin VII.
Average Delta C dA (m2)a.................................................................. 0.5 0.7 1.0 1.3 
Trailer Tire Rolling Resistance: 
Level 1.
Level 2 ...................................................................................................... .................. ...... ........................ ........................ 5% 
Level 3 ...................................................................................................... 100% 
Level 4 ...................................................................................................... .................. ...... 100% 100% 95% 
Average C RR(kg/ton)a....................................................................... 5.1 4.7 4.7 4.8 
Tire Pressure Systems: 
ATIS .......................................................................................................... 100% 100% 100% 100% 
TPMS.
Average Pressure System Reduction (%)a...................................... 1.2% 1.2% 1.2% 1.2% 
Weight Reduction: 
Weight (lb)b.
Notes: 
A blank cell indicates a zero value. 
aCombines projected adoption rates with performance levels shown in Table IV–9. 
bThis set of adoption rates did not apply any assumed weight reduction to meet these standards for these trailers. 
TABLE IV–15—P ROJECTED ADOPTION RATES AND AVERAGE PERFORMANCE PARAMETERS FOR FULL-AEROSHORT BOX 
VANS 
Technology Short box dry & refrigerated vans 
Model year 2018 2021 2024 2027 
Aerodynamic Technologies: 
Bin I.
Bin II ......................................................................................................... ................ ........ 100% 
Bin III ........................................................................................................ ................ ........ ........................ 100% 40% 
Bin IV ........................................................................................................ ................. ....... ........................ ........................ 60% 
Bin V.
Bin VI.
Bin VII.
Average Delta C dA (m2)b.................................................................. 0.0 0.1 0.4 0.6 
Trailer Tire Rolling Resistance: 
Level 1.
Level 2 ...................................................................................................... .................. ...... ........................ ........................ 5% 
Level 3 ...................................................................................................... 100% 
Level 4 ...................................................................................................... .................. ...... 100% 100% 95% 
Average C RR(kg/ton)b....................................................................... 5.1 4.7 4.7 4.8 
Tire Pressure Systems: 
ATIS .......................................................................................................... 100% 100% 100% 100% 
TPMS.
Average Tire Pressure Reduction (%)c............................................ 1.2% 1.2% 1.2% 1.2% 
Weight Reduction: 
Weight (lb)b.
Notes: A blank cell indicates a zero value. 
aThe majority of short box trailers are 28 feet in length. We recognize that they are often operated in tandem, which limits the technologies 
that can be applied (for example, boat tails). 
bCombines projected adoption rates with performance levels shown in Table IV–9. 
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cThis set of adoption rates did not apply any assumed weight reduction to meet these standards for these trailers. 
The agencies proposed that the 
partial-aero box vans would track with 
the full-aero van standards until MY 2024. 80 FR 40257. Wabash commented that partial-aero box vans should be exempt starting in MY 2021 since partial-aero vans cannot use multiple devices. The agencies reconsidered the proposed partial-aero standards and recognize that it would likely be difficult to meet the proposed MY 2024 standards without the use of multiple devices and yet partial-aero trailers, by definition, are restricted from using multiple devices. For these reasons, the agencies redesigned the partial-aero standards, such that trailers with qualifying work-performing equipment can meet standards that would be achievable with the use of a single aerodynamic device throughout the program, similar to the MY 2018 standards. The partial-aero standards do, however, increase in stringency slightly in MY 2021, to reflect the broader use of improved lower rolling resistance tires. 
TABLE IV–16—P ROJECTED ADOPTION RATES AND AVERAGE PERFORMANCE PARAMETERS FOR PARTIAL -AEROBOXVANS 
Technology Partial-aero long box vans Partial-aero short box vans 
Model year 2018 2021+ 2018 2021+ 
Aerodynamic Technologies: 
Bin I.
Bin II ......................................................................................................... ................ ........ ........................ ........................ 100% 
Bin III ........................................................................................................ 100% 100% 
Bin IV.
Bin V.
Bin VI.
Bin VII.
Average Delta C dA (m2)b.................................................................. 0.5 0.5 0.0 0.1 
Trailer Tire Rolling Resistance: 
Level 1.
Level 2.
Level 3 ...................................................................................................... 100% ........................ 100% 
Level 4 ...................................................................................................... .................. ...... 100% ........................ 100% 
Average C RR(kg/ton)b....................................................................... 5.1 4.7 5.1 4.7 
Tire Pressure Systems: 
ATIS .......................................................................................................... 100% 100% 100% 100% 
TPMS.
Average Pressure System Reduction (%)a...................................... 1.2% 1.2% 1.2% 1.2% 
Weight Reduction: 
Weight (lb)b.
Notes: 
A blank cell indicates a zero value. 
aCombines projected adoption rates with performance levels shown in Table IV–9. 
bThis set of adoption rates did not apply weight reduction to meet these standards for these trailers. 
The adoption rates shown in these 
tables are one set of many possible 
combinations that box trailer manufacturers could apply to achieve the same average stringency. If a manufacturer chose these adoption rates, a variety of technology options exist within the aerodynamic bins, and several models of LRR tires exist for the levels shown. Alternatively, technologies from other aero bins and tire levels could be used to comply. It should be noted that since the standards for box vans are all performance-based, box van manufacturers are not limited to specific aerodynamic and tire technologies in their compliance choices. Certain types of weight reduction, for example, may be used as part of a compliance pathway. See RIA Chapter 2.10.2.4.1 for other example compliance pathways that include weight reduction. 
Similar to our analyses of the baseline 
cases, the agencies derived a single set of performance parameters for each subcategory by weighting the performance levels included in Table IV–9 by the corresponding adoption rates. These performance parameters represent a compliant vehicle for each trailer subcategory and are presented as average values in the Table IV–14 through Table IV–16. 
(ii) Tire Technologies for Non-Aero Box 
Vans and Non-Box Trailers 
Neither non-aero vans (i.e., those with 
two or more work-related special components), nor non-box trailers are shown in the tables above. This is because we are adopting design-based (i.e., technology-based) standards for 
these trailers, not performance-based standards. Manufacturers of these trailers do not need to use aerodynamic technologies, but they need to install the lower rolling resistance tires and tire pressure systems established by this program (see Section IV.C.(2)). Compared to manufacturers that needed aerodynamic technologies to comply, the approach for non-aero box trailers and non-box trailers results in a significantly lower compliance burden for manufacturers by reducing the amount of tracking and eliminating the need to calculate a compliance value (see Section IV.E.). The agencies are adopting these design standards, which can be assumed to be 100 percent adoption, in two stages. In MY 2018, the non-box trailer standards require manufacturers to use tires meeting a rolling resistance of Level 2 or better and to install tire pressure systems. In MY 2021, non-box trailers standards require tire pressure systems and LRR tires at Level 3 or better. Non-aero box vans, which we believe are largely at a baseline rolling resistance Level 2 today, require tire pressure monitoring systems with Level 3 tires in MY 2018 and Level 4 tires in MY 2021 and later. 
We received comment that 
manufacturers were concerned about the cost and availability of ATIS for the trailer industry. Still, based on comments about TPMS and further evaluations by the agencies, we are including TPMS as an additional option for tire pressure systems in the trailer program, as discussed in Section IV.D.(1)(c) above. Non-aero vans and 
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non-box trailers are compliant if they 
have appropriate lower rolling resistance tires and either TPMS or ATIS. 
(e) Derivation of the Trailer Standards 
The agencies applied the average 
performance parameters from Table IV– 
14 and Table IV–15 as input values to the GEM vehicle simulation to derive the HD Phase 2 fuel consumption and CO
2emissions standards for each long 
and short full-aero box van subcategory. These full-aero van standards are shown in Table IV–17. Similarly, the average 
performance parameters from Table IV– 16 were used to calculate the partial- aero van standards shown in Table IV– 18. The design standards for non-box trailer and non-aero box van are summarized in Table IV–19. 
Over the four stages of the trailer 
program, the full-aero box vans longer than 50 feet are projected to reduce their CO
2emissions and fuel consumption by 
two percent, five percent, seven percent and nine percent compared to their average baseline cases in Table IV–13. Full-aero box vans 50-feet and shorter 
will achieve reductions of one percent, two percent, four percent and six percent compared to their average baseline cases. The partial-aero long and short box van standards will reduce CO
2 
and fuel consumption by six percent 
and four percent, respectively, by MY 2021. The tire technologies used on non-box and non-aero box trailers are projected to provide reductions of two percent in the first stage and three percent in MY 2021 and later. 
TABLE IV–17—S TANDARDS FOR FULL-AEROBOXVANS 
Model year Subcategory Dry van Refrigerated van 
Length Long Short Long Short 
2018–2020 ............... EPA Standard (CO 2Grams per Ton-Mile) ................................ 81.3 125.4 83.0 129.1 
Voluntary NHTSA Standard (Gallons per 1,000 Ton-Mile) ....... 7.98625 12.31827 8.15324 12.68173 
2021–2023 ............... EPA Standard (CO 2Grams per Ton-Mile) ................................ 78.9 123.7 80.6 127.5 
NHTSA Standard (Gallons per 1,000 Ton-Mile) ....................... 7.75049 12.15128 7.91749 12.52456 
2024–2026 ............... EPA Standard (CO 2Grams per Ton-Mile) ................................ 77.2 120.9 78.9 124.7 
NHTSA Standard (Gallons per 1,000 Ton-Mile) ....................... 7.58350 11.87623 7.75049 12.24951 
2027+ ...................... EPA Standard (CO 2Grams per Ton-Mile) ................................ 75.7 119.4 77.4 123.2 
NHTSA Standard (Gallons per 1,000 Ton-Mile) ....................... 7.43615 11.7288 7.60314 12.10216 
TABLE IV–18—S TANDARDS FOR PARTIAL -AEROBOXVANS 
Model year Subcategory Dry van Refrigerated van 
Length Long Short Long Short 
2018–2020 ............... EPA Standard (CO 2Grams per Ton-Mile) ................................ 81.3 125.4 83.0 129.1 
Voluntary NHTSA Standard (Gallons per 1,000 Ton-Mile) ....... 7.98625 12.31827 8.15324 12.68173 
2021+ ...................... EPA Standard (CO 2Grams per Ton-Mile) ................................ 80.6 123.7 82.3 127.5 
NHTSA Standard (Gallons per 1,000 Ton-Mile) ....................... 7.91749 12.15128 8.08448 12.52456 
TABLE IV–19—D ESIGN -BASED TIRESTANDARDS FOR NON-BOXTRAILERS AND NON-AEROBOXVANS 
Model year Tire technology Non-box trailers Non-aero box vans 
2018–2020 .................... Tire Rolling Resistance Level (kg/ton) ......................................................... ≤6.0 ≤5.1 
Tire Pressure System .................................................................................. TPMS or ATIS TPMS or ATIS  
2021+ ............................ Tire Rolling Resistance Level (kg/ton) ........................................................ . ≤5.1 ≤4.7 
Tire Pressure System .................................................................................. TPMS or ATIS TPMS or ATIS  
(f) Technology Costs for the Trailer 
Standards 
The agencies evaluated the 
incremental technology costs for 53-foot 
dry and refrigerated vans and 28-foot dry vans. (As explained above, we believe these length trailers are representative of the majority of trailers in the long and short box van subcategories, respectively.) We identified costs for each technology package and projected the costs for each year of the program. A summary of the technology costs is included in Table IV–20 through Table IV–23 for MYs 
2018 through 2027, with additional details available in the RIA Chapter 2.12. Costs shown in the following tables are for the specific model year indicated and are incremental to the average baseline costs, which includes some level of adoption of these technologies as shown in Table IV–13. Therefore, the technology costs in the following tables reflect the average cost expected for each of the indicated trailer classes across the fleet. Note that these costs do not represent actual costs for the individual components because they are relative to the costs of the MY 2018 
baselines which are expected due to market-driven adoption of the technologies. For more on the estimated technology costs exclusive of adoption rates, refer to Chapter 2.12 of the RIA. These costs include indirect costs via markups and reflect lower costs over time due to learning impacts. For a description of the markups and learning impacts considered in this analysis and how technology costs for other years are thereby affected, refer to Chapter 7 of the RIA. 
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TABLE IV–20—T RAILER TECHNOLOGY INCREMENTAL COSTS IN THE 2018 M ODEL YEAR 
[2013$] 
Long vans, 
full aero Long vans, 
partial aero Short vans, 
full aero Short vans, 
partial aero Long vans, 
no aero Short vans, 
no aero Non-box 
Aerodynamics .......................................... $367 $742 $0 $0 $0 $0 $0 
Tires ......................................................... 2 40 1 20 40 20 28 
Tire inflation system ................................. 347 659 338 494 421 210 421 
Total .................................................. 716 1,441 339 514 461 231 448 
TABLE IV–21—T RAILER TECHNOLOGY INCREMENTAL COSTS IN THE 2021 M ODEL YEAR 
[2013$] 
Long vans, 
full aero Long vans, 
partial aero Short vans, 
full aero Short vans, 
partial aero Long vans, 
no aero Short vans, 
no aero Non-box 
Aerodynamics .......................................... $743 $679 $450 $475 $0 $0 $0 
Tires ......................................................... 17 49 9 25 49 25 23 
Tire inflation system ................................. 321 609 313 457 389 195 389 
Total .................................................. 1,081 1,337 772 957 438 219 412 
TABLE IV–22—T RAILER TECHNOLOGY INCREMENTAL COSTS IN THE 2024 M ODEL YEAR 
[2013$] 
Long vans, 
full aero Long vans, 
partial aero Short vans, 
full aero Short vans, 
partial aero Long vans, 
no aero Short vans, 
no aero Non-box 
Aerodynamics .......................................... $899 $645 $879 $451 $0 $0 $0 
Tires ......................................................... 11 48 6 24 48 24 27 
Tire inflation system ................................. 294 558 286 418 357 178 357 
Total .................................................. 1,204 1,251 1,171 894 405 202 383 
TABLE IV–23—T RAILER TECHNOLOGY INCREMENTAL COSTS IN THE 2027 M ODEL YEAR 
[2013$] 
Long vans, 
full aero Long vans, 
partial aero Short vans, 
full aero Short vans, 
partial aero Long vans, 
no aero Short vans, 
no aero Non-box 
Aerodynamics .......................................... $1,069 $623 $921 $436 $0 $0 $0 
Tires ......................................................... 22 44 11 22 44 22 16 
Tire inflation system ................................. 279 529 272 397 338 169 338 
Total .................................................. 1,370 1,196 1,204 855 382 191 354 
(3) Consistency of the Trailer Standards 
With the Agencies’ Statutory Obligations 
The agencies have determined that 
the standards presented in the Section IV.C.(2), are the maximum feasible and appropriate under the agencies’ respective authorities, considering lead time, cost, and other factors. The agencies’ decisions on the stringency and timing of the trailer standards focused on available technology and the consequent emission reductions and fuel efficiency improvements associated with use of the technology, while taking into account the circumstances of the trailer manufacturing sector. Trailer manufacturers are subject to first-time emission control and fuel consumption regulation under the trailer standards. These manufacturers are in many cases 
small businesses, with limited resources to master the mechanics of regulatory compliance. Thus, the agencies are providing ample and reasonable time for 
trailer manufacturers to become familiar with the requirements and the new compliance regime. 
The stringency of the standard is 
predicated on more widespread deployment of tire technologies that are already in commercial use and existing aerodynamic devices combinations that we believe will be further optimized in the near-term. The availability, feasibility, and level of effectiveness of these technologies are well- documented. In developing the standards, we also took into account not just the capabilities of the technologies, but also how the use of these 
technologies is likely to expand under the trailer program, considering factors like degree of market penetration over time and the effect of different operational patterns for different trailer types (Section IV.D.(2) above). For example, some commenters point out that trailers operating at lower speeds will achieve smaller CO
2and fuel 
consumption reductions than they will at highway speeds. The agencies acknowledge this fact, and account for a fraction of trailer operation at slower speeds. All long box vans are evaluated with 5 percent of their miles at low speed operation and all short vans are evaluated with 17 percent low speed 
miles. While we cannot predict individual trailer use, we believe these 
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363Memorandum to Docket EPA–HQ–OAR– 
2014–0827, ‘‘Comparison of GEM Drive Cycle 
Weightings and Fleet Data Provided by Utility Trailer Manufacturing Co. in Public Comments’’, July 2016. 
364Roeth, Mike, et al. ‘‘Barriers to Increased 
Adoption of Fuel Efficiency Technologies in Freight Trucking,’’ July 2013. International Council for Clean Transportation. Available here: http://www.theicct.org/sites/default/files/publications/ ICCT–NACFE–CSS_ Barriers_ Report_ Final_
20130722.pdf. 
365See RIA Chapter 7.2.5 and Memo to Docket 
‘‘Tractor-Trailer Cost per Ton Values.’’ July 2016. EPA–HQ–OAR–2014–0827. values are a reasonable estimate of an 
industry average.363Our analysis in RIA 
Chapter 2.10.2.1.1 shows that skirts will provide short trailers with at least 1 percent improvement and long trailers with at least 4 percent improvement at 55 mph. We expect most trailers spend at least some of their miles at 55 mph or faster in use and will gain similar benefits during those speeds. We also show that even trailers operating under fully transient conditions (combining slower and faster operation) will experience a small improvement from use of trailer skirts. 
The agencies do not believe that there 
is any issue of technological feasibility of the levels of the standards and the time line for implementing them in the final trailer program. The agencies considered cost and the sufficiency of lead-time, including lead-time not only to deploy technological improvements, but, as just noted, also for this industry sector to assimilate for the first time the compliance mechanisms of the trailer program. 
The highest cost shown in Table IV– 
23 is associated with the standard for long dry vans. We project that the average cost per trailer to meet the MY 2027 standards for these trailers will be about $1,400, which is less than 10 percent of the cost of a new dry van trailer (estimated to be about $20,000). Other trailer types have lower projected technology costs, and many have higher purchase prices. As a result, we project that the per-trailer costs for all trailers covered in this regulation will be less than 10 percent of the cost of a new trailer. 
The agencies regard these costs as 
reasonable. We project that most customers will rapidly recover the 
initial cost of these technologies due to the associated fuel savings, usually in two years. As discussed in Section IX.M and RIA Chapter 7.2.4, this payback is for tractors and trailers together, and includes both long and short-haul. This payback period is generally considered reasonable in the trailer industry for investments that reduce fuel consumption.
364Although longer 
paybacks will occur for some trailers, we do not project that any trailers will achieve lifetime fuel savings less than the cost of the technologies. In addition, the agencies estimate the cost per metric ton of CO
2eq reduction without 
considering fuel savings to be $36 for tractor-trailers in 2030 which compares favorably with the levels of cost effectiveness the agencies found to be reasonable for light duty trucks.
365 
The agencies believe these 
technologies can be adopted at the projected rates within the lead time provided in the trailer program, as discussed above in Section IV.C.(4) above. 
(4) Alternative Standards and Feasibility 
That the Agencies Considered 
As discussed in Section X of the 
NPRM, the agencies evaluated five regulatory alternatives representing different levels of stringency for the Phase 2 program. See 80 FR 40273. A wide range of stakeholders commented on the proposed (Alternative 3) standards and the other alternatives that we discussed, and our final standards reflect our consideration of all of those comments. 
Comments on our proposed standards 
(Alternative 3) and the alternatives we presented generally fell into three categories: (1) Commenters supporting Alternative 1; i.e., generally advocating 
no mandatory standards and a continuation of today’s voluntary SmartWay regime and; (2) Commenters preferring the proposed Alternative 3 standards and timeline to the standards of Alternative 4; and (3) Commenters supporting the more stringent standards and timeline of Alternative 4, Alternative 5, or of other more stringent potential programs. 
Commenters including the TTMA, 
Utility, and Stoughton stated their belief that no mandatory standards are necessary; however, they did not provide information to show that market forces at work today will achieve the clear potential for the industry to reduce CO
2and fuel consumption in the near- 
and longer-term future. The agencies have concluded that a program involving no or minimal mandatory requirements would not be appropriate or meet our statutory requirements. 
As discussed previously, the agencies 
believe that our final trailer standards are appropriate under the Clean Air Act and are the maximum feasible standards under the EISA. In developing the proposal and the final rule, we considered standards that would be more stringent or would become effective in an earlier model year than the proposed Alternative 3 standards and timeline. Several commenters stated that a still more stringent program should be finalized, including information about current and potential future trailer aerodynamic technologies. Commenters including CARB, NACAA, NRDC, ICCT, UCS, and STEMCO supported the standards we presented for Alternative 4 in the proposal (essentially the pull ahead of the MY 2027 standards) in the proposal. In addition, some of the commenters made the additional suggestion that the agencies should anticipate that manufacturers will incorporate a modest degree of Bin VIII technologies—i.e., two bins higher than any performance demonstrated in our aerodynamic testing—in the later stages of the program. EDF supported a program of even greater stringency, supporting Alternative 5 standards (advanced aerodynamic technologies on all box vans, aerodynamic technologies on some non-box trailers, and tire technologies on all non-box trailers) on the Alternative 4 timeline. The Center for Biological Diversity (CBD) did not specifically comment on the alternatives presented in the proposal, but supported a program that would result in significantly more stringent standards (based, for example, on integrated tractor and trailer technologies, such as in the SuperTruck demonstration program). Great Dane, Wabash, ATA, and the International Foodservice Distributors Association expressed concerns that a program of the stringency and timeline of Alternative 4 would have negative consequences, including requiring trailer manufacturers to adopt less-tested technology. 
Where commenters provided relevant 
data and information, the agencies made adjustments to the final program accordingly. For example, as noted in Section IV.C.(1) and Section IV.D.(2) previously, information from the industry was helpful in the decision to limit the non-box trailer program to tanks, flatbeds, and container chassis. Also, partially in response to information we received in comments, we slightly reduced the proposed stringency for partial-aero vans to better reflect their aerodynamic limitations. Also, while not a direct change to the stringency of the standards, the program limits averaging to the final stage of the program to allow van manufacturers more time to become familiar with the compliance processes and the industry to gain confidence in the technologies. Overall, the final standards are slightly more stringent than proposed, based on 
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366As with the other Phase 2 vehicle programs, 
manufacturers submit their applications to EPA, 
which then shares them with NHTSA. Obtaining an approved certificate of conformity from EPA is the first step in complying with the NHTSA program. 367Trailers that meet the qualifications for 
exclusion do not require a certificate of conformity and manufacturers do not have to submit an application to EPA for these trailers. an expectation of earlier adoption of 
more efficient lower rolling resistance tires for all subcategories, and a strengthened the full-aero van program that includes greater adoption of advanced aerodynamics in the final stage. 
Based on this analysis and as 
informed by the comments, we believe that the final standards in the program, slightly revised from the proposed Alternative 3 standards, are appropriate and represent the maximum feasible standards. In contrast, we believe that the accelerated timeline of Alternative 4 may cause technologies to prematurely enter the market, leading to unnecessary costs and compliance burdens that would not be appropriate for this newly regulated industry. Standards similar to or more stringent than those we evaluated for Alternative 5 would require CO
2and fuel consumption 
reductions that may well not be technologically achievable, even with fundamental changes to the industry. Nor did the commenters present any information as to how advanced aerodynamic technologies (Bins VII and VIII) could be developed and reliably brought to market at reasonable cost within the lead time of the Phase 2 program. On the basis of what we know today, the agencies are unable to show a pathway for the industry to achieve such additional improvements, at least without the potential for major disruptions to the industry due to 
requiring, for example, fundamental changes to trailer design and construction, or impractical levels of tractor-trailer integration. 
E. Trailer Standards: Compliance and 
Flexibilities 
As with other EPA motor vehicle 
programs, trailer manufacturers must annually obtain a certificate of conformity from EPA before introducing into commerce new trailers subject to the new trailer CO
2and fuel 
consumption standards. See CAA section 206(a). The EPA certification provisions align with provisions that apply to the NHTSA trailer program such that this single certification program meets the requirements of both agencies. 
The certification process for trailer 
manufacturers is very similar in its basic structure to the process for the other Phase 2 vehicle programs, although it has been simplified for trailers. This structure involves pre-certification activities, the certification application and its approval, and end-of-year reporting. 
In this section, the agencies first 
describe the general certification process and how we developed 
compliance equations based on the GEM vehicle simulation tool, followed by a discussion of the specified test procedures for measuring the performance of tires and aerodynamic technologies and how manufacturers will apply test results toward compliance and certification. The section closes with discussions of several other certification and compliance provisions as well as provisions to provide manufacturers with compliance flexibility. 
(1) General Certification Process 
Under the process for certification, 
manufacturers of all covered trailers are 
required to apply to EPA for certification.
366In addition, 
manufacturers of box vans subject to the performance-based standards are required to provide aerodynamic performance test data (see 40 CFR 1037.205) in their applications. EPA expects to provide additional guidance to the regulated industry as the program begins to be implemented, including an overview of the regulations, how to prepare for compliance, and instructions for registering with the EPA. Once a trailer manufacturer is registered with EPA, EPA’s Compliance Division in the Office of Transportation and Air Quality will assign a staff certification representative to the company to help them through the compliance process. After this point, manufacturers can arrange to meet with the agencies to discuss compliance plans and obtain any preliminary approvals (e.g., appropriate test 
methods) before applying for certification. 
Trailer manufacturers submit their 
applications through the EPA ‘‘Verify’’ electronic database, and EPA issues certificates based on the information provided. At the end of the model year, trailer manufacturers submit an end-of- year report to the agencies to complete their annual obligations. 
(a) Definition of Model Year 
As mentioned previously, consistent 
with Clean Air Act specifications, EPA’s 
vehicle certification is an annual process. EPA CO
2emissions standards 
start to apply for trailers built on or after January 1, 2018, with later standards being introduced by model year. Under the Clean Air Act, the term ‘‘model year’’ refers to a manufacturer’s annual production period. Manufacturers may use the calendar year as the model year, or may choose a different period of production that includes January 1 of that year. Thus, manufacturers have the option to choose any year-long period of production that begins on or before January 1 of the named model year, but no sooner than January 2 of the previous calendar year. For example, at certification, a manufacturer could specify the 2021 model year production period to be July 1, 2020 through June 30, 2021. 
(b) Preliminary Considerations for 
Compliance 
Before submitting an application for a 
certificate, a manufacturer chooses the technologies they plan to offer their customers, and identifies any trailers in their production line that qualify for exclusion from the program.
367Non-box 
trailers, which are subject to design standards, the manufacturer will need to select which tires and tire pressure systems to include and confirm that their tires meet the LRR performance standards. For box vans subject to performance standards, manufacturers also obtain performance information for these technologies at this time, either from supplier data or their own testing. Manufacturers that choose to perform aerodynamic or tire testing themselves may also need to obtain approval of test methods and perform preliminary testing. Trailer manufacturers relying on data from a third-party aerodynamic device manufacturer would need to verify that these data are approved. 
During this time, the manufacturers 
also decide the strategy they intend to use for compliance by identifying ‘‘families’’ for the trailers they produce. A family is a grouping of similar products that are all subject to the same standard and covered by a single certificate. All products in each trailer subcategory are generally certified as the same family. That is, long box dry vans, short box dry vans, long refrigerated vans, short refrigerated vans, non-box trailers, partial-aero vans (long and short box, dry and refrigerated vans), and non-aero box vans, are each certified as separate trailer families. Manufacturers may combine dissimilar trailers into a single vehicle family to reduce the compliance burden as described in 40 CFR 1037.230(d)(3) and 49 CFR 535.5(e). In general, manufacturers can combine trailers that have less stringent standards with more stringent standards as long as the combined set of trailers 
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368The program essentially requires that 
manufacturers equip 100 percent of their non-box 
and special purpose box trailers with tire pressure systems and tires meeting the specified rolling resistance levels. Partial-aero box vans meet a reduced performance standard. As a result, averaging provisions do not apply to these trailer subcategories. meet the more stringent standards. 
Refrigerated and dry vans of the same length can be combined to meet the dry van standards. Short vans can combine with long vans, meeting the corresponding long van standard. Additionally, non-box trailers can be combined with the non-aero box vans if the manufacturer would like to meet the more stringent non-aero box van design standards with higher-performing tires. 
When no averaging is available (i.e., 
MY 2018 through MY 2026 for full-aero 
box vans, and all years for remaining trailers), all products within a family need to meet or exceed the standards for that trailer subcategory (except for any trailers included in the manufacturer’s allowance for non-complying vehicles (See Section IV.E.(5)(a) below)). This is not to say that, for example, every long box dry van model needs to have identical technologies like skirts, tires, 
and tire inflation systems, but that every model in that family need to meet the standard for that family. 
In MY 2027 and later, full-aero box 
van manufacturers will still generally have one family per subcategory. However, if a full-aero box van manufacturer subject to performance standards wishes to utilize the averaging provisions, it would need to divide the trailer models in each of the van subcategories/families into subfamilies.
368Each subfamily can be a 
grouping of box vans that have similar performance levels, even if they use different technologies. We refer to the performance levels for each subfamily as ‘‘Family Emission Limits’’ (FELs). A long box dry van manufacturer could choose, for example, to create two subfamilies in its long box dry van family. Trailers in one of these subfamilies could be allowed to under- comply with the standard (e.g., not 
apply a tire pressure system) as long as the performance of the other subfamily over-complies with the standard (e.g., installs additional aerodynamic technologies), such that the average of all of the subfamilies’ FELs met or exceeded the standard for that family on a production-weighted basis. Section IV.E.(5)(b) below further discusses how the averaging program would function for any such trailer subfamilies. (c) Submitting a Certification 
Application and Request for a Certificate to EPA 
Once the preliminary steps are 
completed, the manufacturer can prepare and submit applications to EPA for certificate of conformity for each of its trailer families. The contents of the application are specified in 40 CFR 1037.205, though not all items listed in the regulation are applicable to each trailer manufacturer. 
For the early years of the program 
(i.e., MY 2018 through MY 2020), the 
application must specify whether the trailer manufacturer is opting into the NHTSA voluntary program to ensure the information is transferred between the agencies. Throughout the program, the application must include a description of the emission and fuel consumption reduction technologies that a manufacturer intends to offer. These technologies could include aerodynamic features, LRR tire models, tire pressure systems, or components that qualify for weight reduction. Basic information about labeling, warranty, and recommended maintenance should also be included the application (see Section IV.E.(4) for more information on these additional compliance provisions). 
The manufacturer also provides a 
summary of the plans to comply with the standard. This information includes a description of the trailer family and subfamilies (if applicable) covered by the certificate, the technologies that are used for compliance, and projected sales of its products. For trailers subject to performance-based standards (and not those subject to the design-based standards), in the earlier stages of the program when averaging is not available (or for manufacturers of full-aero vans that do not participate in averaging after MY 2026), additional provisions apply. These manufacturers will include information on the configuration with the worst performance level in terms of CO
2and fuel consumption offered in the 
trailer family. Any of these manufacturers that choose to average within their full-aero van families after MY 2026 will include performance information for the projected highest production trailer configuration, as well as the lowest and the highest performing configurations within those families. For all covered trailers, once the certification application is accepted, a certificate is issued and manufacturers can begin selling their trailers. 
(d) End-of-Year Obligations 
After the end of each year, all 
manufacturers, including those with 
design-based standards, need to submit a report to the agencies presenting 
production-related data for that year (see 40 CFR 1037.250 and 49 CFR 535.8). In addition, the year’s final compliance data (as calculated using the compliance equation) for box van manufacturers subject to performance- based standards will include both CO
2 
emissions and fuel consumption information and actual production volumes in order to demonstrate that the trailers met the standards for that year. 
In MY 2027 and later, full-aero box 
van manufacturers that opt to participate in the averaging program will submit a second report that describes their subfamily FELs and a final calculation of their production- weighted average CO
2and fuel 
consumption. See 40 CFR 1037.730, 40 CFR 1037.745, and 49 CFR 535.7. All certifying manufacturers need to maintain records of all the data and information that is required to be supplied to EPA and NHTSA for eight years. 
(2) Evaluating Trailer Performance for 
Compliance 
The agencies believe that this final 
compliance program for trailer manufacturers is straightforward, technically robust, transparent, and minimizes administrative burdens on the industry. As described earlier in this section and in Chapter 4 of the RIA, 
GEM is a customized vehicle simulation model that EPA developed for the Phase 1 program to relate measured aerodynamic and tire performance values, as well as other parameters, to CO
2and fuel consumption without 
performing full-vehicle testing. As with the Phase 1 and Phase 2 tractor and vocational vehicle programs, the trailer program uses GEM in evaluating emissions and fuel consumption in developing the trailer standards. However, unlike the tractor and vocational vehicle programs, trailer manufacturers will not use GEM directly to demonstrate compliance with the trailer standards. Instead, we have developed an equation based on GEM that calculates CO
2and fuel 
consumption from performance inputs without running the model. 
(a) Development of the GEM-Based 
Trailer Compliance Equation 
For compliance with the performance- 
based standards in the trailer program (i.e. the standards for full- and partial- 
aero long and short box vans), the trailer characteristics that a manufacturer supplies to the equation are aerodynamic improvements (i.e., the 
change in the aerodynamic drag area, 
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delta C dA, from the appropriate bin in 
m2), tire rolling resistance (i.e., 
coefficient of rolling resistance, C RR, in 
kg/metric ton), the presence of a tire 
pressure system, and any weight reduction applied in pounds. The use of the equation quantifies the overall performance of the trailer in terms of CO
2emissions on a grams per ton-mile 
basis, which can be converted to fuel consumption on a gallons per 1000 ton- mile basis. 
Chapter 2.10.5 of the RIA provides a 
full a description of the development and evaluation of the equation for trailer compliance where the standards are performance-based. Equation IV–1 is a single linear regression curve that can be used for all box vans in these rules to calculate CO
2emissions, eCO2.Unique 
constant values, C 1through C 4, are 
applied for each of the van types as shown in Table IV–24. Constant C
5is 
equal to 0.988 for any trailer that installs an ATIS (accounting for the 1.2 percent reduction given for use of ATI), 0.990 for any trailer that installs a TPMS, or 1.0 for trailers without tire pressure systems. We found that this equation accurately reproduces the results of GEM for each of the box van subcategories, and the program requires these trailer manufacturers use Equation IV–1 to calculate CO
2for compliance. 
Manufacturers insert their tire rolling resistance level (TRRL), wind-averaged change in drag area (DC
dA), weight 
reduction value (WR) (if applicable), and the appropriate C
5value if a tire 
pressure system is installed into the equation and submit the result to EPA. The program provides for manufacturers to use a conversion of 10.180 grams of CO
2per gallon of diesel to calculate the 
corresponding fuel consumption values for compliance with NHTSA’s regulations. See 40 CFR 1037.515 and 49 CFR 535.6. 
TABLE IV–24—C ONSTANTS FOR GEM-B ASED TRAILER COMPLIANCE EQUATION  
Trailer 
subcategory C1 C 2 C 3 C 4 C5(tire pressure) 
None TPMS ATIS 
Long Dry Van ........................... 76.1 1.67 ¥5.82 ¥0.00103 1.000 0.990 0.988 
Long Refrigerated Van ............. 77.4 1.75 ¥5.78 ¥0.00103 
Short Dry Van .......................... 117.8 1.78 ¥9.48 ¥0.00258 
Short Refrigerated Van ............ 121.1 1.88 ¥9.36 ¥0.00264 
These long and short van constants 
are based on GEM-simulated tractors 
pulling 53-foot and solo 28-foot trailers, respectively. As a result, aerodynamic testing to obtain a trailer’s performance parameters for Equation IV–1 must be performed using consistent trailer sizes (i.e., aerodynamic performance for all 
lengths of short vans would be tested as a solo 28-foot van, and performance for all lengths of long vans would be tested as a 53-foot van). More information about aerodynamic testing is provided in Section IV.E.(3)(b) below. 
The constants for long vans apply for 
all dry or refrigerated vans longer than 50-feet and the constants for short vans apply for all dry or refrigerated vans 50- feet and shorter. The vans with work- performing devices that may be designated as partial-aero vans would use the same equation constants as their full-aero counterparts for compliance. The partial-aero designation simply allows a van to input different values (i.e., lower delta C
dA) and meet a 
different standard. Note that compliance with the design-based standards (non- box trailers and non-aero vans) does not require use of the GEM-based equation. Manufacturers supply the TRRL values for their trailer tires and attest that they installed one of the tire pressure systems (TPMS or ATIS) to EPA for compliance. (b) Use of the Compliance Equation for 
Box Van Compliance 
Box van manufacturers subject to the 
performance-based standards meet the standards using the GEM-based compliance equation to combine the effects of technologies and quantify the overall performance of the vehicle to demonstrate compliance. Trailer manufacturers obtain delta C
dA and tire 
rolling resistance values from testing (either from their own testing or from testing performed by another entity as described in Section IV.E.(3)(b)) and attest that they installed a qualifying tire pressure system and/or adopted weight reduction strategies. Manufacturers adopting aerodynamic improvements will compare their measured delta C
dA 
value to the values shown in Table 2 of 40 CFR 1037.515 (and Table IV–5 previously) and use the appropriate aerodynamic bin value as the aerodynamic input into the equation. The TRRL can be directly applied from measurements. Weight reduction is obtained by summing applicable values in our list of light weight components 
(Table 3 of 40 CFR 1037.515) or from measurements using the off-cycle provisions. Manufacturers indicate use of TPMS or ATIS with a specified percent reduction in CO
2and fuel 
consumption. 
Qualifying components for weight 
reduction can be found in 40 CFR 1037.515(d). Manufacturers that substitute one or more of these components on their box vans sum the weight reductions assigned to each component and enter that total into the equation. As noted in Section IV.D.(1)(d), the equation accounts for weight reduction by assigning one-third of that reduced weight to increase the payload and the remaining weight reduction to reduce the overall weight of the assumed vehicle. 
Manufacturers of box vans subject to 
the performance standards apply the compliance equation separately to each configuration to ensure that all of the trailer configurations they offer need to meet the standard for the given model year. The certification application submitted to EPA includes equation results from the worst performing trailer configuration for each subcategory and the manufacturer attests that no regulated trailer will be sold in a lower performing configuration. If the manufacturer offers a new technology package during the model year, the performance can be evaluated using the equation. If the performance of the new package is lower than the value submitted in the application, the manufacturer would submit a ‘‘running change’’ to EPA to reflect the change. Box van manufacturers will submit a single end-of-year report that will include their production volumes and 
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369See http://www.iso.org/iso/iso_ catalogue/
catalogue_ tc/catalogue _
detail.htm?csnumber=44770. confirmation that all of their trailers 
applied the technology packages outlined in their application. 
Any full-aero box van manufacturers 
that wish to take advantage of the agencies’ averaging provision in MY 2027 and later will make greater use of the compliance equation. Before submitting a certificate application, these manufacturers would decide which technologies to make available for their customers and use the equation to determine the range of performance of the packages they planned to offer. The manufacturers would supply these results from the equation in their certificate application and those manufacturers that wish to perform averaging would continue to calculate emissions (and fuel consumption) with the equation throughout the model year and keep records of the results for each trailer package produced. As described in Section IV.E.(1)(d) above, at the end of the year, these manufacturers would submit two reports. One report would include their production volumes for each configuration. The second report would summarize the families and subfamilies, and CO
2emissions and fuel 
consumption results from the equation for all of the trailer configurations they build in that model year, including a production-weighted average to show compliance. 
For non-box trailers and non-aero box 
vans, compliance is design-based, not performance-based, and the compliance equation is not needed. As described earlier, the standards for these trailers require the use of tires with rolling resistance levels at or below a threshold, and tire pressure systems (either TPMS or ATIS). Instead of aerodynamic testing data in their certification applications, manufacturers of these trailers submit their tire rolling resistance levels and a description of their tire pressure system(s) to EPA. 
(3) Trailer Certification Test Protocols 
The Clean Air Act specifies that 
compliance with emission standards for 
motor vehicles be demonstrated by the manufacturer using emission test data (see CAA section 206(a) and (b)). As discussed earlier, for the design-based standards (non-box trailers and non-aero vans), the trailer program considers the use of specified LRR tires and tire pressure systems an appropriate surrogate for emission testing, and there are no testing requirements associated with these standards beyond the testing required to show the tires qualify as LRR tires. We expect that tire testing will be performed by the tire manufacturers. All full- and partial-aero vans covered 
by the program are subject to performance standards, and compliance is based on measured emission performance. For these trailers, the program uses the GEM-based compliance equation discussed in Section IV.E.(2)(a) above as the official ‘‘test procedure’’ for quantifying CO
2 
and fuel consumption performance for trailer compliance and certification (as opposed to use of GEM, which serves this function in the tractor and vocational vehicle programs). Manufacturers input performance information from the applicable trailer technologies into the equation in order to calculate their impact on overall trailer performance. Manufacturers needing aerodynamic and tire rolling resistance performance data obtain it either through their own testing or through a device or tire manufacturer that performed the testing. The program specifies pre-determined values for tire pressure systems and many weight reduction components for manufacturers to apply. 
The following subsections describe 
the approved performance tests for tire rolling resistance and aerodynamic drag in this trailer program. See 40 CFR part 1037, subpart F, for a full description of the performance tests, in particular section 40 CFR 1037.515. 
(a) Trailer Tire Performance Testing 
Under Phase 1, tractor and vocational 
chassis manufacturers are required to 
input the tire rolling resistance level (TRRL) into GEM, and the agencies adopted the provisions in ISO 28580:2009(E)
369to determine the 
rolling resistance of tires. The tire rolling resistance level (TRRL) is a declared value that is based on a measured value. As described in 40 CFR 1037.520(c), this measured value, expressed as C
RR, is required to be the 
result of measurements of three different tires of a given design, giving a total of at least three data points. Manufacturers specify a C
RRvalue for GEM that is less 
than or equal to the average of these three results. Tire rolling resistance may be determined by either the vehicle or tire manufacturer. In the latter case, the tire manufacturer provides a signed statement confirming that it conducted testing in accordance with this part. 
The Phase 1 tire testing provisions for 
rolling resistance apply to all of the regulated trailers in the Phase 2 program. In the Phase 2 program, full- and partial-aero box van manufacturers, subject to the trailer performance-based 
standards, apply their declared TRRL in the compliance equation. Non-box trailer and non-aero box vans, subject to the design-based standards, simply report the TRRL as part of their certification application. Based on the current practice for Phase 1, we expect the trailer manufacturers to obtain these data from tire manufacturers, but trailer manufacturers have the option to perform tire testing themselves. 
The agencies requested comment on 
adopting a program for tire manufacturers similar to the provision described in Section IV.E.(3)(b)(v) for aerodynamic device manufacturers, through which tire manufacturers would seek preliminary approval of the performance of their trailer tires. 80 FR 40278. CARB supported this option and further requested that EPA create a public database of the tire rolling resistance data submitted to the agency in such preliminary approvals. RMA’s comments opposed making tire data available to the public without first developing a rating system for medium and heavy truck tires. The agencies have chosen not to pursue provisions for pre- approved trailer tire rolling resistance data or a public database of this information in this rulemaking, recognizing the overall unresolved issues relating to standard HD truck and trailer testing within the tire industry (as discussed in the Tractor section of this Preamble, Section III.E(1)(e)). Instead, trailer tire manufacturers provide tire rolling resistance values directly to the trailer manufacturers and that information is shared with EPA and NHTSA for certification. 
(b) Trailer Aerodynamic Performance 
Testing 
As discussed earlier, manufacturers of 
trailers subject to performance standards (i.e., most box vans), need to provide 
EPA with aerodynamic performance data at the time of certification. The purpose of our trailer aerodynamic test procedures is to establish an estimate of the aerodynamic drag experienced by a tractor-trailer vehicle in real-world operation. We based these procedures on the current tractor aerodynamic 
procedures, including coastdown, wind tunnel, and computational fluid dynamics (CFD) modeling. More specifically, the tests are conducted according to the same test procedures for tractors and trailers, but different provisions apply for the test articles and the data analysis. In the tractor program, the resulting C
dA value represents the 
absolute aerodynamic drag of a tested tractor assumed to be pulling a specified standard trailer. In the trailer program, 
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370‘‘Additional Discussion of Selective 
Enforcement Audit and Confirmatory Testing for 
Aerodynamic Parameters for Combination Tractors and for Trailers,’’ February 19, 2015. Docket EPA– HQ–OAR–2014–0827–1625. the tests measure the difference in C dA 
value between the tested trailer as 
pulled by a standard tractor and a reference trailer pulled by the same standard tractor. In other words, the trailer test procedure is intended to measure the aerodynamic improvements rather than the absolute aerodynamic performance. The agencies chose to base the standards on measurements of aerodynamic improvements in part to reflect the market reality that many trailer manufacturers rely on manufacturers of bolt-on aerodynamic devices for the improvements rather than redesigning their trailer or developing their own components. 
To minimize the testing burden, the 
program specifies that all aerodynamic devices for long box vans (i.e., those 
greater than 50-feet in length) be evaluated based on 53-foot box vans, and that devices for all trailers 50-feet and shorter be evaluated based on 28- foot box vans. In other words, a manufacturer can use test data from a single trailer to certify all trailers in the same subcategory. As noted previously in Section IV.D.(1) and demonstrated in Chapter 2.10.2.1.2.6 of the RIA, the performance of aerodynamic devices on these two trailer lengths is expected to provide a conservative estimate of the performance on the longer trailers within the same length category. We believe that this compliance approach effectively represents the performance of such devices on the majority of box vans, yet limits the number of such vans that a manufacturer needs to track and evaluate. 
The program provides for 
manufacturers to have flexibility in the devices (or packages of devices) they install on box vans with lengths that differ from 53-feet or 28-feet. In such situations, a manufacturer could use devices that they believe would be more appropriate for the length of the trailer they are producing, consistent with good engineering judgement. For example, they could test skirts on a 28- foot trailer and use longer skirts on 40- foot trailers that they make. No additional testing would be required in order to validate the appropriateness of using the alternate devices on these trailers. 
The agencies have structured the final 
regulations to make wind tunnel testing 
the primary method for measuring trailer aerodynamic performance. While coastdown testing measures performance of full-scale vehicles, which is generally the agencies’ preference for performance testing, wind tunnel testing achieves similar results in terms of delta C
dA, with the 
added benefit of measuring wind- averaged values in the same test. In 
addition, wind tunnel testing is inexpensive relative to other aero test methods and does not require as much time to complete. Thus, it has generally been the preferred method for the trailer industry. Nevertheless, the program provides for manufacturers to use coastdown or CFD methods as described below and fully in 40 CFR 1037.526(b) and 1037.150(x). 
The agencies considered making 
coastdown testing the primary test method for trailers, as it is for the tractor program. However, the delta C
dA 
approach for the trailer aerodynamic program would require multiple tests to evaluate most configurations. Coastdown testing is a full-scale test method that requires the vehicle, which includes the trailer and an appropriately aerodynamic tractor, be driven on a road or track that meets specified conditions. An important challenge with coastdown testing is that wind and weather restrictions can limit the days in which testing can be performed. Additionally, coastdown testing has higher natural variability due to environmental variability in an uncontrolled system. We have placed an additional restriction on the allowable difference in yaw angles for delta C
dA measurements to 
reduce this variability (see 40 CFR 1037.526(a)(2)). However, the combination of our test constraints (e.g., restrictions on the wind, temperature, and road conditions), can make it challenging to measure a drag difference from two valid coastdown tests. These factors would make accurate coastdown testing for the trailer program even more time-consuming and expensive relative to the tractor program. Accordingly, we decided that wind tunnel testing is more appropriate for this newly regulated industry. 
Coastdown testing has two significant 
advantages over wind tunnel testing. First, as a full-scale method, it can be directly applied to actual products. Second, full-scale methods may be the only way to reliably test small-scale devices that cannot be appropriately scaled or recreated in wind tunnel or CFD. Although these advantages justify allowing coastdown testing as an alternate method, they do not justify the additional costs that would occur if it 
were specified as the primary test method for trailers. 
In making this determination, the 
agencies were cognizant of the limited financial ability of trailer manufacturers (and device manufacturers) to absorb testing costs. Unlike the tractor industry, most of the manufacturers in the trailer industry are small- to medium-sized companies. Even the largest trailer manufacturers are much smaller than the companies that manufacture tractors. Had we established coastdown as the primary method, trailer manufacturers would have needed to not only perform extensive coastdown testing to show equivalency with their preferred methods, but would have also needed to maintain the ability to perform coastdowns on a regular basis like tractor manufacturers are required to under Phase 1 and Phase 2, including owning or maintaining access to an appropriate test tractor or tractors. While this is a manageable burden for the large tractor manufacturers, it would have been a substantial burden for trailer manufacturers, especially the smaller ones. TTMA commented that any of the larger manufacturers in its membership that may do testing would prefer wind tunnel or CFD testing to ‘‘contain costs.’’ In conjunction with the NODA, EPA laid out principles related to aerodynamic testing that we intended to follow when applying our compliance oversight to trailers.
370In 
particular, we indicated that we intended to rely more on our own confirmatory testing, recognizing that both trailer manufacturers and device manufacturers have less financial ability to perform Selective Enforcement Audit (SEA) testing than do tractor manufacturers (see Section IV.E.(4)(f) for more information on SEAs). Under the final regulations, the agencies can perform wind tunnel testing, but would also retain the right to perform coastdown testing, provided we adjusted any coastdown results to account for yaw differences. If we conducted confirmatory testing using coastdowns, we would also need to perform enough runs to minimize variability between the test conditions. Should we measure worse aerodynamic performance (after fully adjusting for methodological differences and accounting for test-to-test variability), we would require the manufacturer to use our test results as the official test results. It is important to emphasize that, because confirmatory testing generally occurs before we have issued a certificate of conformity and before the manufacturer has begun production, there are no penalties or other compliance actions that would result from EPA confirmatory testing. Thus, we do not expect manufacturers using wind tunnels to have any need to 
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separately verify their results using 
coastdown procedures. 
Details of the test procedures can be 
found in 40 CFR 1037.526 and a discussion of EPA’s aerodynamic testing program as it relates to the trailer program is provided in the RIA Chapter 3.2. The following subsections outline the testing requirements for the long term trailer program, as well as simpler testing provisions that apply in the nearer term. 
(i) A to B Testing for Trailer 
Aerodynamic Performance 
The agencies expect a majority of the 
aerodynamic improvements for trailers will be accomplished by adding bolt-on technologies. As just explained above, a key difference between the tractor program and the trailer program is that while the tractor test procedures provide a direct measurement of an absolute C
dA value for each tractor 
model, aerodynamic improvements for trailers are evaluated by measuring a change in C
dA (delta C dA) relative to a 
baseline without aerodynamic improvements. Specifically, trailer tests are performed as ‘‘A to B’’ tests, comparing the aerodynamic performance of a tractor-trailer without a trailer aerodynamic device (or package of devices) to one with the device (or package) installed. As noted below, this approach can be applied if changes are made to the aerodynamic design of a trailer as well. See RIA Chapter 2.10.2.1.2 for more justification for this A to B approach. 
In essence, an A to B test is a pair of 
tests: one test of a baseline tractor-trailer in a ‘‘no-control’’ configuration with zero trailer aerodynamic improvements (A), and one test that includes the aerodynamic improvements to be tested (B). However, because an A test relates to a B test only with respect to the test method and the basic tractor-trailer vehicle, one A test could be used for 
many different B test configurations. This type of testing results in a delta C
dA value instead of an absolute C dA 
value. For the trailer program, the vehicle configuration in the A test includes a standard tractor that meets specified characteristics (40 CFR 1037.501(h)), and a baseline trailer with no aerodynamic improvements. The entity conducting the testing (e.g., the 
trailer manufacturer, a contractor, or an aerodynamic device manufacturer, as discussed below) performs the test for this configuration according to the procedures in 40 CFR 1037.526 and repeats the test for the B configuration, which includes the trailer aerodynamic package/device(s) being tested. The delta C
dA value for that trailer with that aerodynamic improvement is the 
difference between the C dA values 
obtained in the A and B tests. 
The agencies note that it was 
relatively straightforward in Phase 1 to establish a standard trailer with enough specificity to ensure consistent testing of tractors, since there are relatively small differences in aerodynamic performance of base-model dry box vans. However, as discussed in Chapter 2.10 of the RIA, small differences in tractor design can have a significant impact on overall tractor-trailer aerodynamic performance. An advantage of an A to B test approach for trailers is that many of the effects due to differences in tractor design are minimized, which allows different models of tractors to be used as standard tractors in testing without compromising the evaluation of the trailer aerodynamic technology. Thus, the relative approach does not require the agencies to precisely specify a standard tractor, nor does it require trailer manufacturers to purchase, modify or retain a specific tractor model in order to evaluate their trailers. 
In the event that a trailer 
manufacturer makes major changes to the aerodynamic design of its trailer in lieu of installing add-on devices, it could use the same baseline trailer for the A configuration as could be used for bolt-on features. In both cases, the baseline trailer would be a manufacturer’s standard box van. Thus, the manufacturer of a redesigned trailer would get full credit for any aerodynamic improvements it made. 
As discussed in Chapter 2.10 of the 
RIA, measured drag coefficients and drag areas can vary slightly depending on the test method used. In general, absolute wind-averaged C
dA values 
measured using wind tunnels and CFD tend to be higher than values measured using the near-zero yaw coastdown method. The Phase 1 and Phase 2 tractor program use coastdown testing as the reference test method, and the agencies 
require tractor manufacturers to perform at least one test using that method to establish a correction factor to apply to each of the alternative test methods. The proposed trailer regulations referred to coastdown as our reference method, although we noted that the size of the bins and the use of delta C
dA (as 
opposed to absolute values) minimized the significance of variability between test methods. 80 FR 40280. CARB recommended that we require a reference method in our aerodynamic testing, but provided no data to support their recommendation. 
As noted already, the agencies have 
established the wind tunnel method as the primary method. Like the tractor 
program, the allowance to use alternate aerodynamic test procedures provides for adjustments to make the measurements equivalent to the primary method. This is done to ensure that the manufacturer is neither advantaged nor disadvantaged by using the alternate method, relative to results they would have obtained using the primary method. However, because determining equivalency between methods can be burdensome, the agencies are adopting in 40 CFR 1037.150(x) an interim allowance to use certain specific approximations based on data currently available to us. Manufacturers would not be required to justify using these approximations or to seek prior approval for them. Nevertheless, in the unlikely event that we determine that these approximations overstate actual aerodynamic performance for a particular trailer or device, we would not allow the manufacturer to use the approximated values for certification and they would be required to use other more reasonable adjustments. 
Our test results shown in Chapter 2.10 
of the RIA, show that wind tunnel and CFD produce wind-averaged delta C
dA 
values within the same bin for the devices tested. Thus, this interim provision allows CFD results to be used without adjustment. Coastdown delta C
dA results, which are not wind- 
averaged, may be in the same bin, but we note that the tails showed more yaw dependence and coastdown tests under- predicted the performance of tails relative to wind-averaged methods. We anticipate some additional current and future devices may be sensitive to yaw angle, and our interim provision accounts for this. Manufacturers that choose to use coastdown testing can use their results without adjustment, or, if they suspect their device is affected by yaw angle, they can use other testing or analytical methods to demonstrate a means of adjusting their near-zero yaw results to a wind-averaged equivalent 4.5-degree value. The bin values in Section IV.E.(3)(b)(iv), which were 
updated based on additional aerodynamic test data collected between the NPRM and final rules, are based on our wind tunnel testing results, though our results suggest that most CFD and coastdown results will fit into the same bins. See RIA Chapter 2.10.2.1.3. 
(ii) Standard Tractor for Aerodynamic 
Testing in the Trailer Program 
The agencies are adopting a set of 
characteristics that qualify a tractor to be use in trailer aerodynamic compliance testing. EPA’s trailer testing program investigated the impact of 
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371CFD test contracts are often priced for 
individual yaw angles. Wind tunnel test contracts 
are often priced for an entire yaw sweep. Limiting our measurement requirement to one or two yaw angles is expected to reduce the cost of generating a wind-averaged value from CFD, but will only reduce the cost from wind tunnel tests if the manufacturer choses to do individual yaw angles in lieu of the customary sweep. tractor aerodynamics on the 
performance of trailer aerodynamic technologies, as mentioned in Chapter 2.10.2.1.2.2 of the RIA. We found the A to B test strategy reduces the degree of precision with which the standard tractor needs to be specified. Instead of identifying a specific make and model of a tractor to be used over the entire duration of the program, the agencies identified an appropriate aerodynamic performance threshold that maintains a relatively consistent level of performance between trailers. Tractors used in trailer aerodynamic tests must meet Phase 2 aerodynamic Bin III or better tractor requirements. We believe the majority of tractors in the U.S. trucking fleet will be Bin III or better in the timeframe of this rulemaking, and trailer manufacturers have the option to choose higher-performing tractors in later years as tractor technology improves. See Section III.D.2.c.i. The standard tractor for long-box vans is a Class 8 high-roof sleeper cab. The standard tractor for short box vans is a Class 7 or 8 high roof day cab with a single drive axle (i.e., 4x2 axle 
configuration). Trailer or device manufacturers are free to choose any standard tractor that meets these criteria in their aerodynamic performance testing. See 40 CFR 1037.501. 
The compliance equation used to 
determine compliance with the trailer standards is based on GEM, so our discussion of the feasibility of our standards (Section IV.D.(2)) includes a description of the tractor-trailer vehicle used in GEM. The agencies proposed to require use of a 6x4 Class 8 sleeper cab for long box van aerodynamic testing, and a 6x4 Class 8 day cab for short box van testing. 80 FR 40279. We believe Class 8 tractors are more widely available, which will make it easier for the trailer industry to obtain a qualified tractor if they choose to perform trailer testing. In order to align with the test procedures, we also proposed to consistently model a Class 8 tractor across all trailer subcategories in GEM. CARB supported the use of Class 8 tractors in their comments. However, EPA encountered difficulty in meeting the test procedure-specified tractor- trailer gap width when using a dual drive axle day cab in one of our short box van wind tunnel tests due to the location of the landing gear relative to the kingpin. As a result, we are changing the standard tractor specifications for aerodynamic testing to require the use of a 4x2 tractor for short trailers. While we expect most manufacturers will use tractor-trailer models in wind tunnel or CFD testing, we recognize that there are fewer 4x2 
tractors available for full-scale testing, and we are adopting provisions that testers can use either a Class 8 or Class 7 day cab tractor to address availability concerns. We believe the external aerodynamic characteristics of Class 7 and Class 8 day cabs are very similar and the engine performance differences between the two tractor classes would not impact the aerodynamic performance in terms of delta C
dA. Note 
that a Class 7 4x2 day cab tractor is used for all short van default tractor-trailer vehicles within GEM and represented in the GEM-based equation (see Table IV– 8). 
Daimler requested that we choose a 
single tractor for all trailer testing to 
ensure consistency over time. As stated above, the agencies agree that the tractor does have the potential to influence the aerodynamic performance of trailers. As discussed above, however, we believe that influence is reduced with use of a delta C
dA. Additionally, we believe it 
would be a significant burden on the trailer industry to require manufacturers and suppliers to acquire a specific tractor make and model over the timeframe of the rules. Thus, the final trailer program does not require the use of a specific tractor make for the Phase 2 trailer program. 
(iii) Accounting for Wind Impacts When 
Measuring Aerodynamic Performance 
The agencies proposed to determine 
the delta C
dA for trailer aerodynamic 
performance using the zero-yaw (or head-on wind) values from any of the approved test procedures. However, based on comments received, we are revising the final program to be based on wind-averaged results, similar to the tractor program. The agencies recognize the value of wind-averaging to better reflect the performance expected in real- world operation, but at the time of 
proposal, we believed the use of a zero- yaw delta C
dA would reduce the 
number of tests compared to generating a wind-averaged value from a sweep of yaw angles. Additionally, it is relatively straightforward to generate wind- averaged C
dA values from wind tunnel 
and CFD, but there is a significant increase in test burden to obtain wind- averaged results from coastdown tests. Our intent was to ensure parity between test procedures, such that manufacturers would have the several options to test aerodynamic performance. 
The agencies received comment on 
this issue, in the context of the proposed tractor standards, suggesting that the C
dA measured at a yaw angle of 4.5 
degrees is very similar to the wind- averaged C
dA calculated at 7 degrees/65 MPH. The agencies evaluated our own test data using an average of +4.5 degrees and ¥4.5 degrees to minimize the effect of potential facility asymmetry, and found that the results were within two percent of the corresponding wind-averaged values (See Section III.E.2.a and Chapter 3.2 of the RIA). Adoption of this surrogate angle approach reduces the cost of generating a wind-averaged value from wind tunnel and CFD procedures.
371 
Consequently, the tractor program uses an average C
dA measured at +4.5 and 
¥4.5 degree yaw angles as a surrogate wind-averaged value (see RIA Chapter 3.2 for more information). However, it does not address the increased burden for conducting coastdown tests. 
The agencies received comment from 
TTMA that ‘‘repetitive’’ coastdown testing would rarely be used by its trailer manufacturer members. Instead, manufacturers that do choose to perform their own testing will likely rely on CFD and wind tunnel tests. Because we are establishing the wind tunnel method as the primary method, and because we expect it to also be the most commonly used method, we no longer have test burden concerns about requiring wind- averaging. Therefore, the agencies believe we can adopt aerodynamic test procedures for trailers that require wind-averaged delta C
dA values, as 
represented by an average of results from +4.5 and ¥4.5 degree yaw angles, for compliance. We believe that coastdown testing will be chosen by a small number of manufacturers and the burden of performing this optional test on the overall industry will be relatively small. EPA may rely on coastdown testing in its own confirmatory testing, and the agency will accept the additional burden of correcting to a wind-averaged value. 
(iv) Bins for Aerodynamic Performance 
As mentioned in Section IV.D., the 
trailer program uses aerodynamic bins 
to account for testing variability and to provide consistency in the performance values used for compliance. We developed these bins in terms of delta C
dA ranges, and we designed them to be 
broad enough to cover the range of uncertainty seen in our aerodynamic testing program in terms of test-to-test variability as well as variability due to 
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372Note that in the event a device manufacturer 
submits false or inaccurate data to EPA, it could 
incur liability for causing a regulated entity to commit a prohibited act. See 40 CFR 1068.101(c). This same potential liability exists with respect to information provided by a device manufacturer directly to a trailer manufacturer. 
373A trailer manufacturer needs to use good 
engineering judgement (as defined in 40 CFR 1068.5) in combining devices for compliance in order to avoid combinations that are not intended to work together (e.g., both a side skirt and an 
under-body device). differences in test method, tractor 
models, trailer models and device models. The bins are somewhat different than in the proposal, as discussed in Section IV.D.(1)(a)(ii) above RIA Chapter 2.10.2.1.3. 
TABLE IV–25—A ERODYNAMIC BINS 
USED TODETERMINE INPUTS FOR  
TRAILER CERTIFICATION  
Delta C dA measured 
in testing Bin Delta C dA 
input for 
compliance 
<0.1 ......................... Bin I ..... 0.0 
0.10–0.39 ................ Bin II .... 0.1 
0.40–0.69 ................ Bin III ... 0.4 
0.70–0.99 ................ Bin IV .. 0.7 
1.00–1.39 ................ Bin V ... 1.0 
1.40–1.79 ................ Bin VI .. 1.4 
≥1.8 ......................... Bin VII 1.8 
A manufacturer that wishes to 
perform testing first identifies a standard tractor according to 40 CFR 1037.501(h) and a representative 
baseline trailer with no aerodynamic features (or models of these vehicles), then performs the A to B tests with and without aerodynamic improvements to obtain a delta C
dA value. The 
manufacturer uses Table IV–25 to determine the appropriate bin based on their measured delta C
dA. Each bin has 
a corresponding delta C dA threshold 
value that is the value manufacturers insert into the compliance equation. 
(v) Aerodynamic Device Testing 
Compliance Path 
The agencies recognize that much of 
the trailer manufacturing industry may have little experience with aerodynamic performance testing. For this reason, the program includes a compliance option that we believe minimizes the testing burden for trailer manufacturers, and at the same time meets the requirements of the Clean Air Act and of EISA by providing reasonable assurance that the anticipated CO
2and fuel consumption 
benefits of the program will be realized in real-world operation. This approach provides an opportunity for trailer manufacturers to choose technologies with pre-approved test data for installation on their new trailers without performing their own aerodynamic testing. We note that this testing option is consistent with recommendations of the Small Business Advocacy Review (SBAR) Panel, which is summarized in Section XIV.D and Chapter 12 of the RIA. 
The trailer program provides for 
trailer aerodynamic device manufacturers to seek preliminary approval of the performance of their devices (or combinations of devices) based on the same performance tests 
described previously. Trailer manufacturers could then choose to use these devices and apply the approved performance levels in the certification application for their trailer families. A device manufacturer would need to perform the required A to B testing using a tractor-trailer that meets the requirements specified in 40 CFR 1037.211 and 1037.526 and submit the performance results, in terms of delta C
dA, directly to EPA.372EPA would 
require much of the same information from the device manufacturers as it would normally require during certification, including the technology name, a description of its proper installation procedure, and its corresponding delta C
dA derived from 
the approved test procedures. See 40 CFR 1037.211. 
Once a device manufacturer has 
obtained this preliminary approval, it could supply the same information to any trailer manufacturers that wish to install its devices. When the trailer manufacturer certifies, the agencies would merely verify that the values in the trailer manufacturer’s certification application are those already approved 
for the device manufacturer. To ease the transition for MYs 2018 through 2020, we proposed and are adopting a flexibility to allow pre-approval of certain data accepted by the EPA SmartWay aerodynamic verification program. Section IV.E.(5)(c) below describes how a device manufacturer can use certain test data generated for SmartWay verification as a part of its pre-approval in the early years of the program. 
The program also allows trailer 
manufacturers to use multiple devices with individually pre-approved test data on a single trailer configuration, provided each device does not impair the effectiveness of the other(s), consistent with good engineering judgment.
37340 CFR 1037.211 outlines 
a process for combining the effects of multiple devices to determine an appropriate delta C
dA value for 
compliance. More specifically, manufacturers would fully count the technology with largest delta C
dA value, discount the second by 10 percent, and discount each of the remaining additional technologies by 20 percent. This discounting acknowledges the complex interactions that can occur among individual aerodynamic devices and provides a conservative value for the impact of the combined devices (see the analysis of device combinations in RIA Chapter 2.10). For example, a manufacturer applying three separately tested devices with delta C
dA values of 
0.40, 0.30, and 0.10 would calculate the combined delta C
dA as: 
Delta C dA = 0.40 + 0.90*0.30 + 
0.80*0.10 = 0.75 m2 
The agencies believe that discounting 
the delta C dA values of individually- 
tested devices used as a combination provides a modest incentive for trailer or device manufacturers to test and get EPA pre-approval of the combination as an aerodynamic system for compliance. To avoid this discounting, device manufacturers can test a trailer incorporating a combination of devices and receive EPA pre-approval for data from that combination. Trailer manufacturers could then use the test results from that specific combination for certification. 
Note that the aerodynamic bins of 
Table IV–25 do not apply to aerodynamic data that device manufacturers submit to EPA for pre- approval. The pre-approved data will have greater precision than the bin- averaged values shown in Table IV–25. Therefore, trailer manufacturers calculating a delta C
dA value based on 
combinations of pre-approved data use the exact numbers submitted by the device manufacturers to calculate the discounted delta C
dA, and thus select an 
appropriate bin value for compliance based on that result. The process to obtain approval is outlined in 40 CFR 1037.211. 
The agencies note that many of the 
largest van manufacturers are already performing aerodynamic test procedures to some extent, and the agencies expect other van manufacturers will increasingly be capable of and interested in performing these tests as the program progresses. The device testing approach is intended to allow trailer manufacturers to focus on and become familiar with the certification process in the early years of the program and, if they wish, begin to perform testing in the later years, when it may be more appropriate for their individual companies. This approach does not preclude trailer manufacturers from performing their own testing at any time, even if the technologies they wish to install are already pre-approved. For 
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example, a manufacturer that believed a 
specific trailer actually performed in a more synergistic manner with a given device than the device’s pre-approved delta C
dA value suggested could 
perform its own testing and submit the results to EPA for certification. 
STEMCO, an aerodynamic device 
manufacturer, commented in support of the proposed pre-approval option, but also supported the agencies publishing information about the testing performed by device manufacturers for their devices to be pre-approved. The agencies are not committing to publish the pre-approved aerodynamic data at this time. We do note that once data are submitted to EPA and the device is introduced into commerce, the data are available to the public at their request and the information gathered may be published by outside stakeholders. 
(4) Additional Certification and 
Compliance Provisions 
(a) Trailer Useful Life 
Section 202(a)(1) of the CAA specifies 
that EPA is to propose emission 
standards that are applicable for the ‘‘useful life’’ of the vehicle. NHTSA is adopting EPA’s proposed useful life requirements for trailers, to ensure that manufacturers consider in their design process the need for fuel efficiency standards to apply for the same duration as the EPA standards. Based on our own research and discussions with trailer manufacturers, EPA and NHTSA are adopting a regulatory useful life value for trailers of 10 years, as proposed. This useful life value represents the average duration of the initial use of trailers, before they are moved into less rigorous duty (e.g., limited use or storage). We 
note that the useful life value is 10 years or a mileage threshold for other heavy- duty vehicles. However, unlike for the other vehicles, the program does not include a parallel mileage value for trailers. This would require odometers on trailers, and we do not believe that mandating odometers would be appropriate for this purpose. 
With this useful life provision, trailer 
manufacturers are responsible for designing and building their trailers so that they will be able to meet the CO
2 
emissions and fuel consumption standards for 10 years after the trailer is produced, provided that they are properly maintained. For technologies at issue here, we believe that this requirement is essentially the same as customers’ existing durability expectations. The useful life requirements do not include liability for damage to or removal of devices by users. Instead, trailer manufacturers must ensure at the time of sale that 
devices are properly installed and able to maintain functionality throughout the useful life. We believe that manufacturers will be able to demonstrate at certification that their trailers, including all bolt-on technologies used as emissions controls, will comply with the CO
2and fuel 
consumption standards for the useful life of the trailers without separate durability testing. The aerodynamic technologies that we expect manufacturers to use to comply with the trailer standards, including side skirts and boat tails, are designed to continue to provide their full potential benefit indefinitely as long as no serious damage occurs. 
Regarding a useful life value for trailer 
tires, we recognize that the original lower rolling resistance tires will wear over time and will be replaced several times during the useful life of a trailer, either with new or retreaded tires. As with the Phase 1 tractor program, to help ensure that trailer owners have sufficient knowledge of which replacement tires to purchase in order to retain the as-certified emission and fuel consumption performance of their trailer for its useful life, the trailer program requires that trailer manufacturers supply adequate information in the owners manual to allow the trailer owner to purchase replacement tires meeting or exceeding the rolling resistance performance of the original equipment tires. (Note that the ‘‘owners manual’’ need not be a physical document, but could be made available on line). We believe that the favorable fuel consumption benefit of continued use of LRR tires generally results in proper replacements throughout the 10-year useful life. Finally, the program requires that tire pressure systems remain effective for at least the 10-year useful life, although some servicing may be necessary by the customer. See also the related discussions below in Section IV.E.(4)(c) (Emission-Related Warranty) and Section IV.E.(4)(d) (Maintenance). 
(b) Emission Control Labels 
Historically, EPA-certified vehicles 
are required to have a permanent 
emission control label affixed to the vehicle. The label facilitates identification of the vehicle as a certified vehicle. For the trailer program, EPA requires that the labels include the same basic information as we require for tractor labels in Phase 1. For trailers, this information includes the manufacturer, a trailer identifier such as the Vehicle Identification Number, the trailer family and regulatory subcategory, the date of 
manufacture, and compliance statements. Although the Phase 2 label for tractors does not include emission control system identifiers (as previously required for tractors in the Phase 1 program in 40 CFR 1037.135(c)(6)), the trailer program requires that these identifiers be included in the trailer labels. See 40 CFR 1037.135 for a list of general requirements for emissions labels, which includes a reference to Appendix III for appropriate abbreviations for trailer technologies. 
(c) Emission-Related Warranty 
Section 207 (a) of the CAA requires 
manufacturers to warrant their products 
to be free from defects that could otherwise cause non-compliance with emission standards. For purposes of the trailer program, EPA requires trailer manufacturers to warrant all components that form the basis of the certification to the CO
2emission 
standards. The emission-related warranty covers all aerodynamic devices, lower rolling resistance tires, tire pressure systems, and other components that may be included in the certification application. Note that the emission-related warranty is completely separate from any other warranties a manufacturer might offer. 
The trailer manufacturer needs to 
warrant that these emission-related components and systems are designed to remain functional for the warranty period. We note that this emission- related warranty, and the trailer manufacturer’s financial responsibility for repairs, does not apply to components that are damaged in collisions or through abuse; nor does it cover components that experience wear with normal use. This warranty is meant to apply to defects in the product or improper installation by the manufacturer. Based on the historical 
practice of requiring emissions warranties to apply for half of the useful life, we are adopting a warranty period for trailers of five years for everything except tires. For trailer tires, we apply a warranty period of one year. 
Utility and Great Dane noted in their 
comments that the warranty of current ATIS that they are aware of is limited to three years. However, we view this as a business decision by the ATIS manufacturers, rather than as a reflection of the actual durability of the systems. With proper maintenance, we are aware of no reason that these systems would be unable to meet the durability requirements of the trailer program or to be designed to last the full useful life of the trailer if properly maintained. See the Maintenance 
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discussion at IV.E.(4)(d) below. We 
believe a five year emission-related warranty is justified, but we note that trailer manufacturers can specify that their warranty depends on the proper maintenance of components. Manufacturers can offer a more generous warranty if they choose; however, the emission-related warranty may not be shorter than any other warranty they offer without charge for the trailer. NHTSA is not adopting any warranty requirements relating to its trailer fuel consumption program. 
At the time of certification, 
manufacturers need to supply a copy of the warranty statement that they supply to the end customer. This document outlines what is covered under the GHG emissions related warranty as well as the duration of coverage. Customers also need to have clear access to the terms of the warranty, the repair network, and the process for obtaining warranty service. 
(d) Maintenance 
In general, EPA requires that vehicle 
manufacturers specify schedules for any 
maintenance needed to keep their product in compliance with emission standards throughout the useful life of the vehicle (CAA section 207(a)). For trailers, such maintenance could include adjustments to fairings or service to tire pressure systems. EPA believes that any such maintenance is likely to be performed by operators to maintain the fuel savings of the components. If manufacturers believe that the durability of their trailer’s performance is contingent on proper maintenance of these systems, they must include a corresponding maintenance schedule in their certification applications. 
Since lower rolling resistance tires are 
key emission control components under this program, and they will likely require replacement at multiple points 
within the life of a vehicle, it is important to clarify how tires fit into the emission-related maintenance requirements. Although the agencies encourage the exclusive use of LRR tires throughout the life of trailers vehicles, we do not hold trailer manufacturers responsible for the actions of end users. We do not see this as problematic because, as noted above, we believe that trailer end users have a genuine financial motivation for ensuring their vehicles are as fuel efficient as possible, which includes purchasing LRR replacement tires and that they will continue to use them once they are accustomed to their use. Therefore, as mentioned in Section IV.E.(4) above, to help ensure that trailer owners have sufficient knowledge of which replacement tires to purchase in order to retain the as-certified emission and fuel consumption performance of their trailer, the program requires that trailer manufacturers supply adequate information in the owners manual to allow the trailer owner to purchase tires meeting or exceeding the rolling resistance performance of the original equipment tires. (As discussed above, note that the ‘‘owners manual’’ need not be a physical document, but could be made available on line). Manufacturers submit these instructions to EPA as part of the application for certification. 
(e) Post-Useful Life Modifications 
The Clean Air Act generally prohibits 
any person from removing or rendering 
inoperative any emission control device installed for compliance, such as those needed to comply with the requirements of 40 CFR part 1037. However, in 40 CFR 1037.655 EPA clarifies that certain vehicle modifications are allowed after a vehicle reaches the end of its regulatory useful life. This section applies to trailers, since it applies to all vehicles subject to 40 CFR part 1037. 
The provisions of 40 CFR 1037.655 
clarify that owners may modify a vehicle for the purpose of reducing emissions, provided they have a reasonable technical basis for knowing that such modification will not increase emissions of any other pollutant, but emphasizes that EPA presumes such modifications to be more appropriate for second owners. In the case of trailers, an owner would need to have information that would lead an engineer or other person familiar with trailer design and function to reasonably believe that the modifications will not increase emissions of any regulated pollutant. In the absence of such information, modifications during or after the trailer’s useful life would constitute tampering with an emission control system. Thus, this provision does not provide a blanket allowance for modifications after the useful life. 
This section does not specifically 
apply with respect to modifications that occur within the useful life period, other than to note that many such modifications to the vehicle during the useful life are presumed to violate CAA section 203(a)(3)(A). EPA notes, however, that this is merely a presumption, and would not prohibit modifications during the useful life where the owner clearly has a reasonable technical basis for knowing the modifications will not cause the vehicle to exceed any applicable standard. (f) Confirmatory Testing and Selective Enforcement Audits (SEA) for GEM Inputs 
In Phase 2, vehicle performance for 
box vans (except non-aero box vans) is measured using a GEM-based equation, which accepts input parameters related to aerodynamics, tire rolling resistance, and trailer weight. Trailer manufacturers are responsible for obtaining performance measures for these parameters through valid testing according to the specified test procedures. The Clean Air Act authorizes EPA to perform its own testing to confirm the manufacturer’s data. This testing, which is called confirmatory testing, is conducted prior to issuing a certificate. The Act also authorizes EPA to require manufacturers to conduct Selective Enforcement Audits (SEA), which would involve testing performed on production vehicles before they enter into commerce. 
The agencies are finalizing a list of 
lightweight trailer components that can be installed by trailer manufacturers and used in certification. Additionally, we are assigning a set percent reduction value to qualifying tire pressure systems (i.e., ATIS and TPMS) that 
manufacturers can apply if they install these systems. Thus, because these are agency-default values rather than the manufacturers’ measured or declared values, we will not hold trailer manufacturers responsible for the accuracy of these values. Additionally, we expect most trailer manufacturers will obtain LRR tire information directly from the tire manufacturers and many trailer manufacturers will install aerodynamic devices with data that was pre-approved by EPA. Information provided by a third party (such as a tire or device manufacturer) to a regulated entity for compliance is treated as though it was submitted directly to EPA. EPA has the authority to verify such data and hold the third party responsible for any falsified data, since submission of such data could incur liability for causing a regulated entity to commit a prohibited act. See 40 CFR 1068.101(c). 
Of all of the performance measures for 
trailers, we believe aerodynamic testing has the greatest potential for variability and these results are likely to receive the most scrutiny. In the NPRM, we proposed to generally apply the same SEA and confirmatory testing structures to tractors and trailer with respect to aerodynamics. However, we also proposed to retain the authority to require component manufacturers to 
perform SEAs where certification relies 
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3742015 Trailer Production Figures Table. 
Schenk, Paul. March 4, 2016. Accessed January 4, 
2016. Available at: http://trailer-bodybuilders.com/ 
trailer-output/2015-trailer-production-figures-table . on their test data. See, e.g. section 
1037.301(d)(4) of the proposed 
regulations. 
We are revising the SEA and 
confirmatory testing structures for trailers based on further consideration and comments received from the trailer manufacturing industry (TTMA). In general, the final regulations reflect the following principles: 
•Due to the smaller number of 
possible trailer configurations (compared to tractor configurations), it would be more possible for EPA to rely on confirmatory testing for trailer aerodynamics. 
•Since test-to-test variability for 
individual coastdown runs can be high, confirmatory test determinations should be based on average values from multiple runs. 
•Trailer manufacturers and trailer 
component manufacturers have less financial ability to perform SEAs than do tractor manufacturers. Nevertheless, EPA should retain the authority to require trailer and trailer component manufacturers to perform SEAs, especially where EPA has reason to believe the trailers are non-compliant. 
•Given the limited ability to 
eliminate uncertainty, compliance determinations should consider the statistical confidence that a true value lies outside a bin. 
EPA will generally try to duplicate a 
manufacturer’s test setup in any confirmatory testing (which would include the standard tractor) unless we have reason to believe an inappropriate setup was used. While our test results presented in Chapter 2.10 of the RIA show that the trailer program’s delta C
dA approach reduces the tractor’s 
impact on trailer results, to the extent practical, EPA will use the same standard tractors that manufacturers used in their testing. 
We believe that, although the final 
compliance structure for trailers is simpler than for tractors, it will still provide a strong incentive for manufacturers to act in good faith. In particular, the regulations emphasize the final value of EPA’s auditing records and inspecting production components, rather than requiring manufacturers to perform expensive testing. Thus, EPA expects to require manufacturers to perform SEA testing only when we have reasonable evidence leading us to believe a manufacturer have not provided accurate test data. See Section III.E.(2)(a)(ix) for a discussion of how EPA would conduct an aerodynamic SEA. (g) Importation of New Trailers 
Manufacturers have raised concerns 
about enforcement of emission standards for new trailers that are imported into the United States. This poses unique challenges at the point of entry, because new trailers may be carrying cargo and are therefore nearly indistinguishable from trailers that have already been imported or otherwise placed into service. We are not adopting any new or different compliance provisions in this rulemaking to address this; however, we intend to work cooperatively with Customs and Border Protection and other agencies to ensure that first-time state registration of new trailers includes verification that the trailer manufacturers have certified them to meet U.S. emission and fuel consumption standards. We expect this to be similar to the current system for ensuring that new, imported trailers meet NHTSA safety standards. 
A related concern applies for foreign- 
based trailers traveling in the United States for importing or exporting cargo. Such trailers are not subject to emission and fuel consumption standards unless they are considered imported into the United States. U.S. cabotage law prohibits foreign truck drivers from carrying product from one point to another within the United States. Effective enforcement of this cabotage law will help prevent manufacturers of noncompliant foreign-produced trailers from gaining a competitive advantage over manufacturers of compliant domestic trailers. 
(5) Flexibilities 
The trailer program that the agencies 
are adopting incorporates a number of 
provisions that have the effect of providing flexibility and easing the compliance burden on trailer manufacturers while maintaining the expected CO
2and fuel consumption 
benefits of the program. Among these is the basic approach we used in setting the trailer standards, including the staged phase-in of the standards, which gradually increase the CO
2and fuel 
consumption reductions that manufacturers need to achieve over time as they also increase their experience with the program. As described in Section IV.E.(3)(b)(v), another of these is the process for device manufacturers to submit test data directly to EPA for review by the agencies in advance of formal certification, allowing a trailer manufacturer to reduce the amount of testing needed to demonstrate compliance or avoid it altogether. 
In addition to these provisions 
inherent to the trailer program, this section describes additional options the agencies are adopting that we believe will be valuable to many trailer manufacturers. 
(a) Limited Allowance of Non- 
Complying Trailers 
As described in Section IV.B. above 
the agencies are not finalizing the proposed provisions that would have allowed manufacturers to comply with the trailer standards using averaging before MY 2027. As a result, in the absence of mitigating provisions, manufacturers would need to comply with the applicable standards for all of their trailers. The agencies received comment, primarily from trailer manufacturers, that, without the flexibility of averaging, trailer manufacturers should be allowed to ‘‘carve-out’’ a set percentage of their sales that would not be required to meet the standards. Stoughton Trailers suggested a 20 percent carve-out. 
The agencies considered this concept 
and this final program provides each manufacturer with a limited ‘‘allowance’’ of trailers that do not need to meet the standards. In determining an appropriate value for this allowance, the agencies sought to balance the need for some degree of flexibility in the absence of averaging while minimizing changes in the competitive relationships among larger and smaller trailer manufacturers. An allowance of 20 percent, as suggested by Stoughton, is problematic, since the annual production for individual trailer manufacturers varies so widely. An allowance of 20 percent for a very large manufacturer could very well represent the same volume of trailers as an entire year’s sales for a small manufacturer. This in turn could result in a situation where a large number of non-complying trailers would be on the market, potentially attracting customers away from smaller manufacturers that needed to market complying trailers. 
Because of this, the agencies 
estimated a representative volume of trailers based on the 2015 Trailer Production Figures published by Trailer-BodyBuilders.com.
374The 
smallest box van manufacturer in the list produced 1800 dry freight vans in 2015. Twenty percent of that production is 360 trailers. The agencies are adopting an interim provision providing box van manufacturers an allowance of 20 percent of their production (up to a maximum of 350 units) that are not 
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required to meet the standards for 
model years 2018 through 2026 when we do not include averaging. All lengths of box vans, including both dry and refrigerated, produced by a given manufacturer count toward the allowance. 
While averaging does not apply for 
partial- and non-aero box trailers at any point in the program, the agencies believe manufacturers can also benefit from the ability to exempt some trailers from these subcategories in the early years as they transition into the full program. For MY 2018 through 2026, manufacturers can include partial- and non-aero box trailers in their 350 box van allowance. In MY 2027, we believe all partial- and non-aero box vans can meet the reduced standards for their given subcategories. 
Non-box trailers have design-based 
tire standards and averaging thus does not apply for this subcategory. Similar to the partial- and non-aero box vans, we also believe non-box manufacturers can benefit from a transitional exemption allowance. The agencies are adopting a separate allowance for non- box trailers, because their production volumes differ and many non-box trailer manufacturers do not build box vans. Using the same trailer production figures, we found that the smallest non- box trailer manufacturer in the list produced 1325 trailers in 2015 and twenty percent of that production is 265 trailers. From MY 2018 through 2026, non-box trailer manufacturers can 
exempt 20 percent or 250 trailers from the applicable tire standards. By MY 2027, we believe all non-box trailers can incorporate the tire technologies required by the design standards. 
The agencies estimate that the box 
van and non-box trailer allowances translate on average to less than two percent of production across the trailer industry, and the agencies believe that this minor degree of loss of emission and fuel consumption reduction benefits is more than offset by the flexibility which, as pointed out earlier, may be needed by this newly regulated industry segment. These allowances are specified in 40 CFR 1037.150 and 49 CFR 535.3. 
(b) Averaging Provisions for the Late 
Years of the Trailer Program 
The agencies proposed to allow trailer 
manufacturers to use averaging throughout the phase-in of the program as one option for complying with the trailer standards. As noted, we received nearly unanimous comments, in response to the pre-proposal SBREFA panel and to the NPRM, from trailer manufacturers opposing averaging. Specifically, the commenters cited their 
concern that the unique aspects of the trailer market tend to mean that the value of averaging as a tool is less than it has been for manufacturers in other industries, and the potential for negative consequences to some manufacturers is substantial. The trailer manufacturing industry is very competitive, and manufacturers must be highly responsive to their customers’ diverse demands. Compared to other industry sectors, they can have little control over what kinds of trailer models their customers demand and thus limited ability to manage the mix and volume of different products. Additionally, one of the larger, more diverse manufacturers could potentially supply a customer with trailers that had few if any aerodynamic features, while offsetting this part of their business with over-complying trailers that they were able to sell to another customer; many smaller companies with limited product offerings might not be able to compete for those customers. 
As a result of the many comments 
opposing averaging from trailer manufacturers—the very stakeholders meant to benefit from an averaging program—the agencies have reconsidered how averaging is incorporated into the program. The final program does not allow averaging as a compliance option in the early years of the program, in MY 2018 through MY 2026. In those years, all box vans sold (beyond a manufacturer’s allowance of non-complying trailers) must meet the standards using any combination of available technologies. 
However, the agencies have 
concluded that by late in the program, the value of an averaging option to many trailer manufacturers may well outweigh the concerns they have expressed. In addition, the final stage of the phase-in of the standards for MY 2027 represents the most stringent standards in the program, and additional flexibility may be welcome by trailer manufacturers. Therefore, the final program will provide a limited optional averaging program for MY 2027 and later full-aero box vans. By that time, we believe that the trailer manufacturers will be experienced and comfortable with the program, and the 
industry will be more familiar with the technologies. 
The MY 2027 and later averaging 
provisions are identical in most respects to those we proposed for the other Phase 2 vehicle programs. One notable difference involves use of credits. As in the proposed trailer program, the averaging provisions for trailers focus on each individual model year’s production. A manufacturer choosing to 
use the averaging provisions could not ‘‘bank’’ compliance credits for a future model year or ‘‘trade’’ (sell) credits to another manufacturer, since these provisions would disproportionately benefit the few large trailer manufacturers. Under these averaging provisions, a full-aero box van manufacturer that produces some MY 2027 or later box vans that perform better than required by the applicable standard could produce a number of vans in the same family that do not meet the standards, provided that the average compliance levels of the trailers it produces in any given model year is at or below the applicable standards for that family. 
As in the proposed program, 
averaging is only available for full-aero box vans. The program is already designed to offer reduced standards for box vans designated as partial-aero, and the additional flexibility of averaging is not available. Also, averaging is inherently incompatible with design standards for non-aero box vans and non-box trailers, since those manufacturers cannot choose among compliance paths. 
The agencies are adopting averaging 
sets for full-aero box vans based on trailer length. Trailers in a family are certified to a single standard, but individual trailers within the family may be grouped to certify to a family emissions limit (FEL) that is higher or lower than the standard, provided the production-weighted average of all FELs in a family can be averaged to the standard or better. By allowing averaging sets to include both refrigerated and dry vans similar length categories, a manufacturer that over- complies, on average, in one family, can use the credits generated toward compliance in the other family. For example, if a manufacturer has two subfamilies in each of its long dry and long refrigerated van families, and the over-compliance of one dry van subfamily exceeds the under- compliance of the other dry van subfamily, the additional over- compliance beyond the dry van family’s standard become credits that can be used to offset any under-compliance in the refrigerated van family. 
In order to avoid backsliding with the 
use of averaging, the agencies are 
adopting a provision to require a minimum level of technology adoption in MY 2027 and later. No FEL can exceed the MY 2018 standard for the given trailer subcategory. For example, a manufacturer could not over-comply on some trailers and expect to produce a fraction of their trailers with zero 
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375Section IV.E.(1)(b) describes the process of 
identifying trailer families and sub-families based 
on basic trailer characteristics. 40 CFR 1037.710 describes the provisions for establishing subfamilies within a trailer family and the Family Emission Limits that are averaged among the subfamilies. 376Additional information regarding the findings 
and recommendations of the Panel are available in Section XIV, Chapter 12 of the RIA, and in the Panel’s final report titled ‘‘Final Report of the Small Business Advocacy Review Panel on EPA’s Planned Proposed Rule: Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles: Phase 2’’ (See Docket EPA– HQ–OAR–2014–0827). technologies installed; every trailer 
must, at minimum, include enough technologies to meet the corresponding MY 2018 standard. See 40 CFR 1037.107(a)(5) and 49 CFR 535.5(e). 
As mentioned previously, 
manufacturers with a trailer family that performed better than the standard at the end of the year would not be allowed to bank credits for a future model year. However, the agencies understand that it is possible for a manufacturer to misjudge production and come up short at the end of the model year. In such a case, the program provides for a manufacturer to generate a credit deficit, if necessary, as a temporary recourse for unexpected challenges in a given model year.
375The 
agencies would closely monitor the certification applications for the following model year, to ensure the manufacturer can make progress in reducing the deficit. Any such credit deficits would need to be resolved within the following three model years, and the manufacturer would need to generate credits from over-compliance in subsequent years to address deficits from prior model years. See 40 CFR 1037.745. 
The agencies believe that limiting the 
availability of averaging provisions to the final stage of the program will ease a number of the competitive concerns that trailer manufacturers have raised, since the trailer program will be familiar and the value of averaging may be greater as the most stringent standards phase in. Small business manufacturers raised concerns in our pre-proposal small business outreach that averaging would disproportionately benefit larger manufacturers with larger production volumes and greater product diversity. We are limiting our averaging program to single model year averaging (i.e., no 
banking or trading) to help address this concern. Similarly, we are adopting a maximum FEL based on the MY 2018 standard to ensure that larger manufacturers will not be able to produce large volumes of trailers with little or no technologies at the expense of manufacturers that cannot accumulate sufficient over-compliance within their annual production. To the extent that concerns about the MY 2027 and later averaging provisions remain as that model year approaches, the agencies look forward to working with manufacturers as they consider using 
averaging. (c) Aerodynamic Device Testing Using SmartWay-Verified Data 
The agencies expect some trailer 
manufacturers and aerodynamic device manufacturers to continue to submit test data to the SmartWay program for verification. Since many manufacturers have some experience with EPA’s SmartWay program, the agencies have designed the trailer program and aerodynamic testing to recognize the significant synergy with the SmartWay Technology Program. Section IV.E.(3)(b)(v) describes the compliance path available to trailer manufacturers to use pre-approved performance data for aerodynamic devices. As an additional interim option, any device manufacturer that attains SmartWay verification for a device prior to January 1, 2018 is eligible to submit its previous SmartWay-verified data to EPA’s Compliance Division for pre-approval, provided their test results come from one of SmartWay’s 2014 test protocols that measure a delta C
dA. The protocols 
for coastdown, wind tunnel, and computational fluid dynamics analyses result in a C
dA value. Note that 
SmartWay’s 2014 protocols allow SAE J1321 Type 2 track testing, which generates fuel consumption results, not C
dA values. Two commenters (a device 
manufacturer and an NGO) requested that we allow SAE J1321 track test results, but did not suggest a means of converting from the fuel consumption results to an appropriate delta C
dA value 
for use in compliance. As a result, the agencies will not accept J1321 data for pre-approval. 
Beginning on January 1, 2018, EPA 
will require that device and trailer manufacturers that seek approval of new aerodynamic technologies for trailer certification use one of the approved test methods for Phase 2 (i.e., coastdown, wind tunnel or CFD) and the test procedures found in 40 CFR 1037.526. Aerodynamic technologies that were pre-approved using performance data from SmartWay’s 2014 Protocols will maintain their approved status through December 31, 2020. Beginning January 1, 2021, all pre- approval of device performance will need to be based on testing using the Phase 2 test procedures. 
(d) Off-Cycle Technologies 
The Phase 1 and Phase 2 programs 
include provisions for manufacturers to 
request the use of off-cycle technologies that are not recognized in GEM and were not in common use before MY 2010. During the development of the trailer proposal, the agencies were not aware of any technologies that could improve CO
2and fuel consumption 
performance that would not be captured in the trailer test protocols, and we did not propose a process to evaluate off- cycle trailer technologies. We continue to believe that effective trailer aerodynamic technologies that would not be captured by the test protocols are unlikely to emerge. However, Wabash provided comments requesting a process for evaluating future trailer weight reduction options. They suggested that these options could include lightweight components that are not listed in our regulations as approved material substitution components, or overall trailer weight reduction strategies that are not limited to individual components. 
In light of these comments and further 
consideration of the issue, the agencies believe that the off-cycle technology process is an appropriate way for certain box van manufacturers—that is, those using the compliance equation and not subject to the design standards—to receive credit for future lightweighting or other technologies that are not recognized in the compliance equation. For this reason, we have incorporated box vans into the existing off-cycle provisions. In the case of lightweighting, a measured difference in trailer weight could substitute for the weight component of the compliance equation. For other such technologies (should any exist), the general off-cycle provisions apply. See 40 CFR 1037.515(e). 
(e) Small Business Regulatory 
Flexibility Provisions 
As a part of our small business 
obligations under the Regulatory Flexibility Act, EPA and NHTSA have considered additional flexibility provisions aimed at this segment of the trailer manufacturing industry. EPA convened a Small Business Advocacy Review (SBAR) Panel as required by the Small Business Regulatory Enforcement Fairness Act (SBREFA), and much of the information gained and recommendations provided by this process form the basis of the proposed flexibilities.
376As in previous 
rulemakings, our justification for including provisions specific to small businesses is that these entities generally have a greater degree of difficulty in complying with the 
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377In the period between the SBAR Panel and 
Initial Regulatory Flexibility Analysis and issuing 
of the final rule, the Small Business Administration (SBA) finalized new size standards for small business classification. For trailers, the threshold to qualify as small changed from 500 employees to 1000 employees. We have updated our analysis to reflect the new size standards. 
378See Figure 1–3 of Chapter 1 in the RIA 
comparing the 2015 trailer output from the top 28 trailer manufacturers. 379Memorandum to the Docket ‘‘Runspecs, Model 
Inputs, MOVES Code and Database for HD GHG Phase 2 FRM Emissions Modeling.’’. July 2016. See also EPA’s MOVES Web page at https://
www3.epa.gov/otaq/models/moves/index.htm. standards compared to other entities. 
Thus, as discussed below, we are adopting several regulatory flexibility provisions for small trailer manufacturers that we believe will reduce the burden on them while achieving the goals of the program. 
The agencies identified 178 trailer 
and tank manufacturers for our analysis and we believe 147 qualify as small business (i.e., less than 1000 
employees).
377The agencies designed 
many of the program elements and flexibility provisions available to all trailer manufacturers with the large fraction of small business trailer manufacturers in mind. For the small van manufacturers, we believe the option to choose pre-approved aerodynamic data will significantly reduce the compliance burden and 
eliminate the requirement for all manufacturers to perform testing. We are also limiting the final non-box trailer program to tanks, flatbeds, and container chassis. All other non-box trailers are exempt from the Phase 2 trailer program, with no regulatory requirements. This exemption reduces the number of small businesses in the trailer program from 147 to 74 companies at the time of the development of this rulemaking. With no regulatory requirements, these companies have zero burden under the trailer program. We are also adopting the proposed design standards for the remaining non-box trailers, such that they can certify by installing tire technologies only, with no testing requirements. The agencies are also adopting provisions that would increase the number of eligible tire pressure systems that can be installed for compliance. In addition to ATIS, TPMS is a recognized technology in the final rulemaking. Furthermore, the non-box trailers, which have design-based tire standards, comply if they have either a TPMS or an ATIS, and appropriate lower rolling resistance tires. The inclusion of the less expensive TPMS as a tire pressure system option will improve the availability of technologies and reduce the technology cost for many small businesses. 
As noted above, the small trailer 
manufacturers raised concerns that their businesses could be harmed by provisions allowing averaging, banking, and trading of emissions and fuel consumption performance, since they 
will not be able to generate the same volume of credits as large manufacturers. The agencies are not adopting banking and trading provisions in any part of the program, and are limiting the option to average to manufacturers of full-aero dry and refrigerated box trailers and delaying the averaging until MY 2027. Similarly, we are adopting a maximum FEL based on the MY 2018 standard to ensure that larger manufacturers will not be able to produce large volumes of trailers with little or no technologies at the expense of manufacturers that cannot accumulate sufficient over-compliance within their annual production. We expect that the familiarity of the industry, including small business manufacturers, with the trailer program by this stage of the program, and the requirement that all trailers meet at least the MY 2018 level of control, will reduce the concerns of small manufacturer compared to an earlier or broader averaging program. 
For all small business trailer 
manufacturers, the agencies are 
adopting a one-year delay in the beginning of implementation of the program, until MY 2019. We believe that this allows small businesses additional needed lead time to make the necessary staffing adjustments and process changes, and possibly add new infrastructure to meet the requirements of the program. TTMA commented that all trailer manufacturers are ‘‘small businesses’’ relative to other heavy-duty industries and that the one-year delay would divert sales to small businesses for that model year. Wabash argued that providing a flexibility is not required by the RFA and not authorized by the Clean Air Act. The agencies believe that small businesses do not have the same resources available to become familiar with the regulations, make process and staffing changings, or evaluate and market new technologies as their larger counterparts. We believe a one-year delay provides additional time for small businesses to address these issues, without a large CO
2and fuel 
consumption impact or substantial negative competitive effects. The cumulative annual production of all of the small business box trailer manufacturers is estimated to be less than 15 percent of the industry’s total production, which is significantly less than the annual production of the four largest manufacturers.
378We expect any 
diverted sales for this one year will be a small fraction of the large 
manufacturers’ production and we are finalizing the one-year delay for all small business trailer manufacturers. 
Chapter 12 of the RIA presents the 
agencies’ Final Regulatory Flexibility Analysis. In this chapter, we discuss the recommendations of the Panel, what we proposed, and what we finalized for the 
small businesses regulated in Phase 2. We also estimate the economic effect of the rulemaking on these businesses based on their annual revenue. Considering the flexibilities adopted in this rulemaking, our estimate of compliance burden indicates that only 15 of the 147 small trailer manufacturers (about 10 percent) will have an economic impact greater than one percent of their annual revenue. Therefore, we believe the trailer provisions in this rulemaking do not have a significant impact on small businesses. 
V. Class 2b–8 Vocational Vehicles A. Summary of Phase 1 Vocational 
Vehicle Standards 
Class 2b–8 vocational vehicles 
include a wide variety of vehicle types, and serve a wide range of functions. Some examples include service for urban delivery, refuse hauling, utility service, dump, concrete mixing, transit service, shuttle service, school bus, emergency, motor homes, and tow trucks. In the HD Phase 1 Program, the agencies defined Class 2b–8 vocational vehicles as all heavy-duty vehicles that are not included in the Heavy-duty Pickup Truck and Van or the Class 7 and 8 Tractor categories. In effect, the rules classify heavy-duty vehicles that are not a combination tractor or a pickup truck or van as vocational vehicles. Class 2b–8 vocational vehicles and their engines emit approximately 17 percent of the GHG emissions and burn approximately 17 percent of the fuel consumed by today’s heavy-duty truck sector.
379 
Most vocational vehicles are 
produced in a two-stage build process, though some are built from the ‘‘ground up’’ by a single entity. In the two-stage process, the first stage sometimes is completed by a chassis manufacturer that also builds its own proprietary components such as engines or transmissions. This is known as a vertically integrated manufacturer. The first stage can also be completed by a chassis manufacturer who procures all 
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380Specialty Transportation.net, 2012. Truck 
Body Manufacturing in North America. 381See 2013 ICCT Barriers Report, Note 364 
above. 
382See 76 FR 57120. 383See EPA’s regulation at 40 CFR 1037.630 and 
NHTSA’s regulation at 49 CFR 523.2. 
384As noted earlier, NHTSA notes that it has 
greater flexibility in the HD program to include 
consideration of credits and other flexibilities in determining appropriate and feasible levels of stringency than it does in the light-duty CAFE 
program. Cf. 49 U.S.C. 32902(h), which applies to 
light-duty CAFE but not to heavy-duty fuel efficiency under 49 U.S.C. 32902(k). components, including the engine and 
transmission, from separate suppliers. The product completed at the first stage is generally either a stripped chassis, a cowled chassis, or a cab chassis. A stripped chassis may include a steering column, a cowled chassis may include a hood and dashboard, and a cab chassis may include an enclosed driver compartment. Many of the same companies that build Class 7 and 8 tractors also sell vocational chassis in the medium heavy- and heavy heavy- duty weight classes. Similarly, some of the companies that build Class 2b and 3 pickups and vans also sell vocational chassis in the light heavy-duty weight classes. 
The second stage is typically 
completed by a final stage manufacturer or body builder, which installs the primary load carrying device or other work-related equipment, such as a dump bed, delivery box, or utility boom. There are over 200 final stage manufacturers in the U.S., most of which are small businesses. Even the large final stage manufacturers are specialized, producing a narrow range of vehicle body types. These businesses also tend to be small volume producers. In 2011, the top four producers of truck bodies sold a total of 64,000 units, 
which is about 31 percent of sales in that year.
380In that same year, 74 
percent of final stage manufacturers produced less than 500 units. 
The businesses that act both as the 
chassis manufacturer and the final stage manufacturer are those that build the vehicles from the ‘‘ground up.’’ These entities generally produce custom products that are sold in lower volumes than those produced in large commercial processes. Examples of vehicles produced with this build process include fire apparatus and transit buses. 
The diversity in the vocational 
vehicle segment can be primarily attributed to the variety of customer needs for specialized vehicle bodies and added equipment, rather than to the chassis. For example, a body builder can build either a Class 6 bucket truck or a Class 6 delivery truck from the same Class 6 chassis. The aerodynamic difference between these two vehicles due to their bodies leads to different in- use fuel consumption and GHG emissions. However, the baseline fuel consumption and emissions due to the components included in the common chassis (such as the engine, drivetrain, frame, and tires) may be the same between these two types of vehicles. Owners of vocational vehicles that are 
upfitted with high-priced bodies that are 
purpose-built for particular applications tend to keep them longer, on average, than owners of vehicles such as pickups, vans, and tractors, which are traded in broad markets that include many potential secondary markets. The fact that vocational vehicles also generally accumulate far fewer annual miles than tractors further contributes to lengthy trade cycles among owners of these vehicles. To the extent vocational vehicle owners may be similar to 
owners of tractors in terms of business profiles, they are more likely to resemble private fleets or owner- operators than for-hire fleets. A 2013 survey conducted by NACFE found that the trade cycle of private tractor fleets ranged from seven to 12 years.
381 
The Phase 1 standards for this 
vocational vehicle category generally apply at the chassis manufacturer level. For the same reasons given in Phase 1, the agencies are applying the Phase 2 vocational vehicle standards at the chassis manufacturer level.
382 
The Phase 1 regulations prohibit the 
introduction into commerce of any heavy-duty vehicle without a valid certificate or exemption. 40 CFR 1037.622, originally codified as 40 CFR 1037.620, allows for a temporary exemption for the chassis manufacturer if it produces the chassis for a secondary manufacturer that holds a certificate. The agencies received several comments on the requirements for secondary manufacturers. A discussion of temporary exemptions and obligations of secondary manufacturers can be found in Section V.D.(2). 
In Phase 1, the agencies adopted two 
equivalent sets of standards for Class 2b–8 vocational vehicles. For vehicle- level (chassis) emissions, EPA adopted CO
2standards expressed in grams per 
ton-mile. For fuel efficiency, NHTSA adopted fuel consumption standards expressed in gallons per 1,000 ton- miles. The Phase 1 engine-based standards vary based on the expected weight class and usage of the vehicle into which the engine will be installed. We adopted Phase 1 vehicle-based standards that vary according to one key attribute, GVWR, based on the same groupings of vehicle weight classes used for the engine standards—light heavy- duty (LHD, Class 2b–5), medium heavy- duty (MHD, Class 6–7), and heavy heavy-duty (HHD, Class 8). 
In Phase 1, the agencies defined a 
special regulatory category called vocational tractor, which generally 
operate more like vocational vehicles than line haul tractors.
383As described 
above in Section III.C.4, under the Phase 1 rules, a vocational tractor is certified under standards for vocational vehicles, not those for tractors. In Phase 2, the agencies are revising the vocational tractor definition to remove heavy-haul tractors, as we are adopting tractor standards for these. The agencies received many comments pertaining to vocational tractors, which are described in Section III.C.4 and Section V.B. 
Manufacturers are required to use 
GEM to determine compliance with the Phase 1 vocational vehicle standards, where the primary vocational vehicle manufacturer-generated input is the measure of tire rolling resistance. The GEM assumes the use of a typical representative, compliant engine in the simulation, resulting in one overall value for CO
2emissions and one for fuel 
consumption. The manufacturers of engines intended for use in vocational vehicles are subject to separate Phase 1 engine-based standards. Manufacturers also may demonstrate compliance with the CO
2standards in whole or in part 
using credits reflecting CO 2reductions 
resulting from technologies not reflected in the GEM testing regime. See 40 CFR 1037.610. 
In Phase 1, EPA and NHTSA also 
adopted provisions designed to give manufacturers a degree of flexibility in complying with the standards. Most significantly, we adopted an ABT program to allow manufacturers to comply on average within a given averaging set. See 40 CFR part 1037, subpart H. These provisions enabled the agencies to adopt overall standards that are more stringent than we could have considered with a less flexible program.
384 
B. Phase 2 Standards for Vocational Vehicles 
Since proposal, in addition to 
considering substantive written public comments, the agencies have held dozens of meetings with manufacturers, suppliers, non-governmental organizations (NGOs), and other stakeholders to better understand the opportunities and challenges involved with regulating vocational vehicles. These meetings have helped us to better 
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385See Chapter 1 of the RIA. 
386See Dana Spicer Drive Axle Application 
Guidelines, available at http://www.dana.com/wps/ 
wcm/connect/133007004bd8422b9ea8be14e7
b6dae0/DEXT-daag2012 _0712_ DriveAxles
AppGuide_ LR.pdf?MOD=AJPERES&CONVERT_
TO=url&CACHEID=133007004bd8422b9
ea8be14e7b6dae0. See also ZF Driveline and Chassis Technology brochure, available at http://www.zf.com/media/media/en/document/corporate _
2/downloads_ 1/flyer_ and_ brochures/bus_ driveline_
technology_ flyer/Busbroschuere _12_DE_final.pdf. 387National Renewable Energy Laboratory July 
2016, ‘‘The Development of Vocational Vehicle Drive Cycles and Segmentation,’’ NREL/TP–5400– 65921. 
388While drive idle can generally be thought of 
as in-gear and parked idle can generally be thought of as out-of-gear, NREL has data on driving patterns for trucks with manual transmissions and has considered the fact that these are always out of gear when the vehicle has zero speed. See Section 5.5 of the final NREL report for more details. 389See memorandum dated July 2016 titled, 
‘‘NREL Bi-Modal Vocational Vehicle Cluster 
Information.’’ 
390See memorandum dated July 2016 titled, 
‘‘Summary of Late Comments on Vocational Transmissions and N/V.’’ develop final Phase 2 standards. As an 
example, we have updated our industry characterization to better describe the vocational vehicle market, including the custom chassis manufacturers.
385We 
believe these information exchanges have enabled us to develop these rules with an appropriate balance of achievable reductions at reasonable cost with a reasonably small risk of unintended consequences. 
(1) Final Subcategories and Test Cycles 
The Phase 2 vocational vehicle 
standards are based on the performance 
of a wider array of control technologies than the Phase 1 rules. In particular, as proposed, the Phase 2 vocational vehicle standards recognize detailed characteristics of powertrains and drivelines. As described below, driveline improvements present a significant opportunity for reducing fuel consumption and CO
2emissions from 
vocational vehicles. However, there is no single package of driveline technologies that will be equally suitable for the majority of vocational vehicles, because there is an extremely broad range of driveline configurations available in the market. This is due in part to the variety of build processes, ranging from a purpose built custom chassis to a commercial chassis that may be intended as a multi-purpose stock vehicle. Further, the wide range of applications and driving patterns of these vehicles leads manufacturers to offer a variety of drivelines, as each performs differently in use. For example, depending on whether the transmission has an overdrive gear, drive axle ratios for Class 7 and 8 tractors can generally be found in the range of 2.5:1 to 4.1:1. By contrast, across all types of vocational vehicles, drive axle ratios can range from 3.1:1 (delivery vehicle) to 9.8:1 (transit bus).
386Other components of the 
driveline also have a broader range of 
product in vocational vehicles than in tractors, including transmission gears, tire sizes, and engine speeds. Each of these design features affects the GHG emission rate and fuel consumption of the vehicle. It therefore is reasonable to define more than one baseline configuration of vocational vehicle, to encompass a range of drivelines. A detailed list of the technologies the agencies project could be adopted to meet the vocational vehicle standards is described in Section V.C, and in the RIA Chapter 2.9, along with a description of the differences in technology effectiveness that are projected to be demonstrated through GEM under different test cycles. The agencies have found that the ranges of effectiveness of a majority of the technologies are significant enough to merit creation of subcategories with different test cycles. 
(a) Basis for Duty Cycles and 
Subcategories 
The agencies are relying on work 
conducted by the U.S. Department of Energy at the National Renewable Energy Laboratory (NREL), as well as duty cycle information provided in public comments, in establishing the weighting factors for the test cycles to be used in the certification of heavy-duty vocational vehicles to the final Phase 2 standards. NREL’s methodology and findings are described in a report in the docket for this rulemaking.
387The data 
from NREL have also informed our segmentation process, and to some extent the technology assessment. For example, without data regarding the amount of parked idle observed by vocational vehicles in the NREL database, we would not have been able to sufficiently identify and recognize technologies that separately reduce either drive idle or parked idle emissions.
388Based on available fleet 
data, NREL identified three general clusters of vehicle behavior: one cluster of vehicles most often driving with slower speeds and frequent stops; one with higher average speeds and fewer stops; and one multi-modal cluster with vehicles that may operate similarly to either of the other clusters on any given day. In Chapter 2.2 of the NREL report, an alternate bi-modal clustering analysis is also presented, where instead of having a distinct middle cluster, vehicles with highly variable driving patterns are grouped as either high speed or low speed. A preliminary update provided by NREL includes cycle weightings that correspond with this two cluster depiction of vehicle behavior.
389Based on the NREL report 
and other information, the agencies 
believe it is appropriate to finalize a regulatory subcategory structure that includes a drive cycle appropriate for mixed use vehicles; especially considering that the ultimate application of incomplete chassis is unknown at the time of certification. In other words, we are adopting a program structure that follows NREL’s three cluster depiction of vehicle behavior. The final rules’ primary vocational standards thus have subcategories for Regional, Multi-purpose, and Urban drive cycles in each of the three weight classes (LHD, MHD and HHD), which results in nine unique subcategories. 
In the final weeks before 
promulgation, the agencies received significant new comments from a number of vehicle manufacturers, along with new data characterizing in detail the distribution of powertrain configurations of their vehicles.
390 
These recent comments suggested some uncertainty with respect to the three drive cycle structure, and the manufacturers expressed related concerns regarding assumptions about transmissions in our baseline vehicle configurations, which they believe could result in some OEMs being put at competitive disadvantage. The agencies appreciate these new comments and data; however, we determined that it would not be appropriate to alter this regulatory action so late in the rulemaking process based solely upon this newly submitted information, which was not made available for broader public comment. Instead, the agencies will continue to analyze this new information and any other new information we receive. We will also continue to actively engage with manufacturers and other stakeholders to determine if future revisions to the vocational vehicle program structure are warranted, based on this and any other new information. For example, it is possible that further analysis of new data could lead us to consider proposing amendments to adopt the two cluster approach for one or more of the vehicle weight classes, or to consider amending the regulatory constraints limiting the choice of drive cycle subcategory that we are adopting to prevent potential adverse impacts of vehicle misclassification. However, at this time the final program structure, including these constraints, will remain in place 
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391MOVES 2014. See Note 379 above. 392National Renewable Energy Laboratory July 
2016, ‘‘The Development of Vocational Vehicle Drive Cycles and Segmentation,’’ NREL/TP–5400– 
65921. unless and until the agencies determine 
that revisions to the vocational vehicle program structure are warranted, in which case the agencies would undertake a notice and comment rulemaking proposing to amend the programmatic structure, consistent with such a determination. In considering whether to undertake further action, the agencies will necessarily be mindful of statutory lead time requirements and other practical considerations. 
NREL also synthesized a new 
transient test cycle using statistical targets and the DRIVE tool. Eaton commented that the new transient cycle developed by NREL is similar to cycles they use to calibrate shift controls, and is more representative of how trucks are driven than the current ARB Transient 
certification test cycle. Although there is some reason to believe this new cycle may actually be more representative of nationwide operation than the ARB transient cycle, the agencies recognize that sufficient uncertainty remains that we are not prepared to adopt this new NREL transient cycle for Phase 2 certification at this time. The agencies also note that, although GEM has been extensively validated for the ARB transient cycle, we have not conducted a similar validation for the NREL cycle. Nevertheless, we will continue to evaluate this cycle and may reconsider it as part of a future rulemaking. The most significant shortfall identified by NREL in their comparison of real world vocational vehicle operation and the ARB transient cycle is a gap in measurement points between speeds of 48 and 55 mph. We have remedied this shortfall by adjusting the composite weighting factor of the 55 mph cruise cycle. Because vehicles tested in GEM over our final road grade profile have been observed to decrease speed well below 55 mph during this cycle, those measurement points that are absent from the ARB transient cycle are captured in the nominally 55 mph test cycle. 
Other commenters questioned 
whether the vehicles from which NREL collected data for the cycle were sufficiently representative, or whether 
sufficient data existed to justify the NREL weightings, while other commenters supported use of the data. Daimler supported making changes to reflect the NREL-recommended weightings to align with real-world data. ACEEE supported using the more realistic NREL cycle weightings to revisit stringency where certain technologies may be more effective over the new cycles. Both Volvo and Navistar expressed concerns that the NREL study fleet doesn’t appear to be representative. Navistar believes that the NREL data has too few refuse trucks, and Volvo believes that the NREL data has too few class 8 vehicles. In fact, 35 percent of the vehicles in the NREL database that were evaluated for the drive cycle analysis are class 8, which we believe is (if anything) over-representative of the 
percent of new HHD vehicles manufactured each year. Because the full NREL database also contains over five percent refuse trucks and our MOVES model estimates that refuse 
trucks comprise only three percent of newly manufactured vocational vehicles each year, we directed NREL to remove excess refuse trucks from their final analysis, to avoid skewing the data by over-representing refuse trucks.
391A 
similar process was followed for removing excess school buses and transit buses. More details are available in the NREL report.
392While some 
discrepancies may remain between the NREL vehicle distribution and the national fleet, we are confident they are sufficiently small to allow us to use this report to establish weighting factors for different types of operation. Moreover, the agencies believe the more relevant question to be whether or not the cycles exercise the technologies over enough of the range of in-use operation to effect in- use reductions, and to reasonably estimate the extent of those reductions. In this context, the weighting factors and duty-cycles are fully adequate. 
After considering all the comments, 
the agencies are establishing nine subcategories of vocational vehicles in Phase 2, based on the three weight class groups of vocational vehicles described 
above that are continuing from the Phase 1 program, plus Regional, Multipurpose and Urban duty cycle groups, as shown in Table V–1 below. For reasons described below in Section V.C.(2)(a) we are not establishing distinct subcategories for SI-powered vocational vehicles in the HHD weight class. Thus, with nine diesel subcategories and six gasoline subcategories, we are essentially setting 15 separate numerical performance standards. As described in Section V.B.2, we are also adopting optional standards for seven subcategories of custom vocational chassis. 
This structure enables the 
technologies that perform best at highway speeds and those that perform best in urban driving to each be properly recognized over appropriate drive cycles, while avoiding unintended results of forcing vocational vehicles that are designed to serve in different applications to be measured against a single drive cycle. The agencies intend for these three drive cycles to balance the competing pressures to recognize the varying performance of technologies, serve the wide range of customer needs, and maintain reasonable regulatory simplicity. In light of the very recent comments noted above, if the agencies were to determine in the future that revisions to the 
vocational vehicle program structure are warranted, we would intend to propose any revisions in a way that would be consistent with the technology feasibility and cost-benefit analyses of this final rulemaking. In other words, the agencies do not anticipate any changes to the technology basis for, or the effective stringency of, the final standards. Rather, potential changes in program structure would only be to better assure that the projected reductions are achieved in use, consistent with the projected technology packages on whose performance the stringency of the final standards are based, and consistent with the costs we projected for that compliance pathway. 
TABLE V–1—R EGULATORY SUBCATEGORIES FOR VOCATIONAL VEHICLES  
Weight class Light heavy-duty 
class 2b–5 Medium heavy-duty class 6–7 Heavy heavy-duty 
class 8 (CI only) 
Duty Cycle ..................................... Regional ........................................ Regional ........................ ................ Regional. 
Multi-Purpose ................................ Multi-Purpose ................................ Multi-Purpose. 
Urban ............................................ Urban ............................................ Urban. 
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In the NREL Fleet DNA clustering 
analysis, the medioid of each cluster 
was characterized using eight drive cycle metrics, and distance histograms were created for each statistically representative vehicle. By summing the miles accumulated at different driving speeds (including zero speed idle), NREL was able to recommend composite cycle weightings. Commenters suggested that the proposed weightings of both highway cruise and idle were too low for some vehicles. When the agencies released additional data for comment in February 2016, an early draft of NREL’s duty cycle report was included. Most commenters supported the draft NREL duty cycles. Volvo commented that NREL’s cycle weightings didn’t match their extensive telematics database for their class 8 vocational vehicles, and recommended specific changes to increase the weighting of 65 mph for Urban and Multipurpose HHD vehicles. A description of the drive cycle data submitted to the agencies by Volvo in support of the final test cycles is found in the RIA Chapter 3.4.3.1. In response, we have adjusted our composite test weightings for Urban and Multipurpose HHD vehicles in consideration of Volvo’s data. Although Volvo also suggested specific cycle weightings for coach buses, we have established optional coach bus standards (one example of the custom chassis standards the agencies are adopting) with the same weightings as for other Regional vehicles for reasons described below in V.B.2.b. The final cycle weightings shown in Table V–2 reflect NREL’s recommendations along with consideration of public comments. Although both NREL and Volvo data showed vehicles whose behavior would logically be classified as Urban accumulating some miles (from one to seven percent) in the 65 mph range, the agencies are applying a zero weighting factor to the 65 mph cycle for all Urban vehicles for certification purposes. Instead, those miles are assigned to the 55 mph cycle. We believe it is important to have a test cycle available in the primary program for vehicles that may regularly drive on urban or local highways, but are not expected (or designed) to drive on rural highways. Further, the final rules include the refinement of a split idle cycle (parked idle and drive idle), since NREL’s final report includes analysis of data characterizing the percent of time in a work day that vocational vehicles idle when parked as distinct from idling time when stopped in traffic. More details on the characterization of parked and drive idle are found in the RIA Chapter 2.9.3.4. More details of the NREL clustering analysis are found in the RIA Chapter 2.9.2, and more details on the data behind the final composite cycle weightings are found in the RIA Chapter 3.4.3. 
TABLE V–2—C OMPOSITE TESTCYCLE WEIGHTINGS (INPERCENT ) FORVOCATIONAL VEHICLES  
ARB transient 55 mph 
Cruise with 
road gradea 65 mph 
Cruise with 
road gradea Parked idle Drive idle 
Regional ............................................................................... 0.20 0.24 0.56 0.25 0.00 
Multi-Purpose (2b–7) ........................................................... 0.54 0.29 0.17 0.25 0.17 
Multi-Purpose (class 8) ........................................................ 0.54 0.23 0.23 0.25 0.17 
Urban (2b–7) ........................................................................ 0.92 0.08 0.00 0.25 0.15 
Urban (class 8) .................................................................... 0.90 0.10 0.00 0.25 0.15 
Note: 
aAs described in Section II, the agencies have adopted highway cruise test cycles with revised road grade profiles. 
We recognize that by adopting a few 
meaningful duty cycles that ‘‘bound’’ 
how vocational vehicles are generally 
used, we cannot perfectly match how every vocational vehicle is actually used. There are a few vehicle applications we have identified, for which these general cycles are likely to be poorly representative. We received several comments that our proposed duty cycles are particularly unrepresentative of real world behavior of transit buses and refuse trucks, for example. These vehicles also generally have chassis characteristics unlike those in the reference GEM vehicles used to establish the subcategory baselines. The agencies have determined that it is impractical, from a regulatory perspective, to establish separate, unique test cycles for transit buses or refuse trucks. In considering the challenges of such an undertaking, as well as the market structure of manufacturers who produce such vehicles, the agencies are instead adopting separate standards for transit buses and refuse trucks as part of the final Phase 2 program for custom 
vocational chassis, as described in Section V.B.(2)(b). 
Vocational vehicles neither qualifying 
under the optional custom chassis program nor meeting eligibility for exemption as low speed/off road vehicles will need to be certified in one of the primary subcategories established in this rulemaking. Below in Section V.C, the agencies explain the technology basis supporting the standards for each vehicle weight class. 
The agencies received extensive 
comment on how to define attributes of vehicles in each subcategory to provide regulatory certainty to manufacturers. The proposed approach was to set criteria by which a vehicle manufacturer would know in which vocational subcategory—Regional, Urban, or Multipurpose—the vehicle should be certified, by use of cut-points defined using calculations relating engine speed to vehicle speed. Two commenters suggested we reinstate the Phase 1 approach with a one-size-fits-all drive cycle. Six commenters agreed with the proposed approach on 
subcategorization, though some recommended slight adjustments. The 
final rules allow manufacturers to generally choose the subcategory of each vocational chassis, with a revised set of constraints essentially reflecting types of equipment on the vehicle (especially transmission type). In Section V.C.(2)(a) and the RIA Chapter 2.9, we describe changes since proposal with respect to the baseline vehicle configurations. In Section V.C.(2)(d), we describe the changes since proposal reflecting use of fleet average sales mixes in the standard-setting process. In Section V.D.(1)(e), we describe the constraints we are adopting regarding selection of subcategories by manufacturers. Taken together, these analyses demonstrate why we are confident that even if (generally against its own interests) a manufacturer chooses to certify a vehicle over a less appropriate test cycle, that choice would not result in a loss of environmental benefit. Continuing the averaging scheme from Phase 1, each manufacturer will 
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393Comparing the vocational Regional duty cycle 
to the day cab tractor duty cycle, vocational 
Regionals have one percent greater weighting of the ARB Transient, 6 percent more weighting of the 55 cycle, 8 percent less weighting of the 65 cycle, plus 25 percent parked idle. 
394See call log for L. Steele, conversation with M. 
Miller, dated January 18, 2016. generally be able to average within each 
vehicle weight class (i.e. averaging sets 
are not further limited by the Regional, Multi-purpose, Urban subcategorization). 
(b) Vocational Tractors 
As discussed in Section V.A., the 
Phase 1 program includes a special 
regulatory category called vocational tractors, which covers vehicles that are technically tractors but generally operate more like vocational vehicles than line haul tractors. Heavy-haul, off- road, and certain intra-city delivery tractors are eligible for this category in the Phase 1 program, but manufacturers may also choose to certify them as conventional tractors. The agencies proposed to keep this program in Phase 2, but to exclude heavy-haul tractors. With the removal of heavy-haul tractors from the vocational tractor definition (see 40 CFR 1037.630 and 49 CFR 523.2), the agencies have re-assessed the vehicles remaining in this group, and the most appropriate way for them to be certified. One typically thinks of beverage tractors in this group, though it may also include drayage tractors, vehicle carriers, construction vehicles, and many vehicles with unusual axle configurations. NREL observed drayage tractors with operational patterns consistent with the Regional duty cycle.
393Volvo also commented that 
their vocational tractors would logically fall in the Regional duty cycle. The agencies have therefore concluded that these vehicles may reasonably be represented by our final regulatory duty cycles, and are requiring that vocational tractors not meeting other exemption criteria must use one of the vocational vehicle duty cycles. 
There is a separate question of 
whether vocational tractors may have their performance fairly measured against the agencies’ defined baseline vocational configurations. The agencies requested comment on whether vocational tractors would be deficit- 
generating vehicles if certified in the proposed vocational vehicle subcategories. When a vehicle is designed with a higher power engine or higher number of axles to carry a heavier payload than presumed in the GEM baseline for that subcategory, GEM may return a value that poorly represents the real world performance of that vehicle. We received comments from the chassis manufacturers who certify vocational tractors, plus two 
other comments. These comments consistently asked the agencies to allow some tractors with GVWR over 120,000 lbs but not qualifying as heavy-haul tractors to remain as vocational vehicles rather than be forced to certify to the primary tractor standards. Volvo submitted written comments stating that a separate regulatory subcategory with unique performance standard is warranted for vocational tractors. However, during a subsequent telephone conversation, Volvo stated that their vocational tractors would be adequately represented by the other defined subcategories, and a unique subcategory was not necessary.
394See 
Section III.C.(4). for a discussion of the attributes adopted by the agencies as distinguishing vocational tractors from regular or heavy-haul tractors. 
Based on comments and our technical 
analysis, the agencies have concluded that the technologies determined to be feasible for regular vocational vehicles are also feasible for vocational tractors, with similar adoption rates and package costs. Further, we are not aware of any 
non-diversified chassis manufacturers producing vocational tractors. One implication is that we believe that all manufacturers certifying vocational tractors will be able to take advantage of our ABT program flexibilities. According to MY 2014 certification data, less than 14,000 vocational tractors were certified between the three manufacturers, including an unidentifiable number that would likely qualify as heavy-haul tractors, if that definition existed in Phase 1. Thus, possible deficits (if any) generated by the small sales volume of vocational tractors in Phase 2 could likely be accommodated within each company’s overall compliance plan. 
(2) GHG and Fuel Consumption 
Standards for Vocational Vehicles 
EPA is adopting CO
2standards and 
NHTSA is adopting fuel consumption standards for manufacturers of chassis for new vocational vehicles. As described in Sections II.C.(1) and II.D.(1) above, the agencies are adopting test procedures so that engine performance will be evaluated within the GEM simulation tool. These test procedures include corrections for the test fuel, enabling vocational vehicles to be certified with many different types of CI and SI engines. In addition, EPA is establishing HFC leakage standards for air conditioning systems in vocational vehicles, as described in Section V.B.(2)(c), with more details available in the RIA Chapter 2.9.3.8 and Chapter 5.3.4. 
This section describes the standards 
and implementation dates that the agencies are adopting for the 15 regulatory subcategories of vocational vehicles, plus the optional standards for the seven custom vocational chassis categories. The agencies have performed a technology analysis to determine the level of standards that we believe will be available at reasonable cost, cost- effective, technologically feasible, and appropriate in the lead time provided. More details of this analysis are described in the RIA Chapter 2.9. This analysis considered the following for each of the regulatory subcategories: 
•The level of technology that is 
incorporated in current new vehicles, 
•forecasts of manufacturers’ product 
redesign schedules, 
•the available data on CO
2emissions 
and fuel consumption for these vehicles, 
•technologies that will reduce CO 2 
emissions and fuel consumption and that are judged to be feasible and appropriate for these vehicles through the 2027 model year, 
•the effectiveness and cost of these 
technologies, 
•a projection of the technologically 
feasible application rates of these technologies, in this time frame, and 
•projections of future U.S. sales for 
different types of vehicles and engines. 
The final Phase 2 program described 
here and throughout the rulemaking documents is derived from the preferred alternative, referred to as Alternative 3 in the NPRM. 
(a) Primary Fuel Consumption and CO
2 
Standards 
The agencies’ final standards will 
phase in over a period of seven years, 
beginning in the 2021 model year, consistent with the requirement in EISA that NHTSA’s standards provide four full model years of regulatory lead time and three full model years of regulatory stability, and provide sufficient time ‘‘to permit the development and application of the requisite technology’’ for purposes of CAA section 202(a)(2). The Phase 2 program will progress in three- year stages with an intermediate set of standards in MY 2024 and will continue to reduce fuel consumption and CO
2 
emissions well beyond the full implementation year of MY 2027. The agencies have identified a technology path for each of these levels of improvement, as described below. 
Combining engine and vehicle 
technologies, vocational vehicles powered by CI engines are projected to achieve improvements as much as 24 
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395NHTSA is unable to adopt mandatory 
amended standards in those model years since there 
will be less than the statutorily-prescribed amount of lead time available. 49 U.S.C. 32902(k)(3)(A). percent in MY 2027 over the MY 2017 
baseline, as described below and in the RIA Chapter 2.9. The agencies project up to 18 percent improvement in fuel consumption and CO
2emissions in MY 
2027 from SI-powered vocational vehicles, as shown in Table V–3. The incremental Phase 2 vocational vehicle standards will ensure steady progress toward the MY 2027 standards, with improvements for CI-powered vehicles in MY 2021 of up to 12 percent and improvements for CI-powered vehicles in MY 2024 of up to 20 percent over the MY 2017 baseline vehicles, as shown in Table V–3. 
The agencies’ analyses, as discussed 
in this Preamble and in the RIA Chapter 2, show that these standards are appropriate under each agency’s respective statutory authority. 
TABLE V–3—P ROJECTED VOCATIONAL VEHICLE CO 2ANDFUELUSEREDUCTIONS (INPERCENT ) FROM 2017 B ASELINE  
Model year Engine type Heavy 
heavy-duty 
Class 8 Medium 
heavy-duty 
Class 6–7 Light 
heavy-duty 
Class 2b–5 
2021 ....................................... CI Engine ........................................................................... ..... 7–9 6–11 7–12 
SI Engine ................................................................................ ........................ 5–7 6–8 
2024 ....................................... CI Engine ........................................................................... ..... 12–16 11–18 11–20 
SI Engine ................................................................................ ........................ 9–12 9–14 
2027 ....................................... CI Engine ........................................................................... ..... 14–20 12–22 13–24 
SI Engine ................................................................................ ........................ 10–16 11–18 
Based on our analysis and research, 
and our consideration of the public 
comments, the agencies conclude that the improvements in vocational vehicle fuel consumption and CO
2emissions 
can be achieved through deployment and utilization of a greater set of technologies than formed the technology basis for the Phase 1 standards. Further, since proposal, our assessment of technology effectiveness has changed primarily due to revisions in duty cycles and in some cases, the technologies themselves. The agencies received comments addressing the vocational vehicle standards broadly, including baselines, structure, and technologies. In response, in developing the final standards, the agencies have reevaluated the current levels of fuel consumption and emissions, the kinds of technologies that could be utilized by manufacturers to reduce fuel consumption and emissions, the associated lead time, the associated costs for the industry, fuel savings for the owner/operator, and the magnitude of the CO
2reductions and fuel savings 
that may be achieved. After reexamining the possibilities of vehicle improvements, the agencies are basing the final standards on the performance of workday idle reduction technologies, improved transmissions including mild hybrid powertrains, axle technologies, weight reduction, electrified accessories, tire pressure systems, and further tire rolling resistance improvements. The EPA-only air 
conditioning standard is based on leakage improvements. These are largely the same technologies as we considered for the proposal, although some technologies that had been available only to tractors at proposal are now recognized for vocational vehicles. Our updated analysis shows that more stringent standards than proposed are feasible, based in large part on our new assessment of the effectiveness of workday idle controls. 
The agencies’ evaluation indicates 
that some of the above vehicle technologies are commercially available today, though often in limited volumes. Other technologies will need additional time for development. Those that we believe are available today and may be adopted to a limited extent in some vehicles include improved tire rolling resistance, weight reduction, some types of conventional transmission improvements, neutral idle, and air conditioning leakage improvements. However, the first model year for the final Phase 2 standards will not be until MY 2021.
395As at proposal, the EPA 
continues to believe that any potential benefits that could be achieved by implementing rules requiring some technologies on vocational vehicles earlier than MY 2021 to be outweighed by several disadvantages. For one, manufacturers will need lead time to develop compliance tracking tools. Also, if the Phase 2 vocational vehicle standards began in a different year than the tractor standards, this could create unnecessary added complexity, and could strongly detract from the fuel savings and GHG emission reductions that could otherwise be achieved. Therefore the Phase 1 standards will continue to apply in model years 2018 to 2020. No commenter suggested otherwise. 
Vehicle technologies that we expect 
will be available in the near term include neutral idle, low rolling resistance tires, improved axle efficiency, and part-time 6x2 axles. 
Vehicle technologies that we have determined will benefit from even more development time to integrate engine and vehicle systems include stop-start idle reduction and hybrid powertrains. The agencies have analyzed the 
technological feasibility of achieving the fuel consumption and CO
2standards, 
based on projections of what actions manufacturers may be expected to take to reduce fuel consumption and emissions to achieve the standards, and believe that the standards are technologically feasible throughout the regulatory useful life of the program. The basis for this finding is discussed below in Section V.C.3. EPA and NHTSA estimated vehicle package costs are found in Section V.C.(2). 
Table V–4 and Table V–5 present 
EPA’s CO
2standards and NHTSA’s fuel 
consumption standards, respectively, for chassis manufacturers of Class 2b through Class 8 vocational vehicles for the beginning model year of the program, MY 2021. As in Phase 1, the standards are in the form of the mass of emissions, or gallons of fuel, associated with carrying a ton of cargo over a fixed distance. The EPA standards are measured in units of grams CO
2per ton- 
mile and the NHTSA standards are in gallons of fuel per 1,000 ton-miles. With the mass of freight in the denominator of this term, the program is designed to measure improved efficiency in terms of freight efficiency. As in Phase 1, the Phase 2 program assigns a fixed default payload in GEM for each vehicle weight class group (heavy heavy-duty, medium heavy-duty, and light heavy-duty). Even though this simplification does not allow individual vehicle freight efficiencies to be recognized, the general capacity for larger vehicles to carry more payload is represented in the 
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numerical values of these standards for 
each weight class group. 
For each model year of the standards 
described below, the standards for vehicles powered by CI engines reflect improvements that correspond with performance of technologies projected to meet the separate CI engine standard in that year, as modeled over the GEM vehicle cycles. In other words, the CI 
vehicle standard directly reflects, and keeps pace with, the increasing stringency of the CI engine standard. As described above in Section II.D, the SI engine standard is remaining unchanged from Phase 1. However, the standards in each model year for vocational vehicles powered by SI engines are based in part on the performance of some additional engine technologies beyond what is required to meet the SI engine standards. In other words, certain SI engine improvements are reflected in the stringency of the SI vehicle standard. 
EPA’s vocational vehicle CO
2 
standards and NHTSA’s fuel consumption standards for the MY 2024 
stage of the program are presented in Table V–6 and Table V–7, respectively. These reflect broader adoption rates of vehicle technologies already considered in the technology basis for the MY 2021 standards. EPA’s vocational vehicle CO
2 
standards and NHTSA’s fuel consumption standards for the full implementation year of MY 2027 are presented in Table V–8 and Table V–9, respectively. These reflect even greater adoption rates of the same vehicle technologies considered as the basis for the previous stages of the Phase 2 standards. 
These standards are based on highway 
cruise cycles that include a final road 
grade profile that has been refined as a result of comment. This enables the standard and the GEM certification results to better reflect real world driving and to help recognize engine and driveline technologies while seeking to assure that technologies result in real world benefit. See the RIA Chapter 3.4.2.1. As described in Section I, the agencies 
are continuing the Phase 1 approach to 
averaging, banking and trading (ABT), allowing ABT within vehicle weight classes. For Phase 2, continuing this approach means allowing averaging between CI-powered vehicles and SI- powered vehicles of any subcategory belonging to the same weight class group, which have the same regulatory useful life. However these averaging sets exclude vehicles certified to the separate custom chassis standards. Although we are further subdividing each vocational weight class group into Urban, Multi-Purpose, and Regional subcategories, we are not restricting credit exchanges between them. This is similar to the allowance to trade between vocational vehicles and tractors within a weight class. It is also consistent with the Phase 1 program, where the different types of vehicles within a weight class were included in a single averaging set. 
TABLE V–4—EPA CO 2STANDARDS FOR MY 2021 C LASS 2b–8 V OCATIONAL VEHICLES  
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 Heavy 
heavy-duty 
Class 8 
EPA Standard for Vehicle with CI Engine Effective MY 2021 (gram CO 2/ton-mile) 
Urban .......................................................................................................................... ........... 424 296 308 
Multi-Purpose .................................................................................................................. ....... 373 265 261 
Regional ....................................................................................................................... .......... 311 234 205 
EPA Standard for Vehicle with SI Engine Effective MY 2021 (gram CO 2/ton-mile) 
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 
(and C8 
gasoline) 
Urban .......................................................................................................................... ........... 461 328 
Multi-Purpose .................................................................................................................. ....... 407 293 
Regional ....................................................................................................................... .......... 335 261 
TABLE V–5—NHTSA F UELCONSUMPTION STANDARDS FOR MY 2021 C LASS 2b–8 V OCATIONAL VEHICLES  
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 Heavy 
heavy-duty 
Class 8 
NHTSA Standard for Vehicle with CI Engine Effective MY 2021 (Fuel Consumption gallon per 1,000 ton-mile) 
Urban .......................................................................................................................... ........... 41.6503 29.0766 30.2554 
Multi-Purpose .................................................................................................................. ....... 36.6405 26.0314 25.6385 
Regional ....................................................................................................................... .......... 30.5501 22.9862 20.1375 
NHTSA Standard for Vehicle with SI Engine Effective MY 2021 (Fuel Consumption gallon per 1,000 ton-mile) 
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 
(and C8 
gasoline) 
Urban .......................................................................................................................... ........... 51.8735 36.9078 
Multi-Purpose .................................................................................................................. ....... 45.7972 32.9695 
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TABLE V–5—NHTSA F UELCONSUMPTION STANDARDS FOR MY 2021 C LASS 2b–8 V OCATIONAL VEHICLES —Continued 
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 Heavy 
heavy-duty 
Class 8 
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 
(and C8 
gasoline) 
Regional ....................................................................................................................... .......... 37.6955 29.3687 
TABLE V–6—EPA CO 2STANDARDS FOR MY 2024 C LASS 2b–8 V OCATIONAL VEHICLES  
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 Heavy 
heavy-duty 
Class 8 
EPA Standard for Vehicle with CI Engine Effective MY 2024 (gram CO 2/ton-mile) 
Urban .......................................................................................................................... ........... 385 271 283 
Multi-Purpose .................................................................................................................. ....... 344 246 242 
Regional ....................................................................................................................... .......... 296 221 194 
EPA Standard for Vehicle with SI Engine Effective MY 2024 (gram CO 2/ton-mile) 
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 
(and C8 
gasoline) 
Urban .......................................................................................................................... ........... 432 310 
Multi-Purpose .................................................................................................................. ....... 385 279 
Regional ....................................................................................................................... .......... 324 251 
TABLE V–7—NHTSA F UELCONSUMPTION STANDARDS FOR MY 2024 C LASS 2b–8 V OCATIONAL VEHICLES  
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 Heavy 
heavy-duty 
Class 8 
NHTSA Standard for Vehicle with CI Engine Effective MY 2024 (Fuel Consumption gallon per 1,000 ton-mile) 
Urban .......................................................................................................................... ........... 37.8193 26.6208 27.7996 
Multi-Purpose .................................................................................................................. ....... 33.7917 24.1650 23.7721 
Regional ....................................................................................................................... .......... 29.0766 21.7092 19.0570 
NHTSA Standard for Vehicle with SI Engine Effective MY 2024 (Fuel Consumption gallon per 1,000 ton-mile) 
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 
(and C8 
gasoline) 
Urban .......................................................................................................................... ........... 48.6103 34.8824 
Multi-Purpose .................................................................................................................. ....... 43.3217 31.3942 
Regional ....................................................................................................................... .......... 36.4577 28.2435 
TABLE V–8—EPA CO 2STANDARDS FOR MY 2027 C LASS 2b–8 V OCATIONAL VEHICLES  
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 Heavy 
heavy-duty 
Class 8 
EPA Standard for Vehicle with CI Engine Effective MY 2027 (gram CO 2/ton-mile) 
Urban .......................................................................................................................... ........... 367 258 269 
Multi-Purpose .................................................................................................................. ....... 330 235 230 
Regional ....................................................................................................................... .......... 291 218 189 
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TABLE V–8—EPA CO 2STANDARDS FOR MY 2027 C LASS 2b–8 V OCATIONAL VEHICLES —Continued 
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 Heavy 
heavy-duty 
Class 8 
EPA Standard for Vehicle with SI Engine Effective MY 2027 (gram CO 2/ton-mile) 
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 
(and C8 
gasoline) 
Urban .......................................................................................................................... ........... 413 297 
Multi-Purpose .................................................................................................................. ....... 372 268 
Regional ....................................................................................................................... .......... 319 247 
TABLE V–9—NHTSA F UELCONSUMPTION STANDARDS FOR MY 2027 C LASS 2b–8 V OCATIONAL VEHICLES  
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 Heavy 
heavy-duty 
Class 8 
NHTSA Standard for Vehicle with CI Engine Effective MY 2027 (Fuel Consumption gallon per 1,000 ton-mile) 
Urban .......................................................................................................................... ........... 36.0511 25.3438 26.4244 
Multi-Purpose .................................................................................................................. ....... 32.4165 23.0845 22.5933 
Regional ....................................................................................................................... .......... 28.5855 21.4145 18.5658 
NHTSA Standard for Vehicle with SI Engine Effective MY 2027 (Fuel Consumption gallon per 1,000 ton-mile) 
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 
(and C8 
gasoline) 
Urban .......................................................................................................................... ........... 46.4724 33.4196 
Multi-Purpose .................................................................................................................. ....... 41.8589 30.1564 
Regional ....................................................................................................................... .......... 35.8951 27.7934 
As with the other regulatory 
categories of heavy-duty vehicles, 
NHTSA and EPA are adopting standards that apply to Class 2b–8 vocational vehicles at the time of production, and EPA is adopting standards for a specified period of time in use (e.g., 
throughout the regulatory useful life of the vehicle). The derivation of the standards for these vehicles, as well as details about the provisions for certification and implementation of these standards, are discussed in more detail in Sections V.C. and V.D and in the RIA Chapter 2.9. 
(b) Custom Chassis Fuel Consumption 
and CO
2Standards 
The agencies proposed a simplified 
compliance procedure and less stringent standards for emergency vehicles, while requesting comment on extending these flexibilities to other custom chassis such as recreational vehicles and buses. 80 FR 40292–40293. As described below, the agencies are finalizing a broader allowance that will also apply for vehicles other than emergency vehicles. 
In response to the proposed 
provisions for emergency vehicles, we received comments in support of 
adopting separate, less stringent standards for emergency vehicles through a simplified GEM process. Based on the reasoning set forth at proposal, and supported in the public comments, these final rules include optional emergency vehicle standards based on the same technologies as described in the proposal, and using a simplified version of GEM available through the custom chassis program. The use of a default engine in GEM avoids penalizing emergency vehicle manufacturers from installing engines 
that are likely to be credit-using engines against the separate engine standard, and avoids forcing emergency vehicles to be measured against an un- representative baseline over an un- representative drive cycle. 
(i) Justification for an Expanded Custom 
Chassis Program 
In the proposal, we requested 
comment on other manufacturers who could benefit from a similar regulatory approach, such as those offering such a narrow range of products that averaging is not of practical value as a compliance flexibility, and for whom there are not 
large sales volumes over which to distribute technology development costs, as well as having drive cycles and functions that may make the primary standards either unrepresentative or unsuitable. Although this issue has some implications for our consideration of small business concerns, the custom chassis provisions discussed in the proposal were not intended to be limited to small businesses, and the final custom chassis standards are generally applicable (albeit optional). It is important to consider that for some vocational applications the custom- chassis manufacturers can have substantial market share. For example, Blue Bird is a manufacturer of school buses and school bus chassis with a substantial market share of its narrow product line. 
We received comments in support of 
separate standards based on a different technology mix than the primary program for seven vocational vehicle applications. Gillig, New Flyer and Allison commented in support of 
separate standards for transit buses. RVIA, Newell Coach, Allison and Tiffin 
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396See record of Webinar on Vocational Custom 
Chassis, March 2016, Docket ID EPA–HQ–OAR– 
2014–0827–1944. Motor Homes commented in support of 
separate standards for motor homes. OshKosh commented in support of separate standards for cement mixers. Autocar and Volvo commented in support of separate standards for refuse trucks. Volvo and ABC Bus Companies commented in support of separate standards for motor coaches. Daimler and the School Bus Manufacturers Technical Council commented in support of separate standards for school buses. 
The agencies received favorable 
comment on using a simplified compliance procedure for custom chassis from most commenters, but some expressed concerns. Autocar claimed that the simplified GEM interface would not sufficiently reduce the administrative compliance burden of small businesses, and recommended an engine-only certification method. 
Custom chassis manufacturers that are 
not small businesses must comply with the Phase 1 standards and are generally doing so, by installing a mix of tires that, on average, meet the target coefficient of rolling resistance. Large manufacturers were not enthusiastic about offering a different approach for some vehicles, and urged that custom chassis standards, if adopted, be generally available as a compliance option. Based on public comment and extensive stakeholder outreach, the agencies have identified over a dozen chassis manufacturers serving the U.S. vocational market who produce a narrow spectrum of vehicles for which many technologies underlying the primary standards will either be less effective than projected, or are infeasible. Innovus commented that regulatory flexibility should only be offered to small volume producers who are also small entities. However, we do not believe it is warranted to force any of these specialized manufacturers to certify their narrow product line of vehicles to the primary standards, where stringency is premised on performance of some technologies unsuited for their specialized type of vehicle. Thus, the agencies have developed optional standards tailored for these vehicle types, and are not limiting eligibility to small entities. 
Any manufacturer may certify their 
vehicles that we have identified as 
custom chassis vehicles under the primary standards. We expect that diversified chassis manufacturers selling a small number of their products into these defined custom applications could likely meet the primary Phase 2 standards on average, using internal credits. However, because the baseline configurations and duty cycles for these custom applications would be less representative and some technologies would either be less effective or infeasible for them, these custom applications would likely be credit- using vehicles in the averaging set. Even so, we believe the primary Phase 2 standards are both feasible and appropriate for diversified manufacturers, as their broad mix of products allows them to average across their fleets, and some vehicles are likely to over-comply because their in-use applications are more compatible with the full range of available technologies. This is a feature of setting performance- based average standards with less than 100 percent adoption rates of technologies. Because we agree with commenters, including OshKosh who noted this is an expected market practice, we believe it is essential to not only set feasible targets for chassis manufacturers offering a narrow range of products and for whom fleet averaging will provide a smaller degree of compliance flexibility, but to also make this option available to diversified manufacturers. To address stakeholder concerns about large, diversified manufacturers having greater ability to produce credit-using vehicles than smaller, less diversified manufacturers, we are adopting additional flexibilities for manufacturers certifying to the custom chassis standards, including some flexibilities that will be available only for small businesses. 
We do not view these standards as 
achieving less improvement than the primary program for these vehicles, and thus, we are not adopting any sales limits. Nevertheless, we requested comments on an appropriate sales volume that might be considered as a criterion to qualify for the numerically less stringent standards, where vehicle quantities above such sales threshold would need to be certified to the primary standards. We received comments from Allison, Autocar, Innovus, the School Bus Manufacturers Technical Council, and RVIA suggesting appropriate low-volume thresholds ranging from 200 to 26,000 vehicles per year. We received adverse comment from Daimler stating it would be unfair to make less stringent standards available solely on the basis of sales volume, because if a technology exists for one manufacturer, it is available to all manufacturers. We received adverse comment from OshKosh that less stringent regulations on a limited production volume stifles a custom chassis manufacturers’ opportunity to grow their business. For each of the applications listed below in Table V–10, the agencies have identified at least one 
manufacturer who produces chassis regulated under the Phase 2 program that are generally finished as a single vehicle type, as well as at least one competitor who is more diversified. After considering these comments, we continue to believe that no sales limits are needed. 
After considering the comments on 
possible separate standards for custom chassis, the agencies have evaluated the feasibility of technologies for these 
vehicles on an application-specific basis. We shared draft custom chassis technology packages with affected stakeholders and received feedback.
396 
See Section V.C.1.a below discussing the feasibility of each technology as it applies for custom chassis vehicles. Section V.C.(2)(b) discusses the technology adoption rates from which the stringency of the optional custom chassis standards are derived. 
Navistar commented with concerns 
that separate standards for custom chassis could create an unleveled playing field for manufacturers. ACEEE commented that the agencies should strengthen the primary vocational vehicle standard by one percent to offset the weaker standards for the custom chassis. ACEEE also commented that if chassis manufacturers can identify the vehicle application with enough specificity to take advantage of the custom chassis program, then they should also be able to take advantage of the most appropriate fuel-saving technologies, resulting in target stringencies that are not weaker than the main program. Although we agree that the custom chassis program should not result in a weakening of the overall vocational program, we disagree with ACEEE’s recommendation to arbitrarily add back stringency. The agencies did not remove custom chassis in the final stage of a feasibility analysis of the primary program; rather, we separately considered the custom chassis vehicles as an integral part of developing the feasibility analysis in support of the final standards. The optional final standards are technology-advancing, appropriate, and maximum feasible for these applications. No arbitrary offset is needed or justified. 
We disagree with claims made by 
commenters expressing concerns with respect to a shortfall or gap in emissions reductions between the primary vocational vehicle program and the custom chassis program. Some commenters have attempted to quantify 
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397See memorandum dated February 2016 on 
Vocational Vehicle Technology Packages for 
Custom Chassis, Docket ID EPA–HQ–OAR–2014– 0827–1719. 
398Vehicle populations are estimated using 
MOVES2014. More information on projecting populations in MOVES is available in the following report: USEPA (2015). ‘‘Population and Activity of On-road Vehicles in MOVES2014—Draft Report’’ 
Docket No. EPA–HQ–OAR–2014–0827. 
399National Ready Mixed Association Fleet 
Benchmarking and Costs Survey, http://www.nxtbook.com/naylor/NRCQ/NRCQ0315/index.php#/22, from UCS Custom Chassis Recommendations, May 2016. 400ICCT, May 2009, ‘‘Heavy-Duty Vehicle Market 
Analysis: Vehicle Characteristics & Fuel Use, Manufacturer Market Shares.’’ 
401Fire Apparatus Manufacturer’s Association, 
Fire Apparatus Duty Cycle White Paper, August 2004, available at http://www.deepriverct.us/firehousestudy/reports/Apparatus-Duty-Cycle.pdf. a difference in stringency by comparing 
select technology packages for custom chassis described in a February 2016 memorandum with the proposed technology packages for comparable subcategories.
397Because most of the 
baseline configurations for the custom chassis are tailored for each vocational vehicle, the only vehicle types where this comparison is straightforward is school buses and motor homes. In comparing the MY 2027 stringency of the medium heavy-duty Urban subcategory with the optional MY 2027 standard for school buses, for example, it can be seen that diesel vehicles in the primary program are projected to achieve 22 percent improvement on average, while school buses are expected to achieve 18 percent improvement on average. This is nowhere near the gap posited by certain commenters. Moreover, the difference in stringency reflects the reasonable conclusion that certain transmission technologies are not feasible for school buses. 
This comparison is not 
straightforward for motor coaches and other custom chassis types, however, because the baselines are different and the vehicle attributes are not similar. For example, our baseline configuration for coach buses includes a 350 hp 11- liter engine with a 6-speed automatic transmission. However, the primary program includes a baseline for heavy heavy-duty Regional vehicles that is a weighted average of 95 percent with 455 hp 15-liter engine with 10-speed manual transmission and 5 percent with a 350 hp 11-liter engine with a 6-speed automatic transmission. Due to the difference in performance of these configurations in GEM, a non- diversified coach bus manufacturer may find its fleet significantly ‘‘in the hole’’ in the first year of this program due solely to baseline differences. As an example of a technology difference, we have determined that regular HHD Regional chassis may reasonably apply AES on average at a rate of 90 percent by MY 2027, whereas we find that AES is not feasible at all for a conventional coach bus. A diversified manufacturer choosing to certify a coach bus in the HHD–R subcategory to the primary standards is likely to need to apply other technologies or use credits from other types of vehicles to meet the standard on average. A non-diversified coach bus manufacturer would be unlikely to achieve the HHD–R primary program standard unless some very advanced technology is applied (at costs necessarily very different from those analyzed to be reasonable here). Therefore, we do not believe it is accurate to draw a comparison, as certain commenters maintained, between the HHD–R primary program stringency of 14 percent and the coach bus MY 2027 stringency of 11 percent. 
Nonetheless, because these optional 
custom chassis standards are numerically less stringent than the primary Phase 2 vocational vehicle standards, the agencies are adopting a more restrictive approach to averaging, banking and trading (ABT), allowing averaging only within each subcategory for vehicles certified to these optional standards. Trading and banking will not be permitted except that small businesses certifying vehicles to these optional standards may use traded credits to comply. We are adopting these provisions to prevent generation of windfall credits against the less numerically stringent custom chassis standard. If a manufacturer wishes to generate tradeable credits from production of these vehicles, one or more families may be certified to the primary vocational vehicle standards. 
TABLE V–10—C USTOM CHASSIS POPULATION ESTIMATES  
Application type Percent of new 
MY 2018 
vocational 
population Average VMT 
in first yeara 
Coach (Intercity) Bus .......................................................................................................... ......................... 1 85,000 
Motor Home ..................................................................................................................... ............................ 13 2,000 
School Bus ..................................................................................................................... .............................. 10 14,000 
Transit Bus .................................................................................................................... ............................... 1 64,000 
Refuse Truck ................................................................................................................... ............................ 3 34,000 
Cement Mixerb............................................................................................................................... ............. 1 16,000 
Emergency Vehiclec............................................................................................................................... ..... 1 6,000 
Notes: 
aSource: MOVES 2014 for all except mixer and emergency.398 
bSource for cement mixer is UCS.399 
cSource for emergency is ICCT (2009)400and FAMA (2004).401 
As shown in Table V–10, some of 
these vehicle types are produced in 
moderate volumes, and some are driven moderate distances annually. However, those that are produced in slightly higher volumes (motor homes and school buses) are among those driven the fewest miles. Similarly, those driven the most miles (coach and transit buses) are among those produced in the smallest volumes. Collectively, the agencies estimate that the vehicles defined as custom vocational chassis in Phase 2 comprise less than 30 percent of the projected new vocational vehicle sales in MY 2018. Even so, because of the collectively small number of miles driven, the agencies believe that setting less numerically stringent GHG and fuel 
consumptions standards for these vehicles will not detract from the greater 
benefits of this rulemaking, and that such separate standards are warranted in any case. 
As proposed and discussed in the RIA 
Chapter 12, the agencies are adopting a provision for chassis manufacturers qualifying as small businesses to have 
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402See SBA regulations at 13 CFR 121.201. 
Thresholds effective February 2016 are available at 
http://www.regulations.gov/#!documentDetail;D=SBA-2014-0011-0031 , 81 FR 4469. one extra year of lead time to comply 
with the initial Phase 2 standards.402 
Daimler stated it only supported additional lead time if it was provided equally to all custom chassis manufacturers. Because the SBA threshold in this sector is generally 1,500 employees, we believe that small entities have fewer in-house resources to collect and analyze compliance data than do manufacturers with more employees. Due to these resource constraints, the agencies believe it is appropriate to offer this only to small businesses—the entities that need further lead time. However, many custom chassis manufacturers do not qualify as small entities under the SBA regulations. We received comment from OshKosh that additional time to meet an impossible stringency target is not helpful, a comment addressed by adopting the separate custom chassis standards. The final program offers both a feasible standard, as described below, and additional lead time for small businesses. 
Vehicles certifying to the optional 
custom chassis standards will be simulated in GEM using a default EPA engine map as well as many other EPA default parameters that are required inputs for vehicles in the primary program. While this is very similar to the Phase 1 GEM, more inputs are available in the Phase 2 custom chassis program than in Phase 1. Section V.D.(1) below describes the regulatory subcategory identifiers that must be input to GEM to call default vehicle specifications as part of obtaining valid simulation results for custom chassis in GEM. 
The optional custom chassis 
standards will phase in over the same period as the primary vocational vehicle standards, beginning in the 2021 model year. However, there are no intermediate standards in MY 2024, so the optional MY 2021 custom chassis standards will continue until the full implementation year of MY 2027. The agencies have identified a technology path for each of these levels of improvement, as described below. 
Combining engine and vehicle 
technologies, custom chassis are projected to achieve improvements from 6 to 18 percent in MY 2027 over the MY 2017 baseline, as summarized in Table V–11. The incremental standard in MY 2021 will achieve improvements of up to 10 percent over the MY 2017 baseline vehicles when including improvements from MY 2021 diesel engines, as shown 
in Table V–11. 
The agencies’ analyses, summarized 
immediately below and discussed in detail in the RIA Chapter 2.9, show that these optional standards are justified under each agency’s respective statutory authority. We note that for each model year of the Phase 2 custom chassis standards, the numerical value of the 
vehicle-level standard represents the performance of a diesel engine meeting that year’s separate CI engine standard. Put another way, although the agencies are adopting distinct standards for custom chassis vocational vehicles, those vehicles must still use engines certified to the applicable Phase 2 engine standard. As in Phase 1, the chassis manufacturer is free to install any certified engine, and because GEM will run using a default map, the choice of engine will not affect the GEM result. 
TABLE V–11—C USTOM CHASSIS CO 2 
AND FUEL USEREDUCTIONS (IN 
PERCENT ) FROM 2017 B ASELINE  
Vehicle type Model year 
2021 2027 
Coach Bus ........................ 7 11 
Motor Home ...................... 6 9 
School Bus ....................... 10 18 
Transit ............................... 7 14 
Refuse .............................. 4 12 
Mixer ................................. 3 7 
Emergency ........................ 1 6 
It is worth noting that because the 
custom chassis version of GEM will not recognize certain technology improvements that some of these manufacturers will include based on market forces (after they have been introduced into the market as a result of the primary program), we expect actual in-use improvements for some of these vehicles to be slightly greater than is required by the standards. For example, we project that transmission manufacturers will improve the overall efficiency of their transmissions to enable vehicle manufacturers to comply with the primary standards. Once these transmissions have been developed and made available, we would not expect custom chassis manufacturers (or customers) to resist using them simply because they would not impact compliance with the standards. 
(ii) GEM-Based Custom Chassis 
Standards 
Table V–12 and Table V–13 present 
EPA’s CO
2standards and NHTSA’s fuel 
consumption standards, respectively, for custom vocational chassis. The agencies have analyzed the technological feasibility of achieving the fuel consumption and CO
2standards, 
based on projections of actions manufacturers may take to reduce fuel consumption and emissions to achieve the standards, and believe that the standards are technologically feasible throughout the regulatory useful life of the program. EPA and NHTSA describe costs of the custom chassis standards in Section V.C.(2). In all cases we expect the technology package costs to be less than those of the primary Phase 2 standards, reflecting that the full set of technologies on which the stringency of the primary standards are based is not suitable for custom chassis applications. The costs of these standards are reasonable in the context of the reductions achieved, should be offset by fuel savings over the life of the vehicles. 
These custom vehicle-level standards 
are predicated on a simpler set of vehicle technologies than the primary Phase 2 standard for vocational vehicles. (As already noted, these custom chassis vehicles will be required to use engines meeting the Phase 2 engine standards, and thus, should generally incorporate the same engine improvements as other vocational 
vehicles). In developing these optional standards, the agencies have evaluated the current levels of fuel consumption and emissions, the kinds of technologies that could be utilized by custom chassis manufacturers to reduce fuel consumption and emissions, the associated lead time, the associated costs for the industry, fuel savings for the owner/operator, and the magnitude of the CO
2reductions and fuel savings 
that may be achieved. After examining the possibilities of vehicle improvements, the agencies are basing the optional vehicle-level standards for motor homes on adoption of TPMS and low rolling resistance tires. We are basing the optional standards for transit buses and refuse trucks on the performance of workday idle reduction technologies, tire pressure systems, simplified transmission improvements, and further tire rolling resistance improvements. The agencies are basing the standards for coach buses and school buses on all of the above technologies as well as simplified transmission improvements. The agencies are basing the standards for concrete mixers and emergency vehicles on use of tires with current average levels of rolling resistance. The EPA- only air conditioning standard is based on leakage improvements. Of these technologies, we believe that improved tire rolling resistance, neutral idle, and air conditioning leakage improvements 
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are available today and may be adopted 
as early as MY 2021. As described in the RIA 2.9.3.4 and 2.9.5, the vehicle technology that we believe will benefit from more development time for engine and vehicle integration is stop-start idle reduction. 
EPA’s custom chassis CO
2standards 
and NHTSA’s fuel consumption standards for the full implementation year of MY 2027 reflect even greater adoption rates of the same vehicle technologies considered as the basis for the MY 2021 standards, described in more detail in Section V.C below. 
As with the other regulatory 
categories of heavy-duty vehicles, NHTSA and EPA are adopting standards that apply to custom chassis vocational vehicles at the time of production, and EPA is adopting standards for a specified period of time in use (e.g., throughout the regulatory useful life of the vehicle). The derivation of the standards for these vehicles, as well as details about the provisions for certification and implementation of these standards, are discussed in more detail later in this document and in the RIA 2.9.3 to 2.9.6. 
The optional standards shown below 
were derived using baseline vehicle models with many attributes similar to those developed for the primary program, with adjustments that are described below in Section V.C.(2)(a). Details of these configurations are provided in the RIA Chapter 2.9.2. For better transparency with respect to the incremental difference between the MY 2021 and MY 2027 vehicle standards, we have modeled a certified MY 2027 engine for both vehicle model years of optional custom chassis standards. Thus, chassis manufacturers who do not make their own engines may compare 
the two model years of standards presented in Table V–12 and Table V– 13 and know that any differences are due solely to vehicle-level technologies. 
TABLE V–12—EPA E MISSION  
STANDARDS FOR CUSTOM CHASSIS  
[Gram CO 2/ton-mile] 
MY 
2021 MY 
2027 
Coach Bus .................... 210 205 
Motor Home .................. 228 226 
School Bus ................... 291 271 
Transit ........................... 300 286 
Refuse .......................... 313 298 
Mixer ............................. 319 316 
Emergency .................... 324 319 TABLE V–13—NHTSA F UELCON-
SUMPTION STANDARDS FOR CUSTOM  
CHASSIS  
[Gallon per 1,000 ton-mile] 
MY 
2021 MY 
2027 
Coach Bus .................... 20.6287 20.1375 
Motor Home .................. 22.3969 22.2004 
School Bus ................... 28.5855 26.6208 
Transit ........................... 29.4695 28.0943 
Refuse .......................... 30.7466 29.2731 
Mixer ............................. 31.3360 31.0413 
Emergency .................... 31.8271 31.3360 
The agencies are adopting definitional 
provisions for each of the custom 
chassis subcategories to ensure that only eligible chassis will be able to certify to these numerically less stringent standards. The category with the most diversity and the greatest need for regulatory clarification is refuse. We received comments from OshKosh that there are seven distinct types of refuse trucks, including roll-on-roll-off vehicles, type T container haulers (hauling trailers containing waste), as well as residential front loaders, side loaders, and rear loaders. After considering these comments and other available information, we have determined that refuse trucks that do not compact waste are ineligible to certify to the custom chassis standards. For example, roll-off trucks do not engage in neighborhood waste collection and typically transfer full containers to and from regional landfills and construction sites. Furthermore, their driving patterns are more likely to resemble our Regional cycle than the Urban cycle. These trucks do engage in some PTO operation while parked when loading or unloading waste containers using hydraulically operated beds and possibly a winch or other onboard lift system; however, they do not use the PTO while driving. The relevant definitions and certification provisions for refuse and other vehicle types are discussed below in Section V.D. 
As discussed above, we are not 
restricting the optional custom chassis program to small businesses, nor is there a production cap. Because we are allowing diversified manufacturers to certify some vehicles to the optional custom chassis standards, but some large manufacturers may not have a system for tracking what the final build of a vehicle is, we are adopting compliance procedures to assure that the final intended build will be one of the defined vehicle types. This approach is intended to level the playing field by allowing large manufacturers to choose this option where their tracking (and/or controls imposed on the vehicle) is sufficient to know at the time of certification what the final build will be. This avoids restricting this path to a small subset of manufacturers. 
(iii) Design Standards for Select Custom 
Chassis 
The agencies are adopting an 
additional set of optional standards where manufacturers of motor home, cement mixer, and emergency vehicle chassis may elect to certify one or more families of vehicles to an equivalent standard. Certification would not require use of GEM if a manufacturer selects this option. Instead, certification using this option requires installation of specific technologies on every vehicle. This option does not allow any averaging, banking, or trading. These standards are equivalent in stringency to the GEM-based option for these three types of chassis. As mentioned above, the agencies received compelling public comment from Autocar suggesting that use of even the simplified GEM was unreasonably burdensome, and that further simplification was warranted in some cases. For small businesses especially, the certification burden of collecting data and running even a simplified version of GEM can present a disproportionally high burden, especially where there are very limited GEM inputs. Thus, the agencies sought to offer an option that minimizes the certification burden, recognizing the lesser complexity of the technology package associated with the standards for these chassis. 
These equivalent technology-based 
standards are not available for manufacturers of coach bus, school bus, transit bus, and refuse truck chassis, as the technology packages for these chassis are more complex and cannot be projected to be installed at 100 percent adoption rates. 
Table V–14 lists the technologies 
required to be applied to every vehicle sold by a manufacturer as part of a family certified to the optional non- GEM vocational vehicle standards. In addition, the vehicle must have a certified Phase 2 engine and comply with the separate standard to prevent leakage of HFC from the mobile air conditioning system. The combined tire CRR values shown in the table are obtained using Equation V–1. 
Equation V–1 Vocational Tire CRR Level 
Formula 
Steer tire CRR × 0.3 + Drive tire CRR × 
0.7 
Although manufacturers choosing this 
option will not have access to the 
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403See proposed rules at 80 FR 40295, July 13, 
2015. heavy-duty ABT program, this formula 
provides a small degree of freedom to allow for some product variability while meeting the target for every vehicle. 
TABLE V–14—O PTIONAL DESIGN (NON-GEM) S TANDARDS  
Vehicle type Required technology 
MY 2021 MY 2027 
Motor Home ......................... Combined CRR 6.7 kg/ton or less, and either TPMS or 
ATIS.Combined CRR 6.0 kg/ton or less, and either TPMS or 
ATIS. 
Emergency ........................... Combined tire CRR 8.7 kg/ton or less ............................ Combined tire CRR 8.4 kg/ton or less. 
Mixer .................................... Combined tire CRR 7.6 kg/ton or less ............................ Combined tire CRR 7.1 kg/ton or less. 
(c) HFC Leakage Standards 
The Phase 1 GHG standards do not 
include standards to control direct HFC 
emissions from air conditioning systems on vocational vehicles. EPA deferred such standards due to ‘‘the complexity in the build process and the potential for different entities besides the chassis manufacturer to be involved in the air conditioning system production and installation,’’ See 76 FR 57194. During our stakeholder outreach conducted for Phase 2, we learned that the majority of vocational vehicles are sold as cab- completes with the dashboard-mounted air conditioning systems installed by the chassis manufacturer. For those vehicles that have A/C systems installed by a second stage manufacturer, EPA is adopting revisions to our regulations that resolve the issues identified in Phase 1, in what we believe is a practical and feasible manner, as described below in Section V.D.2. 
EPA received comments generally 
supportive of adoption of A/C refrigerant leakage standards for Class 2b–8 vocational vehicles, beginning with the 2021 model year. Chassis sold as cab-completes typically have air conditioning systems installed by the chassis manufacturer. For these configurations, the process for certifying that low leakage components are used will follow the system in place currently for comparable systems in tractors. In the case where a chassis manufacturer will rely on a second stage manufacturer to install a compliant air conditioning system, the chassis manufacturer must follow the certifying manufacturer’s 
installation instructions to ensure that the final vehicle assembly is in a certified configuration. 
(3) Exemptions and Exclusions 
This section describes exemptions 
and exclusions related to vocational 
vehicles, including some that are available only in Phase 1 and some on which we asked for comment but did not adopt in the final program. (a) Small Business Flexibilities 
Although the Phase 1 program 
deferred the requirements for small 
businesses, the Phase 2 program will require small businesses to certify their affected vehicles. The RIA Chapter 12 presents a complete discussion of the outreach process that EPA conducted to solicit input from small businesses on the Phase 2 program. The RIA Chapter 12 explains why the agencies are adopting one year of additional lead time for all small businesses in Phase 2. Thus, the first compliance year for small entities is MY 2022 rather than MY 2021. The Small Business Advocacy Review Panel included representatives who produce vocational vehicle chassis, including emergency vehicles and concrete mixers. Discussions specific to vocational vehicle chassis during that process included exploration of a low volume production threshold below which some manufacturers may avoid some obligations of this regulation. Consistent with the recommendations of the Panel, the agencies requested comments on how to design a small business vocational vehicle program, including comments on a possible small volume threshold below which some small business exemption may be available.
403Innovus commented in 
support of a small volume threshold for vocational small businesses of either 200 vehicles per year or a different threshold set based on the market share of the entity. We received comments from Allison, Autocar, the School Bus Manufacturers Technical Council, and RVIA each suggesting different low- volume vocational chassis thresholds ranging as high as 26,000 vehicles per year. We received adverse comment from Daimler stating it would be unfair to make less stringent standards available solely on the basis of sales volume, because if a technology exists for one manufacturer, it is available to all manufacturers. We received adverse comment from OshKosh that less stringent regulations on a limited 
production volume stifles a custom chassis manufacturers’ opportunity to grow their business. Upon consideration of these comments, the agencies are not finalizing a broad sales volume threshold below which a vocational chassis manufacturer may reduce their compliance burden. Instead we are adopting the custom chassis program, and we are revising some of the exemptions that are carrying forward from Phase 1. 
Autocar requested further 
consideration of the small business concerns of manufacturers of specialty vehicle applications, specifically recommending a low volume threshold if the agencies are not inclined to use a manufacturer’s business size as grounds for an exemption. Examples of specialty vehicles listed by Autocar include street sweepers, asphalt blasters, aircraft deicers, sewer cleaners, and concrete pumpers. Innovus also requested additional flexibility for meeting OBD requirements. Capacity Trucks commented that the terminal tractor industry is primarily comprised of small businesses who produce a total of less than 6,000 terminal tractors per year, 70 percent of which are fully off-road vehicles. See Section V.B.(3)(c) for a discussion of how we are addressing Innovus’ comment. See the discussion in Section V.B.(3)(b) for a discussion of how we are addressing the comments on vehicles that are off-road and low-speed. 
(b) Off-Road and Low-Speed Vocational 
Vehicle Exemptions 
In considering the above comments 
regarding additional vehicles that have significant operation at low speeds or off-road, the agencies are revising the exemptions adopted in Phase 1 for off- road and low-speed vocational vehicles at 40 CFR 1037.631 and 49 CFR 523.2. See generally 76 FR 57175. 
These provisions already apply in 
Phase 1 for vehicles that are defined as ‘‘motor vehicles’’ per 40 CFR 85.1703, 
but may conduct most of their operations off-road, such as drill rigs, mobile cranes and yard hostlers. 
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404See memorandum dated July 2016 with data 
on exempted off-road vocational vehicles. 405See memorandum dated July 2016 titled, 
‘‘Summary of SmartWay Port Dray 2014 Data’’. 406See Note 403, above. Vehicles qualifying under these 
provisions must be built with engines certified to meet the applicable engine standard, but need not comply with a vehicle-level GHG or fuel consumption standard. To date, according to EPA records, vehicles exempted under this provision using the axle rating criterion included airport fire apparatus, airport service, fire service, oil field service, utility repair, refuse, and truck crane. Only two vehicles were exempted using the 45 mph speed criterion, however those also had rear axles with GAWR of 29,000 lbs. No vehicles were exempted under this provision using the 33 mph criterion. Two manufacturers exempted several vehicles under this provision using the 55-mph speed-limited tire criterion, including oil field, mining, construction, rock body, and fertilizer spreader applications.
404RMA 
commented that the agencies should not discontinue the speed-limited tire exemption criterion, as was proposed. However, their argument that it would be detrimental for a vehicle to drive above 55 mph with speed-limited tires is not compelling. It is too easy for a vehicle to be sold with speed-limited tires and subsequently have replacement tires fitted that are appropriate for higher speed operation. Although we are discontinuing the criterion for exemption based solely on use of tires with maximum speed rating at or below 55 mph, we are adding a new criterion whereby a vehicle qualifies to be exempted under this provision if it would exceed 95 percent of maximum engine test speed when traveling at 54 mph or with tamper- proof equivalent electronic controls. We are retaining the qualifying criteria related to design and use of the vehicle. 
In considering the long list of 
specialty vehicle types raised by Capacity, Autocar and others, the agencies note that many of these may be 
primarily off-road vehicles in many respects, although some may not qualify as either off-road or low-speed under our regulations. In considering the drive cycle of those whose primary purpose is to transport an affixed device to an off- road work site for extended PTO operation, the agencies have concluded that the technologies we have determined to be feasible for concrete mixers are also feasible for this type of vehicle, and thus we are adopting a flexibility where vocational chassis that meet one of the two sets of criteria at 40 CFR 1037.631(a) (but not both) may be optionally certified under the custom chassis program to the standards established for concrete mixers. These 
technologies include certified engines, low-leakage air conditioning components, and by MY 2027, steer tires with level 3V rolling resistance and drive tires with level 2v rolling resistance. We have similarly determined these technologies are feasible and reasonable to apply for vehicles whose primary purpose is to conduct work at slow speeds, but do not have affixed devices designed to be used at off-road work sites. This may include street sweepers and some terminal tractors. 
We interpret the comments from 
Capacity to mean that many terminal tractors are produced in very small volumes by a large number of non- diversified small businesses. This is corroborated by comments from Autocar. Based on data from EPA’s Smartway program, the drive cycles of some port drayage tractors can include a significant amount of highway time as well as idle time. According to available records, the average fraction of highway operation of 1,740 participating port dray tractors was 59 percent, and the average annual idle time was 762 hours.
405In considering this drive cycle 
information along with vehicle attributes, the agencies have determined that workday idle reduction technologies, transmission technologies, low rolling resistance tires, and other technologies factored into the primary vocational vehicle standards are feasible for drayage tractors that are not speed- limited. Therefore, the agencies believe that a standard reflecting performance of this type of technology package has potential applicability for this subset of drayage tractors. There is a competing consideration, however. As discussed above regarding our justifications for an expanded custom chassis program, we believe it is essential to set feasible targets for those chassis manufacturers 
who offer a narrow range of products. This is because fleet averaging provides a smaller degree of compliance flexibility for such manufacturers. Therefore we have determined that some type of alternative standard is warranted for non-diversified manufacturers who produce non-speed- limited drayage tractors. The transit bus custom chassis subcategory has a baseline with characteristics reasonably similar to drayage tractors, and is predicated on use of some but not all of the technologies that are feasible for drayage tractors. The agencies are adopting this as an alternative standard for non-speed-limited drayage tractors, with one caveat. We are concerned that offering an optional standard based on adoption of fewer technologies than are actually feasible for drayage tractors could result in a loss of emission reductions that are technically feasible. To address this concern, the agencies are limiting the number of non-speed- limited drayage tractors that may be certified under the alternative standard.
406As stated above in Section 
V.B.(3)(a), Innovus commented that 200 vehicles per year would be an appropriate small volume threshold. Further, Autocar’s written comments as well as information provided during follow-up meetings indicate that this threshold would accommodate their production of non-speed-limited drayage tractors. Therefore the agencies are adopting a flexibility exclusively for small businesses to optionally certify up to 200 drayage tractors annually under the custom chassis program to the standards established for transit buses. Otherwise manufacturers may elect to either certify their drayage tractors to the primary standards or design them to satisfy the eligibility criteria of 40 CFR 1037.631 (i.e., to be speed-limited). We 
are adopting this as an interim provision (although there is no automatic sunset) to allow small businesses time to develop experience in the certification process as well as to develop future product plans. 
(c) Specialty Vehicle Exemption 
As described in Section XIII of this 
Preamble, the agencies are adopting 
alternate engine standards for specialty vehicles as part of the final Phase 2 program. Because some vocational vehicles may have engines certified under these specialty vehicle provisions found at 40 CFR 1037.605, we are clarifying here how these provisions interact. According to the regulations at 40 CFR 1037.605, a manufacturer may produce no more than 1,000 hybrid vehicles in a single model year under this option, and no more than 200 amphibious vehicles, speed-limited vehicles, or all-terrain vehicles. Under this provision, speed-limited vehicles are those that cannot exceed 45 mi/hr by tamper-proof calibration. Only vehicles with hybrid drivetrains that certify engines under this provision must also have a vehicle-level Phase 2 certificate, as required under 40 CFR 1037.105. The three other types would be exempt from the vehicle standards. Depending on the manufacturer and vehicle type, this may mean that such hybrid vehicles may need to meet the primary vocational 
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407Reinhart, T. (February 2016). Commercial 
Medium- and Heavy-Duty (MD/HD) Truck Fuel 
Efficiency Technology Study—Report #2. Washington, DC: National Highway Traffic Safety Administration. EPA–HQ–OAR–2014–0827–1623.; and Schubert, R., Chan, M., Law, K. 2015, 
Commercial Medium- and Heavy-Duty (MD/HD) Truck Fuel Efficiency Cost Study. Washington, DC: National Highway Traffic Safety Administration. 
408See NAS Report, Note 229 above. 
409See TIAX 2009, Note 230 above. 
410See ICF 2010, Note 232 above. 
411Argonne National Laboratory, ‘‘Evaluation of 
Fuel Consumption Potential of Medium and Heavy Duty Vehicles through Modeling and Simulation.’’ October 2009. vehicle standards or one of the custom 
chassis standards. 
C. Feasibility of the Vocational Vehicle 
Standards 
This section describes the agencies’ 
technological feasibility and cost analysis. Further detail on all of these technologies can be found in the RIA Chapter 2.4 and Chapter 2.9. The variation in the design and use of vocational vehicles has led the agencies to project different technology solutions for each regulatory subcategory. Manufacturers may also find additional means to reduce emissions and lower fuel consumption than the technologies identified by the agencies, and of course may adopt any compliance path they deem most advantageous. This section includes discussion of the feasibility of the final standards for non-custom vocational vehicles using the full Phase 2 certification path, as well as the final optional standards for custom chassis standards. 
NHTSA and EPA collected 
information on the cost and effectiveness of fuel consumption and CO
2emission reducing technologies 
from several sources. The primary sources of information were the Southwest Research Institute evaluation of heavy-duty vehicle fuel efficiency and costs for NHTSA,
407the 2010 
National Academy of Sciences report of Technologies and Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty Vehicles,
408 
TIAX’s assessment of technologies to support the NAS panel report,
409the 
technology cost analysis conducted by ICF for EPA,
410and the 2009 report 
from Argonne National Laboratory on Evaluation of Fuel Consumption Potential of Medium and Heavy Duty Vehicles through Modeling and Simulation.
411 
(1) What technologies are the Agencies considering to reduce the CO
2emissions 
and fuel consumption of vocational vehicles? 
In assessing the feasibility of the final 
Phase 2 vocational vehicle standards, the agencies evaluated a suite of technologies, including workday idle reduction, improved tire rolling resistance, tire pressure monitoring or inflation systems, improved transmissions including hybrids, improved axles, improved accessories, and weight reduction, as well as their impact on reducing fuel consumption and GHG emissions. The agencies also evaluated aerodynamic technologies and full electric vehicles. 
As discussed above, vocational 
vehicles may be powered by either SI or CI engines. The technologies and feasibility of the engine standards are discussed in Section II. At the vehicle level, the agencies have considered the same suite of technologies and have applied the same reasoning for including or rejecting these vehicle- level technologies as part of the basis for the final standards, regardless of whether the vehicle is powered by a CI or SI engine, since the vehicle level technologies are not a function of engine type. Generally, the analysis below does not distinguish between vehicles with different types of engines. The resulting vehicle standards do reflect the differences arising from the performance of CI (primarily diesel) or SI (primarily gasoline) engines over the GEM cycles. Note that vehicles powered by engines using fuels other than diesel or gasoline are subject to either the SI or CI vehicle standards, as specified in 40 CFR 1037.101. 
(a) Vehicle Technologies Considered in 
Standard-Setting 
The agencies note that the 
effectiveness values estimated for the technologies have been obtained using a variety of methods, including average literature values, engineering calculation, and GEM simulation. They do not reflect the potentially-limitless combination of possible values that could result from adding the technology to different vehicles. For example, while the agencies have estimated an effectiveness of one percent for e- accessories, each vehicle could experience a unique effectiveness depending on the actual accessory load for that vehicle. On-balance the agencies 
believe this is the most practicable approach for determining effectiveness for the technologies in the Phase 2 vocational vehicle program. This section is organized to first present the agencies’ analyses of technology feasibility and effectiveness in Section V.C.(1), and below in Section V.C.(2) we present our projected technology adoption rates and estimated costs. Where other details are not given, the feasibility sections set forth our rationale for the projected adoption rates. Average vehicle 
technology package costs by regulatory subcategory are presented below in Section V.C.(2)(e). Individual technology costs are summarized in the RIA Chapter 2.9.3, and full details behind all these costs are presented in RIA Chapter 2.11, including the markups and learning effects applied for each of the technologies. 
(i) Transmissions 
Transmission improvements present a 
significant opportunity for reducing fuel 
consumption and CO
2emissions from 
vocational vehicles. Transmission efficiency is important for all vocational vehicles as their duty cycles involve significant amounts of driving under transient operation. Even Regional vocational vehicles have 20 percent of their composite score based on the transient test cycle. The three categories of transmission improvements the agencies proposed to consider as part of a compliance path used to determine standard stringency were driveline optimization, architectural improvements, and hybrid powertrain systems. As a result of comments and enhanced capabilities of GEM, we are adopting standards based on performance of a revised set of transmission technologies. For each technology, we have adjusted our projected penetration rates where we found that comments provided a persuasive reason to do so, and the effectiveness values are all updated according to the current GEM over the new drive cycle weightings. 
The technology we described at 
proposal as driveline integration, 80 FR 40296, is now defined as use of an advanced shift strategy. At proposal the agencies included shift strategy, aggressive torque converter lockup, and a high efficiency gearbox among the technologies defined as driveline integration that would only be recognized by use of powertrain testing. We also proposed a 70 percent adoption rate in MY 2027 on the basis that this approach to improving fuel efficiency is highly cost-effective and technically feasible in a wide range of applications, and that the additional lead time would 
enable manufacturers to overcome barriers related to the non-integrated nature of businesses serving this sector. We received persuasive comments from manufacturers emphasizing the diversity of their product lines and the extent of testing that would be needed to apply this technology to 70 percent of their sales, and as a result we have reduced our projected adoption rates for this technology. The agencies continue to believe that an effective way to derive 
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412See Cummins-Eaton partnership at http://
smartadvantagepowertrain.com/. 413See http://www.truckinginfo.com/channel/
equipment/article/story/2014/10/2015-medium- 
duty-trucks-the-vehicles-and-trends-to-look-for/ page/3.aspx (downloaded November 2014). 
414See TIAX 2009, Table 4–48. efficiency improvements from a 
transmission is by optimizing it with the engine and other driveline components to balance both performance needs and fuel savings. One example of an engine manufacturer partnering with a transmission manufacturer to achieve an optimized driveline is the SmartAdvantage powertrain.
412The 
agencies project transmission shift strategies, including those that make use of enhanced communication between engine and driveline, can yield efficiency improvements ranging from three percent for Regional vehicles to nearly six percent for Urban vehicles, using engineering calculations (see RIA 2.9.3.1) to estimate the benefits that can be demonstrated over the powertrain test. We received comment that we had poorly defined the technology that can bring about improvements related to drive line integration. In considering the comments and available information, we believe it is reasonable to project that transmissions may feature advanced shift strategies where they make use of an additional sensor to improve fuel efficiency such as by detecting payload or road grade. See Section V.D.(1) and the RIA Chapter 3.6 for a discussion of the powertrain test procedure. 
The agencies have revised the GEM 
simulation tool to recognize additional transmission technologies beyond what was possible at the time of proposal. We are adopting a transmission efficiency test to recognize improved mechanical gear efficiency and reduced transmission friction, where the test results can be submitted as GEM inputs to override the default efficiency values. Because this test can be conducted with a bare transmission without needing to be paired with an engine, each test will be valid for a much broader range of vehicle configurations than for a powertrain test. The agencies project 
vehicle fuel efficiency can be improved by up to one percent from improved transmission gear efficiency, which we are projecting to be the same during each of the driving cycles and zero while idling. RIA 2.9.3.1.1. Actual test results are likely to show that some gears have more room for improvement than others, especially where a direct drive gear is already highly efficient. Commenters requested that the minimum torque converter lockup gear be enabled as a GEM input without requiring powertrain testing. In response, final GEM also requires an input field for torque converter lockup gear. The baseline configurations with automatic transmissions were run in GEM using lockup in third gear. The agencies project vehicle fuel efficiency can be improved up to three percent on a cycle average for torque converter lockup in first gear. RIA 2.9.3.1.1. Using the library of agency transmission files, GEM gives a different effectiveness value in every subcategory, because this is influenced by the gear ratios, drive cycle, and torque converter specifications. Manufacturers will obtain slightly different results with their own driveline specifications. The RIA at Chapter 2.9.3.1 includes a table that summarizes the various effectiveness values for different types of transmission improvements. 
Although not factored into our 
stringency calculations, other non- hybrid transmission technologies that can also be recognized by powertrain testing include use of architectures not recognized by GEM such as dual clutch systems, and designs with reduced parasitic losses. 
Most vocational vehicles currently 
use torque converter automatic transmissions (AT), especially in Classes 2b–6. Automatic transmissions offer acceleration benefits over drive cycles with frequent stops, which can enhance productivity. With the diversity of vocational vehicles and drive cycles, other kinds of transmission architectures can meet customer needs, including automated manual transmissions (AMT), dual clutch transmissions (DCT), as well as manual transmissions (MT).
413As at proposal, 
dual clutch transmissions are simulated as AMT’s in GEM. A manufacturer may elect to conduct powertrain testing to obtain specific improvements for use of a DCT. The RIA Chapter 4 explains the EPA default shift strategy and the losses associated with each transmission type, and discusses changes that have been made since proposal. Although the representation of transmissions has improved since proposal, the differences between AT and AMT are too difficult to isolate for purposes of figuring this into our stringency calculations. Although we expect manufacturers to have a reasonable model of transmission behavior for certification purposes, we could not estimate relative improvement values between AT and AMT for vocational vehicles using any defensible estimation method. The agencies have not been able to obtain conclusive data that could support a final vocational vehicle standard, in any subcategory, predicated on adoption of an AMT or DCT with a predictable level of improvement over an AT. As a result, the only architectural changes on which the final vocational vehicle standards are based are increasing the number of gears and automation compared with a manual transmission. 
The benefit of adding more gears 
varies depending on whether the gears are added in the range where most operation occurs. The TIAX 2009 report projected that 8-speed transmissions could incrementally reduce fuel consumption by 2 to 3 percent over a 6- speed automatic transmission, for Class 3–6 box and bucket trucks, refuse haulers, and transit buses.
414We have 
run GEM simulations comparing 5- speed, 6-speed, 7-speed, and 8-speed automatic transmissions where some cases hold the total spread constant, some hold the high end ratio constant, and some hold the low-end ratio constant, where all cases use a third gear lockup and axle ratios are held constant. We have observed mixed results, with some improvements over the highway cruise cycles as high as six percent, and some cases where additional gears increased fuel consumption. As proposed, we are allowing GEM to determine the improvement, where manufacturers will enter the number of gears and gear ratios and the model will simulate the efficiency over the applicable test cycle. The agencies have revised GEM based on comment, and we are confident that it fairly represents the fuel efficiency of transmissions with different gear ratios. Consistent with literature values, we are using engineering calculations to estimate that two extra gears has an effectiveness of one percent improvement during transient driving and two percent improvement during highway driving. Weighting these improvements using our final composite duty cycles (zero improvement at idle), for purposes of setting stringency, we are conservatively estimating that adding two gears will improve vocational vehicle efficiency between 0.9 and 1.7 percent. 
The final Phase 2 GEM has been 
calibrated to reflect a fixed two percent difference between manual transmissions and automated transmissions during the driving cycles (zero at idle). As in the HHD Regional subcategory baseline, manual transmissions simulated in GEM perform two percent worse than similarly-geared AMT. This fixed 
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415For example, see XL Hybrids at http://www.
xlhybrids.com/content/assets/Uploads/XL- 
BoxTruck-US-FLY-8.5x11-0519-LR.pdf, and Crosspoint Kinetics at http://crosspointkinetics.com/members/kinetics-hybrid-partners/ . 416See test procedures at 40 CFR 1037.555. In 
Phase 1, evaluation of hybrid powertrain systems is 
Continued improvement is discussed further in the 
RIA Chapter 2.4. 
Hybrid powertrain systems are 
included under transmission technologies because, depending on the design and degree of hybridization, they may either replace a conventional transmission or be deeply integrated 
with a conventional transmission. Further, these systems are often manufactured by companies that also manufacture conventional transmissions. 
The agencies are including hybrid 
powertrains as a technology on which some of the vocational vehicle standards are predicated. We proposed ten percent overall adoption of strong hybrids by MY 2027, which meant approximately 18 percent adoption in the Multipurpose and Urban subcategories in that model year. 80 FR 40297. We received extensive comments on the ability of the vocational vehicle market to adopt hybrid drivetrains. EDF and Parker both highlighted the successful demonstrations of Parker hydraulic hybrids for refuse applications with effectiveness near 40 percent over refuse duty cycles. Autocar commented that a significant portion of their refuse truck sales have hydrostatic hybrid drives. Fleets such as Pepsico and the City of Bloomington highlighted that they are actively purchasing hybrids. ATA and UPS commented that hybrid technology applications continue to be of interest to the trucking industry, but expressed concern over the high costs that can deter uptake in the market. Eaton commented that a combination of factors is needed to re-ignite the hybrid business: lower battery costs and increased efficiency of the hybrid systems for Class 6–8, lower cost mild hybrid powertrains in Class 3–5, and continued regulatory pull. Eaton says the hybrid market is still very fragile and they do not see market conditions improving for hybrid commercial vehicles except for a few mild hybrids. Securing America’s Future Energy and ACEEE also commented in favor of including mild hybrids as part of the vocational vehicle compliance package. 
After considering all these comments, 
we agree with commenters that mild hybrids are more likely than strong hybrids to succeed initially in the vocational sector, especially outside of the bus market. We are projecting adoption of two types of mild hybrids, defined using system parameters based on actual systems commercially available in the market today.
415NTEA and the Green Truck Association both 
commented that a common way that today’s hybrids are installed is by secondary or intermediate manufacturers. We have taken this into consideration by assuming that some mild hybrid systems will be integrated with an engine sufficient to enable use of an engine stop-start feature, while some mild hybrids will not be integrated and these ‘‘bolt-on’’ systems will only provide transient benefits related to regenerative braking. 
Allison believes that hybrid vehicles 
should be certified on a duty cycle on the same basis as non-hybrid vehicles because the vehicles must perform the same work regardless of the powertrain technology. We agree and the Phase 2 test cycles are the same for conventional and hybrid drivelines. The Sierra Club asked the agencies to consider real world duty cycle data to account for the effectiveness of hybrids for vocational vehicles. Allison says investments for heavy-duty hybrids will be made by component suppliers, not by the vehicle manufacturers. The battery, inverter, and motor suppliers must make investments in addition to the system supplier. In this regard—for a small market like the heavy-duty hybrids—a significant investment, under current conditions, are seen as risky and unlikely to occur according to Allison. Allison commented that even though the transit bus industry has had commercially available hybrids for over a decade, the adoption rate of hybrids in the U.S. transit bus market is only 13.2 percent and that to achieve an overall 5 
percent adoption rate of hybrid technology, the economics of the hybrid ownership would have to substantially change over the period of time covered by this rulemaking. In light of these concerns, we have adjusted our projected adoption rates of hybrid technology as described below in Section V.C.(2)(b)(i). 
We also have reconsidered our 
effectiveness estimation method as a result of comments. Instead of relying on previously published road tests over varying drive cycles, we are applying engineering calculations to account for defined hybrid system capacities and inefficiencies over our certification test cycle. We are using a spreadsheet model that calculates the recovered energy of a hybrid system using road loads of the default baseline GEM vehicles over the ARB Transient test cycle. See RIA Chapter 2.9.3.1.3 to read more about the assumed motor and battery capacity, swing in the state of charge, and system inefficiencies. The effectiveness is 
assumed (conservatively) to be zero for the highway cruise cycles to obtain the projected cycle-weighted effectiveness. For the non-integrated models, the same system was assessed for all weight classes (not scaled up for heavier 
vehicles); however, for the integrated models with stop-start we have scaled up the system specifications to account for the larger road loads, to ensure the projected effectiveness is not decreased for systems on heavier vehicles relative to that projected for lighter vehicles. 
For the non-integrated mild hybrids, 
we are estimating an eight to 13 percent fuel efficiency improvement as measured over the powertrain test, depending on the duty cycle (i.e. Multi- 
purpose or Urban) in GEM for the applicable subcategory. See RIA 2.9.3.1. For the integrated mild hybrids, we have combined the effectiveness calculated for the scaled-up mild hybrid system with the effectiveness of stop- start, described below. Id. 2.9.3.1. These combined effectiveness values range from 18 to 21 percent efficiency improvement, depending on the duty cycle (i.e. Multi-purpose or Urban). 
Even though the actual improvement from hybrids in Phase 2 will be evaluated using the powertrain test, because the model uses the same vehicle test cycle and conservative estimates of realistic configurations, the agencies have concluded it is reasonable to use these spreadsheet-based estimates as a basis for setting stringency in the final rules. 
Based on the public comments from 
hybrid suppliers and other innovators providing evidence of hybrid systems in the market today ranging from prototypes to commercialized, the agencies believe the Phase 2 rulemaking timeframes will offer sufficient lead time to develop, demonstrate, and conduct reliability testing for hybrid technologies to enable market adoptions in the range that we are projecting for the final rules. 
The agencies are working to reduce 
barriers related to hybrid vehicle certification. In Phase 1, there is a significant burden associated with the optional test for demonstrating the GHG and fuel efficiency performance of vehicles with hybrid powertrain systems. If manufacturers wish to earn Phase 1 credit for a hybrid, they must obtain a conventional vehicle that is identical to the hybrid vehicle in every way except the transmission, test both, and compare the results.
416In Phase 2, 
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an option for which advanced technology credits 
are available. 
417California Air Resources Board. Letter from 
Michael Carter to Matthew Spears dated December 29, 2014. CARB Request for Supplemental NO
X 
Emission Check for Hybrid Vehicles. Docket EPA– HA–OAR–2014–0827. 418See Argonne National Laboratory 2009 report, 
Note 411, page 91. manufacturers will conduct powertrain 
testing on the hybrid system itself, and the results of that testing will become inputs to GEM for simulation of the non-powertrain features of the hybrid vehicle, removing a significant test burden. We will continue to work with hybrid suppliers and manufacturers to address other test burden issues, including test procedures to determine a balanced state of charge and number of default configurations needed for the cycle average map. 
Hybrid manufacturers commented 
that meeting the on-board diagnostic requirements for criteria pollutant engine certification continues to be a potential impediment to adoption of hybrid systems. See Section XIII.A.1 for a discussion of regulatory changes to reduce the non-GHG certification burden for engines paired with hybrid powertrain systems. The agencies have also received comments on a letter from the California Air Resources Board requesting consideration of supplemental NO
Xtesting of hybrids.417 
Allison provided comment on CARB’s recommendations, noting that it is not possible to draw conclusions about hybrid vehicles compared with conventional vehicles using the method recommended by CARB. Allison suggests that EPA gather additional data and conduct a future analysis based on data from both low-kinetic intensity and high kinetic intensity vehicles. In the final Phase 2 program, NO
Xemissions 
will be measured and reported as a part of powertrain testing. This will allow EPA to monitor NO
Xperformance and 
identify potential problems long before sales increase to a point at which significant in-use impacts could occur. The information collected will also be used to inform EPA as to the merits of future rulemaking. However, EPA believes that finalizing the approach recommended at this time could represent an undue burden for this emerging technology. 
Based on comments received and 
stakeholder outreach, we have reason to 
believe that some custom chassis manufacturers are better positioned than others to adopt transmission technology to improve fuel efficiency. Most have little or no in-house research capacity, and purchase off-the-shelf transmissions. Some, such as Gillig and Autocar, have partnered with suppliers to successfully implement hybrids on their vehicles. Some bus chassis 
manufacturers are exploring the benefits of applying transmissions with additional gears. In real world driving, vehicles with a lot of transient operation, including custom chassis, can see real fuel savings from adoption of improved transmissions, including those with more efficient gears and advanced shift strategies. We expect that suppliers will continue to develop improved transmissions for vocational vehicles including some custom chassis, and that manufacturers will continue to select transmissions that deliver reliable products to fuel-conscious customers. Specifically, we believe that bus manufacturers will continue to have choices of competing products that offer performance characteristics that improve over time. Below in V.C.(2)(b) we discuss the reasons why we believe that a final Phase 2 program that is largely blind to these transmission- based improvements for custom chassis will avoid adverse unintended consequences. 
(ii) Axles 
The agencies are predicating part of 
the stringency of the final vocational 
vehicle standards on performance of two types of axle technologies. The first is advanced low friction axle lubricants and efficiency as demonstrated using the separate axle test procedure described in the RIA Chapter 3.8 and 40 CFR 1037.560. The agencies received adverse comment on the proposal to assign a fixed 0.5 percent improvement for this technology. In consideration of comments, the agencies are instead assigning default axle efficiencies to all vocational vehicles. Manufacturers may submit test data to over-ride axle efficiency values in GEM. Our cost analysis for the final rulemaking includes maintenance costs of replacing axle lubricants on a periodic basis. See the RIA Chapter 7.1.3. Based on supplier information, some advanced lubricants have a longer drain interval than traditional lubricants. We are estimating the axle lubricating costs for HHD to be the same as for tractors since those vehicles likewise typically have three axles. However, for LHD and MHD vocational vehicles, we scaled down the cost of this technology to reflect the presence of a single rear axle. We expect that improved axle efficiency is technically feasible on all vocational vehicles including custom chassis. However, it’s likely that axle suppliers 
may be more likely to invest in design and lubrication improvements for high sales volume products, such as axles that can serve both tractor and vocational markets. Further, to the extent that extreme duty cycles require 
lubricants with special performance features, it’s likely that the most advanced low-friction lubricants may not be feasible for some custom chassis such as refuse trucks. 
The second axle technology applies 
only for HHD vocational vehicles, which typically are built with two rear axles. Part time 6x2 configuration or axle disconnect is a design that enables one of the rear axles to temporarily disconnect or otherwise behave as if it’s a non-driven axle. The agencies proposed to base the HHD vocational vehicle standard on some use of both part time and full time 6x2 axles. The agencies received adverse comment on the application of the permanent 6x2 configuration for vocational vehicles. The disconnect configuration is one that keeps both drive axles engaged only during some types of vehicle operation, such as when operating at construction sites or in transient driving where traction especially for acceleration is vital. Instead of calculating a fixed improvement as at proposal, the agencies have refined GEM to recognize 
this configuration as an input, and the benefit will be actively simulated over the applicable drive cycle. Effectiveness based on simulations with EPA axle files is projected to be as much as one percent for HHD Regional vehicles. Further information about this technology is provided in RIA Chapter 2.4.5. The feasibility of this technology depends on whether the baseline axle configuration is a 6x4 and whether the vehicle is likely to spend significant amounts of time on the highway. For vocational vehicles, this is largely limited to Regional and Multipurpose HHD vehicles. To the extent that any motor homes and coach buses with GVWR over 33,000 lbs are built with two rear axles, this technology could be technically feasible. However, because these vehicles generally operate on paved roads and may not need the traction of a 6x4, a popular axle configuration for these vehicles is a permanent 6x2. 
(iii) Lower Rolling Resistance Tires 
Tires are the second largest 
contributor to energy losses of 
vocational vehicles, as found in the energy audit conducted by Argonne National Lab.
418The two most helpful 
sources of data in establishing the projected vocational vehicle tire rolling resistance levels for the final Phase 2 standards are the comments from RMA and actual certification data for model 
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419See memorandum dated May 2016 titled, 
Vocational Vehicle Tire Rolling Resistance 
Certification Data. year 2014. At proposal, we projected 
that all vocational vehicle subcategories could achieve average steer tire coefficient of rolling resistance (CRR) of 6.4 kg/ton and drive tire CRR of 7.0 kg/ ton by MY 2027. These new data have informed our analysis to enable us to differentiate the technology projections by subcategory. The RMA comments included CRR values for a wide range of vocational vehicle tires, for rim sizes from 17.5 inches to 24.5 inches, for steer/all position tires as well as drive tires. The RMA data, while illustrating a range of available tires, are not sales weighted. The 2014 certification data include actual production volumes for each vehicle type, thus both steer and drive tire population-weighted data are available for emergency vehicles, cement mixers, school buses, motor homes, coach buses, transit buses, and other chassis cabs. The certification data are consistent with the RMA assessment of the range of tire CRR currently available. We also agree with RMA’s suggestion to set a future CRR level 
where a certain percent of current products can meet future GEM targets. We disagree with RMA that the MY 2027 target should be a level that 50 percent of today’s product can meet. With programmatic averaging, such a level would mean essentially no improvements overall from tire rolling resistance, because today when manufacturers comply on average, half their tires are above the target and half are below. Further, with Phase 2 GEM requiring many more vehicle inputs than tire CRR, manufacturers have many more degrees of freedom to meet the performance standard than they do in Phase 1. In these final rules, the agencies are generally projecting adoption of LRR tires in MY 2027 at levels currently met by 25 to 40 percent of today’s vocational products, on a sales-weighted basis.
419We are 
differentiating the improvement level by weight class and duty cycle, recognizing that heavier vehicles designed for highway use can generally apply tires with lower rolling resistance than other vehicle types, and will see a greater benefit during use. None of the rolling resistance levels projected for adoption in MY 2027 are lower than the 25th percentile of tire CRR on actual vocational vehicles sold in MY 2014. Thus, we believe the improvements will be achievable without need to develop new tires not yet available. Further details are presented in the RIA Chapter 
2.9. 
In simulation, the benefit of LRR tires 
is reflected in GEM differently for vehicles of different weight classes and duty cycles. Based on simulations using the projected tire CRR, the agencies project fuel efficiency improvements by MY 2027 for LRR tires on Regional vocational vehicles between two and three percent, for Multipurpose vehicles between one and three percent, and for Urban vehicles up to one percent. This technology is also feasible on all custom chassis, with similarly larger improvements feasible for coach buses and motor homes with typically regional drive cycles, and similarly smaller improvements feasible for school and transit buses, refuse trucks, and concrete mixers with typically urban drive cycles. 
As proposed, the agencies will 
continue the light truck (LT) tire CRR adjustment factor that was adopted in Phase 1. 80 FR 40299; see generally 76 FR 57172–57174. In Phase 1, the agencies developed this adjustment factor by dividing the overall vocational test average CRR of 7.7 by the LT vocational average CRR of 8.9. This yielded an adjustment factor of 0.87. Because the MY 2014 certification data for LHD vocational vehicles may have included some CRR levels to which this adjustment factor may have already been applied, and because we did not receive adverse comment on our proposal to continue this, the agencies have concluded that we do not have a basis to discontinue allowing the measured CRR values for LT tires to be multiplied by a 0.87 adjustment factor before entering the values in the GEM for compliance. 
In Table V–15, the descriptors 1v 
through 5v refer to levels of rolling resistance that have been identified among the population of tires installed on vocational vehicles certified for MY 2014. Each of these levels is in production today and represents tires that have been fitted on a certified vehicle. The agencies have defined these levels for purposes of estimating the manufacturing costs associated with applying improved tire rolling resistance to vocational vehicles. These levels are not applicable for estimating degrees of improvement or costs of LRR 
tires on tractors, trailers, or HD pickups and vans as part of this rulemaking. Furthermore, these levels do not represent the full range of tire CRR available for vocational vehicles. There are both steer and drive tires on certified vocational vehicles today with CRR ranging from 5 kg/ton to 15 kg/ton. We expect this full range of tires will continue to be available in the market 
well into the future. 
TABLE V–15—D EFINED LEVELS OF  
VOCATIONAL TIRECRR 
Rolling resistance level 
descriptor Range 
min. Range 
max. 
LRR level 1v ........................ 7.5 8.1 
LRR level 2v ........................ 7.0 7.49 
LRR level 3v ........................ 6.6 6.99 
LRR level 4v ........................ 6.3 6.59 
LRR level 5v ........................ 5.8 6.29 
(iv) Workday Idle Reduction 
The Phase 2 idle reduction 
technologies considered for vocational vehicles are those that reduce workday idling, unlike the overnight or driver rest period idling of sleeper cab tractors. Idle reduction technology is one type of technology that is particularly duty- cycle dependent. In light of new information, the agencies have learned that our proposal had mischaracterized 
the idling operation of vocational vehicles, significantly underestimating the extent of this mode of operation, and incorrectly calculating it using a drive idle cycle when significant idling also occurs while parked. As described above in Section V.B.(1), in these final rules we have revised our test cycles to better reflect real world idle operation, including both parked idle and drive idle test conditions. At proposal, we identified two types of idle reduction technologies to reduce workday idle emissions and fuel consumption for vocational vehicles: neutral idle and stop-start. After considering the new duty cycle information and the many comments received, we are basing our final vocational vehicle standards in part on the performance of three types of workday idle reduction technologies: neutral idle, stop-start, and automatic engine shutdown; which we believe are effective, feasible, and cost-effective, as discussed further in this section. 
Neutral idle is essentially a 
transmission technology, but it also requires a compatible engine calibration. Torque converter automatic transmissions traditionally place a load on engines when a vehicle applies the brake while in drive, which we call curb idle transmission torque (CITT). When an engine is paired with a manual or automated manual transmission, the CITT is naturally lower than when paired with an automatic, as a clutch disengagement must occur for the vehicle to stop without stalling the engine. We did not receive adverse comment on our proposal to include this technology in our standard-setting for vocational vehicles. The engineering 
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420See spreadsheet file dated July 2016 titled, 
‘‘FRM_ Vocational-Standards_ GEMpostprocess.xls’’. 
See EPA–HQ–OAR–2014–0827. 
421See Reinhart 2015, Note 345 above. 422See Ford powerstroke guide at https://
www.fleet.ford.com/truckbbas/non-html/ 
DeiselTips/DLSIDLETIMESS.pdf (accessed March 
2016); see also Cummins maintenance schedule, available at http://www.cumminsbridgeway.com/pdf/parts/Recommended _Maintenance_
Schedule.pdf (accessed March 2016). 
423NTEA, 2015 Work Truck Electrification and 
Idle Management Study. 
424We will consider non-tamper-proof AES as off- 
cycle technologies for a lesser credit. required to program sensors to detect 
the brake position and vehicle speed, and enable a smooth re-engagement when the brake pedal is released makes this a relatively low complexity technology that can be deployed broadly. Navistar commented that idle reduction strategies must have sufficient engine, aftertreatment and occupant protections in place such that any fuel 
cost savings are a net benefit for the owner/operator without compromising safety. We agree, and for neutral idle we believe an example of an allowable override is if a vehicle is stopped on a hill. Skilled drivers operating manual transmissions can safely engage a forward gear from neutral when stopped on upslopes with minimal roll-back. With an AT, the vehicle’s computer would need to handle such situations automatically. In addition, engagement of the PTO while driving will be an allowable over-ride condition. In the Phase 2 certification process, transmission suppliers will attest whether the transmission has this feature present and active, and certifying entities will be able to enter Yes or No as a GEM input for the applicable field. The effectiveness of this technology will be calculated using data points collected during the engine test, and the appropriate fueling over the drive idle cycle and the transient cycle will be used. Based on GEM simulations using the final vocational vehicle test cycles, the agencies project neutral idle to provide fuel efficiency improvements up to seven percent for diesel vehicles, and up to two percent for gasoline vehicles, depending on the regulatory subcategory.
420The lesser 
effectiveness for gasoline vehicles is due to lower curb idle transmission torque present in the baseline configurations for gasoline than the diesel vehicles, as documented in the SwRI report.
421 
Neutral idle may be programmed on 
any automatic transmission, and can reasonably be applied for vocational vehicles where this feature would not frequently encounter an over-ride condition. Vehicles with high PTO operation can apply this technology, although they would see reduced effectiveness in use. 
Automatic engine shutdown (AES) is 
an engine technology that is widely available in the market today, but has seen more adoption in the tractor market than for vocational vehicles. Although we did not propose to include this technology, we received many comments suggesting this would be 
appropriate. Some commenters may have conflated the concept of stop-start with AES, such as a comment we received asking us to consider the on- board need to power accessories while the vehicle is in stationary mode. We believe that automatic engine shutdown is effective and feasible for many different types of vehicles, depending on how significant a portion of the work day is spent while parked. Most truck operators are aware of the cost of fuel consumed while idling, and importantly, the wear on the engine due to idling. Engine manufacturers caution owners to monitor the extent of idling that occurs for each work truck and to reduce the oil change interval if the idle time exceeds ten percent of the work day.
422Accordingly, many utility truck 
operators track their oil change intervals in engine hours rather than in miles. 
NTEA provided the agencies with a 
report with survey results on which work truck fleets are adopting AES with backup power, and their reasons for doing so.
423The most common reason 
given in the survey is to allow an engine to shut down and still have vehicle power available to run flashing safety lights. Some vocational vehicles also need to conduct work using a power take-off (PTO) while stationary for hours, such as on a boom truck. The agencies are adopting an allowable AES over-ride for PTO use. Technologies that can reduce fuel consumption during this type of high-load idle are discussed below in V.C.(1)(c)(iii). We are also adopting an allowable AES over-ride if the battery state of charge drops below a safe threshold. This would ensure there is sufficient power to operate any engine-off accessories up to a point where the battery capacity has reached a critical point. Where a vocational vehicle has such extensive stationary accessory demands that an auxiliary power source is impractical or that an over-ride condition would be experienced frequently, we would not consider AES to be feasible. In the Phase 2 certification process, engine suppliers will attest whether this feature is present and tamper-proof, and certifying entities will be able to enter Yes or No as a GEM input for the applicable field.
424As with neutral idle described above, the effectiveness of AES will be calculated in GEM using data obtained through engine testing. The appropriate data points over the parked idle cycle will be used for calculating the fueling. Based on GEM simulations using the final vocational vehicle test cycles, the agencies project AES to provide fuel efficiency improvements ranging from one to seven percent, depending on the regulatory subcategory. 
The agencies proposed to predicate 
the vocational vehicle standards in part on 70 percent adoption of stop-start in MY 2027. We received numerous comments from manufacturers and suppliers with concerns about all aspects of this technology, including its feasibility, its effectiveness, and the lead time to make it commercially available. As discussed above, our assessment of workday idle reduction technologies has been refined since proposal, and part of this refinement includes less reliance on adoption of stop-start than at proposal. 
Stop-start is a technology that requires 
an integration between engine and vehicle systems, and is seeing increasing acceptance in today’s passenger vehicle market. The agencies are aware that for a vocational vehicle’s engine to turn off during workday driving conditions, there must be a minimal reserve source of energy to maintain engine-protection and safety functions such as power steering, transmission pressure, engine lubrication and cooling, among others. As such, stop-start systems can be viewed as having a place on the low- cost end of the hybridization continuum. Effenco commented that a minimum of additional hardware is required to deliver enough power to frequently and seamlessly restart a large engine as well as to keep accessories and equipment operational with the engine turned off. Navistar commented persuasively that coking can occur if the cooling and lubricating oil is removed. The agencies therefore would consider electrified water and oil pumps to be part of the stop-start technology package. However, we must be clear to distinguish this technology from the AES described above. Stop-start technologies will be recognized only over the drive idle cycle and the transient cycle in GEM, not the parked 
idle cycle (whereas AES is recognized only over the parked idle cycle). Accordingly, the purpose of the additional hardware is to protect the engine for short duration stops such as at traffic lights, not to power accessories while the vehicle is parked. 
Volvo commented that stop-start is 
not feasible for HHD engines (generally 11L and larger), and claims engine 
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425Maxwell Technologies, How Ultracapacitors 
Improve Starting Reliability for Truck Fleets, 2016. 
426See comment submitted by Effenco describing 
such a system designed for a refuse packer. 
427See phone log for L. Steele, conversation with 
B. Van Amburg, May 2016. development costs will be very high 
since stop-start cycling tests can only be accelerated by a limited amount before the failure mechanisms are altered. However, their objections relate more to the challenges of stop-start for HHD engines and do not actually show the technology to be infeasible. Although we disagree with Volvo that stop-start is infeasible for HHD engines, we understand it may require more development time and cost than for engines in lighter vehicles. It’s possible that some time may be needed for development work where manufacturers elect to shift away from reliance on batteries for starting the engine and begin to rely instead on ultracapacitors, which do not have the same problems with cold weather operation and long term fatigue as do batteries.
425Volvo 
and EMA commented that main and rod bearings as well as other bearing surfaces would need to be strengthened and improvements may be needed for starters and lubrication systems. We agree with commenters that this type of development work would likely be part of bringing this technology to the vocational vehicle market, and thus we have included costs for upgrades similar to those described for all sizes of engines, not just those over 11L. In the event that an engine manufacturer needs to delay adoption of stop start to roll these changes in to a planned platform redesign, we believe our relatively modest adoption rate of 30 percent in MY 2027 will accommodate this. Descriptions of costs for stop-start may be found in the RIA Chapter 2.11.6.6. 
We are not aware of stop-start systems 
that are commercially available for conventional vocational vehicles today, but this feature is available as part of some current hybrid systems. We are aware of one supplier who is demonstrating today a capacitor-based stop-start system with on-board electronics sufficient to protect a HHD engine and even power a PTO.
426 
Furthermore, other manufacturers and suppliers are researching this.
427 
Therefore we are confident heavy-duty stop-start systems for conventional vehicles will be feasible in the time frame of Phase 2. Where stop-start is relied upon as part of a certified configuration with components installed by a secondary manufacturer, 
these will be subject to specifications and installation instructions of the 
certifying manufacturer. 
In response to comments, we are 
adopting some permissible over-ride conditions under which a stop-start system may either restart sooner than otherwise or not shut down an engine. Navistar, Waste Management and others commented that vehicles with a significant power take-off (PTO) load will not be able to accommodate start/ stop technology. As with neutral idle, we agree that engagement of the PTO while driving should be an allowable over-ride condition, as there are some vehicles that must conduct PTO work while underway. For example, cement mixers must continually rotate the drum and refuse trucks routinely compact their load throughout their neighborhood collection activity. Additional over-rides are discussed in the RIA Chapter 2.9.3.4. If a manufacturer designs a system that does not need as many over-rides due to additional electrification or other on- board systems, then an application for off-cycle credit may be submitted, to recognize a greater effectiveness. The regulations at 40 CFR 1037.660 specify the allowable over-rides. 
The effectiveness of stop-start as 
recognized in GEM will be engine- dependent. Engines with high emissions/fuel consumption at idle will see greater reductions. Also, vehicles that idle frequently will see greater reductions. Based on GEM simulations using the final vocational vehicle test cycles, the agencies project stop-start to provide fuel efficiency improvements up to 14 percent for diesel vehicles, and up to 11 percent for gasoline vehicles, depending on the regulatory subcategory. See RIA 2.9.3.4. The data points for calculating the fueling over the transient and drive idle cycles are obtained from the engine map, and vehicle certifiers may input Yes or No when running GEM, to indicate whether the engine shuts off within five seconds of zero vehicle speed with the service brake applied. Allison commented that GEM should calculate fueling only for a couple seconds before assuming the engine shuts down in a stop-start system. Navistar suggested that we recognize that some fleets—e.g. heavy 
haul, refuse, mixer trucks and tow trucks—may elect to have this feature set as a programmable parameter to ensure maximum safety is maintained. We believe that five seconds is appropriate because we expect a wide variety of stop-start solutions to be deployed in the vocational vehicle market, and we anticipate modest use of 
over-ride conditions. Setting a shorter duration before shutdown could over- estimate the reductions achieved by this 
technology in use. We believe this is a fair way to represent that the system may not have the designed effectiveness under all conditions. 
As with the other idle reduction 
technologies described above, stop-start can reasonably be applied for vocational vehicles where this feature would not frequently encounter an over-ride condition. Vehicles with very little driving in transient conditions or with high PTO operation can apply this technology, although they would see reduced effectiveness in use. Chassis manufacturers certifying refuse trucks to the optional custom chassis standards may enter Yes in the input field in GEM for stop-start and the effectiveness will be computed based on the default 350 hp engine with 5-speed HHD automatic transmission.. Manufacturers opting to certify refuse trucks to the primary standards will have an option to be recognized for enhanced stop-start systems through the powertrain test See RIA 2.9.3.4 and 2.9.5.1.4. 
The agencies received comments from 
Allison Transmission where they observed a seven percent NO
Xco- 
benefit of stop-start idle reduction technology on transit buses. Daimler also commented that it is investigating the potential for improving heat retention in the SCR system via stop- start, but because of early stages of development it cannot verify or quantify actual benefits. The agencies also conducted independent NO
Xtesting of 
engines at idle; however, the data are not conclusive enough for the agencies to quantify the NO
Xco-benefits of 
vocational workday idle reduction as part of this rulemaking. 
(v) Weight Reduction 
The agencies are predicating the final 
vocational vehicle standards in part on 
use of material substitution for weight reduction. The method of recognizing 
this technology is similar to the method used for tractors. The agencies have created a menu of vocational chassis components with fixed reductions in pounds that may be entered in GEM when substituting a component made of a more lightweight material than the base component made of mild steel. According to the 2009 TIAX report, there are freight-efficiency benefits to reducing weight on vocational vehicles that carry heavy cargo, and tax savings potentially available to vocational vehicles that remain below excise tax weight thresholds. This report also estimates that the cost effectiveness of weight reduction over urban drive cycles is potentially greater than the cost effectiveness of weight reduction 
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428See email to L. Steele from D. Richman dated 
March 19, 2015 with attachments. 429See phone log for L. Steele, conversation with 
Terex (Aug 2015) and meeting with Autocar (April 
2016). for long haul tractors and trailers. We 
are adopting as proposed a GEM allocation of half the weight reduction to payload and half to reduced chassis weight. We did not receive comment suggesting a different weight allocation. The menu of components available for a vocational vehicle weight reduction in GEM is presented in Section V.D.1 and in the RIA Chapter 2.9, and is in the regulations at 40 CFR 1037.520. It includes fewer options than proposed, due to persuasive comments from Allison that aluminum transmission cases and clutch housings are standard for automatic transmissions. The American Iron and Steel Institute (AISI) commented that light weight values for high strength steel should be adjusted upward, citing light-duty vehicle weight reduction approaches using high strength steel and saying these improvements should apply to the heavy-duty sector as well. AISI also commented against the inclusion of any light-weight components as a compliance mechanism for vocational vehicles without technical data to support the weight saving values. At proposal, we based our weight reduction values for class 8 vocational vehicles on the values adopted for use in certifying tractors in Phase 1. We proposed to scale these values down for lighter weight vehicles based either on number of axles or other attributes based on engineering judgment. We also considered information supplied by expert members of the Aluminum Transportation Group.
428The final rules 
reflect revised weight reduction values in response to the comments from AISI, and in further consideration of information provided by the Aluminum Transportation Group. We were unable to make use of the additional references submitted by AISI as part of this standard-setting process, either because the technology requires redesign rather than material substitution, or because we did not see a way to apply the light- duty information to heavy-duty vehicles. For setting stringency, however, we do not rely on any values in the lookup table except those for aluminum wheels (although these 
performance-based standards may be achieved in the manner deemed most cost-effective by manufacturers). The stringency of the final vocational vehicle standards for custom chassis transit buses and vehicles in the primary program is based in part on use of aluminum wheels in 10 positions on 3-axle vocational vehicles (250 lbs) and in 6 wheel positions on 2-axle vocational vehicles (150 lbs). Based on the TIAX report and experience with the tractor program, the agencies are confident that manufacturers who choose to incorporate weight reduction on vocational vehicles will have a number of feasible material substitution choices at the chassis level, which could add up to weight savings of hundreds of pounds. The agencies do not have information about any subset of vocational vehicles that would be unable to adopt aluminum wheels, thus our projected adoption rates are much higher than at proposal. Our projected adoption rate is revised upward based on the determination that the technology package is smaller (fewer pounds removed than at proposal) and that aluminum wheels are widely available and feasible. We have learned through stakeholder outreach that weight-sensitive applications such as ready-mix concrete and refuse have already extensively applied weight reduction technologies, for freight efficiency reasons.
429Therefore the 
agencies have not predicated the standards for these custom chassis on further weight reduction. 
Based on the default payloads in 
GEM, and depending on the vocational vehicle subcategory, the agencies estimate a reduction of 250 lbs would offer a fuel efficiency improvement of up to one percent for HHD vehicles, and a reduction of 150 pounds would offer a fuel efficiency improvement up to 0.8 percent for MHD vehicles, and up to 1.5 percent for LHD vehicles. See RIA 2.9.3.5. 
The agencies received comment that 
the HD Phase 2 program should recognize the enhanced benefit of weight reduction of rotating components, but the agencies lack sufficient data to incorporate the necessary programming in GEM to enable this feature. Manufacturers wishing to obtain credit for lightweight components beyond those on the menu in the regulations or for use of lightweighting technologies that are more effective than we have projected, may apply for off-cycle credits. 
(vi) Electrified Accessories 
Although we did not propose to allow 
pre-defined credit for electrified 
accessories as was proposed for tractors, we received comment requesting that this be allowed for vocational vehicles. As discussed above, the agencies are projecting that some electrified accessories will be necessary as part of the development of stop-start idle 
reduction systems for vocational vehicles. The technology package for vocational stop-start includes costs for high-efficiency alternator, electric water pump, electric cooling fan, and electric oil pump. However, because the GEM algorithm for determining the fuel benefit of stop-start does not account for any e-accessories, vehicles certified with stop-start are also eligible to be certified using an improvement value in the e-accessories column. 
Daimler, ICCT, Bendix, Gentherm, 
Navistar, Odyne, and CARB asked the agencies to consider electric cooling fans, variable speed water pumps, clutched air compressors, electric air compressors, electric power steering, electric alternators, and electric A/C compressors. ICCT cautioned that certain accessories would be recognized over an engine test and credit should not be duplicated at the vehicle level. Bosch suggested that high-efficiency alternators be considered, and suggested use of a standard component-level test for alternators to determine their efficiency, and establishment of a minimum efficiency level that must be attained. Although there are industry- accepted test procedures for measuring the performance of alternators, we do not have sufficient information about the baseline level performance of alternators to define an improved level that would qualify for a benefit at certification. We are not able to set a fixed improvement for electric cooling fans or clutched accessories due to similar challenges related to baselines and defining the qualifying technology. In consideration of ICCT’s comment, we are not including water pumps and oil pumps among the components eligible for a fixed improvement because we believe that our engine test procedure will recognize improvements that would be seen in the real world from electrifying these. Thus, we believe it is appropriate to offer a fixed technology improvement for use of electric power steering and an electric A/C compressor as an input to GEM. 
The agencies have conducted 
modeling in GEM to compare configurations with different default accessory loads, and have demonstrated there is a measurable effect of reducing 1 kW of accessory load for each vocational subcategory (see RIA 2.9.3.6). The agencies have incorporated information from this GEM modeling with information from comments provided by ICCT, the TIAX 2009 technology report, CARB’s Driveline Optimization report, and the 2010 NAS 
report to assign fixed improvement values for the defined technologies as 
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430TIAX 2009, pp. 3–5. shown in Table V–16. These values are 
consistent with the TIAX study that used 2 to 4 percent fuel consumption improvement for accessory electrification, with the understanding that electrification of accessories will have more effect in short haul/urban applications and less benefit in line- haul applications.
430The RIA Chapter 
2.9 explains how these effectiveness 
values were obtained. 
TABLE V–16—E FFECTIVENESS OF VOCATIONAL E-ACCESSORIES  
Technology Effectiveness 
% Subcategories 
Electric A/C Compressor ............................................................ 0.5 HHD. 
1.0 MHD & LHD. 
Electric Power Steering .............................................................. 0.5 Regional. 
1.0 Multipurpose & Urban. 
Optimization and improved pressure 
regulation may significantly reduce the 
parasitic load of the water, air and fuel pumps. Electrification may result in a reduction in power demand, because electrically-powered accessories (such as the air compressor or power steering) operate only when needed if they are electrically powered, but they impose a parasitic demand all the time if they are engine-driven. In other cases, such as cooling fans or an engine’s water pump, electric power allows the accessory to run at speeds independent of engine speed, which can reduce power consumption. Electrification of accessories can individually improve fuel consumption, regardless of whether the drivetrain is a strong hybrid. Some vocational vehicle applications have much higher accessory loads than is assumed in the default GEM configurations. In the real world, there may be some vehicles for which there is a much larger potential improvement available than those listed above, as well as some for which electrification is not cost-effective. To date, accessory electrification has been associated only with hybrids, although CalStart commented they are optimistic that accessory electrification will become more widespread among conventional vehicles in the time frame of Phase 2. 
Electric power steering (EPS) or 
Electrohydraulic power steering (EHPS) provides a potential reduction in CO2 emissions and fuel consumption over hydraulic power steering because of reduced overall accessory loads. This eliminates the parasitic losses associated with belt-driven power steering pumps which consistently draw load from the engine to pump hydraulic fluid through the steering actuation systems even when the wheels are not being turned. EPS is an enabler for all vehicle hybridization technologies since it provides power steering when the engine is off. EPS is feasible for most vehicles with a standard 12V system. Some heavier vehicles may require a 
higher voltage system which may add cost and complexity. 
Manufacturers wishing to obtain 
credit for technologies that are more 
effective than we have projected, or technologies beyond the scope of this defined technology improvement, may apply for off-cycle credits. 
(vii) Tire Pressure Systems 
TPMS 
The agencies did not propose to base 
the vocational vehicle standards on the 
performance of tire pressure monitoring systems (TPMS). However, we received comment that we should consider this technology. See discussion in Section III.D.1.b. In addition to comments related to tractors and trailers, RMA commented that TPMS can also apply to the class 2b–6 vehicles, and if the agencies add TPMS to the list of recognized technologies, that this choice should also be made available to class 2b–6 vehicles. Bendix commented that TPMS is a proven product, readily available from a number of truck, bus, and motor coach OEMs. Autocar commented that TPMS is useful for refuse truck applications. Tirestamp said that TPMS is ideal for trucks and buses that are unable to apply ATIS due to difficulties plumbing air lines externally of the axles. The agencies find these comments to be persuasive. As a result, we are finalizing vocational vehicle standards that are predicated on the performance of TPMS in all subcategories, including all custom chassis except emergency vehicles and concrete mixers. Available information indicates that it is feasible to utilize TPMS on all vocational vehicles, though systems for heavy vehicles in duty cycles where the air in the tires becomes very hot must be ruggedized so that the sensors are protected from this heat. Such devices are commercially available, though they cost more. To account for this in our analysis, we have projected a lower adoption rate for TPMS in Urban vehicles than for Regional or Multipurpose vehicles, rather than by increasing the cost and applying an equal adoption rate. We are assigning a fixed improvement in GEM for use of this technology in vocational vehicles of one percent for Regional vehicles including motor coaches and RV’s (the same as for tractors and trailers) and 0.9 percent for Multipurpose, Urban, and other custom chassis vocational vehicles, recognizing that the higher amount of idle is likely to reduce the effectiveness for these vehicles. These values will be specified as GEM inputs in the column designated for tire pressure systems. 
ATIS 
The agencies did not propose to base 
the vocational vehicle standards on the 
performance of automatic tire inflation systems (ATIS), otherwise known as central tire inflation (CTI). However, we did receive comment indicating that it is feasible on some vocational vehicles. Air CTI commented that central tire inflation is not only feasible but enhances safety on vehicles such as dump trucks and heavy haul vehicles that need higher tire pressures under certain driving conditions, such as when loaded, but need lower tire pressures when running empty or operating off-road. Tirestamp commented that ATIS can be plumbed externally for trucks and buses, but such systems have a propensity for damage and Autocar has provided information about how much extra weight this plumbing adds to the chassis. ATA commented that some onboard air pressure systems may not be able to pressurize tires sufficiently for very heavy vehicles. The primary vocational vehicle standards are not predicated on any adoption of this because the agencies do not have sufficient information about which chassis will have an onboard air supply for purposes 
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431Team 1-Refrigerant Leakage Reduction: Final 
Report to Sponsors, SAE, 2007. 432Specifically, EPA is adopting CO 2, N2O, and 
CH 4emission standards for new heavy-duty engines 
over an EPA specified useful life period (See 
Section II). of an air suspension or air brakes. ATIS 
would logically only be adopted for vehicles that already need an onboard air supply for other reasons. Comments received for custom chassis were supportive of standards predicated on ATIS for buses with air suspensions. These comments are again persuasive. As a result, we are basing the optional standards for refuse trucks, school buses, coach buses, and transit buses in part on the adoption of ATIS. Although many motor homes have onboard air supply for other reasons making ATIS technically feasible, it is sufficiently costly that it is not practically feasible. Furthermore, for the same reasons stated above about the disadvantages of installing external plumbing for ATIS on some trucks and buses, we have determined it is not feasible for emergency vehicles or concrete mixers. Nonetheless, we are allowing vocational vehicles including all custom chassis to obtain credit for the performance of ATIS through a GEM input with a fixed improvement of 1.2 percent for Regional vehicles including motor coaches and RV’s (the same as for tractors and trailers) and 1.1 percent for Multipurpose, Urban, and other custom chassis vocational vehicles, recognizing that the higher amount of idle is likely to reduce the effectiveness for these vehicles. These values will be specified as GEM inputs in the column designated for tire pressure systems. See discussion in Section III.D.1.b for our reasoning behind this effectiveness value. 
(viii) HFC Refrigerant From Cabin Air 
Conditioning (A/C) Systems 
Manufacturers can reduce direct A/C 
leakage emissions by utilizing leak-tight components. EPA’s HFC direct emission leakage standard is independent of the CO
2vehicle standard. Manufacturers 
may choose components from a menu of leak-reducing technologies sufficient to comply with the standard, as opposed to using a test to measure performance. See 76 FR 57194. A discussion of comments regarding use of low global warming potential refrigerants and EPA’s responses to those comments can be found in Section I.F of this Preamble. 
In Phase 1, EPA adopted a HFC 
leakage standard to assure that high- 
quality, low-leakage components are used in each air conditioning system installed in HD pickup trucks, vans, and combination tractors (see 40 CFR 1037.115). We did not adopt a HFC leakage standard in Phase 1 for systems installed in vocational vehicles. In the final Phase 2 program, as proposed, EPA is extending the HFC leakage standard to all vocational vehicles. Beginning in the 2021 model year, vocational vehicle air conditioning systems with a 
refrigerant capacity of greater than 733 grams must meet a leakage rate of 1.50 percent leakage per year and systems with a refrigerant capacity of 733 grams or lower meet a leakage standard of 11.0 grams per year. EPA has determined that an approach of having a leak rate standard for lower capacity systems and a percent leakage per year standard for higher capacity systems will result in reduced refrigerant emissions from all air conditioning systems, while still allowing manufacturers the ability to produce low-leak, lower capacity systems in vehicles which require them. 
Research has demonstrated that 
reducing A/C system leakage is both highly cost-effective and technologically feasible. The availability of low leakage components is being driven by the air conditioning program in the light-duty GHG rule which began in the 2012 model year and the HD Phase 1 rule that began in the 2014 model year. The cooperative industry and government Improved Mobile Air Conditioning program has demonstrated that new- vehicle leakage emissions can be reduced by 50 percent by reducing the number and improving the quality of the components, fittings, seals, and hoses of the A/C system.
431All of these 
technologies are already in commercial use and exist on some of today’s systems, and EPA does not anticipate any significant improvements in sealing technologies for model years beyond 2021. However, EPA has recognized some manufacturers utilize an improved manufacturing process for air 
conditioning systems, where a helium leak test is performed on 100 percent of all o-ring fittings and connections after final assembly. By leak testing each fitting, the manufacturer or supplier is verifying the o-ring is not damaged during assembly (which is the primary source of leakage from o-ring fittings), and when calculating the yearly leak rate for a system, EPA will allow a relative emission value equivalent to a ‘seal washer’ to be used in place of the value normally used for an o-ring fitting, when 100 percent helium leak testing is performed on those fittings. 
We received comments from CARB 
and Daimler in support of applying these leakage standards to vocational vehicles. Daimler specifically expressed support for excluding A/C systems used to cool the cargo area of trucks, as well as for allowing helium testing as a compliance option. Thus, we are adopting these provisions as proposed. EMA commented with concerns about the burden of certifying A/C systems that are installed by secondary manufacturers. Section V.D.2 discusses how we have addressed the concerns related to secondary manufacturers. We also received comments from RVIA asking for clarification whether the cargo area exclusion also applied to A/ C units that cool the living space of recreational vehicles. In response, we are adding clarifying language to the regulations at 40 CFR 1037.115 excluding A/C systems that are not powered by the vehicle’s propulsion engine. 
The A/C system leakage control costs 
presented in the RIA Chapter 2.9 and 2.11 are applied to all heavy-duty vocational vehicles. EPA views these costs as minimal and the reductions of potent GHGs to be easily feasible and reasonable in the lead times provided by the final rules. 
(b) Engine Technologies Considered in 
Vehicle Standard-Setting 
Section II explains the technical basis 
for the agencies’ proposed separate engine standards. The agencies are not predicating the vocational vehicle standards on different diesel engine technology packages than those presumed for compliance with the separate diesel engine standards. However, for each model year of the Phase 2 standards, the agencies are predicating the SI-powered vocational vehicle standards on a gasoline engine technology package that includes additional technologies beyond those presumed for compliance with the MY 2016 gasoline engine standard. Put another way, the stringency of certain of the vocational vehicle standards, and those for vehicles using SI engines in particular, reflect in part improvements in engine efficiency which are not measured in the engine standard or in engine certification. 
The primary vocational vehicle 
standards vary depending on whether the engines powering those vehicles are compression-ignition or spark- ignition.
432As in Phase 1, this is not the 
case for the custom chassis standards, because GEM uses a default engine that is the same for every regulated custom chassis type, regardless of the actual engine being installed. As described above in Section II, the Phase 2 vehicle certification tool, GEM, requires manufacturers certifying to the primary standards to enter specific engine performance data, where emissions and 
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433See Section II.D.5 for an explanation of which 
engine architecture will need to meet which 
standard. 
434As noted in Section II.B.2 above, 
manufacturers also have greater flexibility to meet a vehicle standard if engine improvements can be evaluated as part of compliance testing. fuel consumption profiles will differ 
significantly depending on the engine’s architecture.
433 
As explained in Section II.A.2, 
engines will continue to be certified over the FTP test cycle via direct testing, not GEM simulation. The FTP test cycle that is applicable for bare vocational engines is very different than the test cycles for vocational vehicles in GEM. The FTP is a very demanding transient cycle that exercises the engine over its full range of capabilities. In contrast, the cycles evaluated by GEM measure emissions over more frequently used engine operating ranges. The ARB Transient vehicle cycle represents city driving, and the highway cruise cycles measure engine operation that is closer to steady state. Each of these cycles is described in the RIA Chapter 3.4.2. A consequence of recognizing engine performance at the vehicle level is that further engine improvements (i.e. improvements measureable by duty cycles that more precisely represent driving patterns for specific subcategories of vocational vehicles) can be evaluated as components of a technical basis for a vocational vehicle standard.
434For this reason, the 
agencies considered whether any different engine technologies should be included in the feasibility analysis for the vehicle standards (and potentially, in the standard stringency). 
We did not propose to predicate any 
diesel vocational vehicle standard on additional engine technology, including engine waste heat recovery (WHR). We do not believe this technology would show significant benefit in vocational vehicle applications due to their driving cycles, which have fewer highway miles 
than tractors. Thus, the final vocational vehicle standards assume that diesel engines perform at the level of the certified engine configuration. 
The agencies received extensive 
comment on our assessment of SI engine technologies, and how these could be included in the vocational vehicle technology packages. We predicated the proposed MY 2027 SI-powered vocational vehicle standards on additional friction reduction, for a 0.6 percent fuel efficiency improvement. UCS, EDF, NRDC, and ICCT ask the agencies to rely on the 2015 SwRI study suggesting 8 percent improvement is possible. UCS highlights packages #16 and #22 of the SwRI report for the agencies’ further consideration. These packages were assembled by SwRI to simulate the combined performance of engine technologies over some well- known vehicle drive cycles. Because none of the technical data referenced by these commenters provides information on how these technologies perform over the HD gasoline engine FTP test procedure, the agencies are considering these to be comments on the GEM-based vocational vehicle standards, not comments on the separate FTP-based SI engine standard. Please see Section II.D.2(b) of this Preamble for the agencies’ response to comments on the stringency of the separate SI engine standard. 
SwRI package #16 applies variable 
valve actuation and exhaust gas recirculation to a 3.5 liter V6 engine. SwRI package #22 applies stoichiometric direct gas injection, exhaust gas recirculation, dual cam phasers, and advanced friction reduction to a 6.2 liter V8 engine. All of the SwRI packages compare the future vehicle performance to a pre-Phase 1 baseline, thus counting all the improvements already presumed in the MY 2016 engine standard, so the delta between what the commenter seeks and what the agencies proposed is considerably less than initially appears (and than the commenter appeared to believe). The agencies’ default SI engine map for setting the SI-powered vocational vehicle standards is a MY 2016 6.8 liter V8 engine. The RIA Chapter 2.9.1 presents the EPA default map that meets the MY 2016 engine standard. We are adhering to the proposed approach of recognizing SI engine improvements only in the vocational vehicle standard. In response to comments, the agencies are adopting final vehicle-level standards for SI- powered vocational vehicles that are predicated in part on adoption of cylinder deactivation in addition to the advanced friction reduction reflected in the proposal, both of which have incremental costs beyond those needed to meet the separate FTP-based engine standard, and both of which will be recognized over the GEM vehicle cycles. Indeed, cylinder deactivation would not be expected to be recognized at all over the engine FTP cycle (another reason the improvement is reflected in the final vehicle standard). As proposed, the effectiveness and adoption rate of Level 2 engine friction reduction yields a fuel efficiency improvement of 0.6 percent. By adding 30 percent adoption of cylinder deactivation with a vehicle- cycle average effectiveness of 1 percent, and accounting for a dis-synergy factor of 0.9, this yields an overall package 
effectiveness of 0.8 percent. Upon consideration of comments and the data in the SwRI reports, we are not including EGR as a technology for stringency purposes. EGR is potentially feasible, is not already presumed to be adopted in the 2016 engine standard, and may possibly be recognized over the GEM vehicle cycles to some extent. However, we did not have sufficient data to confidently project an effectiveness or adoption rate for this technology on vocational SI engines. Further, the Phase 2 HD pickup truck and van standards are not predicated on any adoption of EGR technologies for SI vehicles. The RIA Chapter 2.9.1 describes how each of the SI engine technologies are expected to perform over the GEM vehicle cycles, as well as the method for projecting that the fuel efficiency improvement will be 0.8 percent compared to the baseline SI vehicle performance. 
With respect to standards for engines 
used in custom chassis, we understand that engines designed for heavy-duty emergency vehicles are generally higher-emitting than other engines. However, because we are maintaining a separate engine standard and regulatory flexibility such as ABT, fire apparatus manufacturers will be able to obtain engines that, on average, meet the Phase 2 engine standards. The agencies further recognize that the engine map inputs to GEM in the primary program could pose a difficulty for emergency vehicle manufacturers. If we required engine- specific inputs then these manufacturers will have to apply extra vehicle technologies to compensate for the necessary but higher-emitting engine. The agencies are therefore not recognizing vehicle-specific engine performance as part of the vehicle standard for emergency vehicles (although the standards for emergency vehicles and custom chassis do presume use of a certified Phase 2 engine). Manufacturers of these vehicles must install an engine that is certified to the applicable separate Phase 2 engine standard. However, under the custom chassis program emergency vehicle manufacturers need not follow the otherwise applicable Phase 2 approach of entering an engine map in GEM. Instead, use of a custom chassis subcategory identifier will instruct GEM to simulate the vehicle using an EPA default engine. 
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(c) Technologies the Agencies Assessed 
But Did Not Use In Standard-Setting 
(i) Aerodynamics 
The agencies did not propose to 
include aerodynamic improvements as a 
basis for the Phase 2 vocational vehicle standards. However, we did request comment on an option to allow credits for use of aerodynamic devices such as fairings on a very limited basis. We received public comments from AAPC in support of offering this as an optional credit, with a suggestion to allow this option for a wide range of vehicle sizes, and suggesting that the grams per ton- mile benefit could be scaled down for larger vehicles. CARB commented in support of a Phase 2 program that would include use of aerodynamic improvements as a basis for the stringency, suggesting that a large fraction of the vocational vehicle fleet could see real world benefits from use of aerodynamic devices. Because we do not have sufficient fleet information to establish a projected application rate for this technology, we are not basing any of the final standards for vocational vehicles on use of aerodynamic improvements. See 80 FR 40303. In consideration of comments, however, we are adopting provisions for vocational vehicles to optionally receive an improved GEM result by certifying use of a pre-approved aerodynamic device, and are expanding eligibility criteria from the relatively narrow criteria proposed. 
Based on testing supported by CARB, 
the agencies have developed a list of specific aerodynamic devices with pre- defined improvement values (in delta C
DA units), as well as criteria regarding 
which vehicles are eligible to earn credit in this manner. See Chapter 2.9.4.1 of the RIA. In response to comments, we 
are allowing a wide range of vehicles to be eligible to use this option. Regional vocational vehicles in any weight class may use this option, subject to restrictions on the size of the chassis (see 40 CFR 1037.520). The degree of change in C
DA for each pre-approved 
device has been set at conservative values due to the small number of configurations tested and the uncertainty inherent in those results. Manufacturers wishing to receive credit for other aerodynamic technologies or on other vehicle configurations may seek credit using the test procedures described in 40 CFR 1037.527. Manufacturers using this credit provision may enter the pre-defined delta C
DA as an input to GEM, and the 
simulation will determine the effectiveness over the duty cycle. Using this approach, we do not need to set a scaled benefit for different sizes of 
vehicles. When the vehicle weight class and duty cycle is specified, a default chassis mass and payload are simulated in GEM. When the pre-defined delta C
DA is entered, the simulation returns a 
resulting improved performance with respect to the specified chassis configuration. GEM will logically return a smaller improvement for heavier vehicles. 
The final Regional composite duty 
cycle in GEM for vocational vehicles has a weighted average speed of 38 mph, increased from the average speed at proposal due to a heftier 56 percent composite weighting of the 65 mph drive cycle. The agencies have learned from the NREL duty cycle analysis that vocational vehicles with operational behavior of a regional nature accumulate more miles at highway speeds than previously assumed. 
Using GEM simulation results, the 
agencies estimate the fuel efficiency benefit of improving the C
DA of a Class 
6 box truck by 11 percent (0.6 m2delta 
CDA off of a default of 5.4 m2) at 
approximately five percent over the Regional composite test cycle. This same delta C
DA simulated in GEM on a 
class 8 Regional vocational vehicle results in an overall improvement of less than four percent because the default C
DA in GEM for class 8 
vocational vehicles is 6.86 m2so the 
change in C DA is only nine percent. 
Although in actual operation the added weight of aerodynamic fairings may 
reduce the operational benefits of these technologies when driving at low speeds, the agencies are not applying any weight penalty as part of the certification process for vocational aerodynamic devices. 
As described in the NPRM, we are 
requiring chassis manufacturers employing this option to provide assurances to the agencies that these devices will be installed as part of the certified configuration, even if the installation is completed by another entity. We received many comments on the requirements for secondary manufacturers as they apply for vocational aerodynamics as well as other technologies that may be specified by a chassis manufacturer but installed later. See Section I.F.2 and Section V.D.2 for further discussion of delegated assembly issues. 
(ii) Full Electric Trucks 
Given the high up-front costs and the 
developing nature of this technology, 
the agencies do not project fully electric vocational vehicles to be widely commercially available in the time frame of the final rules. For this reason, the agencies have not based the Phase 
2 standards on adoption of full-electric vocational vehicles. We received many comments on electric trucks and buses. Specifically, EEI provided information on the total cost of ownership for electric trucks, and some applications may see attractive long term cost scenarios for electric trucks or buses, when considering maintenance savings. While we are not predicating the final vocational vehicle standards on adoption of full electric trucks or buses, we have reinstated an advanced technology credit multiplier, in response to comment. See Section I.C.1.(b) for a discussion of credit multipliers. 
To the extent this technology is able 
to be brought to market in the time frame of the Phase 2 program, there is currently a certification path for these chassis from Phase 1, as described in EPA’s regulations at 40 CFR 1037.150 and NHTSA’s regulations at 49 CFR 535.8. 
(iii) E-PTO 
Although the primary program does 
not simulate vocational vehicles over a 
test cycle that includes PTO operation, the agencies are adopting a revised hybrid-PTO test procedure. See 76 FR 57247 and 40 CFR 1037.540. Recall that we regulate vocational vehicles at the incomplete stage when a chassis manufacturer may not know at the time of certification whether a PTO will be installed or how the vehicle will be used. Chassis manufacturers may rarely know whether the PTO-enabled vehicle will use this capability to maneuver a lift gate on a delivery vehicle, to operate a utility boom, or merely to keep it as a reserve item to add value in the secondary market. For these reasons, it would not be fair to require every vocational vehicle to certify to a standard test procedure with a PTO 
cycle in it. Thus, we are not basing the final standards on use of technology that reduces emissions in PTO mode. 
There are products available today 
that can provide auxiliary power, usually electric, to a vehicle that needs to work in PTO mode for an extended time, to avoid idling the main engine. There are different designs of electrified PTO systems on the market today. Some designs have auxiliary power sources, typically batteries, with sufficient energy storage to power an onboard tool or device for a short period of time, and are intended to be recharged during the workday by operating the main engine, either while driving between work sites, or by idling the engine until a sufficient state of charge is reached that the engine may shut off. Other designs have 
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435National Renewable Energy Laboratory July 
2016, ‘‘Characterization of PTO and Idle Behavior 
for Utility Vehicles,’’ NREL/TP–5400–66747. sufficient energy storage to power an 
onboard tool or device for many hours, and are intended to be recharged as a plug-in hybrid at a home garage. In cases where a manufacturer can certify that a PTO with an idle-reduction technology will be installed either by the chassis manufacturer or by a second stage manufacturer, the hybrid-PTO test cycle may be utilized by the certifying manufacturer to measure an improvement factor over the GEM duty cycle that otherwise applies to that vehicle. In addition, the delegated assembly provisions will apply (see Section V.D). See RIA Chapter 3.7.4 for a discussion of the revisions to the PTO test cycle. 
The agencies will continue the 
hybrid-PTO test option that was available in Phase 1, with a few revisions. See the regulations at 40 CFR 1037.540. The calculations recognize fuel savings over a portion of the test that is determined to be charge- sustaining as well as a portion that is determined to be charge-depleting for systems that are designed to power a work truck during the day and return to the garage where recharging from an external source occurs during off-hours. The agencies requested comment on this idea, and received comment from Odyne relating to the population and energy storage capacity of plug-in e-PTO systems, for which a charge-depleting test cycle may be more appropriate. We also partnered with DOE–NREL to characterize the PTO operation of over 80 trucks with over 1,500 total operating days, and our final regulations include a utility factor table based on these data for use in determining the effectiveness of a hybrid PTO system.
435 
Manufacturers wishing to conduct testing as specified may apply for off- cycle credits derived from e-PTO or 
hybrid PTO technologies. 
(2) Projected Vehicle Technology 
Package Effectiveness and Cost 
(a) Baseline Vocational Engine and 
Vehicle Performance 
The baseline vocational vehicle 
configurations for each of the nine regulatory subcategories for CI-powered and six SI-powered vehicles are described in RIA Chapter 2.9.1, as well as the seven baseline custom chassis configurations. The agencies set the baseline rolling resistance coefficient for the 2017 vocational vehicle fleet at 7.7 kg/metric ton, which assumes that 100 percent of tires meet the Phase 1 standard. In the agencies’ Phase 2 baseline 
configurations, we need to specify 
transmission type, gear number, and gear ratios, as well as axle ratios and tire sizes because these were all defaults in Phase 1. Phase 1 GEM modeled all vehicles with a manual transmission, but as explained elsewhere, the majority of vocational vehicles in today’s U.S. fleet have automatic transmissions. By specifying a mix of manual and automatic transmissions with different sets of gears in the baseline, we are not applying technology beyond what is needed to comply with Phase 1, we are merely defining an appropriate set of baselines. We do not consider these specifications to represent technology that improves fuel efficiency beyond Phase 1, it is merely a better representation of today’s fleet than the Phase 1 GEM that had 100 percent default manual transmissions. In the Regional HHD diesel subcategory, the baseline is a weighted average of two vehicle specs: 95 percent being a 455 hp 
engine paired with a manual transmission with ten forward gears, and five percent being a 350 hp engine paired with a 6-speed automatic transmission. The HHD Multipurpose subcategory is a weighted average of three vehicle specs: 80 percent being a 350 hp engine paired with a 6-speed automatic transmission, 10 percent being a 455 hp engine paired with a 10- speed manual transmission, and 10 percent being a 350 hp engine paired with a 10-speed manual. The automatic transmissions specified in the LHD, MHD, and HHD Regional and Multipurpose subcategories have six forward gears in the baseline, while automatic transmissions in the Urban subcategories have five forward gears in the baseline. This is based on market research, stakeholder outreach, and comments received on the NODA. No vehicle-level efficiency-improving technology is included in the baseline vehicles, nor in the agencies’ analyses for the no-action reference case. Specifically, we have assumed zero adoption rates for other types of transmissions, other numbers of gears, idle reduction, and technologies other than Phase 1 compliant LRR tires in both the nominally flat baseline and the dynamic baseline reference cases. Technology adoption rates for Alternative 1a (nominally flat baseline) can be found in the RIA Chapter 2.11. Chapter 2.11.8 presents the adoption rates for tires on vocational vehicles with different levels of rolling resistance, including the 100 percent adoption rate of tires with Level 1 CRR 
in the reference case and in model years preceding Phase 2. In this manner, we have defined a reference vocational vehicle fleet that meets the Phase 1 standards and includes reasonable representations of vocational vehicle technology and configurations. 
The agencies note that the baseline 
performance derived for the final rules varies between regulatory subcategories—as noted above, this is one of the reasons the agencies are adopting multiple subcategories with discrete standards. The range of performance at baseline is due to the range of attributes and modeling parameters, such as transmission characteristics, final drive ratio, and vehicle weight, which were selected to represent a range of performance across this diverse segment. The agencies received persuasive comment regarding the appropriateness of the baseline configurations, and have made revisions accordingly. For example, we have reduced the LHD default aerodynamic drag area from 5.4 to 3.4 square meters. We are confident these adequately represent a reasonable range of vocational chassis configurations currently manufactured in the US. Details of the vehicle configurations, including reasons why they are reasonably included as baseline technologies, are discussed in the RIA Chapter 2.9.2. 
At proposal the agencies adjusted the 
vocational vehicle GEM numerical baselines using assumptions about the sales mix in the vocational fleet before applying the reductions from technologies. 80 FR 40308. In this process, we developed proposed baseline values that we believed would minimize inappropriate incentives for manufacturers to certify chassis in an inappropriate subcategory. The proposed approach included testing each baseline vehicle over all three duty cycles and applying weighted average adjustments to each GEM output to create normalized baselines, 80 FR 40308. We received adverse comment on this approach from many commenters—indeed, no commenter supported this ‘‘normalization’’ approach. The proposed normalization approach was an attempt to adjust for instances where the agencies’ information on baseline configurations was not fully complete. Most commenters either opposed or were confused by the proposed normalization process. As explained in this Section V., the agencies are adopting final standards for vocational vehicles using 
the same methodology as for all the other standards in this rulemaking, and 
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436See memorandum dated July 2016 titled, 
‘‘Summary of Comments on Vocational Vehicle 
Baselines,’’ see Docket EPA–HQ–OAR–2014–0827. 437Michael Ross, Validation Testing for Phase 2 
Greenhouse Gas Test Procedures and the Greenhouse Gas Emission Model (GEM) for Medium and Heavy-Duty Engines and Powertrains, Final 
Report to EPA, Southwest Research Institute, June 2016. so are neither normalizing nor 
equalizing any of the data relating to either the baseline or the standard. (Equalization is discussed separately in Section V.C.(2)(d) below.) The agencies have received a great deal of information from manufacturers since proposal which rectify weaknesses in our baselines, and make any normalization unnecessary.
436In the 
final rules we have applied other methods (chiefly certain equipment- based constraints) to avoid creating inappropriate incentives for manufacturers to certify chassis in inappropriate subcategories. The final standards are calculated by applying improvements as described below in Section V.C.(2)(c) to the GEM results presented in Table V–17 and Table V– 18—the same methodology as used to develop the other Phase 2 standards. 
Diesel engines used in vocational 
vehicles can be either Light, Medium, or Heavy Heavy-duty Diesel engines. The Light Heavy-duty Diesel engines typically range between 4.7 and 6.7 liters displacement. The Medium Heavy-duty Diesel engines typically have some overlap in displacement with the Light Heavy-duty Diesel engines and range between 6.7 and 9.3 liters. The Heavy Heavy-duty Diesel engines typically are represented by engines between 10.8 and 16 liters. Because of these differences, the GEM simulation of baseline vocational CI engines includes four engines—one for LHD, one for MHD, and two for HHD. Detailed descriptions can be seen in Chapter 4 of the RIA. These four engine models have been employed in setting the vocational vehicle baselines, as described in the RIA Chapter 2.9.1. 
The four baseline diesel engines 
represent fuel consumption improvements beyond currently available engines to achieve the performance level of a 2017 model year diesel engine, as described in the RIA Chapter 2.9.1. Using the values for compression-ignition engines, the baseline performance of vocational vehicles is shown in Table V–17. 
TABLE V–17—B ASELINE VOCATIONAL VEHICLE PERFORMANCE WITHCI E NGINES  
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 Heavy 
heavy-duty 
Class 8 
Baseline Emissions Performance in CO 2gram/ton-mile 
Urban .......................................................................................................................... ................. 482 332 338 
Multi-Purpose .................................................................................................................. ............. 420 294 287 
Regional ....................................................................................................................... ................ 334 249 220 
Baseline Fuel Efficiency Performance in gallon per 1,000 ton-mile 
Urban .......................................................................................................................... ................. 47.3477 32.6130 33.2024 
Multi-Purpose .................................................................................................................. ............. 41.2574 28.8802 28.1925 
Regional ....................................................................................................................... ................ 32.8094 24.4597 21.6110 
The agencies have developed a model 
in GEM of a MY 2016-compliant 
gasoline engine. The agencies received comments on the process for mapping gasoline engines for simulation purposes, as well as information about the power rating and displacement that 
should be considered as a baseline SI engine for vocational vehicle standard- setting purposes. Upon consideration of comments, and based on information obtained through testing at Southwest Research (see Chapter 5.5 of the SwRI report), we are adopting revised test procedures as described in the RIA Chapter 3.1 that apply for mapping of both SI and CI engines.
437 
The baseline performance levels for 
vocational vehicles powered by SI engines were derived using the EPA default fuel map described in the RIA Chapter 2.9.1, for a 6.8 liter, V–8, 300 hp engine. We have used the same engine rating and map for all weight 
classes of SI vocational vehicles. This is because SI engines are not certified with a regulatory structure that calls for declaring an intended service class that is associated with a vehicle weight class. The agencies requested comments on the merits of setting distinct numerical standards for HHD vocational vehicles powered by SI engines, as well as comments on an alternative approach that would have required any class 8 SI vocational vehicles to certify to the standards for CI powered HHD vocational vehicles, or to the MHD 
standards for SI vocational vehicles. In response to comments expressing concern about orphaned vehicles as well as concerns about mismatched engine and vehicle useful life, the agencies are not finalizing distinct HHD SI vocational vehicle standards. We are finalizing six subcategories for SI vocational vehicles: Three LHD and 
three MHD. Where a manufacturer wishes to certify a gasoline SI vocational vehicle with a GVWR over 33,000 lbs, the final regulations allow that vehicle to be certified in one of the MHD vehicle subcategories. Where a manufacturer wishes to certify an alternative-fueled vocational vehicle with a GVWR over 33,000 lbs, the regulations at 40 CFR 1036.108 specify whether that vehicle should be treated as SI or CI for purposes of certification to the final Phase 2 standards. See Section II.D.5 of this Preamble for a 
discussion of these provisions. 
Table V–18 presents the baseline 
performance level for each weight class computed by GEM by calculating the work done by the default engine to move the GEM reference vehicles over the test cycles. 
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TABLE V–18—B ASELINE VOCATIONAL VEHICLE PERFORMANCE WITHSI E NGINES  
Duty cycle Light 
heavy-duty 
Class 2b–5 Medium 
heavy-duty 
Class 6–7 (and 
Gasoline c8)a 
Baseline Emissions Performance in CO 2gram/ton-mile 
Urban .......................................................................................................................... ................................. 502 354 
Multi-Purpose .................................................................................................................. ............................. 441 314 
Regional ....................................................................................................................... ................................ 357 275 
Baseline Fuel Efficiency Performance in gallon per 1,000 ton-mile 
Urban .......................................................................................................................... ................................. 56.4870 39.8335 
Multi-Purpose .................................................................................................................. ............................. 49.6230 35.3325 
Regional ....................................................................................................................... ................................ 40.1710 30.9441 
Note: 
aVocational vehicles with GVWR over 33,000 lbs powered by alternate fueled engines must certify to the vehicle standard corresponding with 
the applicable engine standard. 
(b) Technology Packages for Derivation 
of Final Standards 
Prior to developing the numerical 
values for the final standards, the agencies projected the mix of new technologies and technology improvements that will be feasible within the available lead time. We note that for some technologies, the adoption rates and effectiveness may be very similar across subcategories. However, for other technologies, either the adoption rate, effectiveness, or both differ across subcategories. Where a technology performs differently over different test cycles, these differences are reflected in the derivation of the stringency of the standard. As discussed in Section I.C.1, we assume manufacturers will incorporate appropriate compliance margins for all measured GEM inputs. In other words, they will declare values slightly higher than their measured values. As discussed in Section II.D.5, compliance margins associated with fuel maps are likely to be approximately one percent. For tire rolling resistance, our feasibility rests on the Phase 1 standards, consistent with our expectation that manufacturers will continue to incorporate the compliance margins they considered necessary for Phase 1. With respect to optional axle and/or transmission power loss maps, we believe manufacturers will need very small compliance margins. These power loss procedures require high precision so measurement uncertainty will likely be on the order of 0.1 percent of the transmitted power. All of these margins are reflected in our projections of the emission levels that will be technologically feasible, as well as the associated costs. 
In the package descriptions that 
follow, individual technology costs are not presented, rather these can be found 
in the RIA Chapter 2.9 and 2.11. Section V.C.(2)(d) includes the costs estimated for packages of technologies the agencies project can be applied to vocational vehicles to meet the final Phase 2 standards. 
(i) Transmission Packages 
The agencies project an adoption rate 
of 50 percent in MY 2021, 60 percent in 
MY 2024, and nearly 70 percent in MY 2027 of transmissions with improved gear efficiencies, with inputs over-riding the GEM defaults obtained over the separate transmission efficiency test. We are projecting an adoption rate of 10 percent in MY 2021, 20 percent in MY 2024, and nearly 30 percent in MY 2027 of advanced shift strategies, with demonstration of improvements recognized over the separate powertrain test. 
We are predicating the Phase 2 
standards on zero adoption of added gears in the HHD Regional subcategory, because it is modeled with a 10-speed transmission, and vehicles already using that number of gears are not expected to see any real world improvement by increasing the number of available gears. For the Multipurpose and Urban HHD subcategories, the MY 2021 projected adoption of adding gears is 5 percent, increasing to 10 percent for MY 2024 and MY 2027. We are projecting 10 
percent of adding two gears in each of the other six subcategories for MY 2021, increasing to 20 percent for MY 2024 and MY 2027. Commenters supported the inclusion of this technology as part of the basis for the standards. Allison commented that they have configured an 8-speed vocational transmission. Eaton’s new MHD dual clutch transmission has seven forward gears. There is also a likelihood that suppliers of 8-speed transmissions for HD pickups and vans may sell some into the LHD 
vocational vehicle market. 
We are also predicating the optional 
custom chassis standards for school and coach buses in part on adoption of transmissions with additional gears. In MY 2021, this adoption rate is five percent, increasing to 10 percent in MY 2024 and 15 percent in MY 2027. Manufacturers who certify these vehicles to the primary standards will use GEM to model the actual gears and gear ratios; however, manufacturers using custom chassis regulatory subcategory identifiers will not have this flexibility. The agencies have estimated the cycle-average benefit of adding an extra gear for school buses (modeled as MHD Urban vehicles) at 0.9 percent and coach buses (with 6 gears in the baseline) at 1.7 percent; therefore, manufacturers using custom chassis regulatory subcategory identifiers for these vehicles will be permitted to enter these pre-defined improvement values at the time of certification. 
Based on comment regarding our 
regulatory baselines, both the HHD Regional and HHD Multipurpose subcategories now have manual transmissions in the baseline configuration. For these vehicles, the agencies project upgrades to automated transmissions such as either AMT, DCT, or automatic, at an adoption rate of 30 percent in MY 2021, 50 percent in MY 2024, and 80 percent in MY 2027 for Regional vehicles. For Multipurpose, beginning with 20 percent manuals in the baseline, the adoption rate of automated transmissions is five percent in MY 2021 and 20 percent in MY 2024. Consistent with our projections of technology adoption, the regulations require that any vocational vehicles with manual transmissions must be 
certified as Regional in MY 2024 and beyond. This progression of 
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438See meeting log for proposed rule, specifically 
the April 2014 meeting with Dana. https://
www.regulations.gov/document?D=EPA-HQ-OAR- 2014–0827–0702 transmission automation is consistent 
with the agencies’ projection of 10 percent manuals and 90 percent automated transmissions in the day cab tractor subcategories in MY 2027. See Table III–13. HHD vocational vehicles in regional service have many things in common with day cab tractors, including the same assumed engine size and typical transmission type, and a similar duty cycle. Thus, it is reasonable for the agencies to make similar projections about the fraction of automated vs manual transmissions adopted over the next decade among these sectors. Also consistent with tractors, GEM simulates each of these with a two percent fixed effectiveness improvement over the performance of the MT in the baseline. To the extent any of these transmissions provide additional effectiveness over the GEM cycles with actual OEM data entered, it is not considered in the stringency of the vocational vehicle HHD Regional standard (but would be recognized at certification). The agencies have been unable to characterize the relative effectiveness of DCT compared with AT sufficiently to apply it as a technology on which stringency is predicated. This is consistent with the public comment on this issue: Daimler did not support inclusion of DCT as a technology with different effectiveness than AMT, and Allison did not support treatment of either DCT or AMT as different as AT. 
In the seven subcategories (i.e. all of 
the remaining subcategories) in which automatic transmissions are the base technology, the agencies project that ten percent of the HHD vehicles will apply an aggressive torque converter lockup strategy in MY 2021, and 30 percent in the LHD and MHD subcategories. These adoption rates are projected to increase to 20 percent for HHD and 40 percent for LHD and MHD in MY 2024. We project adoption of aggressive torque converter lockup for HHD automatics of 30 percent in MY 2027, and 50 percent for LHD and MHD. 
In setting the standard stringency, we 
have projected that non-integrated (bolt- on) mild hybrids will not have the function to turn off the engine at stop, while the integrated mild hybrids will have this function. The agencies have estimated the effectiveness for vehicles certified in the Urban subcategories will achieve as much as 13 percent improvement, and integrated systems that turn off at stop will see up to 21 percent improvement depending on the subcategory. We have also projected zero hybrid adoption rate (mild or otherwise) by vehicles in the Regional 
subcategories, expecting that the benefit of hybrids for those vehicles will be too low to merit use of that type of technology. However, there is no fixed hybrid value assigned in GEM and, for any vehicles utilizing hybrid technology, the actual improvement over the applicable test cycle will be determined by powertrain testing, which would likely reflect some benefit of hybrids on Regional vehicles. By the full implementation year of MY 2027, the agencies are projecting an overall vocational vehicle adoption rate of 12 percent mild hybrids, which we estimate will be 14 percent of vehicles certified in the Multi-Purpose and Urban subcategories (six percent integrated and eight percent non- integrated). We are projecting a low adoption rate in the early years of the Phase 2 program, zero integrated hybrid systems and two percent of the bolt-on systems in these subcategories in MY 2021, and three percent integrated mild hybrids in MY 2024 for vehicles certified in the Multi-Purpose and Urban subcategories, plus 5 percent non-integrated mild hybrids in MY 2024. Based on our assumptions about the populations of vehicles in different subcategories, these hybrid adoption rates are about two percent overall in MY 2021 and six percent overall in MY 2024. 
Navistar commented with concerns 
that the agencies may be double counting some of the improvements of deep integration. For example, the addition of a gear to a transmission may reduce the added benefit of deep integration, as the transmission may already achieve a more optimal operation state more often due to the greater number of gears. The agencies have been careful to project adoption rates and effectiveness of transmission technologies in a way that that avoids over-estimating the achievable reductions. For example, as we developed the packages, we reduced the adoption rate of advanced shift strategy by the adoption rate of integrated hybrids, and we reduced the adoption rate of transmission gear efficiency by the amount of non-integrated hybrids. This is because we do not project that any driveline will undergo testing over both the powertrain test and the separate transmission efficiency test. Because we have projected adoption of combinations of transmission technologies in some subcategories, the sum of adoption rates of individual transmission technologies may exceed 100 percent in some cases. However, the effectiveness values have not been summed because we agree with the commenter that we should not double count benefits. Instead of summing the combined efficiencies, we combine multiplicatively as described in Equation V–1, below. Thus, we have fairly accounted for dis-synergies of effectiveness where multiple technologies are applied to a similar vehicle system. 
Custom chassis manufacturers have 
provided compelling comment that the absence of recognition in the certification process of improved transmission technology will not deter them from its adoption. Therefore, although some types of improved transmissions are feasible for some custom chassis, these vehicles are typically assembled from off-the-shelf parts in low production volumes. For most components, this is not a significant obstacle. However, this dynamic can limit their access to the most advanced transmission technologies. Transmission manufacturers would generally be willing to supply advanced transmissions they developed for a larger customer, but would be less likely to invest in developing a special low volume transmission for the custom chassis. Similar circumstances would apply for hybrids. Further, for the reasons described above about non- representative drivelines in the baseline configurations, we believe that allowing these to be certified with a default driveline is a reasonable program structure. For school buses and others, if a manufacturer wishes to be recognized beyond the levels described for adopting improved transmissions, it has the option of certifying to the primary standards. Nevertheless, technology improvements that some of these manufacturers will include based on market forces (after they have been introduced into the market as a result of the primary program) will likely result in actual in-use improvements for many these vehicles beyond what is projected by the standards. 
(ii) Axle Packages 
The agencies project that 10 percent 
of vocational vehicles in all 
subcategories will adopt high efficiency axles in MY 2021, 20 percent in MY 2024, and 30 percent in MY 2027. Fuel efficient lubricant formulations are widespread across the heavy-duty market, though advanced synthetic formulations are currently less popular.
438Axle lubricants with 
improved viscosity and efficiency- enhancing performance are projected to 
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439See Vehicle Valuation Services Quick 
Reference Guide, available at. http://www.vvsi.com/ 
training/TrainingGuide.pdf, (accessed June 2014), the draft RIA at Chapter 2.9.2, and Docket ID EPA– 
HQ–OAR–2014–0827–0434. 440See memorandum on tire data, Note 419, 
above. be widely adopted by manufacturers in 
the time frame of Phase 2. Such formulations are commercially available and the agencies see no reason why they could not be feasible for most vehicles. Nonetheless, we have refrained from projecting full adoption of this technology. The agencies do not have specific information regarding reasons why axle manufacturers may specify a specific type of lubricant over another, and whether advanced lubricant formulations may not be recommended in all cases. The agencies received adverse comment on allowing fixed credit for use of high efficiency axles, whether from lubrication or other mechanical designs. In response, we are adopting a separate axle efficiency test, which can be used as an input to GEM to over-ride default axle efficiency values. The low overall adoption rate 
indicates that we expect axle suppliers to only offer high-efficiency axles for their most high production volume products, especially those that can serve both the tractor and vocational market. Therefore, we believe it is unlikely that high-efficiency axles will be adopted in custom chassis applications. Because we are no longer offering a fixed improvement for this technology as at proposal, this is only available for vocational vehicles that are certified to the primary program. 
The agencies estimate that 10 percent 
of HHD Regional vocational vehicles and five percent of HHD Multipurpose vehicles will adopt part time 6x2 axle technology in MY 2021. This technology 
is most likely to be applied to Class 8 vocational vehicles (with 2 rear axles) that are designed for frequent highway trips. The agencies project a 20 percent adoption rate for HHD Regional and 15 percent adoption rate for HHD Multipurpose for part time 6x2 axle technologies in MY 2024. In MY 2027, we project 30 percent adoption of part time 6x2 for HHD Regional and 25 percent for HHD Multipurpose. We are establishing a custom chassis baseline configuration for coach buses with a 6x2 axle, in consideration of comments from UCS and manufacturers stating this is the standard axle configuration for these vehicles. If a HHD coach bus is sold with a 6x4 or part time 6x2 axle, the manufacturer must enter the as-built axle configuration as a GEM input. This is true whether the vehicle is in the primary program or if it is certified to the custom chassis standard. Because the optional custom chassis standard assumes a 6x2 axle in the coach bus baseline, manufacturers may only qualify to obtain a reduced GEM result 
from use of the 300 pound weight reduction value (specified in 40 CFR 1037.520 associated with use of a permanent 6x2 axle) when certifying coach buses to the primary standards. 
(iii) Tire Packages 
The agencies estimate that the per- 
vehicle average level of rolling 
resistance from vocational vehicle tires could be reduced by up to 13 percent for many vehicles by full implementation of the Phase 2 program in MY 2027, based 
on broader adoption of vocational vehicle tires currently available. We estimate this will yield reductions in fuel use and CO
2emissions of up to 3.3 
percent for these vehicles. All of our estimates of vehicle-level tire CRR improvements employ a weighted average using an assumed axle load distribution of 30 percent on the steer tires and 70 percent on the drive tires, as was proposed.
439The projected 
adoption rates of tires with improved CRR for chassis in the primary program are presented in Table V–19. The levels noted in the table are defined above in Table V–15. By applying the assumed axle load distribution, the estimated vehicle CRR improvement projected as part of the MY 2021 standards ranges from 5 to 8 percent, which we project will achieve up to 1.9 percent reduction 
in fuel use and CO
2emissions, 
depending on the vehicle subcategory. The agencies estimate the vehicle CRR improvement in MY 2024 will range from 5 to 13 percent, yielding reductions in fuel use and CO
2 
emissions up to 3.2 percent, depending on the vehicle subcategory. 
The agencies believe that these tire 
packages recognize the variety of tire purposes and performance levels in the vocational vehicle market, and maintain choices for manufacturers to use the most efficient tires (i.e. those with 
lowest rolling resistance) only where it makes sense given these vehicles’ differing purposes and applications. 
TABLE V–19—P ROJECTED LRR T IREADOPTION RATES  
Regional Multipurpose Urban 
Steer Drive Steer Drive Steer Drive 
2021 HHD 100% LRR 5v .. 100% LRR 2v .. 100% LRR 5v .. 100% LRR 2v .................... 100% LRR 4v .. 100% LRR 1v. 
2021 MHD 100% LRR 3v .. 100% LRR 1v .. 100% LRR 3v .. 100% LRR 1v .................... 100% LRR 3v .. 100% LRR 1v. 
2021 LHD 100% LRR 3v .. 100% LRR 3v .. 100% LRR 3v .. 100% LRR 3v .................... 100% LRR 2v .. 100% LRR 2v. 
2024 HHD 100% LRR 5v .. 100% LRR 3v .. 100% LRR 5v .. 100% LRR 2v .................... 100% LRR 4v .. 100% LRR 1v. 
2024 MHD 100% LRR 5v .. 100% LRR 3v .. 100% LRR 3v .. 50% LRR 1v, 50% LRR 2v 100% LRR 3v .. 100% LRR 1v. 
2024 LHD 100% LRR 5v .. 100% LRR 3v .. 100% LRR 3v .. 100% LRR 3v .................... 100% LRR 2v .. 100% LRR 2v. 
2027 HHD 100% LRR 5v .. 100% LRR 3v .. 100% LRR 5v .. 100% LRR 3v .................... 100% LRR 5v .. 100% LRR 2v. 
2027 MHD 100% LRR 5v .. 100% LRR 3v .. 100% LRR 5v .. 100% LRR 3v .................... 100% LRR 3v .. 50% LRR 1v, 50% LRR 2v. 
2027 LHD 100% LRR 5v .. 100% LRR 3v .. 100% LRR 5v .. 100% LRR 3v .................... 100% LRR 3v .. 50% LRR 2v, 50% LRR 3v. 
Table V–20 presents the projected 
adoption rates of LRR tires for custom 
chassis. As noted above in Section V.C.(1)(a)(iii), the adoption rates generally represent improvements in the range of the 25th to 40th percentile using data from actual vehicles in each application that were certified in MY 2014. A summary of these data is provided in a memorandum to the docket.
440An exception to this is 
emergency vehicles. The final emergency vehicle standards reflect adoption of tires that progress to the 50th percentile by MY 2027, using steer and drive tire data for certified emergency vehicles. At these adoption rates, manufacturers need not change any of the tires they are currently fitting on emergency vehicles, and they will comply on average. 
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TABLE V–20—P ROJECTED LRR T IRE 
ADOPTION RATES FOR CUSTOM  
CHASSIS  
MY 2021 MY 2027 
Steer Drive Steer Drive 
Coach ..... 100% 
LRR 
4v.100% 
LRR 
4v.100% 
LRR 
5v.100% 
LRR 
5v. 
RV .......... 100% 
LRR 
5v.100% 
LRR 5v.100% 
LRR 5v.100% 
LRR 
5v. 
School .... 100% 
LRR 
4v.100% 
LRR 2v.100% 
LRR 5v.100% 
LRR 4v. 
Transit .... 100% 
LRR 1v.100% 
LRR 1v.100% 
LRR 3v.100% 
LRR 3v. 
Refuse .... 100% 
LRR 1v.100% 
LRR 1v.100% 
LRR 
3v.100% 
LRR 
3v. 
Mixer ...... 100% 
LRR 2v.100% 
LRR 
1v.100% 
LRR 
3v.100% 
LRR 
2v. 
Emer-
gency.100% 
LRR 
2v.100% 
LRR 1v.100% 
LRR 4v.100% 
LRR 1v. 
(iv) Idle Reduction Packages 
In these rules, the adoption rate of 
AES for HHD Regional vehicles is 40 
percent in MY 2021, 80 percent in MY 2024, and 90 percent in MY 2027. This 
is because these vehicles have driving patterns with a significant amount of parked idle, and the vast majority have relatively modest accessory demands such that only a few would have such large demands for backup power that turning the engine off while parked would not be feasible. For all weight 
classes of Regional vehicles except coach buses, the neutral idle and stop start adoption rates remain zero in all model years because these vehicles have 
driving patterns with such a small amount of transient driving that this drive-idle technology would not likely provide real world benefits. For coach buses we are predicating the optional custom chassis standard in part on adoption of neutral idle for several reasons. First, according to Volvo, we are underestimating the amount of transient time for these vehicles by applying only a 20 percent weighting of the transient cycle instead of 25 percent as noted in their comment. Second, we estimate that neutral idle is a low cost technology that would easily pay for itself with the miles accumulated by coach buses. Finally, in the custom chassis program manufacturers are able to qualify for a reduced emission rate in GEM through selection of neutral idle even if the transmission architecture inherently functions with neutral idle such as with an AMT or DCT. The Regional vehicles carry a 40 percent, 80 percent, and 90 percent adoption rate of AES in MYs 2021, 2024, and 2027 respectively because these vehicles are not projected to apply any other idle reduction technology and as long as large accessory loads are not required this technology is widely feasible. As reflected in the Multipurpose and Urban duty cycles with an overall composite 
test weighting of zero speed operation of 50 percent with 25 percent composite weighting of the parked idle cycle, idle reduction is a significant technology for these vehicles. We are projecting 30 percent adoption of AES in all weight classes of Multipurpose and Urban vocational vehicles in MY 2021, increasing to 60 percent in MY 2024 and 70% in MY 2027. This is less than for Regional because we expect a larger fraction of vehicles in these subcategories will need to run PTO or other accessories while parked, such that fewer will be able to reasonably apply the low-cost AES that we have identified in this rulemaking. Because we are considering stop-start and neutral idle to be mutually exclusive on a per-vehicle basis, the sum of these two technologies does not exceed 90 percent in MY 2027, and gradually ramps up to this level from the 50 to 60 percent range in MY 2021. Neutral idle adoption rates are greater in the early years because we expect this will not need much lead time, if any. An exception to the 90 percent maximum adoption rate is transit buses, where we believe all vehicles of this type can reasonably apply some form of drive idle reduction technology. The adoption rates of idle reduction technologies for vocational vehicles in MY 2027 is presented in 
Table V–21. 
TABLE V–21—MY 2027 A DOPTION RATES OF IDLEREDUCTION TECHNOLOGIES  
Technology Heavy heavy-duty Medium heavy-duty Light heavy-duty 
Regional Multi- 
purpose Urban Regional Multi- 
purpose Urban Regional Multi- 
purpose Urban 
Neutral Idle ................................ 0 70 70 0 60 60 0 60 60 
Stop-Start .................................. 0 20 20 0 30 30 0 30 30 
AES ........................................... 90 70 70 90 70 70 90 70 70 
Although it is possible that a vehicle 
could have both neutral idle and stop- 
start, our stringency calculations only consider emissions reductions where a vehicle either has one or the other of these technologies. The final GEM input file allows users to apply multiple idle reduction technologies within a single vehicle configuration. 
Because we have included costs to 
maintain engine protection during periods of shut-off, as well as over-rides to recognize instances where it may not be safe to shut off an engine, we believe stop-start can safely be applied at the rates described above in the time frames described. Also, because we have defined two idle cycles where the automatic engine shutoff technology addresses the condition of being parked with the brake off, we believe this alleviates many of the concerns expressed by commenters about stop- start. We believe many commenters were (erroneously) imagining that stop- start systems would be required to function during periods of extended parking. 
We agree with commenters that stop- 
start is not feasible for emergency vehicles and concrete mixers. We further believe that stop-start would not provide any real world benefit for coach buses or motor homes. However, for school buses, transit buses, and refuse trucks, we believe stop-start is feasible and likely to result in real world benefits. The only custom chassis standards that we are basing on adoption of AES is school buses, because for the others, we believe the simple shutdown timer would be likely to encounter an over-ride condition frequently enough to yield a very small benefit from this technology. To make AES practical for a coach or transit bus for example, a much larger auxiliary power source would be needed than the one projected as part of this rulemaking. Although many school buses have voluntarily adopted idle reduction strategies for other reasons, we do not believe many have tamper-proof automatic shutdown systems. 
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TABLE V–22—C USTOM CHASSIS WORKDAY IDLEADOPTION RATES  
Technology MY AES NI Stop-start 
Coach ............................................................................................................... 2021 ...... .................. 40 ........................
2027 ........................ 70 ........................
School .............................................................................................................. 2021 30 60 5 
2027 70 60 30 
Transit .............................................................................................................. 2021 ..... ................... 60 10 
2027 ........................ 70 30 
Refuse .............................................................................................................. 2021 ...... .................. 30 0 
2027 ........................ 50 20 
As described above, the agencies are 
excluding refuse trucks that do not 
compact waste from the optional custom chassis vocational vehicle standards. We believe trucks that do not compact 
waste have sufficiently low PTO operation (usually only while parked) to make application of drive idle reduction technologies (and other technologies projected for regular vocational chassis) quite feasible. Front-loading refuse collection vehicles tend to have a relatively low number of stops per day as they tend to collect waste from central locations such as commercial buildings and apartment complexes. Because these have a relatively low amount of PTO operation, we expect stop-start will be reasonably effective for these vehicles. Rear-loading and side- loading neighborhood waste and recycling collection trucks are the refuse trucks where the largest number of stop- start and neutral idle over-ride conditions are likely to be encountered. Because chassis manufacturers, even those with small production volumes and close customer relationships, do not always know whether a refuse truck chassis will be fitted with a body designed for front loading, rear loading, or side loading, we are applying an adoption rate of 20 percent stop-start in 2027 to refuse trucks certified as custom chassis. In the case where a chassis manufacturer certifies a refuse truck to the primary standards under the HHD Urban subcategory, the MY 2027 adoption rate of stop-start is also 20 percent as shown in Table V–21. The stringency in both cases assumes a sufficiently capable stop-start system to not require an excessive use of over- rides. Manufacturers opting to certify refuse trucks to the primary standards will have an option to be recognized for enhanced stop-start systems through the powertrain test. 
It may take some minor development 
effort to apply neutral idle to high- torque automatic transmissions designed for the largest vocational vehicles. Based on stakeholder input, the designs needed to avoid an uncomfortable re-engagement bump when returning to drive from neutral 
may require some engineering refinement as well as some work to enable two-way communication between engines and transmissions. Nonetheless, this technology should be available in the near term for many vehicles and is low cost compared to many other technologies we considered. Commenters asked for over-rides such as when on a steep hill and we agree and are adopting this provision. 
For the reasons described above, we 
see the above idle reduction technologies being technically feasible on the majority of vocational vehicles. The RIA Chapter 2.9.3.4 and RIA Chapter 2.9.5.1.4 provide additional discussion on workday idle reduction technologies for vocational vehicles. 
(v) Weight Reduction Packages 
As described in the RIA Chapter 
2.11.10.3, weight reduction is a 
relatively costly technology, at approximately $3 to $10 per pound for a 200-lb package. Even so, for vehicles in service classes where dense, heavy loads are frequently carried, weight reduction can translate directly to additional payload. The agencies project 
that modest weight reduction is feasible for all vocational vehicles. The agencies are predicating the final standards on adoption of weight reduction comparable to what can be achieved through use of aluminum wheels (an easy material switch that does not alter load distribution on the chassis). This package is estimated at 150 pounds for LHD and MHD vehicles, and 250 pounds for HHD vehicles, based on six and 10 wheels, respectively. This value is revised upward since proposal based on compelling comments from the Aluminum Association recommending that we set the same level of weight reduction for lightweight aluminum alloys as for regular aluminum, at 25 pounds per wheel. More details on these comments may be found in the Response to Comments Chapter 5. In MY 2021, we project an adoption rate of 10 percent, 30 percent in MY 2024, and 50 percent in MY 2027 for all subcategories in the primary program. 
The agencies project manufacturers 
will have sufficient options of other components eligible for material substitution so that this level of weight reduction will be feasible even where aluminum wheels are not selected by customers. Based on comments, we have removed aluminum transmission cases and aluminum clutch housings from the vocational lookup table. 
We are not predicating the custom 
chassis standards on any use of weight reduction. We have learned that manufacturers of concrete mixers, refuse trucks, and some high end buses have already made extensive use of lightweighting technologies in the baseline fleet. We also received persuasive comment cautioning us not to base the school bus standards on weight reduction due to potential conflicts with safety standards. In considering this information, we are allowing all vehicles certified using custom chassis regulatory subcategory identifiers to make use of weight reduction as a compliance flexibility. We received compelling comment from UCS that weight reduction should be considered feasible for transit buses. Upon consideration of this comment as well as information regarding the preponderance of city buses with overloaded axles, we are predicating standard stringency for transit buses on use of aluminum wheels at the same adoption rate as for the primary program. See the RIA at Chapter 2.9.5.1.5 for more information about transit bus axles. 
(vi) Electrified Accessory Packages 
The agencies are predicating the final 
vocational vehicle standards in part on 
an adoption rate of five percent in MY 2021 of an electrified accessory package that achieves one percent fuel efficiency improvement. The discussion in Section V.C.(1)(a)(vi) describes some pre- defined e-accessory improvements that are available in GEM for all vocational vehicles. In MY 2024 we increase this adoption rate to ten percent, and in MY 
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441See Section II.D.2 of this Preamble for the 
derivation of the engine standards. 2027 the projected adoption rate is 15 
percent, applicable in all subcategories excluding custom chassis. Although we believe some components could be electrified for some custom chassis, we do not have sufficient information to estimate an incremental cost associated with electrifying the more complex systems on custom chassis such as buses, or to project a specific adoption rate for this type of improvement. 
(vii) Tire Pressure System Packages 
The agencies are predicating the 
vocational vehicle standards in part on widespread adoption of tire pressure 
monitoring systems. These are readily accepted by fleets as a cost-effective safety and fuel-saving measure. Because there may be some minor challenges in applying this technology to some vehicles where the payload and duty cycle lead to very high tire temperatures and pressures (as described above), we are applying a lower adoption rate to Urban and Multi-purpose vehicles than to Regional vehicles, as shown in Table V–23. We are applying similarly lower adoption rates for refuse trucks and transit buses. We are not predicating the emergency vehicle or cement mixer standards on adoption of TPMS. 
We are predicating the optional 
school bus, coach bus, transit bus, and refuse truck standards in part on limited adoption of automatic tire inflation systems (ATIS), as shown in Table V– 23. These are more costly than TPMS, and require an onboard air supply and sometimes extensive plumbing of air lines. 
TABLE V–23—V OCATIONAL TIREPRESSURE SYSTEM ADOPTION RATES  
Technology TPMS ATIS 
MY 2021 MY 2024 MY 2027 MY 2021 MY 2027 
Regional ............................................................................... 60 75 90 ........................ ........................
Multi-Purpose ....................................................................... 50 65 80 ........................ .......... ..............
Urban ................................................................................... 40 55 70 ........................ ...... ..................
School .................................................................................. 70 ........................ 80 ......... ............... 20 
Coach ................................................................................... 50 ........................ 75 10 25 
Transit .................................................................................. 40 ........................ 50 10 20 
Refuse .................................................................................. 40 ........................ 50 10 15 
Motor Home ......................................................................... 60 ........................ 90 .............. .......... ........................
(c) GEM Inputs for Derivation of 
Vocational Vehicle Standards 
To account for engine-level 
improvements consistent with those projected to meet Phase 2 vocational engine standards, and which will be reflected over the GEM vehicle test cycles, the agencies developed a suite of fuel consumption maps for use with the GEM: One set of maps that represent engines meeting the MY 2021 vocational diesel engine standards, a second set of maps representing engines meeting the MY 2024 vocational diesel engine standards, and a third set of maps representing engines meeting the MY 2027 vocational diesel engine standards.
441By incorporating the 
engine technology packages projected to be adopted to meet the Phase 2 vocational CI engine standards, the agencies employed GEM engine models in deriving the stringency of the Phase 2 CI-powered vocational vehicle standards. Similarly, to account for the performance of Phase 2 SI engines in deriving the stringency of the Phase 2 SI-powered vocational vehicle standards, the agencies employed our baseline SI GEM engine model. The extra engine technology on which the Phase 2 SI vocational vehicle standards are based was applied in post- 
processing the GEM results, not modeled with an improved GEM map. See the RIA Chapter 2.9.1 for more details about the vocational engines used in standard-setting. 
The derivation of the vocational 
vehicle standards incorporates several methods because some GEM inputs lend themselves to fleet-average values, some are vehicle specific (either on or off) and some improvements are not directly modeled in GEM. For each model year of standards, the agencies derived a scenario vehicle for each subcategory using the future model year engine map with fleet average input values for tire rolling resistance and weight reduction. For example, the MY 2021 HHD weight reduction input value was derived as follows: 250 pounds times 10 percent adoption yields 25 pounds. Those scenario vehicle performance results were combined in a post-process method with subcategory-specific improvements from idle reduction, axle disconnect, torque converter lockup, and transmission automation, using 
directly modeled GEM improvements comparing results with these technologies on or off the scenario vehicle. Subsequently, these performance values were combined with estimated improvement values of 
technologies not modeled in GEM, including TPMS, hybrids, and transmission gear efficiency. 
The set of fleet-average inputs for tire 
CRR and weight reduction for MY 2021, 
as modeled in GEM is shown in Table V–24, along with the respective adoption rates for idle reduction, axle disconnect, and torque converter lockup. The agencies derived the level of the MY 2024 standards by using the GEM inputs and adoption rates shown in Table V–25, below. The agencies derived the level of the MY 2027 standards by using the GEM inputs and adoption rates shown in Table V–26, below. Post-processing improvements for technologies not directly modeled, including TPMS, e-accessories, hybrids, and axle and transmission improvements are presented as a combined driveline improvement factor in Table V–27, below. The values in this table for SI-powered vocational vehicles include improvements due to adoption of SI engine technology. The methodology for estimating these improvements is described in the RIA Chapter 2.9.1. The final standards are presented in Table V–4 through Table V–9. 
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TABLE V–24—GEM I NPUTS USEDTODERIVE FINAL MY 2021 V OCATIONAL VEHICLE STANDARDS  
Class 2B–5 Class 6–7 Class 8 
Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional 
SI Engine 
2018 MY 6.8L, 300 hp engine 
CI Engine 
2021 MY 7L, 200 hp Engine 2021 MY 7L, 270 hp Engine 2021 MY 
11L, 350 
hp 
Engine 2021 MY 11L, 350 
hp Engine and 
2021 MY 15L 455hp Engine
a 
Torque Converter Lockup in 1st (adoption rate) 
30% .................................................................. 30% 30% 30% 30% 30% 10% 10% 0% 
6 x 2 Disconnect Axle (adoption rate) 
0% .................................................................... 0% 0% 0% 0% 0% 0% 5% 10% 
AES (adoption rate) 
30% .................................................................. 30% 40% 30% 30% 40% 30% 30% 40% 
Stop-Start (adoption rate) 
10% .................................................................. 10% 0% 10% 10% 0% 0% 0% 0% 
Neutral Idle (adoption rate) 
50% .................................................................. 50% 0% 50% 50% 0% 50% 50% 0% 
Steer Tires (CRR kg/metric ton) 
7 ....................................................................... 6.8 6.8 6.8 6.7 6.7 6.4 6.2 6.2 
Drive Tires (CRR kg/metric ton) 
7.2 .................................................................... 6.9 6.9 7.8 7.5 7.5 7.8 7.5 7.5 
Weight Reduction (lb) 
15 ..................................................................... 15 15 15 15 15 25 25 25 
Note: 
aThe Multipurpose and Regional HHD standards are established using averages of configurations with different engines as described in RIA 
Chapter 2.9.2. 
TABLE V–25—GEM I NPUTS USEDTODERIVE FINAL MY 2024 V OCATIONAL VEHICLE STANDARDS  
Class 2b–5 Class 6–7 Class 8 
Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional 
SI Engine 
2018 MY 6.8L, 300 hp engine 
CI Engine 
2024 MY 7L, 200 hp Engine 2024 MY 7L, 270 hp Engine 2024 MY 
11L, 350 
hp 
Engine 2024 MY 11L, 350 
hp Engine and 2024 MY 15L 455hp Engine
a 
Torque Converter Lockup in 1st (adoption rate) 
40% .................................................................. 40% 40% 40% 40% 40% 20% 20% 0% 
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TABLE V–25—GEM I NPUTS USEDTODERIVE FINAL MY 2024 V OCATIONAL VEHICLE STANDARDS —Continued 
Class 2b–5 Class 6–7 Class 8 
Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional 
6 x 2 Disconnect Axle (adoption rate) 
0% .................................................................... 0% 0% 0% 0% 0% 0% 15% 20% 
AES (adoption rate) 
60% .................................................................. 60% 80% 60% 60% 80% 60% 60% 80% 
Stop-Start (adoption rate) 
20% .................................................................. 20% 0% 20% 20% 0% 10% 10% 0% 
Neutral Idle (adoption rate) 
70% .................................................................. 70% 0% 70% 70% 0% 70% 70% 0% 
Steer Tires (CRR kg/metric ton) 
7.0 .................................................................... 6.8 6.2 6.8 6.7 6.2 6.4 6.2 6.2 
Drive Tires (CRR kg/metric ton) 
7.2 .................................................................... 6.9 6.9 7.8 7.5 6.9 7.8 7.5 6.9 
Weight Reduction (lb) 
45 ..................................................................... 45 45 45 45 45 75 75 75 
Note: 
aThe Multipurpose and Regional HHD standards are established using averages of configurations with different engines as described in RIA 
Chapter 2.9.2. 
TABLE V–26—GEM I NPUTS USEDTODERIVE FINAL MY 2027 V OCATIONAL VEHICLE STANDARDS  
Class 2b–5 Class 6–7 Class 8 
Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional 
SI Engine 
2018 MY 6.8L, 300 hp engine 
CI Engine 
2027 MY 7L, 200 hp Engine 2027 MY 7L, 270 hp Engine 2027 MY 
11L, 350 
hp 
Engine 2027 MY 11L, 350 
hp Engine and 
2027 MY 15L 455hp Engine
a 
Torque Converter Lockup in 1st (adoption rate) 
50% .................................................................. 50% 50% 50% 50% 50% 30% 30% 0% 
6 x 2 Disconnect Axle (adoption rate) 
0% .................................................................... 0% 0% 0% 0% 0% 0% 25% 30% 
AES (adoption rate) 
70% .................................................................. 70% 90% 70% 70% 90% 70% 70% 90% 
Stop-Start (adoption rate) 
30% .................................................................. 30% 0% 30% 30% 0% 20% 20% 0% 
Neutral Idle (adoption rate) 
60% .................................................................. 60% 0% 60% 60% 0% 70% 70% 0% 
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442See proposed rules at 80 FR 40308, July 13, 
2015. TABLE V–26—GEM I NPUTS USEDTODERIVE FINAL MY 2027 V OCATIONAL VEHICLE STANDARDS —Continued 
Class 2b–5 Class 6–7 Class 8 
Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional 
Steer Tires (CRR kg/metric ton) 
6.8 .................................................................... 6.2 6.2 6.7 6.2 6.2 6.2 6.2 6.2 
Drive Tires (CRR kg/metric ton) 
6.9 .................................................................... 6.9 6.9 7.5 6.9 6.9 7.5 6.9 6.9 
Weight Reduction (lb) 
75 ..................................................................... 75 75 75 75 75 125 125 125 
Note: 
aThe Multipurpose and Regional HHD standards are established using averages of configurations with different engines as described in RIA 
Chapter 2.9.2. 
TABLE V–27—V OCATIONAL DRIVELINE IMPROVEMENT FACTORS  
Class 2b–5 Class 6–7 Class 8 
Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional 
CI 2021 ........................................ 0.019 0.018 0.018 0.019 0.019 0.019 0.019 0.018 0.017 
CI 2024 ........................................ 0.041 0.036 0.029 0.041 0.036 0.029 0.040 0.036 0.026 
CI 2027 ........................................ 0.061 0.053 0.037 0.061 0.053 0.037 0.060 0.052 0.034 
SI 2021 ......................................... 0.027 0.026 0.026 0.028 0.027 0.027 ................ ................ ................
SI 2024 ......................................... 0.048 0.044 0.037 0.049 0.044 0.037 ................ ................ ................
SI 2027 ......................................... 0.067 0.059 0.045 0.068 0.060 0.045 ................ ................ ................
(d) Role of Fleet Averaging and 
Constraints in Vocational Vehicle Standards 
In part to avoid potentially creating 
incentives to misclassify vehicles, the agencies proposed to ‘‘equalize’’ the standards for each of the subcategories. 80 FR 40308. Thus, at proposal, the standards for the Regional, Multipurpose, and Urban subcategories reflected the arithmetic mean of the Regional, Multipurpose and Urban stringency levels (i.e., all three drive cycle subcategory percent improvements averaged together) in each weight class.
442Most commenters 
criticized this proposed approach. For example, Navistar commented that equalization could inappropriately benefit one manufacturer over another based on their product mix. We also note that the equalization process, if adopted, would have made the standards for the Regional vehicles unattainable using the technology pathway identified by the agencies, thus motivating manufacturers to select less appropriate test cycles for vehicles that are designed for Regional service. Therefore, we have decided not to apply ‘‘equalization’’ for finalizing the vocational vehicle standards. Instead, 
we have developed the final vocational vehicle standards using the same methodology as for all of the other Phase 2 standards, where we apply fleet average technology mixes to fleet average baseline vehicle configurations, and each average baseline and technology mix is unique for each vehicle subcategory. Along with this 
standard-setting approach, the agencies are also adopting certain interim constraints on the otherwise generally manufacturer-selected assignment of vehicle configurations to one of the three drive cycle subcategories, as explained in Section V.D.(1)(e) below. 
Elsewhere in this rulemaking we 
present overall costs and benefits, which are based our projected distribution of vocational vehicles in each subcategory. This projection includes our most updated population distributions by weight class, which we have adjusted in part in response to comments on the draft NREL report in the NODA and based on an analysis of telematics data from Ryder’s leased vehicles. We intend to monitor whether our projection of distribution of vehicles among subcategories is consistent with outcomes. Under the three drive cycle subcategory structure, manufacturers must use good engineering judgment (subject to the provisions of 40 CFR 
1068.5) to choose a subcategory for each vehicle configuration that represents the type of operation the vehicle is configured to experience in use, and the agencies expect the manufacturer and customer to specify a technology mix that is most effective for that vehicle’s likely operation. In other words, as long as manufacturers work with their 
customers, the general rule describing this greater flexibility in choice of subcategory could be that the ‘‘customer knows best.’’ In fact, our standards are predicated on the premise that willful misclassification not reflecting good engineering judgment will be rare, and thus environmentally inconsequential. 
In considering our approach for 
setting the final standards, we compared the relative stringencies in each subcategory with each respective baseline, and we observed that Regional vehicles are generally able to achieve the smallest percent improvement from the lowest (most efficient) baseline. By contrast, the Urban vehicles are generally able to achieve the greatest percent improvement from the highest (least efficient) baseline. We are not particularly concerned that adopting final standards with these unequal percent improvements poses a danger of losing environmental benefits from this 
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443See spreadsheet file dated July 2016 titled, 
VocationalStringencyComparison.xlsx. 444See memorandum dated July 2016 titled, 
‘‘Summary of Late Comments on Vocational 
Transmissions and N/V.’’ program, as long as vehicle 
configurations are properly classified at the time of certification. To test the potential impacts of misclassification, we compared the performance of each of our baseline configurations over all three drive cycles. This analysis is presented in a memorandum to the docket.
443Results for LHD and MHD 
weight classes were generally consistent with the rule’s projections across each drive cycle. Results for HHD were equivocal in some instances, particularly for our baseline vehicles equipped with manual transmissions. This issue appears to be related to both the difference in the weighting of time spent in the drive idle mode in the Regional versus Urban and Multi- purpose drive cycles, and whether or not automatic transmissions are part of a baseline. In the analysis, that combination of circumstances showed how manual transmission-equipped vehicles could potentially become credit generators without any further addition of technology, if certified to the Urban or Multi-purpose cycles. The agencies are concerned that if this circumstance were to be left unconstrained, it could 
create an incentive to misclassify some Regional vehicles into one of the other two drive cycle subcategories, even though manual transmissions are generally best suited for Regional driving patterns, as discussed further below. 
In light of this analysis, and 
consistent with recent comments from chassis manufacturers mentioned above in Section V.B.(1)(a), the agencies are adopting some constraints to the otherwise generally manufacturer- selected assignment of vocational chassis to regulatory subcategories. These constraints are described in Section V.D.(1)(e). A subset of the constraints prevents inappropriate classification based on transmission type. These constraints restrict classification options where a vocational vehicle is certifying with a manual transmission or in some cases an automated manual transmission. We are adopting these constraints as interim provisions in response to manufacturers’ concerns that the 
manual transmission constraints could present competitive disadvantages, where different manufacturers produce very different sales mixes of vehicles equipped with different transmission types.
444However, at this time the final 
program structure, including these constraints, will remain in place unless and until the agencies determine that 
revisions to the vocational vehicle program structure are warranted, in which case the agencies would undertake a notice and comment rulemaking proposing to amend the programmatic structure, consistent with such a determination. 
It is important to clarify that we 
would consider all relevant factors together before deciding whether to propose any revisions. If we find that a significant discrepancy arises between our projections and outcomes, such that our estimated GHG and fuel consumption benefits are not being achieved because of the program structure, we may revisit relevant aspects of the program structure, including the drive cycles, subcategories and classification constraints. If we propose to revise the structure in the future, it might also be necessary to propose revising the numerical values of the standards to maintain equivalence with the final stringency being established in this rulemaking. We would of course find it acceptable if manufacturers implemented more cost- effective technologies than we projected, while still achieving the projected reductions in use. Similarly, if the structure results in manufacturers generally adopting the projected cost- effective technologies on the appropriate vehicles, but somehow this fails to fully achieve the projected reductions in use, we do not believe revisions necessarily would be warranted. 
(e) Technology Package Costs 
Associated With Primary Vocational Vehicle Standards 
The agencies have estimated the costs 
of the technologies that could be used to comply with the final Phase 2 vocational vehicle standards. The 
estimated costs are shown in Table V– 28 for MY 2021, in Table V–29 for MY 2024, and Table V–30 for MY 2027. Fleet average costs are shown for light, medium and heavy HD vocational vehicles in each duty-cycle-based subcategory—Urban, Multi-Purpose, and Regional. As shown in Table V–28, in MY 2021 these range from approximately $900 for MHD and LHD Regional vehicles, up to $2,600 for HHD Regional vehicles. Those two lower-cost packages reflect zero hybrids, and the higher-cost package reflects significant adoption of automated transmissions. Many changes have been made to the cost estimates since proposal. In the RIA Chapter 2.12.2, the agencies present vocational vehicle technology package costs differentiated by MOVES vehicle type. These costs do not indicate the per-vehicle cost that may be incurred for any individual technology. For more specific information about the agencies’ estimates of per-vehicle costs, please see the RIA Chapter 2.11. The engine costs listed represent the cost of an average package of diesel engine technologies as set out in Section II. Individual technology adoption rates for engine packages are described in Section II.D. 
For gasoline vocational vehicles, the agencies are projecting adoption of Level 2 engine friction reduction plus cylinder deactivation (i.e., all engine improvements are reflected exclusively in the vehicle standard) for an estimated $138 added to the average SI vocational vehicle package cost beginning in MY 2021. Further details on how the SI vocational vehicle costs were estimated are provided in the RIA Chapter 2.9. 
The details behind all these costs are 
presented in RIA Chapter 2.11, including the markups and learning effects applied and how the costs shown here are weighted to generate an overall cost for the vocational segment. These estimates have changed significantly from those presented in the proposal, due to changes in projected technology adoption rates as well as changes in direct costs that reflect comments received. 
TABLE V–28—F INAL VOCATIONAL VEHICLE TECHNOLOGY INCREMENTAL COSTS IN THE 2021 M ODEL YEARab 
[2013$] 
Light HD Medium HD Heavy HD 
Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional 
Enginec........................................ $298 $298 $298 $275 $275 $275 $275 $275 $275 
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TABLE V–28—F INAL VOCATIONAL VEHICLE TECHNOLOGY INCREMENTAL COSTS IN THE 2021 M ODEL YEARab—Continued 
[2013$] 
Light HD Medium HD Heavy HD 
Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional 
Tires ............................................. 0 27 27 9 9 9 13 13 13 
Tire Pressure Monitoring .............. 123 154 184 123 154 184 233 292 350 
Transmission ................................ 217 217 217 217 217 217 186 413 1,519 
Axle related .................................. 13 13 13 13 13 13 20 26 32 
Weight Reduction ......................... 69 69 69 69 69 69 250 250 250 
Idle reduction ............................... 155 155 12 160 160 12 68 68 12 
Hybridization ................................ 178 178 0 178 178 0 178 178 0 
Air Conditioningd.......................... 22 22 22 22 22 22 22 22 22 
Othere.......................................... 30 30 30 49 49 49 89 89 89 
Total ...................................... 1,106 1,164 873 1,116 1,146 851 1,334 1,625 2,562 
Notes: 
aCosts shown are for the 2021 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include 
indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and 
how it impacts technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.11). 
bNote that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the 
indicated vehicle classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.11 in particular). 
cEngine costs are for a light HD, medium HD or heavy HD diesel engine. We are projecting $138 of additional costs beyond Phase 1 for gaso-
line vocational engines. 
dEPA’s air conditioning standards are presented in Section V.C above. 
eOther incremental technology costs include electrified accessories and advanced shift strategy. 
The estimated fleet average vocational 
vehicle package costs are shown in 
Table V–29 for MY 2024. As shown, these range from approximately $1,300 for MHD and LHD Regional vehicles, up to $4,000 for HHD Regional vehicles. The increased costs above the MY 2021 values reflect increased adoption rates of individual technologies, while the individual technology costs are generally expected to remain the same or decrease, as explained in the RIA Chapter 2.11. The engine costs listed 
represent the average costs associated with the MY 2024 vocational diesel engine standard described in Section II.D. 
TABLE V–29—F INAL VOCATIONAL VEHICLE TECHNOLOGY INCREMENTAL COSTS IN THE 2024 M ODEL YEARab 
[2013$] 
Light HD Medium HD Heavy HD 
Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional 
Enginec........................................ $446 $446 $446 $413 $413 $413 $413 $413 $413 
Tires ............................................. 0 31 33 10 10 33 13 13 53 
Tire Pressure Monitoring .............. 155 183 211 155 183 211 294 347 401 
Transmission ................................ 276 276 276 276 276 276 222 1,032 2,193 
Axle related .................................. 24 24 24 24 24 24 37 54 60 
Weight Reduction ......................... 186 186 186 186 186 186 684 684 684 
Idle reduction ............................... 248 248 21 256 256 21 242 242 21 
Hybridization ................................ 550 550 0 653 653 0 844 844 0 
Air Conditioningd.......................... 20 20 20 20 20 20 20 20 20 
Othere.......................................... 54 54 54 89 89 89 162 162 162 
Total ...................................... 1,959 2,018 1,272 2,082 2,110 1,274 2,932 3,813 4,009 
Notes: 
aCosts shown are for the 2024 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include 
indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and 
how it impacts technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.11). 
bNote that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the 
indicated vehicle classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.9 in particular). 
cEngine costs are for a light HD, medium HD or heavy HD diesel engine. We are projecting $136 additional costs beyond Phase 1 for gaso-
line vocational engines. 
dEPA’s air conditioning standards are presented in Section V.C above. 
eOther incremental technology costs include electrified accessories and advanced shift strategy. 
The estimated fleet average vocational 
vehicle package costs are shown in 
Table V–30 for MY 2027. As shown, these range from approximately $1,500 for MHD and LHD Regional vehicles, up to $5,700 for HHD Regional vehicles. These per-vehicle technology package costs were averaged using our projections of vehicle populations in the 
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445See Heavy Duty Vocational Vehicle Industry 
Characterization, EPA Contract No. EP–C–12–011. 
September 2013. nine regulatory subcategories and do not 
correspond to the MOVES vehicle types. The engine costs shown represent the 
average costs associated with the MY 2027 vocational diesel engine standard described in Section II.D. 
Purchase prices of non-custom 
vocational vehicles can range from $60,000 for a light heavy-duty stake-bed landscape truck to over $300,000 for a heavy heavy-duty boom truck. The costs 
of the vocational vehicle standards can be put into perspective by comparing estimated package costs with typical prices for those vehicles. For example, a package cost of $3,000 on a $60,000 landscaping truck represents an incremental increase of about five percent of the vehicle purchase price. Similarly, a package cost of $4,000 on a $300,000 boom truck represents an incremental increase of less than two percent of the vehicle purchase price. The vocational vehicle industry characterization report in the docket includes additional examples of vehicle prices for a variety of vocational applications.
445 
TABLE V–30—F INAL VOCATIONAL VEHICLE TECHNOLOGY INCREMENTAL COSTS IN THE 2027 M ODEL YEARab 
[2013$] 
Light HD Medium HD Heavy HD 
Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional Urban Multi- 
purpose Regional 
Enginec........................................ $481 $481 $481 $446 $446 $446 $446 $446 $446 
Tires ............................................. 12 24 24 6 24 24 12 36 36 
Tire Pressure Monitoring .............. 187 214 240 187 214 240 355 405 456 
Transmission ................................ 271 271 293 271 271 293 220 990 3,269 
Axle related .................................. 35 35 35 35 35 35 52 82 87 
Weight Reduction ......................... 294 294 294 294 294 294 1,102 1,102 1,102 
Idle reduction ............................... 303 303 23 314 314 23 365 365 23 
Hybridization ................................ 857 857 0 1,032 1,032 0 1,353 1,353 0 
Air Conditioningd.......................... 20 20 20 20 20 20 20 20 20 
Othere.......................................... 73 73 77 122 122 127 227 227 231 
Total ...................................... 2,533 2,571 1,486 2,727 2,771 1,500 4,151 5,025 5,670 
Notes: 
aCosts shown are for the 2027 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include 
indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and 
how it impacts technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.11). 
bNote that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the 
indicated vehicle classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.9 in particular). 
cEngine costs are shown for a light HD, medium HD or heavy HD diesel engine. For gasoline-powered vocational vehicles we are pro jecting 
$125 of additional engine-based costs beyond Phase 1. 
dEPA’s air conditioning standards are presented in Section V.C above. 
eOther incremental technology costs include electrified accessories and advanced shift strategy. 
(f) Custom Chassis Cost Estimates 
The agencies have performed the 
above-described cost analysis using the 
assumption that all custom chassis vocational vehicles are certified to the primary standards, with full technology packages and use of the regular Phase 2 GEM. In terms of costs, we expect that a manufacturer will choose to certify a vehicle family to the optional custom chassis standards only if it is less costly to do so. The cost-benefit analysis found in the RIA Chapter 7 presents some estimates of what the technology package costs of the primary standards are in terms of MOVES vehicle types. For the MOVES types where a custom chassis option is available, these are conservatively high cost estimates. Table 6 and Table 7 of the RIA Executive Summary present estimates of average custom chassis technology packages associated with the final optional standards in MY 2021 and MY 
2027, respectively. 
The agencies are not aware of any 
custom chassis manufacturer that produces engines. Thus, the engine costs will be borne by engine manufacturers. While some of the added engine costs may be passed on to vehicle manufacturers, and some vehicle costs may be passed on to owners/operators, the overall technology costs of the custom chassis standards are significantly less than the Phase 2 vocational vehicle technology costs, which, as shown directly below, are highly cost-effective. 
(3) Consistency of the Vocational 
Vehicle Standards With the Agencies’ Legal Authority 
NHTSA and EPA project these 
standards to be achievable within known design cycles, and we believe these standards, although technology- advancing, will allow many different paths to compliance in addition to the 
technology paths on which standard stringency is predicated. These standards are predicated on manufacturers implementing technologies that we expect will be available in the time frame of these final rules. We are projecting that most vehicles can adopt certain of the technologies. For example, we project a 70 to 90 percent application rate for TPMS. However, for other technologies, such as electrified accessories, we are projecting an adoption rate of 15 percent. These standards offer manufacturers the flexibility to apply the technologies that make sense for their business and for customer needs. 
As discussed above, average per- 
vehicle costs associated with the 2027 MY standards are projected to be generally less than five percent of the 
overall price of a new vehicle. The annual cost-effectiveness of these vocational vehicle standards in dollars 
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446See Chapter 5.3 of the final RIA for the MY 
2017–2025 Light-Duty GHG Rule, available at http://www3.epa.gov/otaq/climate/documents/ 
420r12016.pdf. per metric ton is presented in the RIA 
Chapter 7 in Table 7–47. As shown in that table, without fuel savings the cost per metric ton of the final vocational vehicle standards in calendar year 2021 is $710, decreasing to $100 by 2030. The cost effectiveness estimated for heavy- duty pickup trucks and vans in this rulemaking is presented in Table 7–46 in that same chapter of the RIA. Those Phase 2 standards have an estimated annual cost per metric ton without fuel savings of $2,800 in 2020, decreasing to $110 (about the same as for vocational) by calendar year 2030. The annual cost per ton of the MY 2017–2025 light-duty greenhouse gas standards for pickup trucks as reported in 2010 dollars without fuel savings is $430 in calendar year 2020, decreasing to $142 in 2030.
446The agencies have found these 
standards to be highly cost effective. In addition, the vocational vehicle standards are clearly effective from a net benefits perspective (see RIA Chapter 11.2). Therefore, the agencies regard the cost of the final standards as reasonable, even without considering that the costs are recovered due decreased fuel consumption. 
The agencies note that while the 
projected costs are significantly greater than the costs projected for Phase 1, we still consider these costs to be reasonable, especially given that the first vehicle owner may see the technologies pay for themselves in many cases. As discussed above, the usual period of ownership for a vocational vehicle reflects a lengthy trade cycle that may often exceed seven 
years. For most vehicle types evaluated, the cost of these technologies, if passed on fully to customers, will likely be recovered within four years or less due to the associated fuel savings, as shown 
in the payback analysis included in Section IX.M and in the RIA Chapter 7.1. Specifically, in RIA Chapter 7.2.4, a summary is presented with estimated payback periods for each of the MOVES vocational vehicle types, using the annual vehicle miles traveled from the MOVES model for each vehicle type. As noted above, the cost analysis presented for this rulemaking assumes that all vocational vehicles are certified to the primary standard. Using this assumption, the vocational vehicle type with the shortest payback is intercity buses (less than one year), while most other vehicles (with the exception of school buses and motor homes) are projected to see paybacks in the fourth year or sooner. We expect that manufacturers will certify to the optional custom chassis standards where it is more cost-effective to do so; therefore, our analysis may be overly conservative where it indicates very long paybacks for some vocational vehicles. 
The agencies note further that 
although the rules are technology- advancing (especially with respect to driveline improvements) and the estimated costs for each subcategory vary considerably (by a factor of five in some cases), these costs represent only one of many possible pathways to compliance for manufacturers. Manufacturers retain leeway to develop alternative compliance paths, increasing the likelihood of the standards’ successful implementation. Based on available information, the agencies 
believe the final vocational vehicle standards are technically feasible within the lead time provided, are cost effective while accounting for the fuel savings (see RIA Chapter 7.1.4), and have no 
apparent adverse collateral potential impacts (e.g., there are no projected negative impacts on safety or vehicle utility). 
The final standards thus appear to 
represent a reasonable choice under section 202(a) of the CAA and are maximum feasible under NHTSA’s EISA authority at 49 U.S.C. 32902(k)(2). The agencies believe that the final standards are consistent with their respective authorities. 
(4) Alternative Vocational Vehicle 
Standards Considered 
The agencies developed and 
considered other alternative levels of 
stringency for the Phase 2 program. The results of the analysis of these 
alternatives, and comments received on alternatives, are discussed below in Section X of the Preamble and the RIA Chapter 11. For vocational vehicles, the agencies developed alternatives as shown in Table V–31. The agencies are not adopting standards reflecting Alternative 2, because as already described, technically feasible standards are available that provide for greater emission reductions and reduced fuel consumption than provided under Alternative 2. The agencies are not adopting standards reflecting Alternative 4 or Alternative 5 because we do not believe these standards to be feasible considering lead time and other relevant factors. Nevertheless, we have reevaluated each of the technology projections proposed for Alternative 4 and have determined that some engine and tire reductions will be feasible on the Alternative 4 timeline. 
TABLE V–31—S UMMARY OF ALTERNATIVES CONSIDERED FOR THE FINAL RULEMAKING  
Alternative 1 and 1b No action alternatives 
Alternative 2 ............................ Less stringent than the preferred alternative in the proposal, applying off-the-shelf technologies. 
Final HD Phase 2 program ..... Fully phased-in by MY 2027. 
Alternative 4 ............................ Same stringency as preferred alternative in the proposal, phasing in by MY 2024. 
Alternative 5 ............................ More stringent alternative, based on higher adoption rates of advanced technologies. 
D. Compliance Provisions for 
Vocational Vehicles 
We are adopting many changes in the 
compliance provisions for vocational vehicles compared with what we proposed, as described in this section. (1) Application and Certification Process 
The agencies are adopting changes in 
the final Phase 2 version of GEM, as described in Section II of this Preamble. Below we provide cross-references to test procedures either that are either required or optional, for generation of Phase 2 GEM input values. See Section II.D.1 for details of engine testing and 
GEM inputs for engines. 
As described above in Section I, the 
agencies will continue the Phase 1 compliance process in terms of the manufacturer requirements prior to the effective model year, during the model year, and after the model year. The information that will be required to be 
submitted by manufacturers is set forth 
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in 40 CFR 1037.205, 49 CFR 537.6, and 
49 CFR 537.7. EPA will continue to issue certificates upon approval based on information submitted through the VERIFY database (see 40 CFR 1037.255). End of year reports will continue to include the GEM results for all of the configurations built, along with credit/ deficit balances, if applicable (see 40 CFR 1037.250 and 1037.730). 
(a) GEM Inputs 
In Phase 1, there were two inputs to 
GEM for vocational vehicles: 
•Steer tire coefficient of rolling 
resistance, and 
•Drive tire coefficient of rolling 
resistance 
As discussed above in Section II and 
III.D, there are several additional inputs 
that we are adopting for Phase 2. In addition to the steer and drive tire CRR, the inputs include the following: 
•Engine input file with fuel map, 
full-load torque curve, and motoring 
curve, 
•Transmission input file including 
architecture type, gear number and ratios, and minimum lockup gear for transmissions with torque converters, 
•Drive axle ratio, 
•Axle configuration, 
•Tire size in revs/mi for drive and 
steer tires, 
•Idle Reduction, 
•Weight Reduction, 
•Vehicle Speed Limiter, 
•Aerodynamic Drag Area, and 
•Pre-defined technology inputs for 
Accessory Load and Tire Pressure Systems 
(i) Driveline Inputs 
As with tractors, for each engine 
family, engine fuel maps, full load torque curve, and motoring curve will 
be generated by engine manufacturers and supplied to chassis manufacturers in a format compatible with GEM. The test procedures for the torque and motoring curves are found in 40 CFR part 1065. Section II.D.1.b describes these procedures as well as the procedures for generating the engine fuel maps. We require the steady state map approach for the 55 and 65 mph cruise speed cycles, while the cycle average approach is required for the ARB transient cycle. As an option, the cycle average map may also be used for 55 and 65 mph cruise speed cycles. Also similar to tractors, transmission specifications will be input to GEM. Any number of gears may be entered with a numerical ratio for each, and transmission type must be entered as either a Manual, Automated Manual, or Automatic transmission. 
As part of the driveline information 
needed to run GEM, drive axle ratio will be a user input. If a configuration has a two-speed axle, the agencies are adopting regulations to instruct a manufacturer to enter the ratio that is expected to be engaged for the greatest driving distance. We requested comment on whether the agencies should allow this choice, and what the GEM input instructions should be. Both Dana and Meritor commented that there should be an option to recognize two- speed axles, but neither axle supplier offered a preference for how the agencies should implement this. Two- speed axles are typically specified for heavy-haul vehicles, where the higher numerical ratio axle is engaged during transient driving conditions and to deliver performance needed on work sites, while the lower numerical ratio 
axle may be engaged during light-load highway driving. 
Tire size is a Phase 2 input to GEM 
that is necessary for the model to simulate the performance of the vehicle. As a result of comment and further technical analysis, we are adopting the tire size input as measured in revs/mile, rather than the measure of loaded radius in meters, as was proposed. The RIA Chapter 3 includes a description of how to measure tire size. For each model and nominal size of a tire, there are numerous possible sizes that could be measured, depending on whether the tire is new or ‘‘grown,’’ meaning whether it has been broken in for at least 200 miles. Size can also vary based on load and inflation levels, air temperature, and tread depth. The agencies requested comment on aspects of measuring and reporting tire size. The revised test procedure is described in the RIA Chapter 3.3.4. 
For manufacturers electing to certify a 
vocational vehicle to the optional custom chassis standards, none of the above driveline inputs are applicable. In this case manufacturers must input one of the custom chassis regulatory subcategory identifiers shown in Table V–32. After the remaining input fields are either completed with values or N/A, GEM will simulate the vehicle by calling the default engine and transmission files, tire size, and axle radius from the GEM library. The following subsections describe the required and optional inputs for custom chassis. 
TABLE V–32—C USTOM CHASSIS SUBCATEGORY NAMES  
Vehicle type Regulatory subcategory GEM identifier Default weight class and duty cycle 
Motor Home ........................................................ MHD_ CC_MH ................................................... MHD Regional. 
School Bus ......................................................... MHD_ CC_SB ................................................... MHD Urban. 
Coach Bus .......................................................... HHD_ CC_CB .................................................... HHD Regional. 
Emergency Vehicle ............................................ HHD_ CC_EM ................................................... HHD Urban. 
Concrete Mixer ................................................... HHD_ CC_CM ................................................... HHD Urban. 
Transit and Other bus ........................................ HHD_ CC_OB ................................................... HHD Urban. 
Refuse Truck ...................................................... HHD_ CC_RF .................................................... HHD Urban. 
The agencies requested comments on 
the merits of using an equation-based 
compliance approach for emergency vehicle manufacturers, similar to the approach for trailer manufacturers described in Section IV.F. CARB commented in support of an equation- based compliance approach, but in the same comment they also expressed 
support for using a Phase 1-style GEM interface with a default engine simulated in GEM as appropriate for the 
emergency vehicle category. We received adverse comment on the equation-based approach from Daimler, because they believed it would make the compliance process more complex if some vehicles needed to be tracked differently. Our intent in soliciting comment on an equation-based 
approach was to assess whether running GEM was a burden for non-diversified manufacturers of low-technology vehicles. Because we received sufficient support from non-diversified manufacturers that a simplified GEM would meet their needs, we did not pursue an equation-based approach. 
The final certification approach is 
consistent with the approach recommended by the Small Business Advocacy Review Panel, which believed it will be feasible for small emergency 
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447See NACFE Confidence Findings on the 
Potential of 6x2 Axles. vehicle manufacturers to install a Phase 
2-compliant engine, but recommended a simplified certification approach to reduce the number of required GEM inputs. 
(ii) Idle Reduction Inputs 
The agencies proposed two different 
idle reduction inputs for vocational 
vehicles: Neutral idle and stop-start. Based on comment, we are adding a third type of idle reduction input: Automatic engine shutdown. Based on user inputs derived from engine testing described in Section II and RIA Chapter 3.1, GEM will calculate CO
2emissions 
and fuel consumption at both zero torque (neutral idle) and with torque set to Curb-Idle Transmission Torque for automatic transmissions in ‘‘drive’’ (as described in the RIA Chapter 3.4.2.3) for use in the CO
2emission calculation in 
40 CFR 1037.510(b). At proposal, neutral idle and stop-start were not recognized during the ARB transient cycle, they were recognized only during the separate idle cycle. The agencies received comments requesting recognition of neutral idle during the ARB transient test cycle. We agree this is desirable and have adopted changes in GEM to accomplish this. Also, with the adoption of the alternative engine mapping procedure for the ARB transient cycle, the computation for idle reduction has changed. Please see RIA Chapter 4.4.1.7 for a description of how GEM recognizes idle reduction. 
For vocational custom chassis 
certified to the optional standards, all three idle reduction inputs will be available, however, the computation will be based on the EPA default engine. As described in the GEM User Guide, users will enter Y or N, and GEM will return a predefined improvement. 
(iii) Weight Reduction Inputs 
In Phase 1, the agencies adopted 
tractor regulations that provided 
manufacturers with the ability to utilize high strength steel and aluminum components for weight reduction without the burden of entering the curb weight of every tractor produced. In Phase 2, the agencies are adopting a lookup table of lightweight components for use in certifying vocational vehicles, similar to the process for tractors. As noted above, the agencies will recognize weight reduction by allocating one half of the weight reduction to payload in the denominator, while one half of the weight reduction will be subtracted from the overall weight of the vehicle in GEM. 
The agencies are adopting lookup 
values for components on vocational vehicles in all HD weight classes. Components available for vocational vehicle manufacturers to select for weight reduction are shown below in Table V–33, below. All of these weight reduction inputs will be available for manufacturers of custom chassis certifying to the optional standards. We received comments from Allison Transmission noting that aluminum transmission cases and clutch housings are standard for automatic transmissions so we agree it is inappropriate to include these components in the lookup table. We have revised the values in response to adverse comments from AISI, and after reevaluating information available at proposal. Although we are not projecting any adoption of permanent 6x2 axles for non-custom vocational vehicles, if a manufacturer chooses to apply this technology for class 8 vocational vehicles, users may enter an appropriate weight reduction compared to the traditional 6x4 axle configuration.
447We received adverse 
comments on the proposal to assign a fixed weight increase to natural gas fueled vehicles to reflect the weight increase of natural gas fuel tanks versus gasoline or diesel tanks. Based on comments and further technical analysis, we have determined that to provide equitable treatment to technologies, we will not require a weight penalty for any technology applied to achieve certification in Phase 2. We accounted for adoption of weight- increasing technologies in our MOVES modeling. 
TABLE V–33—P HASE 2 W EIGHT REDUCTION TECHNOLOGIES FOR VOCATIONAL VEHICLES  
Component Material Vocational vehicle class 
Class 2b–5 Class 6–7 Class 8 
Axle Hubs—Non-Drive ............................................................ Aluminum ............................... 40 40 
Axle Hubs—Non-Drive ............................................................ High Strength Steel ................ 5 5 
Axle—Non-Drive ..................................................................... Aluminum ............................... 60 60  
Axle—Non-Drive ..................................................................... High Strength Steel ................ 15 15 
Brake Drums—Non-Drive ....................................................... Aluminum ............................... 60 60 
Brake Drums—Non-Drive ....................................................... High Strength Steel ................ 42 42 
Axle Hubs—Drive .................................................................... Aluminum ............................... 40 80 
Axle Hubs—Drive .................................................................... High Strength Steel ................ 10 20 
Brake Drums—Drive ............................................................... Aluminum ............................... 70 140 
Brake Drums—Drive ............................................................... High Strength Steel ................ 37 74 
Suspension Brackets, Hangers .............................................. Aluminum ............................... 67 100 
Suspension Brackets, Hangers .............................................. High Strength Steel ................ 20 30 
Crossmember—Cab ................................................................ Aluminum ............................... 10 15 15 
Crossmember—Cab ................................................................ High Strength Steel ................ 2 5 5 
Crossmember—Non-Suspension ............................................ Aluminum ............................... 15 15 15 
Crossmember—Non-Suspension ............................................ High Strength Steel ................ 5 5 5 
Crossmember—Suspension ................................................... Aluminum ............................... 15 25 25 
Crossmember—Suspension ................................................... High Strength Steel ................ 6 6 6 
Driveshaft ................................................................................ Aluminum ............................. .. 12 40 50 
Driveshaft ................................................................................ High Strength Steel ................ 5 10 12 
Frame Rails ............................................................................. Aluminum ............................... 120 300 440 
Frame Rails ............................................................................. High Strength Steel ................ 40 40 87 
Wheels—Dual ......................................................................... Aluminum ............................... 150 150 250 
Wheels—Dual ......................................................................... High Strength Steel ................ 48 48 80 
Wheels—Wide Base Single .................................................... Aluminum ............................... 294 294 588 
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TABLE V–33—P HASE 2 W EIGHT REDUCTION TECHNOLOGIES FOR VOCATIONAL VEHICLES —Continued 
Component Material Vocational vehicle class 
Class 2b–5 Class 6–7 Class 8 
Wheels—Wide Base Single .................................................... High Strength Steel ................ 168 168 336 
Permanent 6x2 Axle Configuration ......................................... Multi ........................................ N/A N/A 300 
(iv) Other Inputs 
Certifying manufacturers may enter 
values in GEM as applicable for vehicle 
speed limiters, fairings to reduce aerodynamic drag area, electrified accessories, and tire pressure systems where such features meet the criteria in the regulations at 40 CFR 1037.520. 
(b) Test Procedures 
Powertrain families are defined in 
Section II.C.3.b, and powertrain test 
procedures are discussed in the RIA Chapter 3.6. The results from testing a powertrain configuration using the matrix of tests described in RIA Chapter 3.6 can be applied broadly across all vocational vehicles in which that powertrain will be installed. Powertrain test results become a GEM input file that replaces both the engine input file and transmission input file. 
As in Phase 1, the rolling resistance 
of each tire will be measured using the ISO 28850 test method for drive tires and steer tires planned for fitment to the 
vehicle being certified. Once the test CRR values are obtained, a manufacturer will declare TRRLs (which may be equal to or higher than the measured values) for the drive and steer tires separately to be input into the GEM. For Phase 2 vocational vehicles, GEM will distribute the vehicle load with 30 percent of the load over the steer tires and 70 percent of the load over the drive tires. With these data entered, the amount of GHG reduction attributed to tire rolling resistance will be incorporated into the overall vehicle compliance value. 
The final Phase 2 GEM will accept as 
inputs results from a transmission efficiency test. A procedure for this was discussed in the NPRM, and received favorable comment. The transmission efficiency test will be optional, but will allow manufacturers to reduce the CO
2 
emissions and fuel consumption by designing better transmissions with lower friction due to better gear design and/or mandatory use of better lubricants. 
In lieu of a fixed value for low friction 
axle lubricants as was proposed, the agencies are adopting an axle efficiency test procedure, as was discussed in the NPRM. See 80 FR 40323. The axle efficiency test will be optional, but will allow manufacturers to reduce CO
2 emissions and fuel consumption through improved axle gear designs and/or mandatory use of low friction lubricants. The agencies are not finalizing any other paths to recognize low friction axle lubricants. 
(c) Useful Life and In-Use Standards 
Section 202(a)(1) of the CAA specifies 
that emission standards are to be 
applicable for the useful life of the vehicle. The standards that EPA and NHTSA are adopting will apply to individual vehicles and engines at production and in use. NHTSA is not adopting in-use standards for vehicles or engines. 
Manufacturers may be required to 
submit, as part of the application for certification, an engineering analysis showing that emission control performance will not deteriorate during the useful life, with proper maintenance. If maintenance will be required to prevent or minimize deterioration, a demonstration may be required that this maintenance will be performed in use. See 40 CFR 1037.241. 
EPA will continue the Phase 1 
approach to adjustment factors and deterioration factors for vehicles. The technologies on which the Phase 1 vocational vehicle standards were predicated were not expected to have any deterioration of GHG effectiveness in use. However, the regulations provided a process for manufacturers to develop deterioration factors (DF) if they needed. We anticipate that some hybrid powertrain systems may experience some deterioration of effectiveness with age of the energy storage device. We believe the regulations in place currently provide adequate instructions to manufacturers for developing DF where needed. We received comments from Daimler on deterioration factors for engines and the process for extrapolating where DF’s are nonlinear. See Section 3.7 of the RTC. Allison Transmission commented that the amount of credits generated for a hybrid system should be dependent, in part, on design limits of batteries. We do not believe any changes are needed because the regulations do account for this by basing the FELs on the highest emissions during the useful life, including any effects from deterioration. As with engine certification, a chassis 
manufacturer must design their vehicles 
to be durable enough to maintain compliance through the regulatory useful life of the vehicle. Factors influencing vehicle-level GHG performance over the life of the vehicle fall into two basic categories: Vehicle attributes and maintenance items. Each category merits different treatment from the perspective of assessing useful life compliance, as each has varying degrees of manufacturer versus owner/operator responsibility. The agencies require manufacturers to explain how they meet these requirements as part of certification. 
For vocational vehicles, attributes 
generally refers to components that are 
installed by the manufacturer to meet the standard, whose reduction properties are assessed at the time of certification, and which are expected to last the full life of the vehicle with effectiveness maintained as new for the life of the vehicle with no special maintenance requirements. To assess useful life compliance, we will follow a design-based approach that will ensure that the manufacturer has robustly designed these features so they can reasonably be expected to last the useful life of the vehicle. 
For vocational vehicles, maintenance 
items generally refers to items that are replaced, renewed, cleaned, inspected, or otherwise addressed in the preventative maintenance schedule specified by the vehicle manufacturer. Replacement items that have a direct influence on GHG emissions are primarily tires and lubricants, but may also include hybrid system batteries. Synthetic engine oil may be used by vehicle manufacturers to reduce the GHG emissions of their vehicles. Manufacturers may specify that these fluids be changed throughout the useful life of the vehicle. If this is the case, the manufacturer should have a reasonable basis that the owner/operator will use fluids having the same properties. This may be accomplished by requiring (in service documentation, labeling, etc.) that only these fluids can be used as replacements. We received comments from EMA asking us to consider maintenance costs for hybrids. In these final rules, we have quantified 
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448For most technologies, manufacturers may 
presume zero deterioration unless good engineering 
judgment does not support such a presumption. For example, it would not be appropriate to presume no deterioration in hybrid battery performance. 449See 40 CFR 86.1803–01 for the applicable 
definition of emergency vehicle. 450See 68 FR 44892—Federal Motor Vehicle 
Safety Standards; Definition of Multifunction School Activity Bus; https://www.govinfo.gov/content/pkg/FR-2003-07-31/pdf/03-19457.pdf . 
451See Occupant Crash Protection rule, 
November 25, 2013, 78 FR 70415, 49 CFR 571, FMVSS 208 https://www.gpo.gov/fdsys/pkg/FR- 
2013-11-25/html/2013-28211.htm, accessed February 2016. 
452Phone conversation March 2016, see L. Steele 
phone log. maintenance costs for tire replacement, 
stop-start, axle lubrication, and hybrids, as described in Section IX.D and the RIA Chapter 7.1. 
Aside from those technologies 
identified above, if the vehicle remains in its original certified condition throughout its useful life, it is not believed that GHG emissions will increase as a result of service accumulation. As in Phase 1, the agencies will therefore allow the use of an assigned deterioration factor of zero where appropriate in Phase 2; however this does not negate the responsibility of the manufacturer to ensure compliance with the emission standards throughout the useful life.
448Under both Phase 1 
and the new Phase program, manufacturers must apply good engineering judgment when considering deterioration and may not ignore any evidence that the emissions performance will decline during actual use. The agencies may require vehicle manufacturers to provide engineering analyses at the time of certification demonstrating that vehicle attributes will last for the full useful life of the vehicle. We anticipate this demonstration would often need only show that components are constructed of sufficiently robust materials and design practices so as not to become dysfunctional under normal operating conditions. 
In Phase 1, EPA set the useful life for 
engines and vehicles with respect to GHG emissions equal to the respective useful life periods for criteria pollutants. In April 2014, as part of the Tier 3 light- duty vehicle final rule, EPA extended the regulatory useful life period for criteria pollutants to 150,000 miles or 15 years, whichever comes first, for Class 2b and 3 pickup trucks and vans and some light-duty trucks (79 FR 23414, April 28, 2014). Class 2 through Class 5 heavy-duty vehicles subject to the GHG standards described in this section for vocational applications generally use the same kinds of engines, transmissions, and emission controls as the Class 2b and 3 vehicles that are chassis-certified to the criteria standards under 40 CFR part 86, subpart S. In Phase 2, EPA and NHTSA are adopting a useful life of 150,000 miles or 15 years for vocational vehicles at or below 19,500 lbs GVWR. In many cases, this will result in aligned useful-life values for criteria and GHG standards. Where this longer useful life is not aligned with the useful life that applies for criteria standards (generally in the case of engine-based certification under 40 CFR part 86, subpart A), EPA may revisit the useful-life values for both criteria and GHG standards in a future rulemaking. For medium heavy-duty vehicles (19,500 to 33,000 lbs GVWR) and heavy heavy-duty vehicles (above 33,000 lbs GVWR) EPA will keep the useful-life values from Phase 1, which are 185,000 miles (or 10 years) and 435,000 miles (or 10 years), respectively. EPA received comments in support of this approach, including support for the numerical values and the overall process envisioned for achieving the long-term goal of adopting harmonized useful-life specifications for criteria pollutant and GHG standards that properly represent the manufacturers’ obligation to meet 
emission standards over the expected service life of the vehicles. 
We received comment on what 
policies we should adopt to address the situation where the engine and the vehicle are subject to emission standards over different useful-life periods. For example, a medium heavy- duty engine may power vehicles in weight classes ranging from 2b to 8, with correspondingly different regulatory useful lives for those vehicles. Please see Section I.F.2.f for a discussion of revisions made to the final regulations to address this situation. The Response to Comments also addresses this issue at Chapter 1.4. 
(d) Definitions of Custom Chassis 
Eligible emergency vehicles for Phase 
2 purposes are ambulances and fire 
trucks. The agencies requested comment on aligning the definition of emergency vehicle for purposes of the Phase 2 program with the definition of emergency vehicle for purposes of the light-duty GHG provisions under 40 CFR 86.1818, which includes additional vehicles such as those used by law enforcement.
449Daimler commented in 
support of aligning these definitions of emergency vehicle. Daimler further requested the agencies consider adopting the same definition as in 13 CCR 1956.8(a)(6), the California regulations. We are adopting the narrow definition as was proposed, with agency discretion to apply these provisions to similar vehicles. 
RVIA commented in favor of adopting 
a motor home definition consistent with NHTSA’s definition at 49 CFR 571.3: Motor home means a multipurpose passenger vehicle with motive power that is designed to provide temporary residential accommodations, as evidenced by the presence of at least 
four of the following facilities: Cooking; refrigeration or ice box; self-contained toilet; heating and/or air conditioning; a potable water supply system including a faucet and a sink; and a separate 110– 125 volt electrical power supply and/or propane. The agencies are adopting a definition of motor home that is generally consistent with this, without specifying detailed features. 
Since 2003, NHTSA has implemented 
a broad definition of school bus that includes multifunction school activity buses that don’t have stop arms or flashing lights, need not be painted yellow, and do not have an upper weight limit. These are a category of school bus that must meet the school bus structural standards or the equivalent set forth in 49 Code of Federal Regulations Part 571, and the emergency exit requirements specified in FMVSS No. 217 for school buses, as well as FMVSS 222 for passenger seating and crash protection. This definition was created in part to allow for use of safe buses to transport school age children on trips other those than between home and school. The agencies are adopting Phase 2 provisions such that buses eligible to certify to the custom chassis school bus standards are those that meet NHTSA’s definition of school bus, including multifunction school activity buses.
450 
The most definitive attribute we have 
identified to distinguish over-the-road coach buses from transit buses is whether passengers are permitted to stand while the vehicle is driving. Therefore the only buses permitted to certify to the final custom chassis coach bus standards are those subject to NHTSA’s Occupant Crash Protection Rule.
451 
Allied Specialty Vehicles (aka Rev 
Group) commented on the need for a clear distinction between transit buses and school buses.
452If the pupils 
transported are not K–12 students, such as may be the case for buses serving college campuses, then the chassis may not be easily distinguishable from transit buses. The agencies are adopting provisions in Phase 2 such that buses not qualifying as eligible to certify as coach buses or school buses must meet the custom chassis standards for transit 
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buses. Buses serving college campuses 
do not have the same design and safety restrictions as those intended to transport primary and secondary school children, and may apply the same technologies as general-purpose urban buses. 
Therefore, we are requiring refuse 
trucks that do not compact waste to be certified to the primary vocational vehicle standards. Front-loading refuse collection vehicles tend to have a relatively low number of stops per day as they tend to collect waste from central locations such as commercial buildings and apartment complexes. Because these have a relatively low amount of PTO operation, we expect stop-start will be reasonably effective for these vehicles. Rear-loading and side- loading neighborhood waste and recycling collection trucks are the refuse trucks where the largest number of stop- start and neutral idle over-ride conditions are likely to be encountered. Because chassis manufacturers, even those with small production volumes and close customer relationships, do not always know whether a refuse truck will be a front-loader, rear-loader, or side loader, we are grouping these together in a subcategory. 
We received comment on the need to 
clarify whether vehicles designed to pump and convey concrete at a job site, but which do not carry the wet mix concrete to the job site, would be included in the definition of cement mixers. Although we are not defining other vehicles as cement mixers, we are allowing miscellaneous vocational vehicles meeting some but not all of the eligibility criteria at 40 CFR 1037.631 to be certified under the custom chassis program, using technology equivalent to the cement mixer package, as described above in Section V.B. 
(e) Assigning Vehicles to Subcategories 
In the NPRM, the agencies proposed 
criteria by which a vehicle manufacturer 
would know in which vocational subcategory—Regional, Urban, or Multipurpose—the vehicle should be certified. These cut-points were defined using calculations relating engine speed to vehicle speed. 80 FR 40287–40288. Specifically, we proposed a cutpoint for the Urban duty cycle where a vehicle at 55 mph would have an engine working above 90 percent of maximum engine test speed for vocational vehicles powered by diesel engines and above 50 percent for vocational vehicles powered by gasoline engines. Similarly, we proposed a cutpoint for the Regional duty cycle where a vehicle at 65 mph would have an engine working below 75 percent of maximum engine test speed for vocational vehicles powered by 
diesel engines and below 45 percent for vocational vehicles powered by gasoline engines. We received several comments that identified weaknesses in that approach. Specifically, Allison explained that vehicles with two shift schedules would need clarification which top gear to use when calculating the applicable cut-point. Also, Daimler noted that, to the extent that downspeeding occurs in this sector over the next decade or more, cutpoints based on today’s fleet may not be valid for a future fleet. Allison noted that the presence of additional top gears could strongly influence the subcategory placement of vocational vehicles. These comments highlight the possibility of misclassification, and the potential pitfalls in a mandated classification scheme. 
Two commenters pointed out 
important weaknesses in this approach, namely that future trends in engine speeds, torque curves, and transmission gear ratio spreads may cause the vocational fleet of 2027 to have drivelines that are sufficiently different than those of the baseline fleet, so that segment cut-points based on the 2016 fleet may not be valid a decade or more into the future. For example, if data on today’s fleet indicated an appropriate cut-point for Regional HHD diesel vehicles of 1,400 rpm engine speed with a vehicle speed of 65 mph, while a future fleet might show that Regional vehicles operated at 1,200 rpm at 65 mph, then having a cut-point set by rule at 1,400 rpm could result in an excess of future vehicles certifying as Regional. However, we have further assessed the impact of manufacturers shifting certification of chassis from Multipurpose to Regional subcategories, and we have concluded this is not an unacceptable outcome. As explained above in Section V.C.(2)(d), we are not particularly concerned that adopting final standards with unequal percent improvements poses a danger of losing environmental benefits from this program, as long as vehicle configurations are properly classified at the time of certification. 
In a regulatory structure where 
baselines are equal but future standards for vehicles in different subcategories have different stringencies, the agencies would typically assign subcategorization based on regulatory criteria rather than allowing the manufacturers unconstrained choice because manufacturers would have a strong incentive to simply choose the least stringent standards. However, 
because the baseline performance levels of the different vocational vehicle regulatory subcategories widely differ, the agencies have determined that it is acceptable to adopt standards with unequal percent stringencies. Further discussion of our reasons for this determination is presented above in Section V.C.(2)(d). Another weakness in the proposed approach was that even though we have obtained a great deal of data thanks to manufacturer cooperation and NREL duty cycle analysis, the only one of the proposed regulatory cut- points in which we have a high degree of confidence is the cut-point between Regional and Multipurpose class 8 diesels. Any cut-points we could establish based on available data for lower weight class diesels or for gasoline powered vocational vehicles would be less robust. These weaknesses have led the agencies to take a different approach to assigning vehicles to subcategories. The agencies are adopting final regulations that generally allow manufacturers to choose a subcategory, with a revised set of constraints as well as a provision requiring use of good engineering judgment. The constraints discussed here are being adopted as interim provisions in response to manufacturers’ concerns that some of them could present competitive disadvantages, where different manufacturers produce very different sales mixes of vehicles equipped with different transmission types, as discussed above in Section V.C.(2)(d). 
Because the baseline configurations 
against which vehicles in the Urban subcategories will measure their future performance do not include any manual transmissions, we have determined that vocational vehicles with manual transmissions may not be certified as Urban. In the real world, we do not expect any vehicles intended to be used in urban driving patterns will be specified with manual transmissions. Driver fatigue and other performance problems make this an illogical choice of transmission, and thus it is appropriate for us to adopt this constraint. As described in Chapter 2.9.2 of the RIA, both the HHD Regional and HHD Multipurpose baselines have a blend of manual transmissions, although the majority of manuals are in the HHD Regional baseline. Further, by MY 2024, our adoption rate of transmission technology reflects zero manuals in HHD Multipurpose. Thus, beginning in MY 2024, any vocational vehicle certified with a manual transmission must be classified in a Regional subcategory, except a vehicle with a hybridized manual transmission may be certified in a Multipurpose subcategory beyond MY 2024. 
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453Based on NREL drive cycle analysis of the 
existing fleet, we imagine that HHD vehicles with 
a diesel engine rpm of 1,400 and below when the vehicle is at 65 mph would be appropriately certified as Regional vehicles. However, this is illustrative only, and the final rules do not include an engine speed cutpoint as a criterion in subcategory selection. We are not adopting constraints on 
vehicles with automated manual 
transmissions certifying in either Regional or Multipurpose subcategories, because we believe this is a technology that can provide real world benefits for vehicles with those driving patterns. However, we are adopting an interim constraint to prevent vehicles with AMT from being certified as Urban for a reason similar to one described above for manuals, namely that in the real world, we do not expect any vehicles intended to be used in urban driving patterns will be specified with transmissions that do not have powershifts. Lack of smooth shifting characteristics during low speed accelerations and decelerations make AMT an illogical choice of transmission 
for urban vehicles, and thus it is appropriate for us to adopt this constraint. 
Dual clutch transmissions have very 
recently become available for medium heavy-duty vocational vehicles and very little data are available on their design or performance. We anticipate that in the future, some designs may have features that make them perform similarly to AMT’s while others may have features that make them more similar to automatics with torque converters. Because we are not confident that we know in which duty cycle(s) they are best suited, we are adopting a partial constraint on these, namely that dual clutch transmissions without powershifting must also be constrained out of Urban. We are finalizing as proposed that any vehicle whose engine is exclusively certified over the SET must be certified in the Regional subcategory. Further, to the extent manufacturers of intercity coach buses and recreational vehicles certify these to the primary standards, these also must be certified as Regional vehicles.
453 
In the final regulatory structure, 
although the standards for vehicles in different subcategories have different percent stringencies from each baseline, the agencies can allow the manufacturers to choose without risking a loss of environmental benefits because a standard that may appear less stringent in terms of relative improvement from each respective baseline may also be numerically lower (and farther away from current model performance) due to a comparatively 
better-performing regulatory baseline. As explained above, the final standards described above in Section V.C.(2)(c) are derived directly from the technology packages without applying any assumptions about fleet averages. Thus, unlike at proposal, the final regulations will generally allow manufacturers to certify in the particular duty-cycle subcategory they believe to be most appropriate. Manufacturers may make this choice as part of the certification process and will not be allowed to change it after the vehicle has been introduced into commerce. Under this structure, the agencies expect manufacturers to choose a subcategory for each vehicle configuration that best represents the type of operation that vehicle will actually experience in use (presuming the manufacturer and customer would specify the technologies to reflect such operation). 
(2) Other Compliance Provisions 
(a) Emission Control Labels 
As proposed, EPA is removing the 
requirement to include the emission 
control system identifiers required in 40 CFR 1037.135(c)(6) and in Appendix III to 40 CFR part 1037 from the emission control labels for vehicles certified to the Phase 2 standards. For vehicles certified to the optional custom chassis standards, the label should meet the requirements of 40 CFR 1037.105(h). Please see Section I.C.(1)(g) of this Preamble for additional discussion of labeling. 
(b) End of Year Reports 
In the Phase 1 program, 
manufacturers participating in the ABT 
program provided 90 day and 270 day reports to EPA and NHTSA after the end of the model year. The agencies adopted two reports for the initial program to help manufacturers become familiar with the reporting process. For the HD Phase 2 program, the agencies proposed to simplify reporting such that manufacturers would only be required to submit the final report 90 days after the end of the model year with the potential to obtain approval for a delay up to 30 days. We requested comments on this approach. EMA, PACCAR, Navistar, Daimler, and Cummins recommended keeping the 270 day report to allow sufficient time after the production period is completed. We are accordingly keeping both the 90 day and 270 day reports, with the ability of the agencies’ to waive the 90 day report. 
(c) Delegated Assembly 
The final standards for vocational 
vehicles are based on the application of a wide range of technologies. Certifying 
vehicle manufacturers manage their compliance demonstration to reflect this range of technologies by describing their certified configurations in the application for certification. In most cases, these technologies are designed and assembled (or installed) directly by the certifying vehicle manufacturer, which is typically the chassis manufacturer. In these cases, it is straightforward to assign the responsibility to the certifying vehicle manufacturer for ensuring that vehicles are in their proper certified configuration before they are introduced into commerce. In Phase 1, the only vehicle technology available for certified vocational vehicles is LRR tires. Because these are generally installed by the chassis manufacturer, there is no need to rely on a second stage manufacturer for purposes of certification in Phase 1, unless innovative credits are sought. Thus, the Phase 1 regulations did not specify precise procedures for this. 
In Phase 2, the agencies are projecting 
adoption of certain technologies where the certifying vehicle manufacturer may want or need to rely on a downstream manufacturing company (a secondary vehicle manufacturer) to take steps to assemble or install certain components or technologies to bring the vehicle into a certified configuration. A similar relationship between manufacturers applies with aftertreatment devices for certified engines. EPA previously adopted ‘‘delegated assembly’’ provisions for engines at 40 CFR 1068.261 to describe how manufacturers can share compliance responsibilities through these cooperative assembly procedures, and proposed to also apply it for vehicle-based GHG standards in 40 CFR part 1037, including the vocational vehicle standards. 
The delegated assembly provisions 
being finalized for Phase 2 vehicle standards are only invoked if a certifying manufacturer includes in its certified configuration a technology that it does not install itself. Examples may include fairings to reduce aerodynamic drag, air conditioning systems, automatic tire inflation systems, or hybrid systems. We are clarifying this regulatory process to enable manufacturers to include technologies in their compliance plans that might otherwise not be considered on the basis of what they can install themselves. To the extent certifying manufacturers rely on secondary vehicle manufacturers to bring the vehicle into a certified configuration, the following provisions will apply: 
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•The certifying manufacturer will 
describe its approach to delegated 
assembly in the application for certification. 
•The certifying manufacturer will 
create installation instructions to describe how the secondary vehicle manufacturer will bring the vehicle into a certified configuration. 
•The certifying manufacturer must 
take additional steps for certified configurations that include hybrid powertrain components, auxiliary power units, aerodynamic devices, or natural gas fuel tanks. In these cases, the certifying manufacturer must have a contractual agreement with each affected secondary vehicle manufacturer obligating the secondary vehicle manufacturer to build each vehicle into a certified configuration and to provide affidavits confirming proper assembly procedures, and to provide information 
regarding deployment of each type of technology (if there are technology options that relate to different GEM input values). 
See Section I.F of this Preamble and 
Section 1.4.4 of the RTC for further discussion of the comments received on delegated assembly provisions. 
The agencies have developed the 
delegated-assembly and other provisions in 40 CFR 1037.620— 1037.622 to clarify how manufacturers have shared and separate responsibilities for complying with the regulations. Vocational vehicles are the most likely vehicle types to involve both primary and secondary manufacturers; however, other types of vehicles may also involve multiple manufacturers, so these regulatory provisions apply to all vehicles. 
Secondary manufacturers (such as 
body builders) that build complete vehicles from certified chassis are obligated to comply with the emission- related installation instructions provided by the certifying manufacturer. Secondary manufacturers that build complete vehicles from exempted chassis are similarly obligated to comply with all of the regulatory provisions related to the exemption. 
(d) Demonstrating Compliance With 
HFC Leakage Standards 
EPA’s requirements for vocational 
chassis manufacturers to demonstrate reductions in direct emissions of HFC in their A/C systems and components through a design-based method. The method for calculating A/C leakage is the same as was adopted in Phase 1 for tractors and HD pickups and vans. It is based closely on an industry-consensus leakage scoring method, described below. This leakage scoring method is correlated to experimentally-measured leakage rates from a number of vehicles using the different available A/C components. As is done currently for other HD vehicles, vocational chassis manufacturers will choose from a menu of A/C equipment and components used in their vehicles in order to establish leakage scores, to characterize their A/ C system leakage performance. The percent leakage per year will then be calculated as this score divided by the system refrigerant capacity. We received comments from transit bus manufacturers with concerns that the air conditioning systems on their vehicles are much larger and more complex than systems on typical heavy-duty trucks. As such, they questioned whether our HFC leakage compliance process was valid for their vehicles. Based on information provided by suppliers of air conditioning systems for large buses, we believe some unusually large systems may include components not adequately represented by those listed in the standard compliance procedure, namely the hoses, fittings or seals may not be listed with realistic leakage rates. Therefore EPA is adopting in this final rule provisions allowing use of an alternate compliance procedure where an air conditioning system with refrigerant charge capacity greater than 3,000 grams is installed in a Phase 2 vocational vehicle. 
Consistent with the light-duty rule 
and the Phase 1 program for other HD vehicles, vocational chassis manufacturers will compare the components of a vehicle’s A/C system with a set of leakage-reduction technologies and actions that is based closely on that developed through the Improved Mobile Air Conditioning program and SAE International (as SAE Surface Vehicle Standard J2727, ‘‘HFC– 134a, Mobile Air Conditioning System Refrigerant Emission Chart,’’ August 2008 version). See generally 75 FR 
25426. The SAE J2727 approach was developed from laboratory testing of a variety of A/C related components, and EPA believes that the J2727 leakage scoring system generally represents a reasonable correlation with average real- world leakage in new vehicles. This approach associates each component with a specific leakage rate in grams per year that is identical to the values in J2727 and then sums together the component leakage values to develop the total A/C system leakage. Unlike the light-duty program, in the heavy-duty vehicle program, the total A/C leakage score is divided by the value of the total refrigerant system capacity to develop a percent leakage per year. EPA concludes that the design-based 
approach results in estimates of likely 
leakage emissions reductions that are comparable to those that would result from performance-based testing. Where a manufacturer installs an air conditioning system in a vocational vehicle that has a working fluid consisting of an alternate refrigerant with a lower global warming potential than HFC–134a, compliance with the leakage standard is addressed in the regulations at 40 CFR 1037.115. Please see Section I.F.(2)(b) for a discussion related to alternative refrigerants. 
Consistent with the HD Phase 1 
program and the light-duty rule, where we require that manufacturers attest to the durability of components and systems used to meet the CO
2standards 
(see 75 FR 25689), we are requiring that manufacturers of heavy-duty vocational 
vehicles attest to the durability of these systems, and provide an engineering analysis that demonstrates component and system durability. 
(e) Glider Vehicles 
EPA and NHTSA requested comment 
on gliders and received extensive 
comment. The main issues involve standards for rebuilt engines installed in new glider vehicles. These issues are fully addressed in Preamble Section XIII.B and RTC Section 14.2. Of relevance for the vocational vehicle sector, the final standards contain a number of provisions allowing donor engines that are still within their regulatory useful life to be used in new glider vehicles provided the engine meets all standards applicable to the year in which the engine was originally manufactured and also meets one of the following criteria: 
•The engine is still within its 
original useful life in terms of both miles and years. 
•The engine has less than 100,000 
miles of engine operation. 
•The engine is less than three years 
old. 
Thus, if a donor engine meeting one 
of the above criteria was manufactured before the Phase 1 GHG standards, it would not be subject to those standards when installed in a glider vehicle. Similarly, if such an engine was manufactured before 2010, it would be subject to the pre-2010 criteria pollutant standards corresponding to its year of manufacture. EPA is adopting this provision consistent with the original purpose of glider vehicles as providing a means of salvaging of relatively new powertrains from vehicle chassis that have been damaged or have otherwise failed prematurely. See Section XIII.B of the Preamble. 
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454See 40 CFR 1037.150(o) and 49 CFR 535.7. (3) Compliance Flexibility Provisions 
EPA and NHTSA are adopting several 
flexibility provisions in the Phase 2 
program. Program-wide compliance flexibilities include an averaging, banking and trading program for CO
2 
emissions and fuel consumption credits, provisions for off-cycle credits for technologies that are not included as inputs to the GEM, and advanced technology credits. These are described below as well as in Section I.B.3 to I.C.1. Provisions that are not program-wide include optional chassis certification and a revised interim loose engines provision, as described below. 
(a) Averaging, Banking, and Trading 
(ABT) Program 
Averaging, banking, and trading of 
emission credits have been an important part of many EPA mobile source programs under CAA Title II. ABT provisions provide manufacturers flexibilities that assist in the efficient development and implementation of new technologies and therefore enable new technologies to be implemented at a more aggressive pace than without ABT. NHTSA and EPA are carrying-over the Phase 1 ABT provisions for vocational vehicles into Phase 2, as it is an important way to achieve each agency’s programmatic goals. ABT is also discussed in Section I and Section III.F.1. 
Consistent with the Phase 1 averaging 
sets, the agencies are allowing chassis manufacturers to average SI-powered vocational vehicle chassis with CI- powered vocational vehicle chassis, within the same vehicle weight class group. In Phase 1, all vocational and tractor chassis within a vehicle weight class group were able to average with each other, regardless of whether they were powered by a CI or SI engine. The Phase 2 approach continues this. The only difference is that in Phase 2, there are different numerical standards set for the SI-powered and CI-powered vehicles, but that does not alter the basis for averaging. This is consistent with the Phase 1 approach where, for example, Class 8 day cab tractors, Class 8 sleeper cab tractors and Class 8 vocational vehicles each have different numerical standards, while they all belong to the same averaging set. 
As discussed in V.D.(1)(c), EPA and 
NHTSA are adopting a revised useful life for LHD vocational vehicles for GHG emissions from the current 10 years/ 110,000 miles to 15 years/150,000 miles, to be consistent with the useful life of criteria pollutants recently updated in EPA’s Tier 3 rule. For the same reasons, EPA and NHTSA are also adopting a useful life adjustment for HD pickups 
and vans, as described in Section VI.E.(1). According to the credits calculation formula at 40 CFR 1037.705 and 49 CFR 535.7, useful life in miles is a multiplicative factor included in the calculation of CO
2and fuel 
consumption credits. In order to ensure that banked credits will maintain their value in the transition from Phase 1 to Phase 2, NHTSA and EPA are adopting an interim vocational vehicle adjustment factor of 1.36 for credits that are carried forward from Phase 1 to the MY 2021 and later Phase 2 standards.
454 
Without this adjustment factor the change in useful life would effectively result in a discount of banked credits that are carried forward from Phase 1 to Phase 2, which is not the intent of the change in the useful life. The agencies do not believe that this adjustment will result in a loss of program benefits because there is little or no deterioration anticipated for CO
2emissions and fuel 
consumption over the life of the vehicles. Also, the carry-forward of credits is an integral part of the program, helping to smooth the transition to the Phase 2 standards. The agencies believe that effectively discounting carry-forward credits from Phase 1 to Phase 2 is unnecessary and could negatively impact the feasibility of the Phase 2 standards. EPA and NHTSA requested comment on all aspects of the averaging, banking, and trading program. A complete discussion of the comments on credits and ABT can be found in the RTC Section 1.4. 
(b) Innovative and Off-Cycle Technology 
Credits 
In Phase 1, the agencies adopted an 
emissions and fuel consumption credit generating opportunity that applied to innovative technologies that reduce fuel consumption and CO
2emissions. 
Eligible technologies were required to not be in common use with heavy-duty vehicles before the 2010MY and not 
reflected in the GEM simulation tool (i.e., the benefits are ‘‘off-cycle’’). See 76 
FR 57253. In Phase 2, the agencies are re-designating it as an off-cycle technology program. The agencies are maintaining the requirement that, in order for a manufacturer to receive credits for Phase 2, the off-cycle technology must not have been in common use prior to MY 2010. 
The agencies recognize that there are 
emerging technologies today that are being developed, but will not be accounted for in the GEM tool, and therefore will be considered off-cycle. For vocational vehicles, this could include technologies whose scope and effectiveness surpass those defined and pre-approved in the HD Phase 2 program, such as aerodynamics and electrified accessories. Any credits for these technologies will need to be based on real-world fuel consumption and GHG reductions that can be measured with verifiable test methods using representative driving conditions typical of the engine or vehicle application. More information about off- cycle technology credits can be found at Section I.C.1.c. 
As in Phase 1, the agencies will 
continue to provide two paths for approval of the test procedure to measure the CO
2emissions and fuel 
consumption reductions of an off-cycle technology used in vocational vehicles. See 40 CFR 1037.610 and 49 CFR 535.7. The first path will not require a public approval process of the test method. A manufacturer may use ‘‘pre-approved’’ test methods for HD vehicles including the A-to-B chassis testing, powerpack testing or on-road testing. A manufacturer may also use any developed test procedure that has known quantifiable benefits. A test plan detailing the testing methodology will be required to be approved prior to collecting any test data. The agencies are also continuing the second path, which includes a public approval process of any testing method that could have questionable benefits (i.e., an 
unknown usage rate for a technology). Furthermore, the agencies are adopting revisions to clarify what documentation must be submitted for approval, aligning them with provisions in 40 CFR 86.1869–12. NHTSA is prohibiting credits from technologies addressed by any of its crash avoidance safety rulemakings (i.e., congestion 
management systems). See also 77 FR 62733 (discussion of similar issue in the light duty greenhouse gas/fuel economy regulations). We received extensive comment on the off-cycle technology approval process. In response to requests to develop a streamlined path for off-cycle technology approval, we are not making fundamental changes from the proposal at this time; however, we remain open to working with stakeholders to look for ways to simplify the process. For example, although we are including specific provisions to recognize certain electrified accessories, recognizing others would require the manufacturer to go through the off-cycle process. However, it is quite possible that the agencies could gather sufficient data to allow us to adopt specific provisions in a future rulemaking to recognize other accessories in a simpler 
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455Meeting with Isuzu dated April 22, 2016. manner. Please see Section I.C. of this 
Preamble for further discussion of off- cycle credits. 
There are some technologies that are 
entering the market today, and although our model does not have the capability to simulate the effectiveness over the test cycles, there are reliable estimates 
of effectiveness available to the agencies. These will be recognized in our HD Phase 2 certification procedures as pre-defined technologies, and will not be considered off-cycle. Examples of such technologies for vocational vehicles include narrowly-defined types of electrified accessories or aerodynamic improvements. The agencies are specifying default effectiveness values to be used as valid inputs to GEM for each of these. The projected effectiveness of each vocational vehicle technology is discussed in the RIA Chapter 2.9.3. 
The agencies’ approval for Phase 1 
innovative technology credits (approved prior to 2021 MY) will be carried into the Phase 2 program on a limited basis for those technologies where the benefit is not accounted for in the Phase 2 test procedure. Therefore, the manufacturers will not be required to request new approval for any innovative credits carried into the off-cycle program, but will have to demonstrate, as part of the MY 2021 certification, the extent to which the new cycle does not account for these improvements. The agencies believe this is appropriate because technologies, such as those related to the transmission or driveline, may no longer be ‘‘off-cycle’’ because of the addition of these technologies into the Phase 2 version of GEM. 
(c) Advanced Technology Credits 
As described above in Section I, the 
agencies proposed to discontinue 
advanced technology credits in Phase 2, which had been intended to promote the early implementation of advanced technologies that were not expected to be widely adopted in the market in the 2014 to 2018 time frame. These technologies were defined in Phase 1 as hybrid powertrains, Rankine cycle engines, all-electric vehicles, and fuel cell vehicles (see 40 CFR 1037.150(p)), at a 1.5 credit value. We requested and received comments on the need for such incentives, and as a result we are not only continuing these credits, we are adopting even greater multipliers than before. See Section I of this Preamble for further discussion of the comments received and the agencies’ response regarding advanced technology credits. (d) Optional Chassis Certification 
In Phase 2, the agencies are 
continuing the Phase 1 option to chassis 
certify vehicles over 14,000 lbs GVWR, but only if there is a family with vehicles at or below 14,000 pounds GVWR that can properly accommodate the bigger vehicles as part of the same family. As adopted in this final rule, chassis-certified vehicles above 14,000 pounds GVWR may not rely on a work factor that is greater than the largest work factor that applies for vehicles at or below 14,000 pounds GVWR from the same family. Applying this work factor constraint avoids the need to set a specific upper GVWR limit on vehicles eligible to use this flexibility. See Section XIII.A.2 of this Preamble, and Section 14.3.2 of the RTC, for further discussion of this issue. 
(e) Certifying Loose SI Engines in 
Vocational Vehicles in Phase 2 
The agencies proposed not to 
continue the Phase 1 interim flexibility known as the ‘‘loose engine’’ provision, receiving favorable comment from Cummins and adverse comment on this from Isuzu and AAPC. 80 FR 40331. Under this provision, SI engines produced by manufacturers of HD pickup trucks and vans and sold to chassis manufacturers and intended for use in vocational vehicles need not meet the separate SI engine standard, and instead may be averaged with the manufacturer’s HD pickup and van fleet (see 40 CFR 86.1819–14(k)(8)). The agencies are adopting a Phase 2 SI engine standard that is no more stringent than the MY 2016 SI engine standard adopted in Phase 1, while the Phase 2 standards for the HD pickup and van fleet is progressively more stringent through MY 2027. The primary certification path designed in the Phase 1 program for both CI and SI engines sold separately and intended for use in vocational vehicles is that they are engine certified while the vehicle is GEM certified under the GHG rules. 
This provision was adopted primarily 
to address small volume sales of engines used in complete vehicles that are also sold to other manufacturers. The Phase 1 final rules explain that we set the effective date of the Phase 1 SI engine standard as MY 2016 because we projected by this time all manufacturers would have redesigned their gasoline engine offerings to adopt the technologies needed to reduce FTP- cycle emissions by five percent; technologies that cannot simply be bolted on to an existing engine but can only be effectively applied through an integrated design and development process (76 FR 57180, 57235). The 
Phase 1 final rules also explain that the compliance flexibility provided by the loose engine provision is technically appropriate because it provides manufacturers with an option to focus their energy on improving the GHG and fuel consumption performance of their complete vehicle products (including engine improvements), rather than on concurrently calibrating for both vehicle and engine test compliance (76 FR 57260). At proposal we noted that although gasoline engine manufacturers have accomplished extensive improvements to comply with HD pickup and vans standards as well as the light-duty vehicle standards, the agencies had not seen evidence of the engine redesigns that we had projected to occur by 2016, and we concluded that discontinuation of this flexibility by MY 2021 was appropriate to provide regulatory certainty on the date beyond which engine certification would be mandatory for HD SI engines. 
However, in response to persuasive 
comments from a chassis manufacturer that purchases these engines, we are adopting a narrow extension of this interim flexibility, where for MYs 2021– 2023, each SI engine manufacturer may sell an annual maximum of 10,000 SI engines certified under this provision.
455We believe this three-year 
extension is needed to prevent market disruptions. We are concerned that SI engine manufacturers might not choose to certify any SI engines that can be sold to other vocational chassis manufacturers, which would significantly disrupt the market. With this limited extension, we are ensuring no loss of environmental benefits because any vehicle certified by a chassis manufacturer who obtains a high-emitting SI engine must apply additional technology as needed to meet the applicable vocational vehicle standard. We are generally not allowing custom chassis manufacturers to use SI engines that have been certified under this loose engine provision, if they are certifying using one of the custom chassis regulatory subcategories. However, manufacturers certifying motor homes or emergency vehicles to the optional standards may install engines certified through the interim loose engine provision. The typical annual miles driven by these vehicles is very low, usually between 2,000 and 5,000 miles for either motor homes or emergency vehicles, and thus their contribution to emissions and fuel consumption is very small. See Section II of this Preamble for a discussion of 
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456The Light-duty FTP is a vehicle driving cycle 
that was originally developed for certifying light- 
duty vehicles and subsequently applied to HD chassis testing for criteria pollutants. This contrasts with the Heavy-duty FTP, which refers to the transient engine test cycles used for certifying heavy-duty engines (with separate cycles specified for diesel and spark-ignition engines). 
457Light duty fuel economy standards are 
expressed as miles per gallon (mpg), which is inverse to the HD fuel consumption standards 
which are expressed as gallons per 100 miles. 
458EISA requires CAFE standards for passenger 
cars and light trucks to be attribute-based; See 49 
U.S.C. 32902(b)(3)(A). 
459The NAS 2010 report likewise recommended 
standards recognizing the work function of HD vehicles. See 76 FR 57161. the comments received and the 
agencies’ response on the separate engine standard for SI engines intended for vocational vehicles. 
(f) On-Board Diagnostics for Hybrid 
Vehicle Systems 
In HD Phase 1, EPA adopted 
provisions to delay the onboard diagnostics (OBD) requirements for heavy-duty hybrid powertrains (see 40 CFR 86.010–18(q)). This provision delayed full OBD requirements for hybrids until MY 2016 and MY 2017. The agencies have received comments from hybrid manufacturers regarding their progress toward meeting the on- board diagnostic requirements for criteria pollutant engine certification related to hybrid systems. See Section XIII.A.1 for a discussion of comments received and EPA’s response related to certification of engines paired with hybrid powertrain systems. 
VI. Heavy-Duty Pickups and Vans 
In the NPRM, the agencies conducted 
coordinated and complementary 
analyses using two analytical methods for the heavy-duty pickup and van segment, both of which used the same version of NHTSA’s CAFE model to analyze technology. The agencies have also used two analytical methods for the joint final rule. However, unlike the NPRM, for the joint final rule, the agencies are using different versions of NHTSA’s CAFE model to analyze technology. The Method B approach continues to use the same version of the model and inputs that was used for the NPRM. Method A uses an updated version of the CAFE model and some updated inputs. 
A. Summary of Phase 1 HD Pickup and 
Van Standards 
In the Phase 1 rule, EPA and NHTSA 
established GHG and fuel consumption standards and a program structure for complete Class 2b and 3 heavy-duty vehicles (referred to in these rules as ‘‘HD pickups and vans’’), as described below. The Phase 1 standards began to be phased-in in MY 2014 and the agencies believe the program is working well. The agencies are retaining most elements from the structure of the program established in the Phase 1 rule for the Phase 2 program while establishing more stringent Phase 2 standards for MY 2027, phased in over MYs 2021–2027, that will require additional GHG reductions and fuel consumption improvements. As discussed below, the agencies are adopting the Phase 2 standards as proposed. The MY 2027 standards will remain in place unless and until 
amended by the agencies. 
Heavy-duty vehicles with GVWR 
between 8,501 and 10,000 lbs. are classified in the industry as Class 2b motor vehicles. Class 2b includes vehicles classified as medium-duty passenger vehicles (MDPVs) such as very large SUVs. Because MDPVs are frequently used like light-duty passenger vehicles, they are regulated by the agencies under the light-duty vehicle rules. Thus, the agencies did not adopt additional requirements for MDPVs in the Phase 1 rule and are not adopting additional requirements for MDPVs in this rulemaking. Heavy-duty vehicles with GVWR between 10,001 and 14,000 lbs are classified as Class 3 motor vehicles. Class 2b and Class 3 heavy-duty vehicles together emit about 23 percent of today’s GHG emissions from the heavy-duty vehicle sector. 
About 90 percent of HD pickups and 
vans are 
3⁄4-ton and 1-ton pickup trucks, 
12- and 15-passenger vans, and large work vans that are sold by vehicle manufacturers as complete vehicles, with no secondary manufacturer making substantial modifications prior to registration and use. Most of these vehicles are produced by companies with major light-duty markets in the United States, primarily Ford, General Motors, and Fiat Chrysler. Often, the technologies available to reduce fuel consumption and GHG emissions from this segment are similar to the technologies used for the same purpose on light-duty pickup trucks and vans, including both engine efficiency improvements (for gasoline and diesel engines) and vehicle efficiency improvements. 
In the Phase 1 rule, EPA adopted GHG 
standards for HD pickups and vans based on the whole vehicle (including the engine), expressed as grams of CO
2 
per mile, consistent with the way these vehicles are regulated by EPA today for criteria pollutants. NHTSA adopted corresponding gallons per 100 mile fuel consumption standards that are likewise based on the whole vehicle. This complete vehicle approach adopted by both agencies for HD pickups and vans was consistent with the recommendations of the NAS Committee in its 2010 Report. EPA and NHTSA adopted a structure for the 
Phase 1 HD pickup and van standards that in many respects paralleled long- standing NHTSA CAFE standards and more recent coordinated EPA GHG standards for manufacturers’ fleets of new light-duty vehicles. These commonalities include a new vehicle fleet average standard for each manufacturer in each model year and the determination of these fleet average standards based on production volume- weighted targets for each model, with the targets varying based on a defined vehicle attribute. Vehicle testing for both the HD and light-duty vehicle programs is conducted on chassis dynamometers using the drive cycles from the EPA Federal Test Procedure (Light-duty FTP or ‘‘city’’ test) and Highway Fuel Economy Test (HFET or ‘‘highway’’ test).
456 
For the light-duty GHG and fuel 
economy457standards, the agencies 
factored in vehicle size by basing the emissions and fuel economy targets on vehicle footprint (the wheelbase times the average track width).
458For those 
standards, passenger cars and light trucks with larger footprints are assigned higher GHG and lower fuel economy target levels in acknowledgement of their inherent tendency to consume more fuel and emit more GHGs per mile. EISA requires that NHTSA study ‘‘the appropriate metric for measuring and expressing commercial medium- and heavy-duty vehicle and work truck fuel efficiency performance, taking into consideration, among other things, the work performed by such on-highway vehicles and work trucks . . .’’ See 49 U.S.C. 32902(k)(1)(B).
459For HD pickups and 
vans, the agencies also set standards based on a vehicle attribute, but used a work-based metric as the attribute rather than the footprint attribute utilized in the light-duty vehicle rulemaking. Work-based measures such as payload and towing capability are key among the parameters that characterize differences in the design of these vehicles, as well as differences in how the vehicles will be utilized. Buyers consider these utility-based attributes when purchasing a HD pickup or van. EPA and NHTSA therefore finalized Phase 1 standards for HD pickups and vans based on a ‘‘work factor’’ attribute that combines the vehicle’s payload and towing capabilities, with an added adjustment 
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460The Phase 1 Final Rule provides a full 
discussion of the standard curves including the 
equations and coefficients. See 76 FR 57162–57165, 
September 15 2011. The standards were previously provided in the regulations at 40 CFR 1037.104, but they are now being redesignated as 40 CFR 
86.1819–14. 
461The NHTSA program provides voluntary 
standards for model years 2014 and 2015. Target line functions for 2016–2018 are for the second NHTSA alternative described in the Phase 1 Preamble Section II.C.(d)(ii). for 4-wheel drive vehicles. See generally 
76 FR 57161–57162. 
For Phase 1, the agencies adopted 
provisions such that each manufacturer’s fleet average standard is based on production volume-weighting of target standards for all vehicles that in turn are based on each vehicle’s work factor. These target standards are taken from a set of curves (mathematical 
functions). The Phase 1 curves are shown in the figures below for reference and are described in detail in the Phase 1 final rule.
460The agencies established 
separate curves for diesel and gasoline HD pickups and vans. The agencies will continue to use the work-based attribute 
and gradually declining standards approach for the Phase 2 standards, as 
discussed in Section VI.B. below. Note that this approach does not create an incentive to reduce the capabilities of these vehicles because less capable vehicles are required to have proportionally lower emissions and fuel consumption targets. 
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750 
700 
650 --- ----
E 600 ... 
Ql c. E 55o 
ra ... 
~ 
N 500 
0 u 
450 
400 
350 
300 ' 
0 Diesel Vehicles 
1000 2000 3000 4000 5000 6000 7000 8000 9000 
Work Factor (pounds) 6.95 
5.95 
4.95 
3.95 
2.95 
10000 Ill 
~ .E 
0 
0 
.-1 
Qj 
c. 
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Figure Vl-1 EPA Phase 1 C02 Target Standards and NHTSA Fuel Consumption Target Standards for Diesel 
HD Pickups and Vans461 73731 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
EPA phased in its CO 2standards 
gradually starting in the 2014 model 
year, at 15–20–40–60–100 percent of the model year 2018 standards stringency level in model years 2014–2015–2016– 2017–2018, respectively. The phase-in takes the form of the set of target standard curves shown above, with increasing stringency in each model year. The final EPA Phase 1 standards for 2018 (including a separate standard to control air conditioning system leakage) represent an average per- vehicle reduction in GHGs of 17 percent for diesel vehicles and 12 percent for 
gasoline vehicles, compared to a common MY 2010 baseline. EPA also finalized a compliance alternative whereby manufacturers can phase in different percentages: 15–20–67–67–67– 100 percent of the model year 2019 standards stringency level in model years 2014–2015–2016–2017–2018– 2019, respectively. This compliance 
alternative parallels and is equivalent to NHTSA’s first alternative described below. 
NHTSA’s Phase 1 program allows 
manufacturers to select one of two fuel consumption standard alternatives for model years 2016 and later. The first 
alternative defines individual gasoline vehicle and diesel vehicle fuel consumption target curves that will not change for model years 2016–2018, and are equivalent to EPA’s 67–67–67–100 percent target curves in model years 2016–2017–2018–2019, respectively. This option is consistent with EISA requirements that NHTSA provide 4 years lead-time and 3 years of stability for standards. See 49 U.S.C. 32902(k)(3). The second alternative uses target curves that are equivalent to EPA’s 40– 60–100 percent target curves in model years 2016–2017–2018, respectively. This option is also consistent with EISA 
lead-time and stability requirements. Stringency for the alternatives in Phase 1 was selected by the agencies to allow a manufacturer, through the use of the credit carry-forward and carry-back provisions that the agencies also finalized, to meet both NHTSA fuel efficiency and EPA GHG emission standards using a single compliance strategy. If a manufacturer cannot meet an applicable standard in a given model year, it may make up its shortfall by over-complying in a subsequent year. NHTSA also allows manufacturers to voluntarily opt into the NHTSA HD pickup and van program in model years 2014 or 2015. For these model years, NHTSA’s fuel consumption target curves are equivalent to EPA’s target curves. The Phase 1 phase-in options are summarized in Table VI–1. 
TABLE VI–1—P HASE 1 STANDARDS PHASE -INOPTIONS  
2014 
% 2015 
% 2016 
% 2017 
% 2018 
% 2019 
% 
EPA Primary Phase-in ............................. 15 20 40 60 100 100 
EPA Compliance Option .......................... 15 20 67 67 67 100 
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TABLE VI–1—P HASE 1 STANDARDS PHASE -INOPTIONS —Continued 
2014 
% 2015 
% 2016 
% 2017 
% 2018 
% 2019 
% 
NHTSA First Option ................................. 0 0 67 67 67 100 
NHTSA Second Option ............................ 0 0 40 60 100 100 
The form and stringency of the Phase 
1 standards curves are based on the 
performance of a set of vehicle, engine, and transmission technologies expected (although not required) to be used to meet the GHG emissions and fuel economy standards for model year 2012–2016 light-duty vehicles, with full consideration of how these technologies are likely to perform in heavy-duty vehicle testing and use. All of these technologies are already in use or have been announced for upcoming model years in some light-duty vehicle models, and some are in use in a portion of HD pickups and vans as well. The technologies include: 
•advanced 8-speed automatic 
transmissions 
•aerodynamic improvements 
•electro-hydraulic power steering 
•engine friction reductions 
•improved accessories 
•low friction lubricants in powertrain 
components 
•lower rolling resistance tires 
•lightweighting 
•gasoline direct injection 
•diesel aftertreatment optimization 
•air conditioning system leakage 
reduction (for EPA program only) 
B. HD Pickup and Van Final Phase 2 
Standards 
As described in this section, NHTSA 
and EPA are adopting as proposed Phase 2 standards that will be phased in over model years 2021–2027 and continue thereafter unless and until amended. These standards are identical to those proposed as Alternative 3 (the preferred alternative at proposal). The agencies are adopting standards based on a year-over-year increase in stringency of 2.5 percent over MYs 2021–2027 for a total increase in stringency for the Phase 2 program of about 16 percent compared to the MY 2018 Phase 1 standard. Note that an individual manufacturer’s fleet-wide target may differ from this stringency increase due to changes in vehicle sales mix and changes in work factor. We believe the standards the agencies are adopting are feasible in the time frame of this rule. 
As discussed in detail below in 
Sections C through F, the agencies performed separate analyses, which we refer to as ‘‘Method A’’ and ‘‘Method B.’’ NHTSA considered Method A as the central analysis in its determination of the stringency of the Phase 2 standards. EPA considered the results of Method B as the central analysis for its determination of the stringency of the Phase 2 standards. These analyses are complementary, and independently support the same conclusion. 
In the proposal, the agencies also 
sought comment on a number of alternatives, including an alternative (‘Alternative 4’) which would have resulted in approximately the same stringency increase, but would have done so two years earlier (in MY 2025 rather than MY 2027), so that the effective year-over-year stringency would have been 3.5%. The agencies are not adopting this alternative. The agencies’ analyses show that the additional lead-time provided by the Phase 2 standards that the agencies are adopting will allow manufacturers to more fully utilize lower cost technologies over vehicle life-cycles. In addition, under the method B analysis, this would reduce the projected adoption rate of more advanced higher cost technologies such as strong hybrids compared to Alternative 4. As discussed in more detail in E.1 below, both of the considered phase-ins are projected to require comparable penetration rates of several non-hybrid technologies with some approaching 100 percent penetration. However, as discussed below, the additional lead-time provided by the final standards will allow manufacturers more flexibility to implement technologies at later redesigns and refreshes. The agencies received several comments regarding the timing and stringency of the standards. These comments are discussed in detail in Section E.1 below and in Chapter 7 of the Response to Comments document. 
When considering potential Phase 2 
standards, the agencies anticipate that the technologies listed above that were considered in Phase 1 will continue to be available in the future, if not already applied under Phase 1 standards, and that additional technologies will also be available: 
•advanced engine improvements for 
friction reduction and low friction 
lubricants •improved engine parasitics, including 
fuel pumps, oil pumps, and coolant pumps 
•valvetrain variable lift and timing 
•cylinder deactivation 
•direct gasoline injection 
•cooled exhaust gas recirculation 
•turbo downsizing of gasoline engines 
•Diesel engine efficiency 
improvements 
•downsizing of diesel engines 
•8-speed automatic transmissions 
•electric power steering 
•high efficiency transmission gear 
boxes and driveline 
•further improvements in accessory 
loads 
•additional improvements in 
aerodynamics and tire rolling resistance 
•low drag brakes 
•mass reduction 
•mild hybridization 
•strong hybridization 
Sections VI.C below and Section 2 of 
the RIA provide a detailed analysis of these and other potential technologies for Phase 2, including their feasibility, costs, and effectiveness and projected application rates for reducing fuel consumption and CO
2emissions when 
utilized in HD pickups and vans. Sections VI.D and Section X also discuss the selection of the Phase 2 standards and the alternatives considered. 
In addition to EPA’s CO
2emission 
standards and NHTSA’s fuel consumption standards for HD pickups and vans, EPA in Phase 1 also finalized standards for two additional GHGs— N
2O and CH 4, as well as standards for 
air conditioning-related HFC emissions. EPA will continue these standards in Phase 2. Also, consistent with CAA section 202(a)(1), EPA finalized Phase 1 standards that apply to HD pickups and vans in use and EPA is likewise adopting in-use standards for these vehicles in Phase 2. All of these standards are discussed in more detail below. Program flexibilities and compliance provisions related to the standards for HD pickups and vans are discussed in Section VI.E. 
A relatively small number of HD 
pickups and vans are sold by vehicle manufacturers as incomplete vehicles, without the primary load-carrying device or container attached. A sizeable 
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462See 76 FR 57259–57260, September 15, 2011 
and 78 FR 36374, June 17, 2013. 463The NAS 2010 report. See 76 FR 57161. subset of these incomplete vehicles, 
often called cab-chassis vehicles, are sold by the vehicle manufacturers in configurations with complete cabs plus many of the components that affect GHG emissions and fuel consumption identical to those on complete pickup truck or van counterparts—including engines, cabs, frames, transmissions, axles, and wheels. The Phase 1 program includes provisions that allow manufacturers to include these incomplete vehicles, as well as some Class 4 through 6 vehicles, to be regulated under the chassis-based HD pickup and van program (i.e. subject to 
the standards and chassis certification for HD pickups and vans), rather than under the vocational vehicle program.
462The agencies are continuing 
to allow such incomplete vehicles the option of certifying under either the heavy duty pickup and van standards or the standards for vocational vehicles. As in Phase 1, if such an incomplete vehicle is certified as a vocational vehicle, the engine would have to be certified separately to the applicable 
engine standard. 
Phase 1 also includes optional 
compliance paths for spark-ignition engines identical to engines used in heavy-duty pickups and vans to comply with 2b/3 standards. See 40 CFR 1037.150(m) and 49 CFR 535.5(a)(7). Manufacturers sell such engines as ‘‘loose engines’’ or install these engines in incomplete vehicles that are not cab- complete vehicles. The agencies are providing a temporary loose engine provision for Phase 2 as described in Section V.D.3.e, under Compliance Flexibility Provisions. These program elements are discussed above in Section V.D. on vocational vehicles and XIII.A.2 on engines. 
(1) Vehicle-Based Standards 
For Phase 1, EPA and NHTSA chose 
to set vehicle-based standards whereby 
the entire vehicle is chassis-tested. The agencies will retain this approach for Phase 2. About 90 percent of Class 2b and 3 vehicles are pickup trucks, passenger vans, and work vans that are sold by the original equipment manufacturers as complete vehicles, ready for use on the road. In addition, most of these complete HD pickups and vans are covered by CAA vehicle emissions standards for criteria pollutants (i.e., they are chassis tested 
similar to light-duty), expressed in grams per mile. This distinguishes this category from other, larger heavy-duty vehicles that typically have engines covered by CAA engine emission 
standards for criteria pollutants, expressed in grams per brake horsepower-hour. As a result, Class 2b and 3 complete vehicles share both substantive elements and a regulatory structure much more in common with light-duty trucks than with the other heavy-duty vehicles. 
Three of these features in common are 
especially significant: (1) Over 95 percent of the HD pickups and vans sold in the United States are produced by Ford, General Motors, and Fiat Chrysler—three companies with large light-duty vehicle and light-duty truck sales in the United States; (2) these companies typically base their HD pickup and van designs on higher sales volume light-duty truck platforms and technologies, often incorporating new light-duty truck design features into HD pickups and vans at their next design cycle, and (3) at this time most complete HD pickups and vans are certified to vehicle-based rather than engine-based EPA criteria pollutant and GHG standards. There is also the potential for substantial GHG and fuel consumption reductions from vehicle design improvements beyond engine changes (such as through optimizing aerodynamics, weight, tires, and accessories), and a single manufacturer is generally responsible for both engine and vehicle design. All of these factors together suggest that it is still appropriate and reasonable to base standards on performance of the vehicle as a whole, rather than to establish separate engine and vehicle GHG and fuel consumption standards, as is being done for the other heavy-duty categories. The chassis-based standards approach for complete vehicles is also consistent with NAS
463 
recommendations and there was consensus in the public comments in the Phase 1 rulemaking supporting this 
approach. For all of these reasons, the agencies proposed to continue this approach, and there was again supporting consensus in the public comments. 
(a) Work-Based Attributes 
In developing the Phase 1 HD 
rulemaking, the agencies emphasized 
creating a program structure that achieves reductions in fuel consumption and GHGs based on how vehicles are used and on the work they perform in the real world. Work-based measures such as payload and towing capability are key among the things that characterize differences in the design of vehicles, as well as differences in how the vehicles will be used. Vehicles in 
the 2b and 3 categories have a wide range of payload and towing capacities. These work-based differences in design and in-use operation are key factors in evaluating technological improvements for reducing CO
2emissions and fuel 
consumption. Payload has a particularly important impact on the test results for HD pickup and van emissions and fuel consumption, because testing under existing EPA procedures for criteria pollutants and the Phase 1 standards is conducted with the vehicle loaded to half of its payload capacity (rather than to a flat 300 lbs. as in the light-duty program), and the correlation between test weight and fuel use is strong. 
Towing, on the other hand, does not 
directly factor into test weight as nothing is towed during the test. Hence, setting aside any interdependence between towing capacity and payload, only the higher curb weight caused by any heavier truck components plays a role in affecting measured test results. However towing capacity can be a significant factor to consider because HD pickup truck towing capacities can be quite large, with a correspondingly large effect on vehicle design. 
We note too that, from a purchaser 
perspective, payload and towing capability typically play a greater role than physical dimensions in influencing purchaser decisions on which heavy- duty vehicle to buy. For passenger vans, seating capacity is of course a major consideration, but this correlates closely with payload weight. 
For these reasons, as noted above, 
EPA and NHTSA set Phase 1 standards for HD pickups and vans based on a ‘‘work factor’’ attribute that combines vehicle payload capacity and vehicle towing capacity, in lbs., with an additional fixed adjustment for four- wheel drive (4wd) vehicles. This adjustment accounts for the fact that 4wd, critical to enabling many off-road heavy-duty work applications, adds roughly 500 lbs. to the vehicle weight. The work factor is calculated as follows: 75 percent maximum payload + 25 percent of maximum towing + 375 lbs. if 4wd. Under this approach, target GHG and fuel consumption standards are determined for each vehicle with a unique work factor (analogous to a target for each discrete vehicle footprint 
in the light-duty vehicle rules). These targets will then be production weighted and summed to derive a manufacturer’s annual fleet average standard for its heavy-duty pickups and vans. There was widespread support (and no opposition) for the work factor-based approach to standards and fleet average approach to compliance expressed in 
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the comments we received on the Phase 
1 rule. 
For Phase 2, the agencies proposed to 
continue using the work-based attribute. The agencies received a variety of comments on the details of the work factor approach. The agencies received comments from The American Council for an Energy-Efficient Economy (ACEEE) regarding the definition of payload and towing and manufacturer’s discretion at determining GVWR, GCWR and curb weight of the vehicle. In response, the formula for payload, GVWR minus curb weight, is specified such that it uses the same definition of the input terms as those which have always been used by the agencies for light and heavy duty vehicle regulations, including criteria pollutant emission standards and safety related designations. The agencies feel that there is no ambiguity in the definition of these terms and therefore that payload calculation remains clearly defined with little or no opportunity for manipulation. The agencies have successfully used the previously established definitions of GVWR and curb weight to implement emissions and safety related programs and have not experienced any adverse issues in applying these definitions. The same is true for the definitions of terms used to calculate towing—GCWR minus GVWR. While this definition for towing capacity does not match the method used by manufacturers in their consumer advertising, the agencies determined that the inputs of GCWR and GVWR are clearly defined in our regulations and used for many other emission and safety related determinations and therefore also remain a clear and consistent method to define towing for the purposes of calculating work factor. Again, the agencies have successfully used the previously established definitions of GCWR and have not experienced any issues that would warrant a change to the definition or use of these parameters. 
ACEEE commented on recent 
announcements from two manufacturers that reported increases in payload capacity in their pick-ups due to a decrease in the curb weight of the vehicles from changes to light-weight materials. A reduction in vehicle weight while maintaining the same GVWR will result in a higher payload capacity which will then increase that vehicle’s calculated work factor and therefore result in a higher (less stringent) target GHG and fuel consumption standard. Similar to the light-duty (LD) footprint 
based approach which allows increases in GHG emissions and fuel consumption with increasing footprints, the work factor is designed to allow increases in GHG emissions and fuel consumption with increases in capability to do work, primarily hauling payload and towing. Decreases in curb weight as described in the comment actually demonstrate that the work factor is operating both appropriately and as the agencies intended. By reducing curb weight, these manufacturers are increasing the work capability of their trucks specifically purchased by consumers to transport payload and (sometimes) to tow. Additional payload capacity, while not always needed, will allow the user to transport more goods resulting in an overall reduction in GHGs and fuel used versus taking additional trips to do the same work. This may differ from light- duty pick-ups where transportation of goods may not be the primary use of the vehicle. Additionally, the reduction in curb weight will be beneficial in all other situations of unloaded and partially loaded transport of goods because a reduction in curb weight of the vehicle results in less energy wasted simply to move the vehicle regardless of payload. For this reason, the agencies included mass reduction as among the technologies on which the stringency of the final standards (as well as the phase 1 standards) is based. Mass reduction is discussed in detail in the technology descriptions section below. 
Most of the comments supported the 
continued use of work factor-based standards for heavy duty pickups and vans. The agencies received several comments regarding surplus towing. The American Automotive Policy Council (AAPC) commented that existing NHTSA Federal Motor Vehicle Safety Standards effectively cap the towing and GCWR in this vehicle segment. Cummins noted that the curves were data-based in Phase 1 and any changes to the curves would require a full study, similar to Phase 1, in order to ensure feasibility and a fair framework for all OEMs. Daimler commented in support of changing weighting of payload to 80 percent and towing to 20 percent of work factor formula and did not oppose a cap on towing. Several commenters supported adopting a mechanism to minimize the incentive the standards provide to increase work factor. ACEEE supported further considering changing the shape of the standards curves, shown below in Figure VI–3 and Figure VI–4, to be flatter at higher work factors. Honeywell commented that towing capacity has increased significantly over the last five years, beyond the needs of most buyers, and that the curves should be flattened starting at 7,500 lbs, noting that this 
change would impact less that 10 percent of all class 2b/3 vehicles. The International Council on Clean Transportation (ICCT) similarly suggested a cut point of 5,500 lbs. for gasoline trucks and 8,000 lbs. for diesels, based on these cutpoints being near the 90th percentile for the model year 2014 fleet. The Union of Concerned Scientists (UCS) (like ACEEE) commented that light-weighting is being used to increase payload and also supported leveling off the curves to eliminate the incentive to add payload and towing capacity. 
After considering these comments, the 
agencies concluded that the work factor approach established in the Phase 1 rule appropriately accounts for the different utility aspects of heavy-duty vehicles. While trucks and vans may be used differently depending on the required job, the three main attributes of payload, towing and four wheel drive remain properly accounted for at this time in the work factor equation at the current weightings. While a small portion of the fleet may be considered to have excess towing capacity relative to the actual required towing capacity by the customer, the agencies determined that the work factor design does not necessarily result in an incentive for manufacturers to build excessive towing into the vehicle design. Towing capacity increases require improvements to vehicle powertrains, cooling and brakes, generally at the expense of payload, and therefore the work factor reasonably balances an increase in towing with a reduction in payload. Additionally, increases in vehicle weight for additional towing capacity may result in an increase in the emission test weight, further penalizing unnecessary towing capacity. Moreover, as AAPC discusses in their comments, towing and payload are effectively already capped by existing NHTSA safety requirements in this segment. Consumers will ultimately decide on the appropriate balance of payload and towing for their applications, and the agencies therefore believe that establishing a work factor cap for the small percentage of vehicles with the highest towing capabilities is not necessary and will not result in emission increases or fuel consumption reductions under the high towing conditions for which those vehicles were purchased. 
The agencies also received comments 
regarding making changes to the work factor formula for vans. AAPC commented that the payload, towing, and 4wd inputs do not fully represent 
the intended uses of cargo and passenger vans, where cargo or 
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464Although the final standards are implemented 
in MY 2027, the model looks out to MY 2030 to 
help account for the potential use of credit carry- forward provisions. 465In contrast, light-duty standards must remain 
in place for ‘‘at least 1, but not more than 5, model years.’’ 49 U.S.C. 32902(b)(3)(B). passenger volumes are of primary 
importance. AAPC recommended that the agencies add a volumetric term to the work factor for vans with high (208 cubic feet or greater) cargo and passenger volumes. Vans with high volumes would have higher work factors and therefore less stringent targets with the AAPC recommended formula compared to the current formula. ACEEE commented that the work factor is a far better predictor of fuel efficiency for pickups than for vans and offered general support for adopting different work factor formulas for pickups and vans. 
While it is likely that a portion of the 
vans are used exclusively for cargo volume and that towing is not an important attribute for these vans, the commenter failed to provide sufficient new information to support a new work factor metric specifically to address cargo focused vans. The commenter’s suggested modification does not sufficiently represent the different van cargo volumes available to consumers today. A cargo volume based modification requires a complete industry van analysis of all available van cargo volumes and GHG and fuel economy performance levels from which an appropriately normalized adjustment would be determined, consistent with the approach used to establish the existing work factor equation for the attributes of payload, towing and four wheel drive. The agencies did not receive the level of detailed information required to determine the impact of cargo volume and establish a work factor correlation. Accordingly, the agencies are not incorporating the suggested change to the work factor for vans. 
As noted in the Phase 1 rule, the 
attribute-based CO
2and fuel 
consumption standards are meant to be 
as consistent as practicable from a stringency perspective. Vehicles across the entire range of the HD pickup and van segment have their respective target values for CO
2emissions and fuel 
consumption, and therefore all HD pickups and vans will be affected by the standard. With this attribute-based standards approach, EPA and NHTSA continue to believe there should be no significant effect on the relative distribution of vehicles with differing capabilities in the fleet, which means that buyers should still be able to purchase the vehicle that meets their needs. 
(b) Standards 
The agencies are adopting Phase 2 
standards as proposed based on 
analyses performed to determine the appropriate HD pickup and van Phase 2 standards and the most appropriate phase in of those standards. These analyses, described below and in the Final RIA, considered: 
•projections of future U.S. sales for HD 
pickups and vans 
•the estimates of corresponding CO
2 
emissions and fuel consumption for 
these vehicles 
•forecasts of manufacturers’ product 
redesign schedules 
•the technology available in new MY 
2014 HD pickups and vans to specify preexisting technology content to be included in the analysis fleet (the fleet of vehicles used as a starting point for analysis) extending through MY 2030 
•the estimated effectiveness, cost, 
applicability, and availability of technologies for HD pickup and vans 
•manufacturers’ ability to use credit 
carry-forward 
•the levels of technology that are 
projected to be added to the analysis fleet through MY 2030
464considering 
improvements needed in order to achieve compliance with the Phase 1 standards (thus defining the reference fleet—i.e., under the No-Action 
Alternative—relative to which to measure incremental impacts of Phase 2 standards), and 
•the levels of technology that are 
projected to be added to the analysis fleet through MY 2030 considering further improvements needed in order to achieve compliance with standards defining each regulatory (action) alternative for Phase 2. 
Based on this analysis, EPA is 
adopting as proposed CO
2attribute- 
based target standards shown in Figure 
VI–3 and Figure VI–4, and NHTSA is adopting as proposed the equivalent attribute-based fuel consumption target standards, also shown in Figure VI–3 and Figure VI–4, applicable in model year 2021–2027. As shown in these figures, the Phase 2 standards will be phased in year-by-year commencing in MY 2021. The agencies did not propose and are not adopting changes to the standards for 2018–2020 and therefore the standards will remain at the MY 2018 Phase 1 levels for MYs 2019 and 2020. EISA requires four years of lead- time and three years stability for NHTSA standards and this period of lead-time and stability for 2018–2020 is thus consistent with the EISA requirements. For MYs 2021–2027, the agencies are finalizing as proposed annual reductions (i.e., increases in stringency) in the standards. These 
standards become 16 percent more stringent overall between MY 2020 and MY 2027, compared to the MY 2018 Phase 1 levels. This approach to the Phase 2 standards as a whole can be considered a phase-in or implementation schedule of the MY 2027 standards (which, as noted, will apply thereafter unless and until amended). 
For EPA, Section 202(a) (1) provides 
the Administrator with the authority to 
establish standards, and to revise those standards ‘‘from time to time,’’ thus providing the Administrator with considerable discretion in deciding when to revise the Phase 1 MY 2018 standards. As noted above, EISA requires that NHTSA provide four full model years of regulatory lead time and three full model years of regulatory stability for its fuel economy standards. See 49 U.S.C. 32902(k)(3). 
Congress has not spoken directly to 
the meaning of the words ’’regulatory stability.’’ NHTSA believes that the ’’regulatory stability’’ requirement exists to ensure that manufacturers will not be subject to new standards in repeated rulemakings too rapidly, given that Congress did not include a minimum duration period for the MD/HD standards.
465NHTSA further believes 
that standards, which as set provide for increasing stringency during the period that the standards are applicable under this rule to be the maximum feasible during the regulatory period, are within the meaning of the statute. In this statutory context, NHTSA interprets the phrase ‘‘regulatory stability’’ in Section 32902(k)(3)(B) as requiring that the standards remain in effect for three years before they may be increased by amendment. It does not prohibit standards which contain predetermined stringency increases.’’ 
Consistent with these authorities, the 
agencies are adopting more stringent standards beginning with MY 2021, and ending with MY 2027, that consider the level of technology we judge can be applied to new vehicles at reasonable cost to meet the standards. EPA believes the Phase 2 standards are consistent with CAA requirements regarding lead- time, cost, feasibility, and safety. NHTSA believes the Phase 2 standards are the maximum feasible under EISA. Manufacturers in the HD pickup and van market segment have relatively few vehicle lines and redesign cycles are typically longer compared to light-duty vehicles. Also, the timing of vehicle 
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redesigns differs among manufacturers. 
To provide lead time needed to accommodate these longer redesign cycles, the Phase 2 GHG standards will not reach their highest stringency until 2027. Although these standards will become more stringent each year between MYs 2021 and 2027, the agencies expect manufacturers will likely make improvements as part of planned redesigns, such that some model years will likely involve significant advances, while other model years will likely involve little change. The agencies also expect manufacturers to use program flexibilities (e.g., credit 
carry-forward provisions and averaging and banking provisions) to help achieve compliance without compressing redesign schedules and to efficiently manage resources and capital over time. The MY 2018 standards are unchanged in MYs 2019–2020 to provide necessary lead time for the Phase 2 standards. However, some manufacturers may choose to begin implementing technologies earlier (in some cases potentially as soon as MY 2017) depending on their vehicle redesign cycles. Although standards are not changing in MYs 2019–2020, manufacturers may introduce additional technologies in order to earn credits that may be carried-forward under the 5 year credit carry-forward provisions established in Phase 1 and continuing for Phase 2. 
The agencies received several 
comments on the Phase 2 standards and the technological basis and feasibility of the standards. The comments are discussed in Sections VI.D and 0below, which provide additional discussion of vehicle redesign cycles and the feasibility of the final Phase 2 standards, and also in Section 7 of the Response to Comments document. 
Recognizing that it is unlikely that 
there is a phase-in approach that equally fits with all manufacturers’ unique product redesign schedules, the agencies requested comments on other ways the Phase 2 standards could be phased in. The agencies suggested one 
alternative approach would be to phase in the standards in a few step changes, for example in MYs 2021, 2024 and 2027 (as with the standards for vocational vehicles, tractors, trailers, and the heavy duty engine standards). Under this example, if the step changes on the order of 5 percent, 10 percent, and 16 percent improvements from the 
MY 2020 baseline in MYs 2021, 2024 and 2027 respectively, the program would provide CO
2reductions and fuel 
improvements roughly equivalent to the approach being adopted. EPA did not receive comments on this alternative phase-in approach, which closely resembles the phase-in approach used for the other sectors. 
AAPC commented in support of an 
alternative year-over-year phase-in that would phase-in stringency more gradually than proposed (and now adopted). AAPC recommended that rather than a 2.5 percent per year improvement, the increase should be at 1.75 percent per year through MY 2024 and then 3.5 percent per year for MY 2025 through 2027 with the MY 2027 level of stringency equally the proposed level. AAPC commented that this more gradual approach was consistent with the Phase 1 phase-in approach and would help manufacturers manage the long lead time associated with developing the new vehicles and powertrains that will be required in order to comply with the Phase 2 proposal. 
The agencies are finalizing the 
proposed phase-in rather than adopting the approach recommended by AAPC. The more gradual phase-in recommended by AAPC would result in a loss of program benefits in each of the interim years of the program compared to the promulgated standards until the phase-in caught up with that phase-in in MY 2027. Because of the slower phase- in, the overall reduction in each interim year is lower than the phase-in being finalized. The phase-in adopted for Phase 1 with a more gradual ramp-up in standards took into consideration the shorter lead time associated with the 
Phase 1 standards and the uncertainty associated with implementing a new program. Phase 2 provides more lead- time than Phase 1 and the agencies believe based on their analyses of the standards that the lead-time provided is sufficient, particularly considering the flexibility also provided by credit carry- forward and carry-back provisions. 
As with Phase 1 (and like the light- 
duty vehicle standards), the Phase 2 standards must be met on a production- weighted fleet average basis. No individual vehicle will have to meet a particular target (or the individual fleet average level). Each manufacturer will also have its own fleet average standard. 
Specifically, each manufacturer will have its own unique fleet average requirement based on the production- weighted average of the heavy duty pickups and vans it chooses to produce. Moreover, averaging, banking, and trading provisions, just alluded to and discussed further below, will provide significant additional compliance flexibility in implementing the standards. It is important to note, however, that while the standards will differ numerically from manufacturer to manufacturer, effective stringency should be essentially the same for each manufacturer. The agencies did not receive comments suggesting changes to this general averaging approach to establishing the standards. 
Also, as with the Phase 1 standards, 
the agencies proposed and are finalizing separate Phase 2 targets for gasoline- fueled (and any other Otto-cycle) vehicles and diesel-fueled (and any other diesel-cycle) vehicles. See 80 FR 40337. The targets will be used to determine the production-weighted fleet average standards that apply to the combined diesel and gasoline fleet of HD pickups and vans produced by a manufacturer in each model year. The stringency increase discussed above for Phase 2 applies equally to the separate gasoline and diesel targets. For the proposal, the agencies considered different rates of increase for the gasoline and diesel targets in order to more equally balance compliance burdens across manufacturers with varying gasoline/diesel fleet mixes. However, at least among major HD pickup and van manufacturers, our analyses suggested limited potential for such optimization, especially 
considering uncertainties involved with manufacturers’ future fleet mix. The agencies did not receive comments on the specific topic of maintaining equivalent rates of increase for gasoline and diesel-fueled vehicles. The agencies, however, received several comments regarding maintaining separate standards for the two vehicle types. Some of the comments recommended closing the gap between diesel and gasoline-fueled vehicles by making the gasoline-fueled vehicle standards more stringent. These comments are discussed below. 
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Described mathematically, EPA’s and 
NHTSA’s target standards are defined 
by the following formulas: 
EPA CO 2Target (g/mile) = [a × WF] + 
b NHTSA Fuel Consumption Target 
(gallons/100 miles) = [c × WF] + d 
Where: 
WF = Work Factor = [0.75 × (Payload 
Capacity + xwd)] + [0.25 × Towing 
Capacity] Payload Capacity = GVWR (lb.) ¥ Curb 
Weight (lb.) 
xwd = 500 lbs. if the vehicle is equipped 
with 4wd, otherwise equals 0 lbs. 
Towing Capacity = GCWR (lb.) ¥ GVWR (lb.) 
Coefficients a, b, c, and d are taken from 
TableVI–2. 
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ER25OC16.012</GPH>mstockstill on DSK3G9T082PROD with RULES2Diesel Standards 
I 
700 -L-----------~·~~-~----~---· ---.~--~-·"·--------~--~---------~~----~----------~------ ------~---~------~----~-~,------~--~----· -~---~--~_ .. _____ :-6.94 
I 
; j 
650 t~----~~---~-----~~~-~~-~ -----~--------~------------~--~--~-~-~-------~---~--~~---~------~---~--·---~--~-~- ~--·---~--~~~---~-6.44 
! ' ~ 600 ·i--~~-~--~-~--~-----~-~~~-----~~-----------~----~--~--------~-~---
E I 
Q) 
"-
E\1') sso -r----~ 
~ ' 8 I 
u 500 i·-----
1 
400 3.94 
l i 
350 j ________ .,.. __ "--~-------~---·-:---------~---,--"------- ---~.,.,.,-----~~--------~---~-----"-------~--~~---~-~--~-----,--~------~~-~~-,.-------~--~----~-:-~-----+- 3.44 
3000 3500 4000 4500 5000 
Work Factor 5500 6000 6500 7000 
Figure VI-3 EPA Phase 2 C02 Target Standards and NHTSA Fuel Consumption Target Standards for Diesel 
HD Pickups and Vans 
750 ! 8.44 
Gasoline Standards 
I ' 
700 t·----~----·----·-----------·--~----·----·-----------·--·--·-----· ·-·--·--·----··-------·--- ----------·-----·--·---·--·-]- 7.94 i 
650 I 
I 
-!~·----~-------T-~·-~-C-~>O,._<_<~----~·r--~--_,-·--·--~-~--~-----~·---~·--·~~-~~--~-'-~~----·~------~~0--·~-~-·--·~--~-~--«--"-~~-~-·---~ 
i I ~ 
7.44 .!!! 
E 
§ 
~ 600 ,_ 6.94 Q) 
"-
~ c 
_Q E 
Q) 
"-E sso 
"' ~ 
N 
8 500 -1----~---
450 
3000 3500 4000 4500 5000 
Work Factor 5500 6000 6500 7000 6.44 "' 
~ 
c 
0 
!~ 5.94 ·-g_ 
E 
~ 
5.44 
~ 4.94 
' ---;. 4.44 
i c 
0 u 
Q) 
~ 
Figure VI-4 EPA Phase 2 C02 Target Standards and NHTSA Fuel Consumption Target Standards for 
Gasoline HD Pickups and Vans 73738 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
TABLEVI–2—P HASE 2 COEFFICIENTS FOR HD P ICKUP AND VANTARGET STANDARDS  
Model year a b c d 
Diesel Vehicles 
2018–2020a............................................................................................... 0.0416 320 0.0004086 3.143 
2021 ................................................................................................................. 0.0406 312  0.0003988 3.065 
2022 ................................................................................................................. 0.0395 304  0.0003880 2.986 
2023 ................................................................................................................. 0.0386 297  0.0003792 2.917 
2024 ................................................................................................................. 0.0376 289  0.0003694 2.839 
2025 ................................................................................................................. 0.0367 282  0.0003605 2.770 
2026 ................................................................................................................. 0.0357 275  0.0003507 2.701 
2027 and later .................................................................................................. 0.0348 268 0.00 03418 2.633 
Gasoline Vehicles 
2018–2020a............................................................................................... 0.044 339 0.0004951 3.815 
2021 ................................................................................................................. 0.0429 331  0.0004827 3.725 
2022 ................................................................................................................. 0.0418 322  0.0004703 3.623 
2023 ................................................................................................................. 0.0408 314  0.0004591 3.533 
2024 ................................................................................................................. 0.0398 306  0.0004478 3.443 
2025 ................................................................................................................. 0.0388 299  0.0004366 3.364 
2026 ................................................................................................................. 0.0378 291  0.0004253 3.274 
2027 and later .................................................................................................. 0.0369 284 0.00 04152 3.196 
Note: 
aPhase 1 primary phase-in coefficients. Alternative phase-in coefficients are different in MY 2018 only. 
As noted above, the agencies did not 
propose and are not adopting changes 
from the final Phase 1 standards for MYs 2018–2020. The MYs 2018–2020 standards are shown in the figures and tables above for reference. The agencies did not receive comments recommending changes to the standards in these model years. 
NHTSA and EPA have also analyzed 
regulatory alternatives to these standards, as discussed in Sections VI.D and 0and Section X. below. The agencies requested comment on all of the alternatives analyzed for the proposal, but requested comment on Alternative 4 in particular. The agencies did not propose Alternative 4 because EPA and NHTSA had outstanding questions regarding relative risks and benefits of Alternative 4 due to the timeframe envisioned by that alternative. As noted above, Alternative 4 would have provided less lead time for the complete phase-in of the Phase 
2 standards based on an annual improvement of 3.5 percent per year in MYs 2021–2025 compared to the Alternative 3 per year improvement of 2.5 percent in MYs 2021–2027. 
In the proposal, the agencies 
requested comments, data, and information that would help inform determination of the maximum feasible (for NHTSA) and appropriate (for EPA) stringency for HD pickups and vans and are particularly interested in information and data related to the expected adoption rates of different emerging technologies, such as mild and strong hybridization. The agencies received comments both in support of and not in support of Alternative 4 and 
also received comments in support of standards more stringent than either the proposal or the Alternative 4 pull ahead. The comments regarding stringency and feasibility are discussed in Sections VI.D and E. As described in these sections, and in Section X and RIA Chapter 11, NHTSA and EPA believe the final Phase 2 standards represent, respectively, the maximum feasible standards under EISA and the most stringent standards reasonably achievable under the CAA considering lead-time, reasonable cost, feasibility, and safety. 
As with Phase 1 standards, to 
calculate a manufacturer’s HD pickup and van fleet average standard, the agencies proposed and are finalizing separate target curves for gasoline and diesel vehicles in Phase 2. While diesel and gasoline vehicles have separate work factor-based target standard curves, all of a manufacturer’s vehicles 
are averaged together as a single averaging set to demonstrate compliance. As noted above, the agencies’ Phase 2 standards are estimated to result in approximately 16 percent reductions in CO
2and fuel 
consumption for both diesel and gasoline vehicles relative to the MY 2018 Phase 1 standards for HD pickup trucks and vans. 
The agencies requested comment on 
both the level of stringency of the standards and the continued separate targets for gasoline and diesel HD pickups and vans. AAPC supported the agencies’ proposal to maintain separate targets noting that the approach ensures that manufacturers of either engine type 
will implement the latest CO
2reducing 
technologies. AAPC further commented that significant technological and market-based differences exist between heavy-duty gasoline and heavy-duty diesel engines. According to the commenter, maintaining separate but comparably stringent spark ignition and compression ignition targets will allow customers for specific applications to take advantage of the combustion technology that best meets their specific application requirements. 
Several commenters did not support 
the proposed approach but instead supported setting a single fuel-neutral set of targets. Cummins commented that there is sufficient lead-time and technology to create a pathway to fuel- neutral targets, and that fuel neutral targets would eliminate any competitive advantage or preference to a particular GHG/FE technology and maintain the environmental benefits envisioned for the program. Daimler, Honeywell, and MEMA similarly commented in support of fuel-neutral standards. Honeywell and Motor and Equipment Manufacturers Association (MEMA) suggested basing the standards on a 16 percent improvement from the projected MY 2018 gasoline/diesel combined 
baseline. ACEEE and ICCT commented in support of a single set of standards set at or close to the capabilities of diesel technology. These commenters suggested that gasoline engines should be subject to more stringent standards than proposed and that gasoline and diesel engines should be held to the same performance-based standards. 
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Bosch disagreed with maintaining 
separate targets for gasoline and diesel 
HD pickups and vans. Bosch recommended that targets be fuel neutral, as they are in the light-duty vehicle programs. Bosch commented that it ‘‘believes that a market shift towards spark-ignited vehicles and away from HD pickups and vans powered by ‘‘fundamentally more efficient’’ CI engines would be a very real possibility under Phase 2 if the separate gasoline and diesel targets are finalized as proposed.’’ Bosch continues that ‘‘any such shift would signify not only a move towards less efficient internal combustion engines, but would be counterproductive from a programmatic/environmental and energy standpoint.’’ Bosch further commented that ‘‘diesels from a criteria pollutant (especially NO
Xemissions 
perspective, have made far greater strides over the years than gasoline engines, and for that reason have incurred greater technological development costs than the latter. While equivalent CO
2target values may be 
more expensive, comparatively speaking, for SI engines to achieve (based on the agencies’ cost analysis), the additional cost imposed on these engines likely would not rise to the level of, much less overtake CI engines’ historically higher technological development and system costs.’’ 
The agencies generally prefer to set 
standards that do not distinguish between fuel types where technological or market-based reasons do not strongly argue otherwise. However, as with Phase 1, we continue to believe that fundamental differences between spark ignition and compression ignition engines warrant unique fuel standards, which is also important in ensuring that our program maintains product choices available to vehicle buyers. In fact, gasoline and diesel fuel behave so differently in the internal combustion engine that they have historically required unique test procedures, emission control technologies and emission standards. These technological differences between gasoline and diesel engines for GHGs and fuel consumption exist presently and will continue to exist after Phase 1 and through Phase 2 until advanced research evolves the gasoline fueled engine to diesel-like efficiencies. This will require significant technological breakthroughs currently in early stages of research such as homogeneous charge compression ignition (HCCI) or similar concepts. Because these technologies are still in the early research stages, we believe the separate fuel type standards are appropriate in the timeframe of this rule to assure the availability of both gasoline and diesel engines. We also project that these separate standards will result in roughly equivalent redesign burdens for engines of both fuel types as evidenced by feasibility and cost analysis in RIA Chapter 10. For the same reasons, the agencies are adopting separate standards for diesel and SI vocational engines. See Section V. above. 
In order to maintain the same overall 
level of stringency as proposed for the program, a fuel neutral standard would result in an increase in stringency for gasoline or spark ignition vehicles with a matching relaxation of stringency for diesel or compression ignition vehicles relative to the separate numerical levels established in the proposal for gasoline and diesel vehicles. Based on the analysis of available technologies for both types of vehicles, the agencies do not feel it is appropriate to adopt such a change for either gasoline or diesel vehicles. This change could lead to an undesirable reduction in penetration of fuel efficient technologies in diesels, particularly from manufacturers who produce predominately diesel vehicles, while requiring a higher penetration of advanced technologies like strong hybridization in gasoline vehicles, distorting consumer choice. Additionally, the agencies do not agree with the comment stating that maintaining separate gasoline and diesel targets of equal increases in stringency of 2.5 percent per year from the Phase 1 final standards will result in a shift to less efficient gasoline vehicles. The agencies determined that manufacturers have similar technology challenges and corresponding costs regardless of fuel type and therefore manufacturers do not have an easier or lower cost long term path to compliance by simply shifting production from one fuel type to the other. 
Note further that a manufacturer’s 
fleet average standard is the production weighted average of all its targets, both 
gasoline and diesel. Thus, there is no separate gasoline vehicle standard, or separate diesel standard. Commenters may have been confused on this point (several of the commenters referred to gasoline ‘standards’, or diesel ‘standards’). This averaging feature of the standard further increases incentives to add advanced technologies to either gasoline or diesel vehicles if manufacturers perceive it advantageous to do so, since the benefit is experienced fleet wide, not just for the gasoline or diesel segment of a manufacturer’s production line. The NHTSA fuel consumption target 
curves and EPA GHG target curves are equivalent. The agencies established the target curves using the direct relationship between fuel consumption and CO
2using conversion factors of 
8,887 g CO 2/gallon for gasoline and 
10,180 g CO 2/gallon for diesel fuel. 
It is expected that measured 
performance values for CO 2will 
generally be equivalent to fuel consumption. However, Phase 1 established a provision that EPA is not changing for Phase 2 that allows manufacturers, if they choose, to use CO
2credits to help demonstrate 
compliance with N 2O and CH 4 
emissions standards, by expressing any N
2O and CH 4under compliance in 
terms of their CO 2-equivalent and 
applying CO 2credits as needed. For test 
families that do not use this compliance alternative, the measured performance values for CO
2and fuel consumption 
will be equivalent because the same test runs and measurement data will be used to determine both values, and calculated fuel consumption will be based on the same conversion factors that are used to establish the relationship between the CO
2and fuel consumption target curves 
(8,887 g CO 2/gallon for gasoline and 
10,180 g CO 2/gallon for diesel fuel). For 
manufacturers that choose to use EPA provision for CO
2credit use in 
demonstrating N 2O and CH 4 
compliance, compliance with the CO 2 
standard will not be directly equivalent to compliance with the NHTSA fuel consumption standard. 
(2) What are the HD pickup and van test 
cycles and procedures? 
The Phase 1 program established 
testing procedures for HD pickups and vans and NHTSA and EPA are maintaining these testing protocols. The vehicles will continue to be tested using the same heavy-duty chassis test procedures currently used by EPA for measuring criteria pollutant emissions from these vehicles, including the city fuel economy test cycle (FTP) and the highway fuel economy test cycle (HFET). These test procedures are used by manufacturers for certification and emissions compliance demonstrations and by the agencies for compliance verification and enforcement. While the FTP and the HFET driving patterns are identical to that of the light-duty test cycles, other test parameters for running them, such as test vehicle loaded weight, are specific to complete heavy- duty vehicles. Please see Section II.C (2) of the Phase 1 Preamble (76 FR 57166) for a discussion of how HD pickups and vans are tested. 
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The test procedures for HD pickups 
and vans currently specify using a fuel 
with properties established under the light-duty (LD) vehicle Tier 2 program. EPA recently finalized new emission standards under the Tier 3 program for both LD vehicles and HD pickups and vans which will begin to phase-in in MY 2017 for LD vehicles and MY 2018 for vehicles over 6000 pounds GVWR, including HD pickups and vans. As part of the Tier 3 program, new test procedures for gasoline-fueled vehicles requiring the use of a new test fuel containing 10 percent ethanol which is more representative of in-use fuel that the vehicles will encounter. The agencies are investigating any potential impact of changes to the fuel properties on GHG emissions and fuel consumption and have committed to providing appropriate adjustment to the test procedures if necessary to ensure no change in stringency of the Phase 1 or the Phase 2 standards. 
AAPC commented that the current 
methodology of grouping vehicles by the Equivalent Test Weight (ETW) in increments of 500 pounds for determining their GHG and FE performance is too large to capture weight reductions that may occur within a 500 pound grouping. Under the current test procedures, vehicles are tested at 500 lb. increments of inertial weight classes when testing at or above 5500 lbs. test weight. For example, the commenter stated that all vehicles having a calculated test weight basis of 11,251 to 11,750 lbs. are tested at 11,500 lbs. (i.e., the midpoint of the range). 
However, for some vehicles, the existence of these bins and the large intervals between bins may reduce or eliminate the incentive for mass reduction for some vehicles, as a vehicle may require significant mass reduction before it could switch from one test weight bin to the next lower bin. For other vehicles, these bins may unduly reward relatively small reductions of vehicle mass, as a vehicle’s mass may be only slightly greater than that needed to be assigned a 500-pound lighter inertia weight class. For example, for a vehicle with a calculated test weight basis of 11,700 lbs., a manufacturer would receive no regulatory benefit for reducing the vehicle weight by 400 lbs., because the vehicle would stay within the same weight bracket. 
The agencies believe this (and similar 
comments) have some merit. In response, the agencies are finalizing an option allowing manufacturers to divide vehicle models into finer weight groupings of vehicles for the different 
Adjusted Loaded Vehicle Weights (ALVW) for purposes of more precise calculation of CO
2emissions 
performance within the 500 pound 
increment test weight classes. Manufacturers will be able to select 50, 100, 250, or 500 weight groups for reporting emissions. ALVW will vary within a single ETW largely depending on the varying models curb weights from customer option selection and other production variations. The calculation of CO
2emissions 
performance for the finer groupings is performed as described in 40 CFR 86.1819–14(g))) for analytically adjusting CO
2(ADCO 2) emissions. The 
test results at the existing 500 pound increment ETWs will be used to determine the CO
2emissions 
performance level of the new groupings using the analytically derived equation. This new ADCO
2emissions level is only 
used for this new grouping and cannot be used to extend determination of other ALVW groupings emission performance levels. The vehicle specific values used to determine the change in ETW in the ADCO
2emissions calculation to 
estimate the performance of the smaller grouping should be consistent with value used to calculate the single work factor of that same grouping. This change does not impact the ETW of a group of vehicle models that are contained in the 500 pound increment of ETW when performing testing nor does it eliminate any vehicle in that grouping from being responsible for emission performance at the 500 pound increment test weight classes. As described, this change only allows for more precise CO
2emissions estimation 
for the potentially different curb weights of vehicles grouped in a single ETW class for purposes of fleet average calculation. If a manufacturer chooses to use less than 500 pound increments, they are required to use this option for all of their HD vehicles that are chassis certified (including loose engines). 
(3) Fleet Average Standards 
As proposed, and as noted above, 
NHTSA and EPA are retaining the fleet 
average standards approach finalized in the Phase 1 rule and structurally similar to light-duty Corporate Average Fuel Economy (CAFE) and GHG standards. The fleet average standard for a manufacturer is a production-weighted average of the work factor-based targets assigned to unique vehicle configurations within each model type produced by the manufacturer in a model year, with separate targets for 
gasoline and diesel vehicles (which are then combined into a production weighted average which comprises that manufacturer’s fleet average standard). Each manufacturer will continue to have an average GHG requirement and an average fuel consumption requirement unique to its new HD pickup and van fleet in each model year, depending on the characteristics (payload, towing, and drive type, as well as gasoline and diesel) of the vehicle models produced by that manufacturer, and on the U.S.-directed production volume of each of those models in that model year. Vehicle models with larger payload/towing capacities and/or four-wheel drive have individual targets at numerically higher CO
2and fuel consumption levels than 
less capable vehicles, as discussed in Section VI.B.(1). The agencies did not receive comments suggesting changes to this fundamental approach to the standards. 
The fleet average standard with which 
the manufacturer must comply will continue to be based on its final production figures for the model year, and thus a final assessment of compliance will occur after production for the model year ends. The assessment of compliance also must consider the manufacturer’s use of carry-forward and carry-back credit provisions included in the averaging, banking, and trading program. Because compliance with the fleet average standards depends on actual test group production volumes, it is not possible to determine compliance at the time the manufacturer applies for and receives an (initial) EPA certificate of conformity for a test group. Instead, at certification the manufacturer will demonstrate a level of performance for vehicles in the test group, and make a good faith demonstration that its fleet, regrouped by unique vehicle configurations within each model type, is expected to comply with its fleet average standard when the model year is over. EPA will issue a certificate for the vehicles covered by the test group based on this demonstration, and will include a condition in the certificate that if the manufacturer does not comply with the fleet average, then production vehicles from that test group will be treated as not covered by the certificate to the extent needed to bring the manufacturer’s fleet average into compliance. As in the parallel program for light-duty vehicles, additional ‘‘model type’’ testing will be conducted by the manufacturer over the course of the model year to supplement the initial test group data. The emissions and fuel consumption levels of the test vehicles will be used to calculate the production- weighted fleet averages for the manufacturer, after application of the appropriate deterioration factor to each result to obtain a full useful life value. 
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46679 FR 23492, April 28, 2014 and 40 CFR 
86.1805–17. 467N2O has a GWP of 298 and CH 4has a GWP 
of 34 according to the IPCC AR5. Please see Section II.C.(3)(a) of the 
Phase 1 Preamble (76 FR 57167) for further discussion of the fleet average approach for HD pickups and vans. 
(4) In-Use Standards 
Section 202(a)(1) of the CAA specifies 
that EPA set emissions standards that 
are applicable for the useful life of the vehicle. EPA will continue the in-use standards approach for individual vehicles that EPA finalized for the Phase 1 program. NHTSA did not adopt Phase 1 in-use standards and did not propose in-use standards for Phase 2. For the EPA program, compliance with the in- use standard for individual vehicles and vehicle models does not impact compliance with the fleet average standard, which will be based on the production-weighted average of the new vehicles. Vehicles that fail to meet their in-use emission standards will be 
subject to recall to correct the noncompliance. NHTSA is finalizing the use of EPA’s useful life requirements to ensure manufacturers consider in the design process the need for fuel efficiency standards to apply for the same duration and mileage as EPA standards. NHTSA will limit such penalties to situations in which it determined that the vehicle or engine manufacturer failed to comply with the standards. 
As with Phase 1, the in-use Phase 2 
GHG standards for HD pickups and vans will be established by adding an adjustment factor to the full useful life emissions used to calculate the GHG fleet average. Each model’s in-use CO
2 
standard will be the model-specific level used in calculating the fleet average, plus 10 percent. No adverse comments were received on this provision. Please see Section II.C.(3)(b) of the Phase 1 Preamble (76 FR 57167) for further discussion of in-use standards for HD pickups and vans. This provision, along with the continuation of the Phase 1 test procedures, eliminates that need for the agencies to include any additional compliance margin in our feasibility analysis. 
For Phase 1, EPA aligned the useful 
life for GHG emissions with the useful life that was in place for criteria pollutants: 11 years or 120,000 miles, whichever occurs first (40 CFR 86.1805– 04(a)). Since the Phase 1 rule was finalized, EPA updated the useful life for criteria pollutants as part of the Tier 3 rulemaking.
466The new useful life 
implemented for Tier 3 is 150,000 miles or 15 years, whichever occurs first. As proposed, the useful life for GHG 
emissions and fuel consumption will also be 150,000 miles/15 years starting in MY 2021 when the Phase 2 standards begin so that the useful life remains aligned for GHG and criteria pollutant standards long term. The agencies did not receive adverse comments on this 
provision. 
(5) Other GHG Standards for HD 
Pickups and Vans 
This section addresses greenhouse 
gases other than CO
2. Note that since 
these are greenhouse gases not directly related to fuel consumption, NHTSA does not have equivalent standards. 
(a) Nitrous Oxide (N
2O) and Methane 
(CH 4) 
In the Phase 1 rule, EPA established 
emission standards for HD pickups and 
vans for both nitrous oxide (N 2O) and 
methane (CH 4). Similar to the CO 2 
standard approach, the N 2O and CH 4 
emission levels of a vehicle are based on a composite of the light-duty FTP and HFET cycles with the same 55 percent city weighting and 45 percent highway weighting. The N
2O and CH 4standards 
were both set by EPA at 0.05 g/mile. Unlike the CO
2standards, averaging 
between vehicles is not allowed. The standards are designed to prevent increases in N
2O and CH 4emissions 
from current levels, i.e., a no- 
backsliding standard. EPA did not propose and is not adopting any changes the N
2O or CH 4standards or 
related provisions established in the Phase 1 rule. Please see Phase 1 Preamble Section II.E. (76 FR 57188– 57193) for additional discussion of N
2O 
and CH 4emissions and standards. 
Across both current gasoline- and 
diesel-fueled heavy-duty vehicle designs, emissions of CH
4and N 2O are 
relatively low and the intent of the cap standards is to ensure that future vehicle technologies or fuels do not result in an increase in these emissions. Given the global warning potential (GWP) of CH
4, the 0.05 g/mile cap 
standard is equivalent to about 1.7 g/ mile CO
2, which is much less than 1 
percent of the overall GHG emissions of most HD pickups and vans.
467The 
effectiveness of oxidation of CH 4using 
a three-way or diesel oxidation catalyst is limited by the activation energy, which tends to be higher where the number of carbon atoms in the hydrocarbon molecule is low and thus CH
4is very stable. At this time we are 
not aware of any technologies beyond the already present catalyst systems which are highly effective at oxidizing 
most hydrocarbon species for gasoline and diesel fueled engines that would further lower the activation energy across the catalyst or increase the energy content of the exhaust (without further increasing fuel consumption and CO
2 
emissions) to further reduce CH 4 
emissions at the tailpipe. The CH 4 
standard remains an important backstop to prevent future increases in CH
4 
emissions. EPA did not receive adverse comments regarding the proposal to not change the CH
4standard for HD pickups 
and vans. 
N2O is emitted from gasoline and 
diesel vehicles mainly during specific catalyst temperature conditions conducive to N
2O formation. The 0.05 g/ 
mile standard, which translates to a CO
2-equivalent value of 14.9 g/mile, 
ensures that systems are not designed in a way that emphasizes efficient NO
X 
control while allowing the formation of significant quantities of N
2O. The Phase 
1 N 2O standard of 0.05 g/mile for 
pickups and vans was finalized knowing that it is more stringent than the Phase 1 N
2O engine standard of 0.10 
g/hp-hr, which is being continued for Phase 2, as discussed in Section II.D.3. EPA continues to believe that the 0.05 g/mile standard provides the necessary assurance that N
2O will not significantly 
increase, given the mix of gasoline and diesel fueled engines in this market and the upcoming implementation of the light-duty and heavy-duty (up to 14,000 lbs. GVWR) Tier 3 NO
Xstandards. EPA 
knows of no technologies that would lower N
2O emissions beyond the control 
provided by the precise emissions control systems already being implemented to meet EPA’s criteria pollutant standards. Therefore, EPA continues to believe the 0.05 g/mile N
2O 
standard remains appropriate. 
The California Air Resources Board 
(CARB) suggested that EPA investigate the feasibility of more stringent tailpipe standards. EPA may consider more stringent standards in the future if data is available to support adjustments to the standards as appropriate and consistent with the CAA, but we repeat that at present we know of no further emission reduction technologies for either N
2O or CH 4. 
If a manufacturer is unable to meet 
the N 2O or CH 4cap standards, the EPA 
program allows the manufacturer to 
comply using CO 2credits. In other 
words, a manufacturer may offset any N
2O or CH 4emissions above the 
standard by taking steps to further reduce CO
2. A manufacturer choosing 
this option would use GWPs to convert its measured N
2O and CH 4test results 
that are in excess of the applicable 
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468IPCC AR4 included a N 2O GWP of 298 and a 
CH 4GWP of 25. These factors are used in the Phase 
1 rule credits calculations. 469The U.S. EPA has reclamation requirements 
for refrigerants in place under Title VI of the Clean 
Air Act. See 40 CFR part 82 Subpart B. standards into CO 2eq to determine the 
amount of CO 2credits required. For 
example, for Phase 1, a manufacturer 
would use 25 Mg of positive CO 2credits 
to offset 1 Mg of negative CH 4credits or 
use 298 Mg of positive CO 2credits to 
offset 1 Mg of negative N 2O credits.468 
By using the GWP of N 2O and CH 4, the 
approach recognizes the inter- correlation of these compounds in impacting global warming and is environmentally neutral for demonstrating compliance with the individual emissions caps. Because fuel conversion manufacturers certifying under 40 CFR part 85, subpart F, do not participate in ABT programs, EPA included in the Phase 1 rule a compliance option for fuel conversion manufacturers to comply with the N
2O 
and CH 4standards that is similar to the 
credit program described above. See 76 
FR 57192. The compliance option will allow conversion manufacturers, on an individual engine family basis, to convert CO
2over compliance into CO 2 
equivalents (CO 2eq) of N 2O and/or CH 4 
that can be subtracted from the CH 4and 
N2O measured values to demonstrate 
compliance with CH 4and/or N 2O 
standards. EPA did not include similar provisions allowing over compliance with the N
2O or CH 4standards to serve 
as a means to generate CO 2credits 
because the CH 4and N 2O standards are 
cap standards representing levels that all but the worst vehicles should already be well below. Allowing credit generation against such cap standard would provide a windfall credit without any true GHG reduction. As proposed, EPA is maintaining these provisions for Phase 2 as they provide important flexibility without reducing the overall GHG benefits of the program. 
EPA requested comments on updating 
GWPs used in the calculation of credits discussed above. For Phase 2, EPA is updating the GWP for methane from 25 to 34 based on IPCC AR5. Please see the full discussion of this issue provided in Sections II.D and XI.D. 
CARB suggested that EPA consider 
eliminating or at least phasing out the use of CO
2credits in lieu of compliance 
with tailpipe methane standards. In contrast, NGVAmerica strongly supported extending this compliance option, noting that the ability to offset methane (and also nitrous oxide) emissions with CO
2credits is critical for 
new natural gas engines and vehicles. Cummins also commented in support of continuing to allow the use of CO
2- 
equivalent credits to comply with N2O and CH 4standards. Cummins 
commented that the flexibility has been applied by various manufacturers in Phase 1 and is necessary for Phase 2. Review of MY 2014 certification GHG data confirmed that several manufacturers utilized this Phase 1 program flexibility for either N
2O or CH 4 
debits on their diesel vehicles. EPA continues to believe this flexibility is appropriate as it provides important flexibility to manufacturers in an environmentally neutral manner. 
(b) Air Conditioning Related Emissions 
Air conditioning systems contribute 
to GHG emissions in two ways—direct 
emissions through refrigerant leakage and indirect exhaust emissions due to the extra load on the vehicle’s engine to provide power to the air conditioning system. HFC refrigerants, which are powerful GHG pollutants, can leak from the A/C system. This includes the direct leakage of refrigerant as well as the subsequent leakage associated with maintenance and servicing, and with disposal at the end of the vehicle’s life.
469Currently, the most commonly 
used refrigerant in automotive applications—R134a, has a high GWP. Due to the high GWP of R134a, a small leakage of the refrigerant has a much greater global warming impact than a similar amount of emissions of CO
2or 
other mobile source GHGs. 
In Phase 1, EPA finalized low leakage 
requirement for all air conditioning systems installed in 2014 model year and later HDVs, with the exception of Class 2b–8 vocational vehicles. As discussed in Section V.B.(2)(c), EPA is extending leakage standards to vocational vehicles for Phase 2. For air conditioning systems with a refrigerant capacity greater than 733 grams, EPA finalized a leakage standard which is a ‘‘percent refrigerant leakage per year’’ to assure that high-quality, low-leakage components are used in each air conditioning system design. EPA finalized a standard of 1.50 percent leakage per year for heavy-duty pickup trucks and vans and Class 7 and 8 tractors. See Section II.E.5. of the Phase 1 Preamble (76 FR 57194–57195) for further discussion of the A/C leakage standard. The leakage standard continues to apply for Phase 2 regardless of the refrigerant used in the A/C system. See Section I.F. for how the Phase 2 program handles the use of alternative refrigerants. 
In addition to direct emissions from 
refrigerant leakage, air conditioning systems create indirect exhaust emissions due to the extra load on the vehicle’s engine to provide power to the air conditioning system. These indirect emissions are in the form of the additional CO
2emitted from the engine 
when A/C is being used due to the added loads. Unlike direct emissions which tend to be a set annual leak rate not directly tied to usage, indirect emissions are fully a function of A/C usage. These indirect CO
2emissions are 
associated with air conditioner efficiency, since (as just noted) air conditioners create load on the engine. See 74 FR 49529. In Phase 1, the 
agencies did not set air conditioning efficiency standards for vocational vehicles, combination tractors, or heavy- duty pickup trucks and vans. The CO
2 
emissions due to air conditioning systems in these heavy-duty vehicles were estimated to be minimal compared to their overall emissions of CO
2.76 FR 
57194–57196. This continues to be the case. For this reason, EPA did not propose and is not establishing A/C efficiency standards for Phase 2. This differs from light-duty vehicles where CO
2emissions related to A/C systems 
can be a significant portion of overall vehicle CO
2emissions and EPA has 
established appropriate standards and test procedures. 
AAPC and Nissan commented that the 
agencies should provide A/C efficiency credits similar to those included in the light-duty vehicle program. AAPC also commented that the AC17 test, included in the light-duty vehicle program to confirm A/C system performance, would be impractical and should not be required for heavy-duty vehicles. The agencies did not propose and are not adopting A/C efficiency credits for heavy-duty pickups and vans. AAPC suggests that the agencies could allow the same credits as are available in the light-duty vehicle program but no data is provided regarding the appropriateness of the credits. The EPA would need to resolve a number of open issues relating to environmental implications of A/C efficiency credits for these vehicles (among them, potential credit generation rate, whether credits would be windfall, implications for the standard stringency) before considering adopting an A/C efficiency credit regime. Also, the AC17 test is an integral part of the light-duty vehicle program serving as a confirmation that the credits are based on actual performance improvements. EPA does not believe that it would be appropriate to provide credits based only on the presumption that systems similar to those used in light-duty trucks will 
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provide the same improvements in 
heavy-duty pickups and vans with no confirmation through testing. 
AAPC also recommended that EPA 
provide credits for reduced refrigerant leakage and alternative refrigerant usage similar to the light-duty vehicle program. In response, as discussed above and in Section I.F, EPA has established standards for refrigerant leakage. EPA does not believe that it would be appropriate to provide credits for items that are essentially required. Providing such credits without an increase in total program stringency similar to the light-duty approach to A/ C efficiency and refrigerant leakage would result in a loss of program benefits. 
C. Use of the CAFE Model in Heavy- 
Duty Rulemaking 
NHTSA developed the CAFE model 
in 2002 to support the 2003 issuance of CAFE standards for MYs 2005–2007 light trucks. NHTSA has since significantly expanded and refined the model, and has applied the model to support every ensuing CAFE rulemaking for both light-duty and heavy-duty. For this analysis, the model was reconfigured to use the work based attribute metric of ‘‘work factor’’ established in the Phase 1 rule instead of the light duty ‘‘footprint’’ attribute metric. 
Past analyses conducted using the 
CAFE model have been subjected to extensive and detailed review and comment, much of which has informed the model’s expansion and refinement. NHTSA’s use of the model was 
considered and supported in Center for Biological Diversity v. National Highway 
Traffic Safety Admin., 538 F.3d 1172, 1194 (9th Cir. 2008). For further discussion see 76 FR 57198, and the model has been subjected to formal peer review and review by the General Accounting Office (GAO) and National Research Council (NRC). NHTSA makes public the model, source code, and— except insofar as doing so will compromise confidential business information (CBI) manufacturers have provided to NHTSA—all model inputs and outputs underlying published rulemaking analyses. 
Although the CAFE model can also be 
used for more aggregated analysis (e.g., involving ‘‘representative vehicles,’’ single-year snapshots, etc.), NHTSA designed the model with a view toward (a) detailed simulation of manufacturers’ potential actions given a defined set of standards, followed by (b) calculation of resultant impacts and economic costs and benefits. The model is intended to describe actions manufacturers could take in light of 
defined standards and other input 
assumptions and estimates, not to predict actions manufacturers will take 
in light of competing product and market interests (e.g. engine power, 
customer features, technology acceptance, etc.). 
For the proposal, the agencies 
conducted coordinated and complementary analyses using two analytical methods for the heavy-duty pickup and van segment by employing both NHTSA’s CAFE model and EPA’s MOVES model. The agencies used EPA’s MOVES model to estimate fuel consumption and emissions impacts for tractor-trailers (including the engine that powers the tractor), and vocational vehicles (including the engine that powers the vehicle). Additional calculations were performed to determine corresponding monetized program costs and benefits. For heavy- duty pickups and vans, the agencies performed complementary analyses, which we refer to as ‘‘Method A’’ and ‘‘Method B.’’ 
For the final rule, NHTSA’s Method A 
uses a modified version of the CAFE model developed since the NPRM, as well as accompanying updates to CAFE model inputs, to project a pathway the industry could use to comply with each regulatory alternative and the estimated effects on fuel consumption, emissions, benefits and costs were industry to do so. Method A is presented below in Section D and differs from the Method A analysis provided in the NPRM. NHTSA considered the results of the Method A analysis for decision making for the final rule. 
EPA’s Method B analysis continues to 
use the CAFE model and inputs developed for the NPRM to identify technology pathways the industry could potentially use to comply with each regulatory alternative, along with resultant impacts on per vehicle costs should that compliance path be utilized, and the MOVES model was used to calculate corresponding changes in total fuel consumption and annual emissions. The results are presented in Section E. Additional calculations were performed to determine corresponding monetized program costs and benefits. NHTSA’s consideration of the Method A analysis and EPA’s consideration of the Method B analysis led the agencies to the same conclusions regarding the selection of the Phase 2 standards. See Sections D and E for additional discussion of these two methods and the feasibility of the standards. (1) Overview of the CAFE Model 
As a starting point, the model makes 
use of an input file defining the analysis 
fleet—that is, a set of specific vehicle models (e.g., Ford F250) and model 
configurations (e.g., Ford F250 with 6.2- 
liter V8 engine, 4WD, and 6-speed manual transmission) estimated or assumed to be produced by each manufacturer in each model year to be included in the analysis. The analysis fleet includes key engineering attributes (e.g., curb weight, payload and towing 
capacities, dimensions, presence of various fuel-saving technologies) of each vehicle model, engine, and transmissions, along with estimates or assumptions of future production volumes. It also specifies the extent to which specific vehicle models share engines, transmissions, and vehicle platforms, and describes each manufacturer’s estimated or assumed product cadence (i.e., timing for 
freshening and redesigning different vehicles and platforms). This input file also specifies a payback period used to estimate the potential that each manufacturer might apply technology to improve fuel economy beyond levels required by standards. 
A second input file to the model 
contains a variety of contextual estimates and assumptions. Some of these inputs, such as future fuel prices and vehicle survival and mileage accumulation (versus vehicle age), are relevant to estimating manufacturers’ potential application of fuel-saving technologies. Some others, such as fuel density and carbon content, vehicular and upstream emission factors, the social cost of carbon dioxide emissions, and the discount rate, are relevant to calculating physical and economic impacts of manufacturers’ application of fuel-saving technologies. 
A third input file contains estimates 
and assumptions regarding the future applicability, availability, efficacy, and cost of various fuel-saving technologies. Efficacy is expressed in terms of the percentage reduction in fuel consumption, cost is expressed in dollars, and both efficacy and cost are expressed on an incremental basis (i.e., estimates for more advanced technologies are specified as increments beyond less advanced technologies). The input file also includes ‘‘synergy factors’’ used to make adjustments accounting for the potential that some combinations of technologies may result fuel savings or costs different from those indicated by incremental values. Thus, the model itself does not evaluate which technologies will be available, nor does it evaluate how effective or reliable they 
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470e.g., manufacturers’ Web sites, Wards 
Automotive. will be. The technological availability 
and effectiveness are rather predefined inputs to the model based on the agencies’ judgements and not outputs from the model, which is simply a tool for calculating the effects of combining input assumptions. 
Finally, a fourth model input file 
specifies standards to be evaluated. Standards are defined on a year-by-year basis separately for each regulatory class (passenger cars, light trucks, and heavy- duty pickups and vans). Regulatory alternatives are specified as discrete scenarios, with one scenario defining the no-action alternative or ‘‘baseline,’’ all other scenarios defining regulatory alternatives to be evaluated relative to that no-action alternative. 
Given these inputs, the model 
estimates each manufacturer’s potential year-by-year application of fuel-saving technologies to each engine, transmission, and vehicle. Subject to a range of engineering and planning- related constraints (e.g., secondary axle 
disconnect can’t be applied to 2-wheel drive vehicles, many major technologies can only be applied practicably as part of a vehicle redesign, and applied technologies carry forward between model years), the model attempts to apply technology to each manufacturer’s fleet in a manner that minimizes ‘‘effective costs’’ (accounting, in particular, for technology costs and avoided fuel outlays), continuing to add improvements as long as doing so will help toward compliance with specified standards or will produce fuel savings that ‘‘pay back’’ at least as quickly as specified in the input file mentioned above. 
After estimating the extent to which 
each manufacturer might add fuel- saving technologies under each specified regulatory alternative, the model calculates a range of physical impacts, such as changes in highway travel (i.e., VMT), changes in fleetwide 
fuel consumption, changes in highway fatalities, and changes in vehicular and 
upstream greenhouse gas and criteria pollutant emissions. The model also applies a variety of input estimates and assumptions to calculate economic costs and benefits to vehicle owners and society, based on these physical impacts. These are considered Method A results. 
Since the manufacturers of HD 
pickups and vans generally only have one basic pickup truck and van with different versions ((i.e., different 
wheelbases, cab sizes, two-wheel drive, four-wheel drive, etc.) there exists less flexibility than in the light-duty fleet to coordinate model improvements over several years. As such, the CAFE model allows changes to the HD pickups and 
vans to meet new standards according to estimated redesign cycles included as a model input. As noted above, the opportunities for large-scale changes (e.g., new engines, transmission, vehicle 
body and mass) thus occur less frequently than in the light-duty fleet, typically at spans of eight or more years for this analysis. However, opportunities for gradual improvements not necessarily linked to large scale changes can occur between the redesign cycles (i.e., model refresh). Examples of 
such improvements are upgrades to an existing vehicle model’s engine, transmission and aftertreatment systems. 
(2) How did the agencies develop the 
analysis fleet for the NPRM? 
As discussed above, both agencies 
used a version of NHTSA’s CAFE modeling system to estimate technology costs and application rates under each regulatory alternative considered. The modeling system relies on many inputs, including an analysis fleet. In order to estimate the impacts of potential standards, it is necessary to estimate the composition of the future vehicle fleet. Doing so enables estimation of the extent to which each manufacturer may need to add technology in response to a given series of attribute-based standards, accounting for the mix and fuel consumption of vehicles in each manufacturer’s regulated fleet. The agencies create an analysis fleet in order to track the volumes and types of fuel economy-improving and CO
2-reducing 
technologies that are already present in the existing vehicle fleet. This aspect of the analysis fleet helps to keep the CAFE model from adding technologies to vehicles that already have these technologies, which will result in ‘‘double counting’’ of technologies’ costs and benefits. An additional step involved projecting the fleet sales into MYs 2019–2030. This represents the fleet volumes that the agencies believe will exist in MYs 2019–2030. The following presents an overview of the information and methods applied to develop the analysis fleet, and some 
basic characteristics of that fleet. 
Most of the information about the 
vehicles that make up the 2014 analysis fleet (used in the NPRM and Method B of this FRM) and the 2015 analysis fleet (used in Method A of this FRM) was gathered from the 2014 and 2015 Pre- Model Year Reports submitted to EPA by the manufacturers under Phase 1 of Fuel Efficiency and GHG Emission Program for Medium- and Heavy-Duty Trucks, MYs 2014–2018. The major manufacturers of class 2b and class 3 trucks (Chrysler, Ford and GM) were 
asked to voluntarily submit updates to their Pre-Model Year Reports. The agencies used these updated data in constructing the analysis fleet for these manufacturers. The agencies agreed to treat this information as Confidential Business Information (CBI) until the publication of the proposed rule. This information can be made public at this time because by now all MY 2014 and MY 2015 vehicle models have been 
produced, which makes data about them essentially public information. 
In addition to information about each 
vehicle, the agencies need additional information about the fuel economy- improving/CO
2-reducing technologies 
already on those vehicles in order to assess how much and which technologies to apply to determine a path toward future compliance. To correctly account for the cost and effectiveness of adding technologies, it is necessary to know the technology penetration in the existing vehicle fleet. Otherwise, ‘‘double-counting’’ of technology could occur. Thus, in their respective analysis fleets, the agencies augmented this information with data from public and commercial sources
470 
that include more complete technology descriptions, e.g. for specific engines 
and transmissions. 
The resultant analysis fleets are 
provided in detail at NHTSA’s Web site, along with all other inputs to and outputs from both the NPRM and the current analysis. The agencies invited but did not receive comment on this analysis. 
(a) Vehicle Redesign Schedules and 
Platforms 
Product cadence in the Class 2b and 
3 pickup market has historically ranged from 7–9 years between major redesigns. However, due to increasing competitive pressures and consumer demands the agency anticipates that manufacturers will generally shift to shorter design cycles resembling those of the light duty market. Pickup truck manufacturers in the Class 2b and 3 segments are shown to adopt redesign cycles of six years, allowing two redesigns prior to the end of the regulatory period in 2025. 
The Class 2b and 3 van market has 
changed markedly from five years ago. Ford, Nissan, Ram and Daimler have adopted vans of ‘‘Euro Van’’ appearance, and in many cases now use smaller turbocharged gasoline or diesel engines in the place of larger, naturally- aspirated V8s. The 2014 and 2015 model years used in this analysis 
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471Tables from AEO’s forecast are available at 
http://www.eia.gov/oiaf/aeo/tablebrowser/ . The agencies also made use of the IHS Automotive Light 
Vehicle Production Forecast (August 2014). represent a period where most 
manufacturers, with the exception of General Motors, have recently introduced a completely redesigned product after many years. The van segment has historically been one of the slowest to be redesigned of any product segment, with some products going two decades or more between redesigns. 
Due to new entrants in the field and 
increased competition, the agencies anticipate that most manufacturers will increase the pace of product redesigns in the van segment, but that they will continue to trail other segments. The cycle time used in this analysis is approximately ten years between major redesigns, allowing manufacturers’ only one major redesign during the regulatory period. The agencies did not receive comment on this anticipated product design cycle. 
Additional detail on product cadence 
assumptions for specific manufacturers is located in Chapter 10 of the RIA. 
(b) Sales Volume Forecast 
Since each manufacturer’s required 
average fuel consumption and GHG 
levels are sales-weighted averages of the 
fuel economy/GHG targets across all model offerings, sales volumes play a critical role in estimating that burden. The CAFE model requires a forecast of sales volumes, at the vehicle model- variant level, in order to simulate the technology application necessary for a manufacturer to achieve compliance in each model year for which outcomes are simulated. 
As stated above, the agencies relied 
on the pre-model-year compliance submissions from manufacturers to provide sales volumes at the model level based on the level of disaggregation in which the models appear in the compliance data. However, the agencies only use these reported volumes without adjustment for the reference fleet model year (MY 2014 or MY 2015). For all future model years, we combine the manufacturer submissions with sales projections from the 2014 (for the NPRM and Method B of the FRM) or 2015 (for Method A of the FRM) Annual Energy Outlook Reference Case and IHS Automotive to determine model variant level sales volumes in future years.
471The 
projected sales volumes by class that appear in the Annual Energy Outlook as a result of a collection of assumptions about economic conditions, demand for commercial miles traveled, and technology migration from light-duty pickup trucks in response to the concurrent light-duty CAFE/GHG standards. These are shown in Chapter 2 of the RIA. 
The projection of total sales volumes 
for the Class 2b and 3 market segment was based on the total volumes in the 
2014 AEO Reference Case in the NPRM and for Method B of this FRM. For the purposes of this analysis, the AEO2014 calendar year volumes have been used to represent the corresponding model- year volumes. While AEO2014 provides enough resolution in its projections to separate the volumes for the Class 2b and 3 segments, the agencies deferred to the vehicle manufacturers and chose to rely on the relative shares present in the pre-model-year compliance data. This 
methodology remains the same for the Method A FRM analysis, but we have replaced the 2014 AEO reference case with the 2015 AEO reference case. 
The relative sales share by vehicle 
type (van or pickup truck, in this case) was derived from a sales forecast that the agencies purchased from IHS Automotive, and applied to the total volumes in the AEO2014 projection. Table VI–3 shows the implied shares of the total new 2b/3 vehicle market broken down by manufacturer and vehicle type. The same methodology was applied using 2015 IHS/Polk projections, and the total volumes from the AEO2015 projection for Method A of the FRM. The results of the 2015-based projections are presented in the following section about changes made to the model since the NPRM. 
TABLE VI–3—IHS A UTOMOTIVE MARKET SHARE FORECAST FOR 2B/3 V EHICLES  
Manufacturer Style Model year market share 
2015 
(%) 2016 
(%) 2017 
(%) 2018 
(%) 2019 
(%) 2020 
(%) 2021 
(%) 
Daimler ..................................... Van .................. 3 3 3 3 3 3 3 
Fiat Chrysler ............................. Van .................. 2 2 2 2 2 2 3 
Ford .......................................... Van .................. 16 17 17 17 18 18 18 
General Motors ......................... Van .................. 12 12 11 12 13 13 13 
Nissan ....................................... Van .................. 2 2 2 2 2 2 2 
Daimler ..................................... Pickup ............. 0 0 0 0 0 0 0 
Fiat Chrysler ............................. Pickup ............. 14 14 14 14 11 12 12 
Ford .......................................... Pickup ............. 28 27 30 30 30 27 26 
General Motors ......................... Pickup ............. 23 23 21 21 21 22 23 
Nissan ....................................... Pickup ............. 0 0 0 0 0 0 0 
Within those broadly defined market 
shares, volumes at the manufacturer/ 
model-variant level were constructed by applying the model-variant’s share of manufacturer sales in the pre-model- 
year compliance data for the relevant vehicle style, and multiplied by the total volume estimated for that manufacturer and that style. 
After building out a set of initial 
future sales volumes based on the sources described above, the agencies attempted to incorporate new 
information about changes in sales mix that are not captured by either the existing sales forecasts or the simulated technology changes in vehicle platforms. In particular, Ford has announced intentions to phase out their existing Econoline vans, gradually shifting volumes to the new Transit platform for some model variants (notably chassis cabs and cutaways variants) and eliminating offerings outright for complete Econoline vans as early as model year 2015. In the case of complete Econoline vans, the volumes for those vehicles were allocated to MY 2015 Transit vehicles based on assumptions about likely production splits for the powertrains of the new Transit platform. The volumes for complete Econoline vans were shifted at ratios of 50 percent, 35 percent, and 15 
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472Volpe CAFE Model, available at http://
www.nhtsa.gov/fuel-economy. 473U.S. DOT/NHTSA, Relationships Between 
Fatality Risk Mass and Footprint in MY 2000–2007 
PC and LTVs, ID: NHTSA–2010–0131–0336, Posted August 21, 2012. percent for 3.7 L, 3.5 L Eco-boost, and 
3.2 L diesel, respectively. Within each powertrain, sales were allocated based on the percentage shares present in the pre-model-year compliance data. The chassis cab and cutaway variants of the Econolines were phased out linearly between MY 2015 and MY 2020, at which time the Econolines cease to exist in any form and all corresponding volume resides with the Transits. 
(3) Other Analysis Inputs 
In addition to the inputs summarized 
above, the analysis of potential 
standards for HD pickups and vans makes use of a range of other estimates and assumptions specified as inputs to the CAFE modeling system. Some significant inputs (e.g., estimates of 
future fuel prices) also applicable to other MDHD segments are discussed below in Section IX. Others more specific to the analysis of HD pickups and vans are as follows: 
(a) Vehicle Survival and Mileage 
Accumulation 
The analysis estimates the travel, fuel 
consumption, and emissions over the useful lives of vehicles produced during model years 2014–2030. Doing so requires initial estimates of these vehicles’ survival rates (i.e., shares 
expected to remain in service) and mileage accumulation rates (i.e., anticipated annual travel by vehicles remaining in service), both as a function of vehicle vintage (i.e., age). These 
estimates are based on an empirical analysis of changes in the fleet of registered vehicles over time from HIS/ Polk data, in the case of survival rates. The NPRM and Method A of the FRM use data collected as part of the last Vehicle In Use Survey (the 2002 VIUS) for the mileage accumulation schedule. Method A of the FRM uses mileage accumulation schedules from 2014 Polk/IHS odometer reading data. The changes to the VMT schedules for Method A of the current analysis are further described below in the Method A FRM specific changes. 
(b) Rebound Effect 
Expressed as an elasticity of mileage 
accumulation with respect to the fuel 
cost per mile of operation, the agencies have applied a rebound effect of 10 percent for today’s analysis. Other rebound effects are considered in sensitivity analyses in Sections D. 
(c) On-Road ‘‘Gap’’ 
The model was run with a 20 percent 
adjustment to reflect differences 
between on-road and laboratory performance. (d) Fleet Population Profile 
Though not reported here, cumulative 
fuel consumption and CO
2emissions 
are presented in the accompanying EIS, 
and these calculations utilize estimates of the numbers of vehicles produced in each model year remaining in service in calendar year 2014. The initial age distribution of the registered vehicle population in 2014 is based on vehicle registration data acquired by NHTSA from R.L. Polk Company. For Method A, these values were updated to reflect newer data acquired by NHTSA from Polk. 
(e) Past Fuel Consumption Levels 
Though not reported here, cumulative 
fuel consumption and CO
2emissions 
are presented in the accompanying EIS, 
and these calculations require estimates of the performance of vehicles produced prior to model year 2014. Consistent with AEO 2014, the model was run with the assumption that gasoline and diesel HD pickups and vans averaged 14.9 mpg and 18.6 mpg, respectively, with gasoline versions averaging about 48 percent of production. For Method A, these values were updated to reflect AEO2015, such that gasoline and diesel versions were projected to average 16.0 
mpg and 20.0 mpg, respectively. 
(f) Long-Term Fuel Consumption Levels 
Though not reported here, longer-term 
estimates of fuel consumption and 
emissions are presented in the accompanying EIS. These estimates include calculations involving vehicle produced after MY 2030 and, consistent with AEO 2014, the model was run with the assumption that fuel consumption and CO
2emission levels will continue 
to decline at 0.05 percent annually (compounded) after MY 2030. 
(g) Payback Period 
To estimate in what sequence and to 
what degree manufacturers might add 
fuel-saving technologies to their respective fleets, the CAFE model iteratively ranks remaining opportunities (i.e., applications of 
specific technologies to specific vehicles) in terms of effective cost, primary components of which are the technology cost and the avoided fuel outlays, attempting to minimize effective costs incurred.
472Depending 
on inputs, the model also assumes manufacturers may improve fuel consumption beyond requirements insofar as doing so will involve applications of technology at negative effective cost—i.e., technology application for which buyers’ up-front costs are quickly paid back through avoided fuel outlays. This calculation includes only fuel outlays occurring within a specified payback period. For both Method A and Method B, a payback period of 6 months was applied for the dynamic baseline case, or Alternative 1b. Thus, for example, a manufacturer already in compliance with standards is projected to apply a fuel consumption improvement projected to cost $250 (i.e., as a cost that 
could be charged to the buyer at normal profit to the manufacturer) and reduce fuel costs by $500 in the first year of vehicle operation. The agencies have conducted the same analysis applying a payback period of 0 months for the flat baseline case, or Alternative 1a. For Method A, Alternative 1b is the primary analysis, and Alternative 1a is one of a range of cases included in the sensitivity analysis. 
(h) Civil Penalties in the NHTSA 
Analysis 
EPCA and EISA require that a 
manufacturer pay civil penalties if it does not have enough credits to cover a shortfall with one or both of the light- duty CAFE standards in a model year. While these provisions do not apply to HD pickups and vans, at this time, the CAFE model will show civil penalties owed in cases where available technologies and credits are estimated to be insufficient for a manufacturer to achieve compliance with a standard. These model-reported estimates have been excluded from this analysis. For Method A, this aspect of the model has been modified to also exclude from the calculation of ‘‘effective cost’’ used to select among available options to add specific technologies to specific vehicles. 
(i) Coefficients for Fatality Calculations 
Both the NPRM and the current 
analysis consider the potential effects 
on crash safety of the technologies manufacturers may apply to their vehicles to meet each of the regulatory alternatives. NHTSA research has shown that vehicle mass reduction affects overall societal fatalities associated with crashes
473and, most 
relevant to this rule, mass reduction in heavier light- and medium-duty vehicles has an overall beneficial effect on societal fatalities. Reducing the mass of a heavier vehicle involved in a crash with another vehicle(s) makes it less 
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474EPA MOVES model available at http://
www3.epa.gov/otaq/models/moves/index.htm (last 
accessed Feb 23, 2015). 
475GREET (Greenhouse Gases, Regulated 
Emissions, and Energy Use in Transportation) 
Model, Argonne National Laboratory, https://greet.es.anl.gov/. likely there will be fatalities among the 
occupants of the other vehicles. In addition to the effects of mass reduction, the analysis anticipates that these standards, by reducing the cost of driving HD pickups and vans, will lead to increased travel by these vehicles and, therefore, more crashes involving these vehicles. The Method B analysis considers overall impacts considering both of these factors, using a methodology similar to NHTSA’s analyses for the MYs 2017–2025 CAFE and GHG emission standards. 
The Method B analysis includes 
estimates of the extent to which HD pickups and vans produced during MYs 2014–2030 may be involved in fatal crashes, considering the mass, survival, and mileage accumulation of these vehicles, taking into account changes in mass and mileage accumulation under each regulatory alternative. These calculations make use of the same coefficients applied to light trucks in the MYs 2017–2025 CAFE rulemaking analysis. Baseline rates of involvement in fatal crashes are 13.03 and 13.24 fatalities per billion miles for vehicles with initial curb weights above and below 4,594 lbs, respectively. Considering that the data underlying the corresponding statistical analysis included observations through calendar year 2010, these rates are reduced by 9.6 percent to account for subsequent impacts of recent Federal Motor Vehicle Safety Standards (FMVSS) and anticipated behavioral changes (e.g., continued increases in seat belt use). For vehicles above 4,594 lbs—i.e., the 
majority of the HD pickup and van fleet—mass reduction is estimated to reduce the net incidence of highway fatalities by 0.34 percent per 100 lbs. of removed curb weight. For the few HD pickups and vans below 4,594 lbs, mass reduction is estimated to increase the net incidence of highway fatalities by 0.52 percent per 100 lbs. Consistent with DOT guidance, the social cost of highway fatalities is estimated using a value of statistical life (VSL) of $9.36m in 2014, increasing thereafter at 1.18 percent annually. 
The Method A analysis uses the same 
methodology as described above, but applies coefficients that have been updated to reflect more current data, updated statistical analysis by NHTSA staff, and updated DOT guidance regarding the VSL. Baseline rates of involvement in fatal crashes are 16.06 and 14.35 fatalities per billion miles for pickups and vans with initial curb weights above and below 4,947 lbs, respectively. Considering that the data 
underlying the corresponding statistical analysis included observations through calendar year 2012, these rates are 
reduced by 9.6 percent to account for subsequent impacts of recent Federal Motor Vehicle Safety Standards (FMVSS) and anticipated behavioral changes (e.g., continued increases in 
seat belt use). For vehicles above 4,947 
lbs—i.e., the majority of the HD pickup 
and van fleet—mass reduction is estimated to reduce the net incidence of highway fatalities by 0.72 percent per 100 lbs. of removed curb weight. For HD pickups and vans below 4,947 lbs (accounting for any applied mass reduction), mass reduction is estimated to reduce the net incidence of highway fatalities by 0.10 percent per 100 lbs. Consistent with DOT guidance, the social cost of highway fatalities is estimated using a value of statistical life (VSL) of $9.4m from 2015 forward. 
(j) Compliance Credit Provisions 
Today’s analysis accounts for the 
potential to over comply with standards 
and thereby earn compliance credits, applying these credits to ensuring compliance requirements. In doing so, the agencies treat any unused carried- forward credits as expiring after five model years, consistent with current and standards. For today’s analysis, the agencies are not estimating the potential to ‘‘borrow’’—i.e., to carry credits back 
to past model years. 
(k) Emission Factors 
While CAFE model calculates 
vehicular CO
2emissions directly on a 
per-gallon basis using fuel consumption 
and fuel properties (density and carbon content), the model calculates emissions of other pollutants (methane, nitrogen oxides, ozone precursors, carbon monoxide, sulfur dioxide, particulate matter, and air toxics) on a per-mile basis. In doing so, the Method A analysis used corresponding emission factors estimated using EPA’s MOVES model.
474To estimate emissions 
(including CO 2) from upstream 
processes involved in producing, distributing, and delivering fuel, NHTSA has applied emission factors— all specified on a gram per gallon basis—derived from Argonne National Laboratory’s GREET model.
475 
(l) Refueling Time Benefits 
To estimate the value of time savings 
associated with vehicle refueling, the Method A analysis used estimates that an average refueling event involves 
refilling 60 percent of the tank’s capacity over the course of 3.5 minutes, at an hourly cost of $27.22. 
(m) External Costs of Travel 
Changes in vehicle travel will entail 
economic externalities. To estimate 
these costs, the Method A analysis used estimates that congestion-, crash-, and noise-related externalities will total 5.1¢/mi., 2.8¢/mi., and 0.1¢/mi., respectively. 
(n) Ownership and Operating Costs 
Method A results predict that the total 
cost of vehicle ownership and operation 
will change not just due to changes in vehicle price and fuel outlays, but also due to some other costs likely to vary with vehicle price. To estimate these costs, NHTSA has applied factors of 5.5 percent (of price) for taxes and fees, 15.3 percent for financing, 19.2 percent for insurance, 1.9 percent for relative value loss. The Method A analysis also estimates that average vehicle resale value will increase by 25 percent of any increase in new vehicle price. 
(4) What Technologies Did the Agencies 
Consider 
The agencies considered over 35 
vehicle technologies that manufacturers could use to improve the fuel consumption and reduce CO
2emissions 
of their vehicles during MYs 2021–2027. The majority of the technologies described in this section are readily available, well known and proven in other vehicle sectors, and could be incorporated into vehicles once production decisions are made. Other technologies considered may not currently be in production, but are beyond the research phase and under development, and are expected to be in production in highway vehicles over the next few years. These are technologies that are capable of achieving significant improvements in fuel economy and reductions in CO
2emissions, at 
reasonable costs. The agencies did not consider technologies in the research stage because there is insufficient time for such technologies to move from research to production during the model years covered by this final action. 
The technologies considered in the 
agencies’ analysis are briefly described below. They fall into five broad categories: Engine technologies, transmission technologies, vehicle technologies, electrification/accessory technologies, and hybrid technologies. 
In this class of trucks and vans, diesel 
engines are installed in about half of all vehicles. The buyer’s decision to purchase a diesel versus gasoline engine 
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476‘‘Impact of Friction Reduction Technologies 
on Fuel Economy,’’ Fenske, G. Presented at the 
March 2009 Chicago Chapter Meeting of the ‘Society of Tribologists and Lubricated Engineers’ Meeting, March 18th, 2009. Available at: http://www.chicagostle.org/program/2008-2009/Impact%20of%20Friction%20Reduction%20Technologies%20on%20Fuel%20Economy%20- %20with%20VGs%20removed.pdf (last accessed 
July 9, 2009). 477Although couple cam phasing appears only in 
the single overhead cam and overhead valve branches of the decision tree, it is noted that a single phaser with a secondary chain drive would allow couple cam phasing to be applied to direct overhead cam engines. Since this would potentially be adopted on a limited number of direct overhead cam engines NHTSA did not include it in that branch of the decision tree. 
478It is also noted that coaxial camshaft 
developments would allow other variable valve timing options to be applied to overhead valve engines. However, since they would potentially be adopted on a limited number of overhead valve engines, NHTSA did not include them in the decision tree. depends on several factors including 
initial purchase price, fuel operating costs, durability, towing capability and payload capacity amongst other reasons. As discussed in VI.B. above, the agencies generally prefer to set standards that do not distinguish between fuel types where technological or market-based reasons do not strongly argue otherwise. However, as with Phase 1, we continue to believe that fundamental differences between spark ignition and compression ignition engines warrant unique fuel standards, which is also important in ensuring that our program maintains product choices available to vehicle buyers. Therefore, as discussed in Section B.1, we are maintaining separate standards for gasoline and diesel vehicles. In the context of our technology discussion for heavy-duty pickups and vans, we are treating gasoline and diesel engines separately so each has a set of baseline technologies. We discuss performance improvements in terms of changes to those baseline engines. Our cost and inventory estimates contained elsewhere reflect the current fleet baseline with an appropriate mix of gasoline and diesel engines. Note that we are not basing these standards on a targeted switch in the mix of diesel and gasoline vehicles. We believe our standards require similar levels of technology development and cost for both diesel and gasoline vehicles. Hence the program is not intended to force, nor discourage, changes in a manufacturer’s fleet mix between gasoline and diesel vehicles. 
The following contains a description 
of technologies the agencies considered as potentially available in the rule timeframe, and hence, having potential to be part of a compliance pathway for these vehicles. Additionally, the agencies did not receive any comments indicating that the technology effectiveness estimates used in the determination of potential reductions in GHGs and fuel consumption are not representative of the expected ranges for expected duty cycles. 
(a) Engine Technologies 
The agencies reviewed the engine 
technology estimates used in the 2017– 
2025 light-duty rule, the 2014–2018 heavy-duty rule, and the 2015 NHTSA Technology Study. In doing so the agencies reconsidered all available sources and updated the estimates as 
appropriate. The section below describes both diesel and gasoline engine technologies considered for this program. (i) Low Friction Lubricants 
One of the most basic methods of 
reducing fuel consumption in both 
gasoline and diesel engines is the use of lower viscosity engine lubricants. More advanced multi-viscosity engine oils are available today with improved performance in a wider temperature band and with better lubricating 
properties. This can be accomplished by changes to the oil base stock (e.g., switching engine lubricants from a Group I base oils to lower-friction, lower viscosity Group III synthetic) and through changes to lubricant additive packages (e.g., friction modifiers and 
viscosity improvers). The use of 5W–30 motor oil is now widespread and auto manufacturers are introducing the use of even lower viscosity oils, such as 5W– 20 and 0W–20, to improve cold-flow properties and reduce cold start friction. However, in some cases, changes to the crankshaft, rod and main bearings and changes to the mechanical tolerances of engine components may be required. In all cases, durability testing will be required to ensure that durability is not compromised. The shift to lower viscosity and lower friction lubricants will also improve the effectiveness of valvetrain technologies such as cylinder deactivation, which rely on a minimum oil temperature (viscosity) for operation. 
(ii) Engine Friction Reduction 
In addition to low friction lubricants, 
manufacturers can also reduce friction 
and improve fuel consumption by improving the design of both diesel and gasoline engine components and subsystems. Approximately 10 percent of the energy consumed by a vehicle is lost to friction, and just over half is due to frictional losses within the engine.
476 
Examples include improvements in low- tension piston rings, piston skirt design, roller cam followers, improved crankshaft design and bearings, material coatings, material substitution, more optimal thermal management, and piston and cylinder surface treatments. Additionally, as computer-aided modeling software continues to improve, more opportunities for evolutionary friction reductions may become available. All reciprocating and rotating components in the engine are potential candidates for friction reduction, and minute improvements in 
several components can add up to a measurable fuel efficiency improvement. 
(iii) Engine Parasitic Demand Reduction 
In addition to physical engine friction 
reduction, manufacturers can reduce the 
mechanical load on the engine from parasitics, such as oil, fuel, and coolant pumps. The high-pressure fuel pumps of direct-injection gasoline and diesel engines have particularly high demand. Example improvements include variable speed or variable displacement water pumps, variable displacement oil pumps, more efficient high pressure fuel pumps, valvetrain upgrades and shutting off piston cooling when not needed. 
(iv) Coupled Cam Phasing 
Valvetrains with coupled (or 
coordinated) cam phasing can modify 
the timing of both the inlet valves and the exhaust valves an equal amount by phasing the camshaft of an overhead valve engine.
477For overhead valve 
engines, which have only one camshaft to actuate both inlet and exhaust valves, couple cam phasing is the only variable valve timing (VVT) implementation 
option available and requires only one cam phaser.
478We also considered 
variable valve lift (VVL), which alters the intake valve lift in order to reduce pumping losses and more efficiently ingest air. 
(v) Cylinder Deactivation 
In conventional spark-ignited engines 
throttling the airflow controls engine 
torque output. At partial loads, efficiency can be improved by using cylinder deactivation instead of throttling. Cylinder deactivation can improve engine efficiency by disabling or deactivating (usually) half of the cylinders when the load is less than half of the engine’s total torque capability— the valves are kept closed, and no fuel is injected—as a result, the trapped air within the deactivated cylinders is simply compressed and expanded as an air spring, with reduced friction and 
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heat losses. The active cylinders 
combust at almost double the load required if all of the cylinders were operating. Pumping losses are significantly reduced as long as the engine is operated in this ‘‘part- cylinder’’ mode. 
Cylinder deactivation control strategy 
relies on setting maximum manifold absolute pressures or predicted torque within a range in which it can deactivate the cylinders. Noise and vibration issues reduce the operating range to which cylinder deactivation is allowed, although manufacturers are exploring vehicle changes that enable increasing the amount of time that cylinder deactivation might be suitable. Some manufacturers may choose to adopt active engine mounts and/or active noise cancellations systems to address Noise Vibration and Harshness (NVH) concerns and to allow a greater operating range of activation. 
Cylinder deactivation has seen a 
recent resurgence thanks to better valvetrain designs and engine controls. General Motors and Fiat Chrysler have incorporated cylinder deactivation across a substantial portion of their V8- powered lineups, including some heavy duty applications. 
(vi) Stoichiometric Gasoline Direct 
Injection 
SGDI engines inject fuel at high 
pressure directly into the combustion chamber (rather than the intake port in port fuel injection). SGDI requires changes to the injector design, an additional high pressure fuel pump, new fuel rails to handle the higher fuel 
pressures and changes to the cylinder head and piston crown design. Direct injection of the fuel into the cylinder improves cooling of the air/fuel charge within the cylinder, which allows for higher compression ratios and increased thermodynamic efficiency without the onset of combustion knock. Recent injector design advances, improved electronic engine management systems and the introduction of multiple injection events per cylinder firing cycle promote better mixing of the air and fuel, enhance combustion rates, increase residual exhaust gas tolerance and improve cold start emissions. SGDI engines achieve higher power density and match well with other technologies, such as boosting and variable valvetrain designs. 
Most manufacturers have introduced 
vehicles with SGDI engines in light duty sectors, including GM and Ford and have announced their plans to increase dramatically the number of SGDI engines in their portfolios. SGDI has not been introduction on heavy duty applications at this time however as 
these largely dedicated heavy duty engines approach their redesign window, they are expected to become SGDI engines. 
(vii) Turbocharging and Downsizing 
The specific power of a naturally 
aspirated engine is primarily limited by 
the rate at which the engine is able to draw air into the combustion chambers. Turbocharging and supercharging (grouped together here as boosting) are two methods to increase the intake manifold pressure and cylinder charge- air mass above naturally aspirated levels. Boosting increases the airflow into the engine, thus increasing the specific power level, and with it the ability to reduce engine displacement while maintaining performance. This effectively reduces the pumping losses at lighter loads in comparison to a larger, naturally aspirated engine. 
Almost every major manufacturer 
currently markets a vehicle with some form of boosting. While boosting has been a common practice for increasing performance for several decades, turbocharging has considerable potential to improve fuel economy and reduce CO
2emissions when the engine 
displacement is also reduced. Specific power levels for a boosted engine often exceed 100 hp/L, compared to average naturally aspirated engine power densities of roughly 70 hp/L. As a result, engines can be downsized roughly 30 percent or higher while maintaining similar peak output levels. In the last decade, improvements to turbocharger turbine and compressor design have improved their reliability and performance across the entire engine operating range. New variable geometry turbines and ball-bearing center cartridges allow faster turbocharger spool-up (virtually eliminating the once-common ‘‘turbo 
lag’’) while maintaining high flow rates for increased boost at high engine speeds. Low speed torque output has been dramatically improved for modern turbocharged engines. However, even with turbocharger improvements, maximum engine torque at very low engine speed conditions, for example launch from standstill, is increased less than at mid and high engine speed conditions. The potential to downsize engines may be less on vehicles with low displacement to vehicle mass ratios for example a very small displacement engine in a vehicle with significant curb weight, in order to provide adequate acceleration from standstill, particularly up grades or at high altitudes. 
The use of GDI in combination with 
turbocharging and charge air cooling reduces the fuel octane requirements for 
knock limited combustion enabling the use of higher compression ratios and boosting pressures. Recently published data with advanced spray-guided injection systems and more aggressive engine downsizing targeted towards reduced fuel consumption and CO
2 
emissions reductions indicate that the potential for reducing CO
2emissions for 
turbocharged, downsized GDI engines may be as much as 15 to 30 percent relative to port-fuel-injected engines.
14 15 16 17 18 Confidential 
manufacturer data suggests an incremental range of fuel consumption and CO
2emission reduction of 4.8 to 7.5 
percent for turbocharging and downsizing. Other publicly-available sources suggest a fuel consumption and CO
2emission reduction of 8 to 13 
percent compared to current-production naturally-aspirated engines without friction reduction or other fuel economy technologies: A joint technical paper by Bosch and Ricardo suggesting fuel economy gain of 8 to 10 percent for downsizing from a 5.7 liter port injection V8 to a 3.6 liter V6 with direct injection using a wall-guided direct injection system; a Renault report suggesting a 11.9 percent NEDC fuel consumption gain for downsizing from a 1.4 liter port injection in-line 4- cylinder engine to a 1.0 liter in-line 4- cylinder engine, also with wall-guided direct injection; and a Robert Bosch paper suggesting a 13 percent NEDC gain for downsizing to a turbocharged DI engine, again with wall-guided injection. These reported fuel economy benefits show a wide range depending on the SGDI technology employed. 
Note that for this analysis the agencies 
determined that this technology path is only applicable to heavy duty applications that have operating conditions more closely associated with light duty vehicles. This includes vans designed mainly for cargo volume or modest payloads and having similar GCWR to light duty applications. These vans cannot tow trailers heavier than similar light duty vehicles and are largely already sharing engines of significantly smaller displacement and cylinder count compared to heavy duty vehicles designed mainly for trailer towing. 
ACEEE commented that 10 percent of 
pick-ups in the heavy duty sector are candidates for turbocharging and downsizing if they do not require higher payloads or towing capacity. Other commenters suggested that downsizing that has occurred in light duty could also occur in heavy duty. As discussed 
above, the agencies evaluated turbocharging and downsizing in 
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479Burning one gallon of diesel fuel produces 
about 15 percent more carbon dioxide than gasoline 
due to the higher density and carbon to hydrogen ratio. vehicles like vans which are not 
typically designed for extensive trailer towing. When we looked at pick-ups, we determined that consumers needing a pick-up without higher payload or trailer towing requirements would migrate to the lower cost light-duty versions which are typically identical in cabin size and seating as the heavy-duty versions but have less work capability. Because of this, in the agencies’ assessment, the heavy-duty pickups retained the high trailer towing and payload requirements and the corresponding larger engines. AAPC comments supported this approach as the correct combination of engine to intended use and even provided in their comments data indicating that turbocharged and downsized engines are more fuel efficient at lighter loads however under working conditions expected of a heavy-duty pick-up they are actually less fuel efficient than the larger engines. 
(viii) Cooled Exhaust-Gas Recirculation 
Cooled exhaust gas recirculation or 
Boosted EGR is a combustion concept 
that involves utilizing EGR as a charge diluent for controlling combustion 
temperatures and cooling the EGR prior to its introduction to the combustion system. Higher exhaust gas residual levels at part load conditions reduce pumping losses for increased fuel economy. The additional charge dilution enabled by cooled EGR reduces the incidence of knocking combustion and obviates the need for fuel enrichment at high engine power. This allows for higher boost pressure and/or compression ratio and further reduction in engine displacement and both pumping and friction losses while maintaining performance. Engines of this type use GDI and both dual cam phasing and discrete variable valve lift. The EGR systems considered in this final rule, consistent with the rule, will use a dual-loop system with both high and low pressure EGR loops and dual EGR coolers. The engines will also use single-stage, variable geometry turbocharging with higher intake boost pressure available across a broader range of engine operation than conventional turbocharged SI engines. Such a system is estimated to be capable of an additional 3 to 5 percent effectiveness relative to a turbocharged, downsized GDI engine without cooled- EGR. The agencies have also considered a more advanced version of such a cooled EGR system that employs very high combustion pressures by using dual stage turbocharging. (ix) Lean-Burn Combustion 
The agencies considered the concept 
that gasoline engines that are normally 
stoichiometric mainly for emission reasons can run lean over a range of operating conditions and utilize diesel like aftertreatment systems to control NO
X. For this analysis, we determined 
that the modal operation nature of this technology is currently only beneficial at light loads and will not be appropriate for a heavy duty application purchase specifically for its high work and load capacity. 
(b) Diesel Engine Technologies 
Diesel engines have several 
characteristics that give them superior 
fuel efficiency compared to conventional gasoline, spark-ignited engines. Pumping losses are much lower due to lack of (or greatly reduced) throttling. The diesel combustion cycle operates at a higher compression ratio, with a very lean air/fuel mixture, and turbocharged light-duty diesels typically achieve much higher torque levels at lower engine speeds than equivalent- displacement naturally-aspirated gasoline engines. Additionally, diesel fuel has a higher energy content per gallon.
479However, diesel fuel also has 
a higher carbon to hydrogen ratio, which increases the amount of CO
2 
emitted per gallon of fuel used by approximately 15 percent over a gallon of gasoline. 
Based on confidential business 
information and the 2010 NAS Report, two major areas of diesel engine design could be improved during the timeframe of this final rule. These areas include aftertreatment improvements and a broad range of engine improvements. 
(i) Aftertreatment Improvements 
The HD diesel pickup and van 
segment has largely adopted the SCR 
type of aftertreatment system to comply with criteria pollutant emission standards. As the experience base for SCR expands over the next few years, many improvements in this aftertreatment system such as construction of the catalyst, thermal management, and reductant optimization may result in a reduction in the amount of fuel used in the process. However, due to uncertainties with these improvements regarding the extent of current optimization and future criteria emissions obligations, the agencies are not considering aftertreatment improvements as a fuel- saving technology in the rulemaking analysis. 
(ii) Engine Improvements 
Diesel engines in the HD pickup and 
van segment are expected to have 
several improvements in their base design in the 2021–2027 timeframe. These improvements include items such as improved combustion management, optimal turbocharger design, and improved thermal management. 
(c) Transmission Technologies 
The agencies have also reviewed the 
transmission technology estimates used 
in the 2017–2015 light-duty and 2014– 2018 heavy-duty final rules. In doing so, NHTSA and EPA considered or reconsidered all available sources including the 2015 NHTSA Technology Study and updated the estimates as appropriate. The section below describes each of the transmission technologies considered for this rule. 
(i) Automatic 8-Speed Transmissions 
Manufacturers can also choose to 
replace 6-speed automatic transmissions 
with 8-speed automatic transmissions. Additional ratios allow for further optimization of engine operation over a wider range of conditions, but this is subject to diminishing returns as the number of speeds increases. As additional gear sets are added, additional weight and friction are introduced requiring additional countermeasures to offset these losses. Some manufacturers are replacing 6- speed automatics already, and 7 to 10- speed automatics have entered production. 
(ii) High Efficiency Transmission 
For this rule, a high efficiency 
transmission refers to some or all of a 
suite of incremental transmission improvement technologies that should be available within the 2019 to 2027 timeframe. The majority of these improvements address mechanical friction within the transmission. These improvements include but are not limited to: Shifting clutch technology improvements, improved kinematic design, dry sump lubrication systems, more efficient seals, bearings and clutches (reducing drag), component superfinishing and improved transmission lubricants. 
(iii) Secondary Axle Disconnect 
The ability to disconnect some of the 
rotating components in the front axle on 
4wd vehicles when the secondary axle is not needed for traction. This will reduce friction and increase fuel economy. 
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480In the CAFE model, improved accessories 
refers solely to improved engine cooling. (d) Electrification/Accessory 
Technologies 
(i) Electrical Power Steering or 
Electrohydraulic Power Steering 
Electric power steering (EPS) or 
Electrohydraulic power steering (EHPS) provides a potential reduction in CO
2 
emissions and fuel consumption over hydraulic power steering because of reduced overall accessory loads. This eliminates the parasitic losses associated with belt-driven power steering pumps which consistently draw load from the engine to pump hydraulic fluid through the steering actuation systems even when the wheels are not being turned. EPS is an enabler for all vehicle hybridization technologies since it provides power steering when the engine is off. EPS may be implemented on most vehicles with a standard 12V system. Some heavier vehicles may require a higher voltage system which may add cost and complexity. 
(ii) Improved Accessories 
The accessories on an engine, 
including the alternator, coolant and oil 
pumps are traditionally mechanically- driven. A reduction in CO
2emissions 
and fuel consumption can be realized by driving them electrically, and only when needed (‘‘on-demand’’). 
Electric water pumps and electric fans 
can provide better control of engine cooling. For example, coolant flow from an electric water pump can be reduced and the radiator fan can be shut off during engine warm-up or cold ambient temperature conditions which will reduce warm-up time, reduce warm-up fuel enrichment, and reduce parasitic losses. 
Indirect benefit may be obtained by 
reducing the flow from the water pump electrically during the engine warm-up period, allowing the engine to heat more rapidly and thereby reducing the fuel enrichment needed during cold operation and warm-up of the engine. Faster oil warm-up may also result from better management of the coolant warm- up period. Further benefit may be obtained when electrification is combined with an improved, higher efficiency engine alternator used to supply power to the electrified accessories. 
Intelligent cooling can more easily be 
applied to vehicles that do not typically carry heavy payloads, so larger vehicles with towing capacity present a challenge, as these vehicles have high cooling fan loads.
480However, towing 
vehicles tend to have large cooling system capacity and flow scaled to required heat rejection levels when under full load situations such as towing at GCWR in extreme ambient conditions. During almost all other situations, this design characteristic may result in unnecessary energy usage for coolant pumping and heat rejection to the radiator. 
The agencies considered whether to 
include electric oil pump technology for the rulemaking. Because it is necessary to operate the oil pump any time the engine is running, electric oil pump technology has insignificant effect on efficiency. Therefore, the agencies decided to not include electric oil pump technology. 
(iii) Mild Hybrid 
Mild hybrid systems offer idle-stop 
functionality and a limited level of 
regenerative braking and power assist. These systems replace the conventional alternator with a belt or crank driven starter/alternator and may add high voltage electrical accessories (which may include electric power steering and an auxiliary automatic transmission pump). The limited electrical requirements of these systems allow the use of lead-acid batteries or supercapacitors for energy storage, or the use of a small lithium-ion battery pack. 
(iv) Strong Hybrid 
A hybrid vehicle is a vehicle that 
combines two significant sources of 
propulsion energy, where one uses a consumable fuel (like gasoline), and one is rechargeable (during operation, or by another energy source). Hybrid technology is well established in the U.S. light-duty market and more manufacturers are adding hybrid models to their lineups. Hybrids reduce fuel consumption through three major mechanisms: 
•The internal combustion engine can 
be optimized (through downsizing, modifying the operating cycle, or other control techniques) to operate at or near its most efficient point more of the time. Power loss from engine downsizing can be mitigated by employing power assist from the secondary power source. 
•A significant amount of the energy 
normally lost as heat while braking can be captured and stored in the energy storage system for later use. 
•The engine is turned off when it is 
not needed, such as when the vehicle is coasting or when stopped. 
Hybrid vehicles utilize some 
combination of the three above mechanisms to reduce fuel consumption and CO
2emissions. The effectiveness of 
fuel consumption and CO 2reduction depends on the utilization of the above mechanisms and how aggressively they are pursued. One area where this variation is particularly prevalent is in the choice of engine size and its effect on balancing fuel economy and performance. Some manufacturers choose not to downsize the engine when applying hybrid technologies. In these cases, overall performance (acceleration) is typically improved beyond the conventional engine. However, fuel efficiency improves less than if the engine was downsized to maintain the same performance as the conventional version. The non-downsizing approach is used for vehicles like trucks where towing and/or hauling are an integral part of their performance requirements. In these cases, if the engine is downsized, the battery can be quickly drained during a long hill climb with a heavy load, leaving only a downsized engine to carry the entire load. Because towing capability is currently a heavily- marketed truck attribute, manufacturers are hesitant to offer a truck with a downsized engine, which can lead to a significantly diminished towing performance when the battery state of charge level is low, and therefore engines are traditionally not downsized for these vehicles. In assessing the cost of this technology, the agencies consequently assumed the cost of a full size engine. 
Strong Hybrid technology utilizes an 
axial electric motor connected to the transmission input shaft and connected to the engine crankshaft through a clutch. The axial motor is a motor/ generator that can provide sufficient torque for launch assist, all electric operation, and the ability to recover significant levels of braking energy. 
(e) Vehicle Technologies 
(i) Mass Reduction 
Mass reduction is a technology that 
can be used in a manufacturer’s strategy 
to meet the Heavy Duty Greenhouse Gas Phase 2 standards. Vehicle mass reduction (also referred to as ‘‘down- weighting’’ or ‘‘light-weighting’’), decreases fuel consumption and GHG emissions by reducing the energy demand needed to overcome inertia forces, and rolling resistance. Automotive companies have worked with mass reduction technologies for many years and a lot of these technologies have been used in production vehicles. The weight savings achieved by adopting mass reduction technologies offset weight gains due to increased vehicle size, larger powertrains, and increased feature content (sound insulation, 
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481Committee on the Assessment of Technologies 
for Improving Light-Duty Vehicle Fuel Economy; 
National Research Council, ‘‘Assessment of Fuel Economy Technologies for Light-Duty Vehicles,’’ 2011. Available at http://www.nap.edu/catalog.php?record_ id=12924 (last accessed Jun 27, 
2012). 
482SAE World Congress, ‘‘Focus B-pillar ‘tailor 
rolled’ to 8 different thicknesses,’’ Feb. 24, 2010. Available at http://www.sae.org/mags/AEI/7695 (last accessed Jun. 10, 2012). 483‘‘Mass Reduction and Cost Analysis—Light- 
Duty Pickup Trucks Model Years 2020–2025,’’ FEV, North America, Inc., April 2015, Document no. EPA–420–R–15–006. 
484‘‘Mass Reduction and Cost Analysis Heavy 
Duty Pickup Truck and Light Commercial Vans,’’ 2016, EPA–420–D–16–003. entertainment systems, improved 
climate control, panoramic roof, etc.). Sometimes mass reduction has been used to increase vehicle towing and payload capabilities. 
Manufacturers employ a systematic 
approach to mass reduction, where the net mass reduction is the addition of a direct component or system mass reduction, also referred to as primary mass reduction, plus the additional mass reduction taken from indirect ancillary systems and components, also referred to as secondary mass reduction or mass compounding. There are more secondary mass reductions achievable for light-duty vehicles compared to heavy-duty vehicles, which are limited due to the higher towing and payload requirements for these vehicles. 
Mass reduction can be achieved 
through a number of approaches, even while maintaining other vehicle functionalities. As summarized by NAS in its 2011 light duty vehicle report,
481 
there are two key strategies for primary mass reduction: (1) Changing the design to use less material; (2) substituting lighter materials for heavier materials. 
The first key strategy of using less 
material compared to the baseline component can be achieved by optimizing the design and structure of vehicle components, systems and vehicle structure. Vehicle manufacturers have long used these continually- improving CAE tools to optimize vehicle designs. For example, the Future Steel Vehicle (FSV) project
482 
sponsored by WorldAutoSteel used three levels of optimization: Topology optimization, low fidelity 3G (Geometry Grade and Gauge) optimization, and subsystem optimization, to achieve 30 percent mass reduction in the body structure of a vehicle with a mild steel unibody structure. Using less material can also be achieved through improving the manufacturing process, such as by using improved joining technologies and parts consolidation. This method is often used in combination with applying new materials. 
The second key strategy to reduce 
mass of an assembly or component involves the substitution of lower density and/or higher strength materials. Material substitution includes 
replacing materials, such as mild steel, with higher-strength and advanced 
steels, aluminum, magnesium, and composite materials. In practice, material substitution tends to be quite specific to the manufacturer and situation. Some materials work better than others for particular vehicle components, and a manufacturer may invest more heavily in adjusting to a particular type of advanced material, thus complicating its ability to consider others. The agencies recognize that like any type of mass reduction, material substitution has to be conducted not only with consideration to maintaining equivalent component strength, but also to maintaining all the other attributes of that component, system or vehicle, such as crashworthiness, durability, and noise, vibration and harshness (NVH). 
If vehicle mass is reduced sufficiently 
through application of the two primary strategies of using less material and material substitution described above, secondary mass reduction options may 
become available. Secondary mass reduction is enabled when the load requirements of a component are reduced as a result of primary mass reduction. If the primary mass reduction reaches a sufficient level, a manufacturer may use a smaller, lighter, and potentially more efficient powertrain while maintaining vehicle acceleration performance. If a powertrain is downsized, a portion of the mass reduction may be attributed to the reduced torque requirement which results from the lower vehicle mass. The lower torque requirement enables a reduction in engine displacement, changes to transmission torque converter and gear ratios, and changes to final drive gear ratio. The reduced powertrain torque enables the downsizing and/or mass reduction of powertrain components and accompanying reduced rotating mass (e.g., for transmission, driveshafts/ halfshafts, wheels, and tires) without sacrificing powertrain durability. Likewise, the combined mass reductions of the engine, drivetrain, and body in turn reduce stresses on the suspension components, steering components, wheels, tires, and brakes, which can allow further reductions in the mass of these subsystems. Reducing the un- sprung masses such as the brakes, control arms, wheels, and tires further reduce stresses in the suspension mounting points, which will allow for further optimization and potential mass reduction. However, pickup trucks have towing and hauling requirements which must be taken into account when determining the amount of secondary mass reduction that is possible and so 
it is less than that of passenger cars. 
In 2015, EPA completed a multi-year 
study with FEV North America, Inc. on the lightweighting of a light-duty pickup truck, a 2011 GMC Silverado, titled ‘‘Mass Reduction and Cost Analysis— Light-Duty Pickup Trucks Model Years 2020–2025.’’
483Results contain a cost 
curve for various mass reduction percentages with the main solution being evaluated for a 20.8 percent (510 kg/1122 lb.) mass reduction resulting in an increased direct incremental manufacturing cost of $2228. In addition, the report outlines the compounding effect that occurs in a vehicle with performance requirements including hauling and towing. Secondary mass evaluation was performed on a component level based on an overall 20 percent vehicle mass reduction. Results revealed 84 kg of the 510 kg, or 20 percent of the overall mass reduction, were from secondary mass reduction. Information on this study is summarized in SAE paper 2015–01– 0559. NHTSA has also sponsored an on- going pickup truck lightweighting project. This project uses a more recent baseline vehicle, a MY 2014 GMC Silverado, and the project will be finished in 2016. Both projects will be utilized for the light-duty GHG and CAFE Midterm Evaluation mass reduction baseline characterization and may be used to update assumptions of mass reduction for HD pickups and vans for the final Phase 2 rulemaking. 
In order to determine if technologies 
identified on light duty trucks are applicable to heavy-duty pickups, EPA contracted with FEV North America, Inc. to perform a scaling study in order to evaluate whether the technologies identified for the light-duty truck would be applicable for a heavy-duty pickup truck. In this study a 2013MY Silverado 2500, a 2007 Mercedes Sprinter and a 2010 Renault Master
484were analyzed. 
A 2013MY Silverado 2500 was purchased and torn down. The mass reduction results were 18.9 percent mass reduction at a cost of $2,372 and focused on aluminum intensive with AHSS frame. The Mercedes Sprinter and Renault Master analyses were performed based on information from the A2Mac1 database. The results were 18.15 percent mass reduction at a cost add of $2,293 for the Mercedes Sprinter 
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485http://www.techtimes.com/articles/87961/ 
20150925/ford-s-2017-f-250-super-duty-with-an-
aluminum-body-is-the-toughest-smartest-and-most- capable-super-duty-ever.htm, September 25, 2015. 
486https://www.ford.com/trucks/superduty/ 
2017/. 
487‘‘2008/9 Blueprint for Sustainability,’’ Ford 
Motor Company. Available at: http://www.ford.com/go/sustainability (last accessed 
February 8, 2010). 
488‘‘2015 North American Light Vehicle 
Aluminum Content Study—Executive Summary,’’ 
June 2014, http://www.drivealuminum.org/research-resources/PDF/Research/2014/2014- ducker-report (last accessed February 26, 2015). 
489http://www.foxnews.com/leisure/2014/09/30/
ford-confirms-increased-aluminum-use-on-next- gen-super-duty-pickups/ . 490See RIA Chapter 2.3 for more detailed 
technology descriptions. 491U.S. Environmental Protection Agency, ‘‘Draft 
Report—Light-Duty Technology Cost Analysis Pilot Study,’’ Contract No. EP–C–07–069, Work Assignment 1–3, September 3, 2009. and 18.55 percent mass reduction at a 
cost add of $2,293 for the Master. 
In September 2015, Ford announced 
that its MY 2017 F-Series Super duty pickup (F250) would be manufactured with an aluminum body and overall the truck will be 350 lbs. lighter (5 percent– 6 percent) than the current generation truck with steel.
485 486 This is less 
overall mass reduction than the resultant lightweighting effort on the MY 2015 F–150, which achieved up to 750 lb. decrease in curb weight (12 percent–13 percent) per vehicle.
487 
Strategies were employed by Ford in the F250 to ‘‘improve the productivity of the Super Duty.’’ In addition, Ford added several safety systems (and consequent mass) including cameras, lane departure warning, brake assist, etc. More details on the F250 will be known once it is released; however, a review of the F150 vehicle aluminum intensive design shows that it has an aluminum cab structure, body panels, and suspension components, as well as a high strength steel frame and a smaller, lighter and more efficient engine. The Executive Summary to Ducker Worldwide’s 2014 report
488 
states that the MY 2015 F–150 contains 1080 lbs. of aluminum with at least half being aluminum sheet and extrusions for body and closures. Ford’s engine range for its light duty truck fleet includes a 2.7L EcoBoost V–6. The integrated loop, between Ford and the aluminum sheet suppliers, of aluminum manufacturing scrap and new aluminum sheet is integral to making aluminum a feasible lightweighting technology option for Ford. It is also possible that the strategy of aluminum body panels will be applied to the heavy duty F–350 version when it is redesigned.
489 
The RIA for this rulemaking shows 
that 10 percent or less mass reduction is part of the projected strategy for compliance for HD pickups and vans. The cost and effectiveness assumptions for mass reduction technology are described in the RIA. (ii) Low Rolling Resistance Tires 
Tire rolling resistance is the frictional 
loss associated mainly with the energy 
dissipated in the deformation of the tires under load and thus influences fuel efficiency and CO
2emissions. Other tire 
design characteristics (e.g., materials, construction, and tread design) influence durability, traction (both wet and dry grip), vehicle handling, and ride comfort in addition to rolling resistance. A typical LRR tire’s attributes will include: Increased tire inflation pressure, material changes, and tire construction with less hysteresis, geometry changes (e.g., reduced aspect ratios), and reduction in sidewall and tread deflection. These changes will generally be accompanied with additional changes to suspension tuning and/or suspension design. 
(iii) Aerodynamic Drag Reduction 
Many factors affect a vehicle’s 
aerodynamic drag and the resulting 
power required to move it through the air. While these factors change with air density and the square and cube of vehicle speed, respectively, the overall drag effect is determined by the product of its frontal area and drag coefficient, Cd. Reductions in these quantities can therefore reduce fuel consumption and CO
2emissions. Although frontal areas 
tend to be relatively similar within a vehicle class (mostly due to market- competitive size requirements), significant variations in drag coefficient can be observed. Significant changes to a vehicle’s aerodynamic performance may need to be implemented during a redesign (e.g., changes in vehicle shape). However, shorter-term aerodynamic reductions, with a somewhat lower effectiveness, may be achieved through the use of revised exterior components (typically at a model refresh in mid- cycle) and add-on devices that currently being applied. The latter list will include revised front and rear fascias, modified front air dams and rear valances, addition of rear deck lips and underbody panels, and lower aerodynamic drag exterior mirrors. 
(f) Air Conditioning Technologies 
These technologies include improved 
hoses, connectors and seats for leakage 
control. They also include improved compressors, expansion valves, heat exchangers and the control of these components for the purposes of improving tailpipe CO
2emissions as a 
result of A/C use.490 (5) How did the agencies determine the 
costs and effectiveness of each of these technologies? 
Building on the technical analysis 
underlying the 2017–2025 MY light- duty vehicle rule, the 2014–2018 MY heavy-duty vehicle rule, and the 2015 NHTSA Technology Study, the agencies took a fresh look at technology cost and effectiveness values for purposes of this rule. For costs, the agencies reconsidered both the direct (or ‘‘piece’’) costs and indirect costs of individual components of technologies. For the direct costs, the agencies followed a bill of materials (BOM) approach employed by the agencies in the light-duty rule as well as referencing costs from the 2014– 2018 MY heavy-duty vehicle rule and a new cost survey performed by Tetra Tech in 2014. 
For two technologies, stoichiometric 
gasoline direct injection (SGDI) and turbocharging with engine downsizing, the agencies relied to the extent possible on the available tear-down data and 
scaling methodologies used in EPA’s ongoing study with FEV, Incorporated. This study consists of complete system tear-down to evaluate technologies down to the nuts and bolts to arrive at very detailed estimates of the costs associated with manufacturing them.
491 
For the other technologies, 
considering all sources of information and using the BOM approach, the agencies worked together intensively to determine component costs for each of the technologies and build up the costs accordingly. Where estimates differ between sources, we have used engineering judgment to arrive at what we believe to be the best cost estimate available today, and explained the basis for that exercise of judgment. 
Once costs were determined, they 
were adjusted to ensure that they were all expressed in 2012 dollars, and indirect costs were accounted for using a methodology consistent with the new ICM approach developed by EPA and used in the Phase 1 rule, and the 2012– 2016 and 2017–2025 light-duty rules. NHTSA and EPA also reconsidered how costs should be adjusted by modifying or scaling content assumptions to account for differences across the range of vehicle sizes and functional requirements, and adjusted the associated material cost impacts to account for the revised content. We present the individual technology costs used in this analysis in Chapter 2.11 of the RIA. 
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Regarding estimates for technology 
effectiveness, the agencies used the 
estimates from the 2014 Southwest Research Institute study as a baseline, which was designed specifically to inform this rulemaking. In addition, the agencies used 2017–2025 light-duty rule as a reference, and adjusted these estimates as appropriate, taking into account the unique requirement of the heavy-duty test cycles to test at curb weight plus half payload versus the light-duty requirement of curb plus 300 lbs. The adjustments were made on an individual technology basis by assessing the specific impact of the added load on each technology when compared to the use of the technology on a light-duty vehicle. The agencies also considered other sources such as the 2010 NAS Report, recent compliance data, and confidential manufacturer estimates of technology effectiveness. The agencies reviewed effectiveness information from the multiple sources for each technology and ensured that such effectiveness estimates were based on technology hardware consistent with the BOM components used to estimate costs. Together, the agencies compared the multiple estimates and assessed their validity, taking care to ensure that common BOM definitions and other vehicle attributes such as performance and drivability were taken into account. 
The agencies note that the 
effectiveness values estimated for the technologies may represent average 
values applied to the baseline fleet described earlier, and do not reflect the potentially limitless spectrum of possible values that could result from adding the technology to different vehicles. For example, while the agencies have estimated an effectiveness 
of 0.5 percent for low friction lubricants, each vehicle could have a unique effectiveness estimate depending on the baseline vehicle’s oil viscosity rating. Similarly, the reduction in rolling resistance (and thus the improvement in fuel efficiency and the reduction in CO
2 
emissions) due to the application of LRR tires depends not only on the unique characteristics of the tires originally on the vehicle, but on the unique characteristics of the tires being applied, characteristics which must be balanced between fuel efficiency, safety, and performance. Aerodynamic drag reduction is much the same—it can improve fuel efficiency and reduce CO
2 
emissions, but it is also highly dependent on vehicle-specific functional objectives. For purposes of this final rule, the agencies believe that employing average values for technology effectiveness estimates is an appropriate way of recognizing the potential variation in the specific benefits that individual manufacturers (and individual vehicles) might obtain from adding a fuel-saving technology. 
The assessment of the technology 
effectiveness and costs was determined from a combination of sources. First an assessment was performed by SwRI under contract with the agencies to determine the effectiveness and costs on several technologies that were generally not considered in the Phase 1 GHG rule time frame. Some of the technologies 
were common with the light-duty assessment but the effectiveness and costs of individual technologies were appropriately adjusted to match the expected effectiveness and costs when implemented in a heavy-duty application. Finally, the agencies 
performed extensive outreach to suppliers of engine, transmission and vehicle technologies applicable to heavy-duty applications to get industry input on cost and effectiveness of potential GHG and fuel consumption reducing technologies. The agencies did not receive comments disputing the expected technology effectiveness values or costs developed with input from industry. 
To achieve the levels of the Phase 2 
standards for gasoline and diesel powered heavy-duty vehicles, a combination of the technologies 
previously discussed will be required respective to unique gasoline and diesel technologies and their challenges. Although some of the technologies may already be implemented in a portion of heavy-duty vehicles, none of the technologies discussed are considered ubiquitous in the heavy-duty fleet. Also, as will be expected, the available test data show that some vehicle models will not need the full complement of available technologies to achieve these standards. Furthermore, many technologies can be further improved (e.g., aerodynamic improvements) from today’s best levels, and so allow for compliance without needing to apply a technology that a manufacturer might deem less desirable. 
Technology costs for HD pickups and 
vans are shown in Table VI–4. These costs reflect direct and indirect costs to the vehicle manufacturer for the 2021 model year. See Chapter 2.11. of the RIA for a more complete description of the basis of these costs. 
TABLE VI–4—T ECHNOLOGY COSTS FOR HD P ICKUPS & VANSINCLUSIVE OF INDIRECT COSTMARKUPS FOR MY 2021 
[2012$] 
Technology Gasoline Diesel 
Engine changes to accommodate low friction lubes ............................................................................... ................ 6 6 
Engine friction reduction—level 1 .............................................................................................. .............................. 116 116 
Engine friction reduction—level 2 .............................................................................................. .............................. 254 254 
Dual cam phasing ............................................................................................................... ..................................... 183 183 
Cylinder deactivation .......................................................................................................... ..................................... 196 N/A 
Stoichiometric gasoline direct injection ....................................................................................... ............................ 451 N/A 
Turbo improvements ............................................................................................................. ................................... N/A 16 
Cooled EGR ..................................................................................................................... ........................................ 373 373 
Turbocharging & downsizinga............................................................................................................................... .. 671 N/A 
‘‘Right-sized’’ diesel from larger diesel ...................................................................................... .............................. N/A 0 
8s automatic transmission (increment to 6s automatic transmission) ............................................................. ....... 457 457 
Improved accessories—level 1 ................................................................................................... ............................. 82 82 
Improved accessories—level 2 ................................................................................................... ............................. 132 132 
Low rolling resistance tires—level 1 ........................................................................................... ............................. 10 10 
Passive aerodynamic improvements (aero 1) ...................................................................................... ................... 51 51 
Passive plus Active aerodynamic improvements (aero 2) .......................................................................... ............ 230 230 
Electric (or electro/hydraulic) power steering ................................................................................. ......................... 151 151 
Mass reduction (10% on a 6500 lb vehicle) ...................................................................................... ...................... 318 318 
Driveline friction reduction ................................................................................................... .................................... 139 139 
Stop-start (no regenerative braking) ........................................................................................... ............................. 539 539 
Mild HEV ....................................................................................................................... ........................................... 2730 2730 
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TABLE VI–4—T ECHNOLOGY COSTS FOR HD P ICKUPS & VANSINCLUSIVE OF INDIRECT COSTMARKUPS FOR MY 2021— 
Continued 
[2012$] 
Technology Gasoline Diesel 
Strong HEV, without inclusion of any engine changes ............................................................................ ............... 6779 6779 
Note: 
aCost to downsize from a V8 OHC to a V6 OHC engine with twin turbos. 
As explained above, the CAFE model 
works by adding technologies in an 
incremental fashion to each particular vehicle in a manufacturer’s fleet until that fleet complies with the imposed standards. It does this by following a predefined set of decision trees whereby the particular vehicle is placed on the 
appropriate decision tree and it follows the predefined progression of technology available on that tree. At 
each step along the tree, a decision is made regarding the cost of a given technology relative to what already exists on the vehicle along with the fuel consumption improvement it provides relative to the fuel consumption at the current location on the tree, prior to 
deciding whether to take that next step on the tree or remain in the current location. Because the model works in 
this way, the input files must be structured to provide costs and effectiveness values for each technology relative to whatever technologies have been added in earlier steps along the tree. Table VI–5 presents the cost and effectiveness values used in the CAFE model input files. 
TABLE VI–5—CAFE M ODEL INPUT VALUES FOR COST& EFFECTIVENESS FOR GIVEN TECHNOLOGIESa 
Technology FC savings 
(%) Incremental cost (2012$)abc 
2021 2025 2027 
Improved Lubricants and Engine Friction Reduction ...................................... 1.60 24 24 23 
Coupled Cam Phasing (SOHC) ....................................................................... 3.82 48 43 39 
Dual Variable Valve Lift (SOHC) ..................................................................... 2.47 42 37 34 
Cylinder Deactivation (SOHC) ......................................................................... 3.70 34 30 27 
Intake Cam Phasing (DOHC) .......................................................................... 0.00 48 43 39 
Dual Cam Phasing (DOHC) ............................................................................. 3.82 46 40 37 
Dual Variable Valve Lift (DOHC) ..................................................................... 2.47 42 37 34 
Cylinder Deactivation (DOHC) ......................................................................... 3.70 34 30 27 
Stoichiometric Gasoline Direct Injection (OHC) .............................................. 0.50 71 61 56 
Cylinder Deactivation (OHV) ............................................................................ 3.90 216 188 172 
Variable Valve Actuation (OHV) ...................................................................... 6.10 54 47 43 
Stoichiometric Gasoline Direct Injection (OHV) ............................................... 0.50 71 61 56 
Engine Turbocharging and Downsizing 
Small Gasoline Engines ........................................................................... 8.00 518 441 407 
Medium Gasoline Engines ....................................................................... 8.00 ¥12 ¥62 ¥44 
Large Gasoline Engines ........................................................................... 8.00 623 522 456 
Cooled Exhaust Gas Recirculation .................................................................. 3.04 382 332 303 
Cylinder Deactivation on Turbo/downsized Eng .............................................. 1.70 33 29 26 
Lean-Burn Gasoline Direct Injection ................................................................ 4.30 1,758 1,485 1,282 
Improved Diesel Engine Turbocharging .......................................................... 2.51 22 19 18 
Engine Friction & Parasitic Reduction 
Small Diesel Engines ................................................................................ 3.50 269 253 213 
Medium Diesel Engines ............................................................................ 3.50 345 325 273 
Large Diesel Engines ............................................................................... 3.50 421 397 334 
Downsizing of Diesel Engines (V6 to I–4) ....................................................... 11.10 0 0 0 
8-Speed Automatic Transmissiond.................................................................. 5.00 482 419 382 
Electric Power Steering ................................................................................... 1.00 160 144 130 
Improved Accessories (Level 1) ...................................................................... 0.93 93 83 75 
Improved Accessories (Level 2) ...................................................................... 0.93 57 54 46 
Stop-Start System ............................................................................................ 1.10 612 517 446 
Integrated Starter-Generator ........................................................................... 3.20 1,040 969 760 
Strong Hybrid Electric Vehicle ......................................................................... 17.20 3,038 2,393 2,133 
Mass Reduction (5%) ...................................................................................... 1.50 0.28 0.24 0.21 
Mass Reduction (additional 5%) ...................................................................... 1.50 0.87 0.75 0.66 
Reduced Rolling Resistance Tires .................................................................. 1.10 10 9 9 
Low-Drag Brakes ............................................................................................. 0.40 106 102 102 
Driveline Friction Reduction ............................................................................. 0.50 153 137 124 
Aerodynamic Improvements (10%) ................................................................. 0.70 58 52 47 
Aerodynamic Improvements (add’l 10%) ......................................................... 0.70 193 182 153 
Notes: 
aValues for other model years available in CAFE model input files available at NHTSA Web site. 
bFor mass reduction, cost reported on mass basis (per pound of curb weight reduction). 
cThe model output has been adjusted to 2013$. 
d8-speed automatic transmission costs include costs for high efficiency gearbox and aggressive shift logic whereas those costs were kept sep-
arate in prior analyses. 
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In addition to the base technology 
cost and effectiveness inputs described 
above, the CAFE model accommodates inputs to adjust accumulated effectiveness under circumstances when combining multiple technologies could result in underestimation or overestimation of total incremental effectiveness relative to an ‘‘unevolved’’ baseline vehicle. These so-called synergy factors may be positive, where the combination of the technologies results in greater improvement than the additive improvement of each technology, or negative, where the combination of the technologies is lower than the additive improvement of each technology. The synergy factors used in the NPRM and Method B of the FRM are 
described in Table VI–6 Method A of the FRM uses synergies derived from a simulation project NHTSA undertook with Autnomie Argonne National Lab. A description of these changes is given in Section D.(8). 
TABLE VI–6—T ECHNOLOGY PAIREFFECTIVENESS SYNERGY FACTORS FOR HD P ICKUPS AND VANS 
Technology pair Adjustment 
(%) Technology pair Adjustment 
(%) 
8SPD/CCPS ................................................................. ¥4.60 IATC/CCPS ................................................................... ¥1.30 
8SPD/DEACO ............................................................... ¥4.60 IATC/DEACO ................................................................ ¥1.30 
8SPD/ICP ..................................................................... ¥4.60 IATC/ICP ....................................................................... ¥1.30 
8SPD/TRBDS1 ............................................................. 4.60 IATC/TRBDS1 ....................................... ....................... 1.30 
AERO2/SHEV1 ............................................................. 1.40 MR1/CCPS .......................................... ......................... 0.40 
CCPS/IACC1 ................................................................ ¥0.40 MR1/DCP ...................................................................... 0.40 
CCPS/IACC2 ................................................................ ¥0.60 MR1/VVA ...................................................................... 0.40 
DCP/IACC1 ................................................................... ¥0.40 MR2/ROLL1 .................................................................. ¥0.10 
DCP/IACC2 ................................................................... ¥0.60 MR2/SHEV1 ................................................................. ¥0.40 
DEACD/IATC ................................................................ ¥0.10 NAUTO/CCPS .............................................................. ¥1.70 
DEACO/IACC2 ............................................................. ¥0.80 NAUTO/DEACO ........................................................... ¥1.70 
DEACO/MHEV .............................................................. ¥0.70 NAUTO/ICP .................................................................. ¥1.70 
DEACS/IATC ................................................................ ¥0.10 NAUTO/SAX ................................................................. ¥0.40 
DTURB/IATC ................................................................ 1.00 NAUTO/TRBDS1 .................................... ...................... 1.70 
DTURB/MHEV .............................................................. ¥0.60 ROLL1/AERO1 ............................................................. 0.10 
DTURB/SHEV1 ............................................................. ¥1.00 ROLL1/SHEV1 .............................................................. 1.10 
DVVLD/8SPD ............................................................... ¥0.60 ROLL2/AERO2 ............................................................. 0.20 
DVVLD/IACC2 .............................................................. ¥0.80 SHFTOPT/MHEV .......................................................... ¥0.30 
DVVLD/IATC ................................................................. ¥0.60 TRBDS1/MHEV ............................................................ 0.80 
DVVLD/MHEV .............................................................. ¥0.70 TRBDS1/SHEV1 ........................................................... ¥3.30 
DVVLS/8SPD ................................................................ ¥0.60 TRBDS1/VVA ............................................................... ¥8.00 
DVVLS/IACC2 .............................................................. ¥0.80 TRBDS2/EPS ............................................................... ¥0.30 
DVVLS/IATC ................................................................. ¥0.50 TRBDS2/IACC2 ............................................................ ¥0.30 
DVVLS/MHEV ............................................................... ¥0.70 TRBDS2/NAUTO .......................................................... ¥0.50 
....................................................................................... ........................ VVA/IACC1 ................................................................... ¥0.40 
....................................................................................... ........................ VVA/IACC2 ................................................................... ¥0.60 
....................................................................................... ........................ VVA/IATC ..................................................................... ¥0.60 
The CAFE model also accommodates 
inputs to adjust accumulated 
incremental costs under circumstances when the application sequence could result in underestimation or overestimation of total incremental costs relative to an ‘‘unevolved’’ baseline vehicle. For today’s analysis, the agencies have applied one such adjustment, increasing the cost of medium-sized gasoline engines by $513 in cases where turbocharging and engine downsizing is applied with variable valve actuation. 
The analysis performed using Method 
A also applied cost inputs to address some costs encompassed neither by the agencies’ estimates of the direct cost to apply these technologies, nor by the agencies’ methods for ‘‘marking up’’ these costs to arrive at increases in the new vehicle purchase costs. To account for the additional costs that could be incurred if a technology is applied and then quickly replaced, the CAFE model accommodates inputs specifying a ‘‘stranded capital cost’’ specific to each technology. For this analysis, the model 
was run with inputs to apply about $78 of additional cost (per engine) if 
gasoline engine turbocharging and downsizing (separately for each ‘‘level’’ considered) is applied and then immediately replaced, declining steadily to zero by the tenth model year following initial application of the technology. The model also accommodates inputs specifying any additional changes owners might incur in maintenance and post-warranty repair costs. For this analysis, the model was run with inputs indicating that vehicles equipped with less rolling- resistant tires could incur additional tire replacement costs equivalent to $21–$23 (depending on model year) in additional costs to purchase the new vehicle. The agencies did not, however, include inputs specifying any potential changes repair costs that might accompany application of any of the above technologies. A sensitivity analysis using Method A, discussed below, includes a case in which repair costs are estimated using factors consistent with 
those underlying the indirect cost multipliers used to markup direct costs for the agencies’ central analysis. 
(6) Regulatory Alternatives Considered 
by the Agencies 
As discussed above, the model 
considers regulatory alternatives. The results of regulatory alternatives are considered relative to a ‘‘no action’’ alternative where existing standards persist, but no further regulatory action is taken (in this case the MY 2018 standards from Phase I are the last regulatory action taken). The agencies also considered four regulatory alternatives. The preferred alternative with a standard that increases 2.5 percent in stringency annually for MY’s 2021–2027, and three others with annual increases in stringency of: 2.0 percent, 3.5 percent, and 4.0 percent for MY’s 2021–2025. For each of the ‘‘action alternatives’’ (i.e., those 
involving stringency increases beyond the no-action alternative), the annual 
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stringency increases are applied as 
follows: An annual stringency increase of r is applied by multiplying the model 
year 2020 target functions (identical to those applicable to model year 2018) by 1¥r to define the model year 2021 
target functions, multiplying the model year 2021 target functions by 1¥r to 
define the model year 2022 target functions, continuing through 2025 for all alternatives except for the preferred Alternative 3 which extends through 2027. In summary, the agencies have considered the following five regulatory alternatives in the CAFE model. 
TABLE VI–7—C ONSIDERED REGULATORY ALTERNATIVES  
Regulatory alternative Annual stringency increase 
2019–2020 2021–2025 2026–2027 
1: No Action ................................... None ............................................. None ........................... .................. None. 
2: 2.0%/y ........................................ None ............................................. 2.0% ......................... ..................... None. 
3: 2.5%/y ........................................ None ............................................. 2.5% ......................... ..................... 2.5% 
4: 3.5%/y ........................................ None ............................................. 3.5% ......................... ..................... None. 
5: 4.0%/y ........................................ None ............................................. 4.0% ......................... ..................... None. 
(7) NPRM Modifications of the Model 
The NPRM analysis (and the current 
analysis) reflect several changes made to the model since 2012, when NHTSA used the model to estimate the effects, costs, and benefits of final CAFE standards for light-duty vehicles produced during MYs 2017–2021, and augural standards for MYs 2022–2025. Some of these changes specifically enable analysis of potential fuel consumption standards (and, hence, CO
2emissions standards harmonized 
with fuel consumption standards) for heavy-duty pickups and vans; other changes implement more general improvements to the model. Key changes include the following: 
•Changes to accommodate standards 
for heavy-duty pickups and vans, including attribute-based standards involving targets that vary with ‘‘work factor.’’ 
•Explicit calculation of test weight, 
taking into account test weight ‘‘bins’’ and differences in the definition of test weight for light-duty vehicles (curb weight plus 300 pound) and heavy-duty pickups and vans (average of GVWR and curb weight). 
•Procedures to estimate increases in 
payload when curb weight is reduced, increases in towing capacity if GVWR is reduced, and calculation procedures to correspondingly update calculated work factors. 
•Expansion of model inputs, 
procedures, and outputs to accommodate technologies not included in prior analyses. 
•Changes to the algorithm used to 
apply technologies, enabling more explicit accounting for shared vehicle platforms and adoption and ‘‘inheritance’’ of major engine changes. 
These changes are reflected in 
updated model documentation available at NHTSA’s Web site, the documentation also providing more information about the model’s purpose, scope, structure, design, inputs, 
operation, and outputs. The agencies invited but did not receive comments on the CAFE model used for the NPRM analysis and used in this final rule for the Method B analysis. 
(a) Product Cadence 
Past comments on the CAFE model 
have stressed the importance of product 
cadence—i.e., the development and 
periodic redesign and freshening of vehicles—in terms of involving technical, financial, and other practical constraints on applying new technologies, and NHTSA has steadily made changes to the model with a view toward accounting for these considerations. For example, early versions of the model added explicit ‘‘carrying forward’’ of applied technologies between model years, subsequent versions applied assumptions that most technologies would be applied when vehicles are freshened or redesigned, and more recent versions applied assumptions that manufacturers would sometimes apply technology earlier than ‘‘necessary’’ in order to facilitate compliance with standards in ensuing model years. Thus, for example, if a manufacturer is expected to redesign many of its products in model years 2018 and 2023, and the standard’s stringency increases significantly in model year 2021, the CAFE model will estimate the potential that the manufacturer will add more technology than necessary for compliance in MY 2018, in order to carry those product changes forward through the next redesign and contribute to compliance with the MY 2021 standard. 
The model also accommodates 
estimates of overall limits (expressed as ‘‘phase-in caps’’ in model inputs) on the rates at which manufacturers’ may practicably add technology to their 
respective fleets. So, for example, even if a manufacturer is expected to redesign half of its production in MY 2016, if the 
manufacturer is not already producing any strong hybrid electric vehicles (SHEVs), a phase-in cap can be specified in order to assume that manufacturer will stop applying SHEVs in MY 2016 once it has done so to at least 3 percent of its production in that model year. 
After the light-duty rulemaking 
analysis accompanying the 2012 final rule regarding post-2016 CAFE standards and related GHG emissions standards, NHTSA staff began work on CAFE model changes expected to better reflect additional considerations involved with product planning and cadence. These changes, summarized below, interact with preexisting model characteristics discussed above. 
(b) Platforms and Technology 
The term ‘‘platform’’ is used loosely 
in industry, but generally refers to a 
common structure shared by a group of vehicle variants. The degree of commonality varies, with some platform variants exhibiting traditional ‘‘badge engineering’’ where two products are differentiated by little more than insignias, while other platforms be used to produce a broad suite of vehicles that bear little outer resemblance to one another. 
Given the degree of commonality 
between variants of a single platform, manufacturers do not have complete freedom to apply technology to a vehicle: while some technologies (e.g. low rolling resistance tires) are very nearly ‘‘bolt-on’’ technologies, others involve substantial changes to the structure and design of the vehicle, and 
therefore necessarily are constant between vehicles that share a common platform. NHTSA staff has, therefore, modified the CAFE model such that all mass reduction and aero technologies are forced to be constant between variants of a platform. The agencies requested but did not receive comment on the suitability of this viewpoint, and 
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which technologies can deviate from 
one platform variant to another. 
Within the analysis fleet, each vehicle 
is associated with a specific platform. As the CAFE model applies technology, it first defines a platform ‘‘leader’’ as the vehicle variant of a platform with the highest technology utilization vehicle of mass reduction and aerodynamic technologies. As the vehicle applies technologies, it effectively harmonizes to the highest common denominator of the platform. If there is a tie, the CAFE model begins applying aerodynamic and mass reduction technology to the vehicle with the lowest average sales across all available model years. If there remains a tie, the model begins by choosing the vehicle with the highest average MSRP across all available model years. The model follows this formulation due to previous market trends suggesting that many technologies begin deployment at the high-end, low-volume end of the market as manufacturers build their confidence and capability in a technology, and later expand the technology across more mainstream product lines. 
In the HD pickup and van market, 
there is a relatively small amount of diversity in platforms produced by manufacturers: Typically 1–2 truck platforms and 1–2 van platforms. However, accounting for platforms will take on greater significance in future analyses involving the light-duty fleet. The agency requested but did not receive comments on the general use of 
platforms within CAFE rulemaking. 
(c) Engine and Transmission Inheritance 
In practice, manufacturers are limited 
in the number of engines and 
transmissions that they produce. Typically a manufacturer produces a number of engines—perhaps six or eight engines for a large manufacturer—and tunes them for slight variants in output for a variety of car and truck applications. Manufacturers limit complexity in their engine portfolio for much the same reason as they limit complexity in vehicle variants: They face engineering manpower limitations, and supplier, production and service costs that scale with the number of parts produced. 
In previous usage of the CAFE model, 
engines and transmissions in individual models were allowed relative freedom in technology application, potentially leading to solutions that would, if followed, involve unaccounted-for costs associated with increased complexity in the product portfolio. The lack of a constraint in this area allowed the model to apply different levels of technology to the engine in each vehicle at the time of redesign or refresh, 
independent of what was done to other vehicles using a previously identical engine. 
In the current version of the CAFE 
model, engines and transmissions that are shared between vehicles must apply the same levels of technology in all technologies dictated by engine or transmission inheritance. This forced adoption is referred to as ‘‘engine inheritance’’ in the model documentation. 
As with platform-shared technologies, 
the model first chooses an ‘‘engine leader’’ among vehicles sharing the same engine. The leader is selected first by the vehicle with the lowest average sales across all available model years. If there is a tie, the vehicle with the highest average MSRP across model years is chosen. The model applies the same logic with respect to the application of transmission changes. As with platforms, this is driven by the concept that vehicle manufacturers typically deploy new technologies in small numbers prior to deploying widely across their product lines. 
(d) Interactions Between Regulatory 
Classes 
Like earlier versions, the current 
CAFE model provides for integrated analysis spanning different regulatory classes, accounting both for standards that apply separately to different classes and for interactions between regulatory classes. Light vehicle CAFE standards are specified separately for passenger cars and light trucks. However, there is considerable sharing between these two 
regulatory classes. Some specific engines and transmissions are used in both passenger cars and light trucks, and some vehicle platforms span these regulatory classes. For example, some sport-utility vehicles are offered in 2WD versions classified as passenger cars and 4WD versions classified as light trucks. Integrated analysis of manufacturers’ passenger car and light truck fleets provides the ability to account for such sharing and reduce the likelihood of finding solutions that could involve impractical levels of complexity in manufacturers’ product lines. In addition, integrated analysis provides the ability to simulate the potential that manufactures could earn CAFE credits by over complying with one standard and use those credits toward compliance with the other standard (i.e., to simulate credit transfers between regulatory classes). 
HD pickups and vans are regulated 
separately from light-duty vehicles. While manufacturers cannot transfer credits between light-duty and MDHD classes, there is some sharing of 
engineering and technology between light-duty vehicles and HD pickups and vans. For example, some passenger vans with GVWR over 8,500 lbs. are classified as medium-duty passenger vehicles (MDPVs) and thus included in manufacturers’ light-duty truck fleets, while cargo vans sharing the same nameplate are classified as HD vans. 
(e) Phase-In Caps 
The CAFE model retains the ability to 
use phase-in caps (specified in model 
inputs) as proxies for a variety of practical restrictions on technology application. Unlike vehicle-specific restrictions related to redesign, refreshes or platforms/engines, phase-in caps constrain technology application at the vehicle manufacturer level. They are intended to reflect a manufacturer’s overall resource capacity available for implementing new technologies (such as engineering and development personnel and financial resources), thereby ensuring that resource capacity is accounted for in the modeling process. 
In previous CAFE rulemakings, 
redesign/refresh schedules and phase-in caps were the primary mechanisms to reflect an OEM’s limited pool of available resources during the rulemaking time frame and the years leading up to the rulemaking time frame, especially in years where many models may be scheduled for refresh or redesign. The newly-introduced representation platform-, engine-, and transmission-related considerations discussed above augment the model’s preexisting representation of redesign cycles and accommodation of phase-in caps. Considering these new constraints, inputs for today’s analysis de-emphasize reliance on phase-in caps. 
In the NPRM and Method B of the 
FRM application of the CAFE model, phase-in caps are used only for the most 
advanced technologies included in the analysis, i.e., SHEVs and lean-burn GDI 
engines, considering that these technologies are most likely to involve implementation costs and risks not otherwise accounted for in corresponding input estimates of technology cost. For these two technologies, the agencies have applied caps that begin at 3 percent (i.e., 3 
percent of the manufacturer’s production) in MY 2017, increase at 3 percent annually during the ensuing nine years (reaching 30 percent in the MY 2026), and subsequently increasing at 5 percent annually for four years (reaching 50 percent in MY 2030). Note that the agencies did not feel that lean- burn engines were feasible in the 
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timeframe of this rulemaking, so 
decided to reject any model runs where they were selected. (In any case, due to the cost ineffectiveness of this technology, it was never chosen). The agencies did not receive comments specifically on this approach for phase- in caps. The agencies received comments regarding the general feasibility of SHEVs in this market segment, with some commenters commenting that SHEVs are not feasible for HD pickups and vans. These comments are discussed in Section C.8. While the agencies have retained the above approach for SHEV phase-in caps, the agencies have conducted a sensitivity analysis setting the SHEV caps at zero, showing that the Phase 2 standards are feasible and appropriate without the use of SHEVs. This sensitivity analysis is described in Section E. 
For Method A of the NPRM the phase- 
in caps have been set to 100 percent, so that the model no longer relies on phase-in caps to limit the early-year application of advanced technologies. This changes is further described in the Method B of the FRM specific section below. 
(f) Impact of Vehicle Technology 
Application Requirements 
Compared to prior analyses of light- 
duty standards, these model changes, along with characteristics of the HD pickup and van fleet result in some 
changes in the broad characteristics of the model’s application of technology to manufacturers’ fleets. First, since the number of HD pickup and van platforms in a portfolio is typically small, compliance with standards may appear especially ‘‘lumpy’’ (compared to previous applications of the CAFE model to the more highly segmented light-duty fleet), with significant over compliance when widespread redesigns precede stringency increases, and/or significant application of carried- forward (aka ‘‘banked’’) credits. 
Second, since the use of phase-in caps 
has been de-emphasized and manufacturer technology deployment remains tied strongly to estimated product redesign and freshening schedules, technology penetration rates may jump more quickly as manufacturers apply technology to high- volume products in their portfolio. 
By design, restrictions that enforce 
commonality of mass reduction and 
aerodynamic technologies on variants of a platform, and those that enforce engine inheritance, will result in fewer vehicle-technology combinations in a manufacturer’s future modeled fleet. These restrictions are expected to more accurately capture the true costs associated with producing and maintaining a product portfolio. (g) Accounting for Test Weight, Payload, 
and Towing Capacity 
As mentioned above, NHTSA has also 
revised the CAFE model to explicitly account for the regulatory ‘‘binning’’ of test weights used to certify light-duty fuel economy and HD pickup and van fuel consumption for purposes of evaluating fleet-level compliance with fuel economy and fuel consumption standards. For HD pickups and vans, test weight (TW) is based on adjusted loaded vehicle weight (ALVW), which is defined as the average of gross vehicle weight rating (GVWR) and curb weight (CW). TW values are then rounded, resulting in TW ‘‘bins’’: 
ALVW ≤ 4,000 lb.: TW rounded to 
nearest 125 lb. 
4000 lb. < ALVW ≤ 5,500 lb.: TW 
rounded to nearest 250 lb. 
ALVW > 5,500 lb.: TW rounded to 
nearest 500 lb. 
This ‘‘binning’’ of TW is relevant to 
calculation of fuel consumption 
reductions accompanying mass reduction. Model inputs for mass reduction (as an applied technology) are expressed in terms of a percentage reduction of curb weight and an accompanying estimate of the percentage reduction in fuel consumption, setting aside rounding of test weight. Therefore, to account for rounding of test weight, NHTSA has modified these calculations as follows: 
Where: 
DCW = % change in curb weight (from model 
input), 
DFC unrounded _TW= % change in fuel 
consumption (from model input), 
without TW rounding, 
DTW = % change in test weight (calculated), 
and 
DFC rounded _TW= % change in fuel 
consumption (calculated), with TW rounding. 
As a result, some applications of 
vehicle mass reduction will produce no compliance benefit at all, in cases where the changes in ALVW are too small to change test weight when rounding is taken into account. On the other hand, some other applications of vehicle mass 
reduction will produce significantly more compliance benefit than when rounding is not taken into account, in cases where even small changes in ALVW are sufficient to cause vehicles’ test weights to increase by, e.g., 500 lbs. when rounding is accounted for. Model outputs now include initial and final TW, GVWR, and GCWR (and, as before, CW) for each vehicle model in each model year. The agencies invited but did not receive comment on how TW is modeled. 
In addition, considering that the 
regulatory alternatives in the agencies’ analysis all involve attribute-based standards in which underlying fuel consumption targets vary with ‘‘work factor’’ (defined by the agencies as the sum of three quarters of payload, one quarter of towing capacity, and 500 lb. for vehicles with 4WD), NHTSA has modified the CAFE model to apply inputs defining shares of curb weight reduction to be ‘‘returned’’ to payload and shares of GVWR reduction to be returned to towing capacity. The standards’ dependence on work factor provides some incentive to increase payload and towing capacity, both of which are buyer-facing measures of vehicle utility. In the agencies’ judgment, this provides reason to assume that if vehicle mass is reduced, manufacturers are likely to ‘‘return’’ some of the change to payload and/or towing capacity. For this analysis, the agencies have applied the following assumptions: 
•GVWR will be reduced by half the 
amount by which curb weight is reduced. In other words, 50 percent of the curb weight reduction will be returned to payload. 
•GCWR will not be reduced. In other 
words, 100 percent of any GVWR reduction will be returned to towing capacity. 
•GVWR/CW and GCWR/GVWR will 
not increase beyond levels observed among the majority of similar vehicles (or, for outlier vehicles, initial values): 
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492CARB, Docket No. NHTSA–2014–0132–0125, 
at 17–18; 52–53. 
493UCS, Docket No. EPA–HQ–OAR–2014–0827– 
1329, at pages 23–24. 
494CBD, Docket No. NHTSA–2014–0132–0101 at 
pages 8–9. TABLE VI–8 R ATIOS FOR MODIFYING GVW ANDGCW AS A FUNCTION OF MASSREDUCTION  
Group Maximum ratios assumed 
enabled by mass reduction 
GVWR/CW GCWR/GVWR 
Unibody ........................................................................................................................ ............................................ 1.75 1.50 
Gasoline pickups > 13k GVWR .................................................................................................... ........................... 2.00 1.50 
Other gasoline pickups ......................................................................................................... ................................... 1.75 2.25 
Diesel SRW pickups ............................................................................................................. ................................... 1.75 2.50 
All other ...................................................................................................................... .............................................. 1.75 2.25 
The first of two of these inputs are 
specified along with standards for each 
regulatory alternative, and the GVWR/ CW and GCWR/GVWR ‘‘caps’’ are specified separately for each vehicle model in the analysis fleet. 
In addition, NHTSA has changed the 
model to prevent HD pickup and van GVWR from falling below 8,500 lbs. when mass reduction is applied (because doing so will cause vehicles to be reclassified as light-duty vehicles), and to treat any additional mass for hybrid electric vehicles as reducing payload by the same amount (e.g., if 
adding a strong HEV package to a vehicle involves a 350 pound penalty, GVWR is assumed to remain unchanged, such that payload is also reduced by 350 lbs). 
The agencies invited but did not 
receive comment on estimating how changes in vehicle mass may impact fuel consumption, GVWR, and GCWR. 
(8) Subsequent Changes to the CAFE 
Model (for Method A) 
Since issuing the NPRM, NHTSA has 
made further changes to the CAFE model, in order to estimate the potential impacts of simultaneous standards for both light-duty vehicles and HD pickups and vans. Among the updates most relevant to analysis supporting the final standards for HD pickups and vans, the current model: includes refinements to enable accounting for platforms, engines, and transmissions sharing between light-duty and HD pickups and vans; reflects refinements to how models for the first application of new technology are identified among shared platforms, engines, and transmissions; allows payback period, discount rate, survival rates, and mileage accumulation schedules to be specified separately for each vehicle class; makes use of large scale simulation modeling to more accurately account for synergies among technologies to estimate the fuel consumption impact of different combinations of technologies; provides 
the ability to selectively exclude fine payment from the ‘‘effective cost’’ calculation used to simulation manufacturers’ decisions regarding the application of fuel-saving technologies; 
and expands the use of forward planning to estimate decisions to use credits that would otherwise expire. Changes to the CAFE model are discussed at greater length below and in the CAFE model documentation. 
Also since issuing the NPRM, NHTSA 
has revised many model inputs to reflect information that has become available since the proposal. Among the updates most relevant to analysis supporting the final rule, these inputs reflect: an updated vehicle-level market forecast based on data regarding the 2015 model year fleet and a new commercially-available manufacturer- and segment-level market forecast, and spanning light-duty vehicles and HD pickups and vans; newer fuel prices and total vehicle production volumes from the Energy Information Administration’s Annual Energy Outlook 2015; a database, based on a large-scale full vehicle simulation study, of estimates of the effect of thousands of different 
combinations of technologies on fuel consumption; and updated mileage accumulation schedules based on a database of more than 70 million odometer readings. 
NHTSA implemented these changes 
to the CAFE model and accompanying inputs to support both today’s final rule promulgating new fuel consumption standards for HD pickups and vans and the Draft Technical Assessment Report regarding agency’s consideration of CAFE standards for light duty vehicles for model years 2022–2025. This provided a basis to analyze the fleets simultaneously, accounting for interactions between the fleets; the draft RIA (p. 10–18) accompanying the NPRM identified this as a planned improvement for the final rule, and some stakeholders’ comments (e.g., CARB,
492UCS,493and CBD494) indicated that such interactions should be accounted for. 
The remainder of this section 
summarizes changes to the CAFE model and inputs made subsequent to the NPRM analysis, summarizes results of the updated analysis, and discusses. 
(a) Interactions Between Regulatory 
Classes 
Like earlier versions, the current 
CAFE model provides for integrated analysis spanning different regulatory classes, accounting both for standards that apply separately to different classes and for interactions between regulatory classes. Light vehicle CAFE standards are specified separately for passenger cars and light trucks. However, there is considerable sharing between these two regulatory classes. Some specific engines and transmissions are used in both passenger cars and light trucks, and some vehicle platforms span these regulatory classes. For example, some sport-utility vehicles are offered in 2WD versions classified as passenger cars and 4WD versions classified as light trucks. Integrated analysis of manufacturers’ passenger car and light truck fleets provides the ability to account for such sharing and reduce the likelihood of finding solutions that could involve impractical levels of complexity in manufacturers’ product lines. In addition, integrated analysis provides the ability to simulate the potential that manufactures could earn CAFE credits by over complying with one standard and use those credits toward compliance with the other standard (i.e., to simulate credit transfers between regulatory classes). 
HD pickups and vans are regulated 
separately from light-duty vehicles. While manufacturers cannot transfer credits between light-duty and MDHD classes, there is some sharing of engineering and technology between light-duty vehicles and HD pickups and vans. For example, some passenger vans with GVWR over 8,500 pounds are classified as medium-duty passenger vehicles (MDPVs) and thus included in manufacturers’ light-duty truck fleets, 
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495Volpe CAFE Model Documentation, July 2016, 
pg 64. Available at http://www.nhtsa.gov/
Laws%20&%20Regulations/CAFE%20-%20Fuel%20Economy/cafe-volpe-model. while cargo vans sharing the same 
nameplate are classified as HD vans. 
The FRM Method A analysis uses an 
overall analysis fleet spanning both the light-duty and HD pickup and van fleets. As discussed below, doing so shows some technology ‘‘spilling over’’ to HD pickups and vans due, for example, to the application of technology in response to current light- duty standards. For most manufacturers, these interactions appear relatively small. For Nissan, however, they appear considerable, because Nissan’s heavy- duty vans use engines also used in Nissan’s light-duty SUVs. Unlike the Method A analysis, the Method B analysis is independent from the light- duty program. 
In the NPRM proposing new 
standards for heavy-duty pickups and vans, NHTSA and EPA requested comment on the expansion of the analysis fleet such that the impacts of new HD pickup and van standards can be estimated within the context of an integrated analysis of light-duty vehicles and HD pickups and vans, accounting for interactions between the fleets. As mentioned above, some environmental organizations specifically cited 
commonalities and overlap between light- and heavy-duty products. 
(b) Phase-In Caps 
The model also accommodates 
estimates of overall limits (expressed as 
‘‘phase-in caps’’ in model inputs) on the rates at which manufacturers’ may practicably add technology to their respective fleets. So, for example, even if a manufacturer is expected to redesign half of its production in MY 2016, if the manufacturer is not already producing any strong hybrid electric vehicles (SHEVs), a phase-in cap can be specified in order to assume that manufacturer will stop applying SHEVs in MY 2016 once it has done so to at least 3 percent of its production in that model year. Today’s analysis sets all of these caps at 100 percent, relying on other model constraints (in particular, the assumption that many technologies are most practicably applied as part of a 
vehicle freshening or redesign) to estimate practicable technology application pathways. 
The CAFE model retains the ability to 
use phase-in caps (specified in model inputs) as proxies for a variety of practical restrictions on technology application. Unlike vehicle-specific restrictions related to redesign, refreshes or platforms/engines, phase-in caps constrain technology application at the vehicle manufacturer level. Introduced in the 2006 version of the CAFE model, they were intended to reflect a manufacturer’s overall resource capacity available for implementing new technologies (such as engineering and development personnel and financial resources), thereby ensuring that resource capacity is accounted for in the modeling process. 
In previous fuel efficiency 
rulemakings, redesign/refresh schedules and phase-in caps were the primary mechanisms to reflect an OEM’s limited pool of available resources during the rulemaking time frame and the years leading up to the rulemaking time frame, especially in years where many models may be scheduled for refresh or 
redesign. The newly-introduced representation platform-, engine-, and transmission-related considerations discussed above augment the model’s preexisting representation of redesign cycles, and as discussed above, inputs for today’s analysis de-emphasize reliance on phase-in caps. 
(c) Accounting for Credits 
The changes discussed above relate 
specifically to the model’s approach to 
simulating manufacturers’ potential addition of fuel-saving technology in response to fuel efficiency standards and fuel prices within an explicit product planning context. The model’s approach to simulating compliance decisions also accounts for the potential to earn and use fuel consumption credits, as provided by EPCA/EISA. Like past versions, the current CAFE model can be used to simulate credit carry- forward (a.k.a. banking) between model 
years and transfers between the passenger car and light truck fleets, but not credit carry-back (a.k.a. borrowing) between model years or trading between manufacturers. Unlike past versions, the current CAFE model provides a basis to specify (in model inputs) fuel consumption credits available from model years earlier than those being simulated explicitly. For example, with today’s analysis representing model years 2015–2032 explicitly, credits specified as being available from model year 2014 are made available for use through model year 2019 (given the current 5-year limit on carry-forward of credits). 
As discussed in the CAFE model 
documentation, the model’s default logic attempts to maximize credit carry- forward—that is to ‘‘hold on’’ to credits for as long as possible.
495Although the 
model uses credits before expiry if 
needed to cover shortfalls when insufficient opportunity to add technology is available to achieve compliance with a standard, the model will otherwise carry forward credits until they are about to expire, at which point it will use them before adding technology. As further discussed in the CAFE model documentation, model inputs can be used to adjust this logic to shift the use of credits ahead by one or more model years. 
The example presented below 
illustrates how some of aspects of the current model logic around credits impacts estimation of technology application by a manufacturer within the context of a specified set of standards, focusing here on the model’s estimate of Ford’s potential technology application under the preferred alternative. Overall results for Ford and other manufacturers are summarized in Section VI.D. 
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Several aspects of the estimated 
achieved and required fuel consumption 
levels shown above are notable. First, the characteristics of Ford’s fleet as represented in today’s analysis fleet are such that the heavy duty pickup and van fleet falls short of average fuel efficiency standard in MY’s 2023 through 2027. However, they exceed their standard for MY’s 2016 through 2022. The current analysis uses logic that reflect the potential that Ford could use the 5-year carry forward provision to use fuel efficiency credits earned in MY’s 2018 through MY 2022, to cover the shortfalls for MY’s 2023 to 2027. The model assumes Ford will use as many of the MY 2018 expiring credits as necessary to cover the shortfall in MY 2023. For MY 2024 they will use all available MY 2019 credits before applying any additional MY 2020 credits necessary to cover the shortfall 
(in this particular case there are enough MY 2019 credits to cover the shortfall in MY 2024). This pattern continues for all model years where there is a shortfall— the model applies the oldest remaining credits first. Even so, today’s analysis indicates Ford could be required to pay civil penalties for noncompliance without the addition of modest fuel savings in MY 2027. The change to the model which accounts for credits earned prior to MY 2015 is not illustrated in this example. However, Ford comes in with fuel consumption credits from MY’s prior to MY 2015; if they had come in with an initial shortfall, they could have used these banked credits to cover, at least a 
portion, of that shortfall. 
As discussed above, these results 
provide an estimate, based on analysis inputs, of one way General Motors could add fuel-saving technologies to its 
products under the preferred alternative considered here, and are not a prediction of what General Motors would do under this alternative. In 
addition, it should be recognized that specific results vary among manufacturers and among regulatory alternatives (and under different analytical inputs). Still, the example should serve to illustrate how the ability to model credit banking can impact results. 
(d) Integrating Vehicle Simulation 
Results Into the Synergy Values 
The CAFE model does not itself 
evaluate which technologies will be available, nor does it evaluate how effective or reliable they will be. The technological availability and effectiveness rather, are predefined inputs to the model based on the agencies’ judgements and not outputs from the model, which is simply a tool for calculating the effects of combining input assumptions. 
In previous versions of the CAFE 
Model, technology effectiveness values entered into the model as a single number for each technology (for each of several classes), intended to represent the incremental improvement in fuel consumption achieved by applying that technology to a vehicle in a particular class. At a basic level, this implied that successive application of new vehicle technologies resulted in an improvement in fuel consumption (as a percentage) that was the product of the individual incremental effectiveness of each technology applied. Since this construction fails to capture interactive effects—cases where a given technology either improves or degrades the impact of subsequently applied technologies— the CAFE Model applied ‘‘synergy factors.’’ The synergy factors were defined for a relatively small number of technology pairs, and were intended to represent the result of physical interactions among pairs of technologies—attempting to account for situations where 2 x 2 ≠ 4. 
For a more specific example, for a 
vehicle with an initial fuel consumption of FC
0, if two technologies are applied, 
one with an incremental effectiveness of 5 percent, and a second with an incremental effectiveness of 10 percent, the effectiveness after the application of both technologies without consideration of synergies could be expressed as follows: 
FC
0*(1¥.05)*(1¥.1) 
Which is equivalent to: FC
0*(1¥.145) 
This suggests that the combined 
effectiveness of the two technologies is 
14.5 percent. The synergy factors aim to correct for cases where fuel consumption improvements are not perfectly multiplicative, and the combined fuel consumption in the example above is either greater than or less than 14.5 percent. 
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496The technology tree used to create the 
synergies for this rule are presented in the light- 
duty draft TAR. For this analysis, the CAFE Model has 
been modified to accommodate the 
results of the large-scale vehicle simulation study conducted by Argonne National Laboratory (described in more detail in the light-duty Draft TAR). While Autonomie, Argonne’s vehicle simulation model, produces absolute fuel consumption values for each simulation record, the results have been modified in a way that preserves much of the existing structure of the CAFE Model’s compliance logic, but still faithfully reproduces the totality of the simulation outcomes present in the database. Fundamentally, the implementation represents a translation of the absolute values in the simulation database into incremental improvements and a substantially expanded set of synergy factors. 
Since the simulation efforts only 
included light-duty vehicles, the effectiveness values for heavy duty were not integrated into the heavy-duty fleet; for future rule-makings NHTSA hopes to extend the vehicle simulation efforts to include simulations that would be relevant for heavy-duty pickups and vans. While the effectiveness values for individual technologies remain the same, the synergies between two or more technologies incorporate information from Autonomie Argonne’s light-duty pickup simulations. While these synergy values are not a perfect approximation of the interaction of technology applications particular to heavy-duty vehicles, it is consistent with what we did in the NPRM (where we also used synergy values from light- duty pickups). 
Updating the synergy values to use 
Argonne’s simulation efforts does two things: (1) It allows that these synergies may occur between more than two technologies, and (2) because the synergies are multiplicative, rather than additive, it allows for the consideration that the order of other technology applications matter in determining the incremental percentage improvement correction of the synergy value. Instead of having one additive incremental percentage synergy value for a pair of technologies, regardless of the order of technology application between these pair of technologies, the synergy values are dependent on the initial state and 
ending point of a vehicle within the database. 
As stated, in the past, synergy values 
in the Volpe model were represented as pairs. However, the new values are 7- tuples and there is one for every point in the database. The synergy factors are based (entirely) on values in the Argonne database, producing one for each unique technology combination for each technology class, and are calculated as 
where S kis the synergy factor for 
technology combination k, FC0is the 
fuel consumption of the reference vehicle (in the database), x
iis the fuel 
consumption improvement of each technology i represented in technology 
combination k (where some 
technologies are present in combination k, and some are precedent technologies 
that were applied, incrementally, before reaching the current state on one of the paths). 
In order to incorporate the results of 
the Argonne database, while still preserving the basic structure of the CAFE model’s technology module, it was necessary to translate the points in the database into locations on the technology tree.
496By recognizing that 
most of the paths on the technology tree are unrelated, or separable, it is possible to decompose the technology tree into a small number of paths and branches by technology type. To achieve this level of linearity, we define technology groups— only one of which is new. They are: engine cam configuration (CONFIG), engine technologies (ENG), transmission technologies (TRANS), electrification (ELEC), mass reduction levels (MR), aerodynamic improvements (AERO), and rolling resistance (ROLL). The combination of technology levels along each of these paths define a unique technology combination that corresponds to a single point in the database for each technology class. These technology state definitions are more important for defining synergies than for determining incremental effectiveness, but the paths are incorporated into both. Again, because we did not simulate results applicable to the heavy-duty fleet, we did not use the database to define the incremental technology effectiveness, but only to adjust for the unique interaction of different combinations of technology. 
As an example, a technology state 
vector describing a vehicle with a SOHC engine, variable valve timing (only), a 6- speed automatic transmission, a belt- integrated starter generator, mass reduction (level 1), aerodynamic improvements (level 2), and rolling resistance (level 1) would be specified as SOHC;VVT;AT6;BISG;MR1;AERO2;ROLL1. Once a vehicle is assigned a technology state (one of the tens of thousands of unique 7-tuples, defined as CONFIG;ENG;TRANS;ELEC;MR;AERO;ROLL), adding a new technology to the vehicle simply represents progress from one technology state to another. The vehicle’s fuel consumption is: 
FC
i= FC0· (1 ¥ FCI i) · S K/0 
where FC iis the fuel consumption 
resulting from the application of 
technology i, FC0is the vehicle’s fuel 
consumption before technology i is 
applied, FCI iis the incremental fuel 
consumption (percentage) improvement associated with technology i, S
kis the 
synergy factor associated with the combination, k, of technologies the 
vehicle technology i is applied, and S
0 
the synergy factor associated with the technology state that produced fuel consumption FC
0.The synergy factor is 
defined in a way that captures the incremental improvement of moving between points in the database, where each point is defined uniquely as a 7- tuple describing its cam configuration, highest engine technology, transmission, electrification type, mass reduction level, and level of aerodynamic or rolling resistance improvement. For the current heavy- duty adoption, it is only these synergy values that were used in the current analysis. While, like with the individual fuel consumption improvements, there is likely not a simple mapping from light-duty pickups to heavy-duty pickups (size and power matter), the previous synergy values were also an adoption from light-duty pickups. The integration of the simulation data allows for a more complete set of synergies that account for the order of technology application and the interaction of more than two individual technologies. 
(e) Updating Mileage Accumulation 
Schedules 
In order to develop new mileage 
accumulation schedules for vehicles regulated under NHTSA’s fuel efficiency and CAFE programs (classes 1–3), NHTSA purchased a data set of vehicle odometer readings from IHS/ Polk (Polk). Polk collects odometer readings from registered vehicles when they encounter maintenance facilities, state inspection programs, or interactions with dealerships and OEMs. The (average) odometer readings in the data set NHTSA purchased are based on over 74 million unique odometer readings across 16 model years (2000–2015) and vehicle classes present in the data purchase (all registered vehicles less than 14,000 lbs. GVW). 
The Polk data provide a measure of 
the cumulative lifetime vehicle miles 
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traveled (VMT) for vehicles, at the time 
of measurement, aggregated by the following parameters: make, model, model year, fuel type, drive type, door count, and ownership type (commercial or personal). Within each of these subcategories they provide the average odometer reading, the number of odometer readings in the sample from which Polk calculated the averages, and the total number of that subcategory of vehicles in operation. From these NHTSA was able to develop new estimates of vehicle miles traveled by age as inputs for the CAFE Model. 
(f) Impact of Vehicle Technology 
Application Requirements 
Compared to prior analyses of light- 
duty standards, these model changes result in some changes in the broad characteristics of the model’s application of technology to manufacturers’ fleets. Since the use of phase-in caps has been de-emphasized and manufacturer technology deployment remains tied strongly to estimated product redesign and freshening schedules, technology penetration rates may jump more quickly as manufacturers apply technology to high-volume products in their portfolio. 
By design, restrictions that enforce 
commonality of mass reduction and aerodynamic technologies on variants of a platform, and those that enforce engine inheritance, will result in fewer vehicle-technology combinations in a manufacturer’s future modeled fleet. As explained in the NPRM proposing new standards for HD pickups and vans, these restrictions are expected to more accurately capture the true costs associated with producing and maintaining a product portfolio. 
(i) Updated Schedules 
The new medium-duty van/pickup 
schedule in Figure VI–6 predicts higher annual VMT for vehicles between ages 
one through five years, and lower annual VMT for all other vehicle ages, than the old schedule. Over the first 30- year span, the new schedule predicts that medium-duty vans/pickups drive 24,249 (9 percent) fewer miles than the old schedule. We predict the maximum average annual VMT for medium-duty vehicles (23,307 miles) at age two. These changes to the schedule will have important implications on certain benefits of the standards. More monetary fuel savings will occur during the first five years of a vehicle’s life under the new schedule, but a decrease in fuel savings will occur overall while using these schedules. For payback periods shorter than 5 years, the new schedule will show shorter payback periods than the old schedule. Section 10 of the RIA offers similar figures for light-duty vehicles types. It also offers further explanation about the shape of the new annual VMT schedule. 
Table VI–9 offers a summary of the 
comparison of lifetime VMT (by class) under the new schedule, compared with lifetime VMT under the old schedule. In addition to the total lifetime VMT expected under each schedule for vehicles that survive to their full useful life, Table VI–9also shows the survival- weighted lifetime VMT for both schedules. This represents the average lifetime VMT for all vehicles, not only those that survive to their full useful life. The percentage difference between the two schedules is not as stark for the survival-weighted schedules: The 
percentage decrease of survival- weighted lifetime VMT under the new schedules range from 6.5 percent (for medium-duty trucks and vans) to 21.2 percent (for passenger vans). 
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497For figures that support the conclusions about 
the representativeness of the IHS/Polk data see 
Section 10 of the RIA. TABLE VI–9—S UMMARY COMPARISON OF LIFETIME VMT OF THE NEW AND OLDSCHEDULES  
Survival-Weighted 
Lifetime VMT Lifetime VMT 
New Old % difference New Old % difference 
Car ........................................................... 204,233 301,115 32.2 142,119 179,399 20.8 
Van ........................................................... 237,623 362,482 34.4 155,115 196,725 21.2 
SUV .......................................................... 237,623 338,646 29.8 155,115 193,115 19.7 
Pickup ...................................................... 265,849 360,982 26.4 157,991 188,634 16.2 
2b/3 .......................................................... 246,413 270,662 9.0 176,807 189,020 6.5 
(ii) Data Description 
While the Polk data set contains 
model-level average odometer readings, 
the CAFE model assigns lifetime VMT schedules at a lower resolution based on vehicle body style. For the purposes of VMT accounting, the CAFE model classifies every vehicle in the analysis fleet as being one of the following: passenger car, SUV, pickup truck, passenger van, or medium-duty pickup/ van. In order to use the Polk data to develop VMT schedules for each of the (VMT) classes in the CAFE model, we constructed a mapping between the classification of each model in the Polk data and the classes in the CAFE model. The only difference between the mapping for the VMT schedules and the rest of the CAFE model is that we merged the SUV and van body styles into one class (for reasons described in our discussion of the SUV/van schedule in Section 10 of the RIA). This mapping allowed us to predict the lifetime miles traveled, by the age of a vehicle, for the categories in the CAFE model. 
In estimating the VMT models, we 
weighted each data point (make/model classification) by the share of each make/model in the total population of the corresponding CAFE class. This weighting ensures that the predicted odometer readings, by class and model year, represent each of vehicle classification among observed vehicles (i.e., the vehicles for which Polk has 
odometer readings), based on each vehicles’ representation in the registered vehicle population of its class. Implicit in this weighting scheme, is the assumption that the samples used to calculate each average odometer reading by make, model, and model year are representative of the total population of vehicles of that type. Several indicators suggest that this is a reasonable assumption. 
First, the majority of each vehicle 
make/model is well-represented in the sample. For more than 85 percent of make/model combinations, the average odometer readings are collected for 20 percent or more of the total population. Most make/model observations have 
sufficient sample sizes, relative to their representation in the vehicle population, to produce meaningful average odometer totals at that level. 
We also considered whether the 
representativeness of the odometer sample varies by vehicle age, since VMT schedules in the CAFE model are specific to each age. To investigate, we calculated the percentage of vehicle types (by make, model, and model year) that did not have odometer readings. All model years, apart from 2015, have odometer readings for 96 percent or more of the total types of vehicles observed in the fleet. 
While the preceding discussion 
supports the coverage of the odometer 
sample across makes/models by each model year, it is possible that, for some of those models, an insufficient number of odometer readings is recorded to create an average that is likely to be representative of all of those models in operation for a given year. For all model years other than 2015, about 95 percent or more of vehicles types are represented by at least 5 percent of their population. For this reason, we included observations from all model years, other than 2015, in the estimation of the new VMT schedules. 
It is possible that the odometer 
sample is biased. If certain vehicles are over-represented in the sample of odometer readings relative to the registered vehicle population, a simple average, or even one weighted by the number of odometer observations will be biased. However, while weighting by the share of each vehicle in the 
population will account for this bias, it would not correct for a sample that entirely omits a large number of makes/ models within a model year. We tested for this by computing the proportion of the count of odometer readings for each individual vehicle type—within a class and model year—to the total count of readings for that class and model year. We also compared the population of each make/model—within each class and model year—to the population of the corresponding class and model year. The difference of these two ratios shows the difference of the representation of a vehicle type—in its respective class and model year—in the sample versus the population. All vehicle types are represented in the sample within 10 percent of their representation in the population, and the variance between the two representations is normally distributed. This suggests that, on average, the likelihood that a vehicle is in the sample is comparable to its proportion in the relevant population, and that there is little under or over sampling of certain vehicle makes/ models.
497 
(iii) Estimation 
Since model years are sold in in the 
fall of the previous calendar year, throughout the same calendar year, and even into the following calendar year— not all registered vehicles of a make/ model/model year will have been registered for at least a year (or more) until age 3. The result is that some MY 2014 vehicles may have been driven for longer than one year, and some less, at the time the odometer was observed. In order to consider this in our definition of age, we assign the age of a vehicle to be the difference between the average reading date of a make/model and the average first registration date of that make/model. The result is that the continuous age variable reflects the amount of time that a car has been registered at the time of odometer reading, and presumably the time span that the car has accumulated the miles. 
After creating the ‘‘Age’’ variable, we 
fit the make/model lifetime VMT data points to a weighted quartic polynomial regression of the age of the vehicle (stratified by class). The predicted values of the quartic regressions are used to calculate the marginal annual VMT by age for each class by calculating differences in estimated lifetime mileage accumulation by age. However, the Polk data acquired by NHTSA only contains 
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observations for vehicles newer than 16 
years of age. In order to estimate the schedule for vehicles older than the age 15 vehicles in the Polk data, we combined information about that portion of the schedule from the VMT schedules used in both the 2017–2021 Final Light Duty Rule and 2019–2025 Medium-Duty NPRM. The light-duty schedules were derived from the survey data contained in the 2009 National Household Travel Survey (NHTS) and the 2001 Vehicle in Use Survey (VIUS), for medium-duty trucks. 
Based on the vehicle ages for which 
we have data (from the Polk purchase), the newly estimated annual schedules differ from the previous version in important ways. Perhaps most significantly, the annual mileage associated with ages beyond age 8 begin to, and continue to, trend much lower. The approach taken here attempts to preserve the results obtained through estimation on the Polk observations, while leveraging the existing (NHTS- based) schedules to support estimation of the higher ages (age 16 and beyond). Since the two schedules are so far apart, simply splicing them together would have created not only a discontinuity, but also precluded the possibility of a monotonically decreasing scale with age (which is consistent with previous schedules, the data acquired from Polk, and common sense). 
From the old schedules, we expect 
that the annual VMT is decreasing for all ages. Towards the end of our sample, the predictions for annual VMT increase. In order to force the expected monotonicity, we perform a triangular smoothing algorithm until the schedule is monotonic. This performs a weighted 
average which weights the observations close to the observation more than those farther from it. The result is a monotonic function, which predicts similar lifetime VMT for the sample span as the original function. Since we do not have data beyond 15 years of age, we are not able to correctly capture that 
part of the annual VMT curve using only the new dataset. For this reason, we use trends in the old data to extrapolate the new schedule for ages beyond the sample range. 
In order to use the VMT information 
from the newer data source for ages outside of the sample, we use the final in-sample age (15 years) as a seed and then apply the proportional trend from the old schedules to extrapolate the new schedules out to age 30. To do this, we calculated the annual percentage difference in VMT of the old schedule 
for ages 15–30. The same annual percentage difference in VMT is applied to the new schedule to extend beyond the final in-sample value. This assumes that the overall proportional trend in the outer years is correctly modeled in the old VMT schedule, and imposes this same trend for the outer years of the new schedule. The extrapolated schedules are the final input for the VMT schedules in the CAFE model. 
(iv) Comparison to Previous Schedules 
The new VMT data suggests that the 
VMT schedule used in the last Light- 
Duty CAFE Final Rule likely does not represent current annual VMT rates. Across all classes, the previous VMT schedules overestimate the average annual VMT. The previous schedules are based on data that is outdated and self-reported, while the observations from Polk are between 5 and 7 years newer than those in the NHTS and represent valid odometer readings (rather than self-reported information). 
Additionally, while the NHTS may be 
a representative sample of households, it is less likely to be a representative sample of vehicles. However, by 
properly accounting for vehicle population weights in the new averages and models, we corrected for this issue in the derivation of the new schedules. 
Insofar as these changes better 
represent actual VMT, they lead to better estimates of actual impacts, such 
as avoided fuel consumption and GHG emissions, safety impacts, and monetized benefits. 
(v) Future Direction 
In consultation with other agencies 
closely involved with VMT estimation 
(e.g., FHWA), NHTSA will continue to 
seek means to further refine estimated mileage accumulation schedules. For example, one option under consideration would be to obtain odometer reading data from successive 
calendar years, thus providing a more robust basis to consider, for example, the influence of changing fuel prices or economic conditions on the accumulation of miles by vehicles of a given age. 
(g) Updated Analysis Fleet 
For the current analysis we updated 
the reference fleet from MY 2014, to the 
latest available MY 2015. The projection of total sales volumes for the Class 2b and 3 market segment was based on the total volumes in the 2015 AEO Reference Case. For the purposes of this analysis, the AEO2015 calendar year volumes have been used to represent the corresponding model-year volumes. While AEO2015 provides enough resolution in its projections to separate the volumes for the Class 2b and 3 segments, the agencies deferred to the vehicle manufacturers and chose to rely on the relative shares present in the pre- model-year compliance data. 
The relative sales share by vehicle 
type (van or pickup truck, in this case) was derived from a sales forecast that the agencies purchased from IHS Automotive, and applied to the total volumes in the AEO2015 projection. Table VI–10 shows the implied shares of the total new 2b/3 vehicle market broken down by manufacturer and vehicle type. 
TABLE VI–10—2015 IHS A UTOMOTIVE MARKET SHARE FORECAST FOR 2B/3 V EHICLES  
Manufacturer Style Model year market share 
2016 2017 2018 2019 2020 2021 
Daimler .................. Van ....................... 2% 2% 2% 3% 3% 3% 
Fiat Chrysler .......... Van ....................... 3 3 3 3 3 3 
Ford ....................... Van ....................... 16 16 16 17 18 19 
General Motors ..... Van ....................... 7 7 7 7 8 8 
Nissan ................... Van ....................... 1 1 1 1 2 2 
Daimler .................. Pickup ................... 0 0 0 0 0 0 
Fiat Chrysler .......... Pickup ................... 14 14 14 14 15 14 
Ford ....................... Pickup ................... 29 30 31 31 28 28 
General Motors ..... Pickup ................... 28 27 26 25 24 24 
Nissan ................... Pickup ................... 0 0 0 0 0 0 
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Within those broadly defined market 
shares, volumes at the manufacturer/ 
model-variant level were constructed by applying the model-variant’s share of manufacturer sales in the pre-model- year compliance data for the relevant 
vehicle style, and multiplied by the total volume estimated for that manufacturer and that style. 
(h) Changes to Costs 
(i) Use of Retail Price Equivalent (RPE) 
Multiplier To Calculate Indirect Costs 
To produce a unit of output, vehicle 
manufacturers incur direct and indirect costs. Direct costs include cost of materials and labor costs. Indirect costs are all the costs associated with producing the unit of output that are not direct costs—for example, they may be related to production (such as research and development [R&D]), corporate operations (such as salaries, pensions, and health care costs for corporate staff), or selling (such as transportation, dealer support, and marketing). Indirect costs are generally recovered by allocating a share of the costs to each unit of good sold. Although it is possible to account for direct costs allocated to each unit of good sold, it is more challenging to account for indirect costs allocated to a unit of goods sold. To make a cost analysis process more feasible, markup factors, which relate total indirect costs to total direct costs, have been developed. These factors are often referred to as retail price equivalent (RPE) multipliers. 
Cost analysts and regulatory agencies 
(including both NHTSA and EPA) have frequently used these multipliers to predict the resultant impact on costs associated with manufacturers’ responses to regulatory requirements. The best approach, if it were possible, to determining the impact of changes in direct manufacturing costs on a manufacturer’s indirect costs would be to actually estimate the cost impact on each indirect cost element. However, doing this within the constraints of an agency’s time or budget is not always feasible, and the technical, financial, and accounting information to carry out such an analysis may simply be unavailable. 
The one empirically derived metric 
that addresses the markup of direct costs to consumer costs is the RPE multiplier, which is measured from manufacturer 10–K accounting statements filed with the Securities and Exchange Commission. Over roughly a three decade period, the measured RPE has been remarkably stable, averaging 1.5, with minor annual variation. The National Research Council notes that, ‘‘Based on available data, a reasonable RPE multiplier would be 1.5.’’ The historical trend in the RPE is illustrated in Figure VI.13. 
RPE multipliers provide, at an 
aggregate level, the relationship between 
revenue and direct manufacturing costs. They are measured by dividing total 
revenue by direct costs. However, because this provides only a single aggregate measure, using RPE multipliers results in the application of a common incremental markup to all technologies. It assures that the aggregate cost impact across all technologies is consistent with empirical data, but does not allow for indirect cost discrimination among different technologies. Thus, a concern in using the RPE multiplier in cost 
analysis for new technologies added in response to regulatory requirements is that the indirect costs of vehicle 
modifications are not likely to be the same for all different technologies. For example, less complex technologies could require fewer R&D efforts or less warranty coverage than more complex technologies. In addition, some simple technological adjustments may, for example, have no effect on the number of corporate personnel and the indirect costs attributable to those personnel. The use of RPEs, with their assumption that all technologies have the same 
proportion of indirect costs, is likely to overestimate the costs of less complex technologies and underestimate the costs of more complex technologies. However, for regulations such as the CAFE and GHG emission standards under consideration, which drive changes to nearly every vehicle system, overall average indirect costs should align with the RPE value. Applying RPE to the cost for each technology assures that alignment. 
Modified multipliers have been 
developed by EPA, working with a 
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498RTI International, ‘‘Automobile Industry Retail 
Price Equivalent and Indirect Cost Multipliers,’’ 
February 2009; EPA–420–R–09–003; http://www3.epa.gov/otaq/ld-hwy/420r09003.pdf . 
499Rogozhin, A., et al., ‘‘Using indirect cost 
multipliers to estimate the total cost of adding new technology in the automobile industry,’’ International Journal of Production Economics (2009), doi:10.1016/j.ijpe.2009.11.031. 
50080 FR 40137. contractor, for use in rulemakings.498 
These multipliers are referred to as 
indirect cost multipliers (or ICMs). ICMs assign unique incremental changes to each indirect cost contributor at several different technology levels. 
ICM = (direct cost + adjusted indirect 
cost)/(direct cost) Developing the ICMs from the RPE 
multipliers requires developing 
adjustment factors based on the complexity of the technology and the time frame under consideration: The less complex a technology, the lower its ICM, and the longer the time frame for applying the technology, the lower the ICM. This methodology was used in the cost estimation for the recent light-duty MYs 2012–2016 and MYs 2017–2025 rulemaking and for the heavy-duty MYs 2014–2018 rulemaking. The ICMs for the light-duty context were developed in a peer-reviewed report from RTI International and were subsequently discussed in a peer-reviewed journal article.
499Importantly, since publication 
of that peer-reviewed journal article, the agencies have revised the methodology to include a return on capital (i.e., profits) based on the assumption implicit in ICMs (and RPEs) that capital costs are proportional to direct costs, and businesses need to be able to earn returns on their investments. 
Since their original development in 
February 2009, the agencies have made 
some changes to both the ICMs factors and to the method of applying those factors relative to the factors developed by RTI and presented in their reports. We have described and explained those changes in several rulemakings over the years, most notably the 2017–2025 FRM for light vehicles and the more recent Heavy-duty GHG Phase 2 NPRM.
500In 
the 2015 NAS study, the committee stated a conceptual agreement with the ICM method since ICM takes into account design challenges and the activities required to implement each technology. However, although endorsing ICMs as a concept, the NAS Committee stated that ‘‘. . . the empirical basis for such multipliers is still lacking, and, since their application depends on expert judgment, it is not possible to determine whether the Agencies’ ICMs are accurate or not.’’ NAS also states that ‘‘. . . the specific values for the ICMs are critical since 
they may affect the overall estimates of costs and benefits for the overall standards and the cost effectiveness of the individual technologies.’’ The committee did encourage continued research into ICMs given the lack of empirical data for them to evaluate the ICMs used by the agencies in past analyses. EPA, for its part, continues to study the issue surrounding ICMs but has not pursued further efforts given resource constraints and demands in areas such as technology benchmarking and cost teardowns. 
On balance, NHTSA believes that the 
empirically derived RPE is a more reliable basis for estimating indirect costs. To ensure overall indirect costs in the analysis align with the RPE value, NHTSA has developed its primary analysis based on applying the RPE value of 1.5 to each technology. NHTSA also has conducted a sensitivity analysis examining the impact of applying the ICM approach in the sensitivity analysis portion later in this Section. This marks a change from the NPRM where we use the ICM multiplier to calculate indirect costs as the central analysis and the RPE multiplier as a sensitivity case. 
(ii) Updates to Mass Reduction Based on 
2014 Silverado Study 
As proposed in the NPRM we have 
updated the HD pickup and van mass reduction cost curves with a MY 2014 GMC Silverado EDAG study. The updated mass reduction study suggests that mass reduction will be more costly for heavy-duty vans and pickups than was suggested in the NPRM. This can explain the reduction in mass reduction in the current analysis compared to the NPRM. 
NHTSA awarded a contract to EDAG 
to conduct a vehicle weight reduction feasibility and cost study of a 2014MY full size pick-up truck. The light weighted version of the full size pick-up 
truck (LWT) used manufacturing processes that will likely be available during the model years 2025–2030 and be capable of high volume production. The goal was to determine the maximum feasible weight reduction while maintaining the same vehicle functionalities, such as towing, hauling, performance, noise, vibration, harshness, safety, and crash rating, as the baseline vehicle, as well as the functionality and capability of designs to meet the needs of sharing components across same or cross vehicle platform. Consideration was also given to the sharing of engines and other components with vehicles built on other platforms to achieve manufacturing economies of scale, and in recognition of resource constraints 
which limit the ability to optimize every component for every vehicle. 
A comprehensive teardown/ 
benchmarking of the baseline vehicle was conducted for the engineering analysis. The analysis included geometric optimization of load bearing vehicle structures, advanced material utilization along with a manufacturing technology assessment that would be available in the 2017 to 2025 time frame. The baseline vehicle’s overall mass, center of gravity and all key dimensions were determined. Before the vehicle teardown, laboratory torsional stiffness tests, bending stiffness tests and normal modes of vibration tests were performed on baseline vehicles so that these results could be compared with the CAE model of the light weighted design. After conducting a full tear down and benchmarking of the baseline vehicle, a detailed CAE model of the baseline vehicle was created and correlated with the available crash test results. The project team then used computer modeling and optimization techniques to design the light-weighted pickup truck and optimized the vehicle structure considering redesign of structural geometry, material grade and material gauge to achieve the maximum amount of mass reduction while achieving comparable vehicle performance as the baseline vehicle. Only technologies and materials projected to be available for large scale production and available within two to three design generations (e.g. model 
years 2020, 2025 and 2030) were chosen for the LWT design. Three design concepts were evaluated: (1) A multi- material approach; (2) an aluminum intensive approach; and (3) a Carbon Fiber Reinforced Plastics approach. The multi-material approach was identified as the most cost effective. The recommended materials (advanced high strength steels, aluminum, magnesium and plastics), manufacturing processes, (stamping, hot stamping, die casting, extrusions, and roll forming) and assembly methods (spot welding, laser welding, riveting and adhesive bonding) are currently used, although some to a lesser degree than others. These technologies can be fully developed within the normal product design cycle using the current design and development methods. 
The design of the LWT was verified, 
through CAE modeling, that it meets all relevant crash tests performance. The LS–DYNA finite element software used by the EDAG team is an industry standard for crash simulation and 
modeling. The researchers modeled the crashworthiness of the LWT design 
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using the NCAP Frontal, Lateral Moving 
Deformable Barrier, and Lateral Pole tests, along with the IIHS Roof, Lateral Moving Deformable Barrier, and Frontal Offset (40 percent and 25 percent) tests. All of the modeled tests were comparable to the actual crash tests performed on the 2014 Silverado in the NHTSA database. Furthermore, the FMVSS No. 301 rear impact test was modeled and it showed no damage to the fuel system. 
The baseline 2014 MY Chevrolet 
Silverado’s platform shares components across several platforms. Some of the chassis components and other structural components were designed to accommodate platform derivatives, similar to the components in the baseline vehicle which are shared across platforms such as GMT 920 (GM Tahoe, Cadillac Escalade, GMC Yukon), GMT 930 platform (Chevy Suburban, Cadillac Escalade ESV, GMC Yukon XL), and 
GMT 940 platform (Chevy Avalanche and Cadillac Escalade EXT) and GMT 900 platform (GMC Sierra). As per the National Academy of Science’s guidelines, the study assumes engines would be downsized or redesigned for mass reduction levels at or greater than 10 percent. As a consequence of mass reduction, several of the components used designs that were developed for other vehicles in the weight category of light-weighted designed vehicles were used to maximize economies of scale and resource limitations. Examples include brake systems, fuel tanks, fuel 
lines, exhaust systems, wheels, and other components. 
Cost is a key consideration when 
vehicle manufacturers decide which fuel-saving technology to apply to a vehicle. Incremental cost analysis for all of the new technologies applied to reduce mass of the light-duty full-size pickup truck designed were calculated. The cost estimates include variable costs as well as non-variable costs, such as the manufacturer’s investment cost for tooling. The cost estimates include all the costs directly related to manufacturing the components. For 
example, for a stamped sheet metal part, the cost models estimate the costs for each of the operations involved in the manufacturing process, starting from blanking the steel from coil through the final stamping operation to fabricate the component. The final estimated total manufacturing cost and assembly cost are a sum total of all the respective cost elements including the costs for material, tooling, equipment, direct labor, energy, building and maintenance. 
The information from the LWT design 
study was used to develop a cost curve representing cost effective full vehicle solutions for a wide range of mass reduction levels. At lower levels of mass reduction, non-structural components and aluminum closures provide weight reduction which can be incorporated independently without the redesign of other components and are stand-alone 
solutions for the LWV. The holistic vehicle design using a combination of AHSS and aluminum provides good levels of mass reduction at reasonably acceptable cost. The LWV solution achieves 17.6 percent mass reduction 
from the baseline curb mass. Further two more analytical mass reduction solutions (all aluminum and all carbon fiber reinforced plastics (CFRP)) were developed to show additional mass reduction that could be potentially achieved beyond the LWV mass reduction solution point. The aluminum analytical solution predominantly uses aluminum including chassis frame and other components. The carbon fiber reinforced plastics analytical solution predominantly uses CFRP in many of the components. The CFRP analytical solution shows higher level of mass reduction but at very high costs. Note here that both all-Aluminum and all CFRP mass reduction solutions are analytical solutions only and no computational models were developed to examine all the performance metrics. 
An analysis was also conducted to 
examine the cost sensitivity of major vehicle systems to material cost and production volume variations. 
Table VI–11 lists the components 
included in the various levels of mass reduction for the LWV solution. The components are incorporated in a progression based on cost effectiveness. 
TABLE VI–11—C OMPONENTS INCLUDED FOR DIFFERENT LEVELS OF MASSREDUCTION  
Vehicle component/system Cumulative 
mass saving 
(kg) Cumulative 
MR 
(%) Cumulative 
cost 
($) Cumulative 
cost 
($/kg) 
Interior Electrical Wiring ................................................................................... 1.38 0.06% (28.07)  ¥20.34 
Headliner .......................................................................................................... 1.56 0.06 (2 9.00) ¥18.59 
Trim—Plastic .................................................................................................... 2.59 0.11 (34.3 0) ¥13.24 
Trim—misc. ...................................................................................................... 4.32 0.18 (43.1 9) ¥10.00 
Floor Covering ................................................................................................. 4.81 0.20 (45.69 ) ¥9.50 
Headlamps ....................................................................................................... 6.35 0.26 (45.6 9) ¥7.20 
HVAC System .................................................................................................. 8.06 0.33 (45.69) ¥5.67 
Tail Lamps ....................................................................................................... 8.46 0.35 (45. 69) ¥5.40 
Chassis Frame ................................................................................................. 54.82 2.25 2.57 0.05 
Front Bumper ................................................................................................... 59.93 2.46 7.89 0.13 
Rear Bumper ................................................................................................... 62.96 2.59 11.04 0.18 
Towing Hitch .................................................................................................... 65.93 2.71 14.1 3 0.21 
Rear Doors ...................................................................................................... 77 3.17 28.09 0.36 
Wheels ............................................................................................................. 102.25 4.20 68.89 0.67 
Front Doors ...................................................................................................... 116.66 4.80 92 .53 0.79 
Fenders ............................................................................................................ 128.32 5.28 134.87 1.05 
Front/Rear Seat & Console ............................................................................. 157.56 6.48 272.57 1.73 
Steering Column Assy ..................................................................................... 160.78 6.61 287.90 1.79 
Pickup Box ....................................................................................................... 204.74 8.42 49 8.35 2.43 
Tailgate ............................................................................................................ 213.14 8.76  538.55 2.53 
Instrument Panel .............................................................................................. 218.66 8.99 565.0 6 2.58 
Instrument Panel Plastic Parts ........................................................................ 221.57 9.11 580.49 2.62 
Cab .................................................................................................................. 304.97 12. 54 1,047.35 3.43 
Radiator Support .............................................................................................. 310.87 12.78 1,09 5.34 3.52 
Powertrain ........................................................................................................ 425.82 17.51 1246.68 2.93 
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50149 U.S.C. 32902(k)(2). A fitted curve was developed based 
on the above listed mass reduction 
points to derive cost per kilogram at distinct mass reduction points. The current curve shows costs per kilogram approximately six times as expensive for 5 percent mass reduction (MR1) than in the NPRM, and approximately twice as expensive per kilogram for 7.5 percent mass reduction (MR2), which explains the reduction in mass reduction in the current analysis relative to the NPRM. 
D. NHTSA CAFE Model Analysis of the 
Regulatory Alternatives for HD Pickups and Vans: Method A 
EPCA and EISA require NHTSA to 
‘‘implement a commercial medium- and heavy-duty on-highway vehicle and work truck fuel efficiency improvement program designed to achieve the maximum feasible improvement’’ and to establish corresponding fuel consumption standards ‘‘that are appropriate, cost-effective, and technologically feasible.’’
501For both 
the NPRM and the current analysis of potential standards for HD pickups and vans, NHTSA applied NHTSA’s CAFE Compliance and Effects Modeling System (sometimes referred to as ‘‘the CAFE model’’ or ‘‘the Volpe model’’) to aid in determination of the maximally 
feasible standards. The subsequent analysis, referred to as ‘‘Method A,’’ includes several updates to the model 
and to accompanying inputs, as discussed above in section 6.C. The ‘‘Method A’’ results are used as the primary basis for NHTSA’s final determination of the suitability of the Phase 2 standards. Further discussion of the determination are provided after the discussion of the ‘‘Method A’’ modeling results in Section 6.C.(9) of this document. 
(1) Baseline Costs Across Manufacturers 
As in the NPRM, the main analysis of 
Method A considers costs, benefits and 
other effects of regulatory alternatives relative to the dynamic baseline—or a baseline which assumes that manufacturers will apply all technologies with associated cost that pays back from retail-priced fuel savings within 6 months of purchase. The assumption is that consumers are willing to pay additional technology costs that return in fuel savings within 6-months of purchase, and that as a result, manufacturers will adopt these technologies regardless of fuel efficiency standards. We considered alternative runs with voluntary overcompliance of technologies with a payback period of 0- months (manufacturers will not voluntarily overcomply if there is a cost associated with a technology), 12- 
months, 18-months, and 24-months in the sensitivity analysis. Before considering the effects of 
increases in the standards, it is 
important to discuss the baseline costs. These costs are assumed to be incurred even if no additional regulatory action is taken to increase standards beyond the existing MY 2018 standards. Table VI–12 shows the baseline average and total technology costs for each manufacturer in the heavy duty market, and for the heavy duty industry as a whole for the MY 2021 fleet (cost increases relative to the MY 2015 fleet). The updated CAFE model suggests that under no further increasses to stringency beyond MY 2018, manufacturers would spend $136 million—an industry average of $180 per vehicle—on technologies that improve fuel economy in MY 2021. The additonal baseline costs are not distributed across all manufacturers proportional to their fleet size. The average technology costs of an individual manufacturer fleet range from $80 per vehicle for Fiat/Chrysler to $350 per vehicle for General Motors. In order to explain this heterogeneity it is important to consider the sources of increased technology costs: compliance actions, inheritance from heavy duty vehicles, spillover inheritance from the light-duty vehicles, and voluntary overcompliance. 
TABLE VI–12—MY 2021 C OSTS (2013$) U NDER ALTERNATIVE 1b (C ENTRAL BASELINE ) FOR2b3 M ARKET  
Manufacturer Average per 
vehicle 
technology 
cost 
(2013$) Total 
technology 
cost 
(million 2013$) Estimated 
MY 2015 
fuel 
consumption 
(g/100 mi) Estimated 
MY 2018 
standard 
(g/100 mi) 
Daimler ............................................................................................................. 150 3 4.50 4.84 
FCA .................................................................................................................. 80 10 6.23  5.95 
Ford .................................................................................................................. 90 33 6.0 0 5.76 
GM ................................................................................................................... 350 86 6.5 2 5.94 
Nissan .............................................................................................................. 230 3 6.01 5.63 
Industry ............................................................................................................ 180 136 6.1 8 5.83 
One reason manufacturers incur 
technology costs in the baseline for MY 
2021 vehicles is to achieve compliance with Phase 1 standards, which end their stringency increases in MY 2018. Manufacturers will have different standards and different starting positions relative to these standards. In order to indicate which manufacturers make compliance actions which increase their baseline technology costs, 
Table VI–12 includes the MY 2015 estimated average fuel consumption and the estimated MY 2018 fuel consumption standard—manufacturers with higher average fuel consumption in 
MY 2015 than the estimated MY 2018 fuel consumption standard, will apply technology costs to comply with the final MY 2018 standards. The fuel consumption standards are determined by setting work factor based targets and computing the manufacturer’s sales- weighted average of these targets. While the individual vehicle targets based on work factor are the same for all vehicles 
of the same work factor for model years 2018 and beyond, the overall fuel efficiency standard for a manufacturer may change from model year to model year with changes to the work factors of 
individual vehicle models, as well as changes in relative production volumes of each vehicle model. The model does not capture all means by which a manufacturer’s average fuel efficiency standard may change under the MY 2018 attribute-based standards, but does capture changes to work factor—and therefore individual vehicle targets— due to application of mass reduction. 
The model also predicts changes to the fleet mix of each manufacturer using inputs created from AEO2015 and 2015 IHS/Polk production projections. The 
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502For a more complete discussion of inheritance 
in the model see Chapter 6, Section C. technology cost for a manufacturer to 
meet MY 2018 standards is primarily driven by the fuel consumption gap between the MY 2015 (baseline) compliance level and the 2018 standard. From Table VI.4 it can be seen that only Daimler meets its most-stringent fuel consumption standard in 2015 and does not have to apply technology in the baseline to comply with Phase 1 standards. 
A second source of technology costs 
is from inheritance; vehicles with shared platforms are assumed to inherit technologies applied to the platform leader at their next redesign or refresh to avoid creating a new body or engine platform,
502even if these actions are no 
longer necessary to reach compliance. Manufacturers produce a limited set of engine and body platforms as a strategy to reduce their costs; there is no reason to indicate they will modify this strategy to comply with standards, for this reason this is an important constraint in the CAFE model. A similar source of technology costs are costs associated with spillover from the light-duty MY 2017–2021 standards. Regulatory agencies distinctly define the heavy duty and light duty classes, but from the manufacturer perspective these classes are not clearly delineated. They share some engine and body platforms across regulatory classes, and sometimes the most cost-effective choice to comply with standards will involve making changes to these shared platforms. Comments in the NPRM recommended that we run the model with the ability to capture this spillover effect between the light-duty and heavy-duty fleets—in response to these comments, in the current analysis we run the two fleets together with all existing standards from the light-duty fleet included for all scenarios. Since the MY 2017–2021 light-duty CAFE standards are final, these and their effects are included in the baseline of the model—they will be in effect whether or not additional action is taken with heavy-duty standards. While we have included the ability for the standards from one fleet to affect the other, our modeling has shown that the spilloever effect from the light-duty fleet into the heavy-duty fleet, and from the heavy-duty fleet into the light-duty fleet is small. We hope to further develop the model’s ability to capture the spillover effects in future versions of the model. 
The final way that manufacturers 
might accrue additional technology costs in the MY 2021 dynamic baseline scenario is through voluntary overcompliance. As already discussed: In the baseline case of the central analysis it is assumed that manufacturers will apply technologies which payback in fuel savings within 6 months of operation, regardless of whether or not the standards increase in stringency. Depending on the existing technologies and vehicles in a manufacturer’s fleet, they may voluntarily overcomply by adding different technologies, or none at all. 
The MY 2021 costs of the dynamic 
baseline scenario are lower in the updated analysis than they were in the NPRM for all manufacturers other than Nissan and Daimler. The average technology costs across the industry are less than half the NPRM costs— dropping from $440/vehicle to $180/ vehicle. The largest drop in average costs across the manufacturers is for GM; their costs dropped from $780/ vehicle to $350/vehicle. The modeled costs for Nissan dropped from $280 to $230, and for FCA, from $280 to $80. 
While considering MY 2021 allows 
for comparision to the NPRM analysis, not all baseline costs are incurred in MY 2021. Figure VI–8shows the baseline total technology costs, andFigure VI–9, the average technology costs, by manufacturer for all model years. Like the NPRM analysis assumes manufacturers will likely apply most technologies as part of vehicle redesign or freshening; as a result their technology application comes in discrete blocks. GM applies $20 million in total technolgy for their MY 2016 fleet, and an additional $60 million in for MY 2018—their total technology costs vary slightly after this point with the projection of their fleet size and with the effects of technology learning. Similarly, Ford applies $30 million for MY 2017 and an additional $80 million in 2027. Chrysler/Fiat, Daimler, and Nissan apply technology in only one year—Chrysler/Fiat applies $11 million in MY 2018, Daimler $3 million for MY 2020, and Nissan $3 million for MY 2021. While the total technology costs vary between manufacturers, the per- vehicle baseline costs range between $0–350 for all manufacturers and model years. 
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(2) Relevant Model Updates 
There are changes to model that help 
explain the decrease in baseline 
technology costs for the current analysis. The current analysis uses the 
synergies simulated by Argonne for the light-duty fleet, while the NPRM 
analysis uses a limited set of synergy values (also initially estimated for the light-duty fleet. The changes in these 
synergy factors could impact which technologies are chosen, and how effective the model calculates them to 
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Figure VI-8 Total Annual Baseline Technology Costs (million 2013$) by Model Year and Manufacturer 
---Daimler - - -FCA -Ford -• -General Motors • • • • • • Nissan 
400 
350 ~---~---~~~~·-·-~~~~---~~~~--~-~;liiiil~~--lliiiii~.--~~--~~~-----~---~--~~-~-~-"-·' ·-·-·-·-· 
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503For a more complete discussion of the changes 
to the Argonne simulation synergies see Chapter 6, 
Section C. 504For further discussion on the switch from ICM 
to RPE for the final analysis see Chapter 6, Section C. 505More discussion of the change in mass 
reduction curves is present in Chapter 6, Section C. be.503Changes to the model input costs 
from the NPRM to the current analysis 
could also change which technologies get picked by the model, and the projected costs. One of the major changes to costs is a switch from the ICM cost mark-up methodology used in the NPRM to the RPE cost mark-up methodology of the current analysis.
504 
A more specific change to the input costs is a change to the mass reduction curve to be based off of the newer 2014 Silverado study, which suggests that 5 percent and 10 percent mass reduction is significantly more expensive than was assumed in the NPRM.
505 
The final major input change is that 
the current model uses the 2015 fleet as its reference point, while the NPRM uses the 2014 fleet. This affects the starting point of each manufacturer in the model, and could change their predicted standard (through changes in sales mix and work factor). In order to consider the impacts of using the 2015 reference fleet it is helpful to consider the sales-weighted fuel economy and work factor distributions across the two reference fleets. 
Figure VI–10 shows the sales- 
weighted empirical cumulative distribution function (CDF) for GM’s work factor and fuel economy for the two reference fleets. The dashed line shows the values for the 2014 reference fleet, and the solid, for the 2015 reference fleet. The y-axis shows the cumulative share of the manufacturer’s fleet against the two measures. For GM, the work factor CDF shifted to the right for work factors between 3500 and 5500, suggesting that the proportion of the fleet with work factors in this range increased in the GM fleet. Since increases in work factor will decrease the target value for individual vehicles, this average change in work factor decreases GM’s initial CAFE standard. 
It should also be noted that some 
methods of increasing work factor (mainly, decreasing curb weight) can increase the fuel efficiency of a vehicle, while others (increasing the power) can decrease fuel efficiency. The empirical CDF for GM’s sales-weighted fuel consumption shows GM’s 2015 fleet as having more vehicles with fuel consumption below 6.3 gal/100 mi, fewer with fuel consumption around 6.3 gal/100 mi, significantly more vehicles with fuel consumption around 7.0 gal/ 100 mi. The average fuel consumption of GM’s 2014 fleet was 6.27 gal/100 mi, where the average fuel consumption of GM’s 2015 fleet is 6.52 gal/100 mi. The overall increase in GM’s average fuel consumption diminishes the effect of the increase in work factor from MY 2014 to MY 2015 at improving their starting position in MY 2015 relative to MY 2014—their MY 2015 standard using the 2014 fleet was 6.36, and using the 2014 fleet and is 6.59. Considering this, their initial shortfall is about the same using either reference fleet. 
Figure VI–11 shows the same for 
Ford. There is a similar pattern of a 
higher proportion of heavy duty vehicles in Ford’s fleet with work factors between 3500 and 5000. This 
will decrease Ford’s initial standard in the model. Ford also shows a decrease in the proportion of heavy duty vehicles with higher fuel consumption, which 
will result in an overall lower fuel consumption for the 2015 fleet. The result is that Ford will start with a lower standard by using the 2015 fleet rather 
than the 2014 fleet, and start with a higher fuel efficiency level—both of which will work in the same direction to decrease Ford’s shortfall to MY 2018 
standards. This suggests that Ford will not need to apply as much technology to comply, and helps to explain their lower baseline technology costs in the current analysis. 
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Figure VI–12 shows the cumulative 
distribution function for the work factor 
of Fiat/Chrysler. Although there is some increase in the left tail of the distribution of FCA’s work factor for MY 2015 relative to MY 2014, it is smaller than for the Ford and GM fleets. The CDF of fuel efficiency also shows that Fiat/Chrysler shows nearly identical distribution of fuel consumption between the 2014 and 2015 fleets. These two factors combine to explain why Fiat/Chrysler did not show increases in 
costs from the NPRM to the current analysis—they did not have as much of a change in shortfall to MY 2018 standards as both GM and Ford. 
Figure VI–13 shows the same 
empirical distribution functions for 
Nissan. Both the distribution of work factor and fuel consumption are comparable for Nissan’s 2014 and 2015 fleets. This helps explain the small change in Nissan’s baseline costs 
between the two analyses. 
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Figure VI–14 shows the cumulative 
distribution function for work factor and 
fuel consumption for Daimler for both the 2014 and 2015 fleets. The distribution of work factor shifted right for work factors above 3500. The fuel consumption curve shifted right for all fuel consumptions. This suggests that Daimler will face a lower standard using the 2015 reference fleet, but that they may also start with a lower initial fuel efficiency level. The change to the 2015 reference fleet does not have clear 
implications on the relative starting point of Daimler in the analysis relative to the NPRM analysis. 
(3) Industry-Level Results of Regulatory 
Alternatives 
Table VI–13, below, summarizes the 
stringency of standards, the estimated required fuel efficiency the estimated achieved fuel efficiency, as well as the impacts of each alternative for the overall industry for MY 2030. Using the 
updated fleet and analysis, the MY 2030 stringency is slightly less that in the NPRM (4.91 gallons/100 mile in today’s analysis compared to 4.86 gallons/100 mile in the NPRM for the preferred alternative). As has been noted, the standards are set based in part on the work factor of vehicles; by changing the average work factor of their fleet, manufacturers can change the average stringency of their standard. While the model does not simulate changes to work factor which would increase the 
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power or GVWR, it does simulate 
changes in work factor due to mass reduction. By lowering the curb weight and holding power constant, manufacturers can increase the payload of a vehicle; since payload is a component in calculating the work factor, by lowering curb weight manufacturers can increase their work factor for a vehicle model and reduce its target. However, the average absolute and proportional curb weight reduction in the current analysis is less than it was in the NPRM analysis across all alternatives, which can be explained by the higher mass reduction costs under the current curve. This suggests that the change in the average overall industry standard in today’s analysis is likely due in major part to changes in the work factor between the 2014 and 2015 reference fleet, and not to changes in the work factor simulated within the model runs. 
TABLE VI–13—S UMMARY OF IMPACTS ON THE MY 2030 HD I NDUSTRY FLEET (VS. ALTERNATIVE 1b) 
Alternative 2 3 4 5 
Stringency of Standards 
Annual Increase in Stringency Beginning in MY 2021 .................................................... 2.0% 2.5% 3.5% 4.0% 
Increases Until ................................................................................................................. MY 2025 MY 2027 MY 2025 MY 2025 
Total Increase in MY 2030 Stringency Relative to Final Phase 1 Standards a.............. 9.6% 15.6% 15.6% 17.9% 
Estimated Average Fuel Economy (miles per gallon) 
Required in MY 2030 ....................................................................................................... 19.03  20.37 20.38 20.95 
Achieved in MY 2030 ...................................................................................................... 19.20 20.47 20.45 20.98 
Average Fuel Consumption (gallons/100 miles) 
Required in MY 2030 ....................................................................................................... 5.25 4.91 4.91 4.77 
Achieved in MY 2030 ...................................................................................................... 5.21 4 .88 4.89 4.77 
Estimated Average Greenhouse Gas Emissions (grams per mile) 
CO 2Required in MY 2030 ............................................................................................... 494 462 462 4 50 
CO 2Achieved in MY 2030 .............................................................................................. 490 460 460 44 9 
Technology Penetration in MY 2030 (percent) 
VVT and/or VVL ............................................................................................................... 56 56 56 56 
Cylinder Deactivation ....................................................................................................... 4 4 4 4 
Direct Injection Engine ..................................................................................................... 17 27 26 29 
Turbo Charged Engine .................................................................................................... 59 69 68 68 
8 Speed Auto. Trans. ...................................................................................................... 77 95 94 95 
EPS, Accessories ............................................................................................................ 52 80 80 96 
12V Stop-start ................................................................................................................. . 0 0 3 11 
Strong Hybrid .................................................................................................................. . 0 2 2 7 
Aero. Improvements ........................................................................................................ 46 80 80 98 
Mass Reduction (vs. No-Action) 
Mass Reduction (lb.) ........................................................................................................ 28 240 24 289 
Mass Reduction (percent of curb weight) ....................................................................... 0.43 3.6 3.7 4.3 
Technology Costs (vs. No-Action) 
Average Vehicle ($) ......................................................................................................... $50 0 $1470 $1480 $1890 
Payback Period (m) b...................................................................................................... 19 30 31 33 
Notes: 
aThis increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi) stringency projected by the model 
for the MY 2030 fleet under the final Phase 2 standards relative to the continuation of Phase 1 standards. Note that if manufacturers’ have ap-
plied mass reduction to an individual vehicle model in the CAFE ´model that this will increase the work factor of that vehicle in the model, and 
make the individual target less stringent. Thus, where any mass reduction is applied in the model, the total increase in stringency of the fleet pre-sented here will be lower than the total stringency increase of the fleet if no mass reduction were applied. 
bHere payback period is calculated using estimated undiscounted retail fuel savings and the initial technology costs for MY 2030 . 
Today’s Method A analysis using the 
updated version of the CAFE model and 
updated inputs shows that regulatory Alternatives 3 and 4 could be met with a small application of strong (P2) HEVs. However, Alternative 5 could be met with the considerably greater application of strong HEVs. Although there is some increase in the penetration rates between alternatives as stringency increases, the current analysis suggests that under all alternatives, nearly all of the MY 2030 heavy-duty fleet could use 8-speed transmissions, VVT/VVL improvements and turbo-charged engines with application across more than half of the fleet, direct injection could be present in a quarter of the fleet, and cylinder deactivation could play a minor part in the HD fleet. EPS and improved electrical accessories vary more between alternatives; present in 52 percent of the fleet in Alterative 2, 80 percent in Alternatives 3 and 4, and 96 percent in Alternative 5. Aerodynamic improvements and mass reduction follow a similar pattern; with a larger penetration of these technologies with Alternative 3 than with Alternative 2, a similar penetration under Alternatives 3 
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506The costs now use RPE rather than ICM, and 
we updated the mass reduction curve to the 2014 
Silverado. 
507Nominal effectiveness input values are as for 
the NPRM analysis. Synergy factors applied to adjust fuel consumption impacts for specific combinations of technologies reflect current vehicle simulation work conducted for NHTSA by Argonne National Laboratory. 508The final Phase 2 standard target curves 
increase in stringency by 16.2 percent compared to final Phase 1 standards, as discussed in section VI.B. and 4, and a higher in penetration in 
Alternative 5. 
A way to measure the cost- 
effectiveness of the technologies on consumers is to look at the payback period. In this context, the payback period is defined as the number of months of driving it will take a consumer to earn back the increased technology costs by the amount they save in fuel by driving a more fuel efficient vehicle. Under the current analysis, the average additional technology cost will payback in fuel savings in under 17 months for Alternative 2, 27 months for Alternatives 3 and 4, and 30 months for Alternative 5. It is important to note that there are inputs other than the cost and effectiveness of technologies which could affect the payback period; the fuel prices and mileage accumulation schedules will affect how quickly the cost of a fuel-saving technology pays back. 
The current analysis uses updated 
fuel price estimates from AEO 2015 that 
are lower than in the NPRM analysis. Lower fuel prices will decrease the absolute amount of fuel savings (assuming the same number of gallons is consumed) and increase the payback period if the technologies, their cost, and their effectiveness are unchanged. Further, we have updated the vehicle use schedule (vehicle miles traveled, or VMT) based on actual vehicle odometer readings from IHS/Polk data as shown in Figure VI.6 While the overall survival-weighted schedules show 6.5 percent fewer lifetime miles for heavy- duty vehicles, they show more annual miles driven for the first 5-years of use for heavy-duty vehicles. The result is that the overall lifetime fuel savings will decrease, but the fuel savings will be higher for the first 5 years. Since the payback periods under both analyses are shorter than 5 years, using the updated vehicle schedules will show a shorter payback period (if other factors are unchanged) than in the NPRM analysis. The changes in fuel prices and the change in the mileage accumulation schedule work in opposite directions on the payback period; the total change in payback period is attributable to both of these input changes as well as to the changes in the cost
506and 
effectiveness507of the different 
technology inputs, and the changes in the reference fleet. 
Industry costs in MY 2030 provide 
one perspective on technology costs. Industry cost in each model year provides additional perspective on the timing, pace and the amount of resources and spending that would need to be allocated to implement technologies and is important in the consideration of the feasibility of the alternatives. Figures Figure VI–15and 
Figure VI–16 show the total and average additional and total additional 
technology costs for the industry by model year and alternative. Note that the trend of the total and average costs are very similar, this is because the fleets size the AEO projections suggest a relatively constant fleet size during the considered MY’s. The total and average technology costs increase with alternative stringency. It is important to note that Alternatives 3 and 4 both increase total stringency for the MY 2030 industry fleet by 15.6 percent. Also note that these estimations of stringency increases include the model projections of how the application of mass reduction will alter work factor and individual vehicle targets.
508The 
annual average and total technology costs of Alternative 3 approach those of Alternative 4 by MY 2029 when both alternatives have reached maximum stringency. If manufacturers are to reach the same stringency level over a longer horizon, they will likely make similar technology choices, but be given longer to implement them. This will make the total technology costs lower, but should unsurprisingly make the marginal technology costs for model years where both standards have matured very similar. 
BILLING CODE 6560–50–P 
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The average incremental industry 
technology costs mature to around $500 
under Alternative 2, $1500 under Alternatives 3 and 4, and $1900 under Alternative 5. Figure VI–17 shows the cumulative total industry costs by model year fleet. $4.2 billion in additional technology costs for model years 2016–2030 are associated with Alternative 2, $9.9 billion with Alternative 3, $11.4 billion with Alternative 4, and $14.9 billion with Alternative 5. While the marginal technology costs of Alternative 3 approach those of Alternative 4 as the 
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1.8 
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Figure VI-15 Industry Total Technology Cost Increase by Model Year and Alternative 
---Alternative 2 - - -Alternative 3 • • • • • • Alternative 4 -• -Alternative 5 
2500 
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Figure VI-16 Industry Average Technology Cost Increase by Model Year and Alternative 73779 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
total stringencies converge, the total 
costs of Alternative 4 are $1.5 billion more by MY 2030. It is particularly noteworthy that costs and the rate of increase in costs would be significantly different in the MYs 2017–2021 timeframe among the alternatives. This identifies the significant differences in the resources and capital that would be required to implement the technologies required to comply with each of the alternatives during this period, as well as the reduction in lead time to implement the technologies which increases reliability risk. These 
differences are an important consideration for the feasibility of the alternatives and for the selection of the final standards, as discussed further below. 
BILLING CODE 6560–50–C 
(4) Manufacturer-Specific Results of 
Regulatory Alternatives 
In addition to varying across scenario 
and model year, the impacts of the standards vary across manufacturers. Manufacturers will have different compliance strategies based on which technologies they have already invested in, in both their heavy-duty and light- duty fleets, and based on the effectiveness of new technology applications specific to the vehicles in their heavy duty fleets. Table VI–14 summarizes the initial technology utilization in the 2015 fleet by manufacturer. Ford uses direct injection for 8 percent of their fleet, cylinder deactivation for 13 percent of their fleet, and turbo-charged engines for 8 percent 
of their fleet. Daimler has already invested to equip all of its fleet with 8- speed automatic transmissions. These differences in initial technology levels affect the new investments each manufacturer would need to further improve the fuel efficiency of their fleets. 
TABLE VI–14—S UMMARY OF MY 2015 R EFERENCE FLEET TECHNOLOGY PENETRATION  
Technology Technology Penetration 
(percent) 
GM Ford FCA Daimler Nissan Industry 
Cylinder Deactivation ............................... 0 0 13 0 0 2 
Direct Injection Engine ............................. 0 8 0 0 0 4 
Turbo Charged Engine ............................ 0 8 0 0 0 4 
8 Speed Auto. Trans. ............................... 0 0 0 100 0 3 
EPS, Accessories .................................... 0 0 0 0 0 0 
12V Stop-start .......................................... 0 0 0 0 0 0 
Strong Hybrid ........................................... 0 0 0 0 0 0 
Aero. Improvements ................................. 0 0 0 0 0 0 
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Table VI–15 summarizes the 
alternatives, and a technology pathway 
General Motors could use to comply with each of the alternatives. The pathway includes implementing 8 speed automatic transmissions across its entire fleet. For Alternatives 2 and 3, no stop- start or HEVs are added to GM’s fleet, 
for Alternative 4, 1 percent of GM’s fleet uses stop-start, and for Alternative 5, 2 percent uses stop-start and 13 percent are HEVs. For all alternatives, nearly all of the GM’s fleet would use electric power steering and improved electric accessories. 
For all alternatives, VVT/VVL is 
applied to 65 percent of its engines. For Alternative 2, none of its engines get direct injection and 43 percent get turbocharging and downsizing, while for Alternatives 3–5, direct injection is applied to 28 percent of its engines and turbocharging and downsizing is applied to 61 percent of its engines. For all alternatives, all of GM’s fleet gets 
aerodynamic improvements. The average mass reduction is 52 lbs. (0.78 percent of the average curb weight) under Alternative 2, and 350–380 lbs. (5.2–5.7 percent of the average curb weight) under Alternatives 3–5. Similar technology is applied for Alternatives 3 and 4 in MY 2030, but there are significantly more strong hybrids under Alternative 5. 
TABLE VI–15—S UMMARY IMPACTS ON GENERAL MOTORS HD F LEET BY ALTERNATIVE (VS. ALTERNATIVE 1b) 
Alternative 2 3 4 5 
Alternative Stringency 
Annual Increase in Stringency Beginning in MY 2021 .................................................... 2.0% 2.5% 3.5% 4.0% 
Increases Until ................................................................................................................. MY 2025 MY 2027 MY 2025 MY 2025 
Total Increase in MY 2030 Stringency Relative to Final Phase 1 Standardsa.............. 9.6% 15.2% 15.4% 17.7% 
Estimated Average Fuel Economy (miles per gallon) 
Required in MY 2030 ....................................................................................................... 18.69  19.92 19.96 20.53 
Achieved in MY 2030 ...................................................................................................... 18.70 20.04 20.04 20.6 
Average Fuel Consumption (gallons/100 miles) 
Required in MY 2030 ....................................................................................................... 5.35 5.02 5.01 4.87 
Achieved in MY 2030 ...................................................................................................... 5.35 4 .99 4.99 4.85 
Estimated Average Greenhouse Gas Emissions (grams per mile) 
CO 2Required in MY 2030 ............................................................................................... 498 467 466 4 53 
CO 2Achieved in MY 2030 .............................................................................................. 496 464 464 45 2 
Technology Penetration in MY 2030 (percent) 
VVT and/or VVL ............................................................................................................... 65 65 65 65 
Cylinder Deactivation ....................................................................................................... 0 0 0 0 
Direct Injection Engine ..................................................................................................... 0 28 28 28 
Turbo Charged Engine .................................................................................................... 33 61 61 61 
8 Speed Auto. Trans ....................................................................................................... 100 1 00 100 100 
EPS, Accessories ............................................................................................................ 100  100 100 100 
12V Stop-start ................................................................................................................. . 0 0 2 2 
Strong Hybrid .................................................................................................................. . 0 0 0 13 
Aero. Improvements ........................................................................................................ 100 1 00 100 100 
Mass Reduction (vs. No-Action) 
Curb Weight Mass Reduction (lb.) .................................................................................. 52 384 384 34 0 
Mass Reduction (percent of curb weight) ....................................................................... 0.78 5.7 5.7 5.1 
Note: 
aThis increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi) stringency projected by the model 
for the MY 2030 fleet under the final Phase 2 standards relative to the continuation of Phase 1 standards. Note that if manufacturers’ have ap-
plied mass reduction to an individual vehicle model in the CAFE ´model that this will increase the work factor of that vehicle in the model, and 
make the individual target less stringent. Thus, where any mass reduction is applied in the model, the total increase in stringency of the fleet pre-sented here will be lower than the total stringency increase of the fleet if no mass reduction were applied. 
Figure VI–18 and Figure VI–19 show 
the total and average incremental 
technology costs by alternative. Under Alternative 2 General Motors’ incremental technology cost is $140M in MY 2019, increasing to $180M in MY 2021. The pathways for Alternatives 3 and 4 are very similar, which again 
should not be surprising given that the standards result in the same total stringency increase in MY 2027 and 
beyond and the long redesign cycles in the segment. GM’s incremental technology cost is $190M in MY 2019, increasing to $400M in MY 2021, and $530M in MY 2028. Under Alternative 5 GM could have a similar compliance strategy as Alternative 3 and 4, but 
incremental technology cost is $650M in MY 2028. The highest annual average technology cost for GM is: $750 under 
Alternative 2, $1940 under Alternatives 3 and 4, and $2370 under Alternative 5. In the case of GM, the added lead time of Alternative 4 does not significantly change the cost of their compliance strategy. 
BILLING CODE 6560–50–P 
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Figure VI–20 shows the cumulative 
total incremental costs for GM under all 
alternatives. The total costs to comply with Alternative 2 for GM for MY’s 
2016–2030 is $2.1 billion, for Alternatives 3 and 4 it is $4.8 billion, and for Alternative 5 it is $5.2 billion. 
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700 
600 , ...... -
an s ID s ...... DO s s m s c g N en g g s an g ID ...... g g DO g m g c e 
N N N N N N N N N N N N N N N 
Model Year 
Figure VI-18 Total Technology Cost Increase for General Motors by Model Year and Alternative 
---Alternative 2 - - -Alternative 3 • • • • • • Alternative 4 -• -Alternative 5 
2500 
an s 
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Figure VI-19 Average Technology Cost Increase for General Motors by Model Year and Alternative 73782 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
BILLING CODE 6560–50–C 
Table VI–16 gives the same summary 
of a potential compliance strategy for 
Ford’s heavy-duty fleet. Similar to GM, to reach compliance Ford uses 8 speed automatic transmissions in their entire fleet. For Alternatives 3 and 4, Ford uses hybrid technologies in 4 percent of their fleet, and for Alternative 5, they use hybrid technologies in 7 percent of their fleet. In addition to strong hybrids, Ford uses 12v stop-start in 4 percent of their fleet in Alternative 4, and 12v stop-start in 19 percent of their fleet in Alternative 5. The compliance strategy in the NPRM analysis shows Ford using significantly more hybrids and 12v stop-start systems in Alternatives 4 and 5 than the current analysis which likely explains part of the lowered cost for Ford in the current analysis. 
Under the current analysis possible 
compliance strategy, the application of engine technologies for Ford come in discrete chunks, as with GM. Ford uses VVT/VVL in 58 percent of their fleet under all alternatives by MY 2030; they started with 8 percent direct-injection engines, and end with 27 percent; they also started with 8 percent turbo- charged engines, but end with 69 percent for all scenarios. The application of EPS and improved accessories vary across the compliance strategies of different regulatory alternatives; under Alternative 2, only 13 percent of Ford’s fleet improves these electrical features, while under Alternatives 3–4, 64 percent, and Alternative 5, 96 percent. 
For body-platform technologies, Ford 
applies in discrete chunks to the same platforms across some Alternatives. They apply an average of 77 lb. (1.2 percent) mass reduction across their fleet in Alternative 2 and 132–142 lb. (2.0–2.2 percent) in Alternative 3–5. Progressively less mass reduction is applied under Alternatives 4 and 5— this is likely because more of the fleet was hybridized and mass reduction to small platforms was no longer necessary to comply. Aerodynamic improvements are not applied in Alternative 2, but are applied to 64 percent of the fleet in Alternative 3 and 4, and to all of the fleet in Alternative 5. 
TABLE VI–16—S UMMARY OF IMPACTS ON FORD HD F LEET BY ALTERNATIVE (VS. ALTERNATIVE 1b) 
Alternative 2 3 4 5 
Alternative Stringency 
Annual Increase in Stringency Beginning in MY 2021 .................................... 2.0% 2.5% 3.5% 4.0% 
Increases Until ................................................................................................. MY 2025 MY 2027 MY 2025 MY 2025 
Total Increase in MY 2030 Stringency Relative to Final Phase 1 Standardsa 9.6% 15.7% 15.7% 18.1% 
Estimated Average Fuel Economy (miles per gallon) 
Required in MY 2030 ....................................................................................... 19.23 20.62 20.62 21. 23 
Achieved in MY 2030 ...................................................................................... 19.36 20.61 20.63 21.2 1 
Average Fuel Consumption (gallons/100 miles) 
Required in MY 2030 ....................................................................................... 5.2 4.85 4.85 4.71 
Achieved in MY 2030 ...................................................................................... 5.16 4.85 4.85 4.71 
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TABLE VI–16—S UMMARY OF IMPACTS ON FORD HD F LEET BY ALTERNATIVE (VS. ALTERNATIVE 1b)—Continued 
Alternative 2 3 4 5 
Estimated Average Greenhouse Gas Emissions (grams per mile) 
CO 2Required in MY 2030 ............................................................................... 488 456 455 443 
CO 2Achieved in MY 2030 .............................................................................. 485 455 455 443 
Technology Penetration in MY 2030 (percent) 
VVT and/or VVL ............................................................................................... 58 58 58 58 
Cylinder Deactivation ....................................................................................... 0 0 0 0 
Direct Injection Engine ..................................................................................... 27 27 27 27 
Turbo Charged Engine .................................................................................... 69 69 69 69 
8 Speed Auto. Trans ....................................................................................... 64 100 100 100 
EPS, Accessories ............................................................................................ 13 64 64 96 
12V Stop-start .................................................................................................. 0 0 4 19 
Hybridization .................................................................................................... 0 4 4 7 
Aero. Improvements ........................................................................................ 0 64 64 100 
Mass Reduction (vs. No-Action) 
Curb Weight Mass Reduction (lb.) .................................................................. 77 142 140 132 
Mass Reduction (percent of curb weight) ........................................................ 1.2 2.2 2.1 2.0 
Note: 
aThis increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi) stringency projected by the model 
for the MY 2030 fleet under the final Phase 2 standards relative to the continuation of Phase 1 standards. Note that if manufacturers’ have ap-
plied mass reduction to an individual vehicle model in the CAFE ´model that this will increase the work factor of that vehicle in the model, and 
make the individual target less stringent. Thus, where any mass reduction is applied in the model, the total increase in stringency of the fleet pre-sented here will be lower than the total stringency increase of the fleet if no mass reduction were applied. 
BILLING CODE 6560–50–P 
Figure VI–21 and Figure VI–22 show 
the total and average incremental 
technology costs for Ford by alternative and model year. Ford adds $80 million in technology costs for MY 2017 and an additional $40 million in MY 2026 in Alternative 2. For the Preferred Alternative, Ford adds $130 million in MY 2017 and an additional $300 million in MY 2026. Under Alternative 4, Ford adds $260 million in MY 2017 and $180 million in MY 2026. Similar to the industry pattern, Ford’s compliance strategy involves less annual technology costs early in Alternative 3 than Alternative 4, but their technology costs converge under the two alternatives as the final stringency level is reached under Alternative 3 in MY 2027. 
It is important to note that the 
increase in costs and rate of the increase in costs is significantly different for MY 2017 among the alternatives—with the incremental total cost increase for MY 2017 being double those of Alternative 3 for Alternative 4, and more than double for Alternative 5. MY 2017 is the first redesign year and Ford does not have another scheduled redesign until MY 2026. Under the additional lead time of Alternative 3, the majority of Ford’s cost increases occur in the MY 2026 redesign, while Alternatives 4 and 5 put most of the cost burden to reach compliance on the MY 2017 redesign (or would require an additional redesign be added between MY 2017 and 2026). 
NHTSA judges the lack of lead time 
would make Alternatives 4 and 5 beyond maximum feasibility for Ford because its designs for MY 2017 are essentially complete and substantial resources and very high costs would be required to add another vehicle redesign between MY 2017 and MY 2026 to implement the technologies that would be needed to comply with those alternatives. 
BILLING CODE 6560–50–P 
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Figure VI–23 below shows the 
cumulative total costs for Ford under all 
action alternatives. The total costs for MY’s 2015–2030 under Alternative 2 are $1.3 billion, under Alternative 3 they are $3.4 billion, for Alternative 4 they are $4.5 billion, and finally for Alternative 5 they are $6.7 billion. This further illustrates the point that manufacturers act to minimize costs over multiple model years. The added lead time from Alternative 4 allows them to delay some actions, which will allow them more time to make sure that they are well-implemented. 
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ER25OC16.028</GPH>mstockstill on DSK3G9T082PROD with RULES2---Alternative 2 - - - Alternative 3 • • • • • • Alternative 4 -• -Alternative 
700 
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c a 1ft s U) " s s DCI s en s c s s s s s 1ft g " s DCI g en s 
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Figure VI-21 Total Technology Cost Increase for Ford by Model Year and Alternative 
---Alternative 2 - --Alternative 3 • • • • • • Alternative 4 -• -Alternative 
1800 
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Model Year 
Figure VI-22 Average Technology Cost Increase for Ford by Model Year and Alternative 73785 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
BILLING CODE 6560–50–C 
Table VI–17 shows the MY 2030 
summary for Fiat/Chrysler. Fiat/ 
Chrysler is the only manufacturer which uses cylinder deactivation in their reference fleet, and they are the only manufacturer to use cylinder deactivation as a part of their possible compliance strategy. Under all scenarios, FCA increases their initial cylinder deactivation utilization of 13 percent to 24 percent. Under all scenarios turbo-charged engines are applied to 76 percent of FCA’s fleet by MY 2030. Other technologies are applied to the FCA equally across all scenarios; 37 percent of their fleet uses VVT and/or VVL, and 64 percent uses 8-speed automatic transmissions under all scenarios. 
The additional stringency from 
Alternative 2 to Alternatives 3–5 results in other increased technology applications in the FCA fleet. Under Alternatives 3–5, the presence of EPS/ electrical accessories increases from the 82 percent to the entirety of the FCA fleet. Similarly, increased aerodynamic improvements increase from 84 percent of the fleet to all of it. Finally, 12v stop- start enters 3 percent of the fleet under Alternatives 3–5. Alternatives 3 and 4 look much the same, except that Alternative 3 is the only alternative to use any (1 percent) SHEV–P2 hybrids. Alternative 5 uses twice as much mass reduction than Alternatives 3–4; it uses 37 percent direct injection versus the 24 percent in Alternatives 2–4. The resulting costs are comparable under Alternatives 3 and 4, and almost 50 percent higher under Alternative 5. 
TABLE VI–17—S UMMARY OF IMPACTS ON FIAT/CHRYSLER HD F LEET BY ALTERNATIVE (VS. ALTERNATIVE 1b) 
Alternative 2 3 4 5 
Alternative Stringency 
Annual Increase in Stringency Beginning in MY 2021 .................................... 2.0% 2.5% 3.5% 4.0% 
Increases Until ................................................................................................. MY 2025 MY 2027 MY 2025 MY 2025 
Total Increase in MY 2030 Stringency Relative to Final Phase 1 Standardsa 9.6% 15.8% 15.8% 17.6% 
Estimated Average Fuel Economy (miles per gallon) 
Required in MY 2030 ....................................................................................... 18.59 19.96 19.96 20. 41 
Achieved in MY 2030 ...................................................................................... 18.97 20.06 20.04 20.4 2 
Average Fuel Consumption (gallons/100 miles) 
Required in MY 2030 ....................................................................................... 5.38 5.01 5.01 4.9 
Achieved in MY 2030 ...................................................................................... 5.27 4.99 4.99 4.9 
Estimated Average Greenhouse Gas Emissions (grams per mile) 
CO 2Required in MY 2030 ............................................................................... 520 485 485 474 
CO 2Achieved in MY 2030 .............................................................................. 509 482 482 474 
Technology Penetration in MY 2030 (percent) 
VVT and/or VVL ............................................................................................... 37 37 37 37 
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TABLE VI–17—S UMMARY OF IMPACTS ON FIAT/CHRYSLER HD F LEET BY ALTERNATIVE (VS. ALTERNATIVE 1b)—Continued 
Alternative 2 3 4 5 
Cylinder Deactivation ....................................................................................... 24 24 24 24 
Direct Injection Engine ..................................................................................... 24 24 24 37 
Turbo Charged Engine .................................................................................... 76 76 76 76 
8 Speed Auto. Trans. ...................................................................................... 64 64 64 64 
EPS, Accessories ............................................................................................ 82 100 100 100 
12V Stop-start .................................................................................................. 0 3 3 3 
Hybridization .................................................................................................... 0 1 0 0 
Aero. Improvements ........................................................................................ 84 100 100 100 
Mass Reduction (vs. No-Action) 
Curb Weight Mass Reduction (lb.) .................................................................. 29 330 333 694 
Mass Reduction (percent of curb weight) ........................................................ 0.4 4.6 4.6 9.6 
Note:
aThis increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi) stringency projected by the model 
for the MY 2030 fleet under the final Phase 2 standards relative to the continuation of Phase 1 standards. Note that if manufacturers’ have ap-
plied mass reduction to an individual vehicle model in the CAFE ´model that this will increase the work factor of that vehicle in the model, and 
make the individual target less stringent. Thus, where any mass reduction is applied in the model, the total increase in stringency of the fleet pre-sented here will be lower than the total stringency increase of the fleet if no mass reduction were applied. 
Figures Figure VI–24 and Figure VI– 
25 show the incremental total and 
average technology costs for Chrysler/ Fiat by model year and regulatory stringency. Chrysler/Fiat shows more technology costs for higher stringency alternatives, with annual technology costs of Alternative 3 approaching Alternative 4 annual technology costs as the Alternative 3 approaches the final stringency level in MY 2027. Under all alternatives Chrysler/Fiat incurs increased technology costs starting in MY 2018 and MY 2025, because they are estimated redesign years. The 
maximum annual technology costs for Chrysler are $92M in Alternative 2, $213M in Alternative 3, $227M in 
Alternative 4, and $330M in Alternative 5. This results in average technology costs of: $680, $1640, $1690, and $2460, respectively. 
As with Ford, the costs and the rate 
of increase in costs are significantly different in the MY 2018 timeframe 
among the alternatives, because MY 2018 is the first estimated model year for redesign, and the next estimated redesign opportunity is in MY 2025. Figure identifies the significant differences in the resources and capital that would be required to implement the technologies required to comply with each of the alternatives—with the estimated MY 2018 technology cost 
increases being 48M under Alternative 3, 78M under Alternative 4, and 112M under Alternative 5. NHTSA judges the short lead time would make Alternatives 4 and 5 beyond maximum feasible for FCA because its designs for MY 2018 are nearing completion and substantial resources and very high costs would be required to add another vehicle redesign between MY 2018 and MY 2025 to implement the technologies that would be needed to comply with those alternatives. 
BILLING CODE 6560–50–P 
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The cumulative technology costs 
attributable to the action alternatives for 
FCA are represented in Figure VI–26 below. The total costs for MY’s 2016– 2030 under alter Alternative 2 are $750 million, under Alternative 3, they are $1.5 billion, for Alternative 4, $1.8 billion, and for Alternative 5 they are $2.6 billion. 
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ER25OC16.030</GPH>mstockstill on DSK3G9T082PROD with RULES2Ill Ill 
"' Ill ... u ---Alternative 2 - - -Alternative 3 • • • • • • Alternative 4 -• -Alternative 5 
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N N N N N N N N N N N N N N N N 
Model Year 
Figure VI-24 Total Technology Cost Increase for Fiat/Chrysler by Model Year and Alternative 
Ill 
!Ill Ill II ... u c ------Ah:ernatilre 2 - - -Ah:ernatilre 3 • • • • • • Ah:ernative: 4 -• • Ah:ernatilre 5 
3000 
0 
Model Year 
Figure VI-25 Average Technology Cost Increase for Fiat/Chrysler by Model Year and Alternative 73788 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
BILLING CODE 6560–50–C 
Table VI–18 shows the manufacturer- 
specific MY 2030 summary for Nissan. 
Nissan’s 2015 reference fleet uses VVT and/or VVL on all of their heavy-duty vehicles. Their fleet uses two engines on only one body-style platform. As a result, technologies applied to Nissan’s fleet are applied to large proportions of their fleet. Under all scenarios, their entire fleet gains 8-speed automatic transmissions. Under Alternatives 3–5, all of their fleet gets level-2 body-level aerodynamic improvements and all of their fleet gets electric accessory and/or EPS improvements. Under Alternatives 2, 4, and 5, one of Nissan’s two heavy- duty engines gets direct-injection, while under Alternative 3, both engines get the technology. Direct injection of their entire fleet is the most cost-effective 
way to reach compliance under Alternative 2, applying 5 percent mass reduction to their entire fleet and direct injection of one of their engines is the most cost-effective strategy under Alternative 4, and applying 10 percent mass reduction to their entire fleet, direct injection to one of their engines, and making their other engine hybrid is the most cost-effective strategy under Alternative 5. 
Note that without a change in the 
work factor or fleet mix, a manufacturer 
will face the same MY 2030 standard under Alternatives 3 and 4, and a more stringent standard under Alternative 5. However, by applying 5 percent mass reduction in Alternative 4, Nissan is able to reduce their standard by .27 MPG, and by applying 10 percent mass 
reduction in Alternative 5 to have the same MY 2030 standard under Alternatives 3 and 5. The result is that the CAFE level for Nissan is highest under Alternative 2, where direct injection of their entire fleet is the most cost-effective compliance strategy. We assume that manufacturers are able to make technologies more cost-effectively the longer they are on the market—this is called ‘‘learning.’’ A likely reason that the model prefers direct injection in Alternative 3 but not in Alternatives 4 and 5, is that the longer horizon of the stringency increase (until MY 2027) results in direct injection that is more cost-effective than the shorter time span of Alternatives 4 and 5. 
TABLE VI–18—S UMMARY OF IMPACTS ON NISSAN HD F LEET BY ALTERNATIVE (VS. ALTERNATIVE 1b) 
Alternative 2 3 4 5 
Alternative Stringency 
Annual Increase in Stringency Beginning in MY 2021 .................................... 2.0% 2.5% 3.5% 4.0% 
Increases Until ................................................................................................. MY 2025 MY 2027 MY 2025 MY 2025 
Total Increase in MY 2030 Stringency Relative to Final Phase 1 Standardsa 9.6% 16.2% 15.1% 16.2% 
Estimated Average Fuel Economy (miles per gallon) 
Required in MY 2030 ....................................................................................... 19.65 21.19 20.92 21. 19 
Achieved in MY 2030 ...................................................................................... 19.63 23.12 21.05 21.4 6 
Average Fuel Consumption (gallons/100 miles) 
Required in MY 2030 ....................................................................................... 5.09 4.72 4.78 4.72 
Achieved in MY 2030 ...................................................................................... 5.09 4.32 4.75 4.66 
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TABLE VI–18—S UMMARY OF IMPACTS ON NISSAN HD F LEET BY ALTERNATIVE (VS. ALTERNATIVE 1b)—Continued 
Alternative 2 3 4 5 
Estimated Average Greenhouse Gas Emissions (grams per mile) 
CO 2Required in MY 2030 ............................................................................... 452 419 425 420 
CO 2Achieved in MY 2030 .............................................................................. 453 384 422 414 
Technology Penetration in MY 2030 (percent) 
VVT and/or VVL ............................................................................................... 100 100 100 100 
Cylinder Deactivation ....................................................................................... 0 0 0 0 
Direct Injection Engine ..................................................................................... 51 100 51 51 
Turbo Charged Engine .................................................................................... 51 100 51 51 
8 Speed Auto. Trans. ...................................................................................... 100 100 100 100 
EPS, Accessories ............................................................................................ 37 100 100 100 
12V Stop-start .................................................................................................. 0 0 0 49 
Hybridization .................................................................................................... 0 0 0 0 
Aero. Improvements ........................................................................................ 0 100 100 100 
Mass Reduction (vs. No-Action) 
Curb Weight Mass Reduction (lb.) .................................................................. 0 0 307 615 
Mass Reduction (percent of curb weight) ........................................................ 0 0 5 10 
Note: 
aThis increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi) stringency projected by the model 
for the MY 2030 fleet under the final Phase 2 standards relative to the continuation of Phase 1 standards. Note that if manufacturers’ have ap-
plied mass reduction to an individual vehicle model in the CAFE ´model that this will increase the work factor of that vehicle in the model, and 
make the individual target less stringent. Thus, where any mass reduction is applied in the model, the total increase in stringency of the fleet pre-sented here will be lower than the total stringency increase of the fleet if no mass reduction were applied. 
Figures Figure VI–27 and Figure VI– 
28 show the total and average 
incremental technology costs for Nissan across the different regulatory alternatives. Nissan applies technology in all alternatives in MY 2021; this is a redesign year for much of their fleet. As might be expected, they incur less technology cost in less stringent scenarios at this redesign. However, under Alternative 3 they apply more technology in MY 2029, making their marginal technology costs under Alternative 3 for MY 2029 and after higher than the marginal technology costs under Alternative 4. They incur less technology costs in the early years 
and more in MY’s 2029 and beyond. In order to explain why the model predicts this action of Nissan it is useful to look at the cumulative total incremental costs in Figure VI–29. 
BILLING CODE 6560–50–P 
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By incurring less technology cost 
early, and more technology cost later, 
Nissan has a lower cumulative total cost for MY’s 2016–2030 under Alternative 3 than Alternative 4. The total cumulative cost for MY’s 2016–2030 of Alternative 2 is $86 million, $178 million for Alternative 3, $258 for Alternative 4, and $387 for Alternative 5. Since Nissan is trying to minimize their total cost under all model years, and not their marginal cost under any single model year, the model chooses a compliance strategy in this case which shows higher marginal costs for Nissan in Alternative 
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ER25OC16.032</GPH>mstockstill on DSK3G9T082PROD with RULES2Alternative 2 - --Alternative 3 • • •••• Alternative 4 -• 
50 
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Model Year 
Figure VI-27 Total Technology Cost Increase for Nissan by Model Year and Alternative 
91 
IV 
Gl ... u .5 --Alternative 2 - - -Alternative 3 • • • • • • Alternative 4 -• -Alternative 5 
3000 
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1.1'1 ID " oct en .-1 .-1 .-1 .-1 .-1 Q Q Q Q Q 
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en 
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Figure VI-28 Average Technology Cost Increase for Nissan by Model Year and Alternative 73791 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
3 than 4 for some model years, but lower cumulative total costs over all 
model years. 
BILLING CODE 6560–50–C 
Nissan’s first redesign is in MY 2020, 
and they do not have another redesign 
scheduled until 2029. Under Alternative 4 and 5 all of their technological application is done in MY 2020, but under Alternative 3 the application can be spread out between the two redesign cycles. NHTSA judges the short lead time to apply technology would make Alternatives 4 and 5 beyond maximum feasibility for Nissan because it puts the burden of all technological application on the MY 2020 redesign. Substantial resources and costs would be required 
to do so or to add another vehicle redesign between MY 2020 and MY 2029. Since manufacturers must spread out their capital for such deployment endeavors between the light and heavy duty fleets, the ability to spread costs between model years is important to consider. 
Table VI–19 shows a MY 2030 
summary for Daimler. Daimler came into the analysis with all of their fleet using 8-speed automatic transmissions. Their initial CAFE level in MY 2020 of 25.68 was sufficient to meet their 
standard under Alternatives 2–5. Their only action to turbo-charge all the engines in their fleet occurs in the dynamic baseline. As a result, no additional actions or costs are incurred under any of the alternatives. For this reason, a figure of their annual technology costs, nor their cumulative total technology costs has not been provided—if it were, it would be a horizontal line showing zero costs for all model years. 
TABLE VI–19—S UMMARY OF IMPACTS ON DAIMLER HD F LEET BY ALTERNATIVE (VS. ALTERNATIVE 1b) 
Alternative 2 3 4 5 
Alternative Stringency 
Annual Increase in Stringency Beginning in MY 2021 .................................... 2.0% 2.5% 3.5% 4.0% 
Increases Until ................................................................................................. MY 2025 MY 2027 MY 2025 MY 2025 
Total Increase in Stringency Relative to Final Phase 1 Standardsa.............. 9.7% 16.3% 16.3% 18.4% 
Estimated Average Fuel Economy (miles per gallon) 
Required in MY 2030 ....................................................................................... 22.88 24.69 24.69 25. 32 
Achieved in MY 2030 ...................................................................................... 25.68 25.68 25.68 25.6 8 
Average Fuel Consumption (gallons/100 miles) 
Required in MY 2030 ....................................................................................... 4.37 4.05 4.05 3.95 
Achieved in MY 2030 ...................................................................................... 3.89 3.89 3.89 3.89 
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TABLE VI–19—S UMMARY OF IMPACTS ON DAIMLER HD F LEET BY ALTERNATIVE (VS. ALTERNATIVE 1b)—Continued 
Alternative 2 3 4 5 
Estimated Average Greenhouse Gas Emissions (grams per mile) 
CO 2Required in MY 2030 ............................................................................... 445 413 412 402 
CO 2Achieved in MY 2030 .............................................................................. 396 396 396 396 
Technology Penetration in MY 2030 (percent) 
VVT and/or VVL ............................................................................................... 0 0 0 0 
Cylinder Deactivation ....................................................................................... 0 0 0 0 
Direct Injection Engine ..................................................................................... 0 0 0 0 
Turbo Charged Engine .................................................................................... 100 100 100 100 
8 Speed Auto. Trans. ...................................................................................... 100 100 100 100 
EPS, Accessories ............................................................................................ 0 0 0 0 
12V Stop-start .................................................................................................. 0 0 0 0 
Hybridization .................................................................................................... 0 0 0 0 
Aero. Improvements ........................................................................................ 0 0 0 0 
Mass Reduction (vs. No-Action) 
Curb Weight Mass Reduction (lb.) .................................................................. 0 0 0 0 
Mass Reduction (percent of curb weight) ........................................................ 0 0 0 0 
Note: 
aThis increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi) stringency projected by the model 
for the MY 2030 fleet under the final Phase 2 standards relative to the continuation of Phase 1 standards. Note that if manufacturers’ have ap-
plied mass reduction to an individual vehicle model in the CAFE ´model that this will increase the work factor of that vehicle in the model, and 
make the individual target less stringent. Thus, where any mass reduction is applied in the model, the total increase in stringency of the fleet pre-sented here will be lower than the total stringency increase of the fleet if no mass reduction were applied. 
(5) Summary of Consumer/Operator 
Impacts 
Table VI–20 summarizes the impacts 
of the regulation on the consumer/ operator of the heavy-duty vehicles. Consumers of more fuel efficient vehicles will benefit in several ways: They will spend less on fuel to operate vehicles for the same amount of travel, some will drive more because their per- mile travel costs less, and they will spend less time refueling vehicles. In order to estimate the fuel savings for each regulatory alternative, future gasoline prices must be predicted and the rebound effect (per-mile elasticity of operating a vehicle) must be assumed to account for the cost of additional driving. In the main analysis, the rebound effect is assumed to be 10 percent, so that, for example, a 10 percent reduction in the per-mile travel costs will result in a 1 percent increase in the amount of miles driven. Since the literature has also supported other rebound effects, NHTSA tests several sensitivity cases assuming different rebounds: 5 percent, 15 percent, and 20 percent. Based on the average miles driven of 2b/3 vans and trucks, the expected lifetime fuel savings for a heavy-duty vehicle under the preferred scenario is $3636. 
The other benefits of to the consumer 
of increasing fuel economy are increased mobility and a decreased amount of time spent refueling the vehicle. Because increasing the efficiency of a vehicle makes per-mile 
travel cheaper to the operator, consumers of these vehicles can travel more, at less than the total amount they are willing to pay—this increase in welfare that is not accounted for by the cost of travel is the consumer surplus. The estimated mobility benefit is $394 under the preferred alternative. The avoided time refueling also has a value. In order to estimate this value we make several assumptions outlined in more detail of the NPRM description of the model assumptions (Section E). Over the lifetime of a MY 2030 vehicle, we estimate the refueling surplus at $94 under the preferred alternative. 
It is also important to note that the 
average manufacturer costs will not be 
spread proportionally across the fleet— some vehicles will have incurred more technology costs than others. How manufacturers distribute costs among models will largely depend on the elasticity of particular models and the importance of fleet mix in meeting standards and on total profits. Without privy to this sort of information, we use average technology cost increase as a proxy for measuring the industry and consumer costs across different scenarios. The average technology cost increase is $1472 under the preferred alternative. We assume that all of this cost will be passed onto the consumer in the form of an increase in price. However, we also consider that an increase in price will have other costs 
to the operator of the vehicle. 
More expensive vehicles will have 
higher taxes/fees associated with their purchase, will be more expensive to insure (these costs are related to the purchase price or value of a vehicle) and will be more expensive to finance (higher loan values will be taken out which result in higher amounts paid in total interest). The total additional costs to the average consumer from the sum of these sources is $589 under the preferred alternative. It is important to keep in mind that the additional cost to finance a more expensive vehicle will have different effects depending on the budget constraint of the consumer. For consumers who are budget-constrained, they will finance more of the vehicle and the costs of financing will be higher for these already-constrained consumers. For consumers who do not have to finance the vehicle, there will be no costs—and therefore, no additional costs—to finance the vehicle. Since budget-constrained consumers likely have a more elastic demand for new vehicles, the increase in price and the heterogeneous increase in financing might work in the same direction to price proportionally more of the most budget-constrained consumers out of 
the new vehicle market. 
Considering all the costs and benefits 
the standards will have to the consumer, the result is a net benefit to the consumer under all the considered alternatives. The net benefit to the 
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consumer is $2,063 under the preferred 
alternative, higher than the net benefit under alternative 4. The payback period is another measure of the effect of the rule on consumers—for all alternatives the payback period is under 3 years— suggesting that consumers that own vehicles for at least 3 years will receive a net benefit from the preferred 
regulatory action. 
TABLE VI–20—S UMMARY OF CONSUMER /OPERATOR IMPACTS FOR MY 2030 ( VS. ALTERNATIVE 1b) 
Alternative 2 3 4 5 
Alternative Stringency 
Annual Increase ............................................................................................... 2.0% 2.5% 3.5% 4.0% 
Increases Until ................................................................................................. MY 2025 MY 2027 MY 2025 MY 2025 
Average Value of Lifetime Fuel Savings, $2013 (vs. No-Action) 
Pretax ............................................................................................................... $1,713 $3,256 $3,229 $3,804 
Tax ................................................................................................................... 200 381 377 448 
Total .......................................................................................................... 1,913 3,636 3,607 4,252 
Average Value of Additional Economic Benefits, $2013 (vs. No-Action) 
Mobility Increase .............................................................................................. 220 394 390 453 
Avoided Refueling ............................................................................................ 49 94 93 112 
Average New Vehicle Purchase (vs. No-Action) 
Price Increase ($) ............................................................................................ 496 1,472 1,481 1 ,893 
Additional Costs ($)a....................................................................................... 103 306 336 393 
Payback (months)b.......................................................................................... 20 33 33 38 
Net Lifetime Consumer/Operator Benefits (vs. No-Action) 
Total Net Benefit ($) ........................................................................................ 1,488 2,063 1,989 2,167 
Notes: 
aAdditional Costs include additional taxes, fees, maintenance costs, financing costs, and insurance costs incurred under the regulatory alter-
natives. 
bThe payback period from the consumer perspective uses a 7% discount rate of retail fuel savings starting at the time of purchase. The cost 
increases paid back include: Technology costs, maintenance costs, taxes, and fees. 
(6) Summary of Societal Impacts 
Table VI–21 summarizes the overall 
societal impacts of the regulation under 
different scenarios (relative to the 1b 
baseline). Net social benefits increase with the stringency of the standards. The net benefits for the preferred alternative are $18.8 billion. The largest benefit of the program comes in the 
form of fuel savings. The fuel savings reported above do not include fuel tax savings, as taxes are considered a transfer, and not a loss, of societal well- being. The fuel savings are associated with a fuel security externality, which monetizes the economic risk associated with potential fuel price spikes—as fewer gallons of oil are necessary for transportation, this risk decreases. The carbon externality represents the reduced cost of carbon damage when fuel economy increases (and carbon emissions decrease), and is also related directly with fuel savings. 
TABLE VI–21—S UMMARY OF LIFETIME TOTAL SOCIETAL IMPACTS OF MY’ S2015–2029 ( VS. ALTERNATIVE 1b) 
Alternative 2 3 4 5 
Alternative Stringency 
Annual Increase ............................................................................................... 2.0% 2.5% 3.5% 4.0% 
Increases Until ................................................................................................. MY 2025 MY 2027 MY 2025 MY 2025 
Fuel Purchases vs. No-Action (billion 2013$) 
Pretax Savings ................................................................................................. $11.1 $17.8 $20. 2 $22.7 
Fuel-Related Externalities vs. No-Action (billion 2013$) 
Energy Security ............................................................................................... 0.7 1.2 1.4 1.5 
CO 2Emissions ................................................................................................. 2.4 3.8 4.4 4.9 
VMT-Related Externalities vs. No-Action (billion 2013$) 
Driving Surplus ................................................................................................ 1.3 2.0 2.3 2.5 
Refueling Surplus ............................................................................................ 0.3 0.6 0.6 0.7 
Congestion ....................................................................................................... ¥0.3 ¥0.5 ¥0.5 ¥0.6 
Crashes ............................................................................................................ ¥0.2 ¥0.2 ¥0.3 ¥0.3 
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TABLE VI–21—S UMMARY OF LIFETIME TOTAL SOCIETAL IMPACTS OF MY’ S2015–2029 ( VS. ALTERNATIVE 1b)— 
Continued 
Alternative 2 3 4 5 
Noise ................................................................................................................ 0.0 0.0 0.0 0.0 
Fatalities ........................................................................................................... ¥0.7 ¥0.3 ¥0.4 0.7 
Criteria Emissions ............................................................................................ 0.7 1.2 1.4 1.5 
Vehicle Purchase/Operating Costs vs. No-Action (billion 2013$) 
Technology Costs ............................................................................................ 2.9 6.5 7.7 10.2 
Maintenance Costs .......................................................................................... 0.1 0.3 0.3 0.5 
Cost-Benefit Summary vs. No-Action (billion 2013$) 
Total Social Cost ............................................................................................. 4.2 7.8 9.2 11.6 
Total Social Benefit .......................................................................................... 16.5 26.6 30.3 34.5 
Net Social Benefit ............................................................................................ 12.3 18.8 21.1 22.9 
Increasing fuel economy decreases the 
cost of per-mile travel. Since this 
reduction in the cost of travel results in an increase of total travel, it also results in an increase of externalities associated with increased total VMT. Of these, the driving surplus represents the societal net increase in benefit from increased mobility consumer surplus—the sum of the benefit to all operators of increased travel which is not captured by the total cost of travel. Defined from the societal perspective, the refueling benefit is the sum of all the value of the time saved on refueling by increasing the average fuel efficiency of the heavy duty fleet. Congestion represents the societal cost of increases in congestion on the roads—the lost value of additional time spent in traffic. The crash externality is the cost of the damage done by the additional crashes that will happen with more VMT exposure, and the noise externality represents the cost of a change in noise related to increases in vehicle travel (in this analysis, it is negligible for all alternatives). 
Some VMT-related externalities are 
not always positive or negative, but depend on the stringency of the standards. For this analysis the criteria pollutant externality is always a benefit, but this need not be the case. Reduction in overall fuel consumed reduces emissions associated with production and distribution of fuels. Increases in VMT will result in more emission of vehicle criteria pollutants and more associated damages. However, increasing fuel-economy though vehicle technologies, such as aerodynamics, mass reduction and improved tire rolling resistance, will result in a decrease in vehicle emissions of and damages from criteria pollutants. Shifts in technologies towards electric and hybrid-electric alternatives can increase the emissions of certain pollutants, and reduce the emissions of others. The stringency increases considered in the heavy-duty analysis do not require these technologies to penetrate the market at such a level that this is visible in the results. For these reasons the externality associated with changes in criteria pollutant emissions is always positive for this analysis. 
The vehicle mass reduction in HD 
pickup and vans is estimated to reduce the net incidence of highway fatalities. By reducing mass on some HD pickup and vans, the fatality rate associated with crashes involving at least one HD pickup or van vehicles decreases. However, the analysis anticipates that the indirect effect of the proposed standards, by reducing the operating costs, would lead to increased travel by HD pickups and vans and, therefore, more crashes involving these vehicles. The sign of the fatality externality varies with the stringency of the standards. Over the lifetime of MY’s 2016–2029, for Alternative 2 it is estimated approximately 120 additional fatalities could occur relative to the 30,200 heavy-duty crash-related fatalities in the baseline. For Alternatives 3 and 4 we estimate approximately 50 additional fatalities relative to the no-action alternative. The additional risk of fatality is represented as a social cost in Alternatives 2–4. For Alternative 5 we estimate approximately 110 fewer fatalities (represented as a positive externality). For Alternatives 2–4, the effect of removing mass from the heavier vehicles is less than the effect of increased VMT-exposure; for Alternative 5, it is larger, and the alternative could result in a decrease of fatalities. 
The major direct costs of the program 
are increased technology costs and costs associated with the resultant increase in new vehicle prices and changes in technologies. The sum of technology costs across the industry increase under all increases of stringency, as do the increases in associated additional costs. Additional costs include: additional costs of maintenance associated with certain technologies. These costs will mostly be borne by the consumer, and paid back in the form of fuel savings. 
(7) Summary of Environmental Impacts 
In addition to modeling the societal 
impacts from a monetary standpoint, the 
CAFE model also considers the absolute change in the physical emissions of various criteria pollutants across the Alternatives. Table VI–22 summarizes the total environmental impacts from increased fuel efficiency of MYs 2016– 2030, taking into consideration the reduction in emissions from increased efficiency, the additional emissions associated with the increased VMT from cheaper per-mile travel, and changes in emissions due to the production and distribution of heavy-duty vehicles. Across all scenarios, the absolute reduction in emissions increases. For context, the percentage change of emissions relative to the baseline emission levels is also provided. The proportional reduction in criteria pollutants greatly varies; the greenhouse gases—carbon dioxide, methane, and nitrous oxide—as well as the criteria pollutants—sulfur dioxide and diesel particulate matter—show the largest proportional reductions across all scenarios. 
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509Available at http://www.whitehouse.gov/omb/ 
circulars_ a004_ a-4/. TABLE VI–22—S UMMARY OF LIFETIME EMISSION IMPACTS OF MY’ S2015–2029 ( VS. ALTERNATIVE 1b) 
Alternative 2 3 4 5 
Annual Increase ............................................................................................... 2.0% 2.5% 3.5% 4.0% 
Increases Until ................................................................................................. MY 2025 MY 2027 MY 2025 MY 2025 
Greenhouse Gas Emissions Reductions vs. No-Action 
CO 2(mmt) ........................................................................................................ 66 107 120 135 
CH 4and N 2O (tons) ......................................................................................... 97,925 160,044 180,557 202,666  
Greenhouse Gas Emissions Percent Reduction vs. No-Action 
CO 2.................................................................................................................. 3.8% 6.1% 6.9% 7.7% 
CH 4and N 2O ................................................................................................... 0.7% 1.2% 1.3% 1.5% 
Other Emissions Absolute Reduction vs. No-Action 
CO (tons) ......................................................................................................... 13,747 22,828  26,375 29,589 
VOC and NO X(tons) ....................................................................................... 33,324 56,100 63,237 70,957 
PM25 (tons) ..................................................................................................... 1,320 2,213 2,4 98 2,806 
SO2(tons) ........................................................................................................ 10,713 17,877 20, 172 22,669 
Air Toxics (tons) ............................................................................................... 53 75 84 94 
Diesel PM 10(tons) ........................................................................................... 2,357 3,944 4,450 5,004 
Other Emissions Percent Reduction vs. No-Action 
CO .................................................................................................................... 0.2 0.4 0.4 0.5 
VOC and NO X................................................................................................. 1.6 2.8 3.1 3.5 
PM25 ................................................................................................................ 1.9 3.3 3.7 4.1 
SO2.................................................................................................................. 3.7 6.2 6.9 7 .8 
Air Toxics ......................................................................................................... 0.2 0.2 0.2 0.3 
Diesel PM 10...................................................................................................... 3.5 5.8 6.5 7.3 
(8) Sensitivity Analysis Evaluating 
Different Inputs to the NHTSA CAFE Model 
This section describes some of the 
principal sensitivity results, obtained by running the various scenarios describing the policy alternatives with alternative inputs. OMB Circular A–4 indicates that ‘‘it is usually necessary to provide a sensitivity analysis to reveal whether, and to what extent, the results of the analysis are sensitive to plausible changes in the main assumptions and numeric inputs.’’
509Considering this 
guidance, a number of sensitivity analyses were performed using analysis Method A to examine important assumptions and inputs, including the following, all of which are discussed in greater detail in the accompanying RIA: 
1. Payback Period: In addition to the 
0 and 6 month payback periods discussed above, also evaluated cases involving payback periods of 12, 18, and 24 months. 
2. Fuel Prices: Evaluated cases 
involving fuel prices from the AEO 2015 low and high oil price scenarios. (See AEO-Low and AEO-High in the tables). 
3. Fuel Prices and Payback Period: 
Evaluated one side case involving a 0 month payback period combined with 
fuel prices from the AEO 2015 low oil price scenario, and one side case with 
a 24 month payback period combined with fuel prices from the AEO 2014 high oil price scenario. 
4. Benefits to Vehicle Buyers: The 
main Method A analysis assumes there is no loss in value to owner/operators resulting from vehicles that have an increase in price and higher fuel economy. NHTSA performed this sensitivity analysis assuming that there is a 25, or 50 percent loss in value to owner/operators—equivalent to the assumption that owner/operators will 
only value the calculated benefits they will achieve at 75, or 50 percent, respectively, of the main analysis estimates. (These are labeled as 75pctOwner/Operator Benefit and 50pctOwner/Operator Benefit.) 
5. 7 Pct Discount Rate: The main 
analysis results are considered using either a 0 or 3 percent discount rate. We also considered an alternative case where future savings/costs are discounted 7 percent annually. 
6. Value of Avoided GHG Emissions: 
Evaluated side cases involving lower and higher valuation of avoided CO
2 
emissions, expressed as the social cost of carbon (SCC). 
7. Rebound Effect: Evaluated side 
cases involving rebound effect values of 5 percent, 15 percent, and 25 percent. (These are labeled as 05PctReboundEffect, 15PctReboundEffect and 
25PctReboundEffect). 
8. ICM-based Markup: Evaluated a 
side case using a retail price equivalent (ICM) markup factor. 
9. Mass-Safety Effect: Evaluated side 
cases with the mass-safety impact 
coefficient at the values defining the 5th and 95th percent points of the confidence interval estimated in the underlying statistical analysis. (These are labeled MassFatalityCoeff05pct and MassFatalityCoeff95pct). 
10. VMT Schedules: Evaluated side 
cases considering the NHTS considered in the NPRM analysis as a high-VMT case, and another considered schedule as a low-VMT case. 
11. Strong HEVs: Evaluated a side 
case in which strong HEVs were excluded from the set of technology estimated to be available for HD pickups and vans through model year 2030. As in Section VI.C. (8), this ‘‘no SHEV’’ case allowed turbocharging and downsizing on all GM vans to provide a lower-cost path for compliance. 
Table VI–23, below, summarizes key 
metrics for each of the cases included in the sensitivity analysis using Method A for the alternative. The table reflects the percent change in the metrics (columns) relative to the main analysis, due to the particular sensitivity case (rows) for the alternative 3. For each sensitivity run, the change in the metric can we 
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described as the difference between the 
baseline and the preferred alternative for the sensitivity case, minus the difference between the preferred alternative and the baseline in the main analysis, divided by the difference between the preferred alternative and 
the baseline in the main analysis. Or, 
Each metric represents the sum of the 
impacts of the preferred alternative over 
the model years 2015–2029, and the percent changes in the table represent percent changes to those sums. More detailed results for all alternatives are available in the accompanying RIA 
Chapter 10. 
TABLE VI–23—S ENSITIVITY ANALYSIS RESULTS FROM CAFE M ODEL IN THE HD P ICKUP AND VANMARKET SEGMENT  
USING METHOD A ANDVERSUS THE DYNAMIC BASELINE , ALTERNATIVE 1b 
[2.5% growth in stringency: Cells are percent change from base case]a 
Sensitivity case Fuel savings 
(gallons) 
(%) CO 2savings 
(MMT) 
(%) Fuel savings 
($) 
(%) Social costs 
($billion) 
(%) Social benefits 
($billion) 
(%) Social net 
benefits 
($billion) 
(%) 
0 Month Payback ..................................... 8.4 8.0 7.7 8.0 7.8 7.7 
12 Month Payback ................................... ¥13 ¥14 ¥15 ¥2.8 ¥14 ¥19 
18 Month Payback ................................... ¥30 ¥31 ¥32 ¥16 ¥31 ¥38 
24 Month Payback ................................... ¥47 ¥47 ¥48 ¥32 ¥48 ¥54 
AEO-Low .................................................. ¥5.4 ¥5.8 ¥31 ¥19 ¥26 ¥29 
AEO-High ................................................. ¥27 ¥28 18 ¥2.8 13 20 
AEO-Low, 0 Month Payback ................... 35 33 33 42 34 30 
AEO-High, 24 Month Payback ................. ¥50 ¥50 ¥51 ¥37 ¥51 ¥57 
7pct Discount Rate .................................. 0.0 0.0 ¥41 ¥31 ¥35 ¥37 
50pct Owner/Operator Benefit ................. 0.0 0.0 ¥50 0.0 ¥34 ¥48 
75pct Owner/Operator Benefit ................. 0.0 0.0 ¥25 0.0 ¥17 ¥24 
Low SCC .................................................. 0.0 0.0 0.0 0.0 ¥11 ¥16 
High SCC ................................................. 0.0 0.0 0.0 0.0 8.2 12 
Very High SCC ........................................ 0.0 0.0 0.0 0.0 30 43 
5pct Rebound ........................................... 4.6 4.6 4.6 ¥13 0.37 5.5 
15pct Rebound ......................................... ¥4.6 ¥4.6 ¥4.6 12 ¥0.37 ¥5.5 
25pct Rebound ......................................... ¥14 ¥14 ¥14 37 ¥1.1 ¥17 
5th Percentile Mass Fatality Coefficient .. 0.0 0.0 0.0 ¥11 0.0 4.6 
95th Percentile Mass Fatality Coefficient 0.0 0.0 0.0 15 0.0 ¥6.0 
No SHEV–P2’s ......................................... 0.18 0.29 0.29 ¥1.3 0.26 0.88 
Non-CO 2eq GHG Values ......................... 0.0 0.0 0.0 0.0 0.0 0.0 
ICM-Based Mark-Up ................................ ¥5.7 ¥6.0 ¥6.1 ¥16 ¥6.0 ¥1.8 
High VMT ................................................. 8.6 7.4 5.9 0.11 6.2 8.7 
Low VMT .................................................. ¥7.7 ¥8.3 ¥8.0 ¥14 ¥7.8 ¥5.4 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the less dynamic baseline, 1a, and more dy-
namic baseline, 1b, please see Section X.A.1. 
For some of the cases for which 
results are presented above, the 
sensitivity of results to changes in inputs is simple, direct, and easily observed. For example, changes to valuation of avoided GHG emissions impact only this portion of the estimated economic benefits; manufacturers’ responses and corresponding costs are not impacted. Similarly, a higher discount rate does not affect physical quantities saved (gallons of fuel and metric tons of CO
2 
in the table), but reduces the value of the costs and benefits attributable to these standards in an intuitive way. Higher rebound results in fewer 
volumetric fuel savings and social net benefits, as drivers are assumed to be more responsive in their driving habits to changes in the cost per mile of travel. Some other cases warrant closer consideration: 
First, cases involving alternatives to 
the reference case involving voluntary over compliance of technologies that pay back in six-months involve different degrees of fuel consumption improvement. Increasing the length of the payback period assumption for voluntary over compliance amounts to increasing fuel economy improvements in the absence of the rule (the baseline), and manufacturers are compelled to add less technology in order to comply with the standards (in the regulatory alternatives). Because all estimated impacts of these standards are shown as incremental values relative to this baseline, longer voluntary over compliance payback periods correspond to smaller estimates of incremental impacts. 
Table VI–24 shows the effect of 
varying the voluntary over compliance assumption from the consumer perspective. The baseline over- compliance payback period is as described above—the number of months within which a technology must pay back to the consumer in the form of undiscounted retail fuel savings for a manufacturer to voluntarily apply that technology without regulatory action. The incremental per-vehicle technology cost is the average additional cost of technology applied to MY 2030 vehicles under the final regulation (incremental to the baseline) of each sensitivity case. The per-vehicle lifetime fuel savings is 
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510This is based on the VMT schedules of average 
miles driven by age of MDHD pickups and vans and 
AEO fuel price projections. the average lifetime retail value of fuel 
savings under each sensitivity case discounted at 7 percent annually starting at the time of purchase (MY 2030). Compliance payback period is the number of months of ownership it would take the average consumer to recoup the additional technology costs in discounted fuel savings.
510 As can be seen, the baseline voluntary 
over compliance assumption changes 
how much of the technology costs and fuel savings are attributed to the regulation; both fewer fuel savings and fewer technology costs are attributed to the regulatory alternative as the payback period defining voluntary over compliance increases. Further, because the model only applies the technologies with the shortest payback periods (the 
most cost-effective technologies) in the baseline, the fuel savings decrease at a greater proportion than the technology costs. The result is that the payback period of the regulatory alternative increases (and at an increasing rate) as manufacturers are assumed to apply more technology in the baseline. 
TABLE VI–24—S ENSITIVITY ANALYSIS OF THE VOLUNTARY OVERCOMPLIANCE ASSUMPTION ON COMPLIANCE PAYBACK  
PERIOD AND KEYCONSUMER IMPACTS FOR THE MY 2030 MDHD F LEET 
Baseline over-compliance payback 
(months) Incremental 
per-vehicle 
technology 
cost Per-vehicle 
lifetime 
fuel savings Technology 
cost payback 
period 
(months)a 
0 .............................................................................................................................. ..................... $1,471 $3,966 28 
6 .............................................................................................................................. ..................... 1,472 3,636 31 
12 ............................................................................................................................. .................... 1,317 3,031 33 
18 ............................................................................................................................. .................... 1,214 2,556 38 
24 ............................................................................................................................. .................... 944 1,684 45 
Note: 
aHere the payback calculation uses a 7% discount rate of retail fuel savings starting at the time of purchase and only considers the additional 
costs of technology application. 
Cases involving different fuel prices 
similarly involve different degrees of 
fuel economy improvement in the absence of the standard, as more, or less, improvement occurs as a result of more, 
or fewer, technologies appearing cost effective to owner/operators. Low fuel prices change the amount of fuel savings for each technology, since the choice in technology application also involves both the size of the cost and the fuel savings, lower fuel prices can change the rank of the technologies. Under low fuel prices, the model applies fewer SHEV–P2’s. The result is a reduction in volumetric fuel savings, and an even larger reduction in monetary fuel savings, because the fuel savings are worth less. There is also a reduction in social costs, and social net benefits. Higher fuel prices correspond to reductions in the volumetric fuel savings attributable to these standards as, but lead to increases in the value of fuel saved (and net social benefits) because each gallon saved is worth more when fuel prices are high. 
The low price and 0-month payback 
case leads to a significant increase in volumetric savings compared to the main analysis. Note that the fuel savings are higher than in the 0-month payback case alone. Part of the reason for this is that the lower fuel price case takes into consideration that when fuel prices are lower, consumers buy more heavy-duty vehicles (this is estimated from the AEO2015 low fuel price case). Another 
piece of the explanation is that the lower fuel prices result in a different technology cost-effectiveness ranking of technologies, and that the 0 month 
payback baseline results in no voluntary over compliance in the baseline. Different technologies are picked than in the 0 month pay back sensitivity alone, and the most cost effective that would have been applied in the baseline, are now attributed to the preferred alternative. Similarly, the high price and 24-month payback case results in large reductions to volumetric savings that can be attributed to these standards because more is applied in the baseline. Further, the presence of high fuel prices is not sufficient to lead to increases in either the dollar value of fuel savings or net social benefits. 
The case which involves the VIUS- 
based VMT schedules (the high VMT case) results in greater volumetric fuel and GHG-savings attributable to the standards. Under this case the higher estimate of VMT results in more fuel consumption in the baseline, and a higher absolute change in fuel consumption when fuel-saving technologies are applied in the preferred alternative. These higher amount of gallons saved, results in more monetary fuel savings, comparable social costs, and an increase in overall net social benefits attributed to the standards. The low-VMT schedule, developed as an alternative to the adopted VMT- schedule from the IHS/Polk odometer readings, results in lower volumetric fuel consumption and GHG reductions under the preferred alternative. Lower VMT estimates result in less fuel consumption in the baseline, and a lower absolute change in fuel consumption under the preferred alternative. This schedule attributes lower costs to the standards—the lower fuel savings under the low-VMT schedule changes the technology application decisions of the model, since fewer fuel savings are considered in measure the cost-effectiveness of technologies. The result is lower absolute technology costs, but also lower social net benefits. 
The case which makes SHEV–P2’s 
unavailable involves relatively small increases to volumetric fuel savings and CO
2reductions—not surprising, since 
SHEV–P2’s play only a minor role in the compliance strategy of the preferred alternative in the Method A central analysis. These small increases in fuel savings are associated with small increases in social benefits, slightly larger proportional increases in social costs, but still result in a small increase in social net benefit. 
The case that uses the ICM mark-up 
methodology rather than the RPE methodology results in a reduction of volumetric fuel savings and GHG reductions. The reduction in fuel 
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51149 U.S.C. 32902(k)(2). 512These Alternatives are defined in Section C(6). savings is accompanied by a reduction 
in monetary fuel savings, social benefits, social costs, and social net benefits. This is likely due to shifts in technology applications due to different costs mark- ups associated with different types of technologies under the ICM mark-up methodology. 
If, instead of using the values in the 
main analysis, each sensitivity case were itself the main analysis, the costs 
and benefits attributable to the final rule will be as they appear in Table VI–25, below. 
TABLE VI–25—C OSTS AND BENEFITS OF STANDARDS FOR MY 2015–2029 HD P ICKUPS AND VANSUNDER ALTERNATIVE  
ASSUMPTIONS  
Sensitivity case Fuel savings 
(billion gallons) CO 2 
reduction 
(MMT) Fuel savings 
($billion) Social costs 
($billion) Social 
benefits 
($billion) Net social 
benefits 
($billion) 
6 Month Payback ..................................... 9.2 110 18 7.8 27 19 
0 Month Payback ..................................... 10 120 19 8.2 28 20 
12 Month Payback ................................... 8.0 92 15 7.3 22 15 
18 Month Payback ................................... 6.4 74 12 6.4 18 12 
24 Month Payback ................................... 4.9 56 9.3 5.2 14 8.5 
AEO-Low .................................................. 8.7 100 12 6.1 19 13 
AEO-High ................................................. 6.7 77 21 7.3 30 22 
AEO-Low, 0 Month Payback ................... 12 140 24 11 35 24 
AEO-High, 24 Month Payback ................. 4.7 53 8.8 4.8 13 8.0 
7pct Discount Rate .................................. 9.2 110 11 5.2 17 12 
50pct Owner/Operator Benefit ................. 9.2 110 8.9 7.5 17 9.7 
75pct Owner/Operator Benefit ................. 9.2 110 13 7.5 22 14 
Low SCC .................................................. 9.2 110 18 7.5 23 16 
High SCC ................................................. 9.2 110 18 7.5 28 21 
Very High SCC ........................................ 9.2 110 18 7.5 34 27 
5pct Rebound ........................................... 9.7 110 19 6.6 26 20 
15pct Rebound ......................................... 8.8 100 17 8.5 26 18 
25pct Rebound ......................................... 8.0 92 15 10 26 16 
5th Percentile Mass Fatality Coefficient .. 9.2 110 18 6.7 26 19 
95th Percentile Mass Fatality Coefficient 9.2 110 18 8.7 26 18 
No SHEV–P2’s ......................................... 9.3 110 18 7.5 26 19 
Non-CO 2eq GHG Values ......................... 9.2 110 18 7.5 26 19 
ICM-Based Mark-Up ................................ 8.7 100 17 6.3 25 18 
High-VMT ................................................. 10 110 19 7.6 28 20 
Low-VMT .................................................. 8.5 98 16 6.5 24 18 
(9) Discussion of the Maximum 
Feasibility of the Adopted Standards 
As noted above, EPCA and EISA 
require NHTSA to ‘‘implement a commercial medium- and heavy-duty on-highway vehicle and work truck fuel efficiency improvement program designed to achieve the maximum feasible improvement’’ and to establish corresponding fuel consumption standards ‘‘that are appropriate, cost- effective, and technologically feasible.’’
511In order to determine 
which of the regulatory alternatives meets the requirements of the statute NHTSA has considered both the modeling results of ‘‘Method A’’ and comments offered on the proposed rulemaking. 
(a) Consideration of Modeling Results 
For both the NPRM and the current 
analysis of potential standards for HD 
pickups and vans, NHTSA applied NHTSA’s CAFE Compliance and Effects Modeling System (sometimes referred to as ‘‘the CAFE model’’ or ‘‘the Volpe model’’), which DOT’s Volpe National Transportation Systems Center (Volpe Center) developed, maintains, and applies to support NHTSA CAFE analyses and rulemakings. NHTSA used this model in its Method A analysis to evaluate regulatory alternatives for Phase 2 standards applicable to HD pickups and vans, and used results of this analysis to inform its selection of the regulatory alternative that will achieve the maximum feasible improvement in HD pickup and van fuel efficiency. This analysis includes several updates to the model and to accompanying inputs, as discussed above in this section. 
In the proposal, the agencies proposed 
to adopt Alternative 3 from among the five regulatory alternatives under consideration.
512As discussed in the 
NPRM, the agencies found that Alternative 2 would unduly forego significant fuel savings and avoided GHG emissions, and that Alternative 5 could involve rapid and early cost increases and necessitate significant application of the most advanced technologies considered by the agencies. 80 FR 40494–40495. The agencies have estimated the cost and efficacy of fuel- saving technologies assuming 
performance and utility will be held constant or improved. In particular, we have assumed payload will be preserved (and possibly improved via reduced vehicle curb weight); however, some fuel-saving technologies, such as hybrid electric vehicles, could reduce payload via increased curb weight (due to the added electrical machine, batteries and controls, and because of the physical size of those components). If the increase in weight from the hybrid system is not offset with a weight reduction elsewhere in the vehicle, the payload capability will be reduced resulting in lost utility but also an increase in stringency due to changes in work factor. Further, it is also possible 
that applications such as vans where the advanced technologies of downsized gasoline and diesel engines could be used in conjunction with strong hybridization, extended high power demand resulting from a vehicle at full payload or towing, certain types of hybrid powertrains could experience a temporary loss of towing capacity if the capacity of the hybrid’s energy storage device (e.g., batteries, hydraulic 
accumulator) is insufficient for the 
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extended power demand required to 
maintain expected vehicle speeds. 
The Method A analysis shows in the 
short term, MY 2017–2021 timeframe, that there are significant differences in the rate at which technologies would need to be applied among the alternatives. NHTSA believes the rates of technology application require for Alternatives 4 and 5 are beyond maximum feasible when considering the availability of manufacturers’ resources and capital to implement the technologies in that timeframe, and that Alternatives 4 and 5 would not provide adequate lead time for the industry to fully address reliability considerations. 
Like the NPRM analysis (i.e. the 
Method B analysis), Method A indicates Alterative 4 would achieve little benefit beyond that achieved by Alternative 3. For example, as shown in the following graph of estimated total fuel consumed by HD pickups and vans over time under the various regulatory alternatives, outcomes under Alternative 4 are nearly indistinguishable from those under Alternative 3. By 2030, the two are less than 0.5 percent apart. 
Weighing against the small additional 
benefit estimated to be potentially 
available under Alternative 4, NHTSA 
also considered the estimated additional costs. Method A analysis shows overall incremental costs (i.e., costs beyond the 
No Action Alternative) under Alternative 4 to be about 12 percent more than under Alternative 3. 
As mentioned above, these estimated 
differences were mostly small on a relative basis. Averaged over all model years included in the analysis, estimated incremental costs are $106 higher under Alternative 4 than under Alternative 3. For Daimler and General Motors, there is little or no estimated difference in costs under these two Alternatives. For FCA, Ford, and Nissan, differences are somewhat larger, averaging $120, $173, and $272, respectively. However, as explained in greater detail above, NHTSA’s method A analysis shows considerably greater total and average additional costs in earlier model years under Alternative 4 than under Alternative 3. 
Although NHTSA’s Method A 
analysis also indicates that some manufacturers could need to apply additional technology as soon as MY 2016 under baseline standards defining the No-Action Alternative, average estimated costs (versus continuation today’s technology) in MY 2017 are two thirds more under Alternative 4 than under the No Action Alternative. 
Beyond these directly-estimated costs, 
the agencies also considered factors beyond those addressed quantitatively in either the NPRM analysis or the updated analysis. In general, these other factors reflect risk and uncertainty 
involved with standards for HD pickups and vans. These risks and uncertainty appear considerably greater than for light-duty vehicles. The HD pickup and van market has significantly fewer vehicle models than the light-duty market making forecasting uncertainty a greater risk to compliance. All current manufacturers of HD pickups and vans also produce light-duty vehicles. These 
manufacturers’ light-duty offerings span wide ranges of models, configurations, shared vehicle platforms, engines, transmissions, and design schedules. As a result, if some specific aspects of production do not progress as initially planned for light-duty vehicles (e.g., if 
mass reduction on some platform does not achieve as much benefit as planned, or if a new engine does not perform as 
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513CARB, Docket No. NHTSA–2014–0132–0125 
at pages 52–53. 
514UCS, Docket No. EPA–HQ–OAR–2014–0827– 
1329, at pages 23–25. well as projected, or if limited 
engineering resources make it necessary to delay a redesign), these manufacturers should have ample opportunity to comply with light-duty CAFE and GHG standards by making adjustments among other models, platforms, engines, and transmissions. This is not the case for HD pickups and vans. Current HD PUV manufacturers offer products spanning only 1–3 platforms, at most half a dozen engines or transmissions, and only 1–3 
schedules for redesigns. As summarized below, this provides 5–10 times less flexibility than for light-duty vehicles. 
TABLE VI–26—MY 2015 B ODY AND ENGINE PLATFORMS BY MANUFACTURER FOR LIGHT- ANDHEAVY -DUTYPICKUPS  
Platforms Engines Transmissions Design Schedules 
Light-duty HD PUV Light-duty HD PUV Light-duty HD PUV Light-duty HD PUV 
Daimler ............................. 12 1 29 2 20 2 18 1 
FCA .................................. 15 3 24 5 21 6 24 3 
Ford .................................. 9 2 22 5 27 3 18 2 
General Motors ................ 17 2 26 5 39 3 21 2 
Nissan .............................. 6 1 13 2 21 2 23 1 
Considering further that credits from 
other manufacturers are not potentially 
available as for light-duty vehicles (e.g., several manufacturers currently have excess light-duty CAFE credits that could be traded to other OEMs), this means that overestimating the industry’s capability to improve fuel efficiency and reduce GHG emissions, and consequently setting standards at too stringent of a level, poses a much greater compliance risk for HD PUV fleets than for light-duty fleets. If the factors discussed here, for which the agencies are currently unable to account in our analysis, lead manufacturers to fail to comply with the standards, then the additional benefits of setting standards at slightly more stringent levels would be lost. In the agencies’ judgment, even setting aside the somewhat higher estimated costs under Alternative 4, the very small additional benefit that could be achieved under Alternative 4 do not warrant the increased exposure to this risk. 
Regarding Alternative 5, the Method 
A analysis shows somewhat greater benefits than under Alternatives 3 or 4, but Alternative 5 entails considerably greater costs and dependence on strong hybrid technology, as well as even greater exposure to the above-mentioned uncertainties and risks. Under the Method A analysis for Alternative 5, incremental costs averaged across all model years considered are estimated to be about $400 higher (about 46 percent) than under Alternative 3, and that analysis shows an overall fleet application of approximately 7 percent strong hybrids, with General Motors applying approximately 13 percent and Ford approximately 7 percent. 
We have also assumed that fuel- 
saving technologies will be no more or less reliable than technologies already in production. However, if there is insufficient lead-time to fully develop new technologies, they could prove to be less reliable, perhaps leading to increased repair costs and out-of-service time. If the fuel-saving technologies considered here ultimately involve reliability problems, overall costs will be greater than we have estimated. Method A analysis shows in the short term, MYs 2017–2021 timeframe, there are significant differences in the rate at which technologies would need to be applied among the alternatives. Figures VI.15 and VI.16, above, shows the progression in average and total technology costs and the rate of increase in those costs among the alternatives using Method A. They highlight the increases in resources and capital that would be required to implement the technologies required to comply with each of the alternatives, as well as the reduction in lead time to implement the technologies which increases reliability risk. As discussed further above in the manufacturer-specific effects, Ford and FCA are estimated to redesign vehicles in MYs 2017 and 2018 respectively, and vehicle designs for those model years are complete or nearly complete. The next estimated redesign for Ford is in MY 2026, and for FCA in MY 2025, and substantial resources and very high costs would be required to add another vehicle redesign between the estimated redesign model years to implement the technologies that would be needed to comply with those alternatives. 
(b) Consideration of Comments 
NHTSA proposed that Alternative 3 
represented the maximum feasible 
alternative under EISA, and EPA proposed that Alternative 3 reflected a reasonable consideration of the statutory factors of technology effectiveness, feasibility, cost, lead time, and safety for purposes of CAA sections 202(a)(1) and (2). Although the agencies and commenters also found that Alternative 4 merited serious consideration, the 
agencies noted that Alternative 3 was 
generally designed to achieve the levels of fuel consumption and GHG stringency that Alternative 4 would achieve, but with several years of additional lead time, meaning that manufacturers could, in theory, apply new technology at a more gradual pace, with greater reliability and flexibility. 
Some comments on the proposal 
called for adoption of standards more stringent and/or more rapidly advancing in stringency than those defining Alternative 3. For example, CARB argued that Alternative 4 would, compared to Alternative 3, achieve greater benefits comparably attractive in terms of cost effectiveness and while remaining less stringent than CAFE standards for light-duty trucks.
513UCS 
provided similar comments, indicating further that the standards should be technology forcing and therefore more aggressive than Alternative 4, they specifically suggested that gasoline vehicles could achieve up to a 23.6 percent improvement in MY 2027 while diesel vehicles can achieve an 18 percent improvement.
514ACEEE 
similarly recommended increasing the stringency by 7 percent in MY 2027 and that standards should reflect increased use of cylinder deactivation, cooled EGR, and GDI and turbo downsizing in pickups. For diesels, ACEEE commented that additional reductions were possible, based on an estimate of 10 percent penetration of engine downsizing for pickups and 30 percent penetration for vans in 2027, and also assuming 6 percent penetration of hybrids in diesel vans. 
Citing the potential for fuel-saving 
technology to migrate from light-duty 
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515CBD, Docket No. NHTSA–2014–0132–0101, at 
pages 8–9. 516AAPC, Docket No.NHTSA–2014–0132–0103 ], 
at pages 12–13. 
517AAPC, Docket No. NHTSA–2014–0132–0103 
at pages 13–16. 518Manufacturers generally have only one pickup 
platform and one van platform in this segment. pickups and vans to heavy-duty pickups 
and vans, CBD also called for more stringent HD pickup and van standards that would ‘‘close the gap’’ with light- duty standards, as any gap allows manufacturers to essentially choose to classify a pickup as heavy-duty to avoid more stringent requirements if it was classified as a light-duty vehicle.
515 
ICCT likewise commented that the proposed standards represent only a 2.2 and 1.6 percent year-over-year improvement for the gasoline and diesel fleets, respectively, from MYs 2014– 2025 compared to an almost 3 percent per year improvement for light-duty trucks in the same time frame. ICCT recommended that the agencies’ analysis incorporate the full analysis and inputs from the light-duty rulemaking and that the result would be improvements in the range of 35 percent over the MYs 2014–2025 rather than the proposed 23 percent improvement over this time frame. 
On the other hand, some other 
reviewers commented that the proposed standards could be unduly aggressive considering the products and technologies involved. GM commented that any attempt to force more stringent regulations than proposed, such as Alternative 4, would be extremely detrimental to manufacturers, consumers, the U.S. economy, and the millions of transportation-related jobs. Daimler similarly commented that the proposed standards would be a challenge for automotive manufacturers. Under certain conditions, such a standard may necessitate hybridization of the affected vehicle fleet, which would require substantial development and material costs. All technologies taken into account for the class 2b/3 stringencies should reflect cost effectiveness calculations, especially alternative powertrains such as hybrids, battery, and fuel cell driven electric 
vehicles. Daimler recommends that the agencies adopt the proposed standard over Alternative 4, as the additional two years of lead-time will be critical for automotive manufacturers in developing the necessary technologies to achieve compliance. Nissan commented that the Alternative 4 3.5 percent per stringency level is simply not feasible, as it does not provide the necessary lead-time to enable manufacturers to balance competitive market constraints with the cost of applying new technologies to a limited product offering. Nissan further commented that to the extent that the more stringent alternative is predicated on the adoption of hybrid and electric powertrain technology, Nissan does not 
believe that such technology is feasible for this market segment. 
The American Automotive Policy 
Council (AAPC, representing FCA, Ford, and General Motors) further commented that proposals for greater stringency than Alternative 3 are not supportable given the required early introduction of unproven technologies with their associated consumer acceptance risk, as well as the many implicit risks that impact stringency. AAPC commented that the proposed standards are aggressive and will challenge industry. AAPC noted that the baseline fleet includes a high percentage of advanced diesel technology such as SCR, making additional improvements considerably more challenging. In the light-duty fleet, diesel technology accounts for 3 percent of fleet whereas the heavy-duty fleet consists of over 50 percent diesel. 
AAPC also noted that Phase 2 
technologies are being used today. For 
example, FCA’s modern gasoline engine has robust combustion with multiple spark plugs, variable cam phasing, cylinder deactivation, and cooled EGR. AAPC commented that even with this level of gasoline engine technology, FCA is challenged by the early year Phase 1 standards and will need to look at adding even more technology for Phase 2. AAPC also provided data showing that while smaller displacement boosted gasoline engine technology may be applicable in some variants of commercial vans, this technology is not suited for the pickup truck variants in this segment because of customer demands for towing capability. AAPC commented that concurrent stringency increases in Tier 3/LEV III criteria emission requirements will negatively impact CO
2and fuel 
consumption. As an alternative to the standards proposed in the NPRM, the American Automotive Policy Council (AAPC, representing FCA, Ford, and General Motors) proposed standards that would achieve the stringency by model year 2027, but that would do so at a more gradual pace.
516As means of 
providing flexibility in complying with these standards, AAPC also commented that the agencies should allow credits to be banked for longer than 5 years, and should allow credits to be transferred between the light- and heavy-duty fleets.
517 (c) Determination 
Having considered these comments as 
well as the updated analysis 
summarized above, NHTSA is adopting standards under which the stringency of fuel consumption standards for HD pickups and vans advance at an annual rate of 2.5 percent during model years 2021–2027 relative to the 2018 MY Phase 1 standard level. In NHTSA’s judgment, this pace of stringency increase will appropriately accommodate manufacturers’ redesign workload and product schedules, especially in light of this sector’s limited product offerings
518and long 
product cycles. Given the provided flexibility to carry credits forward (and back) between model years, this approach strikes a balance between, on one hand, meaningful early fuel efficiency improvements and, on the other, providing manufacturers appropriate lead time. 
Compared to Alternative 3, 
Alternative 2 would forego significant cost-efficient opportunities to apply conventional and moderately advanced technology in order to reduce fuel consumption and emissions. Also, although the updated analysis summarized above shows costs for Alternative 3 (as costs incremental to the No Action Alternative) somewhat higher than estimated in the NPRM analysis, the agencies find that under either the Method A or Method B analyses, AAPC’s proposed more gradual progression leading up to MY 2027 would also forego cost-effective improvements which are readily feasible in the lead time provided. Furthermore, the Method A analysis indicates that the standards defining Alternative 3 can likely be met with minimal reliance on hybrid technologies. Considering this, NHTSA also find it unnecessary to extend the lifespan of banked credits or adopt other credit related flexibilities to mitigate the stringency increases under Alternative 3. 
E. Analysis of the Regulatory 
Alternatives for HD Pickups and Vans: Method B 
Section 202(a)(1) and (2) of the Clean 
Air Act require EPA to establish standards for emissions of pollutants from new motor vehicles and engines which emissions cause or contribute to air pollution which may reasonably be anticipated to endanger public health or welfare, which include GHGs. See Section I.E. above. Under section 
202(a)(1) and (2), EPA considers such 
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519Manufacturers generally have only one pickup 
platform and one van platform in this segment. issues as technology effectiveness, its 
cost (both per vehicle, per manufacturer, and per consumer), the lead time necessary to implement the technology, and based on this the feasibility and practicability of potential standards; the impacts of potential standards on emissions reductions of both GHGs and non-GHG emissions; the impacts of standards on oil conservation and energy security; the impacts of standards on fuel savings by customers; the impacts of standards on the truck industry; other energy impacts; as well as other relevant factors such as impacts on safety. 
As part of the proposed feasibility 
analysis of potential standards for HD pickups and vans, the agencies applied NHTSA’s CAFE Model. The agencies used this model to identify technology pathways that could be used to meet a range of stringencies, based on our projections of technology that will be available in the Phase 2 time frame. The agencies considered these technology pathways and identified the stringency level that will be technology-forcing (i.e. reflect levels of stringency based on performance of emerging as well as currently available control technologies) at reasonable cost, and leave manufacturers the flexibility to adopt varying technology paths for compliance and allow adequate lead time to develop, test, and deploy the range of technologies. 
As noted in Section I and discussed 
further below, the analyses consider two versions of the CAFE model, one updated for the NPRM analysis represented here in Method B, and one further updated for the FRM represented in the Method A analysis described in D immediately preceding this section. The results of both versions are reported relative to two baselines, a flat baseline (designated Alternative 1a) where no improvements are modeled beyond those needed to meet Phase 1 standards and a dynamic baseline (designated Alternative 1b) where certain cost- effective technologies (i.e., those that 
payback within a 6 month period) are assumed to be applied by manufacturers to improve fuel efficiency beyond the Phase 1 requirements in the absence of new Phase 2 standards. NHTSA considered its primary analysis to be based on the more dynamic baseline of Method A, whereas EPA considered the flat baseline of Method B. As shown below and in Sections VII through X, using the two different reference cases has little impact on the results of the analysis and leads to the same conclusion regarding the 
appropriateness of the Phase 2 standards. As such, the use of different reference cases corroborates the results 
of the overall analysis. 
For the NPRM, the agencies 
conducted coordinated and complementary analyses by employing both NHTSA’s CAFE model and EPA’s MOVES model and other analytical tools to project fuel consumption and GHG emissions impacts resulting from the Phase 2 standards for HD pickups and vans, against both the flat and dynamic baselines. EPA ran its MOVES model for all HD categories, namely tractors and trailers, vocational vehicles and HD pickups and vans, to develop a consistent set of fuel consumption and CO
2reductions for all HD categories. 
The MOVES runs followed largely the procedures described above, with some differences. MOVES used the same technology application rates and costs that are part of the inputs, and used cost per vehicle outputs of the CAFE model to evaluate the Phase 2 standards for HD pickup trucks and vans. The agencies note that these two independent analyses of aggregate costs and benefits both support these standards. For the final rule, NHTSA has conducted an analysis using a revised version of the CAFE model, as discussed in Section D. This analysis has been designated Method A. The EPA analysis based on the NPRM version of the CAFE model along with EPA’s MOVES model is designated Method B. 
As noted earlier, the agencies are 
adopting as proposed a phase-in schedule of reduction of 2.5 percent per year in fuel consumption and CO
2levels 
relative to the 2018 MY Phase 1 standard level, starting in MY 2021 and 
extending through MY 2027. We continue to believe this phased-in implementation will appropriately accommodate manufacturers’ redesign workload and product schedules, especially in light of this sector’s limited product offerings
519and long 
product cycles. This approach was chosen to strike a balance between meaningful reductions in the early years and providing manufacturers with needed lead time via a gradually accelerating ramp-up of technology penetration. By expressing the phase-in in terms of increasing year to year stringency for each manufacturer, while also providing for credit generation and use (including averaging, carry-forward, and carry-back), we believe our program will afford manufacturers substantial flexibility to satisfy the phase-in through a variety of pathways: The gradual application of technologies across the fleet, greater application levels on only a portion of the fleet, and 
a sufficiently broad set of available technologies to account for the variety of current technology deployment among manufacturers and the lowest- cost compliance paths available to each. 
EPA did not estimate the cost of 
implementing these standards immediately in 2021 without a phase-in, but we qualitatively assessed it to be somewhat higher than the cost of the phase-in we are establishing, due to the workload and product cycle disruptions it could cause, and also due to manufacturers’ resulting need to develop some of these technologies for heavy-duty applications sooner than or simultaneously with light-duty development efforts. See 75 FR 25451 (May 7, 2010) (documenting types of drastic cost increases associated with trying to accelerate redesign schedules and concluding that ‘‘[w]e believe that it would be an inefficient use of societal resources to incur such costs when they can be obtained much more cost effectively just one year later’’). On the other hand, waiting until 2027 before applying any new standards could miss the opportunity to achieve meaningful and cost-effective early reductions not requiring a major product redesign. Comments on the phase-in are discussed in Section B.2. and in the Response to Comments document. 
As noted above, at proposal, the 
agencies requested comment in particular on Alternative 4. EPA is not adopting Alternative 4 due to uncertainty regarding whether or not the potential technologies and market penetration rates included in Alternative 4 would be technologically feasible. Alternative 4 would ultimately reach the same levels of stringency as final Phase 2 standards, but would do so with less lead time. As discussed below, this could require application of both different technologies at higher application rates, neither of which may be feasible (or, at the least, reliable implementable) by MY 2025. 
Moreover, the two years of additional 
lead time provided by the final standards compared to Alternative 4 eases compliance burden by having more vehicle redesigns and lower stringency during the phase-in period. As noted above, historically, the vehicles in this segment are typically 
only redesigned every 6–10 years, so many of the vehicles may not even be redesigned during the timeframe of the stringency increase. In this case, a manufacturer must either make up for any vehicle that falls short of its target through some combination of early compliance, over compliance, credit carry-forward and carry-back, and 
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520Reinhart, T.E. (June 2015). Commercial 
Medium- and Heavy-Duty Truck Fuel Efficiency Technology Study—Report #1. (Report No. DOT HS 812 146). Washington, DC: National Highway 
Traffic Safety Administration. redesigning vehicles more frequently. 
Each of these will increase technology costs to the manufacturers and vehicle purchasers, and early redesigns will significantly increase capital costs and product development costs. Also, the longer implementation time for the final standards means that any manufacturer will have a slightly lower target to meet from 2021–2026 than for the shorter phase-in of Alternative 4, though by 2027 the manufacturers will have the same target in either alternative. 
Due to the projected higher 
technology adoption rates, Alternative 4 is also projected to result in higher costs, and risks of inadequate time to successfully test and integrate new technology, than the standards the agencies are adopting. Moreover, the additional emission reductions and fuel savings predominately occur only during the program phase-in period; from roughly 2030 on, the adopted standards and the pull-ahead alternative are projected to be equivalent from an environmental benefit standpoint. EPA’s analysis and responses to comments are discussed in detail below. 
In some cases, the Method B (NPRM) 
version of the model selects strong hybrids as a more cost effective technology over certain other technologies including stop-start and mild hybrid. In other words, strong hybrids are not a technology of last resort in the analysis. Alternative 4 is projected to be met using a significantly higher degree of hybridization including the use of more strong hybrids, compared to the standards the agencies are finalizing. In order to comply with a 3.5 percent per year increase in stringency over MYs 2021–2025, Method B modeling projects that manufacturers would need to adopt more technology compared to the 2.5 percent per year increase in stringency over MYs 2021–2027. The two years of additional lead time provided by the Phase 2 standards reduces the potential number of strong hybrids projected to be used by allowing for other more cost effective technologies to be more fully utilized across the fleet. EPA believes it is technologically feasible to apply this projected amount of hybridization to HD pickups and vans in the lead time provided (i.e., by MY 2027). However, 
strong hybrids present challenges in this market segment compared to light-duty where there are several strong hybrids already available. EPA does not believe that at this stage there is enough information about the viability of strong hybrid technology in this vehicle segment to assume that they can be a part of large-volume deployment strategies for regulated manufacturers. For example, EPA believes that hybrid electric technology could provide significant GHG and fuel consumption benefits, but recognize that there is uncertainty at this time over the real world effectiveness of these systems in HD pickups and vans, and over customer acceptance of the technology for vehicles with high GCWR towing large loads. Further, the development, design, and tooling effort needed to apply this technology to a vehicle model is quite large, and might not be cost- effective due to the small sales volumes relative to the light-duty sector. 
Additionally, EPA recognizes that 
sufficient engine horsepower and torque needed to meet towing objectives which are important to pickup truck buyers and accordingly the analysis does not down-size engines in conjunction with hybridization. See Section VI.C.4.iv above. Therefore, with no change projected for engine size, the strong hybrid costs do not include costs for engine changes. In light-duty, the use of smaller engines has an associated cost saving which facilitates much of a hybrid’s cost-effectiveness. Section E.2 discusses these issues further, and explains further that the results of the updated CAFE model used in Method A are consistent with these conclusions. 
Due to these considerations in the 
NPRM and in the current Method B analysis, EPA has conducted a sensitivity analysis using the Method B version of the model that assumes the use of no strong hybrids. The results of the analysis are also discussed below. The analysis indicates that there will be a technology pathway that will allow manufacturers to meet the final standards without the use of strong hybrids. However, the analysis indicates that costs will be higher and the cost effectiveness will be lower under the no strong hybrid approach. 
EPA also analyzed less stringent 
standards under which manufacturers could comply by deploying a more limited set of technologies than are needed to meet the Phase 2 standards being adopted. However, our assessment concluded with a high degree of confidence that the technologies on which the final Phase 2 standards are premised will be available at reasonable cost in the 2021–2027 timeframe, and that the phase-in and other flexibility provisions allow for their application in a very cost-effective manner, as discussed in this section below. Accordingly, it would be inappropriate (within the meaning of CAA section 202(a)(1) and (2)) to adopt standards of lesser stringency. 
More difficult to characterize is the 
degree to which more or less stringent standards might be appropriate because of under- or over-estimating the costs or effectiveness of the technologies whose performance is the basis of the Phase 2 standards. For the most part, these technologies have not yet been applied to HD pickups and vans, even on a limited basis. EPA is therefore relying to some degree on engineering judgment in predicting their effectiveness. Even so, we believe that we have applied this judgment using the best information available, primarily from a NHTSA contracted study at SwRI
520and our 
recent rulemaking on light-duty vehicle GHGs and fuel economy, and have generated a robust set of effectiveness values. Chapter 10 of the RIA provides a detailed description of the CAFE Model and the analysis performed for the rule. 
(1) Consistency of the Phase 2 Standards 
With the EPA’s Legal Authority 
Table VI–27 below shows projected 
technology adoption rates for both the final Phase 2 standards and for a two- year pull ahead of those standards (i.e. Alternative 4 from the NPRM). As at proposal, the table shows that the Method B (EPA’s central estimate) analysis estimates that the most cost- effective way to meet the final Phase 2 standards will be to use strong hybrids in up to 9.9 percent of pickups and 5.5 percent of vans on an industry-wide basis. The analysis of Alternative 4 shows strong hybrids on up to 19 percent of pickups (and two years sooner). The analysis shows that the two years of additional lead time provided by the Phase 2 standards compared to Alternative 4 will provide manufacturers with a better opportunity to maximize the use of technologies which are more cost effective than strong hybrids over time thereby reducing the need for strong hybrids which may be particularly challenging for this market segment, as well as providing needed time for the more limited deployment of this technology projected under alternative 3 (i.e. the 
Phase 2 standard). 
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TABLE VI–27—M ETHOD B CAFE M ODEL TECHNOLOGY ADOPTION RATES FOR THE FINAL PHASE 2 STANDARDS RULE AND  
ALTERNATIVE 4 SUMMARY —FLATBASELINE  
Technology Phase 2 standards 
(2.5% per year) 
2021 to 2027 Alternative 4 
(3.5% per year) 
2021 to 2025 
Pickup trucks 
% Vans 
% Pickup trucks 
% Vans 
% 
Low friction lubricants ...................................................................................... 100 100 100 100 
Engine friction reduction .................................................................................. 100 100 100 100 
Cylinder deactivation ....................................................................................... 22 19 22 19 
Variable valve timing ....................................................................................... 22 82 22 82 
Gasoline direct injection .................................................................................. 0 63 0 80 
Diesel engine improvements ........................................................................... 60 3.6 60 3.6 
Turbo downsized engine ................................................................................. 0 63 0 63 
8 speed transmission ....................................................................................... 98 92 98 92 
Low rolling resistance tires .............................................................................. 100 92 100 59 
Aerodynamic drag reduction ............................................................................ 100 100 100 100 
Mass reduction and materials ......................................................................... 100 100 100 100 
Electric power steering .................................................................................... 100 49 100 46 
Improved accessories ...................................................................................... 100 87 100 36 
Low drag brakes .............................................................................................. 100 45 100 45 
Stop/start engine systems ............................................................................... 0 0 15 1.5 
Mild hybrid ....................................................................................................... 0 0 29 15 
Strong hybrid ................................................................................................... 9.9 5.5 19 0 
As discussed earlier, EPA also 
conducted a sensitivity analysis using 
the Method B version of the model to determine a compliance pathway where no strong hybrids would be utilized. Although EPA in this Method B analysis, projects that strong hybrids may be the most cost effective approach, manufacturers may select another compliance path, mainly a 20 percent penetration rate of mild hybrids. This no strong hybrid analysis included the use of downsized turbocharged engines in vans currently equipped with large V–8 engines. Turbo-downsized engines were not allowed on 6+ liter gasoline vans in the primary analysis because EPA sought to preserve consumer choice with respect to vans that have large V–8s for towing. However, given the recent introduction of vans with considerable towing capacity and turbo- downsized engines, EPA believes it will be feasible for vans in the time-frame of these final rules. The tables below reflect the difference in predicted penetration rates of technologies if strong hybridization is not chosen as a technology pathway. For simplicity, pickup trucks and vans are combined into a single industry wide penetration rate. 
The table also shows that when strong 
hybrids are used as a pathway to compliance, penetration rates of all hybrid technologies would increase substantially between the Phase 2 standards and Alternative 4. The analysis predicts an increase in strong hybrid penetration from 8 percent to 12 percent, a 23 percent penetration of mild hybrids and a 10 percent penetration stop/start engine systems for Alternative 4 compared with the Phase 2 standards (hence much of the increased projected cost between these options, as explained below). Also, by having the final standards apply in MY 2027 instead of MY 2025, the rule is not premised on use of any mild hybrids or stop/start engine systems. This analysis shows that the few years of additional lead time provided by the Phase 2 standards allows manufacturer’s important flexibility in choosing a mix of technologies that is best suited for this market. 
TABLE VI–28—CAFE M ETHOD B M ODEL TECHNOLOGY ADOPTION RATES FOR FINAL PHASE 2 STANDARDS AND  
ALTERNATIVE 4 COMBINED FLEET AND FUELS SUMMARY —FLATBASELINE  
Technology Phase 2 standards 
(2.5% per year) 
2021 to 2027 Alternative 4 
(3.5% per year) 
2021 to 2025 
With strong 
hybrids 
% Without 
strong 
hybrids 
% With strong 
hybrids 
% Without 
strong 
hybrids 
% 
Low friction lubricants ...................................................................................... 100 100 100 100 
Engine friction reduction .................................................................................. 100 100 100 100 
Cylinder deactivation ....................................................................................... 21 22 21 14 
Variable valve timing ....................................................................................... 46 46 46 46 
Gasoline direct injection .................................................................................. 25 45 31 45 
Diesel engine improvements ........................................................................... 38 38 38 38 
Turbo downsized enginea............................................................................... 25 31 25 31 
8 speed transmission ....................................................................................... 96 96 96 96 
Low rolling resistance tires .............................................................................. 97 97 84 84 
Aerodynamic drag reduction ............................................................................ 100 100 100 100 
Mass reduction and materials ......................................................................... 100 100 100 100 
Electric power steering .................................................................................... 80 92 79 79 
Improved accessories ...................................................................................... 67 77 75 75 
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TABLE VI–28—CAFE M ETHOD B M ODEL TECHNOLOGY ADOPTION RATES FOR FINAL PHASE 2 STANDARDS AND  
ALTERNATIVE 4 COMBINED FLEET AND FUELS SUMMARY —FLATBASELINE —Continued 
Technology Phase 2 standards 
(2.5% per year) 
2021 to 2027 Alternative 4 
(3.5% per year) 
2021 to 2025 
With strong 
hybrids 
% Without 
strong 
hybrids 
% With strong 
hybrids 
% Without 
strong 
hybrids 
% 
Low drag brakes .............................................................................................. 78 93 78 78 
Stop/start engine systems ............................................................................... 0 1 10 4 
Mild hybrid ....................................................................................................... 0 20 23 66 
Strong hybrid ................................................................................................... 8 0 12 0 
Note: 
aThe 6+ liter V8 vans were allowed to convert to turbocharged and downsized engines in the ‘‘without strong hybrid’’ analysis for both the Rule 
and the Alternative 4 to provide a compliance path. 
The tables Table VI–29 and Table VI– 
30 below provide a further breakdown 
of projected technology adoption rates specifically for gasoline-fueled pickups and vans which shows potential adoption rates of strong hybrids for each vehicle type. Strong hybrids are not projected to be used in diesel applications. The Alternative 4 analysis shows the use of strong hybrids in up to 48 percent of gasoline pickups, depending on the mix of strong and mild hybrids, and stop/start engine systems in 20 percent of gasoline pickups (the largest gasoline HD segment). It is important to again note that this analysis only shows one 
pathway to compliance, and the manufacturers may make other decisions, e.g., changing the mix of 
strong vs. mild hybrids, or applying electrification technologies to HD vans instead. 
TABLE VI–29—CAFE M ETHOD B M ODEL TECHNOLOGY ADOPTION RATES FOR FINAL PHASE 2 STANDARDS AND  
ALTERNATIVE 4 ONGASOLINE PICKUP TRUCKS —FLATBASELINE  
Technology Phase 2 standards 
(2.5% per year) 
2021 to 2027 Alternative 4 (3.5% per year) 
2021 to 2025 
With strong 
hybrids 
% Without 
strong 
hybrids 
% With strong 
hybrids 
% Without 
strong 
hybrids 
% 
Low friction lubricants ...................................................................................... 100 100 100 100 
Engine friction reduction .................................................................................. 100 100 100 100 
Cylinder deactivation ....................................................................................... 56 56 56 56 
Variable valve timing ....................................................................................... 56 56 56 56 
Gasoline direct injection .................................................................................. 0 56 0 56 
8 speed transmission ....................................................................................... 100 100 100 100 
Low rolling resistance tires .............................................................................. 100 100 100 100 
Aerodynamic drag reduction ............................................................................ 100 100 100 100 
Mass reduction and materials ......................................................................... 100 100 100 100 
Electric power steering .................................................................................... 100 100 100 100 
Improved accessories ...................................................................................... 100 100 100 100 
Low drag brakes .............................................................................................. 100 100 100 100 
Driveline friction reduction ............................................................................... 44 68 68 68 
Stop/start engine systems ............................................................................... 0 0 20 0 
Mild hybrid .......................................................................................................aUp to 42 0 a18–86 86 
Strong hybrid ................................................................................................... Up to 25 ........................ Up to 48 
Note: 
aDepending on extent of strong hybrid adoption as hybrid technologies can replace each other, however they will have different e ffectiveness 
and costs. 
TABLE VI–30—CAFE M ETHOD B M ODEL TECHNOLOGY ADOPTION RATES FOR FINAL PHASE 2 STANDARDS AND  
ALTERNATIVE 4 ONGASOLINE VANS—FLATBASELINE  
Technology Phase 2 Standards 
(2.5% per year) 
2021 to 2027 Alternative 4 
(3.5% per year) 
2021 to 2025 
With strong 
hybrids 
% Without 
strong 
hybrids 
% With strong 
hybrids 
% Without 
strong 
hybrids 
% 
Low friction lubricants ...................................................................................... 100 100 100 100 
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TABLE VI–30—CAFE M ETHOD B M ODEL TECHNOLOGY ADOPTION RATES FOR FINAL PHASE 2 STANDARDS AND  
ALTERNATIVE 4 ONGASOLINE VANS—FLATBASELINE —Continued 
Technology Phase 2 Standards 
(2.5% per year) 
2021 to 2027 Alternative 4 
(3.5% per year) 
2021 to 2025 
With strong 
hybrids 
% Without 
strong 
hybrids 
% With strong 
hybrids 
% Without 
strong 
hybrids 
% 
Engine friction reduction .................................................................................. 100 100 100 100 
Cylinder deactivation ....................................................................................... 23 3 23 3 
Variable valve timing ....................................................................................... 100 100 100 100 
Gasoline direct injection .................................................................................. 57 97 97 97 
Turbo downsized enginea............................................................................... 77 97 77 97 
8 speed transmission ....................................................................................... 97 97 97 97 
Low rolling resistance tires .............................................................................. 100 100 60 60 
Aerodynamic drag reduction ............................................................................ 100 100 100 100 
Mass reduction and materials ......................................................................... 100 100 100 100 
Electric power steering .................................................................................... 55 85 53 53 
Improved accessories ...................................................................................... 23 38 43 43 
Low drag brakes .............................................................................................. 53 89 53 100 
Stop/start engine systems ............................................................................... 0 0 2 0 
Mild hybrid .......................................................................................................bUp to 13 13 18 40 
Strong hybrid ................................................................................................... Up to 7 ....... ................. 0 ........................
Notes: 
aThe 6+ liter V8 vans were allowed to convert to turbocharged and downsized engines in the ‘‘without strong hybrid’’ analysis for both the Rule 
and the Alternative 4 to provide a compliance path. 
bDepending on extent of strong hybrid adoption as hybrid technologies can replace each other, however they will have different e ffectiveness 
and costs. 
EPA projects a compliance path for 
these standards showing aggressive 
implementation of technologies that the agencies consider to be available in the time frame of these rules. See Section VI.C.4. Under this approach, manufacturers are expected to implement these technologies at aggressive adoption rates on essentially 
all vehicles across this sector by 2027 model year. In the case of several of these technologies, adoption rates are projected to approach 100 percent. This includes a combination of engine, transmission and vehicle technologies as described in this section across every vehicle. The standard also is premised on less aggressive penetration of particular advanced technologies, including strong hybrid electric vehicles. 
EPA projects the Phase 2 standards to 
be achievable within known design cycles, and we believe these standards will allow different paths to compliance in addition to the one we outline and cost here. As discussed below and throughout this analysis, our rule places a high value on the assurance of in use reliability and market acceptance of new technology, particularly in initial model years of the program. 
The NPRM analysis did not predict 
substantial amounts of technology being added before the start of the MY 2021 standards, and in particular, did not project that there would be substantial additions of more advanced technologies in any redesign cycles 
occurring before MY 2021. This continues to appear to be a reasonable assumption, since substantial lead time is typically required to develop and implement these advanced technologies. Indeed, as the previous discussion shows (and as discussed again in responding to comments later in this section), it is important to provide two additional years of lead time between MY 2025 and 2027. More recent modeling used to update the NHTSA Method A analysis as described in Section C above allows for technology implementation in pre-2021 model years to both meet the final Phase 1 
standards in MY 2018 and to also begin to introduce advanced technologies that will eventually be needed in order to meet the Phase 2 standards. EPA considered this more recent modeling approach with earlier redesign cycles and technology implementation and agrees with NHTSA that this modelling shows that there would be insufficient lead time to adopt the technologies to satisfy the compliance path modelled for Alternatives 4 and 5 in the Method A analysis. See Section VI.D.4 above. 
As discussed above, the agencies 
sought comment on the feasibility and costs associated with the standards being finalized and also on alternative standards. In particular, the agencies sought comment on Alternative 4, which is based on a year-over-year increase in stringency of 3.5 percent in MYs 2021–2025, essentially pulling 
ahead the alternative 3 standard stringency by two model years. The agencies received several comments in support of more stringent standards. Several NGOs commented that more stringent standards than proposed are feasible through the additional application of technology and that the standards should more closely align with standards established for light-duty trucks. UCS commented that gasoline vehicles could achieve up to a 23.6 percent improvement in MY 2027 while diesel vehicles can achieve an 18 percent improvement. ACEEE similarly recommended increasing the stringency by 7 percent in MY 2027 and that standards should reflect increased use of cylinder deactivation, cooled EGR, and GDI and turbo downsizing in pickups. For diesels, ACEEE commented that additional reductions were possible, based on an estimate of 10 percent penetration of engine 
downsizing for pickups and 30 percent penetration for vans in 2027, and also assuming 6 percent penetration of hybrids in diesel vans. ICCT commented that the proposed standards represent only a 2.2 and 1.6 percent year-over- year improvement for the gasoline and diesel fleets, respectively, from MYs 2014–2025 compared to an almost 3 percent per year improvement for light- duty trucks in the same time frame. ICCT recommended that the agencies’ analysis incorporate the full analysis 
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and inputs from the light-duty 
rulemaking and that the result would be improvements in the range of 35 percent over the MYs 2014–2025 rather than the proposed 23 percent improvement over this time frame. 
The agencies also received comments 
that any gap between fuel economy requirements for LD and HD pickups for which there is no engineering rationale could produce distortions in the pickup market, shifting sales toward the heavier vehicles. The Center for Biological Diversity similarly commented that closing the gap between large light-duty and heavy-duty pickups and vans is crucial because the overlap in many characteristics allows manufacturers to essentially choose to classify a pickup as ‘‘heavy duty’’ to avoid the more stringent requirements for ‘‘light duty’’ pickups through minor adjustments to the vehicle. 
CARB staff commented in support of 
Alternative 4, commenting that Alternative 4 is technologically feasible, cost-effective and superior to Alternative 3. CARB noted that the Alternative 4 adds only three to 8 months to the payback period. CARB also commented that Alternative 4 remains significantly less stringent than the light-duty truck standards. CARB further commented that Alternative 4 would result in greater emissions and societal benefits than Alternative 3. 
The agencies also received several 
comments opposing setting standards more stringent than those proposed, although none of these commenters opposed the actual proposal. AAPC commented that proposals for greater stringency than Alternative 3 are not supportable given the required early introduction of unproven technologies with their (purportedly) associated consumer acceptance risk, as well as the many implicit risks that impact stringency. AAPC commented that, in their view, the proposed standards are aggressive and will challenge industry. AAPC noted that the baseline fleet (which is over 50 percent diesel) includes a high percentage of advanced diesel technology such as SCR, making additional improvements more challenging. AAPC also noted that Phase 2 technologies are being used today. For example, FCA’s modern gasoline engine has robust combustion 
with multiple spark plugs, variable cam phasing, cylinder deactivation, and cooled EGR. AAPC commented that even with this level of gasoline engine technology, FCA is challenged by the early year Phase 1 standards and will need to look at adding even more technology for Phase 2. AAPC also provided data showing that while smaller displacement boosted gasoline 
engine technology may be applicable in some variants of commercial vans, this technology is not suited for the pickup truck variants in this segment because of customer demands for towing capability. AAPC commented that concurrent stringency increases in Tier 3/LEV III criteria emission requirements will negatively impact CO
2and fuel 
consumption. 
GM commented that any attempt to 
force more stringent regulations than proposed, such as Alternative 4, would be extremely detrimental to manufacturers, consumers, the U.S. economy, and the millions of transportation-related jobs. Daimler similarly commented that the proposed standards would be a challenge for automotive manufacturers. According to the commenter, under certain conditions, a more stringent standard than proposed may necessitate hybridization of the affected vehicle fleet, which would require substantial development and material costs. Daimler recommends that EPA adopt the proposed standard over Alternative 4, as the additional two years of lead- time will be critical for automotive manufacturers in developing the necessary technologies to achieve compliance. Nissan commented that Alternative 4 at 3.5 percent per year stringency level is simply not feasible, as it does not provide the necessary lead-time to enable manufacturers to balance competitive market constraints with the cost of applying new technologies to a limited product offering. Nissan further commented that to the extent that the more stringent alternative is predicated on the adoption of hybrid and electric powertrain technology, Nissan does not believe that such technology is feasible for this market segment. 
After considering the comments, EPA 
believes that the Phase 2 final standards that the agencies are adopting represent the most stringent standards reasonably achievable within the MY 2021–2027 period. The standards are based largely on the same technologies projected to be used in the light-duty fleet with appropriate adjustments for the heavy- duty fleet because of their specific higher load duty cycles. As shown in the tables 28 and 29 above and repeated below, several technologies are projected to be used at very high adoption rates at or near 100 percent including mass reduction, 8-speed transmissions, engine friction reduction, low rolling resistant tires, improved accessories, and aerodynamic drag 
reductions. For gasoline engines, some commenters noted that downsize turbo engines which are projected to be used extensively in light-duty vehicles should also be relied on in the heavy- duty analysis, including for HD pickups. As discussed in VI.C.4.vii above, the agencies agree with the comments provided by AAPC that turbo downsizing is likely to be counter- productive in heavy-duty pickups. EPA (and NHTSA in the Method A analysis) thus is projecting the use of downsized turbo engines only for vans. Under heavy loads, turbo downsized engines may have higher CO
2and fuel 
consumption than the engine it replaces. For this reason, EPA continues to believe that the technology can only be projected to be available for heavy- duty vans (and not pickups) and, for vans, is projecting its use at 77 to 97 percent. One commenter argued for a standard predicated on a more aggressive penetration rate for cylinder deactivation noting that in the NPRM the agencies only projected cylinder deactivation at an adoption rate of 22 percent of the overall fleet. The commenter believes that an adoption rate of 40 percent would be more appropriate. In response, cylinder deactivation is a gasoline engine technology and EPA is projecting an adoption rate of 56 percent for pickups and an adoption rate of essentially 100 percent for the gasoline engines in vans not projected to be downsized turbo engines (i.e. a more aggressive 
penetration rate than urged by the commenter). 
EPA also remains concerned about 
projecting standards predicated on high levels of hybridization in the heavy- duty pickup and van fleet. Many heavy duty applications need maximum payload and cargo volume which may compete with weight increases and lost cargo volume from hybridization, directly reducing the capability and therefore work factor of the vehicle. Additionally, it is likely not feasible to size a hybridization system to be effective for any high or maximum payload or towing operation without changing the utility of the vehicle. A manufacturer choosing to hybridize a heavy duty vehicle would likely target vans that are primarily used for cargo volumetric capacity reasons where a reasonably sized hybrid system could be incorporated and be effective under typical operation. EPA believes that the final Phase 2 standards will drive the orderly use of technology while still providing enough lead time that manufacturers could meet the standards using technology paths other than high penetration rates of strong hybrids. Thus, the gap in stringency between 
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521As noted earlier, hybrid batteries, motors and 
electronics generally add weight to a vehicle and 
require more space which can result in conflicts with payload weight and volume objectives. 
522Hybrid electric systems are not sized for 
situations when vehicles are required to do trailer towing where the combined weight of vehicle and trailer is 2 to 4 times that of the vehicle alone. During these conditions, the hybrid system will have reduced effectiveness. Sizing the system for trailer towing is prohibitive with respect to hybrid component required sizes and the availability of locations to place larger components like batteries. light-duty trucks and the Phase 2 
standards for HD pickups and vans reflects constraints of the use of some technologies in the heavy-duty market resulting from the intended use of the vehicles to do more work than light- duty trucks. 
The proposed rule discussed several 
considerations that EPA believes remain valid. The NPRM projected that the higher rate of increase in stringency associated with Alternative 4 and the shorter lead time would necessitate the use of a different technology mix under Alternative 4 compared to the Phase 2 standards that the agencies are adopting. The Phase 2 standards are projected to achieve the same final stringency increase as Alternative 4 at about 80 percent of the average per-vehicle cost increase, and without the expected deployment of more advanced technology at high penetration levels. In particular, under EPA’s primary analysis, which does not constrain the use of strong hybrids, manufacturers are estimated to deploy strong hybrids in approximately 8 percent of new vehicles (in MY 2027) under the Phase 2 standards, compared to 12 percent under Alternative 4 (in MY 2025). Less aggressive electrification technologies also appear on 33 percent of new vehicles simulated to be produced in MY 2027 under Alternative 4, but are not projected to be necessary under the Phase 2 standards. Additionally, it is important to note that due to the shorter lead time of Alternative 4, there are fewer vehicle refreshes and redesigns during the phase-in period of MY 2021– 2025. The longer, shallower phase-in of advanced technologies in the standards that the agencies are adopting allows for more compliance flexibility and closer matching with the vehicle redesign cycles, which (as noted above) can be up to ten years for HD vans. While the Method B CAFE model’s algorithm accounts for manufacturers’ consideration of upcoming stringency changes and credit carry-forward, the steeper ramp-up of the standard in Alternative 4, coupled with the five-year credit life, results in a prediction that manufacturers would need to take less cost-effective means to comply with the standards compared with the final phase-in period of MY 2021–2027. The public comments from industry commenters confirmed that this is a realistic prediction. For example, the Method B model predicts that some manufacturers will not implement any amount of strong hybrids on their vans during the 2021–2025 timeframe and instead will implement less effective technologies such as mild hybrids at higher penetration rates. There is also a 
high degree of sensitivity to the estimated effectiveness levels of individual technologies. At high penetration rates of all technologies on a vehicle, the result of a reduced effectiveness of even a single technology could be non-compliance with the standards. If the standards do not account for this uncertainty, there will be a real possibility that a manufacturer who followed the exact technology path we project will not meet their target because a technology performed slightly differently in their application. In this Method B analysis, EPA considered all comments regarding Alternative 4 and concluded that the longer lead time provided by the Phase 2 standards that the agencies are adopting is necessary as it better matches the redesign cycles for vehicles in this market segment and provides the time necessary for manufacturers to more fully utilize a range of technologies best suited for this market segment. These technologies are projected to be available within the lead time provided under the Phase 2 standards—i.e., by MY 2027, as 
discussed in RIA Chapter 2.6. These standards will require a relatively aggressive implementation schedule of most of these technologies during the program phase-in. Heavy-duty pickups and vans will need to have a combination of many individual technologies to achieve these standards. These standards are projected to yield 
significant emission and fuel consumption reductions without requiring a large segment transition to strong hybrids, a technology that while successful in light-duty passenger cars, cross-over vehicles and SUVs, may impact vehicle work capabilities
521and 
have questionable customer acceptance in a large portion of this segment dedicated to towing.
522See discussion 
above and in Section VI.D.9. 
The tables above show that many 
technologies will be at or potentially approach 100 percent adoption rates according to the analysis. If certain technologies turn out to be not well suited for certain vehicle models or less effective that projected, other technology pathways will be needed. The additional lead time provided by 
the Phase 2 standards reduces these concerns because manufacturers will have more flexibility to implement their compliance strategy and are more likely to do so within a product redesign cycle necessary for many new technologies to be implemented. 
The agencies also received comments 
that the standards should be based exclusively on the GHG capabilities of diesel vehicles. The commenters viewed the separate gasoline and diesel standards as preferential treatment of gasoline-powered vehicles which have inherently higher GHG and fuel consumption. As discussed in Section B.1, the agencies are maintaining the separate gasoline and diesel standards for heavy duty pickups and vans. As discussed earlier, diesel engines are fundamentally more efficient than gasoline engines providing the same power (even gasoline engines with the technologies discussed above) while using less fuel. However, dieselization is not a technology path the agencies included in the analysis for the Phase 1 rule or the Phase 2 rules. Gasoline- powered vehicles account for nearly half of the heavy-duty pickup and van market and are used in applications where a diesel may not make sense from a cost or consumer choice standpoint. Commenters did not address the costs of extensive dieselization. 
More stringent standards, including 
Alternative 4, could result in manufacturers switching from gasoline engines to diesel engines in certain challenging segments. While technologically feasible, EPA remains concerned that this pathway could cause a distortion in consumer choices and significantly increase the cost of those vehicles, particularly considering that more stringent standards are projected to require penetration of some form of hybridization. Also, the agencies did not consider the impact dieselization would have on lead-time, as shifting nearly half the market from gasoline to diesel engines would require substantial retooling of production. Commenters also did not account for the costs or address the feasibility of such retooling in the lead time available under either Phase 2 or Alternative 4. In addition, if dieselization occurs by manufacturers equipping vehicles with larger diesel engines designed for broad coverage of applications typical of this sector rather than ‘‘right-sized’’ engines, the towing capability of the vehicles could increase, resulting in higher work factors for the vehicles, higher targets, and reduced program benefits. Bosch 
commented that holding gasoline vehicles to the same GHG standards as 
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523See Table VI–27. 
524Analysis using the MOVES model indicates 
that the cost effectiveness of these standards is $95 per ton CO 2eq removed in MY 2030 (RIA Table 7– 
31), almost identical to the $90 per ton CO 2eq 
removed (MY 2030) which the agencies found to be highly cost effective for these same vehicles in 
Phase 1. See 76 FR 57228. diesels would bring the costs of 
compliance with all emissions standards, including criteria pollutant standards, for gasoline vehicles more in line with diesels, considering the costs of complying with criteria pollutant standards are much higher for diesels compared to gasoline vehicles. In response, EPA’s Method B analysis shows that significantly more stringent gasoline vehicle GHG standards may require high levels of hybridization which, as discussed above, may not be acceptable for this market segment. This, in turn, could lead to dieselization, as manufacturers would opt to phase out gasoline-fueled vehicles rather than opt for widespread hybridization of their product offerings. EPA continues to believe that it is reasonable to adopt Phase 2 standards that continue to preserve the opportunity for manufacturers to 
produce and consumers to choose gasoline-powered vehicles in this market segment. 
Based on the information presented 
here in this Method B analysis, EPA believes that the Phase 2 standards the agencies are finalizing are appropriate within the meaning of CAA section 202(a)(1), for this segment for the model years in question. EPA believes the standards reflect a reasonable consideration of the statutory factors of technology effectiveness, feasibility, cost, lead time, and safety for purposes of CAA sections 202(a)(1) and (2). The standards are appropriately technology- 
forcing, predicated on performance of technologies not only currently deployed but those which reasonably can be developed during the phase in period. EPA has indicated how technologies not currently deployed in this sector can be reliably commercialized in the lead time provided by the standard. See above and RIA Chapter 2.5 ‘‘Technology Application’’ where the individual technologies available during the phase- in are described in detail. Note that advanced technologies like strong hybridization will require several years of development prior to commercialization to meet required reliability and durability goals in this sector. As noted, the Method B analysis projects that the additional lead-time provided by the Phase 2 standards allows for the implement CO
2-reducing 
technologies without the need for 
significant hybridization and at a significantly lower cost compared to Alternative 4, as shown in the tables above. 
EPA has also carefully considered the 
costs of the standards. The technologies associated with meeting the Phase 2 standards are estimated to add costs to heavy-duty pickups and vans as shown in Table VI–31 for the flat baseline. These costs are the average fleet-wide incremental vehicle costs relative to a vehicle meeting the MY 2018 standard in each of the model years shown. Reductions associated with these costs 
and technologies are considerable, estimated at a 16 percent reduction of fuel consumption and CO
2eq emissions 
from the MY 2018 baseline for gasoline 
and diesel engine equipped vehicles.523 
As shown by the analysis, the long-term cost effectiveness of the rule is similar to that of the Phase 1 HD pickup and van standards (found by the agencies to be highly cost effective, without consideration of payback), and also falls within the range of the cost effectiveness for Phase 2 standards for the other HD sectors.
524The agencies 
have already found costs in this range to be cost effective (including for the heavy duty pickup and van sector), independent of the associated fuel savings. 76 FR 57228. EPA reiterates that finding here. Moreover, the cost of controls reflected in potential increased vehicle cost will be fully recovered by the operator due to the associated fuel savings, with a payback period somewhere in the third year of ownership, as shown in Section IX.M of this Preamble. The rules’ projected benefits far exceed costs (see IX.K), and costs are actually projected to be negative when fuel savings are considered. 
Consistent with EPA’s authority 
under 42 U.S.C. 7521(a) and based on its Method B analysis, EPA is thus finalizing the Phase 2 standards as proposed. 
TABLE VI–31—HD P ICKUPS AND VANSINCREMENTAL TECHNOLOGY COSTS PER VEHICLE FINAL PHASE 2 STANDARDS VS . 
FLATBASELINE  
2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 
NPRM (2012$) ......... $112 $104 $106 $516 $508 $791 $948 $1,161 $1,224 $1,342 
FRM (2013$) ............ 114 105 108 524 516 804 963 1,180 1,244 1,364 
(2) HD Pickups and Vans Industry 
Impacts (Method B) 
The analysis fleet provides a starting 
point for estimating the extent to which manufacturers might add fuel-saving (and, therefore, CO
2-avoiding) 
technologies under various regulatory alternatives, including the no-action alternative that defines a baseline against which to measure estimated impacts of new standards. The analysis fleet is a forward-looking projection of production of new HD pickups and 
vans, holding vehicle characteristics (e.g., technology content and fuel 
consumption levels) constant at model year 2014 levels, and adjusting production volumes based on recent DOE and commercially-available forecasts. This analysis fleet includes some significant changes relative to the market characterization that was used to develop the Phase 1 standards applicable starting in model year 2014; in particular, the analysis fleet includes some new HD vans (e.g., Ford’s Transit 
and Fiat Chrysler’s Promaster) that are considerably more fuel-efficient than HD vans these manufacturers have previously produced for the U.S. market. 
While the Phase 2 standards are 
scheduled to begin in model year 2021, the requirements they define are likely to influence manufacturers’ planning 
decisions several years in advance. This is true in light-duty planning, and is accentuated by the comparatively long redesign cycles and small number of models and platforms offered for sale in 
the 2b/3 market segment. Additionally, manufacturers will respond to the cost and efficacy of available fuel consumption improvements, the price of fuel, and the requirements of the Phase 1 standards that specify maximum allowable average fuel consumption and GHG levels for MY 2014–MY 2018 HD pickups and vans (the final standard for MY 2018 is held constant for model years 2019 and 
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525NHTSA generated hundreds of outputs related 
to economic and environmental impacts, each 
available technology, and the costs associated with the rule. A more comprehensive treatment of these outputs appears in Chapter 10 of the RIA. 526As noted above, the NHTSA CAFE model 
estimates that redesign schedules will ‘‘straddle’’ model year 2027, the latest year for which the agencies are increasing the stringency of fuel consumption and GHG standards. Considering also that today’s analysis estimates some earning and 
application of ‘‘carried forward’’ compliance credits, the model was run extending the analysis through model year 2030. 2020). The forward-looking nature of 
product plans that determine which vehicle models will be offered in the model years affected by these standards lead to additional technology application to vehicles in the analysis fleet that occurs in the years prior to the start of these standards. From the industry perspective, this means that manufacturers will incur costs to comply with these standards in the baseline and that the total cost of the regulations will include some costs that occur prior to their start, and represent incremental changes over a world in which manufacturers will have already modified their vehicle offerings compared to today. 
TABLE VI–32—MY 2021 M ETHOD B 
BASELINE COSTS FOR MANUFACTUR -
ERS IN 2b/3 M ARKET SEGMENT IN  
THEDYNAMIC BASELINE , ORALTER-
NATIVE 1b 
Manufacturer Average 
technology 
cost 
($) Total cost 
increase 
($m) 
Fiat Chrysler ..... 275 27 
Daimler ............. 18 0 
Ford .................. 258 78 
General Motors 782 191 
Nissan ............... 282 3 
Industry ............. 442 300 
As Table VI–32 shows, the industry as 
a whole is expected to add about $440 of new technology to each new vehicle model by 2021 under the no-action alternative defined by the Phase 1 standards. Reflecting differences in projected product offerings in the analysis fleet, some manufacturers (notably Daimler) are significantly less constrained by the Phase 1 standards than others and face lower cost increases as a result. General Motors (GM) shows the largest increase in average vehicle cost, but results for GM’s closest competitors (Ford and Fiat Chrysler) do not include the costs of their recent van redesigns, which are already present in the analysis fleet (discussed in greater detail below). 
The above results reflect the 
assumption that manufacturers having achieved compliance with standards might act as if buyers are willing to pay for further fuel consumption improvements that ‘‘pay back’’ within 6 months (i.e., those improvements whose 
incremental costs are exceeded by savings on fuel within the first six months of ownership). It is also possible that manufacturers will choose not to migrate cost-effective technologies to the 2b/3 market segment from similar vehicles in the light-duty market. Resultant technology costs in model year 2021 results for the no-action alternative, summarized in Table VI–33 below, are quite similar to those shown above for the 6-month payback period. Due to the similarity between the two baseline characterizations, results in the following discussion represent differences relative to only the 6-month payback baseline. 
TABLE VI–33—MY 2021 M ETHOD B 
BASELINE COSTS FOR HD P ICKUPS  
AND VANS IN THE FLATBASELINE , 
ORALTERNATIVE 1a 
Manufacturer Average 
technology 
cost 
($) Total cost 
increase 
($m) 
Fiat Chrysler ..... 268 27 
Daimler ............. 0 0 
Ford .................. 248 75 
General Motors 767 188 
Nissan ............... 257 3 
Industry ............. 431 292 
The results below represent the 
impacts of several regulatory alternatives, including those defined by the Phase 2 standards, as incremental changes over the baseline, where the baseline is defined as the state of the world in the absence of this regulatory action (but, of course, including the Phase 1 standards). Large-scale, macroeconomic conditions like fuel prices are constant across all alternatives, including the baseline, as are the fuel economy improvements under the no-action alternative defined by the Phase 1 rule that covers model years 2014–2018 and is constant from model year 2018 through 2020. In the baseline scenario, the Phase 1 standards are assumed to remain in place and at 2018 levels throughout the analysis (i.e. MY 2030). The only difference between the definitions of the alternatives is the stringency of these standards starting in MY 2021 and continuing through either MY 2025 or MY 2027, and all of the differences in outcomes across alternatives are attributable to differences in the standards. 
The standards vary in stringency 
across regulatory alternatives (1–5), but as discussed above, all of the standards are based on the curve developed in the Phase 1 standards that relate fuel economy and GHG emissions to a vehicle’s work factor. The alternatives considered here represent different rates of annual increase in the curve defined for model year 2018, growing from a 0 percent annual increase (Alternative 1, the baseline or ‘‘no-action’’ alternative) up to a 4 percent annual increase (Alternative 5). Table VI–34 shows a summary
525of outcomes by alternative 
incremental to the baseline (Alternative 1b) for Model Year 2030
526, with the 
exception of technology penetration rates, which are absolute. 
The technologies applied as inputs to 
the CAFE model (in either its Method B or A iterations) have been grouped (in most cases) to give readers a general sense of which types of technology are applied more frequently than others, and are more likely to be offered in new class 2b/3 vehicles once manufacturers are fully compliant with the standards in the alternative. Model year 2030 was chosen to account for technology application that occurs once the standards have stabilized, but manufacturers are still redesigning products to achieve compliance— generating technology costs and benefits in those model years. The summaries of technology penetration are also intended to reflect the relationship between technology application and cost increases across the alternatives. The table rows present the degree to which specific technologies are predicted to be present in new class 2b and class 3 vehicles in 2030, and correspond to: Variable valve timing (VVT) and/or variable valve lift (VVL), cylinder deactivation, direct injection, engine turbocharging, 8-speed automatic transmissions, electric power-steering and accessory improvements, micro- hybridization (which reduces engine idle, but does not assist propulsion), full hybridization (integrated starter generator or strong hybrid that assists propulsion and recaptures braking energy), and aerodynamic improvements to the vehicle shape. In addition to the technologies in the following tables, there are some lower- complexity technologies that have high market penetration across all the alternatives and manufacturers; low rolling-resistance tires, low friction lubricants, and reduced engine friction are examples. 
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TABLE VI–34—S UMMARY OF HD P ICKUPS AND VANSALTERNATIVES ’ IMPACT ON INDUSTRY VERSUS THE DYNAMIC  
BASELINE , ALTERNATIVE 1b; M ETHOD B 
Alternative 2 3 4 5 
Annual Stringency Increase ............................................................................. 2.0%/y 2.5%/y 3.5%/y 4.0 %/y 
Stringency Increase Through MY .................................................................... 2025 2027 2025 2025 
Total Stringency Increase ................................................................................ 9.6% 16.2% 16.3% 18.5%  
Average Fuel Economy (miles per gallon) 
Required .......................................................................................................... 19.04 20.57 20.57 21.14 
Achieved .......................................................................................................... 19.14 20.61 20.83 21.27 
Average Fuel Consumption (gallons/100 mi.) 
Required .......................................................................................................... 5.25 4.86 4.8 6 4.73 
Achieved .......................................................................................................... 5.22 4.85 4.80 4.70 
Average Greenhouse Gas Emissions (g/mi) 
Required .......................................................................................................... 495 458 458 446 
Achieved .......................................................................................................... 491 458 453 444 
Technology Penetration (%) 
VVT and/or VVL ............................................................................................... 46 46 46 46 
Cylinder Deac. ................................................................................................. 29 21 21 21 
Direct Injection ................................................................................................. 17 25 31 32 
Turbocharging .................................................................................................. 55 63 63 63 
8-Speed AT ...................................................................................................... 67 96 96 97 
EPS, Accessories ............................................................................................ 54 80 79 79 
Stop Start ......................................................................................................... 0 0 10 13 
Hybridizationa.................................................................................................. 0 8 35 51 
Aero. Improvements ........................................................................................ 36 78 78 78 
Mass Reduction (vs. No-Action) 
CW (lb.) ............................................................................................................ 239 243 325 313 
CW (%) ............................................................................................................ 3.7 3.7 5.0 4 .8 
Technology Cost (vs. No-Action) 
Average ($)b.................................................................................................... 578 1,348 1,655 2,080 
Total ($m)c...................................................................................................... 437 1,019 1,251 1,572 
Payback period (m)c....................................................................................... 25 31 34 38 
Notes: 
aIncludes mild hybrids (ISG) and strong HEVs. 
bValues used in Methods A & B 
cValues used in Method A, calculated using a 3% discount rate. 
In general, as stated above, the 
Method B model projected that the 
standards will cause manufacturers to produce HD pickups and vans that are lighter, more aerodynamic, and more technologically complex across all the alternatives. As Table VI–34 shows, there is a difference between the relatively small increases in required fuel economy and average incremental technology cost between the alternatives, suggesting that the challenge of improving fuel consumption and CO
2emissions 
accelerates as stringency increases (i.e., that there may be a ‘‘knee’’ in the relationship between technology cost 
and reductions in fuel consumption/ GHG emissions). 
The contrast between alternatives 3 
and 4 is even more prominent, with an identical required fuel economy 
improvement projected to lead to price increases greater than 20 percent based on the more rapid rate of increase and shorter time span of Alternative 4, which achieves all of its increases by MY 2025 while Alternative 3 continues to increase at a slower rate until MY 2027. Despite these differences, the increase in average payback period when moving from Alternative 3 to Alternative 4 to Alternative 5 is fairly constant at around an additional three months for each jump in stringency. 
Manufacturers offer few models, 
typically only a pickup truck and/or a cargo van, and while there are a large number of variants of each model, the 
degree of component sharing across the variants can make diversified technology application either economically impractical or impossible. 
This forces manufacturers to apply some technologies more broadly in order to achieve compliance than they might do in other market segments (passenger cars, for example). This difference between broad and narrow application—where some technologies must be applied to entire platforms, while some can be applied to individual model variants—also explains why certain technology penetration rates decrease between alternatives of increasing stringency (cylinder deactivation or mass reductions in Table VI–34, for example). For those cases, narrowly applying a more advanced (and costly) technology can be a more cost effective path to compliance and lead to reductions in the amount of 
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lower-complexity technology that is 
applied. 
As noted in Section E.1 above, one 
driver of the change in technology cost between Alternative 3 and Alternative 4 in the Method B analysis is the amount of hybridization projected to result from the implementation of the standards. While only about 5 percent full hybridization (defined as either integrated starter-generator or strong hybrid) is expected to be needed to comply with Alternative 3, the higher rate of increase and compressed schedule moving from Alternative 3 to Alternative 4 is enough to increase the percentage of the fleet adopting full hybridization by a factor of two. To the extent that manufacturers are concerned about introducing hybrid vehicles in the 2b and 3 market, it is worth noting that new vehicles subject to Alternative 3 achieve the same fuel economy as new vehicle subject to Alternative 4 by 2030, with less full hybridization projected under this Method B analysis as being needed to achieve the improvement. 
The alternatives also lead to 
important differences in outcomes at the manufacturer level, both from the industry average and from each other. General Motors, Ford, and Fiat Chrysler, are expected to have approximately 95 percent of the 2b/3 new vehicle market during the years that these standards are being phased in. Due to their importance to this market and the similarities between their model offerings, these three manufacturers are discussed together and a summary of the way each is impacted by the standards appears below in Table VI–35, Table VI–36 and Table VI–37 for General Motors, Ford, and Fiat Chrysler, respectively. 
TABLE VI–35—S UMMARY OF IMPACTS ON GENERAL MOTORS BY 2030 IN THE HD P ICKUP AND VANMARKET VERSUS THE  
DYNAMIC BASELINE , ALTERNATIVE 1b 
Alternative 2 3 4 5 
Annual Stringency Increase ............................................................................. 2.0%/y 2.5%/y 3.5%/y 4.0 %/y 
Stringency Increase Through MY .................................................................... 2025 2027 2025 2025 
Average Fuel Economy (miles per gallon) 
Required .......................................................................................................... 18.38 19.96 20 20.53 
Achieved .......................................................................................................... 18.43 19.95 20.24 20.51 
Average Fuel Consumption (gallons/100 mi.) 
Required .......................................................................................................... 5.44 5.01 5 4 .87 
Achieved .......................................................................................................... 5.42 5.01 4.94 4.87 
Average Greenhouse Gas Emissions (g/mi) 
Required .......................................................................................................... 507 467 467 455 
Achieved .......................................................................................................... 505 468 461 455 
Technology Penetration (%) 
VVT and/or VVL ............................................................................................... 64 64 64 64 
Cylinder Deac. ................................................................................................. 47 47 47 47 
Direct Injection ................................................................................................. 18 18 36 36 
Turbocharging .................................................................................................. 53 53 53 53 
8-Speed AT ...................................................................................................... 36 100 100 100 
EPS, Accessories ............................................................................................ 100 100 100 100 
Stop Start ......................................................................................................... 0 0 2 0 
Hybridization .................................................................................................... 0 19 79 100 
Aero. Improvements ........................................................................................ 100 100 100 100 
Mass Reduction (vs. No-Action) 
CW (lb.) ............................................................................................................ 325 161 158 164 
CW (%) ............................................................................................................ 5.3 2.6 2.6 2 .7 
Technology Cost (vs. No-Action) 
Average ($)a.................................................................................................... 785 1,706 2,244 2,736 
Total ($m, undiscounted)b............................................................................... 214 465 611 746 
Notes: 
aValues used in Methods A & B. 
bValues used in Method A, calculated at a 3% discount rate. 
TABLE VI–36—S UMMARY OF IMPACTS ON FORD BY 2030 IN THE HD P ICKUP AND VANMARKET VERSUS THE DYNAMIC  
BASELINE , ALTERNATIVE 1b 
Alternative 2 3 4 5 
Annual Stringency Increase ............................................................................. 2.0%/y 2.5%/y 3.5%/y 4.0 %/y 
Stringency Increase Through MY .................................................................... 2025 2027 2025 2025 
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TABLE VI–36—S UMMARY OF IMPACTS ON FORD BY 2030 IN THE HD P ICKUP AND VANMARKET VERSUS THE DYNAMIC  
BASELINE , ALTERNATIVE 1b—Continued 
Alternative 2 3 4 5 
Average Fuel Economy (miles per gallon) 
Required .......................................................................................................... 19.42 20.96 20.92 21.51 
Achieved .......................................................................................................... 19.5 21.04 21.28 21.8 
Average Fuel Consumption (gallons/100 mi.) 
Required .......................................................................................................... 5.15 4.77 4.7 8 4.65 
Achieved .......................................................................................................... 5.13 4.75 4.70 4.59 
Average Greenhouse Gas Emissions (g/mi) 
Required .......................................................................................................... 485 449 450 438 
Achieved .......................................................................................................... 482 447 443 433 
Technology Penetration (%) 
VVT and/or VVL ............................................................................................... 34 34 34 34 
Cylinder Deac. ................................................................................................. 18 0 0 0 
Direct Injection ................................................................................................. 16 34 34 34 
Turbocharging .................................................................................................. 51 69 69 69 
8-Speed AT ...................................................................................................... 100 100 100 100 
EPS, Accessories ............................................................................................ 41 62 59 59 
Stop Start ......................................................................................................... 0 0 20 29 
Hybridization .................................................................................................... 0 2 14 30 
Aero. Improvements ........................................................................................ 0 59 59 59 
Mass Reduction (vs. No-Action) 
CW (lb.) ............................................................................................................ 210 202 379 356 
CW (%) ............................................................................................................ 3.2 3 5.7 5.3 
Technology Cost (vs. No-Action) 
Average ($)a.................................................................................................... 506 1,110 1,353 1,801 
Total ($m, undiscounted)b............................................................................... 170 372 454 604 
Notes: 
aValues used in Methods A & B. 
bValues used in Method A, calculated at a 3% discount rate. 
TABLE VI–37—S UMMARY OF IMPACTS ON FIATCHRYSLER BY 2030 IN THE HD P ICKUP AND VANMARKET VERSUS THE  
DYNAMIC BASELINE , ALTERNATIVE 1b 
Alternative 2 3 4 5 
Annual Stringency Increase ............................................................................. 2.0%/y 2.5%/y 3.5%/y 4.0 %/y 
Stringency Increase Through MY .................................................................... 2025 2027 2025 2025 
Average Fuel Economy (miles per gallon) 
Required .......................................................................................................... 18.73 20.08 20.12 20.70 
Achieved .......................................................................................................... 18.83 20.06 20.10 20.70 
Average Fuel Consumption (gallons/100 mi.) 
Required .......................................................................................................... 5.34 4.98 4.9 7 4.83 
Achieved .......................................................................................................... 5.31 4.99 4.97 4.83 
Average Greenhouse Gas Emissions (g/mi) 
Required .......................................................................................................... 515 480 479 466 
Achieved .......................................................................................................... 512 481 480 467 
Technology Penetration (%) 
VVT and/or VVL ............................................................................................... 40 40 40 40 
Cylinder Deac. ................................................................................................. 23 23 23 23 
Direct Injection ................................................................................................. 17 17 17 17 
Turbocharging .................................................................................................. 74 74 74 74 
8-Speed AT ...................................................................................................... 65 88 88 88 
EPS, Accessories ............................................................................................ 0 100 100 100 
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TABLE VI–37—S UMMARY OF IMPACTS ON FIATCHRYSLER BY 2030 IN THE HD P ICKUP AND VANMARKET VERSUS THE  
DYNAMIC BASELINE , ALTERNATIVE 1b—Continued 
Alternative 2 3 4 5 
Stop-Start ......................................................................................................... 0 0 0 0 
Hybridization .................................................................................................... 0 3 3 10 
Aero. Improvements ........................................................................................ 0 100 100 100 
Mass Reduction (vs. No-Action) 
CW (lb.) ............................................................................................................ 196 649 648 617 
CW (%) ............................................................................................................ 2.8 9.1 9.1 8 .7 
Technology Cost (vs. No-Action) 
Average ($) a................................................................................................... 434 1,469 1,486 1,700 
Total ($m, undiscounted) b.............................................................................. 48 163 164 188 
Notes: 
aValues used in Methods A & B. 
bValues used in Method A, calculated at a 3% discount rate. 
The fuel consumption and GHG 
standards require manufacturers to 
achieve an average level of compliance, represented by a sales-weighted average across the specific targets of all vehicles offered for sale in a given model year, such that each manufacturer will have a unique required consumption/ emissions level determined by the composition of its fleet, as illustrated above. However, there are more interesting differences than the small differences in required fuel economy levels among manufacturers. In particular, the average incremental technology cost increases with the stringency of the alternative for each manufacturer, but the size of the cost increase from one alternative to the next varies among them, with General Motors showing considerably larger increases in cost moving from Alternative 3 to Alternative 4, than from either Alternative 2 to Alternative 3 or Alternative 4 to Alternative 5. Ford is estimated to have more uniform cost increases from each alternative to the next, in increasing stringency, though still benefits from the reduced pace and longer period of increase associated with Alternative 3 compared to Alternative 4. 
The Method B simulation results 
show all three manufacturers facing cost increases when the stringency of the standards move from 2.5 percent annual increases over the period from MY 2021–2027 to 3.5 percent annual increases from MY 2021–2025, but General Motors has the largest at 75 percent more than the industry average price increase for Alternative 4. GM also faces higher cost increases in Alternative 2 about 50 percent more than either Ford or Fiat Chrysler. And for the most stringent alternative considered, EPA estimates that General Motors will face average cost increases of more than $2,700, in addition to the more than $700 increase in the baseline—approaching nearly $3,500 per vehicle over today’s prices. 
Technology choices also differ by 
manufacturer, and some of those decisions are directly responsible for the largest cost discrepancies. For example, in this Method B analysis, GM is estimated to engage in the least amount of mass reduction among the Big 3 after Phase 1, and much less than Fiat Chrysler, but reduces average vehicle mass by over 300 lbs. in the baseline— suggesting that some of GM’s easiest Phase 1 compliance opportunities can be found in lightweighting technologies. Similarly, Fiat Chrysler is projected to apply less hybridization than the others, and much less than General Motors, which is simulated in Alternative 4 to have full hybrids (either integrated starter generator or complete hybrid system) on all of its fleet by 2030, nearly 20 percent of which will be strong hybrids, and the strong hybrid share decreases to about 18 percent in Alternative 5, as some lower level technologies are applied more broadly. Because the analysis applies the same technology inputs and the same logic for selecting among available opportunities to apply technology, the unique situation of each manufacturer determined which technology path is projected as the most cost-effective. 
In order to understand the differences 
in incremental technology costs and fuel economy achievement across manufacturers in this market segment, it is important to understand the differences in their starting position relative to these standards. One important factor, made more obvious in the following figures, is the difference between the fuel economy and performance of the recently redesigned vans offered by Fiat Chrysler and Ford (the Promaster and Transit, respectively), and the more traditionally-styled vans that continue to be offered by General Motors (the Express/Savannah). In MY 2014, Ford began the phase-out of the Econoline van platform, moving those volumes to the Euro-style Transit vans (discussed in more detail in Section VI.D.2). The Transit platform represents a significant improvement over the existing Econoline platform from the perspective of fuel economy, and for the purpose of complying with the standards, the relationship between the Transit’s work factor and fuel economy is a more favorable one than the Econoline vans it replaces. Since the redesign of van offerings from both Fiat Chrysler and Ford occur in (or prior to) the 2014 model year, the costs, fuel consumption improvements, and reductions of vehicle mass associated with those redesigns are included in the analysis fleet, meaning they are not carried forward as part of the compliance modeling exercise. By contrast, General Motors is simulated to redesign their van offerings after 2014, such that there is a greater potential for these vehicles to incur additional costs attributable to new standards, unlike the costs associated with the recent redesigns of their competitors. The inclusion of these new Ford and Fiat Chrysler products in the analysis fleet is the primary driver of the cost discrepancy between GM and its competitors in both the baseline and Alternative 2 in this Method B analysis, when Ford and Fiat Chrysler have to apply considerably less technology to achieve compliance. 
The remaining 5 percent of the 2b/3 
market is attributed to two manufacturers, Daimler and Nissan, 
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which, unlike the other manufacturers 
in this market segment, only produce vans. The vans offered by both manufacturers currently utilize two engines and two transmissions, although both Nissan engines are gasoline engines and both Daimler engines are diesels. Despite the logical grouping, these two manufacturers are projected to be impacted much differently by these standards. For the least stringent alternative considered, Daimler is projected to add no technology and incurs no incremental cost in order to comply with the standards. At stringency increases greater than or equal to 3.5 percent per year, Daimler only really improves some of their transmissions and improves the electrical accessories of its Sprinter vans. By contrast, Nissan’s starting position is much weaker and their compliance costs closer to the industry average in Table VI–34. This difference could increase if the analysis fleet supporting the final rule includes forthcoming Nissan HD pickups. 
TABLE VI–38—S UMMARY OF IMPACTS ON DAIMLER BY 2030 IN THE HD P ICKUP AND VANMARKET VERSUS THE DYNAMIC  
BASELINE , ALTERNATIVE 1b 
Alternative 2 3 4 5 
Annual Stringency Increase ............................................................................. 2.0%/y 2.5%/y 3.5%/y 4.0 %/y 
Stringency Increase Through MY .................................................................... 2025 2027 2025 2025 
Average Fuel Economy (miles per gallon) 
Required .......................................................................................................... 23.36 25.19 25.25 25.91 
Achieved .......................................................................................................... 25.23 25.79 25.79 26.53 
Average Fuel Consumption (gallons/100 mi.) 
Required .......................................................................................................... 4.28 3.97 3.9 6 3.86 
Achieved .......................................................................................................... 3.96 3.88 3.88 3.77 
Average Greenhouse Gas Emissions (g/mi) 
Required .......................................................................................................... 436 404 404 393 
Achieved .......................................................................................................... 404 395 395 384 
Technology Penetration (%) 
VVT and/or VVL ............................................................................................... 0 0 0 0 
Cylinder Deac. ................................................................................................. 0 0 0 0 
Direct Injection ................................................................................................. 0 0 0 0 
Turbocharging .................................................................................................. 44 44 44 44 
8-Speed AT ...................................................................................................... 0 44 44 100 
EPS, Accessories ............................................................................................ 0 0 0 0 
Stop-Start ......................................................................................................... 0 0 0 0 
Hybridization .................................................................................................... 0 0 0 0 
Aero. Improvements ........................................................................................ 0 0 0 0 
Mass Reduction (vs. No-Action) 
CW (lb.) ............................................................................................................ 0 0 0 0 
CW (%) ............................................................................................................ 0 0 0 0 
Technology Cost (vs. No-Action) 
Average ($) a................................................................................................... 0 165 165 374 
Total ($m, undiscounted) b.............................................................................. 0 4 4 9 
Notes: 
aValues used in Methods A & B. 
bValues used in Method A, calculated at a 3% discount rate. 
TABLE VI–39—S UMMARY OF IMPACTS ON NISSAN BY 2030 IN THE HD P ICKUP AND VANMARKET VERSUS THE DYNAMIC  
BASELINE , ALTERNATIVE 1b 
Alternative 2 3 4 5 
Annual Stringency Increase ............................................................................. 2.0%/y 2.5%/y 3.5%/y 4.0 %/y 
Stringency Increase Through MY .................................................................... 2025 2027 2025 2025 
Average Fuel Economy (miles per gallon) 
Required .......................................................................................................... 19.64 21.19 20.92 21.46 
Achieved .......................................................................................................... 19.84 21.17 21.19 21.51 
Average Fuel Consumption (gallons/100 mi.) 
Required .......................................................................................................... 5.09 44.72 4. 78 4.66 
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527See 40 CFR 1037.104(d) and the proposed 40 
CFR 86.1819–14(d). Credits may not be transferred 
or traded between this vehicle averaging set and 
loose engines or other heavy-duty categories, as discussed in Section I. TABLE VI–39—S UMMARY OF IMPACTS ON NISSAN BY 2030 IN THE HD P ICKUP AND VANMARKET VERSUS THE DYNAMIC  
BASELINE , ALTERNATIVE 1b—Continued 
Alternative 2 3 4 5 
Achieved .......................................................................................................... 5.04 4.72 4.72 4.65 
Average Greenhouse Gas Emissions (g/mi) 
Required .......................................................................................................... 452 419 425 414 
Achieved .......................................................................................................... 448 419 419 413 
Technology Penetration (%) 
VVT and/or VVL ............................................................................................... 100 100 100 100 
Cylinder Deac. ................................................................................................. 49 49 49 49 
Direct Injection ................................................................................................. 51 51 51 100 
Turbocharging .................................................................................................. 51 51 51 50 
8-Speed AT ...................................................................................................... 0 51 51 51 
EPS, Accessories ............................................................................................ 0 100 100 100 
Stop-Start ......................................................................................................... 0 0 0 0 
Hybridization .................................................................................................... 0 0 0 28 
Aero. Improvements ........................................................................................ 0 100 100 100 
Mass Reduction (vs. No-Action) 
CW (lb.) ............................................................................................................ 0 0 307 303 
CW (%) ............................................................................................................ 0 0 5 4.9 
Technology Cost (vs. No-Action) 
Average ($)a.................................................................................................... 378 1,150 1,347 1,935 
Total ($m, undiscounted)b............................................................................... 5 15.1 17.7 25.4 
Notes: 
aValues used in Methods A & B. 
bValues used in Method A, calculated at a 3% discount rate. 
As Table VI–38 and Table VI–39 
show, Nissan is projected to apply more 
technology than Daimler in the less stringent alternatives and significantly more technology with increasing stringency. The Euro-style Sprinter vans that comprise all of Daimler’s model offerings in this segment put Daimler in a favorable position. However, those vans are already advanced—containing downsized diesel engines and advanced 
aerodynamic profiles. Much like the Ford Transit vans, the recent improvements to the Sprinter vans occurred outside the scope of the compliance modeling so the costs of the improvements are not captured in the analysis. 
Although Daimler’s required fuel 
economy level is much higher than Nissan’s (in miles per gallon), Nissan starts from a much weaker position than Daimler and must incorporate additional engine, transmission, platform-level technologies (e.g., mass 
reduction and aerodynamic improvements) in order to achieve compliance. In fact, more than 25 percent of Nissan’s van offerings are projected to contain integrated starter generators by 2030 in Alternative 5. 
While the model does not allow sales 
volumes for any manufacturer (or model) to vary across regulatory alternatives in the analysis, it is conceivable that under the most stringent alternatives individual manufacturers could lose market share to their competitors if the prices of their new vehicles rise more than the industry average without compensating fuel savings and/or changes to other features. 
F. Compliance and Flexibility for HD 
Pickup and Van Standards 
(1) Averaging, Banking, and Trading 
The Phase 1 program established 
substantial flexibility in how 
manufacturers can choose to implement EPA and NHTSA standards while preserving the benefits for the environment and for energy consumption and security. Primary among these flexibilities are the gradual phase-in schedule, and the corporate fleet average approach which encompasses averaging, banking and trading described below. See Section IV.A. of the Phase 1 Preamble (76 FR 57238) for additional discussion of the Phase 1 averaging, banking, and trading and Section IV.A (3) of the Phase 1 Preamble (76 FR 57243) for a discussion of the credit calculation methodology. 
Manufacturers in this category 
typically offer gasoline and diesel versions of HD pickup and van vehicle 
models. The agencies established chassis-based Phase 1 standards that are equivalent in terms of stringency for gasoline and diesel vehicles and are continuing this same approach to stringency for Phase 2. In Phase 1, the agencies established that HD pickups and vans are treated as one large averaging set that includes both gasoline and diesel vehicles
527and the agencies 
will maintain this averaging set approach for Phase 2, as discussed above in Section VI.B. 
As explained in Section II.C.(3) of the 
Phase 1 Preamble (76 FR 57167), and in Section VI.B (3) above, the program is structured so that final compliance is determined at the end of each model year, when production for the model year is complete. At that point, each manufacturer calculates production- weighted fleet average CO
2emission 
and fuel consumption rates along with its production-weighted fleet average standard. Under this approach, a manufacturer’s HD pickup and van fleet that achieves a fleet average CO
2or fuel 
consumption level better than its 
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standard will be allowed to generate 
credits. Conversely, if the fleet average CO
2or fuel consumption level does not 
meet its standard, the fleet will incur debits (also referred to as a shortfall). 
A manufacturer whose fleet generates 
credits in a given model year will have several options for using those credits to offset emissions from other HD pickups and vans. These options include credit carry-back, credit carry-forward, and credit trading within the HD pickup and van averaging set. These types of credit provisions also exist in the light-duty 2012–2016 and 2017–2025 MY vehicle rules, as well as many other mobile source standards issued by EPA under the CAA. The manufacturer will be able to carry back credits to offset a deficit that had accrued in a prior model year and was subsequently carried over to the current model year, with a limitation on the carry-back of credits to three model years. After satisfying any need to offset pre-existing deficits, a manufacturer may bank remaining credits for use in future years, with a limitation on the carry-forward of credits to five model years. Averaging vehicle credits with engine credits or between vehicle weight classes is not allowed, as discussed in Section I. The agencies did not propose and are not adopting any changes to any of these provisions for the Phase 2 program. 
While the agencies proposed to retain 
5 year carry-forward of credits for all HD sectors, the agencies requested comment on the merits of a temporary credit carry-forward period of longer than 5 years for HD pickups and vans, allowing Phase 1 credits generated in MYs 2014– 2019 to be used through MY 2027. 80 FR 40388. The agencies received several comments regarding credit carry- forward. AAPC commented that manufacturers should be allowed to carry-forward credits indefinitely until they are used to offset a deficit. AAPC commented that longer credit life batter aligns with the longer redesign cycles and the smaller production volumes for HD vehicles compared to light-duty vehicles. AAPC also commented that longer credit life would motivate earlier introduction of technology and lower compliance costs, while not changing the overall effectiveness of the program. Nissan and Daimler commented in support of a one-time credit carry- forward that would allow Phase 1 credits to be used through MY 2027. The UAW also generally supported extended credit carry-forward. The agencies also received comments from CARB that the agencies should not allow Phase 1 credits to be carried 
forward into Phase 2. CARB commented that Phase 1 credits should be limited to a three year carry-forward or MY 2020 
whichever is sooner. CARB is concerned that Phase 1 credits may reduce the efficacy of the Phase 2 program and delay technology development progress. 
As noted above, the agencies are 
retaining the 5 year credit carry-forward provisions as proposed for HD pickups and vans. As discussed in Section VI.C., the agencies believe that the standards are feasible without extending the credit carry-forward provisions. The agencies continue to believe that credit carry- forward provides important flexibility to manufacturer especially in transitioning to more stringent standards and restricting the provision could be disruptive to manufacturer product plans. However, the agencies understand CARB’s concerns regarding Phase 1 credits being used to postpone technology progress if some manufacturers were to accumulate large credit banks under Phase 1. Large banks of Phase 1 credits combined with unlimited credit-forward could have the unintended effect of allowing some manufacturers to delay the application of Phase 2 technologies. The 5 year credit carry-forward preserves needed flexibility for transitioning to more stringent Phase 2 standards while also helping to address concerns regarding delaying the introduction of technology in Phase 2 for HD pickups and vans. As discussed in Section I.C.(1)(b)(i), the agencies are extending credit life for certain vocational vehicle subcategories during the transition to the Phase 2 standards. We are doing this for two reasons. First, some manufacturers in these in categories do not have diversified production, which limits the extent to which they can use ABT. Second, the Phase 1 program offer little opportunity for manufacturers to build up their credit balances. Neither of these reasons apply for HD pickups and vans. 
As discussed in Section VI.B.4., EPA 
and NHTSA are changing the HD pickup and van useful life for GHG emissions and fuel consumption from the current 11 years/120,000 miles to 15 years/150,000 miles to make the useful life for GHG emissions consistent with the useful life of criteria pollutants recently updated in the Tier 3 rule. As shown in the Equation VI.1 credits calculation formula below, established by the Phase 1 rule, useful life in miles is a multiplicative factor included in the calculation of CO
2and fuel 
consumption credits. In order to ensure banked credits maintain their value in the transition from Phase 1 to Phase 2, NHTSA and EPA proposed and are finalizing an adjustment factor of 1.25 
(i.e., 150,000 ÷ 120,000) for credits that 
are carried forward from Phase 1 to the MY 2021 and later Phase 2 standards. 
Without this adjustment factor, the change in useful life would effectively result in a discount of banked credits that are carried forward from Phase 1 to Phase 2, which is not the intent of the change in the useful life. Consider, for example, a vehicle configuration with annual sales of 1,000 vehicles that was 10 g/mile below the standard. Under Phase 1, those vehicles would generate 1,200 Mg of credit (10 × 1,000 × 120,000 
÷ 1,000,000). Under Phase 2, the same 
vehicles would generate 1,500 Mg of credit (10 × 1,000 × 150,000 ÷ 
1,000,000). The agencies do not believe that this adjustment results in a loss of program benefits because there is little or no deterioration anticipated for CO
2 
emissions and fuel consumption over the life of the vehicles. Also, as described in the standards and feasibility sections above, the carry- forward of credits is an integral part of the program, helping to smoothing the 
transition to the new Phase 2 standards. The agencies believe that effectively discounting carry-forward credits from Phase 1 to Phase 2 is unnecessary and could negatively impact the feasibility of the Phase 2 standards. 
Equation VI.1 Total Model Year Credit 
(Debit) Calculation 
CO
2Credits (Mg) = [(CO 2Std¥CO 2Act) 
× Volume × UL] ÷ 1,000,000 
Fuel Consumption Credits (gallons) = 
(FC Std¥FC Act) × Volume × UL × 
100 
Where: 
CO 2Std = Fleet average CO 2standard (g/mi) 
FC Std = Fleet average fuel consumption 
standard (gal/100 mile) 
CO 2Act = Fleet average actual CO 2value (g/ 
mi) 
FC Act = Fleet average actual fuel 
consumption value (gal/100 mile) 
Volume = the total production of vehicles in 
the regulatory category 
UL = the useful life for the regulatory 
category (miles) 
Manufacturers provided comments in 
support of applying the adjustment 
factor discussed above. CARB recommended not including the adjustment factor. CARB commented that the adjustment would take benefits achieved under the Phase 1 program and allow them to be used to reduce the potential benefits of Phase 2 standards. The agencies do not view the 1.25 adjustment as reducing the benefits of the program because the adjustment to the Phase 1 credits is completely offset by the increase in the useful life used in the Phase 2 credits calculation shown above. In other words, when the Phase 1 credits are used in Phase 2, 1.25 times more credits will be needed to cover a deficit than would be needed under 
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528EPA and NHTSA similarly included 
temporary advanced technology multipliers in the 
light-duty 2017–2025 program, believing it was worthwhile to forego modest additional emissions reductions and fuel consumption improvements in the near-term in order to lay the foundation for the potential for much larger ‘‘game-changing’’ GHG and oil consumption reductions in the longer term. The incentives in the light-duty vehicle program are available through the 2021 model year. See 77 FR 62811, October 15, 2012. 
529See 76 FR 57251, September 15, 2011, 40 CFR 
1037.104(d)(13), and 40 CFR 86.1819–14(d)(13). Note that for the vocational vehicle and tractor standards, and off-cycle credit is to evaluate technologies whose benefit is not recognized by GEM (rather than the two-cycle test). See V.D.3 and III.F.3, respectively. 530Fuel consumption is derived from measured 
CO 2emissions using conversion factors of 8,887 g 
CO 2/gallon for gasoline and 10,180 g CO 2/gallon for 
diesel fuel. 
53177 FR 62832–62839, October 15, 2012. Phase 1. The agencies continue to 
believe this is a reasonable and indeed, necessary, way to address the change in useful life as it applies to the credits calculations. 
(2) Advanced Technology Credits 
The Phase 1 program included on an 
interim basis advanced technology 
credits for MYs 2014 and later in the form of a multiplier of 1.5 for the following technologies: 
•Hybrid powertrain designs that 
include energy storage systems 
•Waste heat recovery 
•All-electric vehicles 
•Fuel cell vehicles 
The advanced technology credit 
program is intended to encourage early development of technologies that are not yet commercially available. This multiplier approach means that each advanced technology vehicle will count as 1.5 vehicles in a manufacturer’s compliance calculation.
528The 
advanced technology multipliers were included on an interim basis in the Phase 1 program and the incentive multipliers included for Phase 1and the 1.5 multiplier incentive adopted for Phase 1 will end beginning in MY 2021, when the more stringent Phase 2 standards are to begin phase-in. However, the agencies are including new incentive multipliers for Phase 2 for PHEVs, EVs, and fuel cell vehicles. 
As discussed in Section I, the 
agencies requested comment on whether or not the incentive multiplier credits should be extended to later model years for more advanced technologies such as EVs and fuel cell vehicles. These technologies are not projected to be part of the technology path used by manufacturers to meet the Phase 2 standards for HD pickups and vans. EV and fuel cell technologies will presumably need to overcome the highest hurdles to commercialization for HD pickups and vans in the time frame of the final rules, and also have the potential to provide the highest level of benefit. The agencies received several comments encouraging the agencies to continue advanced technology multipliers in Phase 2 for heavy-duty vehicles. After considering these comments, and considering that EV and fuel technologies have the potential for 
more significant emission reductions and fuel consumption savings than any of the technologies projected to be used for Phase 2 compliance, the agencies are adopting new incentive multipliers for Phase 2 for these technologies for all heavy-duty vehicle sectors. A detailed discussion of these provisions is provided above in Section I. 
NHTSA and EPA established that for 
Phase 1, EVs and other zero tailpipe emission vehicles be factored into the fleet average GHG and fuel consumption calculations based on the diesel standards targets for their model year and work factor. The agencies also established for electric and zero emission vehicles that in the credits equation the actual emissions and fuel consumption performance be set to zero (i.e., that emissions be considered on a tailpipe basis exclusively) rather than including upstream emissions or energy consumption associated with electricity generation. As we look to the future, we are not projecting the adoption of electric HD pickups and vans into the heavy duty market; therefore, we believe 
that this provision is still appropriate. Unlike the MY 2012–2016 light-duty rule, which adopted a cap whereby upstream emissions will be counted after a certain volume of sales (see 75 FR 25434–25436), we believe there is no need to a cap for HD pickups and vans because of the infrequent projected use of EV technologies in the Phase 2 timeframe. In Phase 2, we thus continue to deem electric vehicles as having zero CO
2, CH 4, and N 2O emissions as well as 
zero fuel consumption. See Section I for a discussion of the treatment of lifecycle emissions for alternative fuel vehicles, including comments regarding the treatment of upstream emissions, and Section XI for the treatment of lifecycle emissions for natural gas specifically. 
(3) Off-Cycle Technology Credits 
The Phase 1 program established an 
opportunity for manufacturers to 
generate credits by applying innovative technologies whose CO
2and fuel 
consumption benefits are not captured on the 2-cycle test procedure (i.e., off- cycle).
529For HD pickups and vans, the 
approach for off-cycle technologies established in Phase 1 is similar to that established for light-duty vehicles due to the use of the same basic chassis test procedures. The agencies are retaining this approach for Phase 2 as proposed. See 80 FR 40389. To generate credits, manufacturers are required to submit data and a methodology for determining the level of credits for the off-cycle technology subject to EPA and NHTSA review and approval. The application for off-cycle technology credits is also subject to a public evaluation process and comment period. EPA and NHTSA would approve the methodology and credits only if certain criteria were met. Baseline emissions and fuel consumption
530and control emissions 
and fuel consumption need to be clearly demonstrated over a wide range of real world driving conditions and over a sufficient number of vehicles to address issues of uncertainty with the data. Data must be on a vehicle model-specific basis unless a manufacturer demonstrated model-specific data were not necessary. Once a complete application is submitted by the manufacturer, the regulations require that the agencies publish a notice of availability in the Federal Register notifying the public of a manufacturer’s off-cycle credit calculation methodology and provide opportunity for comment. 
EPA and NHTSA requested comment 
on establishing a pre-defined technology menu list for HD pickups and vans similar to the approach adopted for light-duty vehicles in the MY 2017– 2025 rule.
531As with the light-duty 
vehicle program, the agencies noted that a pre-defined list could simplify the process for generating off-cycle credits and may further encourage the introduction of these technologies. However, the agencies also noted that appropriate default level of credits for the heavier vehicles would need to be established. The agencies requested comments with supporting HD pickup and van specific data and analysis that would provide a substantive basis for appropriate credits levels for the HD pickup and van category. The data and analysis would need to demonstrate that the pre-defined credit level represents real-world emissions reductions and fuel consumption improvements not captured by the 2-cycle test procedures. 
The agencies received comments 
recommending off-cycle credits for over a dozen technologies. There are three primary reasons that the agencies are not adopting credits for the individual technologies recommended by commenters. In many cases, the analysis provided by commenters did not 
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532This provision states that an off-cycle credit 
must be for a technology that is ‘‘not adequately 
captured on the Federal Test procedure (FTP) and/ or the highway Fuel Economy Test (HFET).’’ EPA has indicated that this requires manufacturers to demonstrate ‘‘an incremental off-cycle benefit that is significantly greater than the 2-cycle benefit.’’ 77 FR 62836 (Oct. 12, 2012). 533MOVES homepage: https://www3.epa.gov/
otaq/models/moves/index.htm (last accessed May 
27, 2016). 
534Annual Energy Outlook 2015. http://
www.eia.gov/forecasts/archive/aeo15/ (last accessed 
May 27, 2016). 
535U.S. EPA. Updates to MOVES for Emissions 
Analysis of Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2 FRM. Docket No. EPA–HQ–OAR–2016. July 2016. include sufficient real-world heavy-duty 
vehicle data on which to base the menu credit value recommended by the commenter. Thus, in several cases, the analysis provided by commenters was based on light-duty vehicle data or on simulations with little detail provided, which analysis is not directly applicable to heavy duty pickups and vans for purposes of technology performance quantification. Second, in several cases, the technologies recommended for off- cycle credits for pickups and vans provide significant on-cycle benefit. Such technologies are considered to be adequately captured by the test procedures (within the meaning of section 86.1819–14(d)(13))
532and are 
not considered to be eligible for off- cycle credits. Examples of adequately captured technologies that commenters recommended for off-cycle credits include cylinder deactivation and cooled EGR. Moreover, these are technologies the agencies expect to be in the mix of technologies used to meet the standards (and are projected to be used in the respective analyses of compliance paths on which the stringency of the final standards are predicated). EPA has already indicated that off-cycle credits are not available for technologies that form part of the technology basis for the greenhouse gas standards because these technologies’ benefits would already be 
reflected in the standard’s stringencies (and costs). 77 FR 62835 (Oct. 12, 2012). Indeed, it is because of these technologies’ robust performance in two-cycle space that the agencies have projected their use as part of the compliance path on which standard stringency is predicated. Likewise, many of these technologies are inherent to vehicle design and so are similarly ineligible. Id. at 62732, 62836. Finally, 
a few other recommended technologies are considered safety-related technologies not eligible for credits because they could reasonably be expected to fall under vehicle safety standards in the future and so would be adopted in any case. Granting off-cycle credits for these technologies consequently would amount to an unwarranted windfall. Adaptive cruise control and forward collision warning systems are examples of these technologies. Chapter 7 of the Response to Comments for this final rule provides 
a detailed response to these comments 
(4) Demonstrating Compliance for 
Heavy-Duty Pickup Trucks and Vans 
The Phase 1 rule established a 
comprehensive compliance program for HD pickups and vans that NHTSA and EPA are generally retaining for Phase 2. The compliance provisions cover details regarding the implementation of the fleet average standards including vehicle certification, demonstrating compliance at the end of the model year, in-use standards and testing, carryover of certification test data, and reporting requirements. Please see Section V.B.(1) of the Phase 1 rule Preamble (76 FR 57256–57263) for a detailed discussion of these provisions. 
The Phase 1 rule contains special 
provisions regarding loose engines and optional chassis certification of certain vocational vehicles over 14,000 lbs. GVWR. As proposed, the agencies are extending the optional chassis certification provisions to Phase 2 and are providing a temporary loose engine provision for Phase 2 as described in Section V.D.3.e, under Compliance Flexibility Provisions. See the vocational vehicle Section V.D. and XIII.A.2 for a detailed discussion of the 
rule for optional chassis certification and Section II.D. for the discussion of loose engines. 
VII. Aggregate GHG, Fuel Consumption, 
and Climate Impacts 
Given that the purpose of setting these 
Phase 2 standards is to reduce fuel consumption and greenhouse gas (GHG) emissions from heavy-duty vehicles, it is necessary for the agencies to analyze the extent to which these standards will accomplish that purpose. This section describes the agencies’ methodologies for projecting the reductions in greenhouse gas (GHG) emissions and fuel consumption and the methodologies the agencies used to quantify the impacts associated with these standards. In addition, EPA’s analyses of the projected change in atmospheric carbon dioxide (CO
2) 
concentration and consequent climate change impacts are discussed. Because of NHTSA’s obligations under EPCA/ EISA and NEPA, NHTSA further analyzes the projected environmental impacts related to fuel consumption, GHG emissions, and climate change, for each regulatory alternative. Detailed documentation of this analysis is provided in Chapters 3, 4 and 5 of NHTSA’s FEIS accompanying today’s notice. A. What methodologies did the Agencies 
use to project GHG emissions and fuel consumption impacts? 
Different tools exist for estimating 
potential fuel consumption and GHG emissions impacts associated with fuel efficiency and GHG emission standards. One such tool is EPA’s official mobile source emissions inventory model named Motor Vehicle Emissions Simulator (MOVES).
533The agencies 
used a revised version of MOVES2014a to quantify the impacts of these 
standards for vocational vehicles and combination tractor-trailers on GHG emissions and fuel consumption. 
Since the notice of proposed 
rulemaking, EPA has made certain updates to MOVES in response to the public comments on the proposal: (1) The projections of vehicle sales, populations, and activity in the version used for the final rulemaking were updated to incorporate the latest projections from the U.S. Department of Energy’s Annual Energy Outlook 2015 report;
534(2) the extended idle and 
APU emission rates in MOVES were updated based on the analyses of latest test programs that reflect the current prevalence of clean idle certified engines; and (3) the baseline adoption rates of idle reduction technology were reassessed and projected to be lower than what was assumed in the proposal, as described in Section III.D.1.a of the Preamble. In addition, changes to APU emissions rates for PM
2.5were 
implemented in MOVES reflecting the fact that EPA is adopting requirements to control PM
2.5emissions from APUs 
installed in new tractors, as discussed in Section III.C.3 of the Preamble. Finally, methodological improvements were made in classifying vehicle types and in forecasting vehicle populations and activity. The aforementioned updates above, along with other changes, are documented in the memorandum to the docket.
535 
MOVES was run with user input 
databases, described in more detail below, that reflected the projected technological improvements resulting from the final rules, such as the improvements in engine and vehicle efficiency, aerodynamic drag, and tire rolling resistance. The changes made to 
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536Memorandum to the Docket ‘‘Runspecs, Model 
Inputs, MOVES Code and Database for HD GHG 
Phase 2 FRM Emissions Modeling’’ Docket No. EPA–HQ–OAR–2016. July 2016. 537U.S. EPA. Draft Regulatory Impact Analysis: 
Changes to Renewable Fuel Standard Program. Chapters 2 and 3. May 26, 2009. Docket ID: EPA– HQ–OAR–2009–0472–0119. 
5382017 and Later Model Year Light-Duty Vehicle 
Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards (77 FR 62623, October 15, 2012). 
539Greenhouse Gas Emission Standards and Fuel 
Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles (76 FR 57106, September 15, 2011). 
540Memorandum to the Docket ‘‘Upstream 
Emissions Modeling Files for HDGHG Phase 2 FRM’’ Docket No. EPA–HQ–OAR–2016. July 2016. 
541The emissions impacts of the final rules on 
non-GHGs, including air toxics, were also estimated using MOVES. See Section VIII of the Preamble for more information. 
542The CAFE model estimates, among other 
things, manufacturers’ potential multiyear planning decisions within the context of an estimated year- by-year product cadence (i.e., schedule for 
redesigning and freshening vehicles). The model was allowed to deploy technology in earlier model years in the analysis in order to account for the potential that manufacturers might take anticipatory actions in model years preceding those covered by today’s rules. the default MOVES database are 
described below in Section VII.B.(3). All the input data, MOVES run spec files, and the scripts used for the analysis, as well as the version of MOVES used to generate the emissions inventories, can be found in the docket.
536 
Another such tool is DOT’s CAFE 
model, which estimates how manufacturers could potentially apply technology improvements in response to new standards, and then calculates, among other things, resultant changes in national fuel consumption and GHG emissions. As described in Section VI, two versions of this model were used for analysis of potential new standards for HD pickups and vans. Both versions use the work-based attribute metric of ‘‘work factor’’ established in the Phase 1 rule for heavy-duty pickups and vans instead of the light-duty ‘‘footprint’’ attribute metric. The CAFE model takes user-specified inputs on, among other things, vehicles that are projected to be produced in a given model year, technologies available to improve fuel efficiency on those vehicles, potential regulatory standards that will drive improvements in fuel efficiency, and economic assumptions. The CAFE model takes every vehicle in each manufacturer’s fleet and decides what technologies to add to those vehicles in order to allow each manufacturer to comply with the standards in the most cost-effective way. Based on those results, the CAFE model then calculates total fuel consumption and GHG emissions impacts based on those inputs, along with economic costs and benefits. The DOT’s CAFE model is further described in detail in Section VI of the Preamble and Chapter 10 of the RIA. 
For these rules, the agencies used two 
analytical methods for the heavy-duty pickup and van segment employing both DOT’s CAFE model and EPA’s MOVES model. The agencies used EPA’s MOVES model to estimate fuel consumption and emissions impacts for tractor-trailers (including the engine that powers the tractor) and vocational vehicles (including the engine that powers the vehicle). 
For heavy-duty pickups and vans, the 
agencies performed separate analyses, which we refer to as ‘‘Method A’’ and ‘‘Method B.’’ In Method A, a modified version of the CAFE model was used to project a pathway the industry could use to comply with each regulatory alternative and the estimated effects on fuel consumption, emissions, benefits 
and costs. In Method B, the MOVES model was used to estimate fuel consumption and emissions from these vehicles. NHTSA considered Method A 
as its central analysis. EPA considered the results of Method B as its central analysis. The agencies concluded that these methods led the agencies to the same conclusions and the same selection of the final standards. See Chapter 5 of the RIA for additional discussions of these two methods. 
For both methods, the agencies 
analyzed the impact of the final rules, relative to two different reference cases—‘‘flat’’ (Alternative 1a) and ‘‘dynamic’’ (Alternative 1b). The flat baseline projects very little improvement in new vehicles in the absence of new Phase 2 standards. In contrast, the dynamic baseline projects more improvements in vehicle fuel efficiency in the absence of new Phase 2 standards. The agencies considered both reference cases (for additional details, see Chapter 11 of the RIA). The results for all of the regulatory alternatives relative to both reference cases, derived via the same methodologies discussed in this section, are presented in Section X of the Preamble. 
For brevity, a subset of these analyses 
are presented in this section, and the reader is referred to both Chapter 11 of the RIA and NHTSA’s FEIS Chapters 3, 4 and 5 for complete sets of these analyses. In this section, Method A is presented for the final standards (i.e., Alternative 3—the agencies’ preferred alternative), relative to both the dynamic baseline (Alternative 1b) and the flat baseline (Alternative 1a). Method B is presented for the final standards, relative only to the flat baseline. 
Because reducing fuel consumption 
also affects emissions that occur as a result of fuel production and distribution (including renewable fuels), the agencies also calculated those ‘‘upstream’’ changes using the ‘‘downstream’’ fuel consumption reductions predicted by the CAFE model (in ‘‘Method A’’) and the MOVES model (in ‘‘Method B’’). As described in Section VI, Method A uses the CAFE model to estimate vehicular fuel consumption and emissions impacts only for HD pickups and vans and to calculate upstream impacts. For vocational vehicles and combination tractor-trailers, both Method A and Method B use the same upstream tools originally created for the Renewable Fuel Standard 2 (RFS2) rulemaking analysis,
537used in the LD GHG 
rulemakings,538HD GHG Phase 1,539 
and updated for the current analysis. 
The estimate of emissions associated with production and distribution of gasoline and diesel from crude oil is based on emission factors in the ‘‘Greenhouse Gases, Regulated Emissions, and Energy Use in 
Transportation’’ model (GREET) developed by DOE’s Argonne National Lab. In some cases, the GREET values were modified or updated by the agencies to be consistent with the National Emission Inventory (NEI) and emission factors from MOVES. Method B uses the same tool described above to estimate the upstream impacts for HD pickups and vans. For additional details, see Chapter 5 of the RIA. The upstream tool used for the Method B can be found in the docket.
540As noted 
in Section VI above, these analyses corroborate each other’s results. 
The agencies analyzed the anticipated 
emissions impacts of the final rules on carbon dioxide (CO
2), methane (CH 4), 
nitrous oxide (N 2O), and 
hydrofluorocarbons (HFCs) for a number of calendar years (for purposes of the discussion in these final rules, only 2025, 2040 and 2050 will be shown) by comparing to both reference cases.
541 
Additional runs were performed for just three of the greenhouse gases (CO
2, CH 4, 
and N 2O) and for fuel consumption for 
every calendar year from 2016 to 2050, inclusive, which fed the economy-wide modeling, monetized greenhouse gas benefits estimation, and climate impacts analyses, discussed in sections below.
542 
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543Memorandum to the Docket ‘‘Runspecs, Model 
Inputs, MOVES Code and Database for HD GHG 
Phase 2 FRM Emissions Modeling’’ Docket No. EPA–HQ–OAR–2016. July 2016. 
544Annual Energy Outlook 2015. http://
www.eia.gov/forecasts/archive/aeo15/ (last accessed 
May 27, 2016). 545Vocational vehicles modeled in MOVES 
include heavy heavy-duty, medium heavy-duty, and light heavy-duty vehicles. However, for light heavy-duty vocational vehicles, class 2b and 3 vehicles are not included in the inventories for the vocational sector. Instead, all vocational vehicles with GVWR of less than 14,000 lbs. were modeled using the energy rate reductions described below for HD pickup trucks and vans. In practice, many manufacturers of these vehicles choose to average the lightest vocational vehicles into chassis- certified families (i.e., heavy-duty pickups and 
vans). B. Analysis of Fuel Consumption and 
GHG Emissions Impacts Resulting From Final Standards 
The following sections describe the 
model inputs and assumptions for both the flat and dynamic reference cases and the control case representing the agencies’ final fuel efficiency and GHG standards. The details of all the MOVES runs and input data tables, as well as the MOVES code and database, can be found in the docket.
543See Section VI.C 
for the discussion of the model inputs and assumptions for the analysis of the HD pickups and vans using DOT’s CAFE Model. 
(1) Model Inputs and Assumptions for 
the Flat Reference Case 
The flat reference case (identified as 
Alternative 1a in Section X), includes the impact of Phase 1, but assumes that fuel efficiency and GHG emission standards are not improved beyond the required 2018 model year levels. Alternative 1a functions as one of the baselines against which the impacts of the final standards can be evaluated. The MOVES2014a default road load parameters and energy rates were used for the vocational vehicles and HD pickups and vans for this alternative because we assumed no market-driven improvements in fuel efficiency. The tractor-trailer road load parameters were changed from the MOVES2014a default values to account for projected improvements in the efficiency of the box trailers pulled by combination tractors due to increased penetration of aerodynamic technologies and low rolling resistance tires attributed to both EPA’s SmartWay Transport Partnership 
and California Air Resources Board’s Tractor-Trailer Greenhouse Gas regulation, as described in Section IV of the Preamble. We maintained the same road load inputs for tractor-trailers for 2018 and beyond. The flat reference case assumed the growth in vehicle populations and miles traveled based on the relative annual VMT growth from AEO2015 Final Release for model years 2014 and later.
544 
(2) Model Inputs and Assumptions for the Dynamic Reference Case 
The dynamic reference case 
(identified as Alternative 1b in Section X) also includes the impact of Phase 1 and generally assumes that fuel efficiency and GHG emission standards are not improved beyond the required 2018 model year levels. However, for this case, the agencies assume market forces will lead to additional fuel efficiency improvements for HD pickups and vans and tractor-trailers. These additional assumed improvements are described in Section X of the Preamble. No additional fuel efficiency improvements due to market forces 
were assumed for vocational vehicles. For HD pickups and vans, the agencies applied the CAFE model using the input assumption that manufacturers having achieved compliance with Phase 1 standards will continue to apply technologies for which increased purchase costs will be ‘‘paid back’’ through corresponding fuel savings within the first six months of vehicle operation. The agencies conducted the MOVES analysis of this case in the same 
manner as for the flat reference case. 
(3) Model Inputs and Assumptions for 
‘‘Control’’ Case 
(a) Vocational Vehicles and Tractor- 
Trailers 
The ‘‘control’’ case represents the 
agencies’ final fuel efficiency and GHG standards. The agencies developed additional user input data for MOVES runs to estimate the control case inventories. The inputs to MOVES for the control case account for improvements of engine and vehicle efficiency in vocational vehicles and combination tractor-trailers. The agencies used the percent reduction in aerodynamic drag and tire rolling resistance coefficients and absolute changes in average total running weight (gross combined weight) expected from the final rules to develop the road load inputs for the control case, based on the GEM analysis. The agencies developed energy inputs for the control case runs using the percent reduction in CO
2 
emissions expected from the powertrain and other vehicle technologies not accounted for in the aerodynamic drag and tire rolling resistance in the final rules. 
Table VII–1 and Table VII–2 describe 
the improvements in engine and vehicle efficiency from the final rules for each affected model year for vocational vehicles and combination tractor-trailers that were input into MOVES for estimating the control case emissions inventories. Additional details regarding the MOVES inputs are included in Chapter 5 of the RIA. 
TABLE VII–1—E STIMATED REDUCTIONS IN ENERGY RATES FOR THE FINAL STANDARDS  
Vehicle type Fuel Model years Reduction 
from flat base-
line 
(%) 
Long-haul Tractor-Trailers and HHD Vocational ....................................... Diesel ..................................... .......... 2018–2020 
2021–2023 
2024–2026 
2027+ 1.0 7.9 
12.4 
16.3 
Short-haul Tractor-Trailers and HHD Vocational ...................................... Diesel ..................................... .......... 2018–2020 
2021–2023 
2024–2026 
2027+ 0.6 7.4 
11.9 
15.0 
Single-Frame Vocational545...................................................................... Diesel ............................................... 2021–2023 
2024–2026 
2027+ 7.8 
12.3 
16.0 
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546Vocational tractors are included in the short- 
haul tractor segment. TABLE VII–1—E STIMATED REDUCTIONS IN ENERGY RATES FOR THE FINAL STANDARDS —Continued 
Vehicle type Fuel Model years Reduction 
from flat base-
line 
(%) 
Gasoline .......................................... 2021–2023 
2024–2026 
2027+ 6.9 
9.8 
13.3 
Urban Bus .................................................................................................. Diesel and CNG ...... ........................ 2021–2023 
2024–2026 
2027+ 7.0 
11.8 
14.4 
TABLE VII–2—E STIMATED REDUCTIONS IN ROADLOADFACTORS FOR THE FINAL STANDARDS  
Vehicle type Model years Reduction in 
tire rolling 
resistance 
coefficient 
(%) Reduction in 
aerodynamic 
drag 
coefficient 
(%) Weight 
reduction 
(lb)a 
Combination Long-haul Tractor-Trailers ................................. 2018–2020 .............................
2021–2023 .............................2024–2026 .............................2027+ .....................................6.1 
13.3 
16.3 18.0 5.6 
12.5 
19.3 
28.2 ¥140 ¥199 ¥294 ¥360 
Combination Short-haul Tractor-Trailers.546 2018–2020 .............................
2021–2023 .............................2024–2026 .............................2027+ .....................................5.2 
11.9 
14.1 15.9 0.9 4.0 6.2 8.8 ¥23 ¥43 ¥43 ¥43 
Intercity Buses ........................................................................ 2021–2023 .............................
2024–2026 .............................2027+ .....................................18.2 
20.8 24.7 0 
0 
0 0 0 
0 
Transit Buses .......................................................................... 2021–2023 .............................
2024–2026 .............................2027+ .....................................0 
0 
12.1 0 
0 
0 0 0 
0 
School Buses .......................................................................... 2021–2023 .............................
2024–2026 .............................2027+ .....................................10.1 14.9 
19.7 0 
0 
0 0 
0 
0 
Refuse Trucks ......................................................................... 2021–2023 .............................
2024–2026 .............................2027+ .....................................0 
0 
12.1 0 0 
0 0 
0 
0 
Single Unit Short-haul Trucks ................................................. 2021–2023 .............................
2024–2026 .............................2027+ .....................................6.4 6.4 
10.2 0 
0 
0 4.4 
10.4 
16.5 
Single Unit Long-haul Trucks .................................................. 2021–2023 .............................
2024–2026 .............................2027+ .....................................8.4 
13.3 
13.3 0 
0 
0 7.9 
23.6 
39.4 
Motor Homes .......................................................................... 2021–2023 .............................
2024–2026 .............................2027+ .....................................20.8 
20.8 
24.7 0 0 
0 0 
0 
0 
Note: 
aNegative weight reductions reflect an expected weight increase as a byproduct of other vehicle and engine improvements as described in 
Chapter 5 of the RIA. 
In addition, the CO 2standard for 
tractors, reflecting the use of idle 
reduction technologies such as diesel- powered auxiliary power units (APUs) and battery-powered APUs, as discussed in Section III.D of the Preamble, was included in the modeling for the long- haul combination tractor-trailers, as shown below in Table VII–3. 
TABLE VII–3—A SSUMED APU U SEDURING EXTENDED IDLING FOR COMBINATION LONG-HAULTRACTOR -TRAILERSa 
Vehicle type Model year Diesel APU 
Penetration 
(%) Battery APU 
Penetration 
(%) 
Combination Long-Haul Trucks ................................................................................................... 2010–2020 
2021–2023 
2024–2026 
2027+ 9 
30 
40 
40 0 
10 
10 15 
Note: 
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547Memorandum to the Docket ‘‘VMT Rebound 
Inputs to MOVES for HDGHG2 Phase 2 FRM’’ 
Docket No. EPA–HQ–OAR–2016. July 2016. aOther idle reduction technologies (such as automatic engine shutdown, fuel operated heaters, and stop-start systems) were modeled as part 
of the energy rates. 
To account for the potential increase 
in vehicle use expected to result from 
improvements in fuel efficiency for vocational vehicles and combination tractor-trailers due to the final rules (also known as the ‘‘rebound effect’’ and described in more detail in Section IX.E of the Preamble), the control case assumed an increase in VMT from the reference levels by 0.30 percent for the vocational vehicles and 0.75 percent for the combination tractor-trailers.
547 
(b) Heavy-Duty Pickups and Vans 
As explained above and as also 
discussed in the RIA, the agencies used both DOT’s CAFE model and EPA’s MOVES model, for Method A and B, respectively, to project fuel consumption and GHG emissions impacts resulting from these standards for HD pickups and vans, including downstream vehicular emissions as well as emissions from upstream processes related to fuel production, distribution, and delivery. 
(i) Method A for HD Pickups and Vans 
For Method A, the agencies used the 
CAFE model which applies fuel 
properties (density and carbon content) to estimated fuel consumption in order to calculate vehicular CO
2emissions, 
applies per-mile emission factors from MOVES to estimated VMT (for each regulatory alternative, adjusted to account for the rebound effect) in order to calculate vehicular CH
4and N 2O 
emissions (as well, as discussed below, of non-GHG pollutants), and applies per-gallon upstream emission factors from GREET in order to calculate upstream GHG (and non-GHG) emissions. 
As discussed above in Section VI, the 
standards for HD pickups and vans increase in stringency by 2.5 percent annually during model years 2021– 2027. The standards define targets specific to each vehicle model, but no individual vehicle is required to meet its target; instead, the production- weighted averages of the vehicle- specific targets define average fuel consumption and CO
2emission rates 
that a given manufacturer’s overall fleet of produced vehicles is required to achieve as a whole. The standards are specified separately for gasoline and diesel vehicles, and vary with work factor. Both the NPRM and today’s analysis assume that some application of mass reduction could enable increased work factor in cases where manufacturers increase a vehicle’s rated payload and/or towing capacity without a change to GVWR and GCWR, but there are other ways manufacturers may change work factor which the analysis does not capture. Average required levels will depend on the future mix of vehicles and the work factors of the vehicles produced for sale in the U.S. Since these can only be estimated at this time, average required and achieved fuel consumption and CO
2emission rates are 
subject to uncertainty. Between the NPRM and the issuance of today’s final rules, the agencies updated the market forecast (and other inputs) used to analyze HD pickup and van standards, and doing so leads to different estimates of required and achieved fuel consumption and CO
2emission rates (as 
well as different estimates of impacts, costs, and benefits). 
The following four tables present 
stringency increases and estimated required and achieved fuel consumption and CO
2emission rates for the two No 
Action Alternatives (Alternative 1a and 1b) and the standards defining the final program. Stringency increases are shown relative to standards applicable in model year 2018 (and through model year 2020). As mathematical functions, the standards themselves are not subject to uncertainty. By 2027, they are 16.2 percent more stringent (i.e., lower) than 
those applicable during 2018–2020. NHTSA estimates that, by model 2027, these standards could reduce average required fuel consumption and CO
2 
emission rates to about 4.88 gallons/100 miles and about 4 grams/mile, respectively. NHTSA further estimates that average achieved fuel consumption and CO
2emission rates could 
correspondingly be reduced to about the same levels. If, as represented by Alternative 1b, manufacturers will, even absent today’s standards, voluntarily make improvements that pay back within six months, these model year 2027 levels are about 12 percent lower than the agencies estimate could be achieved under the Phase 1 standards defining the No Action Alternative. If, as represented by Alternative 1a, manufacturers will, absent today’s standards, only apply technology as required to achieve compliance, these model year 2027 levels are about 13 percent lower than the agencies estimate could be achieved under the Phase 1 standards. As indicated below, the agencies estimate that these improvements in fuel consumption and CO
2emission rates will build from 
model year to model year, beginning as soon as model year 2017 (insofar as manufacturers may make anticipatory improvements if warranted given planned product cadence). 
The NPRM analysis suggested that 
both the achieved and required fuel consumption and CO
2reductions would 
be larger than the current analysis suggests. The NPRM suggested that achieved reductions would be 13.5 and 15 percent, for the dynamic and flat baselines, respectively. The erosion of the standards and fuel consumption reductions can be attributed to the increased work factor of the 2015 fleet relative to the 2014 fleet. Section 6 discusses in more detail the changes in the distribution of work factor for key market players from the MY 2014 to the MY 2015 fleet. 
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TABLE VII–4—S TRINGENCY OF HD P ICKUP AND VANSTANDARDS , ESTIMATED AVERAGE REQUIRED AND ACHIEVED FUEL 
CONSUMPTION RATES FOR METHOD A, R ELATIVE TO ALTERNATIVE 1ba 
Model year Stringency 
(vs. 2018) Ave. required fuel cons. 
(gal./100 mi.) Ave. achieved fuel cons. 
(gal./100 mi.) 
No action Final Reduction 
(%) No action Final Reduction 
(%) 
2016 ................................................
2017 ................................................2018 ................................................2019 ................................................2020 ................................................MYs 2016–2020 
Subject to Phase 1 Stand-ards.6.32 
6.16 
5.83 5.81 
5.80 6.32 
6.16 
5.83 5.81 
5.80 0.0 0.0 0.0 0.0 0.0 6.14 
6.02 
5.97 5.77 
5.75 6.14 
5.89 
5.78 5.47 
5.46 0.0 2.2 3.2 5.3 5.1 
2021 ................................................ 2.5 ....................... 5.79 5.65 2.4 5.68 5.28 7.2 
2022 ................................................ 4.9 ....................... 5.80 5.52 4.8 5.64 5.22 7.5 
2023 ................................................ 7.3 ....................... 5.80 5.38 7.2 5.64 5.21 7.6 
2024 ................................................ 9.6 ....................... 5.80 5.25 9.5 5.65 5.22 7.6 
2025 ................................................ 11.9 ..................... 5.81 5.12 11.8 5.65 5.14 9.1 
2026 ................................................ 14.1 ..................... 5.81 5.01 13.7 5.65 5.02 11.1 
2027 ................................................ 16.2 ..................... 5.80 4.88 15.8 5.57 4.92 11.7 
2028 * .............................................. 16.2 ..................... 5.81 4.91 15.5 5.57 4.89 12.2 
2029 * .............................................. 16.2 ..................... 5.81 4.91 15.6 5.57 4.88 12.4 
2030 * .............................................. 16.2 ..................... 5.81 4.91 15.6 5.57 4.88 12.4 
Notes: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
* Absent further action, standards assumed to continue unchanged after model year 2027. 
TABLE VII–5—S TRINGENCY OF HD P ICKUP AND VANSTANDARDS , ESTIMATED AVERAGE REQUIRED AND ACHIEVED CO 2 
EMISSION RATES FOR METHOD A, R ELATIVE TO ALTERNATIVE 1ba 
Model year Stringency 
(vs. 2018) 
(%) Ave. required CO 2Rate (g./mi.) Ave. achieved CO 2Rate (g./mi.) 
No Action Final Reduction 
(%) No Action Final Reduction 
(%) 
2016 .............................2017 .............................2018 .............................2019 .............................2020 .............................MYs 2016– 
2020 Sub-ject to Phase 1 Standards.597 582 550 
548 
547 597 582 550 
548 
547 0.0 0.0 0.0 0.0 0.0 578 567 562 
543 
541 578 554 544 
514 
513 0.0 2.2 3.2 5.3 5.1 
2021 ............................. 2.5 .................. 545 532 2.4 534 496 7.1 
2022 ............................. 4.9 .................. 546 519 4.9 530 491 7.4 
2023 ............................. 7.3 .................. 545 506 7.2 529 490 7.5 
2024 ............................. 9.6 .................. 547 494 9.5 531 491 7.5 
2025 ............................. 11.9 ................ 547 483 11.7 530 483 9.0 
2026 ............................. 14.1 ................ 547 472 13.7 530 472 11.0 
2027 ............................. 16.2 ................ 546 460 15.8 523 462 11.5 
2028* ............................ 16.2 ................ 547 462 15.5 523 460 12.0 
2029* ............................ 16.2 ................ 547 462 15.5 524 460 12.2 
2030* ............................ 16.2 ................ 547 462 15.5 524 460 12.2 
Notes: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
* Absent further action, standards assumed to continue unchanged after model year 2027. 
TABLE VII–6—S TRINGENCY OF HD P ICKUP AND VANSTANDARDS , ESTIMATED AVERAGE REQUIRED AND ACHIEVED FUEL 
CONSUMPTION RATES FOR METHOD A, R ELATIVE TO ALTERNATIVE 1aa 
Model year Stringency 
(vs. 2018) 
(%) Ave. required fuel cons. 
(gal./100 mi.) Ave. achieved fuel cons. 
(gal./100 mi.) 
No Action Final Reduction 
(%) No Action Final Reduction 
(%) 
2016 .............................2017 .............................2018 .............................2019 .............................2020 .............................MYs 2016– 
2020 Sub-ject to Phase 1 Standards.6.32 
6.16 
5.83 5.81 
5.80 6.32 
6.16 
5.83 5.81 
5.80 0.0 0.0 0.0 0.0 0.0 6.14 
6.00 
5.94 5.74 
5.73 6.14 
5.85 
5.75 5.43 
5.43 0.0 2.4 3.2 5.4 5.2 
2021 ............................. 2.5 .................. 5.79 5.65 2.4 5.70 5.27 7.5 
2022 ............................. 4.9 .................. 5.80 5.52 4.8 5.69 5.23 8.2 
2023 ............................. 7.3 .................. 5.80 5.38 7.2 5.69 5.22 8.3 
2024 ............................. 9.6 .................. 5.80 5.25 9.5 5.70 5.22 8.3 
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548Memorandum to the Docket ‘‘VMT Rebound 
Inputs to MOVES for HDGHG2 Phase 2 FRM’’ 
Docket No. EPA–HQ–OAR–2016. July 2016. TABLE VII–6—S TRINGENCY OF HD P ICKUP AND VANSTANDARDS , ESTIMATED AVERAGE REQUIRED AND ACHIEVED FUEL 
CONSUMPTION RATES FOR METHOD A, R ELATIVE TO ALTERNATIVE 1aa—Continued 
Model year Stringency 
(vs. 2018) 
(%) Ave. required fuel cons. 
(gal./100 mi.) Ave. achieved fuel cons. 
(gal./100 mi.) 
No Action Final Reduction 
(%) No Action Final Reduction 
(%) 
2025 ............................. 11.9 ................ 5.81 5.13 11.8 5.70 5.13 10.0 
2026 ............................. 14.1 ................ 5.81 5.02 13.6 5.70 5.03 11.9 
2027 ............................. 16.2 ................ 5.80 4.89 15.8 5.64 4.92 12.8 
2028* ............................ 16.2 ................ 5.81 4.91 15.4 5.64 4.89 13.3 
2029* ............................ 16.2 ................ 5.81 4.91 15.5 5.64 4.89 13.4 
2030* ............................ 16.2 ................ 5.81 4.91 15.5 5.64 4.89 13.4 
Notes: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
* Absent further action, standards assumed to continue unchanged after model year 2027. 
** Increased work factor for some vehicles produces a slight increase in average required fuel consumption. 
TABLE VII–7—S TRINGENCY OF HD P ICKUP AND VANSTANDARDS , ESTIMATED AVERAGE REQUIRED AND ACHIEVED CO 2 
EMISSION RATES FOR METHOD A, R ELATIVE TO ALTERNATIVE 1aa 
Model year Stringency 
(vs. 2018) 
(%) Ave. required CO 2Rate 
(g./mi.) Ave. achieved CO 2Rate 
(g./mi.) 
No Action Final Reduction 
(%) No Action Final Reduction 
(%) 
2016 .............................
2017 .............................2018 .............................2019 .............................2020 .............................MYs 2016– 
2020 Sub-ject to Phase 1 Standards.597 582 550 
548 
547 597 582 550 
548 
547 0.0 0.0 0.0 0.0 0.0 578 564 559 
540 
538 578 551 541 
511 
510 0.0 2.3 3.2 5.4 5.2 
2021 ............................. 2.5 .................. 545 532 2.4 535 495 7.4 
2022 ............................. 4.9 .................. 546 519 4.8 534 491 8.0 
2023 ............................. 7.3 .................. 545 506 7.2 533 490 8.2 
2024 ............................. 9.6 .................. 547 494 9.5 535 491 8.2 
2025 ............................. 11.9 ................ 547 483 11.7 535 483 9.8 
2026 ............................. 14.1 ................ 547 472 13.6 535 473 11.7 
F 2027 .......................... 16.2 ................ 546 460 15.8 529 462 12.6 
2028* ............................ 16.2 ................ 547 462 15.5 530 460 13.1 
2029* ............................ 16.2 ................ 547 462 15.5 530 460 13.2 
2030* ............................ 16.2 ................ 547 462 15.5 530 460 13.2 
Notes: 
a For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
* Absent further action, standards assumed to continue unchanged after model year 2027. ** Increased work factor for some vehicles produces a slight increase in the average required CO
2emission rate. 
While the above tables show the 
agencies’ estimates of average fuel 
consumption and CO 2emission rates 
manufacturers of pickups and vans might achieve under today’s standards, total U.S. fuel consumption and GHG emissions from HD pickups and vans will also depend on how many of these 
vehicles are produced, and how they are operated over their useful lives. Relevant to estimating these outcomes, the CAFE model applies vintage-specific estimates of vehicle survival and mileage accumulation, and adjusts the latter to account for the rebound effect. This impact of the rebound effect is specific to each model year (and, underlying, to each vehicle model in each model year), varying with changes in achieved fuel consumption rates. 
(ii) Method B for HD Pickups and Vans 
For Method B, the MOVES model was 
used to estimate fuel consumption and 
GHG emissions for HD pickups and vans. MOVES evaluated these standards for HD pickup trucks and vans in terms 
of grams of CO
2per mile or gallons of 
fuel per 100 miles. Since nearly all HD pickup trucks and vans are certified on a chassis dynamometer, the CO
2 
reductions for these vehicles were not represented as engine and road load reduction components, but rather as total vehicle CO
2reductions. The 
control case for HD pickups and vans assumed an increase in VMT from the reference levels of 1.08 percent.
548 
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TABLE VII–8—E STIMATED TOTAL VEHICLE CO 2REDUCTIONS FOR THE FINAL STANDARDS AND IN-USEEMISSIONS FOR HD 
PICKUP TRUCKS AND VANS IN METHOD Ba 
Vehicle type Fuel Model year CO 2reduction 
from flat 
baseline 
(%) 
HD pickup trucks and vans .......................................... Gasoline and Diesel ......................................... ............ 2021 
2022 
2023 
2024 
2025 
2026 
2027+ 2.50 
4.94 
7.31 9.63 
11.89 14.09 16.24 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
C. What are the projected reductions in 
fuel consumption and GHG emissions? 
NHTSA and EPA expect significant 
reductions in GHG emissions and fuel consumption from the final rules—fuel 
consumption reductions from more efficient vehicles, emission reductions from both downstream (tailpipe) and upstream (fuel production and distribution) sources, and reduction in HFC emissions from the air conditioning leakage standards (see Section V.B.(2)(c)). The following subsections summarize two different analyses of the annual GHG emissions and fuel consumption reductions expected from these final rules, as well as the reductions in GHG emissions and fuel consumption expected over the lifetime of each heavy-duty vehicle category. Section VII.C.(1) shows the impacts of the final rules on fuel consumption and GHG emissions, using the MOVES model for tractor-trailers and vocational vehicles and the DOT’s CAFE model for HD pickups and vans (Method A), relative to two different reference cases—flat and dynamic. 
Section VII.C.2 shows the impacts of the final standards, relative to the flat reference case only, using the MOVES model for all heavy-duty vehicle categories. NHTSA also analyzes these impacts resulting from the final rules and reasonable alternatives in Chapters 3, 4 and 5 of its FEIS. 
(1) Impacts of the Final Rules Using 
Analysis Method A 
(a) Calendar Year Analysis (i) Downstream (Tailpipe) Emissions 
Projections 
As described in Section VII.A, for the 
analysis using Method A, the agencies used MOVES to estimate downstream GHG inventories from the final rules for vocational vehicles and tractor-trailers. For HD pickups and vans, DOT’s CAFE model was used. 
The following two tables summarize 
the agencies’ estimates of HD pickup and van fuel consumption and GHG emissions under the current standards defining the No-Action and final program, respectively, using Method A. Table VII–9 shows results assuming manufacturers will voluntarily make improvements that pay back within six months (i.e., Alternative 1b). Table VII– 
10 shows results assuming manufacturers will only make improvements as needed to achieve compliance with standards (i.e., Alternative 1a). While underlying calculations are all performed for each calendar year during each vehicle’s useful life, presentation of outcomes on a model year basis aligns more clearly with consideration of cost impacts in each model year, and with consideration of standards specified on a model year basis. In addition, Method A analyzes manufacturers’ potential responses to HD pickup and van standards on a model year basis through 2030, and any longer-term costs presented in today’s notice represent extrapolation of these results absent any underlying analysis of longer-term technology prospects and manufacturers’ longer-term product offerings. 
TABLE VII–9—E STIMATED FUELCONSUMPTION AND GHG E MISSIONS OVERUSEFUL LIFE OF HD P ICKUPS AND VANS 
PRODUCED IN EACHMODEL YEAR FOR METHOD A, R ELATIVE TO ALTERNATIVE 1ba 
Model year Fuel consumption 
(b. gal.) 
over fleet’s useful life GHG emissions 
(MMT CO 2eq) 
over fleet’s useful life 
No action Final Reduction 
(%) No action Final Reduction 
(%) 
2016 ......................................................... 10.4 10.4 0.0 127 127 0.0 
2017 ......................................................... 10.4 10.2 2.0 127 124 2.0 
2018 ......................................................... 10.5 10.2 2.9 127 124 2.9 
2019 ......................................................... 10.1 9.60 4.8 123 117 4.8 
2020 ......................................................... 10.1 9.60 4.6 123 117 4.6 
2021 ......................................................... 9.82 9.17 6.6 120 112 6.5 
2022 ......................................................... 9.67 9.01 6.9 118 110 6.8 
2023 ......................................................... 9.64 8.97 7.0 117 109 6.9 
2024 ......................................................... 9.67 9.00 7.0 118 110 6.9 
2025 ......................................................... 9.79 8.98 8.3 119 109 8.2 
2026 ......................................................... 9.91 8.90 10.2 121 109 10.1 
2027 ......................................................... 9.89 8.84 10.7 120 108 10.5 
2028 ......................................................... 10.0 8.89 11.1 122 108 10.9 
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TABLE VII–9—E STIMATED FUELCONSUMPTION AND GHG E MISSIONS OVERUSEFUL LIFE OF HD P ICKUPS AND VANS 
PRODUCED IN EACHMODEL YEAR FOR METHOD A, R ELATIVE TO ALTERNATIVE 1ba—Continued 
Model year Fuel consumption 
(b. gal.) 
over fleet’s useful life GHG emissions 
(MMT CO 2eq) 
over fleet’s useful life 
No action Final Reduction 
(%) No action Final Reduction 
(%) 
2029 ......................................................... 10.1 8.97 11.2 123 109 11.1 
2030 ......................................................... 10.1 8.94 11.2 123 109 11.1 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE VII–10—E STIMATED FUELCONSUMPTION AND GHG E MISSIONS OVERUSEFUL LIFE OF HD P ICKUPS AND VANS 
PRODUCED IN EACHMODEL YEAR FOR METHOD A, R ELATIVE TO ALTERNATIVE 1aa 
Model year Fuel consumption 
(b. gal.) 
over fleet’s useful life GHG emissions 
(MMT CO 2eq) 
over fleet’s useful 
No action Final Reduction 
(%) No action Final Reduction 
(%) 
2016 ......................................................... 10.43 10.43 0.0 122 122 0.0 
2017 ......................................................... 10.37 10.15 2.2 122 119 2.2 
2018 ......................................................... 10.41 10.10 3.0 122 118 3.1 
2019 ......................................................... 10.04 9.55 4.9 118 112 5.1 
2020 ......................................................... 10.03 9.56 4.7 118 112 4.9 
2021 ......................................................... 9.84 9.16 6.9 115 107 7.1 
2022 ......................................................... 9.74 9.01 7.5 114 105 7.7 
2023 ......................................................... 9.71 8.97 7.6 114 105 7.8 
2024 ......................................................... 9.75 9.00 7.6 114 105 7.8 
2025 ......................................................... 9.88 8.97 9.1 116 105 9.3 
2026 ......................................................... 10.00 8.92 10.8 117 104 11.1 
2027 ......................................................... 10.01 8.84 11.7 117 103 11.9 
2028 ......................................................... 10.12 8.89 12.1 119 104 12.4 
2029 ......................................................... 10.22 8.98 12.1 120 105 12.4 
2030 ......................................................... 10.18 8.95 12.2 119 105 12.4 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
To more clearly communicate these 
trends visually, the following two charts 
present the above results graphically for Method A, relative to Alternative 1b. As shown, fuel consumption and GHG emissions follow parallel though not precisely identical paths. Though not presented, the charts for Alternative 1a will appear sufficiently similar that differences between Alternative 1a and Alternative 1b remain best 
communicated by comparing values in the above tables. 
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ER25OC16.036</GPH>mstockstill on DSK3G9T082PROD with RULES2~ 
:::i 
:i -CLJ Ill 
::) 
Ill 8 ':., 
CLJ 
CLJ 
u::: 7 ... 
CLJ > 0 6 Ill c 
..2 
"iii 5 Ill) e 4 c 
0 
':;::; c. 3 E :I Ill 2 c 
0 u -Fuel "ii 1 :I 
L&. Fuel (Standards) 
0 
ID ..... 00 Q'l 
.-1 .-1 .-1 .-1 
0 0 0 0 
N N N N 0 .-1 
N N 
0 0 
N N N 
N 
0 
N I'll 
N 
0 
N ;:!; 
0 
N 
Model Year Ill 
N 
0 
N ID 
N 
0 
N ..... 
N 
0 
N 00 
N 
0 
N Q'l 
N 
0 
N 
Figure VII-1 Fuel Consumption (b. gal.) over Useful Life ofHD Pickups and Vans Produced in Each Model 
Year for Method A 
140 
Qj' 130 -:::i 
:i 120 -CLJ Ill 110 ::) 
Ill 
':., 100 CLJ 
CLJ 
u::: 90 ... 
CLJ > 80 0 
C" 
CLJ 70 N 0 60 u .... 
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Ill 40 c 
0 ·u; 30 Ill .E 
20 w 
c;, -GHG (No-Action) 
::r: 10 c;, GHG (Standards} 
0 
ID ..... 00 Q'l 0 .-1 N I'll .,. Ill ID ..... 00 Q'l 
.-1 .-1 .-1 .-1 N N N N N N N N N N 
0 0 0 0 0 0 0 0 0 0 0 0 0 0 
N N N N N N N N N N N N N N 
Model Year 
Figure VII-2 GHG Emissions (MMT C02eq) over Useful Life ofHD Pickups and Vans Produced in Each 
Model Year for Method A 0 I'll 
0 
N 73829 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 
TABLE VII–11—A NNUAL DOWNSTREAM GHG E MISSIONS IMPACTS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL 
PROGRAM VS . ALT1b U SING ANALYSIS METHOD Aa 
CY CO 2 
(MMT) CH 4 
(MMT CO 2eq) N2O 
(MMT CO 2eq) Total downstream 
MMT CO 2eq % Change 
2025 ..................................................................................... ¥26.5 ¥0.004 0.002 ¥26.6 ¥4.9 
2040 ..................................................................................... ¥103.3 ¥0.02 0.006 ¥103.3 ¥17.0 
2050 ..................................................................................... ¥123.8 ¥0.03 0.007 ¥123.8 ¥18.0 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE VII–12—A NNUAL FUELSAVINGS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1b U SING 
ANALYSIS METHOD Aa 
CY Diesel Gasoline 
Billion gallons % Savings Billion gallons % Savings 
2025 ................................................................................................................. 2.3 4.9 0.4 5.0 
2040 ................................................................................................................. 9.2 17.8 1 .0 12.2 
2050 ................................................................................................................. 11.1 19.3 1.2 12.8 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE VII–13—A NNUAL DOWNSTREAM GHG E MISSIONS IMPACTS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL 
PROGRAM VS . ALT1a U SING ANALYSIS METHOD Aa 
CY CO 2 
(MMT) CH 4 
(MMT CO 2eq) N2O 
(MMT CO 2eq) Total downstream 
MMT CO 2eq % Change 
2025 ..................................................................................... ¥28.9 ¥0.005 0.003 ¥28.9 ¥5.3 
2040 ..................................................................................... ¥114.1 ¥0.02 0.006 ¥114.1 ¥18.0 
2050 ..................................................................................... ¥136.9 ¥0.03 0.007 ¥136.9 ¥20.0 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE VII–14—A NNUAL FUELSAVINGS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1a U SING 
ANALYSIS METHOD Aa 
CY Diesel Gasoline 
Billion gallons % Savings Billion gallons % Savings 
2025 ................................................................................................................. 2.4 5.2 0.5 5.6 
2040 ................................................................................................................. 10.2 19.0 1.2 13.0 
2050 ................................................................................................................. 12.3 21.0 1.3 14.0 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(ii) Upstream (Fuel Production and 
Distribution) Emissions Projections 
TABLE VII–15—A NNUAL UPSTREAM GHG E MISSIONS IMPACTS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL 
PROGRAM VS . ALT1b U SING ANALYSIS METHOD Aa 
CY CO 2 
(MMT) CH 4 
(MMT CO 2eq) N2O 
(MMT CO 2eq) Total upstream 
MMT CO 2eq % Change 
2025 ..................................................................................... ¥8.1 ¥0.9 ¥0.08 ¥9.0 ¥4.9 
2040 ..................................................................................... ¥31.8 ¥3.4 ¥0.2 ¥35.5 ¥17.0 
2050 ..................................................................................... ¥38.1 ¥4.2 ¥0.2 ¥42.5 ¥19.0 
Note: 
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aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE VII–16—A NNUAL UPSTREAM GHG E MISSIONS IMPACTS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL 
PROGRAM VS . ALT1a U SING ANALYSIS METHOD Aa 
CY CO 2 
(MMT) CH 4 
(MMT CO 2eq) N2O 
(MMT CO 2eq) Total upstream 
MMT CO 2eq % Change 
2025 ..................................................................................... ¥8.7 ¥0.9 ¥0.09 ¥9.8 ¥5.3 
2040 ..................................................................................... ¥35.2 ¥3.9 ¥0.2 ¥39.3 ¥19.0 
2050 ..................................................................................... ¥42.2 ¥4.6 ¥0.3 ¥47.2 ¥20.0 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(iii) HFC Emissions Projections 
The projected HFC emission 
reductions due to the HD Phase 2 air 
conditioning leakage standards for vocational vehicles are 86,735 metric 
tons of CO 2eq in 2025, 256,061 metric 
tons of CO 2eq in 2040, and 314,930 
metric tons CO 2eq in 2050. See Chapter 5 of the RIA for additional details on 
calculations of HFC emissions. 
(iv) Total (Downstream + Upstream + 
HFC) Emissions Projections 
TABLE VII–17—A NNUAL TOTAL GHG E MISSIONS IMPACTS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM  
VS. ALT1b U SING ANALYSIS METHOD Aa 
CY2025 CY2040 CY2050 
MMT CO 2eq % Change MMT CO 2eq % Change MMT CO 2eq % Change 
Downstream ............................................. ¥26.6 ¥4.9 ¥103.3 ¥17.0 ¥123.8 ¥18.0 
Upstream .................................................. ¥9.0 ¥4.9 ¥35.5 ¥17.0 ¥42.5 ¥19.0 
HFCb........................................................ ¥0.1 ¥15.0 ¥0.3 ¥13.0 ¥0.3 ¥13.0 
Total ......................................................... ¥35.7 ¥4.9 ¥139.1 ¥17.0 ¥166.6 ¥19.0 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
bHFC represents HFC emission reductions and percent change from the vocational vehicle category only. 
TABLE VII–18 A NNUAL TOTAL GHG E MISSIONS IMPACTS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM  
VS. ALT1a U SING ANALYSIS METHOD Aa 
CY2025 CY2040 CY2050 
MMT CO 2eq % Change MMT CO 2eq % Change MMT CO 2eq % Change 
Downstream ............................................. ¥28.9 ¥5.3 ¥114.1 ¥18.0 ¥136.9 ¥20.0 
Upstream .................................................. ¥9.8 ¥5.3 ¥39.3 ¥19.0 ¥47.2 ¥20.0 
HFC .......................................................... ¥0.1 ¥15.0 ¥0.3 ¥13.0 ¥0.3 ¥13.0 
Total ......................................................... ¥38.8 ¥5.3 ¥153.7 ¥19.0 ¥184.4 ¥20.0 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(b) Model Year Lifetime Analysis 
TABLE VII–19—L IFETIME GHG R EDUCTIONS AND FUELSAVINGS USING ANALYSIS METHOD A—S UMMARY FOR MODEL  
YEARS 2018–2029a 
No–action alternative (baseline) Final program 
(alternative 3) 
1b 
(dynamic) 1a 
(flat) 
Fuel Savings (Billion Gallons) ................................................................................................. ................................ 71.1 77.7 
Total GHG Reductions (MMT CO 2eq) .................................................................................................................... 958 1,04 9 
Downstream (MMT CO 2eq) ............................................................................................................................ .. 715 781 
Upstream (MMT CO 2eq) ............................................................................................................................ ...... 243 268 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
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549MOVES is not capable of modeling the 
changes in exhaust N 2O emissions from the 
improvements in fuel efficiency. Due to this 
limitation, a conservative approach was taken to only model the VMT rebound in estimating the emissions impact on N
2O from the final rules, 
resulting in a slight increase in downstream N 2O 
inventory. 550Renewable Fuels Standards assumptions of 
115,000 BTU/gallon gasoline (E0) and 76,330 BTU/ 
gallon ethanol (E100) were weighted 90 percent and 10 percent, respectively, for E10 and 85 percent and 15 percent, respectively, for E15 and converted to 
kJ at 1.055 kJ/BTU. The conversion factors are 117,245 kJ/gallon for gasoline blended with ten percent ethanol (E10) and 115,205 kJ/gallon for gasoline blended with fifteen percent ethanol (E15). 551The conversion factor for diesel is 138,451 kJ/ 
gallon. See MOVES2004 Energy and Emission Inputs. EPA420–P–05–003, March 2005. http://
www3.epa.gov/otaq/models/ngm/420p05003.pdf (last accessed Mar 15, 2016). 
552U.S. EPA. 2014 Standards for the Renewable 
Fuel Standard Program. 40 CFR part 80. EPA–HQ– OAR–2013–0479; FRL–9900–90–OAR, RIN 2060– AR76. (2) Impacts of the Final Rules Using 
Analysis Method B 
(a) Calendar Year Analysis (i) Downstream (Tailpipe) Emissions 
Projections 
As described in Section VII.A., 
Method B used MOVES to estimate downstream GHG inventories from the final rules, relative to Alternative 1a, for 
all heavy-duty vehicle categories (including the engines associated with tractor-trailer combinations and vocational vehicles). The agencies expect reductions in CO
2emissions 
from all heavy-duty vehicle categories due to engine and vehicle improvements. We expect N
2O emissions to increase very slightly 
because of a rebound in vehicle miles traveled (VMT). However, since N
2O is 
produced as a byproduct of fuel combustion, the increase in N
2O 
emissions is expected to be more than offset by the improvements in fuel efficiency from the final rules.
549We 
expect methane emissions to decrease primarily due to reduced refueling from improved fuel efficiency and the differences in hydrocarbon emission characteristics between on-road diesel engines and APUs. The amount of methane emitted as a fraction of total 
hydrocarbons is expected to be less for APUs than for on-road diesel engines during extended idling. Overall, the downstream GHG emissions will be reduced significantly and are described in the following subsections. 
Fuel consumption is calculated from 
the MOVES output of total energy consumption converted using the fuel heating values assumed in the Renewable Fuels Standard rulemaking
550and in MOVES.551 
Table VII–20 shows the impacts on 
downstream GHG emissions and fuel savings in 2025, 2040 and 2050, relative to Alternative 1a, for the final program. 
Table VII–21 shows the estimated fuel 
savings from the final program in 2025, 2040, and 2050, relative to Alternative 1a. The results from the comparable analyses relative to Alternative 1b are presented in Section VII.C.(1). 
TABLE VII–20—A NNUAL DOWNSTREAM GHG E MISSIONS IMPACTS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL 
PROGRAM VS . ALT1a U SING ANALYSIS METHOD Ba 
CY CO 2 
(MMT) CH 4 
(MMT CO 2eq) N2O 
(MMT CO 2eq) Total downstream 
MMT CO 2eq % Change 
2025 ..................................................................................... ¥27.8 ¥0.01 0.002 ¥27.8 ¥4.6 
2040 ..................................................................................... ¥124.3 ¥0.02 0.003 ¥124.3 ¥18.4 
2050 ..................................................................................... ¥148.4 ¥0.03 0.004 ¥148.4 ¥0.0 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE VII–21—A NNUAL FUELSAVINGS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1a U SING 
ANALYSIS METHOD Ba 
CY Diesel Gasoline 
Billion gallons % Savings Billion gallons % Savings 
2025 ................................................................................................................. 2.5 5.0 0.3 2.8 
2040 ................................................................................................................. 10.8 19.4 1.7 13.3 
2050 ................................................................................................................. 13.0 21.0 1.9 14.4 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(ii) Upstream (Fuel Production and 
Distribution) Emissions Projections 
The upstream GHG emission 
reductions associated with the 
production and distribution of gasoline and diesel from crude oil include the domestic emission reductions only. Additionally, since this rulemaking is not expected to impact biofuel volumes mandated by the annual Renewable Fuel Standards (RFS) regulations
552, the 
impacts on upstream emissions from changes in biofuel feedstock (i.e., 
agricultural sources such as fertilizer, fugitive dust, and livestock) are not shown. In other words, we attribute decreased fuel consumption from this program to petroleum-based fuels only, while assuming no net effect on 
volumes of renewable fuels. We used this approach because annual renewable fuel volumes are mandated independently from this rulemaking under RFS. As a consequence, it is not possible to conclude whether the decreasing petroleum consumption projected here would increase the fraction of the U.S. fuel supply that is made up by renewable fuels (if RFS volumes remained constant), or whether future renewable fuel volume mandates would decrease in proportion to the decreased petroleum consumption projected here. 
As background, EPA sets annual 
renewable fuel volume mandates through a separate RFS notice-and- comment rulemaking process, and the 
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553A lifetime of 30 years is assumed in MOVES. final volumes are based on EIA 
projections, EPA’s own market assessment, and information obtained from the RFS notice and comment process. Also, RFS standards are nested within each other, which means that a fuel with a higher GHG reduction threshold can be used to meet the 
standards for a lower GHG reduction threshold. This creates additional 
uncertainty in projecting this rule’s net effect on future annual RFS standards. 
In conclusion, the impacts of this 
rulemaking on annual renewable fuel volume mandates are difficult to project at the present time. However, since it is 
not centrally relevant to the analysis for this rulemaking, we have not included any impacts on renewable fuel volumes in this analysis. The upstream GHG emission reductions of the final program can be found in Table VII–22. 
TABLE VII–22—A NNUAL UPSTREAM GHG E MISSIONS IMPACTS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL 
PROGRAM VS . ALT1a U SING ANALYSIS METHOD Ba 
CY CO 2 
(MMT) CH 4 
(MMT CO 2eq) N2O 
(MMT CO 2eq) Total upstream 
MMT CO 2eq % CHANGE 
2025 ..................................................................................... ¥8.6 ¥0.9 ¥0.04 ¥9.5 ¥4.7 
2040 ..................................................................................... ¥38.0 ¥4.0 ¥0.2 ¥42.2 ¥18.7 
2050 ..................................................................................... ¥45.5 ¥4.8 ¥0.2 ¥50.5 ¥20.3 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(iii) HFC Emissions Projections 
The projected HFC emission 
reductions due to the HD Phase 2 air 
conditioning leakage standards for vocational vehicles are 86,735 metric 
tons of CO
2eq in 2025, 256,061 metric 
tons of CO 2eq in 2040, and 314,930 metric tons CO 2eq in 2050. See Chapter 
5 of the RIA for additional details on 
calculations of HFC emissions. 
(iv) Total (Downstream + Upstream + 
HFC) Emissions Projections 
Table VII–23 combines the impacts of 
the final program from downstream (Table VII–20), upstream (Table VII–22), 
and HFC to summarize the total GHG reductions in calendar years 2025, 2040 and 2050, relative to Alternative 1a. 
TABLE VII–23—A NNUAL TOTAL GHG E MISSIONS IMPACTS IN CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM  
VS. ALT1a U SING ANALYSIS METHOD Ba 
CY2025 CY2040 CY2050 
MMT CO 2eq % Change MMT CO 2eq % Change MMT CO 2eq % Change 
Downstream ............................................. ¥27.8 ¥4.6 ¥124.3 ¥18.4 ¥148.4 ¥20.0 
Upstream .................................................. ¥9.5 ¥4.7 ¥42.2 ¥18.7 ¥50.5 ¥20.3 
HFCb........................................................ ¥0.1 ¥15.0 ¥0.3 ¥13.0 ¥0.3 ¥13.0 
Total ......................................................... ¥37.4 ¥4.7 ¥166.8 ¥18.5 ¥199.2 ¥20.1 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
bHFC represents HFC emission reductions and percent change from the vocational vehicle category only. 
(b) Model Year Lifetime Analysis 
In addition to the annual GHG 
emissions and fuel consumption reductions expected from the final rules, we estimated the combined (downstream and upstream) GHG and 
fuel consumption impacts for the lifetime of the impacted vehicles sold in the regulatory timeframe. Table VII–24 shows the fleet-wide GHG reductions and fuel savings from the final program, relative to Alternative 1a, through the 
lifetime of heavy-duty vehicles.
553For 
the lifetime GHG reductions and fuel savings by vehicle categories, see Chapter 5 of the RIA. 
TABLE VII–24—L IFETIME GHG R EDUCTIONS AND FUELSAVINGS USING ANALYSIS METHOD B—S UMMARY FOR MODEL  
YEARS 2018–2029a 
Model years Final program 
(Alternative 3) 
No-action alternative 
(baseline) 1a (Flat) 
Fuel Savings (Billion Gallons) ................................................................................................. ...................................................... 82.2 
Total GHG Reductions (MMT CO 2eq) .......................................................................................................................................... 1,097.6 
Downstream (MMT CO 2eq) ........................................................................................................................................................... 819.2 
Upstream (MMT CO 2eq) ............................................................................................................................................................... 278.4 
Note: 
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554U.S. EPA (2012) Inventory of U.S. Greenhouse 
Gas Emissions and Sinks: 1990–2010. EPA 430–R– 
12–001. Available at http://epa.gov/climatechange/ 
emissions/downloads12/US-GHG-Inventory-2012-
Main-Text.pdf. 
555For a complete list of core references from 
IPCC, USGCRP/CCSP, NRC and others relied upon for development of the TSD for EPA’s Endangerment and Cause or Contribute Findings 
see Section 1(b), specifically, Table 1.1 of the TSD. (Docket EPA–HQ–OAR–2010–0799). 556‘‘EPA’s Denial of the Petitions to Reconsider 
the Endangerment and Cause or Contribute 
Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act,’’ 75 FR 49,556 (Aug. 13, 2010) (‘‘Reconsideration Denial’’). 
557Intergovernmental Panel on Climate Change 
(IPCC). 2012: Managing the Risks of Extreme Events and Disasters to Advance Climate Change Adaptation. A Special Report of Working Groups I and II of the Intergovernmental Panel on Climate Change. Cambridge University Press, Cambridge, UK, and New York, NY, USA. 
558Intergovernmental Panel on Climate Change 
(IPCC). 2013. Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, Intergovernmental Panel on Climate Change (IPCC). 2014. Climate Change 2014: Impacts, Adaptation, and Vulnerability. Contribution of Working Group II to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, Intergovernmental Panel on Climate Change (IPCC). 2014. Climate Change 2014: Mitigation of Climate Change. Contribution of Working Group III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. 
559Melillo, Jerry M., Terese (T.C.) Richmond, and 
Gary W. Yohe, Eds. 2014. Climate Change Impacts in the United States: The Third National Climate Assessment. U.S. Global Change Research Program. Available at http://nca2014.globalchange.gov. 
560National Research Council (NRC). 2010. Ocean 
Acidification: A National Strategy to Meet the Challenges of a Changing Ocean. National Academies Press. Washington, DC. 
561National Research Council (NRC). 2011. 
Climate Stabilization Targets: Emissions, Concentrations, and Impacts over Decades to Millennia. National Academies Press, Washington, DC. 
562National Research Council (NRC) 2011. 
National Security Implications of Climate Change for U.S. Naval Forces. National Academies Press. Washington, DC. 
563National Research Council (NRC). 2012. Sea- 
Level Rise for the Coasts of California, Oregon, and 
Continued aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
D. Climate Impacts and Indicators 
(1) Climate Change Impacts From GHG 
Emissions 
The impact of GHG emissions on the 
climate has been reviewed in the 2009 Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act, the 2012–2016 light-duty vehicle rulemaking, the 2014–2018 heavy-duty vehicle GHG and fuel efficiency rulemaking, the 2017–2025 light-duty vehicle rulemaking, and the standards for new electricity utility generating units. See 74 FR 66496; 75 FR 25491; 76 FR 57294; 77 FR 62894; 79 FR 1456– 1459; 80 FR 64662. This section briefly discusses again some of the climate impact of EPA’s actions in context of transportation emissions. NHTSA has analyzed the climate impacts of its specific actions (i.e., excluding EPA’s 
HFC regulatory provisions) as well as reasonable alternatives in its DEIS that accompanies this final rules. DOT has considered the potential climate impacts documented in the DEIS as part of the rulemaking process. 
Once emitted, GHGs that are the 
subject of this regulation can remain in the atmosphere for decades to millennia, meaning that (1) their concentrations become well-mixed throughout the global atmosphere regardless of emission origin, and (2) their effects on climate are long lasting. GHG emissions come mainly from the combustion of fossil fuels (coal, oil, and gas), with additional contributions from the clearing of forests, agricultural activities, cement production, and some industrial activities. Transportation activities, in aggregate, were the second largest contributor to total U.S. GHG emissions in 2010 (27 percent of total emissions).
554 
The EPA Administrator relied on 
thorough and peer-reviewed assessments of climate change science prepared by the Intergovernmental Panel on Climate Change (‘‘IPCC’’), the United States Global Change Research Program (‘‘USGCRP’’), and the National Research Council of the National Academies (‘‘NRC’’)
555as the primary scientific and technical basis for the Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act (74 FR 66496, December 15, 2009). These assessments comprehensively address the scientific issues the EPA Administrator had to examine, providing her data and information on a wide range of issues pertinent to the Endangerment Finding. These assessments have been rigorously reviewed by the expert community, and also by United States government agencies and scientists, including by EPA itself. 
Based on these assessments, the EPA 
Administrator determined that the emissions from new motor vehicles and engines contribute to elevated concentrations of greenhouse gases; that these greenhouse gases cause warming; that the recent warming has been attributed to the increase in greenhouse gases; and that warming of the climate endangers the public health and welfare of current and future generations. See Coalition for Responsible Regulation v. EPA, 684 F. 3d 102, 121 (D.C. Cir. 2012) 
(upholding all of EPA’s findings and stating ‘‘EPA had before it substantial record evidence that anthropogenic emissions of greenhouse gases ‘very likely’ caused warming of the climate over the last several decades. EPA further had evidence of current and future effects of this warming on public health and welfare. Relying again upon substantial scientific evidence, EPA determined that anthropogenically induced climate change threatens both public health and public welfare. It found that extreme weather events, changes in air quality, increases in food- and water-borne pathogens, and increases in temperatures are likely to have adverse health effects. The record also supports EPA’s conclusion that climate change endangers human welfare by creating risk to food production and agriculture, forestry, energy, infrastructure, ecosystems, and wildlife. Substantial evidence further supported EPA’s conclusion that the warming resulting from the greenhouse gas emissions could be expected to create risks to water resources and in general to coastal areas as a result of expected increase in sea level.’’) 
A number of major peer-reviewed 
scientific assessments have been released since the administrative record concerning the Endangerment Finding 
closed following EPA’s 2010 Reconsideration Denial.
556These 
assessments include the ‘‘Special Report on Managing the Risks of Extreme Events and Disasters to Advance Climate Change Adaptation’’
557, the 
2013–14 Fifth Assessment Report (AR5),
558the 2014 National Climate 
Assessment report,559the ‘‘Ocean 
Acidification: A National Strategy to Meet the Challenges of a Changing Ocean,’’
560‘‘Report on Climate 
Stabilization Targets: Emissions, Concentrations, and Impacts over Decades to Millennia,’’
561‘‘National 
Security Implications for U.S. Naval Forces’’ (National Security Implications),
562‘‘Understanding 
Earth’s Deep Past: Lessons for Our Climate Future,’’
563‘‘Sea Level Rise for 
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Washington: Past, Present, and Future. National 
Academies Press. Washington, DC. 
564National Research Council (NRC). 2012. Sea- 
Level Rise for the Coasts of California, Oregon, and Washington: Past, Present, and Future. National Academies Press. Washington, DC. 
565National Research Council (NRC). 2013. 
Climate and Social Stress: Implications for Security Analysis. National Academies Press. Washington, DC. 
566National Research Council (NRC). 2013. 
Abrupt Impacts of Climate Change: Anticipating Surprises. National Academies Press. Washington, DC. 567GCAM is a long-term, global integrated 
assessment model of energy, economy, agriculture and land use that considers the sources of emissions of a suite of greenhouse gases (GHG’s), emitted in 14 globally disaggregated regions, the fate of emissions to the atmosphere, and the consequences of changing concentrations of greenhouse related gases for climate change. GCAM begins with a representation of demographic and economic developments in each region and combines these with assumptions about technology development to describe an internally consistent representation of energy, agriculture, land-use, and economic developments that in turn shape global emissions. 
568MAGICC consists of a suite of coupled gas- 
cycle, climate and ice-melt models integrated into a single framework. The framework allows the user to determine changes in greenhouse-gas concentrations, global-mean surface air temperature and sea-level resulting from anthropogenic emissions of carbon dioxide (CO
2), methane (CH 4), 
nitrous oxide (N2O), reactive gases (CO, NO X, 
VOCs), the halocarbons (e.g. HCFCs, HFCs, PFCs) 
and sulfur dioxide (SO 2). MAGICC emulates the 
global-mean temperature responses of more sophisticated coupled Atmosphere/Ocean General Circulation Models (AOGCMs) with high accuracy. the Coasts of California, Oregon, and 
Washington: Past, Present, and Future,’’
564‘‘Climate and Social Stress: 
Implications for Security Analysis,’’565 
and ‘‘Abrupt Impacts of Climate Change’’ (Abrupt Impacts) assessments.
566 
EPA has reviewed these assessments 
and finds that, in general, the improved understanding of the climate system they present is consistent with the assessments underlying the 2009 Endangerment Finding. 
The most recent assessments released 
were the IPCC AR5 assessments between September 2013 and April 2014, the NRC Abrupt Impacts assessment in December of 2013, and the U.S. National Climate Assessment in May of 2014. The NRC Abrupt Impacts report examines the potential for tipping points, thresholds beyond which major and rapid changes occur in the Earth’s climate system or other systems 
impacted by the climate. The Abrupt Impacts report did find less cause for concern than some previous assessments regarding some abrupt events within the next century, such as disruption of the Atlantic Meridional Overturning Circulation (AMOC) and sudden releases of high-latitude methane from hydrates and permafrost, but found that the potential for abrupt changes in ecosystems, weather and climate extremes, and groundwater supplies critical for agriculture now seem more likely, severe, and imminent. The assessment found that some abrupt changes were already underway (Arctic sea ice retreat and increases in extinction risk due to the speed of climate change) but cautioned that even abrupt changes such as the AMOC disruption that are not expected in this century can have severe impacts when they happen. 
The IPCC AR5 assessments are also 
generally consistent with the underlying science supporting the 2009 Endangerment Finding. For example, confidence in attributing recent warming to human causes has increased: The IPCC stated that it is extremely likely (≤95 percent confidence) that human influences have been the dominant cause of recent warming. Moreover, the IPCC found that the last 30 years were likely (≤66 percent confidence) the warmest 30 year period in the Northern Hemisphere of the past 1400 years, that the rate of ice loss of worldwide glaciers and the Greenland and Antarctic ice sheets has likely increased, that there is medium confidence that the recent summer sea ice retreat in the Arctic is larger than it has been in 1450 years, and that concentrations of carbon dioxide and several other of the major greenhouse gases are higher than they have been in at least 800,000 years. Climate-change induced impacts have been observed in changing precipitation patterns, melting snow and ice, species migration, negative impacts on crops, increased heat and decreased cold mortality, and altered ranges for water-borne illnesses and disease vectors. Additional risks from future changes include death, injury, and disrupted livelihoods in coastal zones and regions vulnerable to inland flooding, food insecurity linked to warming, drought, and flooding, especially for poor populations, reduced access to drinking and irrigation water for those with minimal capital in semi- arid regions, and decreased biodiversity in marine ecosystems, especially in the Arctic and tropics, with implications for coastal livelihoods. The IPCC determined that ‘‘[c]ontinued emissions of greenhouse gases will cause further warming and changes in all components of the climate system. Limiting climate change will require substantial and sustained reductions of greenhouse gases emissions.’’ 
Finally, the recently released National 
Climate Assessment stated, ‘‘Climate change is already affecting the American people in far reaching ways. Certain types of extreme weather events with links to climate change have become more frequent and/or intense, including prolonged periods of heat, heavy downpours, and, in some regions, floods and droughts. In addition, warming is causing sea level to rise and glaciers and Arctic sea ice to melt, and oceans are becoming more acidic as they absorb carbon dioxide. These and other aspects of climate change are disrupting people’s lives and damaging some sectors of our economy.’’ 
Assessments from these bodies 
represent the current state of knowledge, comprehensively cover and synthesize thousands of individual studies to obtain the majority conclusions from the body of scientific literature and undergo a rigorous and exacting standard of review by the peer expert community and U.S. government. Based on modeling analysis 
performed by the agencies, reductions 
in CO
2and other GHG emissions 
associated with these final rules will affect future climate change. Since GHGs are well-mixed in the atmosphere and have long atmospheric lifetimes, changes in GHG emissions will affect atmospheric concentrations of greenhouse gases and future climate for decades to millennia, depending on the gas. This section provides estimates of the projected change in atmospheric CO
2concentrations based on the 
emission reductions estimated for these final rules, compared to the reference case. In addition, this section analyzes the response to the changes in GHG concentrations of the following climate- related variables: Global mean temperature, sea level rise, and ocean pH. 
(2) Projected Change in Atmospheric 
CO
2Concentrations, Global Mean 
Surface Temperature and Sea Level Rise 
To assess the impact of the emissions 
reductions from the final rules, EPA estimated changes in projected 
atmospheric CO
2concentrations, global 
mean surface temperature and sea-level rise to 2100 using the GCAM (Global Change Assessment Model, formerly MiniCAM), integrated assessment model
567coupled with the MAGICC 
(Model for the Assessment of Greenhouse-gas Induced Climate Change) simple climate model.
568 
GCAM was used to create the globally and temporally consistent set of climate relevant emissions required for running MAGICC. MAGICC was then used to estimate the projected change in relevant climate variables over time. Given the magnitude of the estimated 
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569National Research Council (NRC) (2011). 
Climate Stabilization Targets: Emissions, 
Concentrations, and Impacts over Decades to Millennia. National Academy Press. Washington, DC. (Docket EPA–HQ–OAR–2010–0799). emissions reductions associated with 
these rules, a simple climate model such as MAGICC is appropriate for estimating the atmospheric and climate response. 
The analysis projects that the final 
rules will reduce atmospheric concentrations of CO
2, global climate 
warming, ocean acidification, and sea level rise relative to the reference case. Although the projected reductions and improvements are small in comparison to the total projected climate change, they are quantifiable, directionally consistent, and will contribute to 
reducing the risks associated with climate change. Climate change is a global phenomenon, and EPA recognizes that this one national action 
alone will not prevent it; EPA notes this would be true for any given GHG mitigation action when taken alone or when considered in isolation. EPA also notes that a substantial portion of CO
2 
emitted into the atmosphere is not removed by natural processes for millennia, and therefore each unit of CO
2not emitted into the atmosphere 
due to this rules avoids essentially permanent climate change on centennial time scales. 
EPA determines that the projected 
reductions in atmospheric CO
2, global 
mean temperature, sea level rise, and 
ocean pH are meaningful in the context of this action. The results of the 
analysis, summarized in Table VII–25, demonstrate that relative to the reference case, by 2100 projected atmospheric CO
2concentrations are 
estimated to be reduced by 1.2 to 1.3 part per million by volume (ppmv), global mean temperature is estimated to be reduced by 0.0027 to 0.0065 °C, and sea-level rise is projected to be reduced by approximately 0.026 to 0.058 cm, based on a range of climate sensitivities (described below). Details about this modeling analysis can be found in the RIA Chapter 6.3. 
TABLE VII–25—I MPACT OF GHG E MISSIONS REDUCTIONS ON PROJECTED CHANGES IN GLOBAL CLIMATE ASSOCIATED  
WITHPHASE 2 STANDARDS FOR MY 2018–2024 
[Based on a range of climate sensitivities from 1.5–6 °C] 
Variable Units Year Projected change 
Atmospheric CO 2Concentration ............................................................... ppmv 2100 ¥1.2 to ¥1.3 
Global Mean Surface Temperature ........................................................... °C 2100 ¥0.0027 to ¥0.0065 
Sea Level Rise .......................................................................................... cm 2100 ¥0.026 to ¥0.058 
Ocean pH ................................................................................................... pH units 2100 +0.000 6a 
Note: 
aThe value for projected change in ocean pH is based on a climate sensitivity of 3.0. 
The projected reductions are small 
relative to the change in temperature 
(1.8–4.8 °C), CO 2concentration (404 to 
470 ppm), sea level rise (23–56 cm), and ocean acidity (¥0.30 pH units) from 1990 to 2100 from the MAGICC simulations for the GCAM reference case. However, this is to be expected given the magnitude of emissions reductions expected from the program in the context of global emissions. Moreover, these effects are occurring everywhere around the globe, so benefits that appear to be marginal for any one location, such as a reduction in sea level rise of half a millimeter, can be sizable when the effects are summed along thousands of miles of coastline. This uncertainty range does not include the effects of uncertainty in future emissions. It should also be noted that the calculations in MAGICC do not include the possible effects of accelerated ice flow in Greenland and/ or Antarctica: estimates of sea level rise from the recent NRC, IPCC, and NCA assessments range from 26 cm to 2 meters depending on the emissions scenario, the processes included, and the likelihood range assessed; inclusion of these effects would lead to correspondingly larger benefits of mitigation. Further discussion of EPA’s modeling analysis is found in the RIA, Chapter 6.3. 
Based on the projected atmospheric 
CO
2concentration reductions resulting from these final rules, EPA calculates an increase in ocean pH of 0.0006 pH units in 2100 relative to the baseline case (this is a reduction in the expected acidification of the ocean of a decrease of 0.3 pH units from 1990 to 2100 in the baseline case). Thus, this analysis indicates the projected decrease in atmospheric CO
2concentrations from 
the Phase 2 standards will result in an increase in ocean pH (i.e., a reduction in 
the expected acidification of the ocean in the reference case). A more detailed discussion of the modeling analysis associated with ocean pH is provided in the RIA, Chapter 6.3. 
The 2011 NRC assessment on 
‘‘Climate Stabilization Targets: Emissions, Concentrations, and Impacts over Decades to Millennia’’ determined how a number of climate impacts—such as heaviest daily rainfalls, crop yields, and Arctic sea ice extent—would change with a temperature change of 1 degree Celsius (C) of warming. These relationships of impacts with temperature change could be combined with the calculated reductions in warming in Table VII–25 to estimate changes in these impacts associated with this final rulemaking. 
As a substantial portion of CO
2 
emitted into the atmosphere is not removed by natural processes for millennia, each unit of CO
2not emitted 
into the atmosphere avoids some degree of effectively permanent climate change. Therefore, reductions in emissions in 
the near term are important in determining climate impacts experienced not just over the next decades but over thousands of years.
569 
Though the magnitude of the avoided climate change projected here in isolation is small in comparison to the total projected changes, these reductions represent a reduction in the adverse risks associated with climate change (though these risks were not formally estimated for this action) across a range of equilibrium climate sensitivities. In addition, these reductions are part of a larger suite of domestic and international mitigation actions, and should be considered in that context. 
EPA’s analysis of this final rule’s 
impact on global climate conditions is intended to quantify these potential reductions using the best available science. EPA’s modeling results show consistent reductions relative to the baseline case in changes of CO
2 
concentration, temperature, sea-level rise, and ocean pH over the next century. 
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570U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). 
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F. Figure 3–1. 
571Regulatory definitions of PM size fractions, 
and information on reference and equivalent methods for measuring PM in ambient air, are provided in 40 CFR parts 50, 53, and 58. With regard to national ambient air quality standards (NAAQS) which provide protection against health and welfare effects, the 24-hour PM
10standard 
provides protection against effects associated with short-term exposure to thoracic coarse particles (i.e., PM
10–2.5 ). 
572U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F. 
573The ISA also evaluated evidence for PM 
components but did not reach causal determinations for components. 574The causal framework draws upon the 
assessment and integration of evidence from across epidemiological, controlled human exposure, and toxicological studies, and the related uncertainties that ultimately influence our understanding of the evidence. This framework employs a five-level hierarchy that classifies the overall weight of evidence and causality using the following categorizations: causal relationship, likely to be causal relationship, suggestive of a causal relationship, inadequate to infer a causal relationship, and not likely to be a causal relationship (U.S. EPA. (2009). Integrated Science Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F, Table 1–3). 
57578 FR 3103–3104, January 15, 2013. 
57677 FR 38906–38911, June 29, 2012. 
577These causal inferences are based not only on 
the more expansive epidemiological evidence available in this review but also reflect consideration of important progress that has been made to advance our understanding of a number of potential biologic modes of action or pathways for PM-related cardiovascular and respiratory effects (U.S. EPA. (2009). Integrated Science Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F, Chapter 5). 
57878 FR 3103–3104, January 15, 2013. 
579U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F, Chapter 6 (Section 6.5) and Chapter 7 (Section 7.6). VIII. How will these rules impact non- 
GHG emissions and their associated effects? 
The heavy-duty vehicle standards are 
expected to influence the emissions of criteria air pollutants and several hazardous air pollutants (air toxics). This section describes the projected impacts of the final rules on non-GHG emissions and air quality and the health and environmental effects associated with these pollutants. NHTSA further analyzes these projected health and environmental effects resulting from its final rules and reasonable alternatives in Chapter 4 of its FEIS. 
A. Health Effects of Non-GHG Pollutants 
In this section, we discuss health 
effects associated with exposure to some 
of the criteria and air toxic pollutants impacted by the final heavy-duty vehicle standards. 
(1) Particulate Matter 
(a) Background 
Particulate matter is a highly complex 
mixture of solid particles and liquid 
droplets distributed among numerous atmospheric gases which interact with solid and liquid phases. Particles range in size from those smaller than 1 nanometer (10
¥9meter) to over 100 
micrometers (mm, or 10¥6meter) in 
diameter (for reference, a typical strand of human hair is 70 mm in diameter and a grain of salt is about 100 mm). Atmospheric particles can be grouped into several classes according to their aerodynamic and physical sizes. Generally, the three broad classes of particles include ultrafine particles (UFPs, generally considered as particulates with a diameter less than or equal to 0.1 mm [typically based on physical size, thermal diffusivity or electrical mobility])), ‘‘fine’’ particles (PM
2.5; particles with a nominal mean 
aerodynamic diameter less than or equal to 2.5 mm), and ‘‘thoracic’’ particles (PM
10; particles with a nominal mean 
aerodynamic diameter less than or equal to 10 mm).
570Particles that fall within 
the size range between PM 2.5and PM 10, 
are referred to as ‘‘thoracic coarse particles’’ (PM
10–2.5 , particles with a 
nominal mean aerodynamic diameter less than or equal to 10 mm and greater 
than 2.5 mm). EPA currently has standards that regulate PM
2.5and 
PM 10.571 Particles span many sizes and shapes 
and may consist of hundreds of different chemicals. Particles are emitted directly from sources and are also formed through atmospheric chemical reactions; the former are often referred to as ‘‘primary’’ particles, and the latter as ‘‘secondary’’ particles. Particle concentration and composition varies by time of year and location, and, in addition to differences in source emissions, is affected by several weather-related factors, such as temperature, clouds, humidity, and wind. A further layer of complexity comes from particles’ ability to shift between solid/liquid and gaseous phases, which is influenced by concentration and meteorology, especially temperature. 
Fine particles are produced primarily 
by combustion processes and by transformations of gaseous emissions (e.g., sulfur oxides (SO
X), oxides of 
nitrogen, and volatile organic compounds (VOC)) in the atmosphere. The chemical and physical properties of PM
2.5may vary greatly with time, 
region, meteorology, and source category. Thus, PM
2.5may include a 
complex mixture of different components including sulfates, nitrates, organic compounds, elemental carbon and metal compounds. These particles can remain in the atmosphere for days to weeks and travel hundreds to thousands of kilometers. 
(b) Health Effects of PM 
Scientific studies show exposure to 
ambient PM is associated with a broad 
range of health effects. These health effects are discussed in detail in the Integrated Science Assessment for Particulate Matter (PM ISA), which was finalized in December 2009.
572The PM 
ISA summarizes health effects evidence for short- and long-term exposures to PM
2.5, PM 10¥2.5, and ultrafine 
particles.573The PM ISA concludes that 
human exposures to ambient PM 2.5are 
associated with a number of adverse health effects and characterizes the weight of evidence for broad health categories (e.g., cardiovascular effects, respiratory effects, etc.).
574The 
discussion below highlights the PM 
ISA’s conclusions pertaining to health effects associated with both short- and long-term PM exposures. Further discussion of health effects associated with PM can also be found in the rulemaking documents for the most recent review of the PM NAAQS completed in 2012.
575 576  
EPA has concluded that ‘‘a causal 
relationship exists’’ between both long- and short-term exposures to PM
2.5and 
premature mortality and cardiovascular effects and that ‘‘a causal relationship is likely to exist’’ between long- and short- term PM
2.5exposures and respiratory 
effects. Further, there is evidence ‘‘suggestive of a causal relationship’’ between long-term PM
2.5exposures and 
other health effects, including developmental and reproductive effects (e.g., low birth weight, infant mortality) 
and carcinogenic, mutagenic, and genotoxic effects (e.g., lung cancer 
mortality).
577 
As summarized in the final rule 
resulting from the last review (2012) of the PM NAAQS, and discussed extensively in the 2009 p.m. ISA, the available scientific evidence significantly strengthens the link 
between long- and short-term exposure to PM
2.5and mortality, while providing 
indications that the magnitude of the PM
2.5- mortality association with long- 
term exposures may be larger than previously estimated.
578 579 The 
strongest evidence comes from recent 
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580U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). 
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F, Chapter 2 (Section 2.3.1 and 2.3.2) and Chapter 6. 
581U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F, Chapter 2 (Section 2.3.1 and 2.3.2) and Chapter 6. 582U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F, Chapter 2 (Section 2.3.1 and 2.3.2) and Chapter 7. 
583U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F. pg 2–13. 
584U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F. pg 2–26. 
585U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F. Section 2.3.4 and Table 2–6. 
58678 FR 3167–3168, January 15, 2013. 
58777 FR 38947–38951, June 29, 2012. 588U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F. Section 2.3.5 and Table 2–6. 
58978 FR 3121, January 15, 2013. 
590U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F. Chapter 8 and Chapter 2. 
59177 FR 38890, June 29, 2012. 
59278 FR 3104, January 15, 2013. 
593U.S. EPA. (2011). Policy Assessment for the 
Review of the PM NAAQS. U.S. Environmental Protection Agency, Washington, DC, EPA/452/R– 11–003. Section 2.2.1. 
594U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F. Chapter 8 and Chapter 2 (Section 2.4.1). studies investigating long-term exposure 
to PM 2.5and cardiovascular-related 
mortality. The evidence supporting a causal relationship between long-term PM
2.5exposure and mortality also 
includes consideration of studies that demonstrated an improvement in community health following reductions in ambient fine particles. 
Several studies evaluated in the 2009 
p.m. ISA have examined the association between cardiovascular effects and long- term PM
2.5exposures in multi-city 
epidemiological studies conducted in the U.S. and Europe. These studies have provided new evidence linking long- term exposure to PM
2.5with an array of 
cardiovascular effects such as heart attacks, congestive heart failure, stroke, and mortality. This evidence is coherent with studies of effects associated with short-term exposure to PM
2.5that have 
observed associations with a continuum of effects ranging from subtle changes in indicators of cardiovascular health to serious clinical events, such as increased hospitalizations and emergency department visits due to cardiovascular disease and cardiovascular mortality.
580 
As detailed in the 2009 p.m. ISA, 
extended analyses of seminal epidemiological studies, as well as more recent epidemiological studies conducted in the U.S. and abroad, provide strong evidence of respiratory- related morbidity effects associated with long-term PM
2.5exposure. The strongest 
evidence for respiratory-related effects is from studies that evaluated decrements in lung function growth (in children), increased respiratory symptoms, and asthma development. The strongest evidence from short-term PM
2.5exposure studies has been 
observed for increased respiratory- related emergency department visits and hospital admissions for chronic obstructive pulmonary disease (COPD) and respiratory infections.
581 
The body of scientific evidence 
detailed in the 2009 PM ISA is still limited with respect to associations between long-term PM
2.5exposures and 
developmental and reproductive effects as well as cancer, mutagenic, and genotoxic effects. The strongest evidence for an association between PM
2.5and developmental and reproductive effects comes from 
epidemiological studies of low birth weight and infant mortality, especially due to respiratory causes during the post-neonatal period (i.e., 1 month to 12 
months of age).
582With regard to cancer 
effects, ‘‘[m]ultiple epidemiologic studies have shown a consistent positive association between PM
2.5and 
lung cancer mortality, but studies have generally not reported associations between PM
2.5and lung cancer 
incidence.’’583 
In addition to evaluating the health 
effects attributed to short- and long-term exposure to PM
2.5, the 2009 PM ISA also 
evaluated whether specific components or sources of PM
2.5are more strongly 
associated with specific health effects. An evaluation of those studies resulted in the 2009 PM ISA concluding that ‘‘many [components] of PM can be linked with differing health effects and 
the evidence is not yet sufficient to allow differentiation of those [components] or sources that are more closely related to specific health outcomes.’’
584 
For PM 10–2.5 , the 2009 PM ISA 
concluded that available evidence was ‘‘suggestive of a causal relationship’’ between short-term exposures to PM
10–2.5 and cardiovascular effects (e.g., 
hospital admissions and Emergency Department (ED) visits, changes in cardiovascular function), respiratory effects (e.g., ED visits and hospital 
admissions, increase in markers of pulmonary inflammation), and premature mortality. The scientific evidence was ‘‘inadequate to infer a causal relationship’’ between long-term exposure to PM
10–2.5 and various health 
effects.585 586 587  
For UFPs, the 2009 PM ISA 
concluded that the evidence was ‘‘suggestive of a causal relationship’’ between short-term exposures and cardiovascular effects, including changes in heart rhythm and vasomotor function (the ability of blood vessels to expand and contract). It also concluded 
that there was evidence ‘‘suggestive of a causal relationship’’ between short-term exposure to UFPs and respiratory effects, including lung function and pulmonary inflammation, with limited and inconsistent evidence for increases in ED visits and hospital admissions. Scientific evidence was ‘‘inadequate to infer a causal relationship’’ between short-term exposure to UFPs and additional health effects including premature mortality as well as long-term exposure to UFPs and all health outcomes evaluated.
588 589  
The 2009 PM ISA conducted an 
evaluation of specific groups within the general population potentially at increased risk for experiencing adverse health effects related to PM exposures.
590 591 592 593 The evidence 
detailed in the 2009 PM ISA expands our understanding of previously identified at-risk populations and lifestages (i.e., children, older adults, 
and individuals with pre-existing heart and lung disease) and supports the 
identification of additional at-risk populations (e.g., persons with lower 
socioeconomic status, genetic differences). Additionally, there is emerging, though still limited, evidence for additional potentially at-risk populations and lifestages, such as those with diabetes, people who are obese, pregnant women, and the developing fetus.
594 
(2) Ozone 
(a) Background 
Ground-level ozone pollution is 
typically formed through reactions 
involving VOC and NO Xin the lower 
atmosphere in the presence of sunlight. These pollutants, often referred to as ozone precursors, are emitted by many types of pollution sources, such as highway and nonroad motor vehicles and engines, power plants, chemical 
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595Human exposure to ozone varies over time 
due to changes in ambient ozone concentration and 
because people move between locations which have notable different ozone concentrations. Also, the amount of ozone delivered to the lung is not only influenced by the ambient concentrations but also by the individuals breathing route and rate. 
596U.S. EPA. Integrated Science Assessment of 
Ozone and Related Photochemical Oxidants (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–10/076F, 2013. The ISA is available at http://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=247492#Download . 
597The ISA evaluates evidence and draws 
conclusions on the causal nature of relationship between relevant pollutant exposures and health effects, assigning one of five ‘‘weight of evidence’’ determinations: causal relationship, likely to be a causal relationship, suggestive of, but not sufficient to infer, a causal relationship, inadequate to infer a causal relationship, and not likely to be a causal relationship. For more information on these levels of evidence, please refer to Table II in the Preamble of the ISA. 
598U.S. EPA. Integrated Science Assessment for 
Oxides of Nitrogen—Health Criteria (2016 Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–15/068, 2016. plants, refineries, makers of consumer 
and commercial products, industrial facilities, and smaller area sources. 
The science of ozone formation, 
transport, and accumulation is complex. Ground-level ozone is produced and destroyed in a cyclical set of chemical reactions, many of which are sensitive to temperature and sunlight. When ambient temperatures and sunlight levels remain high for several days and the air is relatively stagnant, ozone and its precursors can build up and result in more ozone than typically occurs on a single high-temperature day. Ozone and its precursors can be transported hundreds of miles downwind from precursor emissions, resulting in elevated ozone levels even in areas with low local VOC or NO
Xemissions. 
(b) Health Effects of Ozone 
This section provides a summary of 
the health effects associated with exposure to ambient concentrations of ozone.
595The information in this 
section is based on the information and conclusions in the February 2013 Integrated Science Assessment for Ozone (Ozone ISA), which formed the basis for EPA’s revision to the primary and secondary standards in 2015.
596 
The Ozone ISA concludes that human exposures to ambient concentrations of ozone are associated with a number of adverse health effects and characterizes the weight of evidence for these health effects.
597The discussion below 
highlights the Ozone ISA’s conclusions pertaining to health effects associated with both short-term and long-term periods of exposure to ozone. 
For short-term exposure to ozone, the 
Ozone ISA concludes that respiratory effects, including lung function decrements, pulmonary inflammation, exacerbation of asthma, respiratory- related hospital admissions, and mortality, are causally associated with ozone exposure. It also concludes that cardiovascular effects, including decreased cardiac function and increased vascular disease, and total mortality are likely to be causally associated with short-term exposure to ozone and that evidence is suggestive of a causal relationship between central nervous system effects and short-term exposure to ozone. 
For long-term exposure to ozone, the 
Ozone ISA concludes that respiratory effects, including new onset asthma, pulmonary inflammation and injury, are likely to be causally related with ozone exposure. The Ozone ISA characterizes the evidence as suggestive of a causal relationship for associations between long-term ozone exposure and cardiovascular effects, reproductive and developmental effects, central nervous system effects and total mortality. The evidence is inadequate to infer a causal relationship between chronic ozone exposure and increased risk of lung cancer. 
Finally, inter-individual variation in 
human responses to ozone exposure can result in some groups being at increased risk for detrimental effects in response to exposure. In addition, some groups are at increased risk of exposure due to their activities, such as outdoor workers or children. The Ozone ISA identified several groups that are at increased risk for ozone-related health effects. These groups are people with asthma, children and older adults, individuals with reduced intake of certain nutrients (i.e., Vitamins C and E), outdoor workers, and individuals having certain genetic variants related to oxidative metabolism or inflammation. Ozone exposure during childhood can have lasting effects through adulthood. Such effects include altered function of the respiratory and immune systems. Children absorb higher doses (normalized to lung surface area) of ambient ozone, compared to adults, due to their increased time spent outdoors, higher ventilation rates relative to body size, and a tendency to breathe a greater fraction of air through the mouth. Children also have a higher asthma prevalence compared to adults. Additional children’s vulnerability and susceptibility factors are listed in Section XIV. 
(3) Nitrogen Oxides 
(a) Background 
Oxides of nitrogen (NO
X) refers to 
nitric oxide and nitrogen dioxide (NO 2). 
For the NO XNAAQS, NO 2is the 
indicator. Most NO 2is formed in the air 
through the oxidation of nitric oxide (NO) emitted when fuel is burned at a 
high temperature. NO Xis also a major 
contributor to secondary PM 2.5 
formation. The health effects of ambient PM are discussed in Section VIII.A.1.b of this Preamble. NO
Xand VOC are the 
two major precursors of ozone. The health effects of ozone are covered in Section VIII.A.2.b. 
(b) Health Effects of Nitrogen Oxides 
The most recent review of the health 
effects of oxides of nitrogen completed 
by EPA can be found in the 2016 Integrated Science Assessment for Oxides of Nitrogen—Health Criteria (Oxides of Nitrogen ISA).
598The 
primary source of NO 2is motor vehicle 
emissions, and ambient NO 2 
concentrations tend to be highly correlated with other traffic-related pollutants. Thus, a key issue in characterizing the causality of NO
2- 
health effect relationships was evaluating the extent to which studies supported an effect of NO
2that is 
independent of other traffic-related pollutants. EPA concluded that the findings for asthma exacerbation integrated from epidemiologic and controlled human exposure studies provided evidence that is sufficient to infer a causal relationship between respiratory effects and short-term NO
2 
exposure. The strongest evidence supporting an independent effect of NO
2 
exposure comes from controlled human exposure studies demonstrating increased airway responsiveness in individuals with asthma following ambient-relevant NO
2exposures. The 
coherence of this evidence with epidemiologic findings for asthma hospital admissions and ED visits as well as lung function decrements and increased pulmonary inflammation in children with asthma describe a plausible pathway by which NO
2 
exposure can cause an asthma exacerbation. The 2016 ISA for Oxides of Nitrogen also concluded that there is likely to be a causal relationship between long-term NO
2exposure and 
respiratory effects. This conclusion is based on new epidemiologic evidence for associations of NO
2with asthma 
development in children combined with biological plausibility from experimental studies. 
In evaluating a broader range of health 
effects, the 2016 ISA for Oxides of Nitrogen concluded evidence is ‘‘suggestive of, but not sufficient to infer, a causal relationship’’ between 
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599U.S. EPA. (2008). Integrated Science 
Assessment (ISA) for Sulfur Oxides—Health 
Criteria (Final Report). EPA/600/R–08/047F. Washington, DC: U.S. Environmental Protection Agency. 600U.S. EPA, (2010). Integrated Science 
Assessment for Carbon Monoxide (Final Report). 
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–09/019F, 2010. Available at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=218686. See Section 2.1. 
601U.S. EPA, (2010). Integrated Science 
Assessment for Carbon Monoxide (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–09/019F, 2010. Available at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=218686. 
602The ISA evaluates the health evidence 
associated with different health effects, assigning 
one of five ‘‘weight of evidence’’ determinations: causal relationship, likely to be a causal relationship, suggestive of a causal relationship, inadequate to infer a causal relationship, and not likely to be a causal relationship. For definitions of these levels of evidence, please refer to Section 1.6 of the ISA. 
603Personal exposure includes contributions from 
many sources, and in many different environments. Total personal exposure to CO includes both ambient and nonambient components; and both components may contribute to adverse health effects. short-term NO 2exposure and 
cardiovascular effects and mortality and 
between long-term NO 2exposure and 
cardiovascular effects and diabetes, birth outcomes, and cancer. In addition, the scientific evidence is inadequate (insufficient consistency of epidemiologic and toxicological evidence) to infer a causal relationship for long-term NO
2exposure with 
fertility, reproduction, and pregnancy, as well as with postnatal development. A key uncertainty in understanding the relationship between these non- respiratory health effects and short- or long-term exposure to NO
2is 
copollutant confounding, particularly by other roadway pollutants. The available evidence for non-respiratory health effects does not adequately address whether NO
2has an 
independent effect or whether it primarily represents effects related to other or a mixture of traffic-related pollutants. 
The 2016 ISA for Oxides of Nitrogen 
concluded that people with asthma, children, and older adults are at increased risk for NO
2-related health 
effects. In these groups and lifestages, NO
2is consistently related to larger 
effects on outcomes related to asthma exacerbation, for which there is confidence in the relationship with NO
2 
exposure. 
(4) Sulfur Oxides 
(a) Background 
Sulfur dioxide (SO 2), a member of the 
sulfur oxide (SO X) family of gases, is 
formed from burning fuels containing 
sulfur (e.g., coal or oil derived), 
extracting gasoline from oil, or extracting metals from ore. SO
2and its 
gas phase oxidation products can dissolve in water droplets and further oxidize to form sulfuric acid which reacts with ammonia to form sulfates, which are important components of ambient PM. The health effects of ambient PM are discussed in Section VIII.A.1.b of this Preamble. 
(b) Health Effects of SO
2 
Information on the health effects of 
SO 2can be found in the 2008 Integrated 
Science Assessment for Sulfur Oxides— 
Health Criteria (SO XISA).599Short-term 
peaks (5–10 minutes) of SO 2have long 
been known to cause adverse respiratory health effects, particularly among individuals with asthma. In addition to those with asthma (both children and adults), potentially at-risk lifestages 
include all children and the elderly. During periods of elevated ventilation, asthmatics may experience symptomatic bronchoconstriction within minutes of exposure. Following an extensive evaluation of health evidence from epidemiologic and laboratory studies, EPA concluded that there is a causal relationship between respiratory health effects and short-term exposure to SO
2. 
Separately, based on an evaluation of the epidemiologic evidence of associations between short-term exposure to SO
2and mortality, EPA 
concluded that the overall evidence is suggestive of a causal relationship between short-term exposure to SO
2and 
mortality. Additional information on the health effects of SO
2is available in 
Chapter 6.1.1.4.2 of the RIA. 
(5) Carbon Monoxide 
(a) Background 
Carbon monoxide (CO) is a colorless, 
odorless gas emitted from combustion 
processes. Nationally, particularly in urban areas, the majority of CO emissions to ambient air come from mobile sources.
600 
(b) Health Effects of Carbon Monoxide 
Information on the health effects of 
CO can be found in the January 2010 Integrated Science Assessment for Carbon Monoxide (CO ISA).
601The CO 
ISA presents conclusions regarding the presence of causal relationships between CO exposure and categories of adverse health effects.
602This section 
provides a summary of the health effects associated with exposure to ambient concentrations of CO, along with the ISA conclusions.
603 
Controlled human exposure studies of 
subjects with coronary artery disease show a decrease in the time to onset of exercise-induced angina (chest pain) and electrocardiogram changes following CO exposure. In addition, epidemiologic studies observed associations between short-term CO exposure and cardiovascular morbidity, particularly increased emergency room visits and hospital admissions for coronary heart disease (including ischemic heart disease, myocardial infarction, and angina). Some epidemiologic evidence is also available for increased hospital admissions and emergency room visits for congestive heart failure and cardiovascular disease as a whole. The CO ISA concludes that a causal relationship is likely to exist between short-term exposures to CO and cardiovascular morbidity. It also concludes that available data are inadequate to conclude that a causal relationship exists between long-term exposures to CO and cardiovascular morbidity. 
Animal studies show various 
neurological effects with in-utero CO exposure. Controlled human exposure studies report central nervous system and behavioral effects following low- level CO exposures, although the findings have not been consistent across all studies. The CO ISA concludes the evidence is suggestive of a causal relationship with both short- and long- term exposure to CO and central nervous system effects. 
A number of studies cited in the CO 
ISA have evaluated the role of CO exposure in birth outcomes such as preterm birth or cardiac birth defects. There is limited epidemiologic evidence of a CO-induced effect on preterm births and birth defects, with weak evidence for a decrease in birth weight. Animal toxicological studies have found perinatal CO exposure to affect birth weight, as well as other developmental outcomes. The CO ISA concludes the evidence is suggestive of a causal relationship between long-term exposures to CO and developmental effects and birth outcomes. 
Epidemiologic studies provide 
evidence of associations between short- term CO concentrations and respiratory morbidity such as changes in pulmonary function, respiratory symptoms, and hospital admissions. A limited number of epidemiologic 
studies considered copollutants such as ozone, SO
2, and PM in two-pollutant 
models and found that CO risk estimates were generally robust, although this limited evidence makes it difficult to disentangle effects attributed to CO itself from those of the larger complex air pollution mixture. Controlled human exposure studies have not extensively 
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604U.S. EPA. (1999). Guidelines for Carcinogen 
Risk Assessment. Review Draft. NCEA–F–0644, 
July. Washington, DC: U.S. EPA. Retrieved on March 19, 2009 from http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=54932. 
605U.S. EPA (2002). Health Assessment 
Document for Diesel Engine Exhaust. EPA/600/8– 90/057F Office of Research and Development, Washington DC. Retrieved on March 17, 2009 from http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=29060. pp. 1–1 1–2. evaluated the effect of CO on respiratory 
morbidity. Animal studies at levels of 50–100 ppm CO show preliminary evidence of altered pulmonary vascular remodeling and oxidative injury. The CO ISA concludes that the evidence is suggestive of a causal relationship between short-term CO exposure and respiratory morbidity, and inadequate to conclude that a causal relationship exists between long-term exposure and respiratory morbidity. 
Finally, the CO ISA concludes that 
the epidemiologic evidence is suggestive of a causal relationship between short-term concentrations of CO and mortality. Epidemiologic evidence suggests an association exists between short-term exposure to CO and mortality, but limited evidence is available to evaluate cause-specific mortality outcomes associated with CO exposure. In addition, the attenuation of CO risk estimates which was often observed in copollutant models contributes to the uncertainty as to whether CO is acting alone or as an indicator for other combustion-related pollutants. The CO ISA also concludes that there is not likely to be a causal relationship between relevant long-term exposures to CO and mortality. 
(6) Diesel Exhaust 
(a) Background 
Diesel exhaust consists of a complex 
mixture composed of particulate matter, 
carbon dioxide, oxygen, nitrogen, water vapor, carbon monoxide, nitrogen compounds, sulfur compounds and numerous low-molecular-weight hydrocarbons. A number of these gaseous hydrocarbon components are individually known to be toxic, including aldehydes, benzene and 1,3- butadiene. The diesel particulate matter present in diesel exhaust consists mostly of fine particles (<2.5 mm), of which a significant fraction is ultrafine particles (<0.1 mm). These particles have a large surface area which makes them an excellent medium for adsorbing organics, and their small size makes them highly respirable. Many of the organic compounds present in the gases and on the particles, such as polycyclic organic matter, are individually known to have mutagenic and carcinogenic properties. 
Diesel exhaust varies significantly in 
chemical composition and particle sizes between different engine types (heavy- duty, light-duty), engine operating conditions (idle, acceleration, deceleration), and fuel formulations (high/low sulfur fuel). Also, there are emissions differences between on-road and nonroad engines because the nonroad engines are generally of older 
technology. After being emitted in the engine exhaust, diesel exhaust undergoes dilution as well as chemical and physical changes in the atmosphere. The lifetime for some of the compounds present in diesel exhaust ranges from hours to days. 
(b) Health Effects of Diesel Exhaust 
In EPA’s 2002 Diesel Health 
Assessment Document (Diesel HAD), 
exposure to diesel exhaust was classified as likely to be carcinogenic to humans by inhalation from environmental exposures, in accordance with the revised draft 1996/1999 EPA cancer guidelines.
604 605 A number of 
other agencies (National Institute for Occupational Safety and Health, the International Agency for Research on Cancer, the World Health Organization, California EPA, and the U.S. Department of Health and Human Services) had made similar hazard classifications prior to 2002. EPA also concluded in the 2002 Diesel HAD that it was not possible to calculate a cancer unit risk for diesel exhaust due to limitations in the exposure data for the occupational groups or the absence of a dose-response relationship. 
In the absence of a cancer unit risk, 
the Diesel HAD sought to provide additional insight into the significance of the diesel exhaust cancer hazard by estimating possible ranges of risk that might be present in the population. An exploratory analysis was used to characterize a range of possible lung cancer risk. The outcome was that environmental risks of cancer from long- term diesel exhaust exposures could plausibly range from as low as 10
¥5to 
as high as 10¥3. Because of 
uncertainties, the analysis acknowledged that the risks could be lower than 10
¥5, and a zero risk from 
diesel exhaust exposure could not be ruled out. 
Non-cancer health effects of acute and 
chronic exposure to diesel exhaust emissions are also of concern to EPA. EPA derived a diesel exhaust reference concentration (RfC) from consideration 
of four well-conducted chronic rat inhalation studies showing adverse pulmonary effects. The RfC is 5 mg/m
3 
for diesel exhaust measured as diesel particulate matter. This RfC does not 
consider allergenic effects such as those associated with asthma or immunologic or the potential for cardiac effects. There was emerging evidence in 2002, discussed in the Diesel HAD, that exposure to diesel exhaust can exacerbate these effects, but the exposure-response data were lacking at that time to derive an RfC based on these then-emerging considerations. The EPA Diesel HAD states, ‘‘With [diesel particulate matter] being a ubiquitous component of ambient PM, there is an uncertainty about the adequacy of the existing [diesel exhaust] noncancer database to identify all of the pertinent [diesel exhaust]-caused noncancer health hazards.’’ The Diesel HAD also notes ‘‘that acute exposure to [diesel exhaust] has been associated with irritation of the eye, nose, and throat, respiratory symptoms (cough and phlegm), and neurophysiological symptoms such as headache, lightheadedness, nausea, vomiting, and numbness or tingling of the extremities.’’ The Diesel HAD noted that the cancer and noncancer hazard conclusions applied to the general use of diesel engines then on the market and as cleaner engines replace a substantial number of existing ones, the applicability of the conclusions would need to be reevaluated. 
It is important to note that the Diesel 
HAD also briefly summarizes health effects associated with ambient PM and discusses EPA’s then-annual PM
2.5 
NAAQS of 15 mg/m3. In 2012, EPA 
revised the annual PM 2.5NAAQS to 12 
mg/m3. There is a large and extensive 
body of human data showing a wide spectrum of adverse health effects associated with exposure to ambient PM, of which diesel exhaust is an important component. The PM
2.5 
NAAQS is designed to provide protection from the noncancer health effects and premature mortality attributed to exposure to PM
2.5. The 
contribution of diesel PM to total ambient PM varies in different regions of the country and also, within a region, from one area to another. The contribution can be high in near- roadway environments, for example, or in other locations where diesel engine use is concentrated. 
Since 2002, several new studies have 
been published which continue to report increased lung cancer risk with occupational exposure to diesel exhaust from older engines. Of particular note since 2011 are three new epidemiology studies which have examined lung cancer in occupational populations, for 
example, truck drivers, underground nonmetal miners and other diesel 
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606Garshick, Eric, Francine Laden, Jaime E. Hart, 
Mary E. Davis, Ellen A. Eisen, and Thomas J. Smith. 
2012. Lung cancer and elemental carbon exposure in trucking industry workers. Environmental Health Perspectives 120(9): 1301–1306. 
607Silverman, D. T., Samanic, C. M., Lubin, J. H., 
Blair, A. E., Stewart, P. A., Vermeulen, R., & Attfield, M. D. (2012). The diesel exhaust in miners study: A nested case–control study of lung cancer and diesel exhaust. Journal of the National Cancer Institute. 
608Olsson, Ann C., et al. ‘‘Exposure to diesel 
motor exhaust and lung cancer risk in a pooled analysis from case-control studies in Europe and Canada.’’ American journal of respiratory and critical care medicine 183.7 (2011): 941–948. 
609IARC [International Agency for Research on 
Cancer]. (2013). Diesel and gasoline engine exhausts and some nitroarenes. IARC Monographs Volume 105. [Online at http://monographs.iarc.fr/ENG/Monographs/vol105/index.php ]. 
610U.S. EPA. (2015) Summary of Results for the 
2011 National-Scale Assessment. http://www3.epa.gov/sites/production/files/2015-12/
documents/2011-nata-summary-results.pdf . 
611U.S. EPA (2015) 2011 National Air Toxics 
Assessment. http://www3.epa.gov/national-air- 
toxics-assessment/2011-national-air-toxics- 
assessment. 
612U.S. EPA. (2000). Integrated Risk Information 
System File for Benzene. This material is available electronically at: http://www3.epa.gov/iris/subst/ 0276.htm. 
613International Agency for Research on Cancer, 
IARC monographs on the evaluation of carcinogenic risk of chemicals to humans, Volume 29, some industrial chemicals and dyestuffs, International Agency for Research on Cancer, World Health Organization, Lyon, France 1982. 
614Irons, R.D.; Stillman, W.S.; Colagiovanni, D.B.; 
Henry, V.A. (1992). Synergistic action of the benzene metabolite hydroquinone on myelopoietic stimulating activity of granulocyte/macrophage colony-stimulating factor in vitro, Proc. Natl. Acad. Sci. 89:3691–3695. 
615A unit risk estimate is defined as the increase 
in the lifetime risk of an individual who is exposed for a lifetime to 1 mg/m3 benzene in air. 
616U.S. EPA. (2000). Integrated Risk Information 
System File for Benzene. This material is available electronically at: http://www3.epa.gov/iris/subst/ 0276.htm. 
617International Agency for Research on Cancer 
(IARC). (1987). Monographs on the evaluation of carcinogenic risk of chemicals to humans, Volume 29, Supplement 7, Some industrial chemicals and dyestuffs, World Health Organization, Lyon, France. 
618NTP. (2014). 13th Report on Carcinogens. 
Research Triangle Park, NC: U.S. Department of Health and Human Services, Public Health Service, 
National Toxicology Program. 
619Aksoy, M. (1989). Hematotoxicity and 
carcinogenicity of benzene. Environ. Health Perspect. 82: 193–197. 
620Goldstein, B.D. (1988). Benzene toxicity. 
Occupational medicine. State of the Art Reviews. 3: 541–554. 
621Rothman, N., G.L. Li, M. Dosemeci, W.E. 
Bechtold, G.E. Marti, Y.Z. Wang, M. Linet, L.Q. Xi, W. Lu, M.T. Smith, N. Titenko-Holland, L.P. Zhang, W. Blot, S.N. Yin, and R.B. Hayes. (1996). Hematotoxicity among Chinese workers heavily exposed to benzene. Am. J. Ind. Med. 29: 236–246. 
622U.S. EPA. (2002). Toxicological Review of 
Benzene (Noncancer Effects). Environmental Protection Agency, Integrated Risk Information System (IRIS), Research and Development, National Center for Environmental Assessment, Washington DC. This material is available electronically at http://www3.epa.gov/iris/subst/0276.htm . 
623Qu, O.; Shore, R.; Li, G.; Jin, X.; Chen, C.L.; 
Cohen, B.; Melikian, A.; Eastmond, D.; Rappaport, S.; Li, H.; Rupa, D.; Suramaya, R.; Songnian, W.; Huifant, Y.; Meng, M.; Winnik, M.; Kwok, E.; Li, Y.; Mu, R.; Xu, B.; Zhang, X.; Li, K. (2003). HEI Report 115, Validation & Evaluation of Biomarkers in Workers Exposed to Benzene in China. 
624Qu, Q., R. Shore, G. Li, X. Jin, L.C. Chen, B. 
Cohen, et al. (2002). Hematological changes among 
Chinese workers with a broad range of benzene exposures. Am. J. Industr. Med. 42: 275–285. 
625Lan, Qing, Zhang, L., Li, G., Vermeulen, R., et 
al. (2004). Hematotoxically in Workers Exposed to Low Levels of Benzene. Science 306: 1774–1776. 
626Turtletaub, K.W. and Mani, C. (2003). Benzene 
metabolism in rodents at doses relevant to human exposure from Urban Air. Research Reports Health Effect Inst. Report No.113. 
627U.S. Agency for Toxic Substances and Disease 
Registry (ATSDR). (2007). Toxicological profile for benzene. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service. http:// 
www.atsdr.cdc.gov/ToxProfiles/tp3.pdf . 
628A minimal risk level (MRL) is defined as an 
estimate of the daily human exposure to a 
Continued motor-related occupations. These 
studies reported increased risk of lung cancer with exposure to diesel exhaust with evidence of positive exposure- response relationships to varying degrees.
606 607 608 These newer studies 
(along with others that have appeared in the scientific literature) add to the evidence EPA evaluated in the 2002 Diesel HAD and further reinforces the concern that diesel exhaust exposure likely poses a lung cancer hazard. The findings from these newer studies do not necessarily apply to newer technology diesel engines since the newer engines have large reductions in the emission constituents compared to older technology diesel engines. 
In light of the growing body of 
scientific literature evaluating the health effects of exposure to diesel exhaust, in June 2012 the World Health Organization’s International Agency for Research on Cancer (IARC), a recognized international authority on the carcinogenic potential of chemicals and other agents, evaluated the full range of cancer-related health effects data for diesel engine exhaust. IARC concluded that diesel exhaust should be regarded as ‘‘carcinogenic to humans.’’
609This designation was an 
update from its 1988 evaluation that considered the evidence to be indicative of a ‘‘probable human carcinogen.’’ 
(7) Air Toxics 
(a) Background 
Heavy-duty vehicle emissions 
contribute to ambient levels of air toxics 
that are known or suspected human or animal carcinogens, or that have noncancer health effects. The population experiences an elevated risk of cancer and other noncancer health effects from exposure to the class of pollutants known collectively as ‘‘air toxics.’’
610These compounds include, but are not limited to, benzene, 1,3- 
butadiene, formaldehyde, acetaldehyde, acrolein, polycyclic organic matter, and naphthalene. These compounds were identified as national or regional risk drivers or contributors in the 2011 National-scale Air Toxics Assessment and have significant inventory contributions from mobile sources.
611 
(b) Benzene 
EPA’s Integrated Risk Information 
System (IRIS) database lists benzene as a known human carcinogen (causing leukemia) by all routes of exposure, and concludes that exposure is associated with additional health effects, including genetic changes in both humans and animals and increased proliferation of bone marrow cells in mice.
612 613 614 EPA 
states in its IRIS database that data indicate a causal relationship between benzene exposure and acute lymphocytic leukemia and suggest a relationship between benzene exposure and chronic non-lymphocytic leukemia and chronic lymphocytic leukemia. EPA’s IRIS documentation for benzene also lists a range of 2.2 × 10
¥6to 7.8 × 
10¥6per mg/m3as the unit risk estimate 
(URE) for benzene.615 616 The 
International Agency for Research on Cancer (IARC) has determined that benzene is a human carcinogen and the 
U.S. Department of Health and Human Services (DHHS) has characterized benzene as a known human carcinogen.
617 618  A number of adverse noncancer 
health effects including blood disorders, 
such as pre- leukemia and aplastic anemia, have also been associated with long-term exposure to benzene.
619 620  
The most sensitive noncancer effect observed in humans, based on current data, is the depression of the absolute lymphocyte count in blood.
621 622 EPA’s 
inhalation reference concentration (RfC) for benzene is 30 mg/m
3. The RfC is 
based on suppressed absolute lymphocyte counts seen in humans under occupational exposure conditions. In addition, recent work, including studies sponsored by the Health Effects Institute, provides evidence that biochemical responses are occurring at lower levels of benzene exposure than previously known.
623 624 625 626 EPA’s IRIS program 
has not yet evaluated these new data. EPA does not currently have an acute reference concentration for benzene. The Agency for Toxic Substances and Disease Registry (ATSDR) Minimal Risk Level (MRL) for acute exposure to benzene is 29 mg/m
3for 1–14 days 
exposure.627 628  
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hazardous substance that is likely to be without 
appreciable risk of adverse noncancer health effects over a specified duration of exposure. 
629U.S. EPA. (2002). Health Assessment of 1,3- 
Butadiene. Office of Research and Development, National Center for Environmental Assessment, Washington Office, Washington, DC. Report No. EPA600–P–98–001F. This document is available electronically at http://www3.epa.gov/iris/supdocs/ buta-sup.pdf. 
630U.S. EPA. (2002). ‘‘Full IRIS Summary for 1,3- 
butadiene (CASRN 106–99–0)’’ Environmental Protection Agency, Integrated Risk Information System (IRIS), Research and Development, National Center for Environmental Assessment, Washington, DC http://www3.epa.gov/iris/subst/0139.htm . 
631International Agency for Research on Cancer 
(IARC). (1999). Monographs on the evaluation of carcinogenic risk of chemicals to humans, Volume 71, Re-evaluation of some organic chemicals, hydrazine and hydrogen peroxide and Volume 97 (in preparation), World Health Organization, Lyon, France. 
632International Agency for Research on Cancer 
(IARC). (2008). Monographs on the evaluation of carcinogenic risk of chemicals to humans, 1,3- Butadiene, Ethylene Oxide and Vinyl Halides (Vinyl Fluoride, Vinyl Chloride and Vinyl Bromide) Volume 97, World Health Organization, Lyon, France. 
633NTP. (2014). 13th Report on Carcinogens. 
Research Triangle Park, NC: U.S. Department of Health and Human Services, Public Health Service, National Toxicology Program. 
634U.S. EPA. (2002). ‘‘Full IRIS Summary for 1,3- 
butadiene (CASRN 106–99–0)’’ Environmental Protection Agency, Integrated Risk Information System (IRIS), Research and Development, National Center for Environmental Assessment, Washington, DC http://www3.epa.gov/iris/subst/0139.htm. 
635Bevan, C.; Stadler, J.C.; Elliot, G.S.; et al. 
(1996). Subchronic toxicity of 4-vinylcyclohexene in rats and mice by inhalation. Fundam. Appl. Toxicol. 32:1–10. 636EPA. Integrated Risk Information System. 
Formaldehyde (CASRN 50–00–0) http://www3.epa.gov/iris/subst/0419/htm . 
637NTP. (2014). 13th Report on Carcinogens. 
Research Triangle Park, NC: U.S. Department of Health and Human Services, Public Health Service, National Toxicology Program. 
638IARC Monographs on the Evaluation of 
Carcinogenic Risks to Humans Volume 100F (2012): Formaldehyde. 
639Hauptmann, M.; Lubin, J. H.; Stewart, P. A.; 
Hayes, R. B.; Blair, A. 2003. Mortality from lymphohematopoetic malignancies among workers in formaldehyde industries. Journal of the National Cancer Institute 95: 1615–1623. 
640Hauptmann, M.; Lubin, J. H.; Stewart, P. A.; 
Hayes, R. B.; Blair, A. 2004. Mortality from solid cancers among workers in formaldehyde industries. American Journal of Epidemiology 159: 1117–1130. 
641Beane Freeman, L. E.; Blair, A.; Lubin, J. H.; 
Stewart, P. A.; Hayes, R. B.; Hoover, R. N.; Hauptmann, M. 2009. Mortality from lymph hematopoietic malignancies among workers in formaldehyde industries: The National Cancer Institute cohort. J. National Cancer Inst. 101: 751– 761. 
642Pinkerton, L. E. 2004. Mortality among a 
cohort of garment workers exposed to formaldehyde: an update. Occup. Environ. Med. 61: 193–200. 
643Coggon, D, EC Harris, J Poole, KT Palmer. 
2003. Extended follow-up of a cohort of British chemical workers exposed to formaldehyde. J National Cancer Inst. 95:1608–1615. 
644Hauptmann, M,; Stewart P. A.; Lubin J. H.; 
Beane Freeman, L. E.; Hornung, R. W.; Herrick, R. F.; Hoover, R. N.; Fraumeni, J. F.; Hayes, R. B. 2009. Mortality from lymph hematopoietic malignancies and brain cancer among embalmers exposed to formaldehyde. Journal of the National Cancer Institute 101:1696–1708. 
645ATSDR. 1999. Toxicological Profile for 
Formaldehyde, U.S. Department of Health and Human Services (HHS), July 1999. 
646ATSDR. 2010. Addendum to the Toxicological 
Profile for Formaldehyde. U.S. Department of Health and Human Services (HHS), October 2010. 
647IPCS. 2002. Concise International Chemical 
Assessment Document 40. Formaldehyde. World Health Organization. 
648EPA (U.S. Environmental Protection Agency). 
2010. Toxicological Review of Formaldehyde (CAS No. 50–00–0)—Inhalation Assessment: In Support of Summary Information on the Integrated Risk Information System (IRIS). External Review Draft. EPA/635/R–10/002A. U.S. Environmental Protection Agency, Washington DC [online]. Available: http://cfpub.epa.gov/ncea/irs_ drats/
recordisplay.cfm?deid=223614. 
649NRC (National Research Council). 2011. 
Review of the Environmental Protection Agency’s Draft IRIS Assessment of Formaldehyde. Washington DC: National Academies Press. http:// 
books.nap.edu/openbook.php?record_ id=13142. (c) 1,3-Butadiene 
EPA has characterized 1,3-butadiene 
as carcinogenic to humans by 
inhalation.629 630 The IARC has 
determined that 1,3-butadiene is a human carcinogen and the U.S. DHHS has characterized 1,3-butadiene as a known human carcinogen.
631 632 633  
There are numerous studies consistently demonstrating that 1,3-butadiene is metabolized into genotoxic metabolites by experimental animals and humans. The specific mechanisms of 1,3- butadiene-induced carcinogenesis are unknown; however, the scientific evidence strongly suggests that the carcinogenic effects are mediated by genotoxic metabolites. Animal data suggest that females may be more 
sensitive than males for cancer effects associated with 1,3-butadiene exposure; there are insufficient data in humans from which to draw conclusions about sensitive subpopulations. The URE for 1,3-butadiene is 3 × 10
¥5per mg/m3.634 
1,3-butadiene also causes a variety of reproductive and developmental effects in mice; no human data on these effects are available. The most sensitive effect was ovarian atrophy observed in a lifetime bioassay of female mice.
635 Based on this critical effect and the benchmark concentration methodology, an RfC for chronic health effects was calculated at 0.9 ppb (approximately 2 mg/m
3). 
(d) Formaldehyde 
In 1991, EPA concluded that 
formaldehyde is a carcinogen based on nasal tumors in animal bioassays.
636An 
Inhalation URE for cancer and a Reference Dose for oral noncancer effects were developed by the agency and posted on the IRIS database. Since that time, the National Toxicology Program (NTP) and International Agency for Research on Cancer (IARC) have concluded that formaldehyde is a known human carcinogen.
637 638  
The conclusions by IARC and NTP 
reflect the results of epidemiologic research published since 1991 in combination with previous animal, human and mechanistic evidence. Research conducted by the National Cancer Institute reported an increased risk of nasopharyngeal cancer and specific lymph hematopoietic malignancies among workers exposed to formaldehyde.
639 640 641 A National 
Institute of Occupational Safety and Health study of garment workers also reported increased risk of death due to leukemia among workers exposed to formaldehyde.
642Extended follow-up of 
a cohort of British chemical workers did not report evidence of an increase in nasopharyngeal or lymph hematopoietic cancers, but a continuing statistically significant excess in lung cancers was reported.
643Finally, a study of embalmers reported formaldehyde 
exposures to be associated with an increased risk of myeloid leukemia but not brain cancer.
644 
Health effects of formaldehyde in 
addition to cancer were reviewed by the Agency for Toxics Substances and Disease Registry in 1999
645, 
supplemented in 2010,646and by the 
World Health Organization.647These 
organizations reviewed the scientific 
literature concerning health effects linked to formaldehyde exposure to evaluate hazards and dose response relationships and defined exposure concentrations for minimal risk levels (MRLs). The health endpoints reviewed included sensory irritation of eyes and respiratory tract, reduced pulmonary function, nasal histopathology, and immune system effects. In addition, research on reproductive and developmental effects and neurological effects were discussed along with several studies that suggest that formaldehyde may increase the risk of asthma—particularly in the young. 
EPA released a draft Toxicological 
Review of Formaldehyde—Inhalation Assessment through the IRIS program for peer review by the National Research Council (NRC) and public comment in June 2010.
648The draft assessment 
reviewed more recent research from animal and human studies on cancer and other health effects. The NRC released their review report in April 2011.
649EPA is currently developing a 
revised draft assessment in response to this review. 
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650U.S. EPA (1991). Integrated Risk Information 
System File of Acetaldehyde. Research and 
Development, National Center for Environmental Assessment, Washington, DC. This material is available electronically at http://www3.epa.gov/iris/ 
subst/0290.htm. 
651U.S. EPA (1991). Integrated Risk Information 
System File of Acetaldehyde. This material is available electronically at http://www3.epa.gov/iris/ 
subst/0290.htm. 
652NTP. (2014). 13th Report on Carcinogens. 
Research Triangle Park, NC: U.S. Department of Health and Human Services, Public Health Service, National Toxicology Program. 
653International Agency for Research on Cancer 
(IARC). (1999). Re-evaluation of some organic chemicals, hydrazine, and hydrogen peroxide. IARC Monographs on the Evaluation of Carcinogenic Risk of Chemical to Humans, Vol 71. Lyon, France. 
654U.S. EPA (1991). Integrated Risk Information 
System File of Acetaldehyde. This material is available electronically at http://www3.epa.gov/iris/ 
subst/0290.htm. 
655U.S. EPA. (2003). Integrated Risk Information 
System File of Acrolein. Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available electronically at http://www3.epa.gov/iris/ 
subst/0364.htm. 
656Appleman, L.M., R.A. Woutersen, and V.J. 
Feron. (1982). Inhalation toxicity of acetaldehyde in rats. I. Acute and subacute studies. Toxicology. 23: 293–297. 
657Myou, S.; Fujimura, M.; Nishi K.; Ohka, T.; 
and Matsuda, T. (1993) Aerosolized acetaldehyde induces histamine-mediated bronchoconstriction in asthmatics. Am. Rev. Respir. Dis. 148(4 Pt 1): 940– 943. 658U.S. EPA. (2003). Integrated Risk Information 
System File of Acrolein. Research and 
Development, National Center for Environmental Assessment, Washington, DC. This material is available at http://www3.epa.gov/iris/subst/0364.htm. 
659International Agency for Research on Cancer 
(IARC). (1995). Monographs on the evaluation of carcinogenic risk of chemicals to humans, Volume 63. Dry cleaning, some chlorinated solvents and other industrial chemicals, World Health Organization, Lyon, France. 
660U.S. EPA. (2003). Integrated Risk Information 
System File of Acrolein. Office of Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available at http://www3.epa.gov/iris/subst/ 0364.htm. 
661U.S. EPA. (2003). Integrated Risk Information 
System File of Acrolein. Office of Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available at http://www3.epa.gov/iris/subst/ 0364.htm. 
662U.S. EPA. (2003) Toxicological review of 
acrolein in support of summary information on Integrated Risk Information System (IRIS) National Center for Environmental Assessment, Washington, DC. EPA/635/R–03/003. p. 10. Available online at: http://www3.epa.gov/ncea/iris/toxreviews/0364tr.pdf. 
663U.S. EPA. (2003) Toxicological review of 
acrolein in support of summary information on Integrated Risk Information System (IRIS) National Center for Environmental Assessment, Washington, DC. EPA/635/R–03/003. Available online at: http:// 
www3.epa.gov/ncea/iris/toxreviews/0364tr.pdf . 664Morris JB, Symanowicz PT, Olsen JE, et al. 
(2003). Immediate sensory nerve-mediated respiratory responses to irritants in healthy and allergic airway-diseased mice. J Appl Physiol 94(4):1563–1571. 
665U.S. EPA. (2009). Graphical Arrays of 
Chemical-Specific Health Effect Reference Values for Inhalation Exposures (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–09/061, 2009. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=211003 . 
666Agency for Toxic Substances and Disease 
Registry (ATSDR). (1995). Toxicological profile for Polycyclic Aromatic Hydrocarbons (PAHs). Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service. Available electronically at http://www.atsdr.cdc.gov/ToxProfiles/TP.asp?id=122&tid=25. 
667U.S. EPA (2002). Health Assessment 
Document for Diesel Engine Exhaust. EPA/600/8– 90/057F Office of Research and Development, Washington DC. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=29060. (e) Acetaldehyde 
Acetaldehyde is classified in EPA’s 
IRIS database as a probable human 
carcinogen, based on nasal tumors in rats, and is considered toxic by the inhalation, oral, and intravenous routes.
650The URE in IRIS for 
acetaldehyde is 2.2 × 10¥6per mg/m3.651 
Acetaldehyde is reasonably anticipated to be a human carcinogen by the U.S. DHHS in the 13th Report on Carcinogens and is classified as possibly carcinogenic to humans (Group 2B) by the IARC.
652 653 Acetaldehyde is 
currently listed on the IRIS Program Multi-Year Agenda for reassessment within the next few years. 
The primary noncancer effects of 
exposure to acetaldehyde vapors include irritation of the eyes, skin, and respiratory tract.
654In short-term (4 
week) rat studies, degeneration of olfactory epithelium was observed at various concentration levels of acetaldehyde exposure.
655 656 Data from 
these studies were used by EPA to develop an inhalation reference concentration of 9 mg/m
3. Some 
asthmatics have been shown to be a sensitive subpopulation to decrements in functional expiratory volume (FEV1 test) and bronchoconstriction upon acetaldehyde inhalation.
657 
(f) Acrolein 
EPA most recently evaluated the 
toxicological and health effects literature related to acrolein in 2003 and 
concluded that the human carcinogenic potential of acrolein could not be determined because the available data were inadequate. No information was available on the carcinogenic effects of acrolein in humans and the animal data provided inadequate evidence of carcinogenicity.
658The IARC 
determined in 1995 that acrolein was not classifiable as to its carcinogenicity in humans.
659 
Lesions to the lungs and upper 
respiratory tract of rats, rabbits, and hamsters have been observed after subchronic exposure to acrolein.
660The 
agency has developed an RfC for acrolein of 0.02 mg/m
3and an RfD of 0.5 
mg/kg-day.661 
Acrolein is extremely acrid and 
irritating to humans when inhaled, with acute exposure resulting in upper respiratory tract irritation, mucus hypersecretion and congestion. The intense irritancy of this carbonyl has been demonstrated during controlled tests in human subjects, who suffer intolerable eye and nasal mucosal sensory reactions within minutes of exposure.
662These data and additional 
studies regarding acute effects of human exposure to acrolein are summarized in EPA’s 2003 Toxicological Review of Acrolein.
663Studies in humans indicate 
that levels as low as 0.09 ppm (0.21 mg/ m
3) for five minutes may elicit 
subjective complaints of eye irritation with increasing concentrations leading 
to more extensive eye, nose and respiratory symptoms. Acute exposures in animal studies report bronchial hyper-responsiveness. Based on animal data (more pronounced respiratory irritancy in mice with allergic airway disease in comparison to non-diseased mice)
664and demonstration of similar 
effects in humans (e.g., reduction in 
respiratory rate), individuals with compromised respiratory function (e.g., emphysema, asthma) are expected to be at increased risk of developing adverse responses to strong respiratory irritants such as acrolein. EPA does not currently have an acute reference concentration for acrolein. The available health effect reference values for acrolein have been summarized by EPA and include an ATSDR MRL for acute exposure to acrolein of 7 mg/m
3for 1–14 days 
exposure; and Reference Exposure Level (REL) values from the California Office of Environmental Health Hazard Assessment (OEHHA) for one-hour and 8-hour exposures of 2.5 mg/m
3and 0.7 
mg/m3, respectively.665 
(g) Polycyclic Organic Matter 
The term polycyclic organic matter 
(POM) defines a broad class of compounds that includes the polycyclic aromatic hydrocarbon compounds (PAHs). One of these compounds, naphthalene, is discussed separately below. POM compounds are formed primarily from combustion and are present in the atmosphere in gas and particulate form. Cancer is the major concern from exposure to POM. Epidemiologic studies have reported an increase in lung cancer in humans exposed to diesel exhaust, coke oven emissions, roofing tar emissions, and cigarette smoke; all of these mixtures contain POM compounds.
666 667 Animal 
studies have reported respiratory tract tumors from inhalation exposure to 
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668International Agency for Research on Cancer 
(IARC). (2012). Monographs on the Evaluation of 
the Carcinogenic Risk of Chemicals for Humans, Chemical Agents and Related Occupations. Vol. 100F. Lyon, France. 
669U.S. EPA (1997). Integrated Risk Information 
System File of indeno (1,2,3-cd) pyrene. Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available electronically at http://www3.epa.gov/ncea/iris/subst/0457.htm . 
670Perera, F.P.; Rauh, V.; Tsai, W–Y.; et al. (2002). 
Effect of transplacental exposure to environmental pollutants on birth outcomes in a multiethnic population. Environ Health Perspect. 111: 201–205. 
671Perera, F.P.; Rauh, V.; Whyatt, R.M.; Tsai, 
W.Y.; Tang, D.; Diaz, D.; Hoepner, L.; Barr, D.; Tu, Y.H.; Camann, D.; Kinney, P. (2006). Effect of prenatal exposure to airborne polycyclic aromatic hydrocarbons on neurodevelopment in the first 3 years of life among inner-city children. Environ Health Perspect 114: 1287–1292. 
672U. S. EPA. 1998. Toxicological Review of 
Naphthalene (Reassessment of the Inhalation Cancer Risk), Environmental Protection Agency, Integrated Risk Information System, Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available electronically at http://www3.epa.gov/iris/ 
subst/0436.htm. 
673U. S. EPA. 1998. Toxicological Review of 
Naphthalene (Reassessment of the Inhalation 
Cancer Risk), Environmental Protection Agency, Integrated Risk Information System, Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available electronically at http://www3.epa.gov/iris/ 
subst/0436.htm. 
674U. S. EPA. (1998). Toxicological Review of 
Naphthalene (Reassessment of the Inhalation Cancer Risk), Environmental Protection Agency, Integrated Risk Information System, Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available electronically at http://www3.epa.gov/iris/ 
subst/0436.htm. 
675Oak Ridge Institute for Science and Education. 
(2004). External Peer Review for the IRIS Reassessment of the Inhalation Carcinogenicity of Naphthalene. August 2004. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=84403 . 
676NTP. (2014). 13th Report on Carcinogens. U.S. 
Department of Health and Human Services, Public Health Service, National Toxicology Program. 
677International Agency for Research on Cancer 
(IARC). (2002). Monographs on the Evaluation of the Carcinogenic Risk of Chemicals for Humans. Vol. 82. Lyon, France. 
678U. S. EPA. (1998). Toxicological Review of 
Naphthalene, Environmental Protection Agency, Integrated Risk Information System, Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available electronically at http://www3.epa.gov/iris/ 
subst/0436.htm. 
679U.S. EPA. (1998). Toxicological Review of 
Naphthalene. Environmental Protection Agency, Integrated Risk Information System (IRIS), Research and Development, National Center for Environmental Assessment, Washington, DC http:// 
www3.epa.gov/iris/subst/0436.htm. 680U.S. EPA Integrated Risk Information System 
(IRIS) database is available at: www3.epa.gov/iris. 
681Karner, A.A.; Eisinger, D.S.; Niemeier, D.A. 
(2010). Near-roadway air quality: synthesizing the findings from real-world data. Environ Sci Technol 44: 5334–5344. benzo[a]pyrene and alimentary tract and 
liver tumors from oral exposure to benzo[a]pyrene.
668In 1997 EPA 
classified seven PAHs (benzo[a]pyrene, benz[a]anthracene, chrysene, benzo[b]fluoranthene, benzo[k]fluoranthene, dibenz[a,h]anthracene, and indeno[1,2,3-cd]pyrene) as Group B2, probable human carcinogens.
669Since 
that time, studies have found that maternal exposures to PAHs in a population of pregnant women were associated with several adverse birth outcomes, including low birth weight and reduced length at birth, as well as impaired cognitive development in preschool children (3 years of age).
670 671  
These and similar studies are being evaluated as a part of the ongoing IRIS reassessment of health effects associated with exposure to benzo[a]pyrene. 
(h) Naphthalene 
Naphthalene is found in small 
quantities in gasoline and diesel fuels. 
Naphthalene emissions have been measured in larger quantities in both gasoline and diesel exhaust compared with evaporative emissions from mobile sources, indicating it is primarily a product of combustion. Acute (short- term) exposure of humans to naphthalene by inhalation, ingestion, or dermal contact is associated with hemolytic anemia and damage to the liver and the nervous system.
672 
Chronic (long term) exposure of workers and rodents to naphthalene has been reported to cause cataracts and retinal damage.
673EPA released an external review draft of a reassessment of the 
inhalation carcinogenicity of naphthalene based on a number of recent animal carcinogenicity studies.
674The draft reassessment 
completed external peer review.675 
Based on external peer review comments received, a revised draft assessment that considers all routes of exposure, as well as cancer and noncancer effects, is under development. The external review draft does not represent official agency opinion and was released solely for the purposes of external peer review and public comment. The National Toxicology Program listed naphthalene as ‘‘reasonably anticipated to be a human carcinogen’’ in 2004 on the basis of bioassays reporting clear evidence of carcinogenicity in rats and some evidence of carcinogenicity in mice.
676 
California EPA has released a new risk assessment for naphthalene, and the IARC has reevaluated naphthalene and re-classified it as Group 2B: possibly carcinogenic to humans.
677 
Naphthalene also causes a number of 
chronic non-cancer effects in animals, including abnormal cell changes and growth in respiratory and nasal tissues.
678The current EPA IRIS 
assessment includes noncancer data on hyperplasia and metaplasia in nasal tissue that form the basis of the inhalation RfC of 3 mg/m
3.679The ATSDR MRL for acute exposure to 
naphthalene is 0.6 mg/kg/day. 
(i) Other Air Toxics 
In addition to the compounds 
described above, other compounds in 
gaseous hydrocarbon and PM emissions from motor vehicles will be affected by this action. Mobile source air toxic compounds that will potentially be impacted include ethylbenzene, propionaldehyde, toluene, and xylene. Information regarding the health effects of these compounds can be found in EPA’s IRIS database.
680 
(8) Exposure and Health Effects Associated With Traffic 
Locations in close proximity to major 
roadways generally have elevated concentrations of many air pollutants emitted from motor vehicles. Hundreds of such studies have been published in peer-reviewed journals, concluding that concentrations of CO, NO, NO
2, 
benzene, aldehydes, particulate matter, black carbon, and many other compounds are elevated in ambient air within approximately 300–600 meters (about 1,000–2,000 feet) of major roadways. Highest concentrations of most pollutants emitted directly by motor vehicles are found at locations within 50 meters (about 165 feet) of the edge of a roadway’s traffic lanes. 
A large-scale review of air quality 
measurements in the vicinity of major 
roadways between 1978 and 2008 concluded that the pollutants with the steepest concentration gradients in vicinities of roadways were CO, ultrafine particles, metals, elemental carbon (EC), NO, NO
X, and several 
VOCs.681These pollutants showed a 
large reduction in concentrations within 100 meters downwind of the roadway. Pollutants that showed more gradual reductions with distance from roadways included benzene, NO
2, PM 2.5, and 
PM 10. In the review article, results 
varied based on the method of statistical analysis used to determine the trend. 
For pollutants with relatively high 
background concentrations relative to near-road concentrations, detecting concentration gradients can be difficult. For example, many aldehydes have high background concentrations as a result of photochemical breakdown of precursors from many different organic compounds. This can make detection of gradients around roadways and other primary emission sources difficult. 
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682Liu, W.; Zhang, J.; Kwon, J.L.; et al. (2006). 
Concentrations and source characteristics of 
airborne carbonyl comlbs measured outside urban residences. J Air Waste Manage Assoc 56: 1196– 1204. 
683Cahill, T.M.; Charles, M.J.; Seaman, V.Y. 
(2010). Development and application of a sensitive method to determine concentrations of acrolein and other carbonyls in ambient air. Health Effects Institute Research Report 149.Available at http://
dx.doi.org. 
684In the widely-used PubMed database of health 
publications, between January 1, 1990 and August 18, 2011, 605 publications contained the keywords ‘‘traffic, pollution, epidemiology,’’ with approximately half the studies published after 2007. 
685Laden, F.; Hart, J.E.; Smith, T.J.; Davis, M.E.; 
Garshick, E. (2007) Cause-specific mortality in the unionized U.S. trucking industry. Environmental Health Perspect 115:1192–1196. 
686Peters, A.; von Klot, S.; Heier, M.; 
Trentinaglia, I.; Ho ¨rmann, A.; Wichmann, H.E.; 
Lo¨wel, H. (2004) Exposure to traffic and the onset 
of myocardial infarction. New England J Med 351: 1721–1730. 
687Zanobetti, A.; Stone, P.H.; Spelzer, F.E.; 
Schwartz, J.D.; Coull, B.A.; Suh, H.H.; Nearling, B.D.; Mittleman, M.A.; Verrier, R.L.; Gold, D.R. (2009) T-wave alternans, air pollution and traffic in high-risk subjects. Am J Cardiol 104: 665–670. 
688Dubowsky Adar, S.; Adamkiewicz, G.; Gold, 
D.R.; Schwartz, J.; Coull, B.A.; Suh, H. (2007) Ambient and microenvironmental particles and exhaled nitric oxide before and after a group bus trip. Environ Health Perspect 115: 507–512. 
689Health Effects Institute Panel on the Health 
Effects of Traffic-Related Air Pollution. (2010). Traffic-related air pollution: a critical review of the literature on emissions, exposure, and health effects. HEI Special Report 17. Available at http:// 
www.healtheffects.org. 690Boothe, V.L.; Shendell, D.G. (2008). Potential 
health effects associated with residential proximity to freeways and primary roads: review of scientific literature, 1999–2006. J Environ Health 70: 33–41. 
691Salam, M.T.; Islam, T.; Gilliland, F.D. (2008). 
Recent evidence for adverse effects of residential proximity to traffic sources on asthma. Curr Opin Pulm Med 14: 3–8. 
692Sun, X.; Zhang, S.; Ma, X. (2014) No 
association between traffic density and risk of childhood leukemia: a meta-analysis. Asia Pac J Cancer Prev 15: 5229–5232. 
693Raaschou-Nielsen, O.; Reynolds, P. (2006). Air 
pollution and childhood cancer: a review of the epidemiological literature. Int J Cancer 118: 2920– 9. 
694Boothe, VL.; Boehmer, T.K.; Wendel, A.M.; 
Yip, F.Y. (2014) Residential traffic exposure and childhood leukemia: a systematic review and meta- analysis. Am J Prev Med 46: 413–422. 
695Volk, H.E.; Hertz-Picciotto, I.; Delwiche, L.; et 
al. (2011). Residential proximity to freeways and autism in the CHARGE study. Environ Health Perspect 119: 873–877. 696Franco-Suglia, S.; Gryparis, A.; Wright, R.O.; 
et al. (2007). Association of black carbon with 
cognition among children in a prospective birth cohort study. Am J Epidemiol. doi: 10.1093/aje/ kwm308. [Online at http://dx.doi.org]. 
697Power, M.C.; Weisskopf, M.G.; Alexeef, SE.; et 
al. (2011). Traffic-related air pollution and cognitive function in a cohort of older men. Environ Health Perspect 2011: 682–687. 
698Wu, J.; Wilhelm, M.; Chung, J.; et al. (2011). 
Comparing exposure assessment methods for traffic- related air pollution in and adverse pregnancy outcome study. Environ Res 111: 685–6692. 
699Riediker, M. (2007). Cardiovascular effects of 
fine particulate matter components in highway 
patrol officers. Inhal Toxicol 19: 99–105. doi: 10.1080/08958370701495238 Available at http://dx.doi.org. 
700Alexeef, SE.; Coull, B.A.; Gryparis, A.; et al. 
(2011). Medium-term exposure to traffic-related air pollution and markers of inflammation and endothelial function. Environ Health Perspect 119: 481–486. doi:10.1289/ehp.1002560 Available at http://dx.doi.org. 
701Eckel. S.P.; Berhane, K.; Salam, M.T.; et al. 
(2011). Traffic-related pollution exposure and exhaled nitric oxide in the Children’s Health Study. Environ Health Perspect (IN PRESS). doi:10.1289/ ehp.1103516. Available at http://dx.doi.org. 
702Zhang, J.; McCreanor, J.E.; Cullinan, P.; et al. 
(2009). Health effects of real-world exposure diesel exhaust in persons with asthma. Res Rep Health Effects Inst 138. [Online at http://www.healtheffects.org]. 
703Adar, S.D.; Klein, R.; Klein, E.K.; et al. (2010). 
Air pollution and the microvasculatory: a cross- sectional assessment of in vivo retinal images in the population-based Multi-Ethnic Study of Atherosclerosis. PLoS Med 7(11): E1000372. doi:10.1371/journal.pmed.1000372. Available at http://dx.doi.org. 
704Kan, H.; Heiss, G.; Rose, K.M.; et al. (2008). 
Prospective analysis of traffic exposure as a risk factor for incident coronary heart disease: the Atherosclerosis Risk in Communities (ARIC) study. Environ Health Perspect 116: 1463–1468. doi:10.1289/ehp.11290. Available at http://dx.doi.org. 
705McConnell, R.; Islam, T.; Shankardass, K.; et 
al. (2010). Childhood incident asthma and traffic- related air pollution at home and school. Environ Health Perspect 1021–1026. 
706Islam, T.; Urban, R.; Gauderman, W.J.; et al. 
(2011). Parental stress increases the detrimental 
Continued However, several studies have measured 
aldehydes in multiple weather conditions and found higher concentrations of many carbonyls downwind of roadways.
682 683 These 
findings suggest a substantial roadway source of these carbonyls. 
In the past 15 years, many studies 
have been published with results reporting that populations who live, work, or go to school near high-traffic roadways experience higher rates of numerous adverse health effects, compared to populations far away from major roads.
684In addition, numerous 
studies have found adverse health effects associated with spending time in traffic, such as commuting or walking along high-traffic roadways.
685 686 687 688  
The health outcomes with the strongest evidence linking them with traffic- associated air pollutants are respiratory effects, particularly in asthmatic children, and cardiovascular effects. 
Numerous reviews of this body of 
health literature have been published as well. In 2010, an expert panel of the Health Effects Institute (HEI) published a review of hundreds of exposure, epidemiology, and toxicology studies.
689The panel rated how the 
evidence for each type of health 
outcome supported a conclusion of a causal association with traffic- associated air pollution as either 
‘‘sufficient,’’ ‘‘suggestive but not sufficient,’’ or ‘‘inadequate and insufficient.’’ The panel categorized evidence of a causal association for exacerbation of childhood asthma as ‘‘sufficient.’’ The panel categorized evidence of a causal association for new onset asthma as between ‘‘sufficient’’ 
and ‘‘suggestive but not sufficient.’’ ‘‘Suggestive of a causal association’’ was how the panel categorized evidence linking traffic-associated air pollutants with exacerbation of adult respiratory symptoms and lung function decrement. It categorized as ‘‘inadequate and insufficient’’ evidence of a causal relationship between traffic-related air pollution and health care utilization for respiratory problems, new onset adult asthma, chronic obstructive pulmonary disease (COPD), nonasthmatic respiratory allergy, and cancer in adults and children. Other literature reviews have been published with conclusions generally similar to the HEI panel’s.
690 691 692 693 However, in 2014, 
researchers from the U.S. Centers for Disease Control and Prevention (CDC) published a systematic review and meta-analysis of studies evaluating the risk of childhood leukemia associated with traffic exposure and reported positive associations between ‘‘postnatal’’ proximity to traffic and leukemia risks, but no such association for ‘‘prenatal’’ exposures.
694 
Health outcomes with few 
publications suggest the possibility of other effects still lacking sufficient evidence to draw definitive conclusions. Among these outcomes with a small number of positive studies are neurological impacts (e.g., autism and 
reduced cognitive function) and reproductive outcomes (e.g., preterm 
birth, low birth weight).
695 696 697 698  In addition to health outcomes, 
particularly cardiopulmonary effects, 
conclusions of numerous studies suggest mechanisms by which traffic- related air pollution affects health. Numerous studies indicate that near- roadway exposures may increase systemic inflammation, affecting organ systems, including blood vessels and lungs.
699 700 701 702 Long-term exposures 
in near-road environments have been associated with inflammation-associated conditions, such as atherosclerosis and asthma.
703 704 705  
Several studies suggest that some 
factors may increase susceptibility to the effects of traffic-associated air pollution. Several studies have found stronger respiratory associations in children experiencing chronic social stress, such as in violent neighborhoods or in homes with high family stress.
706 707 708  
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effect of traffic exposure on children’s lung 
function. Am J Respir Crit Care Med (In press). 
707Clougherty, J.E.; Levy, J.I.; Kubzansky, L.D.; et 
al. (2007). Synergistic effects of traffic-related air pollution and exposure to violence on urban asthma etiology. Environ Health Perspect 115: 1140–1146. 
708Chen, E.; Schrier, H.M.; Strunk, R.C.; et al. 
(2008). Chronic traffic-related air pollution and stress interact to predict biologic and clinical outcomes in asthma. Environ Health Perspect 116: 970–5. 
709Rowangould, G.M. (2013) A census of the U.S. 
near-roadway population: public health and environmental justice considerations. Transportation Research Part D 25: 59–67. 
710Boehmer, T.K.; Foster, S.L.; Henry, J.R.; 
Woghiren-Akinnifesi, E.L.; Yip, F.Y. (2013) Residential proximity to major highways—United States, 2010. Morbidity and Mortality Weekly Report 62(3); 46–50. 
711http://www.cdc.gov/asthma/most_ recent_
data.htm. 712Marshall, J.D. (2008) Environmental 
inequality: air pollution exposures in California’s 
South Coast Air Basin. 
713Su, J.G.; Larson, T.; Gould, T.; Cohen, M.; 
Buzzelli, M. (2010) Transboundary air pollution and environmental justice: Vancouver and Seattle compared. GeoJournal 57: 595–608. doi:10.1007/ s10708–009–9269–6 [Online at http://dx.doi.org]. 
714Chakraborty, J.; Zandbergen, P.A. (2007) 
Children at risk: measuring racial/ethnic disparities in potential exposure to air pollution at school and home. J Epidemiol Community Health 61: 1074– 1079. doi: 10.1136/jech.2006.054130 [Online at http://dx.doi.org]. 
715Green, R.S.; Smorodinsky, S.; Kim, J.J.; 
McLaughlin, R.; Ostro, B. (2003) Proximity of California public schools to busy roads. Environ Health Perspect 112: 61–66. doi:10.1289/ehp.6566 [http://dx.doi.org]. 
716Wu, Y; Batterman, S.A. (2006) Proximity of 
schools in Detroit, Michigan to automobile and truck traffic. J Exposure Sci & Environ Epidemiol. doi:10.1038/sj.jes.7500484 [Online at http://dx.doi.org]. 
717Su, J.G.; Jerrett, M.; de Nazelle, A.; Wolch, J. 
(2011) Does exposure to air pollution in urban parks have socioeconomic, racial, or ethnic gradients? Environ Res 111: 319–328. 
718Depro, B.; Timmins, C. (2008) Mobility and 
environmental equity: do housing choices determine exposure to air pollution? North Caroline State University Center for Environmental and Resource Economic Policy. 
719Clougherty, J.E.; Kubzansky, L.D. (2009) A 
framework for examining social stress and susceptibility to air pollution in respiratory health. Environ Health Perspect 117: 1351–1358. Doi:10.1289/ehp.0900612 [Online at http://dx.doi.org]. 
720Clougherty, J.E.; Levy, J.I.; Kubzansky, L.D.; 
Ryan, P.B.; Franco Suglia, S.; Jacobson Canner, M.; Wright, R.J. (2007) Synergistic effects of traffic- related air pollution and exposure to violence on urban asthma etiology. Environ Health Perspect 
115: 1140–1146. doi:10.1289/ehp.9863 [Online at http://dx.doi.org]. 
721Finkelstein, M.M.; Jerrett, M.; DeLuca, P.; 
Finkelstein, N.; Verma, D.K.; Chapman, K.; Sears, The risks associated with residence, 
workplace, or schools near major roads 
are of potentially high public health significance due to the large population in such locations. According to the 2009 American Housing Survey, over 22 million homes (17.0 percent of all U.S. housing units) were located within 300 feet of an airport, railroad, or highway with four or more lanes. This corresponds to a population of more than 50 million U.S. residents in close proximity to high-traffic roadways or other transportation sources. Based on 2010 Census data, a 2013 publication estimated that 19 percent of the U.S. population (over 59 million people) lived within 500 meters of roads with at least 25,000 annual average daily traffic (AADT), while about 3.2 percent of the population lived within 100 meters (about 300 feet) of such roads.
709 
Another 2013 study estimated that 3.7 percent of the U.S. population (about 11.3 million people) lived within 150 meters (about 500 feet) of interstate highways or other freeways and expressways.
710As discussed in Section 
VIII.A.(9), on average, populations near 
major roads have higher fractions of minority residents and lower socioeconomic status. Furthermore, on average, Americans spend more than an hour traveling each day, bringing nearly all residents into a high-exposure microenvironment for part of the day. 
In light of these concerns, EPA has 
required through the NAAQS process that air quality monitors be placed near high-traffic roadways for determining concentrations of CO, NO
2, and PM 2.5 
(in addition to those existing monitors located in neighborhoods and other locations farther away from pollution sources). Near-roadway monitors for NO
2begin operation between 2014 and 
2017 in Core Based Statistical Areas (CBSAs) with population of at least 500,000. Monitors for CO and PM
2.5 
begin operation between 2015 and 2017. These monitors will further our understanding of exposure in these 
locations. 
EPA and DOT continue to research 
near-road air quality, including the types of pollutants found in high concentrations near major roads and health problems associated with the mixture of pollutants near roads. 
(9) Environmental Justice 
Environmental justice (EJ) is a 
principle asserting that all people 
deserve fair treatment and meaningful involvement with respect to environmental laws, regulations, and policies. EPA seeks to provide the same 
degree of protection from environmental health hazards for all people. DOT shares this goal and is informed about the potential environmental impacts of its rulemakings through its NEPA process (see NHTSA’s DEIS). As referenced below, numerous studies have found that some environmental hazards are more prevalent in areas where racial/ethnic minorities and people with low socioeconomic status (SES) represent a higher fraction of the population compared with the general population. In addition, compared to non-Hispanic whites, some types of minorities may have greater levels of health problems during some life stages. For example, in 2014, about 13 percent of Black, non-Hispanic and 24 percent of Puerto Rican children were estimated to currently have asthma, compared with 8 percent of white, non-Hispanic children.
711 
As discussed in Section VIII.A.(8) of 
this document and NHTSA’s FEIS, concentrations of many air pollutants are elevated near high-traffic roadways. If minority populations and low-income populations disproportionately live near such roads, then an issue of EJ may be present. We reviewed existing scholarly literature examining the potential for disproportionate exposure among minorities and people with low SES, and we conducted our own evaluation of two national datasets: The U.S. Census Bureau’s American Housing Survey for calendar year 2009 and the U.S. Department of Education’s database of school locations. 
Publications that address EJ issues 
generally report that populations living near major roadways (and other types of transportation infrastructure) tend to be composed of larger fractions of nonwhite residents. People living in neighborhoods near such sources of air pollution also tend to be lower in income than people living elsewhere. Numerous studies evaluating the demographics and socioeconomic status 
of populations or schools near roadways have found that they include a greater percentage of minority residents, as well as lower SES (indicated by variables such as median household income). Locations in these studies include Los Angeles, CA; Seattle, WA; Wayne County, MI; Orange County, FL; and the State of California 
712 713 714 715 716 717  
Such disparities may be due to multiple factors.
718 
People with low SES often live in 
neighborhoods with multiple stressors and health risk factors, including reduced health insurance coverage rates, higher smoking and drug use rates, limited access to fresh food, visible neighborhood violence, and elevated rates of obesity and some diseases such as asthma, diabetes, and ischemic heart disease. Although questions remain, several studies find stronger associations between air pollution and health in locations with such chronic neighborhood stress, suggesting that populations in these areas may be more susceptible to the effects of air pollution. 
719 720 721 722 Household-level 
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M.R. (2003) Relation between income, air pollution 
and mortality: a cohort study. Canadian Med Assn J 169: 397–402. 
722Shankardass, K.; McConnell, R.; Jerrett, M.; 
Milam, J.; Richardson, J.; Berhane, K. (2009) Parental stress increases the effect of traffic-related air pollution on childhood asthma incidence. Proc Natl Acad Sci 106: 12406–12411. doi:10.1073/ pnas.0812910106 [Online at http://dx.doi.org]. 
723Lewis, A.S.; Sax, S.N.; Wason, S.C.; 
Campleman, S.L (2011) Non-chemical stressors and cumulative risk assessment: an overview of current initiatives and potential air pollutant interactions. Int J Environ Res Public Health 8: 2020–2073. Doi:10.3390/ijerph8062020 [Online at http://dx.doi.org]. 
724Rosa, M.J.; Jung, K.H.; Perzanowski, M.S.; 
Kelvin, E.A.; Darling, K.W.; Camann, D.E.; Chillrud, S.N.; Whyatt, R.M.; Kinney, P.L.; Perera, F.P.; Miller, R.L (2010) Prenatal exposure to polycyclic aromatic hydrocarbons, environmental tobacco smoke and asthma. Respir Med (In press). doi:10.1016/j.rmed.2010.11.022 [Online at http://dx.doi.org]. 
725Rowangould, G.M. (2013) A census of the U.S. 
near-roadway population: public health and environmental justice considerations. Transportation Research Part D; 59–67. 
726Tian, N.; Xue, J.; Barzyk. T.M. (2013) 
Evaluating socioeconomic and racial differences in traffic-related metrics in the United States using a GIS approach. J Exposure Sci Environ Epidemiol 23: 215–222. 
727Boehmer, T.K.; Foster, S.L.; Henry, J.R.; 
Woghiren-Akinnifesi, E.L.; Yip, F.Y. (2013) Residential proximity to major highways—United States, 2010. Morbidity and Mortality Weekly Report 62(3): 46–50. 728This variable primarily represents roadway 
proximity. According to the Central Intelligence Agency’s World Factbook, in 2010, the United States had 6,506,204 km or roadways, 224,792 km of railways, and 15,079 airports. Highways thus represent the overwhelming majority of transportation facilities described by this factor in the AHS. 
729Bailey, C. (2011) Demographic and Social 
Patterns in Housing Units Near Large Highways and other Transportation Sources. Memorandum to docket. 
730http://nces.ed.gov/ccd/. 
731Pedde, M.; Bailey, C. (2011) Identification of 
Schools within 200 Meters of U.S. Primary and Secondary Roads. Memorandum to the docket. 732National Research Council, (1993). Protecting 
Visibility in National Parks and Wilderness Areas. National Academy of Sciences Committee on Haze in National Parks and Wilderness Areas. National Academy Press, Washington, DC. This book can be viewed on the National Academy Press Web site at http://www.nap.edu/books/0309048443/html/ . 
733U.S. EPA. (2009). Integrated Science 
Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F. stressors such as parental smoking and 
relationship stress also may increase susceptibility to the adverse effects of air pollution.
723 724  
More recently, three publications 
report nationwide analyses that compare the demographic patterns of people who do or do not live near major roadways.
725 726 727 All three of these 
studies found that people living near major roadways are more likely to be minorities or low in SES. They also found that the outcomes of their analyses varied between regions within the U.S. However, only one such study looked at whether such conclusions were confounded by living in a location with higher population density and how demographics differ between locations nationwide. In general, it found that higher density areas have higher proportions of low income and minority residents. 
We analyzed two national databases 
that allowed us to evaluate whether homes and schools were located near a major road and whether disparities in exposure may be occurring in these environments. The American Housing Survey (AHS) includes descriptive statistics of over 70,000 housing units across the nation. The study survey is conducted every two years by the U.S. Census Bureau. The second database we analyzed was the U.S. Department of Education’s Common Core of Data, which includes enrollment and location information for schools across the U.S. 
In analyzing the 2009 AHS, we 
focused on whether or not a housing unit was located within 300 feet of ‘‘4- or-more lane highway, railroad, or airport.’’
728We analyzed whether there 
were differences between households in such locations compared with those in locations farther from these transportation facilities.
729We included 
other variables, such as land use category, region of country, and housing type. We found that homes with a nonwhite householder were 22–34 percent more likely to be located within 300 feet of these large transportation facilities than homes with white householders. Homes with a Hispanic householder were 17–33 percent more likely to be located within 300 feet of these large transportation facilities than homes with non-Hispanic householders. Households near large transportation facilities were, on average, lower in income and educational attainment, more likely to be a rental property and located in an urban area compared with households more distant from transportation facilities. 
In examining schools near major 
roadways, we examined the Common Core of Data (CCD) from the U.S. Department of Education, which includes information on all public elementary and secondary schools and school districts nationwide.
730To 
determine school proximities to major roadways, we used a geographic information system (GIS) to map each school and roadways based on the U.S. Census’s TIGER roadway file.
731We 
found that minority students were overrepresented at schools within 200 meters of the largest roadways, and that schools within 200 meters of the largest roadways also had higher than expected numbers of students eligible for free or reduced-price lunches. For example, Black students represent 22 percent of students at schools located within 200 meters of a primary road, whereas Black students represent 17 percent of students in all U.S. schools. Hispanic students represent 30 percent of 
students at schools located within 200 meters of a primary road, whereas Hispanic students represent 22 percent of students in all U.S. schools. 
Overall, there is substantial evidence 
that people who live or attend school near major roadways are more likely to be of a minority race, Hispanic ethnicity, and/or low SES. The emission reductions from these final rules will likely result in widespread air quality improvements, but the impact on pollution levels in close proximity to roadways will be most direct. Thus, these final rules will likely help in mitigating the disparity in racial, ethnic, and economically based exposures. 
B. Environmental Effects of Non-GHG 
Pollutants 
(1) Visibility 
Visibility can be defined as the degree 
to which the atmosphere is transparent 
to visible light.
732Visibility impairment 
is caused by light scattering and absorption by suspended particles and gases. Visibility is important because it has direct significance to people’s enjoyment of daily activities in all parts of the country. Individuals value good visibility for the well-being it provides them directly, where they live and work, and in places where they enjoy recreational opportunities. Visibility is also highly valued in significant natural areas, such as national parks and wilderness areas, and special emphasis is given to protecting visibility in these areas. For more information on visibility see the final 2009 p.m. ISA.
733 
EPA is working to address visibility 
impairment. Reductions in air pollution from implementation of various programs associated with the Clean Air Act Amendments of 1990 (CAAA) provisions have resulted in substantial improvements in visibility and will continue to do so in the future. Because trends in haze are closely associated with trends in particulate sulfate and nitrate due to the relationship between their concentration and light extinction, visibility trends have improved as emissions of SO
2and NO Xhave 
decreased over time due to air pollution 
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734U.S. EPA. 2009 Final Report: Integrated 
Science Assessment for Particulate Matter. U.S. 
Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F, 2009. 
735See Section 169(a) of the Clean Air Act. 
73664 FR 35714, July 1, 1999. 
73762 FR 38680–38681, July 18, 1997. 
73873 FR 16486, March 27, 2008. 73973 FR 16491, March 27, 2008. Only a small 
percentage of all the plant species growing within 
the U.S. (over 43,000 species have been catalogued in the USDA PLANTS database) have been studied with respect to ozone sensitivity. 
740The concentration at which ozone levels 
overwhelm a plant’s ability to detoxify or compensate for oxidant exposure varies. Thus, 
whether a plant is classified as sensitive or tolerant depends in part on the exposure levels being considered. Chapter 9, Section 9.3.4 of U.S. EPA, 2013 Integrated Science Assessment for Ozone and Related Photochemical Oxidants. Office of Research and Development/National Center for Environmental Assessment. U.S. Environmental Protection Agency. EPA 600/R–10/076F. 
74173 FR 16492, March 27, 2008. 
74273 FR 16493–16494, March 27, 2008, Ozone 
impacts could be occurring in areas where plant species sensitive to ozone have not yet been studied or identified. 
74373 FR 16490–16497, March 27, 2008. 
744U.S. EPA. Integrated Science Assessment of 
Ozone and Related Photochemical Oxidants (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–10/076F, 2013. The ISA is available at http://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=247492#Download . 745The Ozone ISA evaluates the evidence 
associated with different ozone related health and 
welfare effects, assigning one of five ‘‘weight of evidence’’ determinations: causal relationship, likely to be a causal relationship, suggestive of a causal relationship, inadequate to infer a causal relationship, and not likely to be a causal relationship. For more information on these levels of evidence, please refer to Table II of the ISA. 
746U.S. EPA. Integrated Science Assessment for 
Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/139F, 2009. 
747U.S. EPA. (2000). Deposition of Air Pollutants 
to the Great Waters: Third Report to Congress. Office of Air Quality Planning and Standards. EPA– 453/R–00–0005. regulations such as the Acid Rain 
Program.734 
In the Clean Air Act Amendments of 
1977, Congress recognized visibility’s value to society by establishing a national goal to protect national parks and wilderness areas from visibility impairment caused by manmade pollution.
735In 1999, EPA finalized the 
regional haze program to protect the visibility in Mandatory Class I Federal areas.
736There are 156 national parks, 
forests and wilderness areas categorized as Mandatory Class I Federal areas.
737 
These areas are defined in CAA Section 162 as those national parks exceeding 6,000 acres, wilderness areas and memorial parks exceeding 5,000 acres, and all international parks which were in existence on August 7, 1977. 
EPA has also concluded that PM
2.5 
causes adverse effects on visibility in other areas that are not targeted by the Regional Haze Rule, such as urban areas, depending on PM
2.5 
concentrations and other factors such as dry chemical composition and relative humidity (i.e., an indicator of the water 
composition of the particles). EPA revised the PM
2.5standards in December 
2012 and established a target level of protection that is expected to be met through attainment of the existing secondary standards for PM
2.5. 
(2) Plant and Ecosystem Effects of Ozone 
The welfare effects of ozone can be 
observed across a variety of scales, i.e. subcellular, cellular, leaf, whole plant, population and ecosystem. Ozone effects that begin at small spatial scales, such as the leaf of an individual plant, when they occur at sufficient magnitudes (or to a sufficient degree) can result in effects being propagated along a continuum to larger and larger spatial scales. For example, effects at the individual plant level, such as altered rates of leaf gas exchange, growth and reproduction, can, when widespread, result in broad changes in ecosystems, such as productivity, carbon storage, water cycling, nutrient cycling, and community composition. 
Ozone can produce both acute and 
chronic injury in sensitive species depending on the concentration level and the duration of the exposure.
738In those sensitive species,739effects from 
repeated exposure to ozone throughout 
the growing season of the plant tend to accumulate, so that even low concentrations experienced for a longer duration have the potential to create chronic stress on vegetation.
740Ozone 
damage to sensitive species includes impaired photosynthesis and visible injury to leaves. The impairment of photosynthesis, the process by which the plant makes carbohydrates (its source of energy and food), can lead to reduced crop yields, timber production, and plant productivity and growth. Impaired photosynthesis can also lead to a reduction in root growth and carbohydrate storage below ground, resulting in other, more subtle plant and ecosystems impacts.
741These latter 
impacts include increased susceptibility of plants to insect attack, disease, harsh weather, interspecies competition and overall decreased plant vigor. The adverse effects of ozone on areas with sensitive species could potentially lead to species shifts and loss from the affected ecosystems,
742resulting in a 
loss or reduction in associated ecosystem goods and services. Additionally, visible ozone injury to leaves can result in a loss of aesthetic value in areas of special scenic significance like national parks and wilderness areas and reduced use of sensitive ornamentals in landscaping.
743 
The most recent Integrated Science 
Assessment (ISA) for Ozone presents more detailed information on how ozone affects vegetation and ecosystems.
744The ISA concludes that 
ambient concentrations of ozone are associated with a number of adverse welfare effects and characterizes the weight of evidence for different effects associated with ozone.
745The ISA 
concludes that visible foliar injury 
effects on vegetation, reduced vegetation growth, reduced productivity in terrestrial ecosystems, reduced yield and quality of agricultural crops, and alteration of below-ground biogeochemical cycles are causally associated with exposure to ozone. It also concludes that reduced carbon sequestration in terrestrial ecosystems, alteration of terrestrial ecosystem water cycling, and alteration of terrestrial community composition are likely to be causally associated with exposure to ozone. 
(3) Atmospheric Deposition 
Wet and dry deposition of ambient 
particulate matter delivers a complex 
mixture of metals (e.g., mercury, zinc, 
lead, nickel, aluminum, and cadmium), organic compounds (e.g., polycyclic 
organic matter, dioxins, and furans) and inorganic compounds (e.g., nitrate, 
sulfate) to terrestrial and aquatic ecosystems. The chemical form of the compounds deposited depends on a variety of factors including ambient conditions (e.g., temperature, humidity, 
oxidant levels) and the sources of the material. Chemical and physical transformations of the compounds occur in the atmosphere as well as the media onto which they deposit. These transformations in turn influence the fate, bioavailability and potential toxicity of these compounds. 
Adverse impacts to human health and 
the environment can occur when particulate matter is deposited to soils, water, and biota.
746Deposition of heavy 
metals or other toxics may lead to the human ingestion of contaminated fish, impairment of drinking water, damage to terrestrial, freshwater and marine ecosystem components, and limits to recreational uses. Atmospheric deposition has been identified as a key component of the environmental and human health hazard posed by several pollutants including mercury, dioxin and PCBs.
747 
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748NO Xand SO Xsecondary ISA1U.S. EPA. 
Integrated Science Assessment (ISA) for Oxides of 
Nitrogen and Sulfur Ecological Criteria (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R–08/082F, 2008. 749U.S. Environmental Protection Agency (U.S. 
EPA). 2009. Integrated Science Assessment for Particulate Matter (Final Report). EPA–600–R–08– 139F. National Center for Environmental Assessment—RTP Division. December. Available on the Internet at <http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=216546>. 
750Irving, P.M., e.d. 1991. Acid Deposition: State 
of Science and Technology, Volume III, Terrestrial, Materials, Health, and Visibility Effects, The U.S. National Acid Precipitation Assessment Program, Chapter 24, page 24–76. 
751U.S. EPA. (1991). Effects of organic chemicals 
in the atmosphere on terrestrial plants. EPA/600/3– 91/001. 
752Cape JN, ID Leith, J Binnie, J Content, M 
Donkin, M Skewes, DN Price AR Brown, AD Sharpe. (2003). Effects of VOCs on herbaceous plants in an open-top chamber experiment. Environ. Pollut. 124:341–343. 
753Cape JN, ID Leith, J Binnie, J Content, M 
Donkin, M Skewes, DN Price AR Brown, AD Sharpe. (2003). Effects of VOCs on herbaceous plants in an open-top chamber experiment. Environ. Pollut. 124:341–343. 754Viskari E–L. (2000). Epicuticular wax of 
Norway spruce needles as indicator of traffic 
pollutant deposition. Water, Air, and Soil Pollut. 121:327–337. 
755Ugrekhelidze D, F Korte, G Kvesitadze. (1997). 
Uptake and transformation of benzene and toluene by plant leaves. Ecotox. Environ. Safety 37:24–29. 
756Kammerbauer H, H Selinger, R Rommelt, A 
Ziegler-Jons, D Knoppik, B Hock. (1987). Toxic 
components of motor vehicle emissions for the spruce Picea abies. Environ. Pollut. 48:235–243. The ecological effects of acidifying 
deposition and nutrient enrichment are 
detailed in the Integrated Science Assessment for Oxides of Nitrogen and Sulfur-Ecological Criteria.
748 
Atmospheric deposition of nitrogen and sulfur contributes to acidification, altering biogeochemistry and affecting animal and plant life in terrestrial and aquatic ecosystems across the United States. The sensitivity of terrestrial and aquatic ecosystems to acidification from nitrogen and sulfur deposition is predominantly governed by geology. Prolonged exposure to excess nitrogen and sulfur deposition in sensitive areas acidifies lakes, rivers and soils. Increased acidity in surface waters creates inhospitable conditions for biota and affects the abundance and biodiversity of fishes, zooplankton and macroinvertebrates and ecosystem function. Over time, acidifying deposition also removes essential nutrients from forest soils, depleting the capacity of soils to neutralize future acid loadings and negatively affecting forest sustainability. Major effects in forests include a decline in sensitive tree species, such as red spruce (Picea rubens) and sugar maple (Acer saccharum). In addition to the role nitrogen deposition plays in acidification, nitrogen deposition also leads to nutrient enrichment and altered biogeochemical cycling. In aquatic systems increased nitrogen can alter species assemblages and cause eutrophication. In terrestrial systems nitrogen loading can lead to loss of nitrogen-sensitive lichen species, decreased biodiversity of grasslands, meadows and other sensitive habitats, and increased potential for invasive species. For a broader explanation of the topics treated here, refer to the description in Chapter 8.1.2.3 of the RIA. 
Building materials including metals, 
stones, cements, and paints undergo natural weathering processes from exposure to environmental elements (e.g., wind, moisture, temperature 
fluctuations, sunlight, etc.). Pollution can worsen and accelerate these effects. Deposition of PM is associated with both physical damage (materials damage effects) and impaired aesthetic qualities (soiling effects). Wet and dry deposition of PM can physically affect materials, adding to the effects of natural weathering processes, by potentially promoting or accelerating the corrosion of metals, by degrading paints and by 
deteriorating building materials such as stone, concrete and marble.
749The 
effects of PM are exacerbated by the presence of acidic gases and can be additive or synergistic due to the complex mixture of pollutants in the air and surface characteristics of the material. Acidic deposition has been shown to have an effect on materials including zinc/galvanized steel and other metal, carbonate stone (as monuments and building facings), and surface coatings (paints).
750The effects 
on historic buildings and outdoor works of art are of particular concern because of the uniqueness and irreplaceability of many of these objects. 
(4) Environmental Effects of Air Toxics 
Emissions from producing, 
transporting and combusting fuel 
contribute to ambient levels of pollutants that contribute to adverse 
effects on vegetation. Volatile organic compounds, some of which are considered air toxics, have long been suspected to play a role in vegetation damage.
751In laboratory experiments, a 
wide range of tolerance to VOCs has been observed.
752Decreases in 
harvested seed pod weight have been reported for the more sensitive plants, and some studies have reported effects on seed germination, flowering and fruit ripening. Effects of individual VOCs or their role in conjunction with other stressors (e.g., acidification, drought, 
temperature extremes) have not been well studied. In a recent study of a mixture of VOCs including ethanol and toluene on herbaceous plants, significant effects on seed production, leaf water content and photosynthetic efficiency were reported for some plant species.
753 Research suggests an adverse impact 
of vehicle exhaust on plants, which has 
in some cases been attributed to aromatic compounds and in other cases to nitrogen oxides.
754 755 756  
C. Emissions Inventory Impacts 
As described in Section VII, the 
agencies conducted two analyses for these rules using DOT’s CAFE model and EPA’s MOVES model, relative to different reference cases (i.e., different 
baselines). The agencies used EPA’s MOVES model to estimate the non-GHG impacts for tractor-trailers (including the engine that powers the vehicle) and vocational vehicles (including the engine that powers the vehicle). For heavy-duty pickups and vans, the agencies performed separate analyses using the CAFE model (included in NHTSA’s ‘‘Method A;’’ See Section VI) and the MOVES model (included in EPA’s ‘‘Method B;’’ See Section VI) to estimate non-GHG emissions from these vehicles. For these methods, the agencies analyzed the impact of the rules relative to two different reference cases—flat and dynamic. The flat baseline projects very little improvement in new vehicles in the absence of new Phase 2 standards. In contrast, the dynamic baseline projects more significant improvements in vehicle fuel efficiency. The agencies considered both reference cases. The results for all of the regulatory alternatives relative to both reference cases, derived via the same methodologies discussed in Section VII of the Preamble, are presented in Section X of the Preamble. 
For brevity, a subset of these analyses 
are presented in this section and the reader is referred to both Chapter 11 of the RIA and NHTSA’s FEIS Chapters 3, 4 and 5 for complete sets of these analyses. In this section, Method A is presented for the final standards, relative to both the dynamic baseline (Alternative 1b) and the flat baseline (Alternative 1a). Method B is presented for the final standards, relative only to the flat baseline. 
The following subsections summarize 
two slightly different analyses of the annual non-GHG emissions reductions expected from these standards. Section VIII.A.(1) presents the impacts of the 
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final rules on non-GHG emissions using 
the analytical Method A, relative to two different reference cases—flat and dynamic. Section VIII.A.(2) presents the impacts of these standards, relative to the flat reference case only, using the MOVES model for all heavy-duty vehicle categories. 
(1) Impacts of the Final Rules Using 
Analysis Method A 
(a) Calendar Year Analysis (i) Upstream Impacts of the Final 
Program 
Increasing efficiency in heavy-duty 
vehicles will result in reduced fuel demand and, therefore, reductions in the emissions associated with all processes involved in getting petroleum to the pump. Both Method A and Method B project these impacts for fuel consumed by vocational vehicles and combination tractor-trailers, using EPA’s MOVES model. See Section VII.A. for the description of this methodology. To project these impacts for fuel consumed by HD pickups and vans, Method A used similar calculations and inputs applicable to the CAFE model, as discussed above in Section VI. More information on the development of the emission factors used in this analysis can be found in Chapter 5 of the RIA. 
The following two tables summarize 
the projected upstream emission impacts of the final program on both criteria pollutants and air toxics from the heavy-duty sector, relative to Alternative 1b (dynamic baseline conditions under the No-Action Alternative) and Alternative 1a (flat baseline conditions under the No- Action Alternative), using analysis method A. Using either No-Action Alternative shows decreases in upstream emissions of all criteria pollutants, precursors, and air toxics; using Alternative 1a as the reference point attributes more of the emission reduction to the standards. Note that the rule is projected, in all analyses, of reducing emissions of NO
X, contrary to 
implications in some of the public comments that fuel efficiency/GHG controls come at the expense of increased NO
Xemissions. 
TABLE VIII–1—A NNUAL UPSTREAM IMPACTS ON CRITERIA POLLUTANTS AND AIRTOXICS FROM HEAVY -DUTYSECTOR IN  
CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1b U SING ANALYSIS METHOD Aa 
Pollutant CY2025 CY2040 CY2050 
US short tons % Change US short tons % Change US short tons % Change 
1,3-Butadiene ........................................... ¥1 ¥4.9 ¥4 ¥18 ¥5 ¥19 
Acetaldehyde ........................................... ¥3 ¥4.4 ¥14 ¥15 ¥16 ¥16 
Acrolein .................................................... ¥0.4 ¥4.6 ¥2 ¥16 ¥2 ¥17 
Benzene ................................................... ¥23 ¥4.8 ¥88 ¥16 ¥105 ¥18 
CO ............................................................ ¥3,785 ¥4.9 ¥14,714 ¥17 ¥17,629 ¥19 
Formaldehyde .......................................... ¥18 ¥4.9 ¥71 ¥17 ¥86 ¥19 
NO X.......................................................... ¥9,255 ¥4.9 ¥35,964 ¥17 ¥43,089 ¥19 
PM 2.5........................................................ ¥975 ¥4.9 ¥3,850 ¥18 ¥4,618 ¥19 
SO X.......................................................... ¥5,804 ¥4.9 ¥22,550 ¥17 ¥27,019 ¥19 
VOC ......................................................... ¥4,419 ¥4.8 ¥14,857 ¥15 ¥17,385 ¥16 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE VIII–2—A NNUAL UPSTREAM IMPACTS ON CRITERIA POLLUTANTS AND AIRTOXICS FROM HEAVY -DUTYSECTOR IN  
CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1a U SING ANALYSIS METHOD Aa 
Pollutant CY2025 CY2040 CY2050 
US short tons % Change US short tons % Change US short tons % Change 
1,3-Butadiene ........................................... ¥1 ¥5.3 ¥4 ¥20 ¥5 ¥21 
Acetaldehyde ........................................... ¥4 ¥4.6 ¥15 ¥16 ¥17 ¥17 
Acrolein .................................................... ¥0.4 ¥4.9 ¥2 ¥17 ¥2 ¥18 
Benzene ................................................... ¥25 ¥5.1 ¥96 ¥18 ¥115 ¥19 
CO ............................................................ ¥4,142 ¥5.4 ¥16,298 ¥19 ¥19,558 ¥20 
Formaldehyde .......................................... ¥20 ¥5.3 ¥79 ¥19 ¥95 ¥20 
NO X.......................................................... ¥10,124 ¥5.4 ¥39,813 ¥19 ¥47,779 ¥20 
PM 2.5........................................................ ¥1,065 ¥5.3 ¥4,258 ¥19 ¥5,117 ¥21 
SO X.......................................................... ¥6,349 ¥5.4 ¥24,961 ¥19 ¥29,958 ¥20 
VOC ......................................................... ¥4,810 ¥5.2 ¥16,218 ¥16 ¥19,004 ¥17 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(ii) Downstream Impacts of the Final Program 
For vocational vehicles and tractor- 
trailers, the agencies used the MOVES model to determine non-GHG emissions inventories. The improvements in engine efficiency and road load, the increased use of APUs, and VMT rebound were included in the MOVES 
analysis. For NHTSA’s Method A analysis, presented in this section, the DOT CAFE model was used for HD pickups and vans. Further information about DOT’s CAFE model is available in Section VI.C and Chapter 10 of the RIA. The following two tables summarize the projected downstream emission impacts of the final program on both criteria pollutants and air toxics from the heavy- duty sector, relative to Alternative 1b and Alternative 1a, using analysis Method A. Using either baseline shows a reduction in all criteria pollutants and air toxics—except for 1,3-Butadiene, 
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and CY2025 levels of acrolein, which show small increases in downstream 
emissions. 
TABLE VIII–3—A NNUAL DOWNSTREAM IMPACTS ON CRITERIA POLLUTANTS AND AIRTOXICS FROM HEAVY -DUTYSECTOR  
INCALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1b U SING ANALYSIS METHOD Aa 
Pollutant CY2025 CY2040 CY2050 
US short tons % Change US short tons % Change US short tons % Change 
1,3-Butadiene ........................................... 1 0.5 4 3.6 4 3.4 
Acetaldehyde ........................................... ¥1 0.0 ¥16 ¥0.7 ¥19 ¥0.8 
Acrolein .................................................... 0.2 0.0 ¥0.3 ¥0.1 ¥1 ¥0.4 
Benzene ................................................... ¥2 ¥0.1 ¥13 ¥1.2 ¥13 ¥1.1 
CO ............................................................ ¥9,045 ¥0.6 ¥34,702 ¥2.8 ¥42,095 ¥3.0 
Formaldehyde .......................................... ¥21 ¥0.3 ¥96 ¥1.6 ¥119 ¥1.8 
NO X.......................................................... ¥12,082 ¥1.3 ¥53,254 ¥9.1 ¥65,068 ¥9.9 
PM 2.5b...................................................... ¥58 ¥0.2 ¥363 ¥2.0 ¥453 ¥2.2 
SO X.......................................................... ¥201 ¥4.1 ¥851 ¥16 ¥1,028 ¥17 
VOC ......................................................... ¥769 ¥0.8 ¥3,436 ¥5.3 ¥4,128 ¥5.8 
Notes: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
bPM 2.5from tire wear and brake wear are included. 
TABLE VIII–4—A NNUAL DOWNSTREAM IMPACTS ON CRITERIA POLLUTANTS AND AIRTOXICS FROM HEAVY -DUTYSECTOR  
INCALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1a U SING ANALYSIS METHOD Aa 
Pollutant CY2025 CY2040 CY2050 
US short tons % Change US short tons % Change US short tons % Change 
1,3-Butadiene ........................................... 1 0.5 4 3.7 4 3.5 
Acetaldehyde ........................................... ¥1 0.0 ¥14 ¥0.7 ¥18 ¥0.8 
Acrolein .................................................... 0.2 0.0 ¥0.3 ¥0.1 ¥1 ¥0.4 
Benzene ................................................... ¥2 ¥0.2 ¥13 ¥1.2 ¥14 ¥1.2 
CO ............................................................ ¥8,944 ¥0.6 ¥34,502 ¥2.8 ¥41,880 ¥3.0 
Formaldehyde .......................................... ¥20 ¥0.3 ¥91 ¥1.6 ¥113 ¥1.7 
NO X.......................................................... ¥13,368 ¥1.5 ¥60,594 ¥10.2 ¥74,206 ¥11 
PM 2.5b...................................................... ¥78 ¥0.2 ¥473 ¥2.6 ¥591 ¥2.9 
SO X.......................................................... ¥219 ¥4.5 ¥941 ¥17 ¥1,138 ¥19 
VOC ......................................................... ¥831 ¥0.8 ¥3,736 ¥5.8 ¥4,499 ¥6.3 
Notes: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
bPM 2.5from tire wear and brake wear are included. 
(iii) Total Impacts of the Final Program 
The following two tables summarize 
the projected upstream emission 
impacts of the final program on both criteria pollutants and air toxics from 
the heavy-duty sector, relative to Alternative 1b and Alternative 1a, using analysis Method A. Under both baselines, Method A predicts a decrease in total emissions by calendar year 
2050, but the amount attributable to the standards is larger using the flat baseline than the dynamic baseline. 
TABLE VIII–5—A NNUAL TOTAL IMPACTS (UPSTREAM AND DOWNSTREAM ) OFCRITERIA POLLUTANTS AND AIRTOXICS  
FROM HEAVY -DUTYSECTOR IN CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1b U SING ANAL-
YSIS METHOD Aa 
Pollutant CY2025 CY2040 CY2050 
US short tons % Change US short tons % Change US short tons % Change 
1,3-Butadiene ........................................... 0.3 0.1 0.1 0.1 ¥0.4 ¥0.3 
Acetaldehyde ........................................... ¥4 ¥0.1 ¥30 ¥1.3 ¥35 ¥1.4 
Acrolein .................................................... ¥0.2 0.0 ¥2 ¥0.7 ¥3 ¥0.9 
Benzene ................................................... ¥25 ¥1.2 ¥101 ¥6.3 ¥118 ¥6.7 
CO ............................................................ ¥12,830 ¥0.9 ¥49,416 ¥3.7 ¥59,724 ¥4.0 
Formaldehyde .......................................... ¥39 ¥0.5 ¥167 ¥2.7 ¥205 ¥2.9 
NO X.......................................................... ¥21,337 ¥2.0 ¥89,218 ¥11 ¥108,157 ¥12 
PM 2.5........................................................ ¥1,033 ¥2.0 ¥4,213 ¥10 ¥5,071 ¥11 
SO X.......................................................... ¥6,005 ¥4.9 ¥23,401 ¥17 ¥28,047 ¥19 
VOC ......................................................... ¥5,188 ¥2.7 ¥18,293 ¥11 ¥21,513 ¥12 
Notes: 
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757U.S. EPA. Draft Regulatory Impact Analysis: 
Changes to Renewable Fuel Standard Program. aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE VIII–6—A NNUAL TOTAL IMPACTS (UPSTREAM AND DOWNSTREAM ) OFCRITERIA POLLUTANTS AND AIRTOXICS  
FROM HEAVY -DUTYSECTOR IN CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1a U SING ANAL-
YSIS METHOD Aa 
Pollutant CY2025 CY2040 CY2050 
US short tons % Change US short tons % Change US short tons % Change 
1,3-Butadiene ........................................... 0.2 0.1 ¥0.2 ¥0.1 ¥1.0 ¥0.5 
Acetaldehyde ........................................... ¥5 ¥0.2 ¥29 ¥1.3 ¥35 ¥1.4 
Acrolein .................................................... ¥0.2 0.0 ¥2 ¥0.7 ¥3 ¥1.0 
Benzene ................................................... ¥27 ¥1.4 ¥109 ¥6.8 ¥129 ¥7.2 
CO ............................................................ ¥13,086 ¥0.9 ¥50,800 ¥3.8 ¥61,438 ¥4.1 
Formaldehyde .......................................... ¥40 ¥0.5 ¥170 ¥2.7 ¥208 ¥2.9 
NO X.......................................................... ¥23,492 ¥2.2 ¥100,407 ¥12 ¥121,985 ¥14 
PM 2.5........................................................ ¥1,143 ¥2.2 ¥4,731 ¥12 ¥5,708 ¥13 
SO X.......................................................... ¥6,568 ¥5.3 ¥25,902 ¥19 ¥31,096 ¥20 
VOC ......................................................... ¥5,641 ¥3.0 ¥19,954 ¥12 ¥23,503 ¥13 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(b) Model Year Lifetime Analysis 
Table VIII–7 shows the lifetime Non- 
GHG reductions for model years 2018– 
2029 attributable to the standards using Method A relative to both No-Action Alternatives. For NO
X, approximately half of the emission reductions are 
downstream and half are upstream. However, for PM
2.5and SO X 
proportionally more of the emission reductions are attributable to upstream emission reductions than to downstream emission reductions. A similar pattern emerges as with single 
calendar year snapshots; more emission reductions are attributable to the standards using the 1a baseline as the reference point than by using the 1b baseline as the reference point. 
TABLE VIII–7—L IFETIME NON-GHG R EDUCTIONS USING ANALYSIS METHOD A—S UMMARY FOR MODEL YEARS 2018– 
2029 
[U.S. Short Tons]a 
NO–action alternative (baseline) Final program 
1b (Dynamic) 1a (Flat) 
NO X............................................................................................................................... ........................................... 494,495 548,630 
Downstream ..................................................................................................................... ................................. 246,509 276,413 
Upstream ....................................................................................................................... ................................... 247,986 272,217 
PM 2.5............................................................................................................................... ......................................... 27,827 30,838 
Downstreamb............................................................................................................................... ..................... 1,437 1,891 
Upstream ....................................................................................................................... ................................... 26,390 28,947 
SO X............................................................................................................................... ........................................... 159,367 174,918 
Downstream ..................................................................................................................... ................................. 3,849 4,214 
Upstream ....................................................................................................................... ................................... 155,518 170,704 
Notes: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
bPM 2.5from tire wear and brake wear are included. 
(2) Impacts of the Final Rules Using 
Analysis Method B 
(a) Calendar Year Analysis (i) Upstream Impacts of the Final 
Program 
Increasing efficiency in heavy-duty 
vehicles will result in reduced fuel demand and, therefore, reductions in the emissions associated with all processes involved in getting petroleum 
to the pump. To project these impacts, Method B estimated the impact of reduced petroleum volumes on the extraction and transportation of crude oil as well as the production and 
distribution of finished gasoline and diesel. For the purpose of assessing 
domestic-only emission reductions, it was necessary to estimate the fraction of fuel savings attributable to domestic finished gasoline and diesel and, of this fuel, what fraction is produced from domestic crude. Method B estimated the emissions associated with production and distribution of gasoline and diesel from crude oil based on emission factors in the ‘‘Greenhouse Gases, Regulated Emissions, and Energy used in Transportation’’ model (GREET) developed by DOE’s Argonne National 
Laboratory. In some cases, the GREET values were modified or updated by the agencies to be consistent with the National Emission Inventory (NEI) and emission factors from MOVES. Method B estimated the projected corresponding changes in upstream emissions using the same tools originally created for the Renewable Fuel Standard 2 (RFS2) rulemaking analysis,
757used in the LD 
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Chapters 2 and 3. May 26, 2009. Docket ID: EPA– 
HQ–OAR–2009–0472–0119. 
7582017 and Later Model Year Light-Duty Vehicle 
Greenhouse Gas Emissions and Corporate Average 
Fuel Economy Standards (77 FR 62623, October 15, 2012). 759Greenhouse Gas Emission Standards and Fuel 
Efficiency Standards for Medium- and Heavy-Duty 
Engines and Vehicles (76 FR 57106, September 15, 
2011). 
760HD pickups and vans are subject to gram per 
mile (distance) emission standards, as opposed to larger heavy-duty vehicles which are certified to a 
gram per brake horsepower (work) standard. GHG rulemakings,758HD GHG Phase 
1,759and updated for the current 
analysis. More information on the 
development of the emission factors used in this analysis can be found in 
Chapter 5 of the RIA. 
Table VIII–8 summarizes the 
projected upstream emission impacts of the final program on both criteria pollutants and air toxics from the heavy- duty sector, relative to Alternative 1a, 
using analysis Method B. The comparable estimates relative to Alternative 1b are presented in Section VIII.C.(1). 
TABLE VIII–8—A NNUAL UPSTREAM IMPACTS ON CRITERIA POLLUTANTS AND AIRTOXICS FROM HEAVY -DUTYSECTOR IN  
CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1a U SING ANALYSIS METHOD Ba 
Pollutant CY2025 CY2040 CY2050 
US short 
tons % 
Change US short 
tons % 
Change US short 
tons % 
Change 
1,3-Butadiene ........................................... ¥1 ¥4.8 ¥5 ¥19.0 ¥6 ¥20.6 
Acetaldehyde ........................................... ¥7 ¥3.2 ¥35 ¥14.5 ¥38 ¥15.9 
Acrolein .................................................... ¥1 ¥3.5 ¥3 ¥15.2 ¥4 ¥16.7 
Benzene ................................................... ¥30 ¥3.8 ¥143 ¥16.1 ¥166 ¥17.6 
CO ............................................................ ¥3,809 ¥4.8 ¥16,884 ¥18.9 ¥20,227 ¥20.5 
Formaldehyde .......................................... ¥20 ¥4.6 ¥90 ¥18.3 ¥107 ¥19.9 
NO X.......................................................... ¥9,314 ¥4.8 ¥41,280 ¥18.9 ¥49,462 ¥20.5 
PM 2.5........................................................ ¥1,037 ¥4.7 ¥4,619 ¥18.7 ¥5,520 ¥20.3 
SO X.......................................................... ¥5,828 ¥4.8 ¥25,811 ¥18.9 ¥30,941 ¥20.5 
VOC ......................................................... ¥4,234 ¥3.7 ¥20,010 ¥15.9 ¥23,240 ¥17.4 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(ii) Downstream Impacts of the Final 
Program 
The final program will impact the 
downstream emissions of non-GHG pollutants. These pollutants include oxides of nitrogen (NO
X), oxides of 
sulfur (SO X), volatile organic 
compounds (VOC), carbon monoxide (CO), fine particulate matter (PM
2.5), and 
air toxics. The agencies expect reductions in downstream emissions of 
NO
X,PM 2.5, VOC, SO X, CO, and air 
toxics. Much of these estimated net reductions are a result of the agencies’ anticipation of increased use of auxiliary power units (APUs) in combination tractors during extended idling; APUs emit these pollutants at a lower rate than on-road engines during extended idle operation, with the exception of PM
2.5. As discussed in Section III.C.3, EPA is adopting Phase 1 
and Phase 2 requirements to control PM
2.5emissions from APUs installed in 
new tractors and therefore, eliminate the unintended consequence of increased PM
2.5emissions from increased APU 
use. 
Additional reductions in tailpipe 
emissions of NO Xand CO and refueling 
emissions of VOC will be achieved through improvements in engine efficiency and reduced road load (improved aerodynamics and tire rolling resistance), which reduces the amount of work required to travel a given distance and increases fuel economy. For vehicle types not affected by road load improvements, such as HD pickups and vans
760, non-GHG emissions will 
increase very slightly due to VMT rebound. In addition, brake wear and tire wear emissions of PM
2.5will also increase very slightly due to VMT rebound. The agencies estimate that downstream emissions of SO
Xwill be 
reduced, because they are roughly proportional to fuel consumption. 
For vocational vehicles and tractor- 
trailers, the agencies used MOVES to determine non-GHG emissions impacts of the final rules, relative to the flat baseline (Alternative 1a) and the dynamic baseline (Alternative 1b). The improvements in engine efficiency and road load, the increased use of APUs, and VMT rebound were included in the MOVES analysis. For this analysis, Method B also used the MOVES model for HD pickups and vans. 
The downstream criteria pollutant 
and air toxics impacts of the final program, relative to Alternative 1a, using analysis Method B, are presented in Table VIII–9. 
TABLE VIII–9—A NNUAL DOWNSTREAM IMPACTS ON CRITERIA POLLUTANTS AND AIRTOXICS FROM HEAVY -DUTYSECTOR  
INCALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1a U SING ANALYSIS METHOD Ba 
Pollutant CY2025 CY2040 CY2050 
US short 
tons % 
Change US short 
tons % 
Change US short 
tons % 
Change 
1,3-Butadiene ........................................... ¥1 ¥0.2 ¥3 ¥1.5 ¥3 ¥1.8 
Acetaldehyde ........................................... ¥3 ¥0.1 ¥18 ¥0.8 ¥23 ¥0.9 
Acrolein .................................................... ¥0.1 0 ¥1 ¥0.3 ¥1 ¥0.4 
Benzene ................................................... ¥5 ¥0.2 ¥22 ¥1.4 ¥26 ¥1.6 
CO ............................................................ ¥9,445 ¥0.4 ¥35,710 ¥2.4 ¥43,642 ¥2.7 
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761U.S. EPA. Updates to MOVES for Emissions 
Analysis of Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2 FRM. Docket No. 
EPA–HQ–OAR–2016, July 2016. TABLE VIII–9—A NNUAL DOWNSTREAM IMPACTS ON CRITERIA POLLUTANTS AND AIRTOXICS FROM HEAVY -DUTYSECTOR  
INCALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1a U SING ANALYSIS METHOD Ba—Continued 
Pollutant CY2025 CY2040 CY2050 
US short 
tons % 
Change US short 
tons % 
Change US short 
tons % 
Change 
Formaldehyde .......................................... ¥20 ¥0.2 ¥97 ¥1.5 ¥120 ¥1.7 
NO X.......................................................... ¥13,396 ¥1.4 ¥60,681 ¥9.7 ¥74,362 ¥10.8 
PM 2.5b...................................................... ¥73 ¥0.2 ¥462 ¥2.2 ¥580 ¥2.5 
SO X.......................................................... ¥252 ¥4.7 ¥1,122 ¥18.5 ¥1,341 ¥20.1 
VOC ......................................................... ¥1,071 ¥0.8 ¥5,060 ¥5.9 ¥6,013 ¥6.6 
Notes: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
bPM 2.5from tire wear and brake wear are included. 
As noted above, EPA is adopting 
Phase 1 and Phase 2 requirements to 
control PM 2.5emissions from APUs 
installed in new tractors. In the NPRM, EPA projected an unintended increase in downstream PM
2.5emissions because 
engines powering APUs are currently required to meet less stringent PM 
standards (40 CFR 1039.101) than on- road engines (40 CFR 86.007–11) and because the increase in emissions from 
APUs more than offset the reduced tailpipe emissions from improved engine efficiency and road load. However, with the new requirements for APUs, the final program is projected to lead to reduced downstream PM
2.5 
emissions of 462 tons in 2040 and 580 
tons in 2050 (Table VIII–9). The net reductions in national PM
2.5emissions from the requirements for APUs are 927 
tons and 1,114 tons in 2040 and 2050, respectively (Table VIII–10). See Section III.C.3 of the Preamble for additional details on EPA’s PM emission standards for APUs. The development of APU emission rates with PM control is documented in a memorandum to the docket.
761 
TABLE VIII–10—I MPACT ON PM 2.5EMISSIONS OF FURTHER PM 2.5CONTROL ON APU S—FINAL PROGRAM VS . ALT1a 
USING ANALYSIS METHOD B 
[US Short Tons]a 
CY Baseline na-
tional heavy- 
duty vehicle 
PM 2.5emis-
sions (tons) Final HD 
phase 2 pro-
gram national 
PM 2.5emis-
sions without 
further PM 
control (tons) Final HD 
phase 2 pro-
gram national 
PM 2.5emis-
sions with fur-
ther PM con-
trol (tons) Net impact on 
national PM 2.5 
emission with 
further PM 
control on 
APUs (tons) 
2040 ................................................................................................................. 20,939 21, 403 20,476 ¥927 
2050 ................................................................................................................. 22,995 23, 529 22,416 ¥1,114 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
It is worth noting that the emission 
reductions shown in Table VIII–9 are 
not incremental to the emissions reductions projected in the Phase 1 rulemaking. This is because, as 
described in Sections III.D.(1).a of the Preamble, the agencies have revised their assumptions about the adoption rate of APUs. This final rule assumes that without the Phase 2 program (i.e., in the Phase 2 baselines), the APU 
adoption rate will be 9 percent for model years 2010 and later. EPA conducted an analysis to estimate the combined emissions impacts of the 
Phase 1 and the Phase 2 programs for NO
X, VOC, SO Xand PM 2.5in calendar 
year 2050 using MOVES2014a. The results are shown in Table VIII–11. For NO
Xand PM 2.5only, we also estimated the combined Phase 1 and Phase 2 
downstream and upstream emissions impacts for calendar year 2025, and project that the two rules combined will reduce NO
Xby up to 55,000 tons and 
PM 2.5by up to 33,000 tons in that year. 
For additional details, see Chapter 5 of the RIA. 
TABLE VIII–11—C OMBINED PHASE 1 ANDPHASE 2 ANNUAL DOWNSTREAM IMPACTS ON CRITERIA POLLUTANTS FROM 
HEAVY -DUTYSECTOR IN CALENDAR YEAR2050—F INAL PROGRAM VS . ALT1a U SING ANALYSIS METHOD B 
[US Short Tons]a 
CY NO X VOC SO X PM 2.5b 
2050 ................................................................................................................. ¥100,878 ¥10,067 ¥2,249 ¥1,001 
Notes: 
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762A lifetime of 30 years is assumed in MOVES. 763U.S. EPA, 2011. Our Nation’s Air: Status and 
Trends through 2010. EPA–454/R–12–001. February 
2012. Available at: http://www3.epa.gov/airtrends/2011/. 
764Data come from Summary Nonattainment Area 
Population Exposure Report, current as of April 22, 2016 at: https://www3.epa.gov/airquality/greenbk/popexp.html and contained in Docket EPA–HQ– 
OAR–2014–0827. 765U.S. EPA. (2015) Summary of Results for the 
2011 National-Scale Assessment. https://www3.epa.gov/sites/production/files/2015-12/documents/2011-nata-summary-results.pdf . 
766Health Effects Institute Panel on the Health 
Effects of Traffic-Related Air Pollution. (2010) Traffic-related air pollution: A critical review of the literature on emissions, exposure, and health effects. HEI Special Report 17. Available at http:// 
www.healtheffects.org]. 
76770 FR 19844 (April 14, 2005). aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and more dynamic 
baseline, 1b, please see Section X.A.1. 
(iii) Total Impacts of the Final Program 
As shown in Table VIII–12, EPA 
estimates that the final program will result in overall net reductions of NO X, 
VOC, SO X, CO, PM 2.5, and air toxics 
emissions. The results are shown both 
in changes in absolute tons and in percent reductions from the flat 
reference to the final program for the heavy-duty sector. 
TABLE VIII–12—A NNUAL TOTAL IMPACTS (UPSTREAM AND DOWNSTREAM ) OFCRITERIA POLLUTANTS AND AIRTOXICS  
FROM HEAVY -DUTYSECTOR IN CALENDAR YEARS 2025, 2040 AND2050—F INAL PROGRAM VS . ALT1a U SING ANAL-
YSIS METHOD Ba 
Pollutant CY2025 CY2040 CY2050 
US short 
tons % 
Change US short 
tons % 
Change US short 
tons % 
Change 
1,3-Butadiene ........................................... ¥2 ¥0.5 ¥8 ¥3.7 ¥9 ¥4.1 
Acetaldehyde ........................................... ¥10 ¥0.3 ¥53 ¥2.0 ¥61 ¥2.1 
Acrolein .................................................... ¥1 ¥0.1 ¥4 ¥1.3 ¥5 ¥1.3 
Benzene ................................................... ¥35 ¥1.1 ¥165 ¥6.8 ¥192 ¥7.5 
CO ............................................................ ¥13,254 ¥0.6 ¥52,594 ¥3.3 ¥63,869 ¥3.8 
Formaldehyde .......................................... ¥40 ¥0.5 ¥187 ¥2.7 ¥227 ¥2.9 
NO X.......................................................... ¥22,710 ¥1.9 ¥101,961 ¥12.1 ¥123,824 ¥13.3 
PM 2.5........................................................ ¥1,110 ¥1.9 ¥5,081 ¥11.1 ¥6,100 ¥12.1 
SO X.......................................................... ¥6,080 ¥4.8 ¥26,933 ¥18.9 ¥32,282 ¥20.5 
VOC ......................................................... ¥5,305 ¥2.2 ¥25,070 ¥11.9 ¥29,253 ¥13.0 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(b) Model Year Lifetime Analysis 
In addition to the annual non-GHG 
emissions reductions expected from the final rules, EPA estimated the combined (downstream and upstream) non-GHG impacts for the lifetime of the impacted vehicles. Table VIII–13 shows the fleet- wide reductions of NO
X, PM 2.5and SO X 
from the final program, relative to Alternative 1a, through the lifetime
762 
of heavy-duty vehicles. For the lifetime non-GHG reductions by vehicle categories, see Chapter 5 of the RIA. 
TABLE VIII–13—L IFETIME NON-GHG 
REDUCTIONS USING ANALYSIS  
METHOD B—S UMMARY FOR MODEL  
YEARS 2018–2029 
[U.S. Short Tons]a 
No-action alternative 
(baseline) Final program 
1a (Flat) 
NO X...................................... 549,881 
Downstream .................. 277,644 
Upstream ....................... 272,237 
PM 2.5..................................... 32,251 
Downstreamb................ 1,824 
Upstream ....................... 30,427 
SO X....................................... 175,202 
Downstream .................. 4,931 
Upstream ....................... 170,272 
Note: aFor an explanation of analytical Methods A 
and B, please see Section I.D; for an expla-
nation of the flat baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1. 
bPM 2.5from tire wear and brake wear are 
included. 
D. Air Quality Impacts of Non-GHG 
Pollutants 
Changes in emissions of non-GHG 
pollutants due to these rules will impact air quality. Information on current air quality and the results of our air quality modeling of the projected impacts of these rules are summarized in the following section. Additional 
information is available in Chapter 6 of the RIA. 
(1) Current Concentrations of Non-GHG 
Pollutants 
Nationally, levels of PM
2.5, ozone, 
NO X, SO X, CO and air toxics are 
declining.763However, as of April 22, 
2016, more than 125 million people lived in counties designated nonattainment for one or more of the NAAQS, and this figure does not include the people living in areas with a risk of exceeding a NAAQS in the future.
764Many Americans continue to be exposed to ambient concentrations of 
air toxics at levels which have the 
potential to cause adverse health effects.
765In addition, populations who 
live, work, or attend school near major roads experience elevated exposure concentrations to a wide range of air pollutants.
766 
(a) Particulate Matter 
There are two primary NAAQS for 
PM 2.5: An annual standard (12.0 
micrograms per cubic meter (mg/m3)) set 
in 2012 and a 24-hour standard (35 mg/ m
3) set in 2006, and two secondary 
NAAQS for PM 2.5: An annual standard 
(15.0 mg/m3) set in 1997 and a 24-hour 
standard (35 mg/m3) set in 2006. 
There are many areas of the country 
that are currently in nonattainment for the annual and 24-hour primary PM
2.5 
NAAQS. In 2005 the EPA designated 39 nonattainment areas for the 1997 PM
2.5 
NAAQS.767As of April 22, 2016, more 
than 23 million people lived in the 7 areas that are still designated as nonattainment for the 1997 annual PM
2.5NAAQS. These PM 2.5 
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768EPA 2014. Fact Sheet: Final Area Designations 
for the Annual Fine Particle Standard. https://
www3.epa.gov/pmdesignations/2012standards/
final/20141218fs.pdf . 
769https://www3.epa.gov/pmdesignations/
2012standards/final/20150331fs.pdf . 
77074 FR 58688 (November 13, 2009) and 76 FR 
6056 (February 3, 2011). 
771The 39 million total is calculated by summing, 
without double counting, the 1997, 2006 and 2012 
PM 2.5nonattainment populations contained in the 
Summary Nonattainment Area Population Exposure report (https://www3.epa.gov/airquality/greenbk/popexp.html). If there is a population associated with more than one of the 1997, 2006 and 2012 nonattainment areas, and they are not the same, then the larger of the populations is included in the sum. 772The final Phase 2 trailer standards and PM 
controls for APUs begin with model year 2018. 
77377 FR 30088 (May 21, 2012) and 77 FR 34221 
(June 11, 2012). 
774https://www3.epa.gov/ozone-pollution/2015- 
ozone-naaqs-timelines. 
775The final Phase 2 trailer standards begin with 
model year 2018. 776U.S. EPA. (2012). Fact Sheet—Air Quality 
Designations for the 2010 Primary Nitrogen Dioxide 
(NO 2) National Ambient Air Quality Standards. 
http://www3.epa.gov/airquality/nitrogenoxides/
designations/pdfs/20120120FS.pdf. 
777U.S. Environmental Protection Agency (2013). 
Revision to Ambient Nitrogen Dioxide Monitoring Requirements. March 7, 2013. http://www3.epa.gov/ 
airquality/nitrogenoxides/pdfs/20130307fr.pdf . 
778Sierra Club v. McCarthy, No. 3–13–cv–3953 
(SI) (N.D. Cal. Mar. 2, 2015). nonattainment areas are comprised of 33 
full or partial counties. In December 2014 EPA designated 14 nonattainment areas for the 2012 annual PM
2.5 
NAAQS.768In March 2015, EPA 
changed the initial designation from nonattainment to unclassifiable/ attainment for four areas based on the availability of complete, certified 2014 air quality data showing these areas met the 2012 annual PM
2.5NAAQS. The 
EPA also changed the initial 2012 annual PM
2.5NAAQS designation from 
nonattainment to unclassifiable for the Louisville, Indiana-Kentucky area. 
769 
As of April 22, 2016, 9 of these areas remain designated as nonattainment, and they are composed of 20 full or partial counties with a population of over 23 million. On November 13, 2009 and February 3, 2011, the EPA designated 32 nonattainment areas for the 2006 24-hour PM
2.5NAAQS.770As 
of April 22, 2016, 16 of these areas remain designated as nonattainment for the 2006 24-hour PM
2.5NAAQS, and 
they are composed of 46 full or partial counties with a population of over 32 million. In total, there are currently 24 PM
2.5nonattainment areas with a 
population of more than 39 million people.
771 
The EPA has already adopted many 
mobile source emission control programs that are expected to reduce ambient PM concentrations. As a result of these and other federal, state and local programs, the number of areas that fail to meet the PM
2.5NAAQS in the 
future is expected to decrease. However, even with the implementation of all current state and federal regulations, there are projected to be counties violating the PM
2.5NAAQS well into the 
future. States will need to meet the 2006 24-hour standards in the 2015–2019 timeframe and the 2012 primary annual standard in the 2021–2025 timeframe. The emission reductions and improvements in ambient PM
2.5 
concentrations from this action, which will take effect as early as model year 2018, will be helpful to states as they work to attain and maintain the PM
2.5 
NAAQS.772The standards can assist 
areas with attainment dates in 2018 and beyond in attaining the NAAQS as expeditiously as practicable and may relieve areas with already stringent local regulations from some of the burden associated with adopting additional local controls. 
(b) Ozone 
The primary and secondary NAAQS 
for ozone are 8-hour standards with a 
level of 0.07 ppm. The most recent revision to the ozone standards was in 2015; the previous 8-hour ozone primary standard, set in 2008, had a level of 0.075 ppm. Final nonattainment designations for the 2008 ozone standard were issued on April 30, 2012, and May 31, 2012.
773As of April 22, 
2016, there were 44 ozone nonattainment areas for the 2008 ozone NAAQS, composed of 216 full or partial counties, with a population of more than 120 million. In addition, EPA plans to finalize nonattainment areas for the 2015 ozone NAAQS in October 2017. 
States with ozone nonattainment 
areas are required to take action to bring those areas into attainment. The attainment date assigned to an ozone nonattainment area is based on the area’s classification. The attainment 
dates for areas designated nonattainment for the 2008 8-hour ozone NAAQS are in the 2015 to 2032 timeframe, depending on the severity of the problem in each area. Nonattainment area attainment dates associated with areas designated for the 2015 NAAQS will be in the 2020–2037 timeframe, depending on the severity of the problem in each area.
774 
EPA has already adopted many 
emission control programs that are expected to reduce ambient ozone levels. As a result of these and other federal, state and local programs, 8-hour ozone levels are expected to improve in the future. However, even with the implementation of all current state and federal regulations, there are projected to be counties violating the ozone NAAQS well into the future. The emission reductions from this action, which will take effect as early as model year 2018, will be helpful to states as they work to attain and maintain the ozone NAAQS.
775The standards can 
assist areas with attainment dates in 2018 and beyond in attaining the 
NAAQS as expeditiously as practicable and may relieve areas with already stringent local regulations from some of the burden associated with adopting additional local controls. 
(c) Nitrogen Dioxide 
The EPA most recently completed a 
review of the primary NAAQS for NO
2 
in January 2010. There are two primary 
NAAQS for NO 2: An annual standard 
(53 ppb) and a 1-hour standard (100 ppb). The EPA promulgated area designations in the Federal Register on February 17, 2012. In this initial round of designations, all areas of the country were designated as ‘‘unclassifiable/ attainment’’ for the 2010 NO
2NAAQS 
based on data from the existing air quality monitoring network. The EPA and state agencies are working to establish an expanded network of NO
2 
monitors, expected to be deployed in the 2014–2017 time frame. Once three years of air quality data have been collected from the expanded network, the EPA will be able to evaluate NO
2air 
quality in additional locations.776 777  
(d) Sulfur Dioxide 
The EPA most recently completed a 
review of the primary SO 2NAAQS in 
June 2010. The current primary NAAQS for SO
2is a 1-hour standard of 75 ppb. 
The EPA finalized the initial area designations for 29 nonattainment areas in 16 states in a notice published in the Federal Register on August 5, 2013. In this first round of designations, EPA only designated nonattainment areas that were violating the standard based on existing air quality monitoring data provided by the states. The agency did not have sufficient information to designate any area as ‘‘attainment’’ or make final decisions about areas for which additional modeling or monitoring is needed (78 FR 47191, August 5, 2013). On March 2, 2015, the U.S. District Court for the Northern District of California accepted, as an enforceable order, an agreement between the EPA and Sierra Club and Natural Resources Defense Council to resolve litigation concerning the deadline for completing designations.
778 
The court’s order directs the EPA to complete designations for all remaining 
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779U.S. EPA (2015) 2011 National-Scale Air 
Toxics Assessment. https://www3.epa.gov/national- 
air-toxics-assessment/2011-nata-assessment-results#emissions. 780U.S. Environmental Protection Agency (2007). 
Control of Hazardous Air Pollutants from Mobile Sources; Final Rule. 72 FR 8434, February 26, 2007. 
781U.S. EPA. (2015) 2011 NATA: Assessment 
Results. https://www3.epa.gov/national-air-toxics- 
assessment/2011-nata-assessment-results . 
782NATA also includes estimates of risk 
attributable to background concentrations, which includes contributions from long-range transport, persistent air toxics, and natural sources; as well as secondary concentrations, where toxics are formed via secondary formation. Mobile sources substantially contribute to long-range transport and secondarily formed air toxics. 783The range of Social Cost of Carbon (SC–CO 2) 
values uses several discount rates because the literature shows that the SC–CO
2is quite sensitive 
to assumptions about the discount rate, and because no consensus exists on the appropriate rate to use in an intergenerational context (where costs and benefits are incurred by different generations). Refer to Section IX.F.1 for more information. areas in the country in up to three 
additional rounds: The first round by July 2, 2016, the second round by December 31, 2017, and the final round by December 31, 2020. 
(e) Carbon Monoxide 
There are two primary NAAQS for 
CO: An 8-hour standard (9 ppm) and a 
1-hour standard (35 ppm). The primary NAAQS for CO were retained in August 2011. There are currently no CO nonattainment areas; as of September 27, 2010, all CO nonattainment areas have been redesignated to attainment. 
The past designations were based on 
the existing community-wide monitoring network. EPA is making changes to the ambient air monitoring requirements for CO. The new requirements are expected to result in approximately 52 CO monitors operating near roads within 52 urban areas by January 2015 (76 FR 54294, August 31, 2011). 
(f) Diesel Exhaust PM 
Because DPM is part of overall 
ambient PM and cannot be easily 
distinguished from overall PM, we do not have direct measurements of DPM in the ambient air. DPM concentrations are estimated using ambient air quality modeling based on DPM emission inventories. DPM emission inventories are computed as the exhaust PM emissions from mobile sources combusting diesel or residual oil fuel. DPM concentrations were recently estimated as part of the 2011 NATA.
779 
Areas with high concentrations are clustered in the Northeast, Great Lake States, California, and the Gulf Coast States and are also distributed throughout the rest of the U.S. The median DPM concentration calculated nationwide is 0.76 mg/m
3. Half of the 
DPM can be attributed to heavy-duty diesel vehicles. 
(g) Air Toxics 
The most recent available data 
indicate that the majority of Americans 
continue to be exposed to ambient concentrations of air toxics at levels which have the potential to cause adverse health effects. The levels of air toxics to which people are exposed vary depending on where people live and 
work and the kinds of activities in which they engage, as discussed in detail in EPA’s most recent Mobile Source Air Toxics Rule.
780According to 
the National Air Toxic Assessment 
(NATA) for 2011, mobile sources were responsible for 50 percent of outdoor anthropogenic toxic emissions and were the largest contributor to cancer and noncancer risk from directly emitted pollutants.
781 782 Mobile sources are also 
large contributors to precursor 
emissions which react to form air toxics. Formaldehyde is the largest contributor to cancer risk of all 71 pollutants quantitatively assessed in the 2011 NATA. Mobile sources were responsible for more than 25 percent of primary anthropogenic emissions of this pollutant in 2011 and are major contributors to formaldehyde precursor emissions. Benzene is also a large contributor to cancer risk, and mobile sources account for almost 80 percent of ambient exposure. Over the years, EPA has implemented a number of mobile source and fuel controls which have resulted in VOC reductions, which also reduced formaldehyde, benzene and other air toxic emissions. 
(2) Impacts of the Rule on Projected Air 
Quality 
Along with reducing GHGs, the Phase 
2 standards also have an impact on non- GHG, criteria and air toxic pollutant, emissions. As shown above in Section VIII.C, the standards will impact exhaust emissions of these pollutants from vehicles and will also impact emissions that occur during the refining and distribution of fuel (upstream sources). Reductions in emissions of NO
X, VOC, PM 2.5and air toxics 
expected as a result of the Phase 2 standards will lead to improvements in air quality, specifically decreases in ambient concentrations of PM
2.5, ozone, 
NO 2and air toxics, as well as better 
visibility and reduced deposition. 
Emissions and air quality modeling 
decisions are made early in the analytical process because of the time and resources associated with full-scale photochemical air quality modeling. As a result, the inventories used in the air quality modeling and the benefits modeling are different from the final emissions inventories presented in Section VIII.C. The air quality inventories and the final inventories are consistent in many ways, but there are some important differences. For example, in this final rulemaking, EPA is adopting Phase 1 and Phase 2 requirements to control PM
2.5emissions 
from APUs installed in new tractors, so we do not expect increases in downstream PM
2.5emissions from the 
Phase 2 program; however, the air quality inventories do not reflect these requirements and therefore show increases in downstream PM
2.5 
emissions. Chapter 5 of the RIA has more detail on the differences between the air quality and final inventories. The results of our air quality modeling of the criteria pollutant and air toxics impacts of the Phase 2 standards are summarized in the RIA and presented in more detail in Appendix 6A to the RIA. 
IX. Economic and Other Impacts 
This section presents the costs, 
benefits and other economic impacts of 
the Phase 2 standards. It is important to note that NHTSA’s fuel consumption standards and EPA’s GHG standards will both be in effect, and each will lead to average fuel efficiency increases and GHG emission reductions. 
The net benefits of the Phase 2 
standards consist of the effects of the program on: 
•vehicle program costs (costs of 
complying with the vehicle CO
2and 
fuel consumption standards) 
•changes in fuel expenditures 
associated with reduced fuel use 
resulting from more efficient vehicles and increased fuel use associated with the ‘‘rebound’’ effect, both of which result from the program 
•economic value of reductions in 
GHGs 
•economic value of reductions in non- 
GHG pollutants 
•costs associated with increases in 
noise, congestion, and crashes resulting from increased vehicle use 
•savings in drivers’ time from less 
frequent refueling 
•benefits of increased vehicle use 
associated with the ‘‘rebound’’ effect 
•economic value of improvements in 
U.S. energy security 
The benefits and costs of these rules 
are analyzed using 3 percent and 7 
percent discount rates, consistent with current OMB guidance.
783These rates 
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784This approach describes the economic concept 
of compensating variation, a payment of money 
after a change that would make a consumer as well off after the change as before it. A related concept, equivalent variation, estimates the income change that would be an alternative to the change taking place. The difference between them is whether the consumer’s point of reference is her welfare before the change (compensating variation) or after the change (equivalent variation). In practice, these two measures are typically very close together. 
785Indeed, it is likely to be an overestimate of the 
loss to the consumer, because the buyer has choices other than buying the same vehicle with a higher price; she could choose a different vehicle, or decide not to buy a new vehicle. The buyer would choose one of those options only if the alternative involves less loss than paying the higher price. Thus, the increase in price that the buyer faces would be the upper bound of loss of consumer welfare, unless there are other changes to the 
vehicle due to the fuel efficiency improvements that make the vehicle less desirable to consumers. 
786Environmental Protection Agency and 
Department of Transportation, ‘‘Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards; Final Rule,’’ 75 FR 25324, May 7, 2010, especially Sections III.H.1 (25510–25513) and IV.G.6 (25651–25657); Environmental Protection Agency and Department of Transportation, ’’2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and 
Corporate Average Fuel Economy Standards; Final Rule,’’ 77 FR 62624, October 15, 2012, especially Sections III.H.1 (62913–62919) and IV.G.5.a (63102– 63104). 
787State of Massachusetts v. EPA, 549 U.S. at 
533. are intended to represent consumers’ 
preference for current over future consumption (3 percent), and the real rate of return on private investment (7 percent) which indicates the opportunity cost of capital. However, neither of these rates necessarily represents the discount rate that individual decision-makers use. 
The program may also have other 
economic effects that are not included here. As discussed in Sections III through VI of this Preamble and in Chapter 2 of the RIA, the technology cost estimates developed here take into account the costs to hold other vehicle attributes, such as size and performance, constant. With these assumptions, and because welfare losses represent monetary estimates of how much buyers would have to be compensated to be made as well off as they would have been in the absence of this regulation,
784 
price increases for new vehicles measure the welfare losses to the vehicle buyers.
785If the full technology 
cost gets passed along to the buyer as an increase in price, the technology cost thus measures the primary welfare loss of the standards, including impacts on buyers. Increasing fuel efficiency would have to lead to other changes in the vehicles that buyers find undesirable for there to be additional welfare losses that are not included in the technology costs. 
As the 2012–2016 and 2017–2025 
light-duty GHG/CAFE rules discussed, if other vehicle attributes are not held constant, then the technology cost estimates do not capture the losses to vehicle buyers associated with these changes.
786The light-duty rules also discussed other potential issues that 
could affect the calculation of the welfare impacts of these types of changes, such as aspects of buyers’ behavior that might affect the demand for technology investments, uncertainty in buyers’ investment horizons, and the rate at which truck owner’s trade off higher vehicle purchase price against future fuel savings. 
Where possible, we identify the 
uncertain aspects of these economic impacts and attempt to quantify them (e.g., sensitivity ranges associated with 
quantified and monetized GHG impacts; range of dollar-per-ton values to monetize non-GHG health benefits; uncertainty with respect to learning and markups). The agencies have examined the sensitivity of oil prices on fuel expenditures; results of this sensitivity analysis can be found in Chapter 8 of the RIA. NHTSA’s EIS also characterizes the uncertainty in economic impacts associated with the HD national program. For other impacts, however, there is inadequate information to inform a thorough, quantitative assessment of uncertainty. EPA and NHTSA continue to work toward developing a comprehensive strategy for characterizing the aggregate impact of uncertainty in key elements of its analyses and we will continue to work to refine these uncertainty analyses in the future as time and resources permit. 
This and other sections of the 
Preamble address Section 317 of the Clean Air Act on economic analysis. Section IX.L addresses Section 321 of the Clean Air Act on employment analysis. The total monetized benefits and costs of the program are summarized in Section IX.K for the final program and in Section X for all alternatives. 
The agencies sought comment on 
numerous aspects of the analyses presented in this section, such as the potential omissions of costs or benefits, additional impacts of the standards on vehicle attributes and performance, and the quantification of uncertainty. Responses to comments on specific aspects of the analysis are addressed as appropriate in the relevant sections below, and in Sections III through VI of this Preamble as they relate to certain technologies. Further detail can be found in Section 11 of the RTC. 
A. Conceptual Framework 
The HD Phase 2 standards will 
implement both the 2007 Energy Independence and Security Act 
requirement that NHTSA establish fuel efficiency standards for medium- and heavy-duty vehicles and the Clean Air Act requirement that EPA adopt technology-based standards to control pollutant emissions from motor vehicles and engines contributing to air pollution that endangers public health and welfare. NHTSA’s statutory mandate is intended to further the agency’s long- standing goals of reducing U.S. consumption and imports of petroleum energy to improve the nation’s energy security. 
From an economics perspective, 
government actions to improve our nation’s energy security and to protect our nation from the potential threats of climate change address ‘‘externalities,’’ or economic consequences of decisions by individuals and businesses that extend beyond those who make these decisions. For example, users of transportation fuels increase the entire U.S. economy’s risk of having to make costly adjustments due to rapid increases in oil prices, but these users generally do not consider such costs when they decide to consume more fuel. 
Similarly, consuming transportation 
fuel also increases emissions of greenhouse gases and other more localized air pollutants that occur when 
fuel is refined, distributed, and consumed. Some of these emissions increase the likelihood and severity of potential climate-related economic damages, and others cause economic damages by adversely affecting human health. The need to address these external costs and other adverse effects provides a well-established economic rationale that supports the statutory direction given to government agencies to establish regulatory programs that reduce the magnitude of these adverse effects at reasonable costs. 
The Phase 2 standards will require 
manufacturers of new heavy-duty vehicles, including trailers (HDVs), to improve the fuel efficiency of the products that they produce. As HDV users purchase and operate these new vehicles, they will consume significantly less fuel, in turn reducing U.S. petroleum consumption and imports as well as emissions of GHGs and other air pollutants. Thus, as a consequence of the agencies’ efforts to meet our statutory obligations to improve U.S. energy security and EPA’s obligation to issue standards ‘‘to regulate emissions of the deleterious pollutant . . . from motor vehicles’’ that endangers public health and welfare,
787 
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788Klemick, Heather, Elizabeth Kopits, Keith 
Sargent, and Ann Wolverton (2015). ‘‘Heavy-Duty 
Trucking and the Energy Efficiency Paradox: Evidence form Focus Groups and Interviews.’’ Transportation Research Part A 77: 154–166, Docket EPA–HQ–OAR–2014–0827; Roeth, Mike, Dave Kircher, Joel Smith, and Rob Swim (2013). ‘‘Barriers to the Increased Adoption of Fuel Efficiency Technologies in the North American On- Road Freight Sector.’’ NACFE report for the International Council on Clean Transportation, 
Continued the fuel efficiency and GHG emission 
standards will also reduce HDV operators’ outlays for fuel purchases. These fuel savings are one measure of the final rule’s effectiveness in promoting NHTSA’s statutory goal of conserving energy, as well as EPA’s obligation under section 202(a)(1) and (2) of the Clean Air Act to assess the cost of standards. Although these savings are not the agencies’ primary motivation for adopting higher fuel efficiency standards, these substantial fuel savings represent significant additional economic benefits of these rules. 
Potential savings in fuel costs appear 
to offer HDV buyer’s strong incentives to pay higher prices for vehicles that feature technology or equipment that reduces fuel consumption. These potential savings also appear to offer HDV manufacturers similarly strong incentives to produce more fuel- efficient vehicles. Economic theory suggests that interactions between vehicle buyers and sellers in a normally- functioning competitive market would lead HDV manufacturers to incorporate all technologies that contribute to lower net costs into the vehicles they offer, and buyers to purchase them willingly. Nevertheless, many readily available technologies that appear to offer cost- effective increases in HDV fuel efficiency (when evaluated over their expected lifetimes using conventional discount rates) have not been widely adopted, despite their potential to repay buyers’ initial investments rapidly. 
This economic situation is commonly 
known as the ‘‘energy efficiency gap’’ or ‘‘energy paradox.’’ This situation is perhaps more challenging to understand with respect to the heavy-duty sector versus the light-duty vehicle sector. Unlike light-duty vehicles—which are purchased and used mainly by individuals and households—the vast majority of HDVs are purchased and operated by profit-seeking businesses for which fuel costs represent a substantial operating expense. We asked for comments on our hypotheses about causes of the gap, as well as data or other information that can inform our understanding of why this situation seems to persist. The California Air Resources Board, CALSTART, Consumer Federation of America, Institute for Policy Integrity at NYU School of Law, and International Council on Clean Transportation supported, either in whole or in part, the agencies’ arguments for potential barriers to market adoption. Caterpillar Inc. et al., Competitive Enterprise Institute (CEI), Randall Lutter, Brian 
Mannix, NAFA Fleet Management Association (NAFA), Owner-Operator Independent Drivers Association 
(OOIDA), Truck Renting and Leasing Association (TRALA), and Utility Trailer Manufacturing Company express skepticism or raise concerns about the agencies’ discussion. The skeptical comments, discussed in more depth in context below, generally find it implausible that regulations can save money for profit-seeking businesses. If the savings were real, they argue, then private markets would have adopted these technologies without regulations; the agencies must therefore have exaggerated the benefits or underestimated the costs of the standards. Problems exist not in private market operations, they claim, but rather in the economic analysis of those operations. 
The economic analysis of these 
standards is based on the engineering analysis of the costs and effectiveness of the technologies. The agencies have detailed their findings on costs and effectiveness in Preamble Sections III, IV, V, and VI, and RIA Chapter 2. If these cost and effectiveness estimates are correct, and if the agencies have not omitted key costs or benefits, then the efficiency gap exists, even if it seems implausible to some. As will be discussed further below, comments that raise issues with that technical analysis, such as concerns about maintenance and reliability costs of the technologies, present possible reasons that the gap is not as large as the agencies have found, and are discussed in the cost and effectiveness sections mentioned above. Comments that question the explanations provided for the gap without addressing the cost and effectiveness analyses do not provide evidence of an absence of the gap. Explaining why the gap exists is a separate and difficult challenge from observing the existence of the gap, because of the difficulties involved in developing tests of the different possible explanations. As discussed below, there is very little empirical evidence on behaviors that might lead to the gap, even while there continues to be substantial evidence, via the cost and effectiveness analysis, of the gap’s existence. On the basis of that evidence, the agencies believe that a significant number of fuel efficiency improving technologies would remain far less widely adopted in the absence of these standards. 
Economic research offers several 
possible explanations for why the prospect of these apparent savings might not lead HDV manufacturers and buyers to adopt technologies that would 
be expected to reduce HDV operating costs. Some of these explanations involve failures of the HDV market for 
reasons other than the externalities caused by producing and consuming fuel. Examples include situations where information about the performance of fuel economy technologies is incomplete, costly to obtain, or available only to one party to a transaction (or ‘‘asymmetrical’’), as well as behavioral rigidities in either the HDV manufacturing or HDV-operating industries, such as standardized or inflexibly administered operating procedures, or requirements of other regulations on HDVs. Examples that do not involve market failures include possible effects on the performance, reliability, carrying capacity, maintenance requirements of new 
technology under the demands of everyday use, or transaction or adjustment costs. We note again that these and other hypotheses are presented as potential explanations of the finding of an efficiency gap based on an engineering analysis. They are not themselves the basis for regulation. 
In the HD Phase 1 rulemaking (which, 
in contrast to these standards, did not apply to trailers), and in the Phase 2 NPRM, the agencies raised various hypotheses that might explain this energy efficiency gap or paradox. 
•Imperfect information in the new 
vehicle market: Information available to prospective buyers about the effectiveness of some fuel-saving technologies for new vehicles may be inadequate or unreliable. If reliable information on their effectiveness in reducing fuel consumption is unavailable or difficult to obtain, HDV buyers will understandably be reluctant to pay higher prices to purchase vehicles equipped with unproven technologies. 
Some commenters argue that this 
explanation implies implausibly that the agencies have information that those with profit motives do not, and that EPA’s SmartWay Program has already served the function of sharing public information with the private sector. Other commenters agree with the agencies that imperfect information is a potential market barrier. 
As discussed in the NPRM, one 
common theme from recent research
788 
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Docket EPA–HQ–OAR–2014–0827–0084; Aarnink, 
Sanne, Jasper Faber, and Eelco den Boer (2012). ‘‘Market Barriers to Increased Efficiency in the European On-road Freight Sector.’’ CE Delft report for the International Council on Clean Transportation, Docket EPA–HQ–OAR–2014–0827– 0076. 
789Committee to Assess Fuel Economy 
Technologies for Medium- and Heavy-Duty Vehicles; National Research Council; Transportation Research Board (2010). ‘‘Technologies and Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty Vehicles,’’ (hereafter, ‘‘NAS 2010’’). Washington, DC The National Academies Press. Available electronically from the National Academies Press Web site at http://www.nap.edu/ catalog.php?record_ id=12845 (accessed September 
10, 2010), Docket EPA–HQ–OAR–2014–0827–0122. 
790Fraas, Art, Randall Lutter, Zachary Porter, and 
Alexander Wallace (2016). ‘‘The Energy Paradox and the Adoption of Energy-Saving Technologies in the Trucking Industry.’’ Working Paper, Mercatus Center, George Mason University, Docket EPA–HQ– OAR–2014–0827–1879. 791Vernon, David and Alan Meier (2012). 
‘‘Identification and quantification of principal-agent problems affecting energy efficiency investments and use decisions in the trucking industry.’’ Energy Policy, 49(C), pp. 266–273, Docket EPA–HQ–OAR– 2014–0827–0090. is the inability of HDV buyers to obtain 
reliable information about the fuel 
savings, reliability, and maintenance costs of technologies that improve fuel efficiency. See 80 FR 40436. In the trucking industry, the performance of fuel-saving technology is likely to depend on many firm-specific attributes, including the intensity of HDV use, the typical distance and routing of HDV trips, driver characteristics, road conditions, regional geography and traffic patterns. As a result, businesses that operate HDVs have strong preferences for testing fuel- saving technologies ‘‘in-house’’ because they are concerned that their patterns of vehicle use may lead to different results from those reported in published information. Businesses with less capability to do in-house testing often seek information from peers, yet often remain skeptical of its applicability due to differences in the nature of their operations. 
•Imperfect information in the resale 
market: Buyers in the used vehicle market may not be willing to pay adequate premiums for more fuel efficient vehicles when they are offered for resale to ensure that buyers of new vehicles can recover the remaining value of their original investment in higher fuel efficiency. The prospect of an inadequate return on their original owners’ investments in higher fuel efficiency may contribute to the short payback periods that buyers of new vehicles appear to demand.
789 
CEI rejects this hypothesis, asserting 
that buyers in this market do consider the value of technologies on used vehicles; other commenters support this possibility. 
The recent research cited above 
(Klemick et al. 2015, Roeth et al. 2013, Aarnink et al. 2012) found mixed evidence for imperfect information in the market for used HDVs. On the one hand, some studies noted that fuel- saving technology is often not appreciated in the used vehicle market, because of imperfect information about 
its benefits, or greater mistrust of its performance among buyers in the used vehicle market than among buyers of new vehicles. When buyers of new vehicles considered features that would affect value in the secondary market, those features were rarely related to fuel economy. In addition, some used- vehicle buyers might have a larger ‘‘knowledge gap’’ than new-vehicle buyers. In other cases, the lack of interest might be due to the intended use of the used HDVs, which may not reward the presence of certain fuel- saving technologies. In other cases, however, fuel-saving technology can lead to a premium in the used market, as for instance to meet the more stringent requirements for HDVs operating in California. 
•Principal-agent problems causing 
split incentives: An HDV buyer may not be directly responsible for its future fuel costs, or the individual who will be responsible for fuel costs may not participate in the HDV purchase decision. In these cases, the signal to invest in higher fuel efficiency normally provided by savings in fuel costs may not be transmitted effectively to HDV buyers, and the incentives of HDV buyers and fuel buyers will diverge, or be ‘‘split.’’ The trailers towed by heavy- duty tractors, which are typically not supplied by the tractor manufacturer or seller, present an obvious potential situation of split incentives that was not addressed in the HD Phase 1 rulemaking, but which may apply in this rulemaking. If there is inadequate pass-through of price signals from trailer users to their buyers, then low adoption of fuel-saving technologies may result. 
CEI argues that, even if these split 
incentives existed, vehicle purchasers still might not invest in fuel-saving technologies due to capital constraints. As discussed below, capital constraints may be an issue for smaller companies, but they do not appear to be a significant concern for larger companies. Mr. Lutter provides a working paper
790in which the authors 
do not find a statistically significant or negative relationship when the box trailer has different ownership than the tractor, a result that does not support evidence of the split-incentives problem between tractors and trailers. As the papers below discuss, the split- incentives problem can take more forms 
than the difference in ownership between tractors and box trailers 
examined in this comment. 
Other recent research identifies split 
incentives, or principal-agent problems, as a potential barrier to technology adoption. For instance, Vernon and Meier (2012) estimate that 23 percent of trailers may be exposed to split incentives due to businesses that own and lease trailers to HDV operators not having an incentive to invest in trailer- specific fuel-saving technology.
791They 
also estimate that 5 percent of HDV fuel use is subject to split incentives that arise when the firm paying fuel costs does not make the tractor investment decision (e.g., because a carrier 
subcontracts to an owner-operator but still pays for fuel). As CEI points out, in the case of a split incentive when the driver is not responsible for paying fuel costs, the owner is the principal who seeks fuel savings, and the driver is the agent with potentially low incentive to provide those savings; there are a number of potential sources of inefficiency in fuel use, though not all of them are expected to result in underinvestment in fuel-saving technologies. Vernon and Meier (2012) do not quantify the financial significance of these problems. 
Klemick et al. (2015), Aarnink et al. 
(2012), and Roeth et al. (2013) provide mixed evidence on the severity of the split-incentive problem. Focus groups often identify diverging incentives between drivers and the decision- makers responsible for purchasing vehicles. Aarnink et al. (2012) and Roeth et al. (2013) cite examples of split incentives involving trailers and fuel surcharges, although the latter also cites other examples where these same issues do not lead to split incentives. In an effort to minimize problems that can arise from split incentives, many businesses that operate HDVs also train drivers in the use of specific technologies or to modify their driving behavior in order to improve fuel efficiency, while some also offer financial incentives to their drivers to conserve fuel. All of these options can 
help to reduce the split incentive problem. 
•Uncertainty about future fuel cost 
savings: HDV buyers may be uncertain about future fuel prices, or about maintenance costs and reliability of some fuel efficiency technologies. In contrast, the costs of fuel-saving technologies are immediate. If buyers 
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792The distinction between simply requiring 
drivers (or mechanics) to adjust their expectations 
and compromises in vehicle performance or utility is subtle. While the former may not impose significant compliance costs in the long run, the latter would represent additional economic costs of complying with the standard. are loss-averse, they may react to this 
uncertainty by underinvesting in technologies to improve fuel economy. In this situation, potential variability about buyers’ expected returns on capital investments to achieve higher fuel efficiency may shorten the payback period—the time required to repay those investments—they demand in order to make them. 
Various commenters support this 
hypothesis. The CEI draws on the experience of nitrogen oxides (NO
X) 
regulations from 2004 and 2007 to support its arguments. As discussed more below, the NO
Xstandards are 
unlikely to provide much, if any, precedential value for the GHG/fuel economy standards. Other commenters raise questions related to uncertainty about future costs for fuel and maintenance, as well as about the reliability of new technology that could result in costly downtime. Section IX.D. below discusses maintenance expenditures under these standards. These examples illustrate the problem of uncertain or unreliable information about the actual performance of fuel efficiency technology discussed above. Roeth et al. (2013) and Klemick et al. (2015) both document the short payback periods that HDV buyers require on their investments—usually about 2 years—which may be partly attributable to these uncertainties. 
•Adjustment and transactions costs: 
Potential resistance to new technologies—stemming, for example, from drivers’ reluctance or slowness to adjust to changes in the way vehicles operate—may slow or inhibit new technology adoption. If a conservative approach to new technologies leads HDV buyers to adopt them slowly, then successful new technologies will be adopted over time without market intervention, but only with potentially significant delays in achieving the fuel saving, environmental, and energy security benefits they offer. There also may be costs associated with training drivers to realize potential fuel savings enabled by new technologies, or with accelerating fleet operators’ scheduled fleet turnover and replacement to hasten their acquisition of vehicles equipped with these technologies. These factors might present real resource costs to firms that are not reflected in a typical engineering analysis. 
CEI argues that these costs are normal 
aspects of the innovation process, and competition continually drives firms to innovate in most industries. As discussed below, innovation is not always a continual and smooth response to competition as CEI suggests. Klemick et al. (2015), Roeth et al. 
(2013), and Aarnink et al. (2012) 
provide some support for the view that adjustment and transactions costs may impede HDV buyers from investing in higher fuel efficiency. These studies note that HDV buyers are less likely to select new technology when it is not available from their preferred manufacturers. Some technologies are only available as after-market additions, which can add other costs to adopting them. 
•Driver acceptance of new 
equipment or technologies as a barrier to their adoption. HDV driver turnover is high in the U.S., and businesses that 
operate HDVs are concerned about retaining their best drivers. Therefore, they may avoid technologies that require significant new training or adjustments in driver behavior. 
NAFA Fleet Management Association 
states that the standards will increase pressure on already strained driver and technician resources. The agencies understand that the industry experiences a great deal of driver turnover; we do not know how the standards will affect that turnover. Changes to vehicles that require some changes in driver behavior may increase driver turnover. For instance, drivers who prefer manual transmissions may respond poorly to vehicles with automatic transmissions. On the other hand, the switch to automatic transmissions may facilitate entry of new drivers who no longer need to learn as much about shifting. 
For some technologies that can be 
used to meet these standards, such as automatic tire inflation systems, training costs are likely to be minimal. Other technologies, such as stop-start systems, may require drivers to adjust their expectations about vehicle operation, and it is difficult for the agencies to anticipate how drivers will respond to such changes.
792 
•Constraints on access to capital for 
investment. If buyers of new vehicles have limited funds available, then they must choose between investing in fuel- saving technology and other vehicle technologies or attributes. 
CEI states that investments require 
tradeoffs: Investment in fuel economy crowds out other investments. There would be tradeoffs in purchasing choices if capital markets are constrained, and fuel-saving technologies do not provide returns 
sufficient to achieve the hurdle rates that the buyers require. Klemick et al. (2015) did not find capital constraints to be a problem for the medium- and large- sized businesses participating in their study. On the other hand, Roeth et al. (2013) noted that access to capital can be a significant challenge to smaller or independent businesses, and that price is always a concern to buyers. Section XIV.D. discusses the agencies’ outreach 
to small businesses to learn about their special circumstances. These are reflected in various flexibilities for small businesses in the regulations. 
•‘‘Network externalities,’’ where the 
benefits to new users of a technology depend on how many others have already adopted it. If the value of a technology increases with increasing adoption, then it can be difficult for the adoption process to begin: Each potential adopter has an incentive to wait for others to adopt before making the investment. If all adopters wait for others, then adoption may not happen. 
One example where network 
externalities seem likely to arise is the market for natural gas-fueled HDVs: The limited availability of refueling stations may reduce potential buyers’ willingness to purchase natural gas- fueled HDVs, while the small number of such HDVs in use does not provide sufficient economic incentive to construct more natural gas refueling stations. Some businesses that operate HDVs may also be concerned about the difficulty in locating repair facilities or replacement parts, such as single-wide tires, wherever their vehicles operate. When a technology has been widely adopted, then it is likely to be serviceable even in remote or rural places, but until it becomes widely available, its early adopters may face difficulties with repairs or replacements. By accelerating the widespread adoption of these technologies, these standards may assist in overcoming these difficulties. 
Consumer Federation of America 
states that network externalities are a potentially important barrier to adoption of fuel-saving technologies. 
•First-mover disadvantage. Many 
manufacturers prefer to observe the market and follow other manufacturers rather than be the first to market with a specific technology. The ‘‘first-mover disadvantage’’ has been recognized in other research where the ‘‘first-mover’’ pays a higher proportion of the costs of developing technology, but loses the long-term advantage when other 
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793Blumstein, Carl and Margaret Taylor (2013). 
‘‘Rethinking the Energy-Efficiency Gap: Producers, 
Intermediaries, and Innovation,’’ Energy Institute at Haas Working Paper 243, University of California at Berkeley, Docket EPA–HQ–OAR–2014–0827–0075; Tirole, Jean (1998). The Theory of Industrial Organization. Cambridge, MA: MIT Press, pp.400, 
402, Docket EPA–HQ–OAR–2014–0827–0089. This first-mover disadvantage must be large enough to overcome the potential incentive for first movers to earn unusually high but temporary profit levels. 794American Transportation Research Institute, 
An Analysis of the Operational Costs of Trucking, September 2013 (Docket ID: EPA–HQ–OAR–2014– 0827–0512). 
795Transport Canada, Operating Cost of Trucks, 
2005. See http://www.tc.gc.ca/eng/policy/report- acg-operatingcost2005-2005-e-2-1727.htm , accessed 
on July 16, 2010 (Docket ID: EPA–HQ–OAR–2014– 0827–0070). 796ICF International. Investigation of Costs for 
Strategies to Reduce Greenhouse Gas Emissions for Heavy-Duty On-Road Vehicles. July 2010. 
797Schubert, R., Chan, M., Law, K. (2015). 
Commercial Medium- and Heavy-Duty (MD/HD) Truck Fuel Efficiency Cost Study. Washington, DC: National Highway Traffic Safety Administration. businesses follow quickly.793In this 
way, there may be barriers to innovation 
on the supply side that result in lower adoption rates of fuel-efficiency technology than would be optimal. 
Several commenters support the 
existence of the first-mover disadvantage. Roeth et al. (2013) noted that HDV buyers often prefer to have technology or equipment installed by their favored original equipment manufacturers. However, some technologies may not be available through these preferred sources, or may be available only as after-market installations from third parties (Aarnink et al. 2012, Roeth et al. 2013). Manufacturers may be hesitant to offer technologies for which there is not strong demand, especially if the technologies require significant research and development expenses and other costs of bringing the technology to a market of uncertain demand. Roeth et al. (2013) noted that it can take years, and sometimes as much as a decade, for a specific technology to become available from all manufacturers. 
As mentioned above, the Competitive 
Enterprise Institute argues that EPA regulations on nitrogen oxides (NO
Xand 
other pollutants from heavy duty engines in the 2000s hindered development of fuel-saving technologies, in part because the technologies increased fuel consumption, and in part because, if manufacturers invested in NO
Xcontrols, 
they could not invest in reducing fuel consumption. The agencies do not find these potential explanations compelling. Most obviously, the NO
Xand other 
standards do not provide a useful analogy for industry response to the GHG/fuel efficiency standards, because those standards imposed costs without returning fuel savings to operators. In addition, as the discussion of technology cost and effectiveness indicates, technologies that are not in widespread use seem to be available to reduce fuel consumption with reasonable payback periods. Finally, the agencies consider it possible to reduce NO
Xin the presence of GHG controls, 
and to reduce GHG emissions in the presence of NO
Xcontrols; the cost 
analysis for this rulemaking accounts for achieving NO Xemissions standards. See 
also RTC Sections 11.2.2.3 and 11.7.2. 
In summary, the agencies recognize 
that businesses that operate HDVs are under competitive pressure to reduce operating costs, which should compel HDV buyers to identify and rapidly adopt cost-effective fuel-saving technologies. Outlays for labor and fuel generally constitute the two largest shares of HDV operating costs, depending on the price of fuel, distance traveled, type of HDV, and commodity transported (if any), so businesses that operate HDVs face strong incentives to reduce these costs.
794 795  
However, the relatively short payback 
periods that buyers of new HDVs appear to require suggest that some combination of the factors cited above impedes this process. Markets for both new and used HDVs may face these problems, although it is difficult to assess empirically the degree to which they actually do. Even if the benefits from widespread adoption of fuel-saving technologies exceed their costs, their use may remain limited or spread slowly because their early adopters bear a disproportionate share of those costs. In this case, as CFA says in its comments, these standards may help to overcome such barriers by ensuring that these measures will be widely adopted. 
Providing information about fuel- 
saving technologies, offering incentives for their adoption, and sharing HDV operators’ real-world experiences with their performance through voluntary programs such as EPA’s SmartWay Transport Partnership should assist in the adoption of new cost-saving technologies. Nevertheless, other barriers that impede the diffusion of new technologies are likely to remain. Buyers who are willing to experiment with new technologies expect to find cost savings, but those savings may be difficult to verify or replicate. As noted previously, because benefits from employing these technologies are likely to vary with the characteristics of individual routes and traffic patterns, buyers of new HDVs may find it difficult to identify or verify the effects of fuel-saving technologies in their operations. Risk-averse buyers may also avoid new technologies out of concerns over the possibility of inadequate returns on their investments, or with 
other possible adverse impacts. 
As various commenters note, 
competitive pressures in the HDV freight transport industry can provide a strong incentive to reduce fuel consumption and improve environmental performance. Nevertheless, HDV manufacturers may 
delay in investing in the development and production of new technologies, instead waiting for other manufacturers to bear the initial risks of those investments. In addition, not every HDV operator has the requisite ability or interest to access and utilize the technical information, or the resources necessary to evaluate this information within the context of his or her own operations. 
As discussed previously, whether the 
technologies available to improve HDVs’ fuel efficiency would be adopted widely in the absence of the program is challenging to assess. To the extent that these technologies would be adopted in its absence, neither their costs nor their benefits should be attributed to the program. 
The agencies will continue to explore 
reasons for the slow adoption of readily available and apparently cost-effective technologies for improving fuel efficiency. 
B. Vehicle-Related Costs Associated 
With the Program 
(1) Technology Cost Methodology 
(a) Direct Manufacturing Costs 
The direct manufacturing costs 
(DMCs) used throughout this analysis 
are derived from several sources. Many of the tractor, vocational and trailer DMCs can be sourced to the Phase 1 rule which, in turn, were sourced largely from a contracted study by ICF International for EPA.
796We have 
updated those costs by converting them to 2013 dollars, as described in Section IX.B.1.e below, and by continuing the learning effects described in the Phase 1 rule and in Section IX.B.1.c below. The new tractor, vocational and trailer costs can be sourced to a more recent study conducted by Tetra Tech under contract to NHTSA.
797The cost 
methodology used by Tetra Tech was to estimate retail costs and work backward from there to derive a DMC for each technology. The agencies did not agree with the approach used by Tetra Tech 
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798Schubert, R., Chan, M., Law, K. (2015). 
Commercial Medium- and Heavy-Duty (MD/HD) 
Truck Fuel Efficiency Cost Study. Washington, DC: National Highway Traffic Safety Administration. 799We note that the labor portion of warranty 
repairs does not decrease due to learning. However, we do not have data to separate this portion and so we apply learning to the entire warranty cost. Because warranty costs are a small portion of overall indirect costs, this has only a minor impact on the analysis. to move from retail cost to DMC as the 
approach was to simply divide retail costs by 2 and use the result as a DMC. Our research, discussed below, suggests that a divisor of 2 is too high. Therefore, where we have used a Tetra Tech derived retail estimate, we have divided by our researched markups to arrive at many of the DMCs used in this analysis. In this way, the agencies have used an approach consistent with past GHG/ CAFE/fuel consumption rules by dividing estimated retail prices by our estimated retail price equivalent (RPE) markups to derive an appropriate DMC for each technology. We describe our RPEs in Section IX.B.1.b, below. Importantly, nearly all of the technology costs used in the final analysis are identical to those used in the proposal, except for updating those costs from 2012 dollars to 2013 dollars. Notable changes are the costs for waste heat recovery and the use of new technologies (e.g., APU with DPF, 
battery powered APU and a different stop-start technology on vocational vehicles) that were not considered in the proposal. We describe these changes in Chapter 2 .11of the RIA. 
Importantly, technology costs differ 
from package costs which include adoption rates. Package costs have changed more significantly due to changes to the adoption rates as described throughout the earlier sections of this Preamble and briefly below in Section IX.B.1.(d). 
For HD pickups and vans, we have 
similarly used costs from the proposal except for the updating to 2013 dollars. As explained in the proposal, we relied primarily on the Phase 1 rule and the recent light-duty 2017–2025 model year rule since most technologies expected on these vehicles are, in effect, the same as those used on light-duty pickups. Many of those technology DMCs are based on cost teardown studies which the agencies consider to be the most robust method of cost estimation. However, because most of the HD versions of those technologies are expected to be more costly than their light-duty counterparts, we have scaled upward most of the light-duty DMCs for this analysis. We have also used some costs developed under contract to NHTSA by Tetra Tech.
798 
Importantly, in our methodology, all 
technologies are treated as being sourced from a supplier rather than being developed and produced in- house. As a result, some portion of the total indirect costs of making a 
technology or system—those costs incurred by the supplier for research, development, transportation, marketing etc.—are contained in the sales price to the engine and/or vehicle/trailer manufacturer (i.e., the original 
equipment manufacturer (OEM)). That sale price paid by the OEM to the supplier is the DMC we estimate. 
We present the details—sources, DMC 
values, scaling from light-duty values, markups, learning effects, adoption rates—behind all our costs in Chapter 2 of the RIA. 
(b) Indirect Costs 
To produce a unit of output, engine 
and truck manufacturers incur direct 
and indirect costs. Direct costs include cost of materials and labor costs. Indirect costs are all the costs associated with producing the unit of output that are not direct costs—for example, they may be related to production (such as research and development [R&D]), corporate operations (such as salaries, pensions, and health care costs for corporate staff), or selling (such as transportation, dealer support, and marketing). Indirect costs are generally recovered by allocating a share of the costs to each unit of good sold. Although it is possible to account for direct costs allocated to each unit of good sold, it is more challenging to account for indirect costs allocated to a unit of goods sold. To make a cost analysis process more feasible, markup factors, which relate total indirect costs to total direct costs, have been 
developed. These factors are often referred to as retail price equivalent (RPE) multipliers. 
While the agencies have traditionally 
used RPE multipliers to estimate indirect costs, in recent GHG/CAFE/fuel consumption rules RPEs have been replaced in the primary analysis with indirect cost multipliers (ICMs). ICMs differ from RPEs in that they attempt to estimate not all indirect costs incurred to bring a product to point of sale, but only those indirect costs that change as a result of a government action or regulatory requirement. As such, some indirect costs, notably health and retirement benefits of retired employees, among other indirect costs, will not be expected to change due to a government action and, therefore, the portion of the RPE that covered those costs does not change. 
Further, the ICM is not a ‘‘one-size- 
fits-all’’ markup as is the traditional RPE. With ICMs, higher complexity technologies like hybridization or moving from a manual to automatic transmission may require higher indirect costs—more research and 
development, more integration work, etc.—suggesting a higher markup. Conversely, lower complexity technologies like reducing friction or adding passive aero features may require fewer indirect costs thereby suggesting a lower markup. 
Notably, ICMs are also not a simple 
multiplier as are traditional RPEs. The ICM is broken into two parts—warranty related and non-warranty related costs. The warranty related portion of the ICM is relatively small while the non- warranty portion represents typically over 95 percent of indirect costs. These two portions are applied to different DMC values to arrive at total costs (TC). The warranty portion of the markup is applied to a DMC that decreases year- over-year due to learning effects (described below in Section IX.B.1.c).
799 
As learning effects decrease the DMC with production volumes, it makes sense that warranty costs will decrease since those parts replaced under warranty should be less costly. In contrast, the non-warranty portion of the markup is applied to a static DMC year-over-year resulting in static indirect costs. This is logical since the production plants and transportation networks and general overhead required to build parts, market them, deliver them and integrate them into vehicles do not necessarily decrease in cost year- over-year. Because the warranty and non-warranty portions of the ICM are applied differently, one cannot compare the markup itself to the RPE to determine which markup will result in 
higher indirect cost estimates, at least in the time periods typically considered in our rules (four to ten years). 
In the NPRM, the agencies expressed 
concern that some potential costs associated with this rulemaking may not be adequately captured by our ICMs. ICMs are estimated based on a few specific technologies and these technologies may not be representative of the changes actually made to meet the requirements. We requested and received comment on this issue. Specifically, some commenters argued that we had underestimated costs associated with R&D and costs associated with our compliance programs, both of which are indirect costs. However, we address those indirect costs separately because GHG- related R&D and GHG-related 
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800See ‘‘Learning Curves in Manufacturing,’’ L. 
Argote and D. Epple, Science, Volume 247; 
‘‘Toward Cost Buy down Via Learning-by-Doing for Environmental Energy Technologies, R. Williams, Princeton University, Workshop on Learning-by- Doing in Energy Technologies, June 2003; ‘‘Industry Learning Environmental and the Heterogeneity of Firm Performance, N. Balasubramanian and M. Lieberman, UCLA Anderson School of Management, December 2006, Discussion Papers, Center for Economic Studies, Washington DC. 
801The one exception are the design standards for 
non-aero box vans and non-box trailers, which do mandate use of certain tire-related technologies. compliance were not part of the retail 
price equivalent markups upon which our indirect cost multipliers are based. We discuss these R&D and compliance costs more below and in Chapter 7 of the RIA. 
We provide more details on our ICM 
approach and the markups used for each technology in Chapter 2.12 of the RIA. 
(c) Learning Effects on Direct and 
Indirect Costs 
For some of the technologies 
considered in this analysis, manufacturer learning effects will be expected to play a role in the actual end costs. The ‘‘learning curve’’ or ‘‘experience curve’’ describes the reduction in unit production costs as a function of accumulated production volume. In theory, the cost behavior it describes applies to cumulative production volume measured at the level of an individual manufacturer, although it is often assumed—as both agencies have done in past regulatory analyses—to apply at the industry-wide level, particularly in industries that utilize many common technologies and component supply sources. Both agencies believe there are indeed many factors that cause costs to decrease over time. Research in the costs of manufacturing has consistently shown that, as manufacturers gain experience in production, they are able to apply innovations to simplify machining and assembly operations, use lower cost materials, and reduce the number or complexity of component parts. All of these factors allow manufacturers to lower the per-unit cost of production (i.e., the manufacturing learning 
curve).
800 
In this analysis, the agencies are using 
the same approach to learning as done 
in the proposal and in past GHG/CAFE/ fuel consumption rules. In short, learning effects result in rapid cost reductions in the early years following introduction of a new technology. The agencies have estimated those cost reductions as resulting in 20 percent lower costs for every doubling of production volume. As production volumes increase, learning rates continue at the same pace but flatten asymptotically due to the nature of the persistent doubling of production required to realize that cost reduction. 
As such, the cost reductions flatten out as production volumes continue to increase. Consistent with the Phase 1 rule, we refer to these two distinct portions of the ‘‘learning cost reduction curve’’ or ‘‘learning curve’’ as the steeper and flatter portions of the curve. On that steep portion of the curve, costs are estimated to decrease by 20 percent for each double of production or, by proxy, in the third and then fifth year of production following introduction. On the flat portion of the curve, costs are estimated to decrease by 3 percent per year for 5 years, then 2 percent per year for 5 years, then 1 percent per year for 5 years. Also consistent with the Phase 1 rule, the majority of the technologies we expect will be adopted are considered to be on the flat portion of the learning curve meaning that the 20 percent cost reductions are rarely applied. The agencies requested and received comments on our approach to estimating learning effects, specifically with respect to cost reductions applied to waste heat recovery and APUs. Commenters suggested that, since waste heat recovery is not in production, the agencies should not have applied learning effect to that technology. They also argued that, since APUs have been around for years, applying any cost reduction effects to their costs is ‘‘questionable.’’ The agencies disagree with both of these comments. Whether production-related learning-by-doing cost reductions or from other factors, we are aware of dramatic changes to waste heat recovery systems that clearly make that technology less costly. We describe these changes in more detail in Chapter 2 of the RIA. Also, to suggest that APUs cannot undergo any cost reductions from learning does not seem reasonable. The agencies have placed that technology on the flat portion of the learning curve since it is well established. As a result, the estimated learning effects are not large in scale, but to suggest that an APU will cost the same in the 2020s as it does today, in 
constant dollar terms, is not reasonable. Further, the commenter provided no supporting data or information to support this claim. 
We provide more details on the 
concept of learning-by-doing and the learning effects applied in this analysis in Chapter 2.11 of the RIA. 
(d) Technology Adoption Rates and 
Developing Package Costs 
Determining the stringency of these 
standards involves a balancing of relevant factors—chiefly technology feasibility and effectiveness, costs, and lead time. For vocational vehicles, tractors and trailers, the agencies have projected a technology path to achieve these standards reflecting an application rate of those technologies the agencies consider to be available at reasonable cost in the lead times provided. The agencies do not expect (and do not require) each of the technologies for which costs have been developed to be employed by all trucks and trailers across the board.
801Further, many of 
today’s vehicles are already equipped with some of the technologies and/or are expected to adopt them by MY 2018 to comply with the HD Phase 1 standards. Estimated adoption rates in both the reference and control cases are necessary for each vehicle/trailer category. The adoption rates for most technologies are zero in the reference case; however, for some technologies— notably aero and tire technologies—the adoption rate is not zero in the reference case. These reference and control case adoption rates are then applied to the technology costs with the result being a package cost for each vehicle/trailer category. Technology adoption rates were presented in Sections II through V for engines, tractors, vocational vehicles and trailers. Individual technology costs are presented in Chapter 2.11 of the final RIA. 
For HD pickups and vans, the CAFE 
model determines the technology adoption rates that are estimated to most cost effectively meet the standards. Similar to vocational vehicles, tractors and trailers, package costs are rarely if ever a simple sum of all the technology costs since each technology will be expected to be adopted at different rates. The methods for estimating technology adoption rates and resultant costs per vehicle (and other impacts) for HD pickups and vans are discussed above in Section VI. Individual technology costs are presented in Chapter 2.11 of the final RIA. 
We provide details of expected 
technology adoption rates for each of the regulatory subcategories in Chapter 2 of the RIA. We present package costs both in Sections III through VI of this Preamble and in more detail in Chapter 2 of the RIA. 
(e) Conversion of Technology Costs to 
2013 U.S. Dollars 
As noted above in Section IX.B.1, the 
agencies are using technology costs from many different sources. These sources, having been published in different years, present costs in different year dollars (i.e., 2009 dollars or 2010 
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802U.S. Energy Information Administration, 
Annual Energy Outlook 2015, Early Release; Report 
Number DOE/EIA–0383(2015), April 2015. 803Bureau of Economic Analysis, Table 1.1.9 
Implicit Price Deflators for Gross Domestic Product; as revised on August 27, 2015. dollars). For this analysis, the agencies 
sought to have all costs in terms of 2013 dollars to be consistent with the dollars used by AEO in its 2015 Annual Energy Outlook.
802The agencies have used the 
GDP Implicit Price Deflator for Gross Domestic Product as the converter, with the actual factors used as shown in Table IX–1.
803 
TABLE IX–1—I MPLICIT PRICE DEFLATORS AND CONVERSION FACTORS FOR CONVERSION TO 2013$ 
2006 2007 2008 2009 2010 2011 2012 2013 
Price index for GDP ......................................... 94.814 97.337 99.246 100 101.221 103.311 105.214 106.929 
Factor applied for 2012$ .................................. 1.128 1.099 1.077 1.069 1.056 1.035 1.016 1.000 
(2) Compliance Program Costs 
The agencies have also estimated 
additional and/or new compliance costs associated with these standards. Normally, compliance program costs will be considered part of the indirect costs and, therefore, will be accounted for via the markup applied to direct manufacturing costs. However, since the agencies are proposing new compliance elements that were not present during development of the indirect cost markups used in this analysis, additional compliance program costs are being accounted for via a separate ‘‘line- item.’’ New research and development costs (see below) are being handled in the same way. 
The new compliance program 
elements included in this rule are new powertrain testing within the vocational vehicle program, and an all-new compliance program (since none has existed to date) for the trailer program. The remaining compliance provisions are identical to those in Phase 1, and the estimated costs therefore are derived using the same methodology used to estimate compliance costs in the Phase 1 rule. Compliance program costs cover costs associated with any necessary compliance testing and reporting to the agencies. The details behind the estimated compliance program costs are provided in Chapter 7 of the RIA. 
The agencies requested and received 
comments on our compliance cost estimates. Some commenters were concerned that we had significantly underestimated costs. In response, we have adjusted our compliance costs estimates, including those for testing 
and reporting, and have increased our annual compliance costs from roughly $6 million per year to nearly $11 million per year. This excludes the estimated $16 million in 2020 to build and/or upgrade facilities to conduct testing. We discuss our updated estimates in more detail in Chapter 7 of the RIA. 
(3) Research and Development Costs 
Much like the compliance program 
costs described above, we have 
estimated additional HDD engine, vocational vehicle and tractor R&D associated with these standards that is not accounted for via the indirect cost markups used for these segments. Much like the Phase 1 rule, EPA is estimating these additional R&D costs will occur over a 4-year timeframe as these standards come into force and industry works on means to comply. After that period, the additional R&D costs go to $0 as R&D expenditures return to their normal levels and R&D costs are accounted for via the ICMs—and the RPEs behind them—used for these segments. The details behind the estimated R&D costs are provided in Chapter 7 of the RIA 
The agencies requested and received 
comments on our R&D estimates. One 
commenter suggested that our estimate of $960 million over four years, for hundreds of types of disparate vehicles was unrealistic given the $80 million of R&D spent on the Super Truck program over 5 years. Unfortunately, no better estimate was provided by commenters. We have increased our estimated R&D, relative to that estimated in the proposal, by roughly $14 million per year for 4 years resulting in a total additional R&D estimate of over $1 billion. Importantly, as noted, this R&D spending is an additional expenditure above and beyond that estimated as part of the indirect cost markups which include in them an estimate of roughly 4 percent of revenues spent on R&D. Another way of stating this is that roughly 4 percent of our technology costs are actually estimated as R&D- related costs. Given our annual technology costs of $2 billion to $5 billion per year from 2021 through 2027, or over $24 billion over those 7 years, we are estimating another $1 billion in R&D via our indirect cost markups (4 percent of $24 billion). In other words, we are really estimating roughly $2 billion in R&D spending during the calendar years 2021 through 2027. 
(4) Summary of Costs of the Vehicle 
Programs 
The agencies have estimated the costs 
of the vehicle standards on an annual basis for the years 2018 through 2050, and have also estimated costs for the full model year lifetimes of MY 2018 through MY 2029 vehicles. Table IX–2 shows the annual costs of these standards along with net present values using both 3 percent and 7 percent discount rates. Table IX–3 shows the discounted model year lifetime costs of these standards at both 3 percent and 7 percent discount rates along with sums across applicable model years. 
TABLE IX–2—A NNUAL COSTS OF THE FINAL PROGRAM AND NETPRESENT VALUES AT 3% AND7% D ISCOUNT RATES  
USING METHOD B ANDRELATIVE TO THE FLATBASELINE  
[$Millions of 2013$]a 
Calendar 
year New 
technology Compliance R&D Sum 
2018 ................................................................................................................. $227 $0 $0  $227 
2019 ................................................................................................................. 215 0 0 215 
2020 ................................................................................................................. 220 17 0 2 37 
2021 ................................................................................................................. 2,270 11 2 59 2,540 
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TABLE IX–2—A NNUAL COSTS OF THE FINAL PROGRAM AND NETPRESENT VALUES AT 3% AND7% D ISCOUNT RATES  
USING METHOD B ANDRELATIVE TO THE FLATBASELINE —Continued 
[$Millions of 2013$]a 
Calendar 
year New 
technology Compliance R&D Sum 
2022 ................................................................................................................. 2,243 11 2 59 2,512 
2023 ................................................................................................................. 2,485 11 2 59 2,755 
2024 ................................................................................................................. 3,890 11 2 59 4,160 
2025 ................................................................................................................. 4,146 11 0  4,157 
2026 ................................................................................................................. 4,203 11 0  4,213 
2027 ................................................................................................................. 5,219 11 0  5,230 
2028 ................................................................................................................. 5,176 11 0  5,186 
2029 ................................................................................................................. 5,195 11 0  5,206 
2030 ................................................................................................................. 5,219 11 0  5,229 
2035 ................................................................................................................. 5,642 11 0  5,653 
2040 ................................................................................................................. 6,245 11 0  6,255 
2050 ................................................................................................................. 7,270 11 0  7,280 
NPV, 3% .......................................................................................................... 86,780 191 818 87,788 
NPV, 7% .......................................................................................................... 41,148 102 604 41,854 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE IX–3—D ISCOUNTED MY L IFETIME COSTS OF THE FINAL PROGRAM USING METHOD B ANDRELATIVE TO THE FLAT 
BASELINE  
[$Millions of 2013$]a 
Model year Discounted at 3% Discounted at 7% 
New 
technology Compliance R&D Sum New 
technology Compliance R&D Sum 
2018 ................................. $205 $0 $0 $205 $179 $0 $0 $179 
2019 ................................. 188 0 0 188 159 0 0 159 
2020 ................................. 187 14 0 201 152 12 0 163 
2021 ................................. 1,873 9 214 2,096 1,462 7 167 1,636 
2022 ................................. 1,797 8 207 2,013 1,350 6 156 1,513 
2023 ................................. 1,933 8 201 2,143 1,398 6 146 1,550 
2024 ................................. 2,938 8 195 3,141 2,046 6 136 2,187 
2025 ................................. 3,040 8 0 3,048 2,038 5 0 2,043 
2026 ................................. 2,992 8 0 2,999 1,930 5 0 1,935 
2027 ................................. 3,607 7 0 3,614 2,240 5 0 2,245 
2028 ................................. 3,473 7 0 3,480 2,076 4 0 2,080 
2029 ................................. 3,384 7 0 3,391 1,948 4 0 1,952 
Sum ........................... 25,617 84 818 26,519 16,978 59 604 17,642 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
New technology costs begin in MY 
2018 as trailers begin to add new 
technology. Compliance costs begin with the new standards with capital cost expenditure in that year for building and upgrading test facilities to conduct the powertrain testing in the vocational program. Research and development costs begin in 2021 and last for 4 years as engine, tractor and vocational vehicle manufacturers conduct research and development testing to integrate new technologies into their engines and vehicles. C. Changes in Fuel Consumption and 
Expenditures 
(1) Changes in Fuel Consumption 
The new GHG and fuel consumption 
standards will result in significant 
improvements in the fuel efficiency of affected vehicles, and drivers of those vehicles will see corresponding savings associated with reduced fuel expenditures. The agencies have estimated the impacts on fuel consumption for these standards. Details behind how these changes in fuel consumption were calculated are presented in Section VII of this Preamble and in Chapter 5 of the RIA. The total number of miles that vehicles 
are driven each year is different under the regulatory alternatives than in the 
reference case due to the ‘‘rebound effect’’ (discussed below in Section 
IX.E), so the changes in fuel consumption associated with each alternative are not strictly proportional to differences in the fuel economy levels they require. 
The expected annual impacts on fuel 
consumption are shown in Table IX–4. Table IX–5 shows the MY lifetime changes in fuel consumption. The gallons shown in these tables as reductions in fuel consumption reflect reductions due to these standards and include any increased consumption resulting from the rebound effect (discussed below in Section IX.E). 
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804U.S. Energy Information Administration, 
Annual Energy Outlook 2015; Report Number DOE/ 
EIA–0383(2015), April 2015. TABLE IX–4—A NNUAL FUELCONSUMPTION REDUCTIONS DUE TO THE FINAL PROGRAM USING METHOD B ANDRELATIVE  
TO THE FLATBASELINE  
[Millions of gallons]a 
Calendar year Retail gasoline Diesel 
Reference 
case Fuel 
consumption 
reduction % 
Reduction Reference 
case Fuel 
consumption 
reduction % 
Reduction 
2018 ......................................................... 10,958 0 0 46,636 37 0 
2019 ......................................................... 11,118 0 0 47,056 76 0 
2020 ......................................................... 11,265 0 0 47,397 117 0 
2021 ......................................................... 11,391 28 0 47,548 428 1 
2022 ......................................................... 11,515 74 1 47,813 812 2 
2023 ......................................................... 11,633 138 1 48,146 1,211 3 
2024 ......................................................... 11,745 226 2 48,572 1,835 4 
2025 ......................................................... 11,843 330 3 48,941 2,457 5 
2026 ......................................................... 11,936 448 4 49,194 3,063 6 
2027 ......................................................... 12,039 588 5 49,483 3,853 8 
2028 ......................................................... 12,138 723 6 49,753 4,610 9 
2029 ......................................................... 12,234 852 7 50,036 5,335 11 
2030 ......................................................... 12,324 974 8 50,393 6,031 12 
2035 ......................................................... 12,680 1,454 11 52,492 8,883 17 
2040 ......................................................... 12,920 1,724 13 55,399 10,778 19 
2050 ......................................................... 13,185 1,904 14 61,663 12,986 21 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE IX–5—M ODEL YEARLIFETIME FUELCONSUMPTION REDUCTIONS DUE TO THE FINAL PROGRAM USING METHOD B 
ANDRELATIVE TO THE FLATBASELINE  
[Millions of gallons]a 
Model year Retail gasoline Diesel 
Reference Fuel 
consumption 
reduction % 
Reduction Reference Fuel 
consumption 
reduction % 
Reduction 
2018 ......................................................... 12,541 0 0 46,628 302 1 
2019 ......................................................... 12,409 0 0 47,583 293 1 
2020 ......................................................... 12,455 0 0 49,084 286 1 
2021 ......................................................... 12,328 322 3 48,950 4,643 9 
2022 ......................................................... 12,252 550 4 48,994 4,807 10 
2023 ......................................................... 12,233 772 6 48,884 4,947 10 
2024 ......................................................... 12,342 1,075 9 49,924 7,742 16 
2025 ......................................................... 12,452 1,301 10 50,364 7,954 16 
2026 ......................................................... 12,555 1,525 12 50,477 8,111 16 
2027 ......................................................... 12,591 1,836 15 50,664 10,646 21 
2028 ......................................................... 12,619 1,840 15 50,916 10,698 21 
2029 ......................................................... 12,631 1,841 15 51,381 10,800 21 
Sum ................................................... 149,408 11,062 7 593,848 71,229 12 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(2) Fuel Savings 
We have also estimated the changes in 
fuel expenditures, or the fuel savings, 
using fuel prices estimated in the Energy and Information Administration’s 2015 Annual Energy 
Outlook.
804As the AEO fuel price 
projections go through 2040 and not beyond, fuel prices beyond 2040 were set equal to the 2040 values. These estimates do not account for the 
significant uncertainty in future fuel prices; the monetized fuel savings will be understated if actual fuel prices are higher (or overstated if fuel prices are lower) than estimated. The Annual Energy Outlook (AEO) is a standard reference used by NHTSA and EPA and many other government agencies to estimate the projected price of fuel. This has been done using both the pre-tax and post-tax fuel prices. Since the post- tax fuel prices are the prices paid at fuel pumps, the fuel savings calculated using these prices represent the changes fuel purchasers will see. The pre-tax fuel savings measure the value to society of the resources saved when less fuel is refined and consumed. Assuming no change in fuel tax rates, the difference between these two columns represents the reduction in fuel tax revenues that will be received by state and federal governments, or about $204 million in 2021 and $5.8 billion by 2050 as shown in Table IX–6 where annual changes in monetized fuel savings are shown along with net present values using 3 percent 
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and 7 percent discount rates. Table IX– 
7 and Table IX–8 show the discounted model year lifetime fuel savings using 3 percent and 7 percent discount rates, 
respectively. 
TABLE IX–6—A NNUAL FUELSAVINGS AND NETPRESENT VALUES AT 3% AND7% D ISCOUNT RATES USING METHOD B 
FOR THE FINAL PROGRAM AND RELATIVE TO THE FLATBASELINE  
[$Millions of 2013$]a 
Model year Fuel savings—retail Fuel savings—untaxed Change in 
transfer Gasoline Diesel Sum Gasoline Diesel Sum 
2018 ............................. $0 $114 $114 $0 $97 $97 $17 
2019 ............................. 0 237 237 0 202 202 35 
2020 ............................. 0 371 371 0 319 319 53 
2021 ............................. 78 1,384 1,462 67 1,191 1,258 204 
2022 ............................. 210 2,689 2,899 181 2,323 2,504 395 
2023 ............................. 396 4,081 4,476 342 3,548 3,889 587 
2024 ............................. 657 6,296 6,952 571 5,488 6,059 894 
2025 ............................. 973 8,576 9,550 848 7,495 8,343 1,207 
2026 ............................. 1,343 10,903 12,246 1,173 9,586 10,759 1,487 
2027 ............................. 1,787 13,985 15,772 1,564 12,328 13,892 1,880 
2028 ............................. 2,234 17,057 19,290 1,959 15,074 17,033 2,257 
2029 ............................. 2,675 20,114 22,789 2,351 17,873 20,224 2,565 
2030 ............................. 3,116 23,160 26,276 2,746 20,627 23,373 2,903 
2035 ............................. 5,131 37,840 42,971 4,593 34,287 38,880 4,091 
2040 ............................. 6,722 51,194 57,916 6,102 46,991 53,093 4,824 
2050 ............................. 7,426 61,684 69,109 6,740 56,619 63,359 5,750 
NPV, 3% ...................... 65,703 511,060 576,763 59,061 464,240 523,301 53,462 
NPR, 7% ...................... 26,936 209,666 236,602 24,131 189,702 213,833 22,769 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE IX–7—D ISCOUNTED MODEL YEARLIFETIME FUELSAVINGS , 3% D ISCOUNT RATEUSING METHOD B FOR THE FINAL 
PROGRAM AND RELATIVE TO THE FLATBASELINE  
[$Millions of 2013$]a 
Model year Fuel savings—retail Fuel savings—untaxed Change in 
transfer Gasoline Diesel Sum Gasoline Diesel Sum 
2018 ............................. $0 $781 $781 $0 $680 $680 $101 
2019 ............................. 0 747 747 0 653 653 94 
2020 ............................. 0 719 719 0 631 631 87 
2021 ............................. 674 11,497 12,171 590 10,155 10,746 1,426 
2022 ............................. 1,132 11,781 12,912 994 10,440 11,435 1,478 
2023 ............................. 1,567 11,990 13,557 1,381 10,660 12,041 1,516 
2024 ............................. 2,154 18,556 20,709 1,903 16,548 18,451 2,259 
2025 ............................. 2,571 18,849 21,420 2,278 16,859 19,137 2,283 
2026 ............................. 2,973 19,003 21,976 2,640 17,048 19,688 2,288 
2027 ............................. 3,532 24,648 28,180 3,144 22,171 25,315 2,865 
2028 ............................. 3,493 24,459 27,953 3,116 22,060 25,176 2,776 
2029 ............................. 3,449 24,378 27,828 3,084 22,044 25,128 2,700 
Sum .............................. 21,545 167,408 188,954 19,131 149,950 169,081 19,873 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
TABLE IX–8—D ISCOUNTED MODEL YEARLIFETIME FUELSAVINGS , 7% D ISCOUNT RATEUSING METHOD B FOR THE FINAL 
PROGRAM AND RELATIVE TO THE FLATBASELINE  
[$Millions of 2013$]a 
Model year Fuel savings—retail Fuel savings—untaxed Change in 
transfer Gasoline Diesel Sum Gasoline Diesel Sum 
2018 ............................. $0 $558 $558 $0 $483 $483 $74 
2019 ............................. 0 510 510 0 444 444 66 
2020 ............................. 0 466 466 0 408 408 58 
2021 ............................. 420 7,031 7,451 367 6,188 6,554 897 
2022 ............................. 674 6,946 7,620 591 6,134 6,725 895 
2023 ............................. 896 6,814 7,710 788 6,038 6,826 884 
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805Allison Transmission’s Responses to EPA’s 
Hybrid Questions, November 6, 2014. 806Winebrake, J.J., Green, E.H., Comer, B., 
Corbett, J.J., Froman, S., 2012. Estimating the direct 
rebound effect for on-road freight transportation. Energy Policy 48, 252–259. 
807Greene, D.L., Kahn, J.R., Gibson, R.C., 1999, 
‘‘Fuel economy rebound effect for U.S. household vehicles,’’ The Energy Journal, 20. 
808For a discussion of the wide range of 
definitions found in the literature, see Appendix D: 
Discrepancy in Rebound Effect Definitions, in EERA (2014), ‘‘Research to Inform Analysis of the Heavy- Duty vehicle Rebound Effect,’’ Excerpts of Draft Final Report of Phase 1 under EPA contract EP–C– 
Continued TABLE IX–8—D ISCOUNTED MODEL YEARLIFETIME FUELSAVINGS , 7% D ISCOUNT RATEUSING METHOD B FOR THE FINAL 
PROGRAM AND RELATIVE TO THE FLATBASELINE —Continued 
[$Millions of 2013$]a 
Model year Fuel savings—retail Fuel savings—untaxed Change in 
transfer Gasoline Diesel Sum Gasoline Diesel Sum 
2024 ............................. 1,186 10,161 11,347 1,045 9,033 10,078 1,269 
2025 ............................. 1,362 9,947 11,309 1,204 8,870 10,074 1,235 
2026 ............................. 1,516 9,666 11,182 1,343 8,648 9,991 1,191 
2027 ............................. 1,737 12,081 13,818 1,542 10,839 12,381 1,436 
2028 ............................. 1,655 11,551 13,206 1,474 10,393 11,866 1,340 
2029 ............................. 1,576 11,097 12,672 1,406 10,013 11,419 1,254 
Sum .............................. 11,022 86,827 97,849 9,759 77,491 87,249 10,600 
Note: 
aFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
D. Maintenance Expenditures 
The agencies expect increases in 
maintenance costs under these 
standards. In the NPRM, we estimated maintenance costs associated with lower rolling resistance tires. In the final rule, we have included maintenance costs for many more systems, including waste heat recovery, APUs, transmission fluids, etc. We have estimated that these maintenance costs will be incurred throughout the vehicle lifetime at intervals consistent with typical replacement intervals. Those intervals are difficult to quantify given the variety of vehicles and operating modes within the HD industry. We detail the inputs used to estimate maintenance impacts in Chapter 7.3.3 of the RIA. 
We have heard from at least one 
source
805that strong hybrid 
maintenance can be higher in some ways, including possible battery replacement, but may also be much lower for some vehicle systems like brakes and general engine wear. New for the FRM, relative to the proposal, are maintenance costs on hybrid battery systems in vocational vehicles and some reduction in oil change costs on vocational vehicles with stop-start systems since less idling should result in fewer oil changes. See RIA 2.11.7. We have also included new costs for axle fluid replacements for vocational vehicles adding high efficiency axles, and transmission fluid replacements for vehicles projected to move from manual to automated transmissions. For tractors, we have added these same axle and transmission fluid costs and for the same reasons. For tractors, we have also added maintenance costs associated with auxiliary power units and for fuel operated heaters. All of the new cost estimates and the maintenance intervals are presented in more detail in Chapter 
7.2.3 of the RIA. 
Table IX–9 shows the annual 
increased maintenance costs of the final program along with net present values using both 3 percent and 7 percent discount rates. Table IX–10 shows the discounted model year lifetime increased maintenance costs of the final program at both 3 percent and 7 percent discount rates along with sums across applicable model years. 
TABLE IX–9—A NNUAL MAINTENANCE  
EXPENDITURE INCREASE DUE TO THE  
RULE AND NETPRESENT VALUES AT  
3% AND 7% D ISCOUNT RATES  
USING METHOD B AND RELATIVE TO  
THEFLATBASELINE  
[$Millions of 2013$]a 
Calendar year Maintenance 
expenditure 
increase 
2018 ...................................... $1 
2019 ...................................... 1 
2020 ...................................... 2 
2021 ...................................... 20 
2022 ...................................... 39 
2023 ...................................... 60 
2024 ...................................... 83 
2025 ...................................... 106 
2026 ...................................... 127 
2027 ...................................... 167 
2028 ...................................... 206 
2029 ...................................... 244 
2030 ...................................... 244 
2035 ...................................... 244 
2040 ...................................... 244 
2050 ...................................... 244 
NPV, 3% ............................... 3,188 
NPV, 7% ............................... 1,463 
Note: 
aFor an explanation of analytical Methods A 
and B, please see Section I.D; for an expla-
nation of the flat baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1. TABLE IX–10—D ISCOUNTED MY L IFE-
TIME MAINTENANCE EXPENDITURE  
INCREASE DUE TO THE RULEUSING 
METHOD B AND RELATIVE TO THE  
FLATBASELINE  
[$Millions of 2013$]a 
Model 
year 3% Discount 
rate 7% Discount 
rate 
2018 .............. $7 $5 
2019 .............. 6 4 
2020 .............. 6 4 
2021 .............. 155 96 
2022 .............. 156 94 
2023 .............. 160 93 
2024 .............. 175 98 
2025 .............. 177 96 
2026 .............. 165 86 
2027 .............. 303 152 
2028 .............. 293 141 
2029 .............. 285 132 
Sum ....... 1,889 1,000 
Note: 
aFor an explanation of analytical Methods A 
and B, please see Section I.D; for an expla-nation of the flat baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1. 
E. Analysis of the Rebound Effect 
The ‘‘rebound effect’’ has been 
defined in a variety of different ways in 
the energy policy and economics literature. One common definition states that the rebound effect is the increase in demand for an energy service when the cost of the energy service is reduced due to efficiency improvements.
806 807 808 In 
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13–025. (Docket ID: EPA–HQ–OAR–2014–0827). 
See also Greening, L.A., Greene, D.L., Difiglio, C., 2000, ‘‘Energy efficiency and consumption—the rebound effect—a survey,’’ Energy Policy, 28, 389– 401. 
809We discuss other potential rebound effects in 
Section E.3.b., such as the indirect and economy- wide rebound effects. Note also that there is more than one way to measure HDV energy services and vehicle use. The agencies’ analyses use VMT as a measure (as discussed below); other potential measures include ton-miles, cube-miles, and fuel consumption. 810These factors are discussed more fully in a 
report to EPA from EERA, which illustrates in a series of diagrams the complex system of decisions and decision-makers that could influence the magnitude and timing of the rebound effect. See Sections 2.2.2, 2.2.3, 2.2.4, and 2.3 in EERA (2014), ‘‘Research to Inform Analysis of the Heavy-Duty Vehicle Rebound Effect,’’ Excerpts of Draft Final Report of Phase 1 under EPA contract EP–C–13–025 (EPA–HQ–OAR–2014–0827–0514). 
811Elasticity is the measurement of how 
responsive an economic variable is to a change in another. For example: Price elasticity of demand is a measure used in economics to show the responsiveness, or elasticity, of the quantity demanded of a good or service to a change in its price. More precisely, it gives the percentage change in quantity demanded in response to a one percent change in price. 
812See 80 FR 40448–40452. 
813See 80 FR 40448–40452. the context of heavy-duty vehicles 
(HDVs), this can be interpreted as an increase in HDV fuel consumption resulting from more intensive vehicle use in response to increased vehicle fuel efficiency.
809Although much of this 
vehicle use increase is likely to take the 
form of increases in the number of miles vehicles are driven, it can also take the form of increases in the loaded weight at which vehicles operate or changes in traffic and road conditions vehicles encounter as operators alter their routes and schedules in response to improved fuel efficiency. Because this more intensive use consumes fuel and generates emissions, it reduces the fuel savings and avoided emissions that would otherwise be expected to result from the increases in fuel efficiency in this rulemaking. 
In our analysis and discussion below, 
we focus on one widely-used metric to estimate the rebound effect associated with all types of more intensive vehicle 
use, the increase in vehicle miles traveled (VMT) that results from improved fuel efficiency. VMT can often provide a reasonable approximation for all types of more intensive vehicle use. For simplicity, we refer to this as ‘‘the VMT rebound effect’’ or ‘‘the direct VMT rebound’’ throughout this section, although we acknowledge that it is an approximation to the rebound effect associated with all types of more intensive vehicle use. The agencies use our VMT rebound estimates to generate VMT inputs that are then entered into the EPA MOVES national emissions inventory model and the Volpe Center’s HD CAFE model. Both of these models use these inputs along with many others to generate projected emissions and fuel consumption changes resulting from each of the regulatory alternatives analyzed. 
The following sections describe the 
factors affecting the magnitude of HDV VMT rebound; review the econometric and other evidence related to HDV VMT rebound; and summarize how we estimated the HDV rebound effect for this rulemaking. (1) Factors Affecting the Magnitude of 
HDV VMT Rebound 
The magnitude and timing of HDV 
VMT rebound are driven by the interaction of many different factors.
810 
Fuel savings resulting from fuel efficiency standards may cause HDV operators and their customers to change their patterns of HDV use and fuel consumption in a variety of ways. As discussed in the RIA (Chapter 8), HDV VMT rebound estimates determined via other proxy elasticities vary, but in no case has there been an estimate that fully offsets the fuel saved due to efficiency improvements (i.e., no 
rebound effect greater than or equal to 100 percent).
811 
If fuel cost savings are passed on to 
the HDV operators’ customers (e.g., logistics businesses, manufacturers, retailers, municipalities, utilities consumers, etc.), those customers might reorganize their logistics and distribution networks over time to take advantage of lower operating costs. For example, customers might order more frequent shipments or choose products that entail longer shipping distances, while freight carriers might divert some shipments to trucks from other shipping modes such as rail, barge or air. In addition, customers might choose to reduce their number of warehouses, reduce shipment rates or make smaller but more frequent shipments, all of which could lead to an increase in HDV VMT. Ultimately, fuel cost savings could ripple through the entire economy, thus increasing demand for goods and services shipped by trucks, and therefore increase HDV VMT due to increased gross domestic product (GDP). 
Conversely, if fuel efficiency 
standards lead to net increases in the 
total costs of HDV operation because fuel cost savings do not fully offset the increase in HDV purchase prices and associated depreciation costs, then the price of HDV services could rise. This is likely to spur a decrease in HDV VMT, and perhaps a shift to alternative shipping modes. These effects could 
also ripple through the economy and affect GDP. Note, however, that we project fuel cost savings will offset technology costs in our analysis supporting the final standards. 
It is also important to note that any 
increase in HDV VMT resulting from the final standards may be offset, to some extent, by a decrease in VMT by older HDVs. This may occur if lower fuel costs resulting from our standards cause multi-vehicle fleet operators to shift VMT to newer, more efficient HDVs in their fleet or cause operators with newer, more efficient HDVs to be more successful at winning contracts than operators with older HDVs. 
Also, as discussed in Chapter 8.2 of 
the RIA, the magnitude of the rebound effect is likely to be influenced by the extent of any market failures that affect the demand for more fuel efficient HDVs, as well as by HDV operators’ 
responses to their perception of the tradeoff between higher upfront HDV purchase costs versus lower but uncertain future expenditures on fuel. 
(2) Recent Econometric and Other 
Evidence Related to HDV VMT Rebound 
As discussed above, HDV VMT 
rebound is defined as the change in HDV VMT that occurs in response to an increase in HDV fuel efficiency. We are not aware of any studies that directly estimate this elasticity for the U.S. In the proposal, we discussed a number of econometric analyses of other related elasticities that could potentially be used as a proxy for measuring HDV VMT rebound, as well as several other analyses that may provide insight into the magnitude of HDV VMT rebound.
812 
These studies produced a wide range of estimates for HDV VMT rebound, however, and we were unable to draw any strong conclusions about the magnitude of rebound based on this available literature. 
We also discussed several challenges 
that researchers face in attempting to quantify the VMT rebound effect for HDVs,
813including limited data on the 
HD sector and the difficulty of specifying mathematical models that reflect the complex set of factors that influence HD VMT. Given these limitations, the agencies requested comment on a number of aspects of the proposed VMT rebound analysis, including procedures for measuring the rebound effect and the studies discussed in the proposal. The agencies also committed to reviewing and considering revisions to VMT rebound estimates for 
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814EERA (2014), ‘‘Research to Inform Analysis of 
the Heavy-Duty Vehicle Rebound Effect,’’ Excerpts 
of Draft Final Report of Phase 1 under EPA contract EP–C–13–025, EPA–HQ–OAR–2014–0827–0514. 
815EERA (2015), ‘‘Working Paper on Fuel Price 
Elasticities for Heavy Duty Vehicles,’’ Draft Final Report of Phase 2 under EPA contract EP–C–11– 046, EPA–HQ–OAR–2014–0827–0515. 
816Winebrake, J.J., et al., Fuel price elasticities in 
the U.S. combination trucking sector. Transportation Research Part D: Transport and Environment, 2015. 38: p. 166–177. 
Winebrake, J.J., et al., Fuel price elasticities for 
single unit truck operations in the United States. Transportation Research Part D: Transport and Environment, 2015. 38: p. 178–187. 817Gately, D., 1990. The U.S. demand for 
highway travel and motor fuel. Energy J. 11, 59–74. 
818Resources for the Future (RFF) comment, 
EPA–HQ–OAR–2014–0827–1200. 
819Leard, B., et al., Fuel Costs, Economic Activity, 
and the Rebound Effect for Heavy-Duty Trucks. September 2015, Resources for the Future: RF DP 15–43, Washington, DC. EPA–HQ–OAR–2014– 0827–1200–A1. 820Leard et al. report a total VMT rebound effect 
result of 29.7 percent for combination trucks, which is a sum of separate estimates associated with both VMT elasticity and truck count elasticity with respect to fuel costs per mile. 
821For vocational trucks, Leard et al. report an 
overall 9.3 percent rebound value, which is a sum of separate estimates associated with both VMT elasticity and truck count elasticity with respect to fuel costs per mile. 
822Wadud, Zia, Diesel Demand in the Road 
Freight Sector in the UK: Estimates for Different Vehicle Types. Applied Energy 165 (2016), p. 849– 857. the final rule based on submissions from 
public commenters and new research on the rebound effect. 
This section reviews new econometric 
analyses that have been produced since the release of the proposal. All of these analyses study the change in HDV use (measured in VMT, ton-mile, or fuel consumption) in response to changes in fuel price ($/gallon) or fuel cost ($/mile or $/ton-mile). The studies presented below attempt to estimate these elasticities in the HDV sector using varying approaches and data sources. 
Concurrent with the development of 
the proposal for this rule, EPA contracted with Energy and Environmental Research Associates (EERA) to analyze the HDV rebound effect for regulatory assessment purposes. Excerpts of EERA’s initial report to EPA are included in the NPRM docket and contain detailed qualitative discussions of the rebound effect as well as data sources that could be used in quantitative analysis.
814EERA also 
conducted follow-on quantitative analyses focused on estimating the impact of fuel prices on VMT and fuel consumption. We included a Working Paper in the NPRM docket that described much of this work.
815Note 
that EERA’s Working Paper was not available at the time the agencies conducted the analysis of the rebound effect for the proposal, but that the agencies agreed to consider this work and any other work in the analysis supporting the final rule. 
At the time of publication of the 
NPRM, Winebrake et al. (2015) published two papers in Transportation Research Part D: Transport and Environment based on the EERA work mentioned above.
816These two papers 
have been filed in each agency’s docket and received public review and comment. In the first paper, the fuel price elasticities of VMT and fuel consumption for combination trucks are estimated with regression models. The combination trucks paper uses annual data for the period 1970–2012. VMT and fuel consumption are used as the dependent variables. The control 
variables include: A macroeconomic variable (e.g., gross domestic product 
(GDP)), imports/exports, and fuel price, among other variables. In the second paper, the fuel price elasticity of VMT for single unit vehicles is estimated by using annual data for the period 1980– 2012. The single unit vehicle paper uses similar control variables but includes additional variables related to lane miles and housing construction. VMT is 
the only dependent variable modeled in the single unit vehicle paper (i.e., fuel 
consumption is not modeled). 
The results in Winebrake et al. are 
that the null hypothesis—which states that the fuel price elasticity of VMT and the fuel price elasticity of fuel consumption are zero—cannot be rejected with statistical confidence. The papers hypothesize that low elasticities may be due to a range of possibilities including: (1) The common use of fuel surcharges; (2) adjustments in other operational costs such as labor; (3) possible principal-agent problems affecting driver behavior; and (4) the nature of freight transportation as an input to a larger supply chain system that is driven by other factors. These two papers suggest that previous regulatory analysis that uses a five percent rebound effect for combination trucks and a 15 percent rebound effect for single unit trucks may be overestimating the direct VMT rebound effect. 
To the best of our knowledge, the 
Winebrake et al. paper represents the first peer-reviewed work in the last two decades, after Gately (1990),
817that 
attempts to estimate quantitatively the impact of a change in fuel costs on HDV VMT in the U.S. context. A subsequent paper by Wadud, discussed in more detail below, states that there is ‘‘only one creditable study’’ on ‘‘the responses of different [heavy duty] vehicle sectors to fuel price or income changes,’’ specifically the Winebrake et al. combination truck work. 
However, there is also other recent 
work that has not been peer reviewed, or that studies HD VMT rebound in other countries, that bears mention. Resources for the Future (RFF) filed a comment on the proposal with a Working Paper by Leard et al. (2015) to address HDV rebound effects.
818 819  Leard et al.’s paper uses detailed truck- 
level micro-data from the Vehicle Inventory and Use Survey (VIUS) for six survey years (specifically, 1977, 1982, 1987, 1992, 1997, and 2002). The ‘‘rebound effect’’ in this paper is defined to be a combination of a ‘‘VMT elasticity with respect to fuel costs per mile’’ ($/ mile); and a ‘‘truck count elasticity with respect to fuel costs per mile.’’ Fuel costs per mile are defined as fuel price ($/gal) divided by efficiency (mpg). Because the agencies do not estimate the directional impact of this rulemaking on vehicle sales, the portion of Leard et al.’s estimates associated with VMT rebound with respect to fuel costs per mile are the most useful point of comparison to the estimates in the proposal for this rulemaking. 
Leard et al. report a VMT rebound 
effect result of 18.5 percent with respect 
to fuel costs per mile for combination trucks.
820This finding suggests that 
previous estimates of combination truck rebound effects used in the proposed rule, a five percent rebound effect, may be underestimating the true rebound effect. Leard et al. also report a VMT rebound effect with respect to fuel costs per mile of 12.2 percent for single unit trucks.
821This finding (like the findings 
of the Winebrake paper) suggests that the previous use of a 15 percent rebound effect for single unit vehicles in the proposed rule may be overestimating the true rebound effect. As noted, VIUS was discontinued in 2002, so the most recent data in this study is 2002, which is fourteen years old. The Leard et al. Working Paper has not yet been peer reviewed or published. 
Recently, Wadud (2016) has estimated 
price elasticities of diesel demand in the U.K.
822The paper aims to model diesel 
demand elasticities for different freight duty vehicle types in the U.K. Wadud uses a similar model specification as Winebrake et al. in the regression analysis. Wadud finds that diesel consumption in freight vehicles overall is quite inelastic. Diesel demand from articulated trucks and large goods vehicles (similar to combination trucks in the U.S.) does not respond to changes 
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823EPA–HQ–OAR–2014–0827–1336. 
824EPA–HQ–OAR–2014–0827–1467. in diesel prices. Demand in rigid trucks 
(similar to single unit trucks in the U.S.) responds to fuel price changes with a 15 percent elasticity. Wadud’s work presents empirical results in the U.K., which might not be necessarily be appropriate to apply to the U.S. 
(3) How the Agencies Estimated the 
HDV Rebound Effect for the Final Rule 
(a) Values Used in the Phase 2 NPRM 
Analysis 
At the time the agencies conducted 
their analysis of the proposed Phase 2 HD fuel efficiency and GHG emissions standards, the agencies determined that the evidence did not lend itself to any changes in the values used to estimate the VMT rebound effect in the HD Phase 1 rulemaking. The agencies used the rebound effects estimate of 15 percent for vocational vehicles five percent for combination tractors, and 10 percent for HD pickup trucks and vans from the HD Phase 1 rulemaking. 
(b) How the Agencies Analyzed VMT 
Rebound in This Final Rulemaking 
The emergence of new information as 
well as public comment are cause for updating the quantitative values used to estimate the VMT rebound effect from those estimated by the analysis conducted for the HD Phase 1 rulemaking. For vocational trucks, the Winebrake et al. study found no responsiveness of truck travel to diesel fuel prices, suggesting a VMT rebound of essentially zero. Leard et al. suggested a VMT rebound effect for vocational trucks of roughly 12 percent. For combination trucks, the Winebrake et al. study found a rebound effect of essentially zero percent. The Leard et al. study found a VMT elasticity rebound effect of roughly 18 percent for combination trucks. In addition to the RFF comments to which Leard et al. was included, EPA and NHTSA received ten other comments on HDV rebound during the comment period for the proposal, six of which were substantive. One of these commenters suggested that the agencies’ rebound numbers ‘‘appear reasonable.’’ The five others commented that the rebound estimates for both combination and vocational vehicles used in the proposal were overestimated, and suggested using the Winebrake et al. estimates. 
In revising the HD VMT rebound 
estimates, we give somewhat greater consideration to the findings of Winebrake et al. because it is peer- reviewed and published, whereas Leard et al. is a Working Paper. Based on this consideration and on the comments that we received in response to the proposal, the agencies have chosen to revise the 
VMT rebound estimate for vocational trucks down to five percent, and have elected to maintain the use of the five percent rebound effect for tractors. We note that while the Winebrake et al. work supports rebound estimates of zero percent for vocational vehicles and tractors, using a five percent value is conservative and leaves some consideration of uncertainty, as well as some consideration of the (un-peer reviewed and unpublished) findings of the Leard et al. study. The five percent value is in range of the two U.S. studies and generally addresses the issues raised by the commenters. We did not receive new data or comments on our estimated VMT rebound effect for heavy-duty pick-up trucks and vans. Therefore, we have elected to use the 10 percent value used for the proposal. 
It should be noted that the rebound 
estimates we have selected for our analysis represent the VMT impact from the final standards with respect to changes in the fuel cost per mile driven. As described in the RIA (Chapter 8), the HDV rebound effect should ideally be a measure of the change in fuel consumed with respect to the change in overall operating costs due to a change in HDV fuel efficiency. Such a measure would incorporate all impacts from our rules, including those from incremental increases in vehicle prices that reflect costs for improving their fuel efficiency. Therefore, VMT rebound estimates with respect to fuel costs per mile must be ‘‘scaled’’ to apply to total operating costs, by dividing them by the fraction of total operating costs accounted for by fuel use. 
In the NPRM, due to timing 
constraints, we used the same ‘‘overall’’ VMT rebound value for each of the alternatives. For the final rulemaking, we determined VMT rebound separately for each HDV category and for each alternative. The agencies made simplifying assumptions in the VMT rebound analysis for this final rulemaking, similar to the approach taken during HD Phase 1 final rules. For example, due to timing constraints, the agencies did not have the final technology package costs for each of the alternatives prior to the need to conduct the emission inventory analysis. Therefore, the agencies used the technology package costs developed for each of the NPRM alternatives. Chapter 8.3.3 in the RIA provides more details on our assessment of HDV VMT rebound. In addition, Chapter 7 of the RIA presents VMT rebound for each HDV sector that we estimated for the 
final program. These VMT impacts are reflected in the estimates of total fuel savings and reductions in emissions of 
GHG and other air pollutants presented in Section VII and VIII of this Preamble for all categories. 
For the purposes of this final 
rulemaking, we have not taken into account any potential fuel savings or GHG emission reductions from the rail sector due to mode shift because estimates of this effect seem too speculative at this time. Similarly, we have not taken into account any fuel savings or GHG emissions reductions from the potential shift in VMT from older HDVs to newer, more efficient HDVs because we have found no evidence of this potential effect from fuel efficiency standards. The agencies requested comment on these assumptions in the NPRM, but did not receive any. 
Note that while we focus on the VMT 
rebound effect in our analysis of these final rules, there are at least two other types of rebound effects discussed in the energy policy and economics literature. In addition to VMT rebound effects, there are ‘‘indirect’’ rebound effects, which refers to the purchase of other goods or services (that consume energy) with the costs savings from energy efficiency improvements; and ‘‘economy-wide’’ rebound effects, which refers to the increased demand for energy throughout the economy in response to the reduced market price of energy that happens as a result of energy efficiency improvements. One commenter pointed out that consumers may use their savings from lower fuel costs as a result of the direct rebound effect to buy more goods and services, which indirectly increases the use of energy (i.e., the indirect rebound 
effect).
823The commenter states that the 
indirect rebound effect represents a 
positive economic result for consumers, since consumer welfare increases, although it could result in increased energy use and GHG emissions. We agree with the commenter’s observation that, to the extent that indirect rebound does occur, it could have both positive and negative impacts. 
Another commenter suggested that 
the indirect or economy-wide rebound effect could be large enough so as to fully offset the fuel savings and GHG emissions benefits of the rule.
824The 
commenter provides multiple estimates of the potential size of the indirect rebound effect. However, the unpublished methodology used to perform these estimates has not undergone peer review and, as explained in the response to comment 
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825The same entity responsible for these 
comments also sought reconsideration of the Phase 
1 rule on the grounds that indirect rebound effects had not been considered by the agencies and could negate all of the benefits of the standards. This assertion rested on an unsupported affidavit lacking any peer review or other indicia of objectivity. This affidavit cited only one published study. The study cited did not deal with vehicle efficiency, has methodological limitations (many of them acknowledged), and otherwise was not pertinent. EPA and NHTSA thus declined to reconsider the Phase 1 rule based on these speculative assertions. See generally 77 FR 51703–51704, August 27, 2012 and 77 FR 51502–51503, August 24, 2012. The analysis in this entity’s comments on this rulemaking rests largely on that same unsupported affidavit. 
82680 FR 40137. 827See 2010 NAS Report, page 152. document, the agencies find it to be 
dubious. Further, as discussed in detail in the proposal rule and our response to comment document, there are a number of other important questions not addressed by the commenter that must be examined before we can have enough confidence in these kinds of estimates to include them in our economic analysis. 
As discussed in this rule, all of the 
fuel costs savings will not necessarily be passed through to the consumer in terms of cheaper goods and services. First, there may be market barriers that impede trucking companies from passing along the fuel cost savings from the rule in the form of lower rates. Second, there are upfront vehicle costs (and potentially transaction or transition costs associated with the adoption of new technologies) that would partially offset some of the fuel cost savings from our rule, thereby limiting the magnitude of the impact on prices of final goods and services. Also, it is not clear how the fuel savings from the rule would be utilized by trucking firms. For example, trucking firms may reinvest fuel savings in their own company; retain fuel savings as profits; pass fuel savings onto customers or others; or increase driver pay. Finally, it is not clear how the different pathways that fuel savings would be utilized would affect greenhouse gas emissions. 
Research on indirect and economy- 
wide rebound effects is scant, and we have not identified any peer-reviewed research that attempts to quantify indirect or economy-wide rebound effects for HDVs. In particular, the 
agencies are not aware of any peer- reviewed approach which indicates that the magnitude of indirect or economy- wide rebound effects, if any, would be significant for this final rule.
825 
Therefore, we rely on the analysis of vehicle miles traveled to estimate the rebound effect in this rule, as we did for the HD Phase 1 rule, where we attempted to quantify only rebound effects from our rule that impact HDV 
VMT. 
In order to test the effect of alternative 
assumptions about the rebound effect, NHTSA examined the sensitivity of its estimates of benefits and costs of the proposed Phase 2 program for HD pickups and vans to alternative assumptions about the rebound effect. While the main analysis for pickups and vans assumes a 10 percent rebound effect, the sensitivity analysis estimates the benefits and costs of these standards under the assumptions of 5, 15, and 20 percent rebound effects. This sensitivity analysis can be found in Section IX.E.3 of the NPRM Preamble
826and shows 
that (a) using a 5 percent value for the rebound effect reduced benefits and costs of the proposed standards by identical amounts, leaving net benefits unaffected; and (b) rebound effects of 15 percent and 20 percent increased costs and reduced benefits compared to their values in the main analysis, thus reducing net benefits of the proposed standards. Nevertheless, the proposed and now the final program have significant net benefits and these 
alternative values of the rebound effect would not have affected the agencies’ selection of the final program stringency, as that selection is based on NHTSA’s assessment of the maximum feasible fuel efficiency standards and EPA’s selection of appropriate GHG standards to address energy security and the environment. 
F. Impact on Class Shifting, Fleet 
Turnover, and Sales 
The agencies considered two 
additional potential indirect effects which may lead to unintended consequences of the program to improve the fuel efficiency and reduce GHG emissions from HD trucks. The next sections cover the agencies’ qualitative discussions on potential class shifting and fleet turnover effects. 
(1) Class Shifting 
Heavy-duty vehicles are typically 
configured and purchased to perform a 
function. For example, a concrete mixer truck is purchased to transport concrete, a combination tractor is purchased to move freight with the use of a trailer, and a Class 3 pickup truck could be purchased by a landscape company to pull a trailer carrying lawnmowers. The purchaser makes decisions based on many attributes of the vehicle, including the gross vehicle weight rating of the vehicle, which in part determines the amount of freight or equipment that can be carried. If the Phase 2 standards impact either the performance of the 
vehicle or the marginal cost of the vehicle relative to the other vehicle classes, then consumers may choose to purchase a different vehicle, resulting in the unintended consequence of increased fuel consumption and GHG emissions in-use. 
The agencies, along with the NAS 
panel, found that there is little or no literature which evaluates class shifting between trucks.
827In addition, the 
agencies did not receive comments specifically raising concerns about class shifting. NHTSA and EPA qualitatively evaluated the final rules in light of potential class shifting. The agencies looked at four potential cases of shifting: From light-duty pickup trucks to heavy- duty pickup trucks; from sleeper cabs to day cabs; from combination tractors to vocational vehicles; and within vocational vehicles. 
Light-duty pickup trucks, those with 
a GVWR of less than 8,500 lbs, are currently regulated under the existing GHG/CAFE standards for light duty vehicles. The increased stringency of the light-duty 2017–2025 MY vehicle rule has led some to speculate that vehicle consumers may choose to purchase heavy-duty pickup trucks that are currently regulated under the HD Phase 1 program if the cost of the light- duty regulation is high relative to the cost to buy the larger heavy-duty pickup trucks. Since fuel consumption and GHG emissions rise significantly with vehicle mass, a shift from light-duty trucks to heavy-duty trucks would likely lead to higher fuel consumption and GHG emissions, an untended consequence of the regulations. Given the significant price premium of a heavy-duty truck (often five to ten thousand dollars more than a light-duty pickup), we believe that such a class shift would be unlikely whether or not this program exited. These final rules would continue to diminish any incentive for such a class shift because they would narrow the GHG and fuel efficiency performance gap between light-duty and heavy-duty pickup trucks. The regulations for the HD pickup trucks, and similarly for vans, are based on similar technologies and therefore reflect a similar expected increase in cost when compared to the light-duty GHG regulation. Hence, the combination of the two regulations provides little incentive for a shift from 
light-duty trucks to HD trucks. To the extent that this regulation of heavy-duty pickups and vans could conceivably encourage a class shift towards lighter pickups, this unintended consequence 
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828A baseline tractor price of a new day cab is 
$89,500 versus $113,000 for a new sleeper cab 
based on information gathered by ICF in the ‘‘Investigation of Costs for Strategies to Reduce Greenhouse Gas Emissions for Heavy-Duty On-Road Vehicles,’’ July 2010. Page 3. Docket Identification Number EPA–HQ–OAR–2014—0827. 
829The average marginal cost difference between 
sleeper cabs and day cabs in the rule is roughly $2,500. 830The final rule projects the average per-vehicle 
costs associated with the 2027 MY standards to be generally less than five percent of the overall price of a new vehicle. The cost-effectiveness of these vocational vehicle standards in dollars per ton is similar to the cost effectiveness estimated for light- duty trucks in the 2017–2025 light duty greenhouse gas standards (Preamble section V.C.3). would in fact be expected to lead to 
lower fuel consumption and GHG emissions as the smaller light-duty pickups have significantly better fuel economy ratings than heavy-duty pickup trucks. 
The projected cost increases for this 
action differ between Class 8 day cabs and Class 8 sleeper cabs, reflecting our conservative assumption for purposes of this analysis on shifting that compliance with these standards would lead truck consumers to specify sleeper cabs equipped with APUs or alternatives to APU while day cab consumers would not. Since Class 8 day cab and sleeper cab trucks perform essentially the same function when hauling a trailer, this raises the possibility that the additional cost for an APU or alternatives to APU equipped sleeper cab could lead to a shift from sleeper cab to day cab trucks. We do not believe that such an intended consequence would occur for the following reasons. The addition of a sleeper berth to a tractor cab is not a consumer-selectable attribute in quite the same way as other vehicle features. The sleeper cab provides a utility that long-distance trucking fleets need to conduct their operations—an on-board sleeping berth that lets a driver comply with federally-mandated rest periods, as required by the Department of Transportation Federal Motor Carrier Safety Administration’s hours-of-service regulations. The cost of sleeper trucks is already higher than the cost of day cabs, yet the fleets that need this utility purchase them.
828A day cab simply 
cannot provide this utility with a single driver. The need for this utility would not be changed even if the additional costs to reduce greenhouse gas emissions from sleeper cabs exceed those for reducing greenhouse gas emissions from day cabs.
829 
A trucking fleet could instead decide 
to put its drivers in hotels in lieu of using sleeper berths, and switch to day cabs. However, this is unlikely to occur in any great number, since the added cost for the hotel stays would far overwhelm differences in the marginal cost between day and sleeper cabs. Even if some fleets do opt to buy hotel rooms and switch to day cabs, they would be highly unlikely to purchase a day cab that was aerodynamically worse than the sleeper cab they replaced, since the 
need for features optimized for long- distance hauling would not have changed. So in practice, there would likely be little difference to the environment for any switching that might occur. Further, while our projected costs in the NPRM assumed the purchase of an APU for compliance for nearly all sleeper cabs, the updated analysis reflects additional flexibility in the final rules that would allow manufacturers to use several other alternatives to APUs that would be much less expensive. Thus, even though we are now projecting that APU costs will be somewhat higher than what we projected for the NPRM, manufacturers and consumers will not be required to use them. In fact, this regulatory structure would allow compliance using a near zero cost software utility that eliminates tractor idling after five minutes. Using this compliance approach, the cost difference between a Class 8 sleeper cab and day cab due to these regulations is small. We are proposing this alternative compliance approach reflecting that some sleeper cabs are used in team driving situations where one driver sleeps while the other drives. In that situation, an APU is unnecessary since the tractor is continually being driven when occupied. When it is parked, it would automatically eliminate any additional idling through the shutdown software. If trucking businesses choose this option, then costs based on purchase of APUs may overestimate the costs of this program to this sector. 
Class shifting from combination 
tractors to vocational vehicles may occur if a customer deems the additional marginal cost of tractors due to the regulation to be greater than the utility provided by the tractor. The agencies initially considered this issue when deciding whether to include Class 7 tractors with the Class 8 tractors or regulate them as vocational vehicles. The agencies’ evaluation of the combined vehicle weight rating of the Class 7 shows that if these vehicles were treated significantly differently from the Class 8 tractors, then they could be easily substituted for Class 8 tractors. Therefore, the agencies will continue to include both classes in the tractor category. The agencies believe that a shift from tractors to vocational vehicles would be limited because of the ability of tractors to pick up and drop off trailers at locations which cannot be done by vocational vehicles. 
The agencies do not envision that the 
regulatory program would cause class 
shifting within the vocational vehicle class. As vocational vehicles include a wide variety of vehicle types, and serve a wide range of functions, the diversity in the vocational vehicle segment can be primarily attributed to the variety of customer needs for specialized vehicle bodies and added equipment, rather than to the chassis. The new standards are projected to lead to a small increase in the incremental cost per vehicle. However, these cost increases are consistent across the board for both vocational vehicles and the engines used in the vehicle (Table V–30 at Preamble Section V.C.(2)(e)). The agencies believe that the utility gained from the additional technology package would outweigh the additional cost for vocational vehicles.
830 
In conclusion, NHTSA and EPA 
believe that the regulatory structure for HD vehicles and engines would not significantly change the current competitive and market factors that determine purchaser preferences. Furthermore, even if a small amount of shifting would occur, any resulting GHG impacts would likely to be negligible because any vehicle class that sees an uptick in sales is also being regulated for GHG emission control and fuel efficiency. Therefore, the agencies did not include an impact of class shifting on the vehicle populations used to assess the benefits of the program. 
(2) Fleet Turnover and Sales Effects 
A regulation that affects the cost to 
purchase and/or operate trucks could 
affect whether a consumer decides to purchase a new truck and the timing of that purchase. The term pre-buy refers to the idea that truck purchases may occur earlier than otherwise planned to avoid the additional costs associated with a new regulatory requirement. Slower fleet turnover, or low-buys, may occur when owners opt to keep their existing truck rather than purchase a new truck due to the incremental cost of the regulation. 
Several commenters raised the 
possibility of pre-buy for these standards. Allison Transmission, the National Automobile Dealers Association, the Owner-Operator Independent Drivers Association, and the Truck Renting and Leasing Association point toward pre-buy associated with standards from the 2000s for nitrogen oxides (NO
X) 
regulations as evidence of the likelihood 
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831Committee to Assess Fuel Economy 
Technologies for Medium- and Heavy-Duty 
Vehicles; National Research Council; Transportation Research Board (2010). ‘‘Technologies and Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty Vehicles,’’ (hereafter, ‘‘NAS Report’’). Washington, DC, the National Academies Press. Available electronically from the National Academies Press Web site at http://www.nap.edu/ catalog.php?record_ id=12845., pp. 150–151, Docket 
EPA–HQ–OAR–2014–0827–0276. 
832See NAS Report, Note 831, page 151, Docket 
EPA–HQ–OAR–2014–0827–0276. 833Technical Support Document: Technical 
Update of the Social Cost of Carbon for Regulatory 
Impact Analysis Under Executive Order 12866 (May 2013, Revised July 2015), Interagency Working Group on Social Cost of Carbon, with participation by Council of Economic Advisers, Council on Environmental Quality, Department of Agriculture, Department of Commerce, Department of Energy, Department of Transportation, Environmental Protection Agency, National Economic Council, Office of Energy and Climate Change, Office of Management and Budget, Office of Science and Technology Policy, and Department of Treasury. Available at: https://www.whitehouse.gov/sites/default/files/omb/inforeg/scc-tsd-final-july- 2015.pdf. of pre-buy for vehicle GHG and fuel 
efficiency standards. Daimler Trucks North America, the International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America, and the Truck and Engine Manufacturers Association express concern about pre-buy specifically in the context of NPRM Alternative 4, due to concerns that the time frame for technology development and adoption was too short. Daimler Trucks and the Environmental Defense Fund note that Phase 1 did not appear to result in pre- buy. Volvo Group notes that the phase- in approach of Phase 1 plus the flexibilities available eased the transition to new technologies, and that gradual market acceptance of new technologies will lead to less disruption than an accelerated program. The Recreational Vehicle Industry Association expressed concern that the standards will have a negative effect on recreational vehicle sales. 
The 2010 NAS HD Report discussed 
the topics associated with medium- and heavy-duty vehicle fleet turnover. NAS 
noted that there is some empirical evidence of pre-buy behavior in response to the 2004 and 2007 heavy- duty engine emission standards, with larger impacts occurring in response to higher costs.
831However, those 
regulations increased upfront costs to firms without any offsetting future cost savings from reduced fuel purchases. In summary, NAS stated that: 
. . . during periods of stable or 
growing demand in the freight sector, pre-buy behavior may have significant impact on purchase patterns, especially for larger fleets with better access to capital and financing. Under these same conditions, smaller operators may simply elect to keep their current equipment on the road longer, all the more likely given continued improvements in diesel engine durability over time. On the other hand, to the extent that fuel economy improvements can offset incremental purchase costs, these impacts will be lessened. Nevertheless, when it comes to efficiency investments, most heavy- duty fleet operators require relatively quick payback periods, on the order of two to three years.
832 
The regulations are projected to return 
fuel savings to the vehicle owners that offset the cost of the regulation within a few years. The effects of the regulation on purchasing behavior and sales will depend on the nature of the market failures and the extent to which firms consider the projected future fuel savings in their purchasing decisions. 
If trucking firms or other buyers 
account for the rapid payback, they are unlikely to strategically accelerate or delay their purchase plans at additional cost in capital to avoid a regulation that will lower their overall operating costs. As discussed in Section IX.A., this scenario may occur if this program reduces uncertainty about fuel-saving technologies. More reliable information about ways to reduce fuel consumption allows truck purchasers to evaluate better the benefits and costs of additional fuel savings, primarily in the original vehicle market, but possibly in the resale market as well. In addition, these standards are expected to lead manufacturers to install more fuel- saving technologies and promote their purchase; the increased availability and promotion may encourage sales. 
Other market failures may leave open 
the possibility of some pre-buy or delayed purchasing behavior. Firms may not consider the full value of the future fuel savings for several reasons. For instance, truck purchasers may not want to invest in fuel efficiency because of uncertainty about fuel prices. Another explanation is that the resale market may not fully recognize the value of fuel savings, due to lack of trust of new technologies or changes in the uses of the vehicles. Lack of coordination (also called split incentives—see Section IX.A) between truck purchasers (who may emphasize the up-front costs of the trucks) and truck operators, who like the fuel savings, can also lead to pre-buy or delayed purchasing behavior. If these market failures prevent firms from fully internalizing fuel savings when deciding on vehicle purchases, then pre- buy and delayed purchase could occur and could result in a slight decrease in the GHG benefits of the regulation. 
Thus, whether pre-buy or delayed 
purchase is likely to play a significant role in the truck market depends on the specific behaviors of purchasers in that market. Without additional information about which scenario is more likely to be prevalent, the agencies are not projecting a change in fleet turnover 
characteristics due to this regulation. 
Industry purchasing in relation to the 
advent of the Phase 1 standards offers at least some insight into the impacts of these standards. The Environmental Defense Fund observes that MY 2014 heavy-duty trucks had the highest sales since 2005. Any trends in sales are likely to be affected by macroeconomic conditions, which have been recovering since 2009–2010. The standards may have affected sales, but the size of that effect is likely to be swamped by the effects of the economic recovery. It is unlikely to be possible to separate the effects of the existing standards from other confounding factors. 
G. Monetized GHG Impacts (1) Monetized CO
2Impacts—The Social 
Cost of Carbon (SC-CO 2) 
We estimate the global social benefits 
of CO 2emission reductions expected 
from the heavy-duty GHG and fuel 
efficiency standards using the social cost of carbon (SC-CO
2) estimates 
presented in the Technical Support Document: Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866 (May 2013, Revised July 2015) 
(‘‘current SC-CO2 TSD’’).
833(The SC- 
CO 2estimates are presented in Table 
IX–11). We refer to these estimates, which were developed by the U.S. government, as ‘‘SC-CO
2estimates.’’ The 
SC-CO 2is a metric that estimates the 
monetary value of impacts associated with marginal changes in CO
2emissions 
in a given year. It includes a wide range of anticipated climate impacts, such as net changes in agricultural productivity and human health, property damage from increased flood risk, and changes in energy system costs, such as reduced costs for heating and increased costs for air conditioning. It is typically used to assess the avoided damages as a result of regulatory actions (i.e., benefits of 
rulemakings that lead to an incremental reduction in cumulative global CO
2 
emissions). 
The SC-CO 2estimates used in this 
analysis were developed over many 
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834Both the 2010 SC-CO 2TSD and the current 
TSD are available at: https://www.whitehouse.gov/ 
omb/oira/social-cost-of-carbon. The 2010 SC-CO 2 
TSD also available in the docket: Docket ID EPA– 
HQ–OAR–2009–0472–114577, Technical Support 
Document: Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866, Interagency Working Group on Social Cost of Carbon, with participation by the Council of Economic Advisers, Council on Environmental Quality, Department of Agriculture, Department of Commerce, Department of Energy, Department of Transportation, Environmental Protection Agency, National Economic Council, Office of Energy and Climate Change, Office of Management and Budget, Office of Science and Technology Policy, and Department of Treasury (February 2010). Also available at: http://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost- 
of-Carbon-for-RIA.pdf . 
835See https://www.whitehouse.gov/sites/default/ 
files/omb/inforeg/scc-response-to-comments-final- 
july-2015.pdf. 836The current SC-CO 2TSD presents the SC-CO 2 
estimates in $2007. These estimates were adjusted 
to 2013$ using the GDP Implicit Price Deflator. Bureau of Economic Analysis, Table 1.1.9 Implicit Price Deflators for Gross Domestic Product; last revised on September 25, 2015. years, using the best science available, 
and with input from the public. Specifically, an interagency working group (IWG) that included EPA, DOT, and other executive branch agencies and offices used three integrated assessment models (IAMs) to develop the SC-CO
2 
estimates and recommended four global values for use in regulatory analyses. The SC-CO
2estimates were first 
released in February 2010 and updated in 2013 using new versions of each IAM. The 2013 update did not revisit the 2010 modeling decisions (e.g., with 
regard to the discount rate, reference case socioeconomic and emission scenarios or equilibrium climate sensitivity). Rather, improvements in the way damages are modeled are confined to those that have been incorporated into the latest versions of the models by the developers themselves and used for analyses in peer-reviewed publications. The 2010 SC-CO
2Technical Support Document 
(2010 SC-CO 2TSD) provides a complete 
discussion of the methods used to develop these estimates and the current SC-CO
2TSD presents and discusses the 
update (including recent minor technical corrections to the estimates).
834 
The 2010 SC-CO 2TSD noted a 
number of limitations to the SC-CO 2 
analysis, including the incomplete way in which the IAMs capture catastrophic and non-catastrophic impacts, their incomplete treatment of adaptation and technological change, uncertainty in the extrapolation of damages to high temperatures, and assumptions regarding risk aversion. Currently IAMs do not assign value to all of the important physical, ecological, and economic impacts of climate change recognized in the climate change literature due to a lack of precise information on the nature of damages and because the science incorporated into these models understandably lags behind the most recent research. Nonetheless, these estimates and the discussion of their limitations represent the best available information about the social benefits of CO
2reductions to 
inform benefit-cost analysis; see RIA of this rule and the SC-CO
2TSDs for 
additional details. The new versions of the models used to estimate the values presented below offer some improvements in these areas, although further work is warranted. 
Accordingly, EPA and other agencies 
continue to engage in research on modeling and valuation of climate impacts with the goal to improve these estimates. The EPA and other federal agencies also continue to consider feedback on the SC-CO
2estimates from 
stakeholders through a range of channels, including public comments on Agency rulemakings that use the SC- CO
2in supporting analyses and through 
regular interactions with stakeholders 
and research analysts implementing the SC-CO
2methodology used by the IWG. 
The SC-CO 2comments received on this 
rulemaking covered the technical details of the modeling conducted to develop the SC-CO
2estimates and some also 
provided constructive recommendations for potential opportunities to improve the SC-CO
2estimates in future updates. 
EPA has carefully considered all of these comments and continues to conclude that the current estimates represent the best scientific information on the impacts of climate change available in a form appropriate for incorporating the damages from incremental CO
2emissions changes into 
regulatory analysis. Therefore, EPA has presented the current SC-CO
2estimates 
in this rulemaking. See Section 11.8 of the RTC document for a summary of and response to the SC-CO
2comments 
submitted to this rulemaking. In addition, OMB sought public comment on the approach used to develop the SC- CO
2estimates through a separate 
comment period and published a response to those comments in 2015.
835 
After careful evaluation of the full 
range of comments submitted to OMB, the IWG continues to recommend the use of the SC-CO
2estimates in 
regulatory impact analysis. With the July 2015 release of the response to comments, the IWG announced plans to obtain expert independent advice from the National Academies of Sciences, Engineering and Medicine to ensure that the SC-CO
2estimates continue to reflect 
the best available scientific and economic information on climate change. The Academies then convened a committee, ‘‘Assessing Approaches to Updating the Social Cost of Carbon,’’ 
(Committee) which is reviewing the state of the science on estimating the SC-CO
2, and will provide expert, 
independent advice on the merits of different technical approaches for modeling and highlight research priorities going forward. EPA will evaluate its approach based upon any feedback received from the Academies’ panel. 
To date, the Committee has released 
an interim report, which recommended against doing a near term update of the SC-CO
2estimates. For future revisions, 
the Committee recommended the IWG move efforts towards a broader update of the climate system module consistent with the most recent, best available science, and also offered recommendations for how to enhance the discussion and presentation of uncertainty in the SC-CO
2estimates. 
Specifically, the Committee recommended that ‘‘the IWG provide guidance in their technical support documents about how [SC-CO
2] 
uncertainty should be represented and discussed in individual regulatory impact analyses that use the [SC-CO
2]’’ 
and that the technical support document for each update of the estimates present a section discussing the uncertainty in the overall approach, in the models used, and uncertainty that may not be included in the estimates. At the time of this writing, the IWG is reviewing the interim report and considering the recommendations. EPA looks forward to working with the IWG to respond to the recommendations and will continue to follow IWG guidance on SC-CO
2. 
The four global SC-CO 2estimates are 
as follows: $13, $46, $68, and $140 per metric ton of CO
2emissions in the year 
2020 (2013$).836The first three values 
are based on the average SC-CO 2from 
the three IAMs, at discount rates of 5, 3, and 2.5 percent, respectively. SC-CO
2 
estimates for several discount rates are included because the literature shows that the SC-CO
2is quite sensitive to 
assumptions about the discount rate, and because no consensus exists on the appropriate rate to use in an intergenerational context (where costs and benefits are incurred by different generations). The fourth value is the 95th percentile of the SC-CO
2from all 
three models at a 3 percent discount rate. It is included to represent lower 
probability but higher outcomes from 
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837See more discussion on the appropriate 
discounting of climate benefits using SC-CO 2in the 2010 SCC TSD. Other benefits and costs of 
proposed regulations unrelated to CO 2emissions are discounted at the 3% and 7% rates specified in OMB guidance for regulatory analysis. climate change, which are captured 
further out in the tail of the SC-CO 2 
distribution, and while less likely than those reflected by the average SC-CO
2 
estimates, would be much more harmful to society and therefore, are relevant to policy makers. The SC-CO
2increases 
over time because future emissions are expected to produce larger incremental damages as economies grow and physical and economic systems become more stressed in response to greater climate change. The SC-CO
2values are 
presented in Table IX–11. 
Applying the global SC-CO 2estimates, 
shown in Table, to the estimated 
reductions in domestic CO 2emissions 
for the program, yields estimates of the dollar value of the climate related benefits for each analysis year. These estimates are then discounted back to the analysis year using the same discount rate used to estimate the SC- CO
2. For internal consistency, the 
annual benefits are discounted back to net present value terms using the same 
discount rate as each SC-CO 2estimate 
(i.e., 5 percent, 3 percent, and 2.5 
percent) rather than the discount rates 
of 3 percent and 7 percent used to derive the net present value of other streams of costs and benefits of the final rule.
837The SC-CO 2benefit estimates 
for each calendar year are shown in 
Table. The SC-CO 2benefit estimates for 
each model year are shown in Table IX– 13. 
TABLE IX–11—S OCIAL COST OF CO 2, 2012–2050a 
[in 2013$ per Metric Ton] 
Calendar 
year 5% 
Average 3% 
Average 2.5% 
Average 3%, 
95th Percentile 
2012 ................................................................................................................. $12 $36 $5 8 $100 
2015 ................................................................................................................. 12 40 62 1 20 
2020 ................................................................................................................. 13 46 68 1 40 
2025 ................................................................................................................. 15 51 75 1 50 
2030 ................................................................................................................. 18 55 80 1 70 
2035 ................................................................................................................. 20 60 86 1 80 
2040 ................................................................................................................. 23 66 92 2 00 
2045 ................................................................................................................. 25 70 98 2 20 
2050 ................................................................................................................. 29 76 100 230 
Note: 
aThe SC-CO 2values are dollar-year and emissions-year specific and have been rounded to two significant digits. Unrounded numbers from 
the current SC-CO 2TSD were used to calculate the CO 2benefits. 
TABLE IX–12—U PSTREAM AND DOWNSTREAM ANNUAL CO 2BENEFITS FOR THE GIVEN SC-CO 2VALUEaUSING METHOD  
B ANDRELATIVE TO THE FLATBASELINE  
[Millions of 2013$]b 
Calendar year 5% 
average 3% 
average 2.5% 
average 3% 
95th percentile 
2018 ................................................................................................................. $7 $22 $33  $63 
2019 ................................................................................................................. 13 46 68 1 30 
2020 ................................................................................................................. 21 73 110 210 
2021 ................................................................................................................. 80 280 420  840 
2022 ................................................................................................................. 170 550 82 0 1,700 
2023 ................................................................................................................. 250 850 1, 300 2,600 
2024 ................................................................................................................. 390 1,300 2,000 4,000 
2025 ................................................................................................................. 560 1,800 2,700 5,500 
2026 ................................................................................................................. 700 2,400 3,500 7,100 
2027 ................................................................................................................. 950 3,000 4,400 9,100 
2028 ................................................................................................................. 1,100 3,700 5,400 11,000 
2029 ................................................................................................................. 1,300 4,300 6,400 13,000 
2030 ................................................................................................................. 1,600 5,000 7,300 15,000 
2035 ................................................................................................................. 2,700 8,10 0 11,000 25,000 
2040 ................................................................................................................. 3,700 11,0 00 15,000 33,000 
2050 ................................................................................................................. 5,500 15,0 00 20,000 45,000 
NPV .................................................................................................................. 24,000 110 ,000 180,000 340,000 
Notes: 
aThe SC-CO 2values are dollar-year and emissions-year specific. 
bFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
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838As discussed in the RIA, there is considerable 
variation among these published estimates in the 
models and input assumptions they employ. These 
studies differ in the emission perturbation year, employ a wide range of constant and variable discount rate specifications, and consider a range of 
baseline socioeconomic and emissions scenarios that have been developed over the last 20 years. See 
also Reilly and Richards, 1993; Schmalensee, 1993; Fankhauser, 1994; Marten and Newbold, 2012. 839Marten, A.L., E.A. Kopits, C.W. Griffiths, S.C. 
Newbold & A. Wolverton (2014). Incremental CH 4 
and N 2O mitigation benefits consistent with the 
U.S. Government’s SC-CO 2estimates, Climate 
Policy, DOI: 10.1080/14693062.2014.912981. TABLE IX–13—U PSTREAM AND DOWNSTREAM DISCOUNTED MODEL YEARLIFETIME CO 2BENEFITS FOR THE GIVEN SC- 
CO 2VALUE USING METHOD B ANDRELATIVE TO THE FLATBASELINE  
[Millions of 2013$]ab 
Model year 5% 
average 3% 
average 2.5% 
average 3% 
95th percentile 
2018 ................................................................................................................. $38 $150 $230 $450 
2019 ................................................................................................................. 36 140 220  430 
2020 ................................................................................................................. 34 140 220  420 
2021 ................................................................................................................. 560 2,300 3,600 7,000 
2022 ................................................................................................................. 590 2,500 3,900 7,500 
2023 ................................................................................................................. 610 2,600 4,000 7,800 
2024 ................................................................................................................. 920 4,000 6,200 12,000 
2025 ................................................................................................................. 940 4,100 6,400 12,000 
2026 ................................................................................................................. 950 4,200 6,600 13,000 
2027 ................................................................................................................. 1,200 5,400 8,500 16,000 
2028 ................................................................................................................. 1,200 5,300 8,400 16,000 
2029 ................................................................................................................. 1,200 5,300 8,400 16,000 
Sum .................................................................................................................. 8,200 36,0 00 57,000 110,000 
Notes: 
aThe SC-CO 2values are dollar-year and emissions-year specific. 
bFor an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 
1b, please see Section X.A.1. 
(2) Monetized Non-CO 2GHG Impacts 
EPA calculated the global social 
benefits of CH 4and N 2O emissions 
reductions expected from the final 
rulemaking using estimates of the social cost of methane (SC-CH
4) and the social 
cost of nitrous oxide (SC-N 2O). Similar 
to the SC-CO 2, the SC-CH 4and SC-N 2O 
estimate the monetary value of impacts associated with marginal changes in CH
4and N 2O emissions, respectively, in 
a given year. Each metric includes a wide range of anticipated climate impacts, such as net changes in agricultural productivity and human health, property damage from increased flood risk, and changes in energy system costs, such as reduced costs for heating and increased costs for air conditioning. The SC-CH
4and SC-N 2O estimates 
applied in this analysis were developed by Marten et al. (2014) and are discussed in greater detail below. EPA is unaware of analogous estimates of HFC–134a and has therefore presented a sensitivity analysis, separate from the main benefit cost analysis, that 
approximates the benefits of HFC–134a reductions based on global warming potential (GWP) gas comparison metrics (‘‘GWP approach’’). Other unquantified non-CO
2benefits are discussed in this 
section as well. Additional details are provided in the RIA of these rules. 
(a) Monetized CH
4and N 2O Impacts 
As discussed in the proposed 
rulemaking, a challenge particularly 
relevant to the monetization of non-CO 2 
GHG impacts is that the IWG did not estimate the social costs of non-CO
2 
GHG emissions at the time the SC-CO 2 
estimates were developed. While there are other estimates of the social cost of non-CO
2GHGs in the peer review 
literature, none of those estimates are consistent with the SC-CO
2estimates 
developed by the IWG and most are likely underestimates due to changes in 
the underlying science subsequent to their publication.
838 
However, in the time leading up to 
the proposal for this rulemaking, a paper by Marten et al. (2014) provided 
the first set of published SC-CH 4and 
SC-N 2O estimates in the peer-reviewed 
literature that are consistent with the modeling assumptions the IWG used to develop the SC-CO
2estimates.839 
Specifically, the estimation approach of Marten et al. (2014) used the same set of three IAMs, five socioeconomic- emissions scenarios, equilibrium climate sensitivity distribution, three constant discount rates, and aggregation approach used to develop the SC-CO
2 
estimates. Marten et al. also used the same rationale as the IWG to develop global estimates of the SC-CH
4and the 
SC-N 2O, given that CH 4and N 2O are 
global pollutants. 
The resulting SC-CH 4and SC-N 2O 
estimates are presented in Table IX–14. More detailed discussion of their methodology, results and a comparison to other published estimates can be found in the RIA and in Marten et al. (2014). 
TABLE IX–14—S OCIAL COST OF CH 4ANDN2O, 2012–2050a 
[In 2013$ per metric ton] [Source: Marten et al., 2014b] 
Year SC-CH 4 SC-N 2O 
5% 
average 3% 
average 2.5% 
average 3% 
95th percentile 5% 
average 3% 
average 2.5% 
average 3% 
95th percentile 
2012 .................................. $440 $1,000 $1,400 $2,800 $4,000 $14,000 $21,000 $36,000 
2015 .................................. 490 1,100 1,500 3,100 4,400 14,000 22,000 38,000 
2020 .................................. 590 1,300 1,800 3,500 5,200 16,000 24,000 43,000 
2025 .................................. 710 1,500 2,000 4,100 6,000 19,000 26,000 48,000 
2030 .................................. 830 1,800 2,200 4,600 6,900 21,000 30,000 54,000 
2035 .................................. 990 2,000 2,500 5,400 8,100 23,000 32,000 60,000 
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840For a copy of the peer review and the 
responses, see https://cfpub.epa.gov/si/si _public_pra_view.cfm?dirEntryID=291976 (see ‘‘SCCH 4EPA 
PEER REVIEW FILES.PDF’’). TABLE IX–14—S OCIAL COST OF CH 4ANDN2O, 2012–2050a—Continued 
[In 2013$ per metric ton] [Source: Marten et al., 2014b] 
Year SC-CH 4 SC-N 2O 
5% 
average 3% 
average 2.5% 
average 3% 
95th percentile 5% 
average 3% 
average 2.5% 
average 3% 
95th percentile 
2040 .................................. 1,100 2,200 2,900 6,000 9,200 25,000 35,000 66,000 
2045 .................................. 1,300 2,500 3,100 6,700 10,000 27,000 37,000 73,000 
2050 .................................. 1,400 2,700 3,400 7,400 12,000 30,000 41,000 79,000 
Notes: 
aThe values are emissions-year specific and have been rounded to two significant digits. Unrounded numbers were used to calculate the GHG benefits. 
bThe estimates in this table have been adjusted to reflect the minor technical corrections to the SC-CO 2estimates described above. See the Corrigendum to 
Marten et al. (2014), http://www.tandfonline.com/doi/abs/10.1080/14693062.2015.1070550. 
In addition to requesting comment on 
these estimates in the proposed 
rulemaking, EPA noted that it had initiated a peer review of the application of the Marten et al (2014) non-CO
2social cost estimates in 
regulatory analysis.840EPA also stated 
that, pending a favorable peer review, it planned to use the Marten et al (2014) estimates to monetize benefits of CH
4 
and N 2O emission reduction in the main 
benefit-cost analysis of the final rule. 
Since then, EPA received responses 
that supported use of the Marten et al. estimates. Three reviewers considered seven charge questions that covered issues such as the EPA’s interpretation of the Marten et al. estimates, the consistency of the estimates with the SC-CO
2estimates, the EPA’s 
characterization of the limits of the GWP-approach to value non-CO
2GHG 
impacts, and the appropriateness of using the Marten et al. estimates in regulatory impact analyses. The reviewers agreed with the EPA’s interpretation of Marten et al.’s estimates, generally found the estimates to be consistent with the SC-CO
2 
estimates, and concurred with the limitations of the GWP approach, finding directly modeled estimates to be more appropriate. While outside of the scope of the review, the reviewers briefly considered the limitations in the SC-CO
2methodology (e.g., those 
discussed earlier in this section) and noted that because the SC-CO
2and SC- 
CH 4and SC-N 2O methodologies are 
similar, the limitations also apply to the resulting SC-CH
4and SC-N 2O estimates. Two of the reviewers concluded that use of the SC-CH
4and SC-N 2O estimates 
developed by Marten et al. and published in the peer-reviewed literature is appropriate in RIAs, provided that the Agency discuss the limitations, similar to the discussion provided for SC-CO
2and other 
economic analyses. All three reviewers encouraged continued improvements in the SC-CO
2estimates and suggested that 
as those improvements are realized they should also be reflected in the SC-CH
4 
and SC-N 2O estimates, with one 
reviewer suggesting the SC-CH 4and SC- 
N2O estimates lag this process. The EPA 
supports continued improvement in the SC-CO
2estimates developed by the U.S. 
government and agrees that improvements in the SC-CO
2estimates 
should also be reflected in the SC-CH 4 
and SC-N 2O estimates. The fact that the 
reviewers agree that the SC-CH 4and SC- 
N2O estimates are generally consistent 
with the SC-CO 2estimates that are 
recommended by OMB’s guidance on valuing CO
2emissions reductions, leads 
the EPA to conclude that use of the SC- CH
4and SC-N 2O estimates is an 
analytical improvement over excluding CH
4and N 2O emissions from the 
monetized portion of the benefit cost analysis. 
The EPA also carefully considered the 
full range of public comments and associated technical issues on the Marten et al. estimates received in this rulemaking and determined that it would continue to use the estimates in the final rulemaking analysis. Based on the evaluation of the public comments on this rulemaking, the favorable peer 
review of the application of Marten et al. estimates, and past comments urging EPA to value non-CO
2GHG impacts in 
its rulemakings, EPA concluded that the 
estimates represent the best scientific information on the impacts of climate change available in a form appropriate for incorporating the damages from incremental CH
4and N 2O emissions 
changes into regulatory analysis and has 
included those benefits in the main benefits analysis. Please see RTC Section 11.8 for detailed responses to the comments on non-CO
2GHG 
valuation. 
The application of directly modeled 
estimates from Marten et al. (2014) to benefit-cost analysis of a regulatory 
action is analogous to the use of the SC- CO
2estimates. Specifically, the SC-CH 4 
and SC-N 2O estimates in Table IX–15 
are used to monetize the benefits of changes in CH
4and N 2O emissions 
expected as a result of the final rulemaking. Forecast changes in CH
4 
and N 2O emissions in a given year 
resulting from the regulatory action are multiplied by the SC-CH
4and SC-N 2O 
estimate for that year, respectively. To obtain a present value estimate, the monetized stream of future non-CO
2 
benefits are discounted back to the analysis year using the same discount rate used to estimate the social cost of the non-CO
2GHG emission changes. 
The CH 4and N 2O benefits based on 
Marten et al. (2014) are presented for each calendar year in Table IX–15. 
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