3) Annualized Estimates of Costs and Benefits using Model 

Year 2014-2018 analysis

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) Analysis of Alternatives for Subcategories

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 CO2 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 BaselineTotal39 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 $32,000
2.5% (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