# 3) **Annualized Estimat es of Costs and Benefits using Model** 

**Ye ar 2014**  **- 2018 anal** **ysis** Commenters also recommend that agencies include summary tables of annualized costs and benefits using 3 and 7% discount rates using model year 2014 -2018 analysis. Please include these tables in the summary of the Preamble and the RIA. **Response:** We now have such a table in the Executive Summary of the RIA and can also include the annualized costs in the preamble as well, as shown below. Lifetime Present Valuec



### – 3% Discount Rate Program Costs $ 8.8 Fuel Savings $ 50 Benefits $7.4 Net Benefits $49

Annualized Valued



### – 3% Discount Rate Annualized benefits $2.6 Annualized costs $0.4 Net benefits $2.2

Lifetime Present Valuec 

### - 7% Discount Rate Program Costs $ 8.8 Fuel Savings $ 34 Benefits $6.7 Net Benefits $ 32

Annualized Valued



### – 7% Discount Rate Annualized benefits $3.1 Annualized costs $0.7 Net benefits $2.4

# 8) **Anal ysis of Alternati** **ve s for Subcat** **egories**

Also regarding the analysis of alternatives, while tables 6 -22 and 6-23 (once corrected) will allow for a comparison of the monetized net benefits of an overall alternative in aggregate across all model years, the tables present aggregate information on the entire set of regulatory subcategories (e.g., vehicle weight classes) and for all model years included in the rulemaking. However, the RIA does not currently present net benefit calculations for the alternatives with respect to individual subcategories or model years, which would allow reviewers to establish that the selected regulatory alternative was the one that maximizes net benefits for each subcategory (e.g., pickups and vans, vocational vehicles, and combination tractors) and model year. During review of the proposed rule, agencies requested that this information be added to the RIA, given that the agencies have flexibility with respect to the choice of standards for each model year and for each regulatory subcategory. **Commenters request that the agencies provide versions of Tables 6 -** **22 and 6 -** **23 for each subcategory and model year (2014** **- 2018).**  **Response:** The agencies have presented the net benefits by alternative as the sum of 2014 through 2018 model years. The agencies believe that the presentation that is already included in the RIA (see page 6- 14 and 6- 15) and preamble (see page 496) which reflects the CO 2 

### emissions reductions, oil savings, and costs by subcategory in 2030 and 2050 provides the ability for reviewers to analyze the different alternatives relative to each subcategory. These tables have been added below. DOWNSTREAM CO2 

### REDUCTIONS (MMT) OIL REDUCTIONS (BILLION GALLONS) 2030 2050 2030 2050 Alt. 1 Baseline 0 0 0 0 Alt. 1a AEO 2011 BaselineTotal 39 90 3.9 9.0

Tractors 29 73 2.9 7.1 HD Pickup Trucks 9 16 0.9 1.7 Vocational Vehicles 1 2 0.1 0.2 Alt. 2 Less Stringent- Total 54 78 5.4 7.7

Tractors 42 59 4.2 5.8 HD Pickup Trucks 7 11 0.8 1.2 Vocational Vehicles 5 7 0.4 0.7 Alt. 3 Preferred

– Total 61 88 6.0 8.7

Tractors 45 63 4.4 6.2 HD Pickup Trucks 8 13 0.9 1.3 Vocational Vehicles 7 11 0.7 1.1

### Alt. 4 More Stringent

– Total 74 107 7.4 10.7

Tractors 53 74 5.2 7.3 HD Pickup Trucks 10 15 1.0 1.6 Vocational Vehicles 11 18 1.1 1.8 Alt. 5 Max Technology

– Total 99 146 9.8 14.5

Tractors 61 85 6.0 8.3 HD Pickup Trucks 15 24 1.6 2.5 Vocational Vehicles 23 37 2.2 3.6 TECHNOLOGY COSTS (2009$ MILLIONS)

2030 2050 Alt. 1 Baseline $0 $0 Alt. 1a AEO 2011 BaselineTotal b 

### -- --

Tractors -- -- HD Pickup Trucks -- -- Vocational Vehicles -- -- Alt. 2 Less Stringent - Total $1,676 $2,440



### Tractors $743 $1,227 

### HD Pickup Trucks $817 $1,029 

### Vocational Vehicles $117 $185 

### Alt. 3 Preferred

– Total $2,593 $3,769



### Tractors $1,076 $1,777 

### HD Pickup Trucks $1,300 $1,638 

### Vocational Vehicles $216 $354 

### Alt. 4 More Stringent

– Total $5,594+c $7,478+c 

### Tractors $1,953+c $3,225+c 

### HD Pickup Trucks $1,824+c $2,298+c 

### Vocational Vehicles $1,816+c $1,954+c 

### Alt. 5 Max Technology

– Total $18,291+c $27,788+c 

### Tractors $2,747+c $4,292+c 

### HD Pickup Trucks $6,051+c $7,623+c 

### Vocational Vehicles $9,493+c $15,873+c 

### We can add tables reflecting the individual model years for each alternative, such as the table below which represents Alternative 2 at 3% discount rate. However, the agencies are not able to apportion some of the cost/benefit categories to specific categories. For example, there is sufficient overlap of engines used in all three categories that it is difficult

### to separate out the benefits.

**Estimated Societal Impacts of Alternative 2 of the Heavy -** **duty Program (Millions of 2009 dollars; 3% discount rate)**  MONETIZED VALUES 2014MY 2015MY 2016MY 2017MY 2018MY SUM Costs Truck Program Costs - $1,100 -$1,000 - $1,100 - $1,200 - $1,500 - $5,900 Benefits Pre-tax Fuel Savings $8,800 $7,800 $7,600 $10,800 $12,100 $47,100 Energy Security $500 $400 $400 $600 $600 $2,500 Accidents, Congestion, Noise - $300 - $300 -$300 - $200 - $300 - $1,400 Refueling $100 $100 $100 $100 $100 $500 Reduced CO2 emissions 5% (avg SCC) $200 $200 $200 $300 $300 $1,200 3% (avg SCC) $1,000 $900 $800 $1,200 $1,300 $5,200 2.5% (avg SCC) $1,600 $1,400 $1,400 $1,900 $2,200 $8,500 3% (95th percentile) $2,900 $2,600 $2,500 $3,500 $4,000 $15,500 Net Benefits 5% (avg SCC) $8,200 $7,200 $6,900 $10,400 $11,300 $44,000 3% (avg SCC) $9,000 $7,900 $7,500 $11,300 $12,300 $48,000 2.5% (avg SCC) $9,600 $8,400 $8,100 $12,000 $13,200 $51,300 3% (95th percentile) $10,900 $9,600 $9,200 $13,600 $15,000 $58,300

# 25) **Learning**

How does learning affect the total cost estimate? What is the projected cost without any learning? **Response:** The agencies provided the requested analysis to OMB last week. The first set of tables below contains no learning. The second set of tables contains learning. 

# Without Learning **Estimated Societal Impacts of the Proposed Heavy** **- duty Program** **(Millions of 2009 dollars; 3% discount rate)** Monetized Values 2014MY 2015MY 2016MY 2017MY 2018MY Sum Costs Truck Program Costs - $1,700 - $1,600 - $1,700 - $2,000 - $2,500 -$9,500 Benefits Pre-tax Fuel Savings $9,500 $8,400 $8,200 $11,600 $13,100 $50,800 Energy Security $500 $400 $400 $600 $700 $2,600 Accidents, Congestion, Noise - $300 - $300 - $300 - $300 - $300 -$1,500 Refueling $100 $100 $100 $100 $100 $500 Reduced CO2 emissions 5% (avg SCC) $200 $200 $200 $300 $300 $1,200 3% (avg SCC) $1,100 $1,000 $900 $1,300 $1,500 $5,800 2.5% (avg SCC) $1,800 $1,600 $1,500 $2,200 $2,500 $9,600 3% (95th percentile) $3,300 $2,900 $2,800 $4,000 $4,500 $17,500 Net Benefits 5% (avg SCC) $8,300 $7,200 $6,900 $10,300 $11,400 $44,100 3% (avg SCC) $9,200 $8,000 $7,600 $11,300 $12,600 $48,700 2.5% (avg SCC) $9,900 $8,600 $8,200 $12,200 $13,600 $52,500 3% (95th percentile) $11,400 $9,900 $9,500 $14,000 $15,600 $60,400 **Estimated Societal Impacts of the Proposed Heavy -** **duty Program (Millions of 2009 dollars; 7% discount rate)**  Monetized Values 2014MY 2015MY 2016MY 2017MY 2018MY Sum Costs Truck Program Costs - $1,700 - $1,600 - $1,700 - $2,000 - $2,500 -$9,500 Benefits Pre-tax Fuel Savings $7,000 $6,000 $5,700 $7,700 $8,400 $34,800 Energy Security $400 $300 $300 $400 $400 $1,800 Accidents, Congestion, Noise - $300 - $200 - $200 - $200 - $200 -$1,100 Refueling $0 $0 $0 $100 $100 $200 Reduced CO2 emissions 5% (avg SCC) $200 $200 $200 $300 $300 $1,200 3% (avg SCC) $1,100 $1,000 $900 $1,300 $1,500 $5,800 2.5% (avg SCC) $1,800 $1,600 $1,500 $2,200 $2,500 $9,600 3% (95th percentile) $3,300 $2,900 $2,800 $4,000 $4,500 $17,500 Net Benefits 5% (avg SCC) $5,600 $4,700 $4,300 $6,300 $6,500 $27,400 3% (avg SCC) $6,500 $5,500 $5,000 $7,300 $7,700 $32,0002.5% (avg SCC) $7,200 $6,100 $5,600 $8,200 $8,700 $35,800

3% (95th percentile) $8,700 $7,400 $6,900 $10,000 $10,700 $43,700 

## With Learning **Estimated Societal Impacts of the Proposed Heavy -** **duty Program (Millions of 2009 dollars; 3% discount rate)**  Monetized Values 2014MY 2015MY 2016MY 2017MY 2018MY Sum Costs Truck Program Costs - $1,700 - $1,500 - $1,600 - $1,800 - $2,300 -$8,900 Benefits Pre-tax Fuel Savings $9,500 $8,400 $8,200 $11,600 $13,100 $50,800 Energy Security $500 $400 $400 $600 $700 $2,600 Accidents, Congestion, Noise - $300 - $300 - $300 - $300 - $300 -$1,500 Refueling $100 $100 $100 $100 $100 $500 Reduced CO2 emissions 5% (avg SCC) $200 $200 $200 $300 $300 $1,200 3% (avg SCC) $1,100 $1,000 $900 $1,300 $1,500 $5,800 2.5% (avg SCC) $1,800 $1,600 $1,500 $2,200 $2,500 $9,600 3% (95th percentile) $3,300 $2,900 $2,800 $4,000 $4,500 $17,500 Net Benefits 5% (avg SCC) $8,300 $7,300 $7,000 $10,500 $11,600 $44,700 3% (avg SCC) $9,200 $8,100 $7,700 $11,500 $12,800 $49,300 2.5% (avg SCC) $9,900 $8,700 $8,300 $12,400 $13,800 $53,100 3% (95th percentile) $11,400 $10,000 $9,600 $14,200 $15,800 $61,000 **Estimated Societal Impacts of the Proposed Heavy -** **duty Program (Millions of 2009 dollars; 7% discount rate)**  Monetized Values 2014MY 2015MY 2016MY 2017MY 2018MY Sum Costs Truck Program Costs - $1,700 - $1,500 - $1,600 - $1,800 - $2,300 -$8,900 Benefits Pre-tax Fuel Savings $7,000 $6,000 $5,700 $7,700 $8,400 $34,800 Energy Security $400 $300 $300 $400 $400 $1,800 Accidents, Congestion, Noise - $300 - $200 - $200 - $200 - $200 -$1,100 Refueling $0 $0 $0 $100 $100 $200 Reduced CO2 emissions 5% (avg SCC) $200 $200 $200 $300 $300 $1,200 3% (avg SCC) $1,100 $1,000 $900 $1,300 $1,500 $5,800 2.5% (avg SCC) $1,800 $1,600 $1,500 $2,200 $2,500 $9,600 3% (95th percentile) $3,300 $2,900 $2,800 $4,000 $4,500 $17,500 Net Benefits 5% (avg SCC) $5,600 $4,800 $4,400 $6,500 $6,700 $28,000 3% (avg SCC) $6,500 $5,600 $5,100 $7,500 $7,900 $32,600 2.5% (avg SCC) $7,200 $6,200 $5,700 $8,400 $8,900 $36,400 3% (95th percentile) $8,700 $7,500 $7,000 $10,200 $10,900 $44,300