Peer Review of FEV Inc. Report 

“Light Duty Technology Cost Analysis,

Power-Split and P2 Hybrid Electric 

Vehicle Case Studies” 
Peer Review of FEV Inc. Report 

“Light Duty Technology Cost Analysis,

Power-Split and P2 Hybrid Electric 

Vehicle Case Studies” 

Assessment and Standards Division 

Office of Transportation and Air Quality 

U.S. Environmental Protection Agency 

Prepared for EPA by
 

ICF International
 

EPA Contract No. EP-C-06-094
 

Work Assignment No. 4-08
 

NOTICE 

This technical report does not necessarily represent final EPA decisions or 


positions. It is intended to present technical analysis of issues using data 


that are currently available. The purpose in the release of such reports is to 


facilitate the exchange of technical information and to inform the public of 


technical developments.
 

EPA-420-R-11-016 

November 2011 
 

Contents 

1. Introduction........................................................................................................................................................... 1 

2. The Peer Review Process .................................................................................................................................... 1 

3. Summary of Peer Reviewer Comments ..............................................................................................................3 

3.1. Comments on Methodology/Results ..........................................................................................................3 

a. Reasonableness and Potential Bias of the Methodology as Documented.............................................3 

b. General Flaws in the Scope of the Study...............................................................................................4 

c. Appropriateness of Study Inputs ............................................................................................................5 

d. Reasonableness of Assumptions...........................................................................................................5 

e. Appropriateness of Results ....................................................................................................................7 

f. Appropriateness of Scaling Costs to Other Vehicle Classes and to Other Hybrid Technologies ............7 

3.2. Comments on Other/General Observations...............................................................................................8 

4. Verbatim Peer Reviewer Comments in Response to Charge Questions .........................................................8 

Appendix A: Charge to Peer Reviewers.................................................................................................................A-1 

Appendix B. Reviewer Resumes ...........................................................................................................................B-1 

Appendix C. Peer Reviewer Comments As Submitted.........................................................................................C-1 
 

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page 
 

 

1. Introduction 

The U.S. Environmental Protection Agency’s (EPA's) Office of Transportation and Air Quality (OTAQ) 

is developing programs to control greenhouse gas (GHG) emissions from light-duty highway vehicles, 

which require an evaluation of the costs of technologies likely to be used to meet any standards. EPA 

contracted with FEV Incorporated to perform this cost analysis through tearing down vehicles, engines, 

and components, both with and without these technologies, and evaluating, part by part, the observed 

differences in size, weight, materials, machining steps and other cost-affecting parameters. Though 

complex and time-consuming, EPA believes this approach has great potential for determining accurate 

technology costs, a goal that is of paramount importance in the setting of appropriate GHG standards. 

Although the teardown and analysis work is ongoing, FEV wrote a report detailing the methodology it 

and its subcontractor are using to cost out technologies and describing the results of the cost-out work to 

date.1

 To assure that this work incorporates the highest quality science, EPA contracted with ICF 

International (ICF) to determine appropriate independent peer reviewers for the FEV report, “Light Duty 

Technology Cost Analysis, Power-Split and P2 Hybrid Electric Vehicle (HEV) Case Studies” and 

document their feedback on the costing methodology it presents. The reviewers selected were 

independent subject matter experts and their reviews were conducted in compliance with EPA peer 

review guidelines.2 

This report presents the findings of the reviews conducted by four subcontracted subject matter experts. 

The peer reviewers were: 

1. Mr. Ted Bohn, Argonne National Laboratories 

2. Dr. Linos Jacovides, Delphi (Retired) 

3. Ms. Linda Miller, independent consultant 

4. Dr. Deepa Ramaswamy, Hybrid Chakra 

2. The Peer Review Process 

From December 2010 to April 2011, EPA contracted with ICF to coordinate this peer review. ICF 

implemented the peer review in compliance with EPA’s Peer Review Handbook (3rd Edition).2 EPA 

requested that the peer reviewers represent subject matter expertise in manufacturing cost estimating 

and/or automotive design. 

ICF developed a list of candidate peer reviewers from the following sources: (1) ICF experts in this field 

with knowledge of relevant professional society membership, industry, academia, and other 

organizations, and (2) suggestions from EPA staff. ICF identified 25 qualified individuals as candidates 

to participate in the peer review. ICF sent each of these individuals an introductory screening email to 

describe the needs of the peer review and to gauge the candidate’s interest and availability. ICF attached 

to the email the reviewer charge to ensure each candidate was familiar with the scope of work. ICF also 

1 Draft Report FEV07-069-303F, February 22, 2011. 

2 EPA's Science Policy Council. Peer Review Handbook, 3rd Edition (http://www.epa.gov/peerreview/).OMB's Information Quality 

Bulletin for Peer Review and Preamble (also in the EPA's Peer Review Handbook, Appendix B). 

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The Peer Review Process 

asked candidates to provide an updated resume or curriculum vitae (CV). Several candidate reviewers 

were unable to participate in the peer review due to previous commitments, and several others did not 

respond. ICF reviewed the responses and evaluated the resumes/CVs of the interested and available 

individuals for relevant experience and demonstrated expertise in the above areas, as demonstrated by 

educational degrees attained, research and work experience, publications, awards, and participation in 

relevant professional societies. 

ICF reviewed the interested, available, and qualified candidates with the following concerns in mind. As 

stated in the EPA’s Peer Review Handbook, the group of selected peer reviewers should be “sufficiently 

broad and diverse to fairly represent the relevant scientific and technical perspectives and fields of 

knowledge; they should represent a balanced range of technically legitimate points of view.” As such, 

ICF selected peer reviewers to provide a complimentary balance of expertise of the above criteria. 

EPA reviewed ICF’s proposed peer reviewers and concurred with ICF’s recommendations; these peer 

reviewers were listed in the introduction. Exhibit 1 shows the representation of the peer reviewers in the 

required areas of expertise. 

Exhibit 1. Chart of Peer Reviewer Expertise Areas and Affiliation 

Expertise Areas/ 

Affiliation 

T. Bohn, 

Argonne 

National 

Laboratories 

L. Jacovides, 

Delphi (Retired) 

L. Miller, 

independent

consultant 

D. Ramaswamy, 

Hybrid Chakra 

HEVs 9 9 9 9

Cost Modeling 9

Manufacturing 9 9 9

Mass Production 9 9 9

Tier 1 Supplier 9

Original Equipment 

Manufacturer (OEM) 9 9 9

Prior to distributing the review materials, ICF sent each of the reviewers a conflict of interest (COI) 

disclosure and certification form to confirm that no real or potential conflicts of interests existed. The 

disclosure form addressed topics such as relationships with the report’s authoring organization, 

employment, investment interests and assets, property interests, research funding, and various other 

relevant issues. Upon review of each form, ICF determined that each peer reviewer had no COI issues. 

ICF executed subcontract agreements with all of the reviewers. 

2
 
 

 

Summary of Peer Reviewer Comments 

ICF provided peer reviewers with the following materials: 

•	 Draft report by FEV, Inc., entitled, “Light-Duty Technology Cost Analysis Power-split and P2 

HEV Case Studies,” dated February 22, 2011; 

•	 The Peer Reviewer Charge to guide their evaluation; and 

•	 A template for the comments organized around the Peer Reviewer charge. 

The Peer Reviewer Charge provided peer reviewers with general guidelines, as well as example 

questions, for preparing their overall review, with particular emphasis on methodologies and cost results. 

In addition, EPA asked each reviewer to provide recommendations on the “overall adequacy of the model 

for predicting future battery prices, and on any improvements that might reasonably be adopted by the 

authors to improve the model.” 

A mid-review teleconference was held on March 8, 2011, to discuss the charge, the purpose of the review, 

and to answer any outstanding questions the reviewers might have. The call was moderated by ICF and 

attended by reviewers Mr. Bohn, Dr. Jacovides, Ms. Miller, and Dr. Ramaswamy, as well as EPA staff 

Brian Nelson, and FEV, Inc. staff Greg Kolwich who were familiar with the report. 

The charge to peer reviewers is provided in Appendix A. The CVs or resumes for the reviewers are 

included in Appendix B. 

3. Summary of Peer Reviewer Comments 

This section presents a brief summary of the various comments received from the peer reviewers. The 

intention here is to convey the overall results of the individual peer reviews in a concise summary 

highlighting any lessons learned. 

This summary is organized into two categories, issues related to study methodology and results and 

general observations of the study. Editorial comments were excluded from this summary and may be 

found in the full verbatim comments that are provided in Section 4. 

3.1. Comments on Methodology/Results 

a. Reasonableness and Potential Bias of the Methodology as Documented 

Dr. Jacovides stated that the methodology is correct and can lead to correct results, as he had familiarity 

with the approach and expected results from prior work. Given that familiarity, he felt the report 

represented a superb implementation of the concept and that the analysis of the HEV and internal 

combustion engine (ICE) equivalent was done very carefully, correctly, without any obvious bias, and 

achieved results in agreement with his own. Mr. Bohn agreed generally, but only for the baseline HEV. 

However, two other reviewers expressed skepticism. Ms. Miller felt that the methodologies are generally 

reasonable, but raised some specific concerns, including a lack of documentation proving accurate results. 

Specifically, she noted that, while the paper references marketplace validation, no examples were given. 

Dr. Ramaswamy agreed that the report does not sufficiently document the validation of the methodology 

at a subsystem or a system level. The implication was that, while the bottom-up approach was highly 

detailed, insufficient data was given in the report to show that the resulting subsystem or system costs 

3
 
 

 

Summary of Peer Reviewer Comments 

agreed with those developed or published by other reasonable sources. Ms. Miller also noted that the 

methodology only predicts absolute costs, and that a sensitivity analysis should be included and 

documented. Dr. Ramaswamy agreed that the methodology for determining costs is generally 

reasonable, but highlights some significant exceptions. Specifically, engineering development costs and 

use of indirect cost multipliers (ICMs) was not considered in sufficient detail and may be incorrect. An 

example was given (see specific comment excerpt number 8 in Table 1) where ICM costs are incorrectly 

applied to the OEMs. This would introduce bias to lower predicted costs beyond reality, thus the 

engineering development costs for the subsystems should be revised. Ms. Miller also noted that the 

scaling methodology appeared to be overly simplified when it was applied to labor and manufacturing 

overhead. Whereas the cost of direct labor is more a factor of part complexity than one of size, certain 

elements of overhead costs were only minimally affected by part size. This could introduce bias that 

should be explored through use of sensitivity tests. 

The only key limitation Dr. Jacovides noted is that the methodology was limited to the two architectures 

studied (split power hybrids used by Toyota and Ford and, to a limited extent, Hyundai’s P2 architecture). 

While he noted that the P2 battery was properly analyzed by tear down of an actual unit and could be 

extended to other hybrids (GM [two mode and the Malibu ISG] and the Honda Insight), Mr. Bohn 

expressed skepticism about the general subjectivity of the scaling assumptions, particularly for P2 HEVs, 

but, while noting that bias was possible, he made no judgment on its direction or magnitude. However, a 

general consensus seemed to be that the P2 HEV results were more likely to be erroneous than the scaling 

to other vehicle types, which was, in turn, likely to be more erroneous than the results for the baseline 

vehicles. 

b. General Flaws in the Scope of the Study 

Mr. Bohn suggested that the scope is “just right” and offered no conclusive statements. He noted that 

expanding the scope of the study would likely introduce more variability and that reducing it would not 

necessarily increase its validity or accuracy. 

Dr. Jacovides said that, although beyond the scope of this report, the study results would be meaningless 

without knowledge of appropriate use of ICMs. This was a limitation of the study—the study may be 

sufficiently detailed exclusive of ICMs, but end results could vary by up to a factor of two depending on 

the ICMs. 

As introduced previously, more substantial concerns were raised over the scaling of results, especially to 

P2 HEVs. Dr. Jacovides expanded on the comments from part (a), expressed concerns about both the 

methods and results for the P2 system. While the results of scaling for the P2 system may be in the right 

direction, the sizing of the electrical system (power electronics and the electrical machine) were likely 

incorrect. Because the duty cycle of the electrical system in a P2 HEV is very different than that of the 

power split HEV, the ratios of copper to iron in magnets will likely be different. Further, if the electrical 

machine for the P2 was sized based on power, this was incorrect. Instead, torque and duty cycle are the 

primary determinants of size (and cost). Also P2 HEVs have a clutch to disconnect the engine so that 

regenerative braking does not have to be reduced to provide for engine friction thus providing an all 

electric range (AER). The resulting 32.4kW power of the electrical machine will not provide sufficient 

required torque and power for AER. Further, since the size of electrical machine is determined by torque, 

not power, a slower speed machine will be heavier which contradicts the assumed 20% vehicle curb 

4
 
 

Summary of Peer Reviewer Comments 

weight reduction for the P2 architecture for all vehicle segments. Dr. Ramaswamy agreed that the 

assumption of a 20% power and weight reduction assumed for the P2 hybrid may be unjustified. Further, 

she found that there is no justification in other literature that the Lithium Polymer battery (as opposed to 

nickel metal hydride [NiMH]) would be a better long term solution for the P2 hybrid. 

Dr. Jacovides argued that the study will be difficult to apply to other vehicles or architectures without the 

detail provided by a similar tear-down. Ms. Miller agreed that extrapolation to other vehicle sizes cannot 

be done without the basic underlying detailed studies, and that extrapolation of costs for vehicles other 

than the Fusion relies on use of scaling and does not have the same level of detail as the rest of the study. 

A different use of scaling factors, such as by applying scaling factors to material cost and investment in 

equipment instead of for manufacturing cost and burden could yield a very different result. 

The general consensus was that the scaling portion of the study was the most dubious. 

c. Appropriateness of Study Inputs 

Dr. Jacovides reiterated his contention that the report’s central analysis (comparison of a hybrid and an 

ICE Fusion) was very well done. However, he raised concerns with estimation of the following cost 

assumptions: 1) development of control software, 2) integration of the electrical and mechanical parts, 

and 3) calibration. All are upfront engineering costs that should be considered as part of the cost of the 

vehicle, although they may be insignificant by the time production volume has reached 450,000 units. 

Ms. Miller was concerned that lack of communication with the OEM's – while consistent with EPA 

policy – can lead to inappropriate validation of the teardown costing. Dr. Ramaswamy agreed that 

insufficient independently determined system/subsystem costs were used to validate the calculated costs. 

The report does discuss this, but specific examples of validation should be considered as additional inputs 

to the process. 

Dr. Ramaswamy also argued that the major flawed assumption of this study was that the high voltage 

battery will be manufactured in the United States. NiMH batteries are not manufactured in volume in the 

United States. Although several companies have plans to manufacture Li-ion batteries, the cells typically 

come from Asia. This inaccurate assumption biased the cost results high. 

d. Reasonableness of Assumptions 

Reviewers noted concern about several assumptions included in the study. Dr. Jacovides again noted his 

general conclusion that while the assumptions used are appropriate, the implicit assumption that a 

downstream user without the same expertise as FEV would be able to run the model is unlikely. Dr. 

Ramaswamy agreed that assumptions were generally reasonable, but highlighted especially the 

unreasonable assumption incorporated in the scaling parameter for the battery. 

Ms. Miller listed the following specific assumptions that should be re-considered: 

•	 The assumption that the technologies used may be considered mature should be evaluated. The 

assumption of maturity impacted numerous underlying cost elements, including lack of 

allowances for learning, scrap rates, non-recovered engineering, design, and testing (ED&T) 

expense and capital costs, and equipment end of life costs. 

5
 
 

Summary of Peer Reviewer Comments 

•	 The assumption that no new or modified equipment maintenance is required is inconsistent with 

equipment at the end of its life cycle, assumed above. Together, these biased the cost estimates 

low. 

•	 The assumption that integration of new technology would be planned and phased in to minimize 

non-recoverable expenses would be cost effective. In reality, new technology requirements to 

achieve fuel economy improvements and emissions reductions will preempt this consideration. 

•	 The markup rate needs to vary dependent upon the part size and part complexity. If tolerance 

limits are not considered part of part complexity, tolerances need to be considered as another 

factor in determining scrap rates. Assumed scrap rates should also be verified. 

•	 The assumption that all sourcing/manufacturing centers will be in the United States was not valid 

and could bias the results high or low. 

•	 Assumed labor rates may need to be adjusted to include overtime costs and other premiums. It 

was unclear from the report if this was included and could bias the results, depending on union 

agreements and/or operating practices. 

•	 Packaging cost assumptions should be checked, based on the sample calculation (page 50, Figure 

C-6). 

•	 Allowances for a percentage of pallets/racks out for cleaning/repair are not included and biased 

the packaging cost low. 

•	 The assumed Cost of Complexity is inappropriate. Volumes of 450,000 per year assumed that the 

major complex assemblies (engine, transmission, and complex subsystems) are produced on 

dedicated lines. If they are not, then a cost of complexity factor needs to be added. The 75% 

combined utilization/efficiency assumption was reasonable unless hybrid components are 

assembled on the same lines as the baseline products (as they will be), in which case this 

utilization/efficiency is over-stated. This biases the results low; additional complexity should be 

factored into the utilization/efficiency calculation. 

•	 With respect to System Scaling Cost Analysis, ratios used to develop sizes and material costs for 

HEV components (traction motors, high traction batteries, etc.) were appropriate, but use of these 

ratios to determine other factors (especially labor and P2 HEV powertrain components) was less 

valid. These are more related to part complexity than part size. Which costs are scalable should 

be reevaluated. 

Mr. Bohn discussed some assumptions, particularly regarding the base vehicle and the P2 Hybrid having 

equivalent performance with increased fuel economy. He said associated assumptions about the amount 

of engine blending and depth of battery discharge were subjective and expressed concerns regarding the 

lack of electric machine rating standards. However, he made no mention of their reasonableness or 

direction of influence on the study’s results. 

6
 
 

Summary of Peer Reviewer Comments 

e. Appropriateness of Results 

Three of four reviewers generally considered the study results appropriate but commented on the need for 

increased validation. Dr. Jacovides commented that the results were reasonable, but noted that it would be 

useful to have Ford and Toyota review them before making the report public. Dr. Ramaswamy agreed 

that the results were appropriate for the given scope, assumptions, and inputs, but noted that the 

description of the validation of the costing methodology was insufficient and that a sensitivity analyses 

and further analyses/correction of some assumptions were warranted. Mr. Bohn, too, agreed that the 

results were reasonable given the scope, assumptions, and inputs, but felt that reasonable validation was 

achieved, although he considers the level of validation appropriate to be subjective. 

Ms. Miller disagreed. She felt that, given the levels of assumptions made, at best cost estimates are 

directionally correct, which is inconsistent with the stated goal of absolute costs. In particular, she had 

concerns regarding validation. While the methods used were solid (teardown analysis, process flow 

diagrams, analysis of comparable parts, etc.), numerous methodological assumptions were used and their 

validation is insufficiently documented. She recommended sensitivity testing, appropriate and correct 

accounting for component sourcing, and reevaluating labor costs. 

f. Appropriateness of Scaling Costs to Other Vehicle Classes and to Other Hybrid 

Technologies 

Generally reviewers seemed to express more reservation about the scaled results than the baseline 

vehicles, for a variety of reasons. 

Dr. Jacovides noted that scaling for vehicles with identical architecture but different power 

inappropriately account for labor. Similarly for P2 HEVs, costs for electrical machines should not be 

scaled as power, but on torque and duty cycle. Ms. Miller agreed that the ratios used to size HEV 

components was appropriate for material costs and investment in equipment, but that using the size ratio 

scaling methodology for overhead cost, direct labor costs, and required staffing was inappropriate. She 

had these same concerns with scaling for the P2 HEV calculations. Dr. Ramaswamy also agreed that for 

most components, the scaling to other vehicle classes was reasonable. Mr. Bohn added that while the 

approach used in scaling appears reasonable, he had concerns that the actual values used in the scaling 

approach could be off and lead to erroneous results. However, this was not supported by his general 

conclusion above regarding the reasonableness of results. 

Mr. Bohn and Dr. Jacovides commented that the NiMH battery scaling was done correctly, although Dr. 

Jacovides noted that scaling did not consider an alternative approach of using a larger number of smaller 

cells. He believed that the approach used for the P2 architecture was directionally correct but the results 

would not be as accurate as those between the baseline hybrid and ICE vehicles. Although he noted that 

the estimated cost of the cells seemed reasonable, Dr. Jacovides raised two questions about the treatment 

of the Li-ion battery: 1) that discussion should be added to explain preservation of battery life when 

scaling by nominal kWh, and 2) that clarification should be made on what size battery is cost for the P2 

HEV. Dr. Ramaswamy agreed. She noted that scaling of parameters across different vehicle classes 

needed to be better explained and justified, given that this one component was responsible for the bulk of 

the cost of the hybrid powertrain. 

7
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

3.2. Comments on Other/General Observations 

General comments not included in the earlier sections are discussed in this section. 

Ms. Miller complemented the detail and effort of the analysis and report and the use of recognized 

methodologies. Dr. Ramaswamy noted a small number of omissions and discrepancies. She noted that, 

while the report talked about the applicability of the power split hybrid system to the sub-compact, small, 

large, and minivan vehicle segments, it should clarify that this group also covers small SUVs such as the 

Ford Hybrid Escape, which is one platform that already supports this architecture. 

Dr. Ramaswamy also noted several specific items of concern. She indicated that the study seemed to 

omit a high-voltage DC/DC converter used by the traction motor and generator, which is used in the 

Fusion Hybrid and should be included in the cost. Table E-2, compared to those in Table D-3, showed 

inconsistencies that should be addressed. Dr. Ramaswamy also noted that Table A-1 should have 

calculated the percentage increase as compared to the base non-hybrid vehicle cost, instead of calculating 

the increase with respect to the mid/large size vehicle segment cost. Also, in Figure B-1, she questioned 

why the bill of materials (BOM) was not updated after step 6, when additional information has been 

gained about the component after its disassembly. She also asked what the 19,149 parts stand for on page 

50, first paragraph. 

Dr. Ramaswamy also believed the methods for determining the engineering design costs for various 

components/systems were unclear. These included: 1) the Atkinson engine engineering design cost, 

associated control system, and calibration; 2) the engineering design cost for the electronics controllers, 

software for the battery system, and mechanical design of the battery system (the numbers presented 

appear low); 3) the ED&T for the traction battery assembly (too high relative to that for the control 

module, given the relative engineering efforts) (Table D-11). 

Dr. Jacovides recommended specific companies that should be consulted to assess the accuracy of results: 

Ford for the baseline vehicles and those scaled according to size and Honda or GM for scaling to P2 

HEVs. Also, individual component costs should be compared to those used on the Volt and Leaf. 

Ms. Miller also noted that validity testing of the Munro & Associates software, FEV databases, and 

costing algorithms should be performed and documented. Hypothesis testing of assumptions concerning 

burden rates, product maturity, etc. and sensitivity analysis to demonstrate correlation to actual 

component costs should also be added to the study. 

4. Verbatim Peer Reviewer Comments in Response to Charge

Questions 

Table 1 presents the verbatim comments received by the three subject matter experts. Comments are 

sorted by charge question and then topic/categories. Appendix C provides the actual peer reviewer 

comments. 

8
 
Table 1. Sorted, Verbatim Comments from Reviewers 

Charge 

Question Topic 

Specific 

Assumption/ 

Topic 

Comment 

Excerpt 

No. 

Reviewer Comment Excerpt 

Methodology/ 

Results 

Methodological 

Issues 

1 Bohn Overall, the draft document presents a generally 

reasonable methodology that is likely to yield accurate 

results. 

Methodology/ 

Results 

Methodological 

Issues 

2 Bohn The assumptions used for the P2 HEV system are 

somewhat subjective on adding the P2 functionality as an 

80/20 power sharing between engine and motor for peak 

conditions. This may introduce a bias in the results of the 

benefit vs the component cost, or in this case incremental 

costs. The assumption about engine downsizing is that the 

base vehicle and the P2 Hybrid will have equivalent 

performance with increased fuel economy. While peak 

performance is straight forward to assess for both the 

baseline and P2 Hybrid versions, the amount of engine 

blending, depth of discharge of the batteries, etc will affect 

the assessed fuel economy. 

Methodology/ 

Results 

Methodological 

Issues 

3 Bohn It is difficult to assess the direction of the bias (cost or 

performance/F.E. mismatch)- i.e. component sizing is cost 

sensitive and depending on the engine/motor torque 

blending, component cost may be over stated or 

understated based on blending assumptions and 

equivalence the to the base vehicle. 

Methodology 

/Results 

Methodological 

Issues 

4 Bohn There is no simple remedy for this supposed bias since 

engine downsizing and component sizing are subjective 

based on the desired performance attributes to compare 

the hybrid version to the base vehicle. The assumptions 

made in the report (section A) are fair, and clearly stated. 

Methodology/ 

Results 

Methodological 

Issues 

5 Bohn As with many vehicle simulations, the component scaling 

methodologies need validation. In some industries, 

component scaling is limited to technology or performance 

ranges. For instance IGBT transistors versus MOSFET 

transistors are used for two different voltage ranges with 

some overlap. Even so, the scaling assumptions are 

bounded by the available voltage limit for the transistors. 

Scaling up power ratings on an inverter, or battery voltage 

have impacts on the scaled inverter costs, caused by (for 

instance) the boundary where one would use MOSFETs 

for lower voltage and IGBTs for high voltage. 

Methodology/ 

Results 

Methodological 

Issues 

6 Jacovides The methodology is clearly correct and could lead to 

correct results. As stated above, I am familiar with the 

approach because it was discussed during the NRC 

committee on “Improving the Fuel Economy of LDV” and in 

the references listed earlier. The report, under review, 

represents a superb implementation of the concept. 

9
 
 

 

 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ Methodological 7 Jacovides The analysis of the Ford Hybrid and cost comparisons with 

Results Issues its ICE equivalent is done very carefully and correctly 

without any bias that I can detect. Interestingly the 

increase in cost of $3435 that this report comes up with is 

almost identical to the one we came up for the Prius in the 

NRC study of $3385. We did that by talking to OEM’s and 

suppliers. However I want to emphasize that the approach 

taken by this report is far superior. As long as a detailed 

design or an actual vehicle is available this is the way to do 

it. It does require a great deal of industrial engineering skill 

to estimate the amount of labor, and cost of materials but 

in the hands of FEV this has produced excellent results 

Methodology/ Methodological 8 Jacovides It should be pointed out that the methodology is limited to 

Results Issues the two architectures studied viz. split power hybrids as 

implemented by Toyota and Ford and to a limited extend 

on the P2 architecture as implemented by Hyundai. I say 

limited since there was no design available for the 

electrical machine in this case. The battery for the P2 was 

properly analyzed by tear down of an actual unit. 

Nevertheless the analysis can be extended to other 

hybrids such as the two types made by GM (two mode and 

the Malibu ISG) and the Honda Insight 

Methodology/ Methodological 9 Miller • While the methodologies, for the most part, appear 

Results Issues reasonable, there are some areas of concern. There is a 

lack of documentation in the paper proving that the 

methodologies yield accurate results. While the paper 

references marketplace validation, no examples are given. 

• Recommendation: Include examples taking developed 

costs for items such as fuel injector assemblies(Figure C-3, 

page 45, Sample MAQS Costing Worksheet); extrapolating 

these to a total cost using the approach outlined in the 

paper; and then comparing these costs to actual 

marketplace pricing for the example used. One or two 

worked examples of this nature would help to validate the 

overall methodology. Alternatively, include a table, 

detailed by component/ sub-assembly, showing the 

methodologies and comparisons used for costing each 

item. 

Methodology/ Methodological 10 Miller • The costing methodology, as presented, develops costs 

Results Issues that are absolute. Given the complex nature of the end 

product and the manufacturing processes, it would have 

been appropriate to include sensitivity analysis in the 

costing detail. If sensitivity analysis has been performed 

on a sampling of costs, it is not shown in the paper. 

• Recommendation: Assuming sensitivity analysis is 

available, show the impact of sensitivity analysis in the 

examples in the paper. If sensitivity analysis has not been 

performed, then this is an area of detail that needs to be 

completed. From a manufacturing perspective, sensitivity 

analysis on high dollar components needs to include scrap 

rates, mean time to repair of equipment, equipment 

uptime, etc. 

10
 
 

 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ 

Results 

Methodological 

Issues 

11 Miller The scaling methodology appears to be overly simplified. 

For example, scaling factors are applied to labor and 

manufacturing overhead. The cost of direct labor is more a 

factor of part complexity than one of size. Also, certain 

elements of overhead cost such as salaries and front office 

costs are not impacted, or at most minimally, by part size. 

•Recommendation: A deeper review of the approach to 

scaling needs to be undertaken to insure that costs are not 

under/over-stated. Again, applying sensitivity tests may 

help determine whether or not these differences are 

significant. 

Methodology/ 

Results 

Methodological 

Issues 

12 Miller Without the documentation noted above, it is not possible 

to say whether or not bias has been created. 

Methodology/ 

Results 

Methodological 

Issues 

13 Ramaswamy The methodology for determining the costs are generally 

reasonable, with some significant exceptions that are listed 

below. 

• The first is the engineering development cost, which 

appears to have been not considered in detail in this 

report. An example of these are the costs to develop 

control systems, be they battery control systems or 

otherwise. They cannot be lumped in with the indirect cost 

multipliers (ICMs), because these costs are not borne by 

the OEMs. Rather, these are costs borne by the suppliers. 

The bias introduced by this is that the overall cost of some 

components is lower than it should be. The remedy for this 

is to revisit the engineering development costs for the 

subsystems. 

Methodology/ 

Results 

Methodological 

Issues 

14 Ramaswamy What this report does not document sufficiently is the 

validation of this methodology at a subsystem or a system 

level. The bottoms up towards cost that is employed by 

FEV is certainly very detail oriented, but there isn’t 

sufficient data in the report to show that the final 

subsystem or system costs that they result in, are inline 

with those developed or published by other reasonable 

sources 

Methodology/ 

Results 

General Flaws 15 Bohn The scope of the document is broad reaching. Expanding 

the scope of the study would likely introduce more 

variability with increased assumption. 

Methodology/ 

Results 

General Flaws 16 Bohn The scope does not need to be reduced since it covers 

many aspects on the cost of producing an automobile and 

reducing the scope would not necessarily increase the 

validity or accuracy of the study. 

Methodology/ 

Results 

General Flaws 17 Jacovides The results of this study cannot properly be evaluated 

without knowledge of what EPA considers the IC factor to 

be. I realize that this is not in the scope of the report. 

However IC factors range from 1.02 to 1.45 as stated in 

reference 5. Industry RPE factors were estimated in 

Reference 4 to be 1.5 or 2.0 depending on whether parts 

were bought or made in house. One can calculate 

manufacturing costs to the penny but then the end result 

can vary by a factor of up to two depending on the 

multiplier 

11
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ General Flaws 18 Jacovides The results for the P2 may be directionally correct, but I am 

Results concerned about the sizing of the power electronics and 

the electrical machine. FEV should have bought a Honda 

Insight (IMA), available in the US in the spring of 2010, or a 

GM Malibu (ISG) for a tear down of the electrical system 

(Power electronics and machine). The duty cycle of the 

electrical system is very different than that of the power 

split and so the ratios of copper to iron to magnets will 

likely be different. Also it seems from Table F2 that the 

electrical machine was sized based on power. As 

discussed below torque and duty cycle are the primary 

determinants of size and hence cost. It should be pointed 

out that P2 has a clutch which provides two features that 

the Insight and the Malibu do not have. The clutch can 

disconnect the engine so that regenerative braking does 

not have to be reduced to provide for engine friction and 

can provide an all electric range (AER). The 32.4kW 

power of the electrical machine will not provide the 

required torque and power. There should be a statement 

to the effect that the P2 is not designed to provide an AER 

Methodology/ General Flaws 19 Jacovides Another problem is the assumption of a 20% vehicle curb 

Results weight reduction for the P2 architecture and for all vehicle 

segments. Such a reduction does not come for free and I 

found no rationale for this. In reference 4 we found that a 

10% reduction in a 3600 lbs vehicle would add around 

$700. During the conference call it was implied that the P2 

electrical systems is lighter. This may not be so and 

certainly not by 20%. The speed of the P2 electrical 

machine is not an independent variable and it is much 

lower than the speeds of the two power split machines. 

The size of electrical machines is determined by torque 

and not power and so a slower speed machine will be 

heavier. Clearly getting an Insight or a Malibu would have 

given a better estimate. 

Methodology/ General Flaws 20 Jacovides Another flaw of the study is that it depends on the ability of 

Results the people using the study to turn the crank for other 

vehicles or for vehicles without the detail provided by a 

teardown. Clearly FEV has demonstrated that it is 

developing that knowledge, although I am not sure about 

the accuracy of the electrical systems numbers for the P2. 

The question then becomes “will EPA need FEV in the 

future in order to use this work”. Based on the conference 

call with EPA, FEV and the Reviewers, this study will not 

be used for other architectures so the above point is moot. 

However I would like to caution that any extension to other 

architectures needs to be done by skilled manufacturing 

engineers and cost analysts. 

12
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ General Flaws 21 Miller • I do not see any general flaws inherent in the scope of 

Results the study. Extrapolation to other vehicle sizes could not be 

done without the basic underlying detailed studies. 

However, once the component costs had been developed 

for the Fusion, the justification for the extensive use of 

scaling factors to approximate these costs for other vehicle 

lines does not have the same level of detail as the rest of 

the study. Whether or not this has been impacted by the 

scope of the project can not be determined. 

• Recommendation: Review the application of scaling 

factors, especially for manufacturing cost and burden. The 

methodology described in the paper yields a result that 

should be considered as one end of a range estimate. The 

other end of the estimate should be developed by applying 

scaling factors to material cost and investment in 

equipment and holding the other costs constant. If it is 

necessary to state an absolute cost, the pick a middle 

ground between these two numbers based on expert 

opinion. 

Methodology/ General Flaws 22 Ramaswamy Although not a flaw per se, it is not clear why the 20% 

Results power and weight reduction was assumed for the P2 

hybrid. This was the direction provided by the EPA to FEV, 

but the rationale for this is not clear, and this reviewer 

could not see why it is justified. 

Methodology/ General Flaws 23 Ramaswamy Secondly, the reports stated that the team felt that the Li 

Results Polymer battery (as opposed to NiMH) is a better long term 

solution for the P2 hybrid. It’s unclear if this was the EPA 

team or the FEV team. Either way, there is no good 

rationale provided for such a statement, and this reviewer 

has not seen data (even outside of this report) to justify 

such a statement. 

Methodology/ Appropriate Inputs 24 Bohn The scope and breadth of inputs used for the study and 

Results cost assessments are broad and apparently all 

encompassing. There are many input items on costs, 

such as labor rates and overhead on labor, which are 

outside the expertise of this reviewer. To the best of my 

knowledge, all the inputs used in this study are 

appropriate. 

13
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ Appropriate Inputs 25 Jacovides When it comes to the main part of the report i.e. the 

Results comparison between a hybrid and an ICE Fusion 

everything seems to be done very well. Possible 

exceptions are in estimating the following costs 

1.Development of control software. 

2.Integration of the electrical and mechanical parts. 

3.Calibration. Hybrid vehicles are more complex and to 

make performance transparent to the driver is expensive. 

Safety also requires extensive calibration. Toyota has 

recalled the 2010 Prius to fix software when braking on ice 

on bumpy roads. If this can happen to Toyota with 10 

years experience on hybrids, it must be taken seriously. 

These are upfront engineering costs and by the time 

production volume has reached 450k units may not be 

significant. However they need to be added to the cost of 

the vehicle. 

Methodology/ Appropriate Inputs 26 Miller Although, as explained in the conference call on March 8, 

Results 2011, it is EPA policy to perform studies of this nature 

independent of the OEM's, it would have seemed 

appropriate to seek validation of the teardown costing from 

the manufacturer whose vehicle is the basis for this 

analysis. For a review of other assumptions that are of 

concern, see the response to the next Question. 

Methodology/ Appropriate Inputs 27 Ramaswamy One of the major assumptions in this study that is flawed is 

Results that the high voltage battery will be manufactured in the 

United States. NiMH batteries are not manufactured in 

volume in the United States, and although several 

companies have plans to manufacture Li Ion batteries, the 

cells typically come from Asia. To assume that all this 

manufacturing is done in the US will results in artificially 

high unit costs for these systems. If this information is then 

used by the EPA for downstream rule making, it will have 

the effect of having hybrid technologies show up in an 

unfavorable light as compared to other technologies. This 

inaccuracy could be remedied by a modification of the 

assumptions in terms of where the battery will be 

manufactured. 

Methodology/ Appropriate Inputs 28 Ramaswamy This study does not present sufficient examples of 

Results independently determined system/subsystem costs to be 

used for validation of the costs that FEV/Munro calculates 

through their process. Although the report mentions this 

was done (section C.7), examples of such validation are 

not presented. These independently determined 

costs/sources should be additional inputs to this process. 

Methodology/ 

Results 

Assumptions in 

Model 

29 Bohn Comments in the boxes above discuss some of the 

bounded areas of assumptions that affect cost and/or 

performance, such as engine/motor blending. 

14
 
 

 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ Assumptions in 30 Bohn A somewhat contentious point related to assumptions is 

Results Model the component rating system for electric machines. There 

is currently no published standard for electric machine 

rating methods in automotive applications. Peak ratings 

versus average versus steady state, as well as inlet 

cooling rates and losses at different operating points are 

tied up in the assumptions used to compare one electric 

machine to another after the scaling algorithm. 

Methodology/ Assumptions in 31 Bohn The model is very comprehensive, and according to the 

Results Model reviewer’s teleconference, the authors of this study 

validated many of the models and component scaling 

models. 

Methodology/ 

Results 

Assumptions in 

Model 

32 Bohn To the best of this reviewer’s knowledge, the assumptions 

used in this study are reasonable. Inputs on materials cost 

for the study appear to be reasonable to this reviewer. 

Methodology/ Assumptions in 33 Jacovides These seem to me to be appropriate. A problem will arise 

Results Model with the next person who runs the model. Will they have 

the expertise of FEV, which I think is one of the premier 

automotive engineering firms? 

Methodology/ Assumptions in 34 Miller While the majority of assumptions cited in the study are 

Results Model valid, there are a number of assumptions that need to be 

re-considered. They are as follows: 

• The technologies used are considered to be mature. It is 

more likely that the technology will continue to evolve 

requiring changes to manufacturing facilities and tooling. 

The assumption of maturity, for example, impacts a 

number of underlying cost elements and other 

assumptions: there are assumed to be no allowances for 

product/manufacturing learning, scrap rates are minimal, 

non-recovered E,D&T expense and capital costs are zero, 

and there are no allowances for equipment end of life 

costs. All of these stem from the assumption of maturity. 

At the same time, however, it is assumed that no new or 

modified equipment maintenance is required (See pages 

16 & 17). This is not consistent with equipment at the end 

of its life cycle. All of the above will cause cost estimates to 

be understated. 

• Recommendation: Review the costs impacted by the 

assumption of maturity. Uplift costs by a percentage factor 

where appropriate. If the assumption remains that 

equipment will be at the end of its useful life, then increase 

maintenance costs over time according to the equipment 

OEM’s guidelines. 

Methodology/ Assumptions in 35 Miller • It is assumed that “integration of new technology would 

Results Model be planned and phased in to minimize non-recoverable 

expenses”. This would indeed be the most cost effective 

decision. However, given the significant requirements for 

fuel economy improvements and emissions reductions, the 

need to implement new technology will likely be the overriding consideration. 

• Recommendation: Perform cost sensitivity analyses with 

non-recovered E,D&T and stranded capital in percent 

increments ranging from 10 to 30 %. Include the results in 

the paper. 

15
 
 

 

 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ Assumptions in 36 Miller • End-item scrap includes quality defects, rework costs, 

Results Model and/or destructive test parts (page 29). The general markup varies from 0.3% to 0.7% depending on part complexity 

and size (page40, Table C-1). However, it is stated that 

exceptions are made depending on the part. Examples 

cited in Section C.4.5.2 include sand and investment 

casting. These are considered to be “generic” processes 

and the end-item scrap mark-up is uplifted to 5% in both 

cases. However, just as in Table C-1, this rate needs to 

vary dependent upon the part size and part complexity (I 

am assuming tolerance limits are considered part of part 

complexity. If not, tolerances need to be considered as 

another factor in determining scrap rates.) Without a part 

by part review of the assumptions, the impact to the cost 

analysis can not be determined. 

• Recommendation: To test the reasonableness of the 

scrap percentages, check a random sample of 

components and compare the end-item scrap rates for 

those processes to industry standards. Use complexity 

and size of the parts to adjust averaged rates 

Methodology/ Assumptions in 37 Miller • All sourcing/manufacturing centers are assumed to be in 

Results Model the United States. As discussed in the March 8, 2011 

conference call, this is not a valid assumption and can 

significantly impact cost either negatively or positively. 

• Recommendation: Review present sourcing patterns, at 

least for the high cost components and sub-assemblies, 

and utilize these patterns as the basis for the cost analysis. 

Methodology/ Assumptions in 38 Miller • Labor Rates MAQS Costing Worksheet Example (page 

Results Model 46). It can not be determined whether or not any overtime 

costs were assumed in the labor cost/hour calculation. 

Overtime costs will vary manufacturer to manufacturer 

based on Union agreements and/or operating practices. 

However, in a number of cases (Ford Motor Company for 

one), shifts of 10 hours per day in the United States would 

generally include 2 hours of overtime pay. Afternoon shift 

also has an associated premium cost. 

• Recommendation: Verify underlying assumptions in the 

labor rate models. 

Methodology/ Assumptions in 39 Miller • Packaging Assumptions: Based on the sample 

Results Model calculation (page 50, Figure C-6), allowances for a 

percentage of pallets/racks out for cleaning and/or repair 

(generally around 5%) have not been included. This 

understates the packaging cost. 

• Recommendation: Increase the # of packaging units 

required by 5% where returnable packaging is used. 

16
 
 

 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology Assumptions in 40 Miller • Cost of Complexity Assumptions: Based on the volume 

/Results Model assumption of 450K per year, although it is not stated in 

the report, it is assumed that the major complex 

assemblies: Engine and Transmission as well as Complex 

Subsystems are produced on dedicated lines. If not, then 

a cost of complexity factor needs to be added. The 75% 

combined utilization/efficiency assumption (calculated 

based on page 37) is reasonable. However, if hybrid 

components are assembled on the same lines as the 

baseline products, then this utilization/efficiency is overstated due to the inherent inefficiencies caused by 

manufacturing complexity. Note: It should be assumed 

that hybrid and base vehicles will be assembled on the 

same line and so this added complexity must be factored 

into the utilization/efficiency calculation. 

• Recommendation: Process flow diagrams for complex 

base-line vehicle assemblies/components should be 

compared to those developed for HEV vehicle and 

adjustments made to the efficiency/utilization percents for 

HEV based on this comparison. 

Methodology/ Assumptions in 41 Miller • System Scaling Cost Analysis: While the use of ratios to 

Results Model develop sizing for HEV components such as traction 

motors, high traction batteries, etc. is appropriate and can 

be used to estimate material costs, the use of these ratios 

to determine other factors within manufacturing cost such 

as labor (page 126) is less valid. Part complexity 

influences these costs more than part size. The same 

concerns exist with establishing component costs for P2 

HEV powertrain components using manufacturing cost to 

component size ratios (page 127). 

Recommendations: 

• Re-evaluate the assumptions around use of a scaling 

factor to better define those costs which are scalable and 

those which are not. 

• Assuming the validity of the approach to costing using 

manufacturing cost to component size ratios, provide 

background data supporting this assumption. 

• As outlined above. review the application of scaling 

factors, especially for manufacturing cost and burden. The 

methodology described in the paper yields a result that 

should be considered as one end of a range estimate. The 

other end of the estimate should be developed by applying 

scaling factors to material cost and investment in 

equipment and holding the other costs constant. If it is 

necessary to state an absolute cost, the pick a middle 

ground between these two numbers based on expert 

opinion. 

Methodology/ Assumptions in 42 Ramaswamy In general, the assumptions that are utilized to calculate 

Results Model cost and performance are reasonable. One big exception 

(also mentioned in question 6 below) is the scaling 

parameter for the battery. Only two paragraphs are 

devoted to it in the report, and nowhere is a definition of “a 

common run-time”, which is used in the scaling of the 

battery, provided. 

17
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ 

Results 

Result 

Appropriateness 

43 Bohn Yes. The results expected of the study are reasonable 

given the scope, assumptions and inputs. 

Methodology/ 

Results 

Result 

Appropriateness 

44 Bohn The net incremental cost for each of the vehicle sizes and 

two hybrid topologies seems intuitive on cost magnitude, if 

in fact performance is equivalent. 

Methodology/ 

Results 

Result 

Appropriateness 

45 Bohn This reviewer cannot comment on other results that could 

be derived from the study. 

Methodology/ 

Results 

Result 

Appropriateness 

46 Bohn Validation is a very subjective process with regard to the 

‘level of validity’. After reading the study description, and 

listening to the authors during the reviewer’s 

teleconference where the validation process was 

described, it appears that reasonable validation was 

achieved on the costing results. 

Methodology/ 

Results 

Result 

Appropriateness 

47 Jacovides The results are reasonable, not only because the actual 

number is the same as we got in our study but because the 

costs are estimated with great detail. I am aware of one 

other company that has used this approach to come up 

with detailed costs of automotive components [Footnote 6: 

Intellicosting LLC, 980 Chicago Road, Troy, MI 48083-

4226]. However I am not aware of any similar results for 

hybrids. 

Methodology/ 

Results 

Result 

Appropriateness 

48 Jacovides I realize that you cannot publish confidential information 

that you obtain from OEM’s, but I think it would be useful to 

show the results to Ford and Toyota before making the 

report public. They are much more likely to find errors than 

the review panel and it may prevent any arguments after 

the report is made public. I understand that this a policy 

matter, but getting their input seems reasonable to me 

Methodology/ 

Results 

Result 

Appropriateness 

49 Miller At best, the levels of assumptions that are made in a study 

of this magnitude provide costs that are directionally 

correct. During the conference call on March 8, 2011, it 

was stated that the study commissioned was for absolute 

costs as opposed to range estimates. However, this gives 

the study results more credence than the assumptions can 

support. It was also stated, in the same conference call, 

that a manufacturer had been asked to provide costs for 

one component and that the cost differential to that 

developed in this study was 5%. This further supports the 

concern with reporting the cost results of the analysis as 

absolutes. 

18
 
 

 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ Result 50 Miller • Concerns regarding validation have been stated 

Results Appropriateness consistently throughout this review. Teardown analysis, 

development of process flow diagrams, analysis of 

comparable parts where available, etc., are excellent 

methodologies. However, a number of assumptions have 

gone into the methodology used to develop the 

manufacturing costs from these process flow diagrams and 

the validation of these assumptions are not documented in 

this paper. Of particular concern are the assumptions 

around sourcing (directed by the EPA), product maturity, 

development of burden rates by piece of equipment, direct 

labor cost calculations and the application of component 

size ratios as the primary scaling factor for manufacturing 

cost in other vehicle applications. 

Recommendations: 

• For those components/ assemblies which most impact 

vehicle cost, provide range estimates. Without looking at 

more detail, a proposal for these ranges can not be made. 

However, the cost developers for this study should be able 

to provide such ranges as are appropriate based on 

sensitivity testing. 

• Where components are most likely to be sourced outside 

the United States, costs need to be adjusted for sourcing 

pattern. The sourcing pattern may be a cost reduction or 

cost increase dependent upon a number of factors. 

• In the direct labor calculation of the mean manufacturing 

labor wage for a component or assembly (page 32), it is 

unclear whether or not the various labor wage rates are 

weighted by the calculated number of employees in that 

classification to obtain a weighted average. If this has not 

been done, direct labor costs need to be re-evaluated. 

There are significant wage differentials between the 

various classifications with general assembler being the 

lowest paid. (The same applies to the indirect labor costs.) 

Methodology/ 

Results 

Result 

Appropriateness 

51 Ramaswamy The results of the study are appropriate for the given 

scope, assumptions and inputs. 

Methodology/ Result 52 Ramaswamy The description/report of the validation of the costing 

Results Appropriateness methodolgy is not sufficient. The report does say that 

experts have been consulted in determining the costs of 

various components, but little validation has been shown 

(in the report) of cost validation at a subsystem or system 

level. The overall costs developed by FEV would present a 

greater punch if there were examples of the comparison of 

their system/subsystem costs with other costs that have 

been published in literature. 

Methodology/ Result 53 Ramaswamy FEV and Munro have the tools necessary to do a 

Results Appropriateness sensitivity analyses of the costs with respect to different 

variables of interest. Further analyses could include 

refinement/correction of some of the assumptions around 

this study (as mentioned in this review) and studying how 

the overall system costs are impacted by those changes. 

19
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ Approach used in 54 Bohn The approach used in scaling cost of the powersplit 

Results Scaling technology to other vehicle classes appears reasonable 

and shows no reason that it may be not accurate. The 

actual numbers placed into the scaling routines may be off, 

and result in turn may be off, but the approach is 

reasonable. 

Methodology/ Approach used in 55 Bohn The methodology for using power-split component costs in 

Results Scaling other hybrid technologies is reasonably and appropriate 

since several components are common, but scaled. As 

mentioned above, there are currently no published electric 

machine rating standards for automotive applications. The 

electric machine in the P2 topology has (or likely may 

have) a different load profile than that used for the powersplit topology where engine power is split through the two 

electric machines instead of just one in the P2. To that 

point using the normalized cost of the electric machines 

($/peak watt) from the power-split in the P2 topology is 

reasonable, but the machine rating/sizing may not directly 

translate. The battery costs will be equivalent between the 

two on peak power/energy, scaled as described in the 

report. 

Methodology/ Approach used in 56 Jacovides Scaling for a vehicle with identical architecture but with 

Results Scaling higher power is not as simple as it appears. Results are 

given on page 132 (pdf) [Footnote 7: Page numbers refer 

to the pdf not the pages in the report] for the HVAC 

system where the fixed cost of the electronics is, correctly, 

taken out. However the compressor cost appears to be 

scaled as the power. This is not correct since the material 

may indeed be scaled as the power but the labor is not. 

Methodology/ Approach used in 57 Jacovides Similarly the cost of the electrical machines should not be 

Results Scaling scaled as power. As stated above scaling for the P2 should 

be made on the basis of torque and duty cycle. I 

understand that two designs were made for a 30kW 

generator and for a 60kW motor. It was said during the 

conference call that using these designs the data were 

extrapolated for different size vehicle. This can only be 

done if the motor and generator have identical torque and 

duty cycle profiles. This is highly unlikely and so someone 

with electrical machine design experience needs to 

develop parametric results for the motor and generator 

separately. Also as stated above one cannot use power 

for scaling a slow speed machine used for the P2 

20
 
 

 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ Approach used in 58 Jacovides The NiMH battery scaling is done correctly. A possible 

Results Scaling weakness is that as an alternative to reducing the number 

of cells to estimate a smaller system, one may choose to 

use a larger number of smaller cells. Regarding the 

electrical machines and the compressor I suggest that a 

separate small study be undertaken to determine the 

scaling factor. I suspect it will be between two extremes, 

.a) scale as power and b) scale material as power and 

leave labor and overhead the same. Things get even more 

complex if a different architecture is used. The approach 

used here for the P2 architecture is directionally correct but 

the results will not have the accuracy that the Ford Fusion 

comparison has with its ICE counterpart. 

Methodology/ Approach used in 59 Jacovides The treatment of the Li-ion battery (LIB) raises a number of 

Results Scaling questions 

1.What is the available energy? Typically the SOC 

variation is limited in order to obtain life. For hybrids like 

the Prius the swing is from about 50% to 60%. The GM 

Volt battery swing is 30 to 80%. Scaling the LIB to the 

same nominal kWh assumes that the life of the LIB will be 

comparable. Some discussion is needed that the life will 

not be compromised 

2.It is not clear what size battery is costed for the P2. 

Page 126 (pdf) states that the battery from the Avante is 

0.954 kWh and this battery was costed on table D13 at 

$1399. Increasing the energy by 270/180 and scaling the 

costs as energy the P2 battery should cost $2098. Please 

explain whether the cost of the P2 battery is $1399, $1798 

or $2098. To add to my confusion table F2 shows a 

battery of 0.9117 kWh for the mid large (Fusion size 

vehicle). Also table A4 shows $1690.43 for the High 

Voltage Traction Battery Subsystem. I am sure I am 

missing something but it needs to be clarified for the 

reader 

3.The estimated cost of the cells given in D-13 for a 0.954 

kWh battery of $1020 seems reasonable at roughly 1000 

$/kWh 

Methodology/ Approach used in 60 Miller The use of ratios to develop sizing for HEV components 

Results Scaling such as traction motors, high traction batteries, etc. as 

described in the paper is appropriate and can be used 

effectively to estimate material costs and investment in 

equipment. 

21
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ Approach used in 61 Miller • Concerns with using the size ratio scaling methodology 

Results Scaling for certain other cost estimates is documented in other 

sections of the response. For convenience, they are 

repeated here:-Certain elements of overhead cost such as 

salaries and front office costs are not impacted, or at most 

minimally, by part size. -Direct labor costs are more closely 

tied to part complexity than to part size. -While part size 

will impact certain areas of indirect labor, such as material 

handlers, it will have a lesser impact on number of 

supervisors, quality inspectors, etc. Like direct labor, these 

numbers are more closely tied topart complexity than size.-

The same concerns exist with establishing component 

costs for the P2 HEV powertrain components using 

manufacturing cost to component size ratios (page 127). 

• The issues addressed above regarding scaling 

methodology apply equally to the P2 manufacturing cost 

calculations. 

Methodology/ Approach used in 62 Miller Recommendations: 

Results Scaling • Re-evaluate the assumptions around use of a scaling 

factor to better define those costs which are scalable and 

those which are not. 

• Assuming the validity of the approach to costing using 

manufacturing cost to component size ratios, provide 

background data supporting this assumption. 

• As outlined above, review the application of scaling 

factors, especially for manufacturing cost and burden. The 

methodology described in the paper yields a result that 

should be considered as one end of a range estimate. The 

other end of the estimate should be developed by applying 

scaling factors to material cost and investment in 

equipment and holding the other costs constant. If it is 

necessary to state an absolute cost, the pick a middle 

ground between these two numbers based on expert 

opinion. 

Methodology/ 

Results 

Approach used in 

Scaling 

63 Ramaswamy For most of the components, the approach used in scaling 

the cost of power split technology to other vehicle classes 

is reasonable and likely to yield reasonable results. 

Methodology/ Approach used in 64 Ramaswamy The one potential exception (and it is stated as potential, 

Results Scaling because the approach is not well explained in the report) is 

the scaling of the high voltage battery parameters across 

the the different vehicle classes. This needs to be better 

explained and justified, particularly because this one 

component is responsible for the bulk of the cost of the 

hybrid powertrain. 

Methodology/ Approach used in 65 Ramaswamy Given that the overall cost of the hybrid powertrain is so 

Results Scaling sensitive to this one component, this reviewer feels that 

greater care is needed in developing this cost. Conversely, 

there is considerable detail in the report on the costs for 

much more minor components, and although that is not a 

bad thing, the appropriate scaling of the battery system 

needs to have more effort put into it. 

22
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Methodology/ 

Results 

Approach used in 

Scaling 

66 Ramaswamy Although the scaling for the most of the components 

across the different vehicle classes seems reasonable, one 

big item that is not explained clearly is the high voltage 

battery. Given that it is the single most expensive 

subsystem within the hybrid powertrain, more care needs 

to be put into ensuring that this is done in a reasonable 

manner, and the report needs to explain how this was 

done. The last paragraph on page 132 talks about the 

“common run-time” parameter that is used to scale the 

battery system across vehicle segments. This parameter 

needs to be defined, and the report should have more of 

an explanation why the value of 0.0168 hours was used, 

and how it translates to the other parameters (power 

rating, energy rating) that define a battery 

Methodology/ 

Results 

Approach used in 

Scaling 

67 Ramaswamy In Table E-2, the nominal pack voltage for the subcompact 

passenger vehicle is quite low, namely 148V. Could other, 

potentially cheaper power electronics technologies be used 

at this battery voltage? 

Methodology/ 

Results 

Approach used in 

Scaling 

68 Ramaswamy There is a small discrepancy between some of the 

numbers in Table E-2 as compared to those in Table D-3. 

For example, for the Fusion Hybrid, Table D-3 lists the net 

power as 142kW, whereas Table E-2 lists it as 140.6kW. 

Similarly, the engine power is listed as 116kW in Table D3, but as 114.8kW in Table E-2. Even a rounding of the 

numbers doesn’t make them the same. 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

69 Bohn The report is sufficiently detailed for a reader familiar with 

the subject report to understand the process and 

conclusions. Each of the sections provides a very detailed, 

pedagogical approach on the rationale of systems and 

subsystem functions, components and assessed costs. 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

70 Bohn The tables inserted in the report are, of necessity, very 

small font with many values in a small area making it 

somewhat difficult to read in 8.5” x 11” printed format. The 

electronic format was easier to read and understand, 

zooming in on one column at a time. No change is needed 

for this in the report format, but possibly extracted column 

highlighting significant results would add clarity. A great 

deal of effort was expended to produce this space efficient 

report in a readable number of pages (sufficient detail 

without being too long.) 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

71 Bohn The appendices are appropriate. The cost model template 

is sufficient for the appendix. 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

72 Jacovides I would like to see a clear definition of what is assumed to 

be the Indirect cost (IC). Is everything not included in Step 

7 MAQS on page 21 assumed to be covered by IC? I 

realize that assigning an IC factor is beyond the scope of 

this report but it should be made clear what is included. 

Also it should be made clear that no allowance was made 

for a different IC factor for parts sold by suppliers and 

made by the OEM’s. 

23
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

73 Jacovides A minor editorial point deals with Page 10 figure A1. I 

would clarify the planetary gear set by showing ring, 

planets and sun clearly. Also remove the gap between the 

differential to show that the two gears mesh. Further label 

the output of the differential as going to vehicle wheels not 

coming from the wheels 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

74 Jacovides Page 9 makes a good point up front ...based on current 

automotive and/or surrogate industry manufacturing 

operations and processes, it is acknowledged that a 

reduction to the costs presented is very likely based on 

both product and manufacturing learning. Projected 

technology cost reductions, as a result of learning, are not 

covered as part of this analysis. 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

75 Jacovides Page 21.Item #8, Market Place Crosscheck, is a good idea 

but needs further explanation and the report should show 

results. Comparison with FEV in house experts seems 

less than satisfactory. 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

76 Jacovides Page 37 uses labor rates from BLS. Since lithium ion 

batteries are not made in the US it would be good to say 

what labor rate was used for the Li-ion battery. Some of 

the operations need to be made in low grade clean room 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

77 Jacovides I would be interested to find out how the electrical 

machines are cooled for the split power. Oil cooling is 

used for the P2 and coolant fluid is used for the power 

electronics but I doubt that coolant was used for direct 

cooling of the motor and generators 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

78 Miller Although a substantial amount of detail is included, there 

are a number of things that should be added to the report 

to substantiate the process and conclusions. As outlined 

in a number of questions above, these details are 

necessary to validate the processes and underlying 

assumptions used to arrive at the cost conclusions. These 

details include:-Validation of the Munro & Associates 

software including methodology and results 

•Validation and sensitivity testing (or results of the testing) 

of the FEV cost algorithms 

•A worked example showing the detail behind each 

number in the MAQS costing sheet. 

•Sensitivity analysis for a sampling of the components and 

assemblies in the cost analysis. 

•Data supporting the assumption that manufacturing costs 

can be calculated as a ratio of component size. 

•Clarification of the calculations for direct labor cost. 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

79 Miller With the exception of the last item [Clarification of the 

calculations for direct labor cost.], all of the appropriate 

documentation should be provided as appendices or as 

links to other papers/detailed analytical data. 

24
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Editorial Content Sufficient 

Detail/Appropriate 

Appendices 

80 Ramaswamy In most cases, sufficient detail has been provided for a 

reader familiar with the subject report to understand the 

process and conclusions. Exceptions are: 

• Rationale for assuming the high voltage battery is 

manufactured in the United States-Development of the 

ED&T costs for different subsystems, particularly that for 

control systems-Validation of the calculated costs at a 

subsystem/system level 

• Scaling of the battery system across different vehicle 

classes Cost for the high voltage DC/DC converter doesn’t 

appear to be included 

Editorial Content Editorial Issues 81 Bohn There is a divergence in the electrical engineering world on 

the proper use of the term for electrical distribution 

‘omnibus’. The classic spelling of the word has only one ‘s’ 

as in ‘bus’. The other spelling is also accepted as ‘buss’. 

There is no direct reference to point of divergence since 

the word ‘electrical bus’ was first used. No action required, 

just pointing out that there are two accepted spellings, the 

first coming from the origin of the word ‘omnibus’. The link 

below shows a survey of the percentage of respondents on 

their preference/where they were educated: 

http://www.gearslutz.com/board/so-much-gear-so-littletime/15867-buss-bus-where-you-learned-3.html 

Editorial Content Editorial Issues 82 Bohn Pagination and grammar in general are very consistent 

and acceptable. 

Editorial Content Editorial Issues 83 Jacovides No comments- everything seems very well done 

Editorial Content Editorial Issues 84 Miller The general organization of the paper is clear. 

Editorial Content Editorial Issues 85 Miller The following are areas where typographical errors or 

other editorial issues exist:-Page 16—Item 2 net to the last 

line. “Develop” should read Development” •Page 35—next 

to the last paragraph references a template in Appendix 

E.4. This Appendix could not be found in my copy of the 

paper. This may just be a labeling error, but none of the 

pages in the appendix appeared to be the template 

referenced.•Page 42—Next to the last paragraph, 2cnd 

sentence.FOB (freight on board) is usually designated as 

FOB, destination—supplier pays the shipping costs or FOB 

Factory—customer takes control of the product and pays 

the shipping cost. Note that in Europe, FOB is always 

referred to as “Free on Board”. Assuming you mean the 

receiving company pays the freight, the more common 

term would be FOB Factory. 

25
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Editorial Content Editorial Issues 86 Ramaswamy In most cases, sufficient detail has been provided for a 

reader familiar with the subject report to understand the 

process and conclusions. 

Exceptions are: 

• Rationale for assuming the high voltage battery is 

manufactured in the United States-Development of the 

ED&T costs for different subsystems, particularly that for 

control systems 

• Validation of the calculated costs at a subsystem/system 

level 

• Scaling of the battery system across different vehicle 

classes 

• Cost for the high voltage DC/DC converter doesn’t 

appear to be included 

Editorial Content Editorial Issues 87 Ramaswamy The overall report is well organized. There are a few minor 

typographical/grammatical issues. These are included in 

detail in section Grammatical/Typographical Errors 

1.Page 10, 2nd line, replace “advance” with “advanced” 

2.Page 11, 3rd line, replace “value” with “valve” 

3.Page 18, 3rd line, replace “standardize” with 

“standardized” 

4.Page 18, paragraph 2, 1st line, replace “very” with “vary” 

5.Page 19, paragraph3, 5th line from bottom, replace 

“develop” with “developed” 

6.Page 21, extra bullet point in Scenario #2 

7.Page 52, last paragraph, replace “Too” with “To” 

8.Page 52, last paragraph, replace “truck” with “trunk” 

9.Page 56, 2nd paragraph, replace “approximate” with 

“approximately” 

10.Page 91, 3rd paragraph, replace “acknowledge” with 

“acknowledged” 

11.Page 97, 1st paragraph, replace “VEV” with “HEV” 

Additional Next Steps 88 Jacovides Here are some unsolicited improvements and possible 

Comments next steps: 

As discussed above under f) have small study made on 

how to scale electrical machines and the compressor to 

distinguish between scalable and fixed costs. 

Additional Next Steps 89 Jacovides It would be good to check with Ford as to the accuracy of 

Comments the results. Although their volume is not up to 450k they 

should be able to give you an estimate. For comparing the 

P2 costs check with Honda or GM, which produce similar 

architectures although, without a clutch between the 

engine and transmission. More problematic will be a check 

with the GM on their two mode hybrids. They have higher 

power and one additional gear, but they seem to be much 

more expensive. As I said earlier the numbers check with 

the Prius that we studied, but we were puzzled by the GM 

figures. Although the Fusion is bigger the Prius data are a 

couple of years old and Toyota had not reached the 450k 

volume. 

26
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Additional Next Steps 90 Jacovides I would use the scaling exercise for the Volt and the Leaf. 

Comments These are much different vehicles but have components 

that have been included in this study. Then check with GM 

and Nissan on costs. 

Additional General 91 Jacovides Accurate calculation of the cost of new technology is very 

Comments Observations important to EPA since it needs to relate it to fuel 

consumption reductions. The recent history of these efforts 

is summarized in three reports [Footnote 1,2,3: 1: EPA420-

R-08-008 March 2008; 2: EPA-420-R-10-010 April 2010; 3: 

EPA-420-R-09-020 December 2009]. Until recently the 

approach was to ask OEMs and suppliers the cost of 

technologies and by taking several samples and probing to 

create reasonable estimates of the cost to manufacture. 

This approach was taken in reference 1 and also by an 

NRC Committee to study an "Assessment of Technologies 

for Improving Light-Duty Vehicle Fuel Economy" [Footnote 

4:http://www8.nationalacademies.org/cp/CommitteeView.a 

spx?key=48843] . 

Additional General 92 Jacovides I was a member of this committee and during our 

Comments Observations discussions we thought that a better approach would be to 

take apart the components of a new technology and 

analyze how much each component would cost. Such an 

approach would include no only the cost of labor and 

materials but all other "manufacturing" costs. Reference 2 

and 3 are examples of such an approach and deal with 

vehicles with conventional power trains and, in my view, 

confirm the accuracy of the process. 

Additional General 93 Jacovides The present report deals with hybrids and my evaluation 

Comments Observations will deal with the report as it calculates manufacturing 

costs. Of course in evaluating new technology EPA is 

charged to estimate not the manufacturing cost but the 

cost to the consumer to determine the cost to the 

consumer. Traditionally this was done using the so called 

Retail Price Equivalent (RPE) factor. The present report 

uses a factor called Indirect Cost (IC) multiplier. 

Establishing the multiplier is a highly controversial process 

and an EPA's attempt is given in [Footnote 5: EPA-420-R09-003 February 2009]. The controversy as discussed in 

reference 4 is that EPA tends to come up with a small 

factor and OEM's with a larger one. Also OEMs insist that 

a different factor should be used for technologies bought 

from suppliers and technologies manufacturer in house. 

Since the present report does not address this issue, I will 

limit my remarks to the estimation of the "manufacturing" 

costs as described. However since the EPA will use this 

factor in its regulatory process, the end result will likely 

underestimate the final cost to the consumer 

Additional 

Comments 

General 

Observations 

94 Miller It is clear that a great deal of detail and effort has gone into 

FEV‘s analysis and preparation of the report. 

Additional General 95 Miller The use of vehicle/component teardowns is an integral part 

Comments Observations of the analysis and recognized by the industry as an 

excellent means of cost analysis. Likewise, the 

development of detailed process flow charts used in the 

detailed costing is a well accepted practice. 

27
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Additional General 96 Miller The report analysis relies heavily on a number of data 

Comments Observations bases and models that are necessarily quite complex. 

However, validity testing of the Munro & Associates 

software which is fundamental to the development of the 

cost estimates is not documented. Additionally, tests that 

have been performed to validate the FEV data bases and 

the costing algorithms are not included. 

Additional General 97 Miller Recommendation: Since these data bases are integral to 

Comments Observations the study, include the detailed methodology, including 

worked examples, used to validate these data bases. 

Hypothesis testing of assumptions concerning burden 

rates, product maturity, etc. and sensitivity analysis to 

demonstrate correlation to actual component costs should 

be a part of the study. It is recognized that providing all the 

supporting detail in a paper of this magnitude would be 

excessive. However, a link to the data could be included 

similar to the one for OTAQ documents (page 126). If the 

data is considered proprietary, then examples tracing both 

a simple and a complex component/assembly through the 

process demonstrating how the various costs were derived 

should be included in an Appendix or as a separate 

document. 

Additional General 98 Miller The process for defining and apportioning manufacturing 

Comments Observations burden costs such as front office salaries down to a single 

machine on the plant floor is questionable. 

Recommendation: It would be more acceptable to apply 

the developed burden rates at a manufacturing 

process/component level. 

Additional General 99 Ramaswamy Table A-1 has a calculation of the percent 

Comments Observations decrease/increase in cost of adding the power split system 

to different vehicle segments. It would be more appropriate 

to calculate the percentage increase as compared to the 

base non-hybrid vehicle cost, instead of calculating the 

increase with respect to the mid/large size vehicle 

segement cost. 

Additional General 100 Ramaswamy Nowhere in the paper (for example, section D.7.1 makes 

Comments Observations no mention of it, and neither do Tables D-5 or D-6) could 

this reviewer find the mention of the high voltage DC/DC 

converter (which converts the voltage from approx 300V to 

approx 600V, and subsequently utilized by the traction 

motor and generator), which is used in the Fusion Hybrid. 

The corresponding cost for this part is also not mentioned. 

Additional Battery 101 Ramaswamy The report assumes that the battery will be manufactured 

Comments Manufacturing in locations in North America. Although this reviewer 

understands this to be a constraint from the EPA, this is 

not a reasonable assumption. There is no large scale 

automotive NiMH manufacturing in North America currently 

and there are few plans for the same. Although there are 

more examples of Li Ion battery manufacturing in North 

America, it is questionable if Li Ion will be the battery of 

choice for hybrid vehicles. In this reviewer’s 

experience/knowledge, the NiMH battery will continue to 

dominate the HEV market, while Li Ion will dominate the 

PHEV/EV market. 

28
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Additional Power Split 102 Ramaswamy The report talks about the applicability of the power split 

Comments Systems hybrid system to the sub-compact, small, large and 

minivan vehicle segments. It should be clarified that this 

group covers small SUVs, such as the Ford Hybrid 

Escape, which is one platform that clearly already supports 

this hybrid platform. 

Additional P2 Hybrid Systems 103 Ramaswamy P2 Hybrid System 

Comments 1. Although the EPA provided the direction to reduce the 

maximum system torque/power by 18-19%, the rationale 

for this isn’t clear. Without this rationale, a meaningful 

comparison between the cost figures for the power split 

system and those for the P2 system cannot be made 

2. Why was it felt that the Li Ion battery would be more 

appropriate for the P2 hybrid? Li Ion batteries have much 

better energy density than NiMH batteries, so for 

applications that require large battery energy (such as 

PHEVs or EVs), it is understandable to use Li Ion packs. 

However, for the P2 application, the required kWH of the 

battery (from Table F-2) was less than that for the power 

split application (from Table E-2). Given this, the selection 

of the Li Ion technology for the P2 system is not well 

justified. 

Additional 

Comments 

Cost Analysis 

Observations 

104 Ramaswamy In Figure B-1, why isn’t the BOM updated after step 6, 

when additional information has been gained about the 

component after its disassembly? 

Additional 

Comments 

Cost Analysis 

Observations 

105 Ramaswamy Page 50, first paragraph refers to 19,149 parts, and it 

wasn’t clear what the 19,149 parts stand for? Are these 

19,149 battery packs? 

Additional Cost Analysis 106 Ramaswamy It isn’t too clear how the engineering design costs for 

Comments Observations various components/systems have been calculated. 

a. For example, in section D.2.2, how has the engineering 

design cost for the Atkinson engine and the control system 

for it, and the calibration for it been calculated/estimated? 

b.Similarly, how is the engineering design cost for the 

electronics controllers, for the software for the battery 

system, for the mechanical design of the battery system 

been estimated? The actual numbers that have been 

presented in the tables appear to be too low. 

c.In Table D-11, why is the ED&T for the traction battery 

assembly so high ($49) compared to that for the control 

module (listed as $4)? The relative engineering effort for 

the control module is not 12 times less than that for the 

design of the mechanical assembly 

29
 
 

Verbatim Peer Reviewer Comments in Response to Charge Questions 

Additional Cost Analysis 107 Ramaswamy In general, FEV and Munro are to be commended for the 

Comments Observations detail that they have shown in this approach to determining 

hybrid system cost. The use of linked MAQS worksheets 

that allow the component costs to be rolled up to 

subsystem and system costs is a powerful tool, that can be 

used to do sensitivity analysis further down the line. 

However, the best system is only as good as the 

inputs/assumptions that drive it. Some of the assumptions 

used in this report(e.g. battery technology and size, 

manufacturing location, system power)that are key in 

determining overall system cost have to be carefully 

thought through and considered during future rulemaking 

by the EPA. 

30
 
 

Appendix A: Charge to Peer Reviewers 

Charge to the Peer Reviewers of EPA's Parallel Hybrid Technology Cost Report 

EPA's Parallel Hybrid Technology Cost Analysis Report is another key milestone in an extensive 

effort being carried out by FEV, under contract with EPA, to estimate the costs of technologies 

likely to be used in meeting future light-duty highway vehicle greenhouse gas (GHG) emissions 

standards. The report details the methodologies used by FEV and its subcontractor(s) to 

determine the incremental manufacturing cost of one particular LD emission control technology 

– a power-split parallel hybrid drivetrain, such as found in the Toyota Prius and Ford Fusion 

Hybrid. In addition to detailing the cost results of power-split technology, this report details the 

scaling of this technology to other vehicle classes, and establishes how the cost of major powersplit components can be used to inform the cost model for other types of vehicle technologies, 

such as P2 hybrids. 

No independent data analysis will be required for this review. Instead, EPA is seeking the 

reviewer's expert opinion on the methodologies and cost results of this study, and whether they 

are likely to yield an accurate assessment of the true cost of the technology. We ask that each 

reviewer comment on all aspects of the report. Please organize all responses according to the 

charge questions for each of the two categories listed below. 

1.	 Methodology/Results: 

a.	 Is the methodology documented in the report generally reasonable and likely to 

yield accurate results? Is any bias likely to be introduced to the results due to 

methodological issues? If so, please indicate the direction of this bias and 

potential remedies. 

b.	 Please identify any general flaws inherent in the scope of the study. Do you feel 

the results would be altered if the scope were more limited or expanded? Please 

explain. 

c.	 Are all appropriate inputs for the study being considered? Conversely, are all 

inputs considered in the study appropriate? Please cite any particular inputs or 

assumptions made by the study that you feel are inappropriate or likely to bias the 

results and how they could be remedied, with particular emphasis on sources of 

information used in determining labor rates, material prices, manufacturing 

burdens and other key factors. 

d.	 Are the assumptions embedded in the model that affect projected cost or 

performance reasonable? Such assumptions might include learning curve, 

economies of scale, scaling parameters such as weight and power, labor rates, 

plant scaling, and material costs. 

e.	 Are the results expected of the study appropriate for the given scope, assumptions, 

and inputs? Are there other results that could be derived from the analysis that 

A-1
 
 

 

Appendix A: Charge to Peer Reviewers 

would support or contradict those cited by the study? Is appropriate validation 

made on the costing methodology and results? Please expand on any 

recommendations that you would make for analyses of study results. 

f.	 Is the approach used in scaling the cost of power-split technology to other vehicle 

classes appropriate and likely to yield accurate results?, Is the methodology for 

using the cost of power-split components in other hybrid technologies appropriate 

and likely to yield accurate results? 

2.	 Editorial content: 

a.	 Is sufficient detail provided in the body for a reader familiar with the subject 

report to understand the process and conclusions? Are appropriate appendices 

included? Please specify any specific content that you recommended be added or 

removed. 

b.	 Please comment on any editorial issues that should be addressed in the report, 

including any comments on general organization, pagination, or grammar and 

wording. 

In preparing comments, please distinguish between recommendations for clearly defined 

improvements that can be readily made, based on data or literature reasonably available to EPA, 

and improvements that are more exploratory or dependent, which would be based on information 

not readily available to EPA. Comments should be clear and detailed enough to EPA readers or 

other parties familiar with the report to allow a thorough understanding of the comment's 

relevance to material provided for review. 

Additionally, EPA requests that the reviewers not release the peer review materials or their 

comments until the Agency makes its report/cost model and supporting documentation public. 

EPA will notify the reviewers when this occurs. 

If the reviewer has questions about what is required in order to complete this review or needs additional 

background material, please contact Susan Blaine at ICF International (SBlaine@icfi.com or 703-225-

2471). If the reviewer has any questions about the EPA peer review process itself, please contact Ms. 

Ruth Schenk in EPA's Quality Office, National Vehicle and Fuel Emissions Laboratory 

(schenk.ruth@epa.gov or 734-214-4017). 

A-2
 
 

Appendix B. Peer Reviewer CVs/Resumes 

B-1
 
 

Appendix B. Peer Reviewer CVs/Resumes 

blank 

page 

B-2
 
Theodore P. Bohn 

Educational Background 

M.S. 2003 Electrical Engineering, University of Wisconsin-Madison Electric Machine Design, 

Power Electronics and Controls 

B.S. 1994 Electrical Engineering, University of Wisconsin-Madison Power Electronics, Electric 

Machines and Control Systems 

A.S. 1982	 Electrical Engineering Technology, Herzing College 

Professional Experience 

1999 – Present Electrical Engineer 

Argonne National Laboratory, Lemont, IL 

Mr. Bohn is a principal investigator in the Vehicle Systems Section of Argonne National 

Laboratory’s Center for Transportation Research. His team is responsible for advanced 

vehicle testing and evaluation, modeling and systems analysis, and hardware-in-the-loop 

(HIL) development of hybrid vehicle technologies. He has been designated the de facto 

electric machines and power electronics expert, in a vehicle systems context, for the DOE 

National Laboratory system. His current assignments include positioning Argonne as the lead 

national laboratory in plug-in hybrid vehicle research within DOE. 

The following lists of achievements and responsibilities are derived from current and past 

projects within the CTR Annual Operating Plan tasks, as well as from the current position 

description. 

Achievements: 

Technology Crosscut: Supported by funds from several DOE sponsors, this effort bridges 

research on component-level plug-in hybrid vehicle (PHEV) power electronics/motors at Oak 

Ridge National Laboratory (ORNL), through Advanced Power Electric Machines Projects 

(APEEM); thermal studies at the National Renewable Energy Laboratory (NREL); and the 

Energy Storage Tech Team (ESTT), with the FreedomCAR Vehicle Systems (VSATT) work 

performed at Argonne. 

• Interacted with the FreedomCAR APEEM tech team, as well as ORNL, to develop 

methods for benchmarking high-speed, automotive-grade electric machines and power 

electronics for PHEVs. 

• Constructed, on the basis of a previous proof-of-concept scaled design, a fully capable 

55-kW fractional slot, segmented stator, surface permanent magnet prototype motor with 

an Argonne-motor fabricator-university team. This motor met FreedomCAR targets for 

cost, mass, operating temperature, and performance (being validated at present) goals. 

Three prototype motors were constructed to study effects on losses for different stator 

winding techniques. One of these motors was integrated into a production Lexus RX400h 

rear motor gearbox and is scheduled to be integrated into an Argonne PHEV prototype 

vehicle for evaluation. 

• Provided technology transfer and information dissemination of state-of-the-art in power 

electronics and electric machines to FreedomCAR tech teams and OEM partners, as well 

as component vendors. 
 

 

Theodore Bohn - January 2008 2 

• Procured sample OEM electric machines and transaxles from all of the current production 

hybrid vehicles e.g.., Prius, Lexus, Accord, Civic, Escape, etc). Each of these machines 

has been modified to connect to a conventional bench dynamometer to catalog key 

electrical and mechanical parameters commonly used by motor designers. Loss 

components, such as mechanical/gear loss, windage, and magnetic hysteresis losses, are 

also part of the catalog of measured motor metrics. 

• Generated open-source electric machine motor-drive control software as part of 

benchmarking the OEM machines described above. These software and benchmarking 

methods are used to support the SAE Task Force on electric machine rating methods for 

hybrid vehicle motors. 

PHEV Technology Platform Development: 

• Created a low-cost, real-time, robust, data collection system for PHEVs based on 

physical sensors, Global Positioning System (GPS) tracking, and interrogating vehicle 

CAN bus data; uploaded system to a server via WiFi link (ARDAQ). 

• Exploited the surplus computing power of the processor used in ARDAQ to run a Realtime In-Vehicle Emulation Toolkit (RIVETS) vehicle model to emulate a PHEV while 

driving a conventional vehicle, by using in-vehicle sensors as model inputs. 

• Designed, procured, and constructed several custom battery packs based on state-of-theart battery technologies, such as A123 Systems lithium-nanophosphate chemistry. 

• Initiated a research effort to develop PHEV energy storage systems with in-house-derived 

battery state-of-charge tracking algorithms, which are usually proprietary and not 

adjustable/tunable by the user, as required for PHEV experiments. 

• Created a TTR (through the road) parallel hybrid platform capable of all-electric 

operation at highway speeds, to be used as a research tool to develop electric/gasoline 

energy-blending strategies, develop Smart Charging communication techniques, and 

serve as a benchmark platform for PHEV electric motors and large-capacity batteries. 

Vehicle uses PSAT-based in-house vehicle-control algorithms. 

• Designed and constructed a flex-fuel-powered series PHEV prototype vehicle that 

contains Vehicle-to-Grid bi-directional power flow charging capability as a tool to 

evaluate/develop control algorithms, various battery sizes/types, and electric machines. 

This vehicle and evaluation of component technologies are all in support of SAE J1711, 

J1772, and J2293 standards development. 

• Supported a U.S.-Swedish PHEV technology collaboration that included rapid redesign 

and upgrading of the Volvo Recharge PHEV concept vehicle to include Vehicle-to-Grid 

intelligent charging capability. This project is an example of Argonne tech transfer. 

• Created the Argonne Advanced Powertrain Embedded Controls Systems (APECS) 

laboratory to develop many of the controller- and software-enabling applications needed 

to support the goals of the PHEV research program at Argonne. 

• Received Argonne Pacesetter Award for efforts to market Argonne “brand” for PHEV 

research innovation; as a result, Argonne was named the DOE PHEV Lead Laboratory. 

• Worked closely with Argonne Technical Services Division (TSD) to produce marketing 

materials (e.g., press releases, web updates, brochures for sponsors/conference attendees, 

DVD-ROMs of data and publications). Hosted a full-sized booth at several professional 

conferences to aggressively promote CTR transportation programs to the engineering and 

environmental policy community. 

Vehicle Technology Validation and Benchmarking: 

• Collaborated with Continental Automotive to validate, in a production vehicle, a 

prototype 14-V alternator synchronous rectification system that replaces the stock 
 

Theodore Bohn - January 2008 3 

alternator regulator and effectively is bona-fide “bolt-on fuel economy improvement 

device” (by measurably reducing accessory load losses) (~1.5 mpg). 

• Implemented an EMI-resistant Rogowski Coil-based AC power measurement system to 

overcome challenges in the electrically “noisy” HEV test environment. 

• Demonstrated the use of a novel Gigantic Magneto-Resistive (GMR) effect field sensor 

embedded in an integrated power module for an HEV traction inverter to sense current 

inside the power electronics, where a convention probe will not work. 

• Developed world-class in-situ torque sensors, incorporating EMI noise-resistant digital 

telemetry, to measure pulse-by-pulse engine torque without affecting the 

functionality/accuracy of the vehicle. This was accomplished by replicating the engine 

flywheel and matching mass and inertia with instrumented force bridges and wireless 

sensor power transfer. 

• Created innovative, non-invasive torque sensor located inside the transmission input shaft 

by hollowing out the center of the shaft and adding internal strain gauges. 

• Successfully procured each of the production hybrid vehicles within the stringent 

DOE/GSA guidelines and numerous justification letters required by all parties involved. 

These include the 2007 Hybrid Camry, 2006 Civic Hybrid, 2005 Honda Accord Hybrid, 

2004 Toyota Prius, as well as 170,000 mile end-of-life-study (used) hybrids such as 2000 

Honda Insight CVT, and 2002 Toyota Prius. 

•	 Created a real-world dynamometer driving simulator based on physical HEV pedals and a 

computer-based vehicle model. This device is used for the APRF Driver training 

program, which develops the eye-foot coordination of new vehicle operators to more 

accurately follow the EPA drive cycle trace. Vehicle parameters and drive cycles are 

selectable and feedback on driver accuracy is scored; this information is logged into the 

central host computer. This is also a quality assurance measure. 

• Designed and built baseline robotic driver for repetitive vehicle testing at the APRF. 

System used air-electric brake pedal actuators and direct “by wire” input control to the 

HEV accelerator pedal command. A newer system is now being constructed with a faster 

control computer, faster actuators, and better control algorithms. 

Hardware-in-the-Loop: 

• Participated on initial concept, design, and construction of the Mobile Advanced 

Technology Testbed (MATT). 

• Conceptualized, designed, and implemented a MATT “virtual inertia” electric motor that 

not only allows the power rating of the motor to be scaled to emulate smaller HEV 

motors, but the system can dynamically mimic different inertial driveline 

components/motors via torque sensors and real-time torque feedback equations. 

• Participated in a team that created first HIL experiment at Argonne. Based on the 

bedplate dynamometer, the pre-transmission parallel hybrid diesel-electric hybrid 

powertrain used an in-house-built constantly variable transmission. 

• Constructed and commissioned an axial flux motor (10 kW), HIL test stand that 

evaluated mechanically field-weakened wheel motors for future HEV powertrain designs. 

Powertrain was scaled to one-quarter of total road-load, for one of 4 wheel motors. 

• Constructed both 120 kW battery HIL test facilities inside the Advanced Powertrain 

Research Facility (one slow response, one fast response), with battery liquid coolant 

chiller and environmental chamber for air-cooled tests. 

• Initiated new PHEV energy storage system research area for active combination of 

ultracapacitors, via power electronics, with Li-ion battery experiments for lower-cost, 

more-robust energy-storage systems for PHEVs. 

• Developed new, novel, and robust current regulation algorithms for maintaining 

ultracapacitor state of charge (SOC) under highly dynamic operating conditions. 
 

Theodore Bohn - January 2008 4 

• Worked with OEM component vendors to study (and reduce) costs of boost converter 

magnetic components for electronics used in capacitor/battery studies. 

Advanced Vehicle Technology Competitions (AVTCs): 

• Worked with AVTC team to collect competition vehicle performance data and reduce it 

to a set of scored results for the 1999 FutureCar Competition. 

• Created a new set of competition rules for the 2000 FutureTruck competition, as well as 

annual revisions of these rules through the 2004 FutureTruck final year. 

• Worked with AVTC team to modify FutureTruck competition rules to match the goals of 

ChallengeX competition (2005–2008). 

• Conducted team on-site inspections and inspections of all participating vehicles at the 

competition to ensure a safe FutureTruck student vehicle competition for five years of its 

existence (2000–2004). 

• Created high-voltage systems safety and mechanical design “best practices” guideline 

document used in safety training for the ChallengeX student vehicle designs. 

• Responsible for all competition vehicle electrical safety inspections for ChallengeX 

(2005–2008). 

•	 Worked with highly experienced automotive engineers and academics to organize and 

host the first ever SAE Formula Hybrid competition, May 3-5, 2007. Responsible for 

overall competition safety as well as high voltage vehicle safety. 

Laboratory Directed Research and Development (LDRD): 

• Engine Waste Heat Recovery, System-Level Study: Collaborated with university 

researchers to investigate total quantity of heat recoverable from engine exhaust and 

coolant loop. Validated heat flux model showing as much as 7% of the total energy input, 

or 10% of the total waste heat, could be recovered under an arbitrary city driving load 

cycle (using Argonne Prius vehicle test data). For the assumptions used in this model, 

these percentages correspond to increasing the useable engine output from 43 kW (at the 

drive shaft) to 55 kW (drive shaft + electrical generation). 

• Studied advanced spray pattern and micro-channel/mini-channel heat exchangers, along 

with system-level simulation based on Toyota Prius hybrid vehicle actual drive cycle. 

Recovered waste heat energy converted to electricity via turbo-expander/generator and 

added to electricity available for traction power in hybrid powertrain. Future work to 

implement technology in on-road hybrid was proposed, but unfunded. 

Work-for-Others: Worked as point of contact and participant in several Work for Others 

and Technical Services Agreements for outside companies, including: 

• Oak Ridge National Laboratory: Instrumentation of 2004 Toyota Prius power electronics 

drive system for its component benchmarking activities 

• General Electric: Hybrid Delivery Truck powertrain testing and development 

• Hyundai: PHEV and in-depth HEV benchmarking 

• SK Battery: Battery hardware-in-the-loop evaluation and tech transfer/training of test 

methods to SK Battery, Inc. 

•	 University of Alabama- Birmingham: Created a fully instrumented Ford Escape Hybrid 

for the university’s newly formed hybrid vehicle research lab. Trained faculty and 

graduate students on details of internal power flow of this vehicle, along with the cutting 

edge custom torque sensors as well as the turn-key National Instruments turn-key data 

collection system. 
 

Theodore Bohn - January 2008 5 

Responsibilities: 

• Design and implement experiments that advance the state of the art for hybrid electric 

vehicle technology. 

• Participate in research teams performing complex testing of advanced powertrain 

subsystems and vehicles, including, battery packs, motors, imported production vehicles, 

and purpose-built research vehicles. 

• Gather and analyze data collected from complex testing of engines, battery packs, 

motors, and vehicles. 

• Prepare technical reports and papers that describe the results of R&D on hybrid electric 

vehicle technology. Present these results at relevant conferences. 

• Supervise technicians and students working on equipment in the Advanced Powertrain 

Research Facility. 

• Determine technical goals, provide organizational-logistical support, and maintain a high 

level of safety for Advanced Vehicle Technology Competitions. 

• Provide DOE sponsors with technology updates and progress summaries of Argonne 

research. 

• Foster relationships with automotive industry component vendors, government agencies, 

and academia that enhance the hybrid technical community’s base knowledge about 

hybrid vehicle advancements 

2000–2004 Renewable Energy Program Manager/Pre-doctoral Researcher 

University of Wisconsin-Madison, Madison, WI 

Mr. Bohn was the Renewable Energy Program Manager at University of Wisconsin-Madison, 

College of Engineering, responsible for fundraising, information dissemination, the teaching 

of power electronics design for renewable energy applications, and the development of 

curriculum and accompanying text/reference books. As a pre-doctoral researcher, he worked 

on developing electric machine and power electronics component models used in the 

Argonne-PSAT system toolkit. 

Responsibilities: 

• Developed transient response electric motor model for PSAT toolkit. 

• Taught course in power electronics design for renewable resources at junior/senior level. 

• Raised funds to support renewable energy education program. 

• Developed curriculum for undergraduate renewable energy education. 

• Managed financial, human/labor, and equipment resources to achieve student design 

project goals. 

• Developed control systems for characterizing interior permanent magnet electric 

machines, such as the motor in the Toyota Prius. 

Achievements: 

• Raised $50K in funds to start up renewable energy education program. 

• Developed power electronics curriculum for renewable energy applications and 

associated text/reference book. 

• Delivered custom-developed transient electric motor model and simulations for PSAT 

toolkit. 

• Designed, built, and tested prototype low-cost/high-performance soft magnet surface 

PM motor for HVAC applications. 

• Installed 1 kW of wind, solar/photovoltaic (PV), and fuel cell energy on-site resources. 
 

Theodore Bohn - January 2008 6 

1999–2000 Senior Design Engineer 

Power Designers LLC, Madison WI 

Mr. Bohn designed and developed a modular, low-cost interlaced battery management system 

module, called PowerCheq, to manage large battery systems, such as in a hybrid transit bus. 

He also designed off-road vehicle drive systems, as well as hybrid vehicle power 

management and high-power/rapid battery chargers. Before leaving Power Designers Corp 

(PDC) for graduate school, Mr. Bohn initiated work on fuel cell power conditioning power 

electronics. 

Achievements: 

• Produced low-cost reliable stationary charger for Kwang Yang Motor Company 

(KYMCO) electric scooters to reduce emissions in Taiwan. Funded by Industrial 

Technology Research Institute (ITRI). 

• Produced demonstration-level fast-charge system for electric scooters in Taiwan, with 

communication from battery management system to charger, including method to 

automatically bill owner of scooter being charged. 

• Built proof-of-concept PowerCheq battery equalization module, now in high-volume 

production. 

• Participated on team that designed and built prototype PowerCharge 10-kW battery 

charger used in industrial lift truck charge stations, as well as ISE Corporation’s hybrid 

buses. 

• Designed low-cost sensing and communication interface for PowerTrac battery 

monitoring system. 

Responsibilities: 

• Produced promotional materials and represented Power Designers at trade 

shows/conferences. 

• Tracked state of the art in power electronics products and competitive assessments of 

similar products produced by Power Designers. 

• Produced feasibility reports for Power Designers marketing group. 

• Designed power electronics circuits for commercial electric vehicles. 

• Developed test system software for prototype battery monitoring systems. 

• Developed burn-in fixtures for higher-volume-production electronic devices. 

September 1982–1992 Engineering Associate- Senior Technical Specialist 

Fermi National Accelerator Laboratory, Batavia, IL 

Achievements: 

• Commissioned 5,000-amp custom-built prime mover and protection system on 

superconducting solenoid for Colliding Detector Facility (CDF) experiment. 

• Designed custom-application specific integrated circuit robust enough to survive 

radiation levels at the beam aperture for silicon microvertex detector (SVX) and sensitive 

enough to count individual electrons of signal. 

• Designed quench detection/protection system for $6M superconducting solenoid and 

quench recovery system. 

• Produced prototype and sufficient quantity of custom waveform generators for 

quadrapole steering magnet power supplies in superconducting Tevatron accelerator to 

correct for higher-order harmonics beam orbit instabilities. 
 

Theodore Bohn - January 2008 7 

Responsibilities: 

• Designed, installed, and commissioned electronic apparatus to support experiments at 

CDF. 

• Oversaw quality assurance and documentation of installed systems. 

• Oversaw trouble shooting and maintenance of mission critical systems on experiments 

(e.g., Tevatron, CDF, D0 Muon line). 

• Characterized radiation hardness and performance degradation of Application-Specific 

Integrated Circuit (ASIC) signal conditioning devices for Silicon Vertex (SVX) detectors. 

• Performed periodic power system performance/quality upgrades for detector electronics. 

Other Relevant Work Experience 

2003–2004 Caterpillar Corp., Peoria, IL: (subcontractor) Research Engineer 

• Constructed open source code controller on prototype dynamometer to develop standardized 

test procedures to measure critical electrical parameters of production interior permanent 

magnet motors; led to the characterization of Caterpillar custom motors. 

1997–1998 Hyperdyne Corp., Madison, WI: President, Co-founder of S-type Corporation 

• S-type Corporation founded with colleagues to compete for Small Business Innovation 

Research grants (SBIRs). Research projects included such topics as development of 

algorithms to track battery state of charge, state of health, and instantaneous power capability 

of electric vehicle batteries. Proof-of-concept products included a power electronics unit for a 

higher-efficiency electronic “fish fence” to contain migration of invasive non-native species 

that can cause unnecessary fouling of water inlet hardware. 

1996–1997 Industrias Murrell, Guadalajara, Mexico: Electrical Engineer Consultant 

• Designed proof-of-concept range-extended clean hybrid industrial burden carrier, legal for 

use as delivery vehicle in Mexico. Project sponsored by Mexican government to reduce 

emissions in Mexico City by producing a delivery vehicle capable of driving from remote 

warehouse to downtown on propane-powered internal-combustion (IC) engine, then electric 

mode for delivery of goods down narrow streets where conventional delivery trucks will not 

fit. 

1995–1996 Columbia Par Car, Reedsburg, WI: Electrical Engineer 

• Started as consultant hired to resolve noise-vibration-harshness (NVH) problems arising from 

use of new 4-stroke engine in golf cart design, for Mazda spin-off joint product. Responsible 

for implementing electric drive systems in custom tram vehicles, industrial burden carriers, 

and specialty golf carts. Qualified potential charger and drive electronics for future products. 

Performed range and durability benchmark studies. 

1994–1995 Kohler Company - Generator Division, Kohler, WI: Researcher/Electrical Engineer 

• Developed proof-of-concept solid-state generator set based on latest state-of-the-art 

components, such as coaxially wound boost power transformers, for market study. 

1994–1994 GM-Advanced Technology Vehicles, Torrance, CA: Electrical Engineer 

• Worked on high-power inductively coupled battery charger for EV-1 electric car as an 

extension of university research. Initiated series hybrid APU for RE-29 transit bus to study 

low-noise, low-emission range-extending technologies, via reduced auxiliary loads. 

1994–2004 EVRx Electric Vehicle Design/Development, Madison, WI: Owner/Consultant 
 

Theodore Bohn - January 2008 8 

• Electric vehicle design consulting service founded as a result of connections and contacts 

made through DOE Advanced Vehicle Technology Competitions. Focus of the enterprise was 

on energy storages systems, power electronics/machines, and controls. 

1989–1994 University of Wisconsin-Madison, High Energy Physics Department: Electrical Engineer 

• Continuation of Fermilab-based experiment apparatus design. Developed very high speed 

trigger processor systems (1 GHz throughput) for the D0-Muon detection system at the 

Tevatron proton-antiproton collider at Fermilab. Worked as part of a team on wire chamber 

particle detectors for the (proposed) SuperCollider in Waxahachie, TX, as well as detector 

electronics for the Large Hadron Collider (LHC) at CERN, France. 

1982–1982 Kohler General Corp., Sheboygan Falls, WI: Engineering Intern 

• Led efforts to design, construct, program, and evaluate a low-cost programmable controller 

for a polystyrene thermal expansion press that produced formed packing inserts for 

Craftsman Tools. Project used (at the time, cutting edge) a Zilog Z-80 single-chip 

microprocessor on $200 single-board computer as the basis for a low-cost alternative to a 

$2,000 commercially available Texas Instruments Programmable Logic Controllers (PLC). 

1977–1999 Sunshine Satellite Systems, Cleveland, WI: Founder/owner/operator 

• Started as apprentice for communications equipment repair/refurbishment business. New 

digital era satellite communications afforded an opportunity to start a small business based on 

installing and maintaining Very Small Aperture Terminals (VSAT) for retail stores (ground 

satellite terminal), as well as home-based satellite receivers. 

Professional Societies (chosen to be consistent with job responsibilities) 

Society of Automotive Engineers (SAE)
 

Institute of Electrical and Electronics Engineers (IEEE) 

IEEE Power Electronics Society (PELS) 

IEEE Industrial Applications Society (IAS) 

Honors and Awards 

1997 Granger Outstanding Power Engineering Student Award (undergrad) 

2001 Focus on Energy $2,000 Scholarship for design of grid-tied power inverter 

2002 Granger Outstanding Power Engineering Student Award (graduate) 

2003 Tong Innovative Student Design Award (low-cost third-world electric vehicle) 

2005 Recipient of an SAE Transactions Paper Award (Characterization of Variability in 

4WD Dynamometer Testing Results Due to Tie-Down Methods) 

2007 Argonne Pacesetter Award for establishing Argonne as DOE lead on PHEV research 

2008 Society for Technical Communications “Distinguished Award” for PHEV informational 

materials (brochures and posters), developed with Argonne TSD staff 

2008 Nominated for R&D100 Award for ARDAQ real-time data acquisition system 

Patents 

US Patent applied for — Real-time In-Vehicle Emulation Toolkit 

This patent applied for as enhancement of Argonne’s Real-time Data Acquisition System 

(ARDAQ) that allows users to emulate future technologies, with a conventional production 

vehicle, in real time. 

Organizational Activities (subset) 
 

 

Theodore Bohn - January 2008 9 

Session Chair of Advanced Battery Technology Committee, SAE World Congress 2008 

Session Chair of Fuel Cell Committee, SAE World Congress 2007 

General Committee of the 23rd Electric Vehicle Symposium, Anaheim CA, 2007 

Organizer of International Electric Machines Designer Conference, 2003 

SAE Electric Machine Rating Standards Task force—current 

SAE J1772 Electric/Hybrid Vehicle Conductive Charging Equipment Standards—current 

SAE J1711 Recommended Practice for Measuring the Exhaust Emissions and Fuel Economy of 

Hybrid-Electric Vehicles—current 

SAE J2238 Energy Transfer System for Electric Vehicles: Functional Requirements, System 

Architectures, and Communication Messaging—current 

Peer reviewer for IEEE conferences (APEC, IAS, PESC, IEMDC) and SAE World Congress 

Community Service (subset) 

Volunteer — Introduce a Girl to Engineering Day (IGED) program 2007, 2008 

Volunteer — Mentor for Future Energy Challenge design competition 1999–present 

Volunteer — Habitat for Humanity 1990–present 

Volunteer — Adult Literacy Program 1985–1990 

Publications: Journal Articles and Book Contributions 

(listed as separate document) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

LINOS J. JACOVIDES
 

A native of Paphos, Cyprus, Dr. Linos J. Jacovides received 

Bachelor’s and Master’s degrees in Electrical Engineering, from the 

University of Glasgow, Scotland, and a Doctorate in Generator Control 

Systems from the Imperial College, University of London, in 1965. 

Dr. Jacovides was most recently Director, Delphi Research 

Labs, from December of 1998 until he retired in January of 2007. This 

was the Central research operation for Delphi with a budget around 

$20M and involved a group of about 90 researchers dealing with 

advanced projects - 5 to 15 year horizon. The staff has mostly 

doctorates in physical sciences and engineering with at least 10 Fellows 

of IEEE, SAE, and the American Physical Society. In this post, he was responsible for R&D in 

the following areas: Manufacturing Processes, Materials, Devices, Mechatronics, Polymers, and 

Systems. Unlike some Corporate Research Labs the funding was based on voluntary 

contributions from the Business Units (BUs). Although in many industrial labs such a 

mechanism leads to short term projects, an agreement was reached that 30% of the budget 

would be allocated to long term exploratory projects at the discretion of the Lab Director. The 

remaining 70% was for projects that were approved by the BUs. This worked very well until the 

company declared bankruptcy in 2005. 

He joined General Motors Research and Development in 1967 after a two-year 

assignment at the Defense Research Laboratories in Goleta, California. He held several 

positions at General Motors Research becoming one of GM’s youngest executives at age 35. 

He became department head, electrical engineering in 1985. 

His areas of research were the interactions between power electronics and electrical 

machines in electric vehicles and locomotives. He worked on some of the electric vehicles of 

the 60’s to the 80’s at GM. By the 80’s he argued against commercializing the EV1 maintaining 

that the batteries were not ready for the market. At Delphi his technical interests were on fuel 

economy, electronics and alternative fuels. He is the author of ten peer reviewed articles, two 

patents and several internal research reports. He edited the first SAE special publication on 

Electric Vehicles. 

Since retirement he acted as a consultant to Delphi for several months, to help formulate 

Delphi’s strategy on fuel economy. Since September of 2007 he is also on four Committees of 

the National Academies to assess various aspects of vehicle technologies for improving fuel 

economy. His contributions are in the area of vehicle propulsion (internal combustion, hybrids, 

fuel cell and plug-in hybrids). He is also a member of the Visiting Committee for the EE Dept at 

Michigan State University 

He is a Fellow of the Institute of Electrical and Electronics Engineers (IEEE), where he 

served as President of the Industry Applications Society in 1990. He is also a 43 year member 

of SAE and was recently elected Fellow for his work on electric propulsion. He was a 

representative of Delphi at the Industrial Research Institute. 

Linos Jacovides 1 1/12/2011 
 

 

 

 

 

 

 

 

 

 

Resume
 

Education 

B.Sc. 1961, (1st Class Honours, Electrical Engineering) University of Glasgow,
 

Scotland -- Prize for " .. the most distinguished graduate of the year in the
 

engineering faculty".
 

M.Sc. 1962, University of Glasgow -- Thesis on synchronous machine theory.
 

Ph.D. 1965, Imperial College, University of London, England-- Thesis on electric
 

power grid stability control systems.
 

Goethe Institut German for foreign students - summers of 1960 and 1961
 

Employment

Consulting 

•	 Expert witness in case against the Army 

•	 Taught classes on electric drives at University of Michigan 

•	 Member of Board of Directors Novolyte Technologies –Electrolytes for Lithium ion 

batteries 

•	 National Research Council - Economy Assessment of Resource Needs for 

Development of Fuel Cell and Hydrogen Technology & Potential Impacts of PlugIn Hybrid Electric Vehicles. 

Delphi 

•	 Special assignment to formulate Delphi strategy on fuel economy 2007-08 (4 

months) 

• Director Delphi Research Laboratories (Executive Position) 1999- 2007 

General Motors Research Laboratories 

•	 Chief Scientist Delphi Energy and Engine Management 1994 - 99 

•	 Head, Electrical and Electronics Department, 1988- 99 (Executive Position) 

•	 Principal Research Engineer, EE Dept., 1987-1988 

•	 Asst. Department Head, EE Dept., 1985-1987 (Executive Position) 

•	 Senior Staff Research Engineer, EE Dept., 1975-1985 (Executive Position) 

•	 Senior Research Engineer, EE Dept., (Special bonus awards 1969, 1970, 1972), 

1970-1975, 

Research Engineer, EE Dept., 1967-1970 

GM Defense Research Laboratories, Goleta, California, 1965-1967 

1959 Summer intern Ferranti Limited Manchester. UK 

1961 Summer intern Siemens & Halske Karlsruhe. Germany 

Professional Societies 

IEEE Fellow 1990 

IEEE Industry Applications Society 

Society President 1990 Vice President 1989 Secretary 1988 

Chairman of the Industrial Power Conversion Systems Department 1986-88 

Chairman of the Industrial Drives Committee 1984-85 

IEEE Power Electronics Society – past member 

IEEE Magnetics Society – past member 

Linos Jacovides	 2 1/12/2011 
 

 

 

 

 

 

 

SAE (past chairman of both the Electric Vehicle Committee and the Electrical and 

Electronics Systems Committee) 

Institution of Electrical Engineers, (IEE) England – past member 

Invited Talks 

•	 An Electrical Engineer in the Automobile Industry 

•	 Student Activities Committee 

•	 IAS Annual Meetings 1986 and 1987 

Technical activities 

•	 Organized many technical sessions in technical meetings for both the SAE and 

the IEEE. Starting in 1970 

•	 Initiated a series of Global Technical conferences where Delphi engineers could 

present their advanced work 

•	 Technical Vice Chair for Convergence in 2000 and 2004. convergence is the 

premier conference for automotive electronics and the Vice chair is actually the 

person in charge of the program 

•	 National Research Council. Committee memberships 

o Assessment of Technologies for Improving Light-Duty Vehicle Fuel 

Economy 2007 to 2010 

o	 Review of the FreedomCAR and Fuel Research and Development 

Partnership, Phase 3. 2009 to 2010 

o	 Transportation Research Board. Chair of PANEL SP20-83(04) Effects of 

Changing Transportation Energy Supplies and Alternative Fuel Sources on 

State Departments of Transportation. 2009 to 2012 

Publications 

1. "A Critical Evaluation of AC Motor Drives for Traction," B. V. Murty and L. J. 

Jacovides. Presented at the 20th Intersociety Energy Conversion Engineering 

Conference, Miami, FL, Aug. 18-23, 1985. 

2. "Brushless Motor Drive for In-Tank Fuel Pump," B. R. Patel, L. J. Jacovides, J. G. 

Neuman. Presented at the 1984 SAE Congress Feb. 27 Mar. 2 1984. SAE Paper No. 

84445. 

3. "A Cycloconverter-Synchronous Motor Drive for Traction Applications," L. J. 

Jacovides, M. F. Matouka, and D. W. Shimer. IEEE Trans. Industry Applications Vol. IA17 #4, pp. 407-418, (Jul/Aug. 1981). 

4. "An Improved Triggering Method for a High-Power Cycloconverter-Induction 

Motor Drive," IEEE Trans. Industry Applications Vol. IA-15 #5, pp. 

472-481, (Sept./Oct. 1979). 

Linos Jacovides	 3 1/12/2011 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

5. "Electric Vehicle Simulation Program," R. H. Nelson, L. J. Jacovides, F. J. 

Schauerte, and E. J. Woods. Presented at the International Electric Vehicle 

Symposium, Philadelphia, PA, October 2-5, 1978. Published at the Conference 

Proceedings. 

6. "Digital Simulation of a High-Performance AC Drive System, Part II," S. D Rajan, L. J. 

Jacovides and W. A. Lewis. IEEE Trans. Industry Applications Vol. IA-10 #3, pp. 397­

402, (May/June 1974). 

7. "Digital Simulation of a High-Performance AC Drive System, Part-I," S. D. Rajan, L. 

J. Jacovides and W. A. Lewis. IEEE Trans. Industry Applications Vol. IA-10 #3, pp. 391­

396, (May/June 1974). 

8. "Analysis of a Cycloconverter Induction Motor Drive System Allowing for Stator 

Current Discontinuities," IEEE Trans. Industry Applications Vol. IA-9 #6, pp. 206-215, 

(Mar/Apr 1973). 

9. "Analysis of Induction Motor Drives with Non-sinusoidal Supply Voltage Using Fourier 

Analysis." IEEE Trans. Industry Applications Vol. IA-9 #6, pp. 741-747, (Nov/Dec 1973). 

10. "Effect of Excitation Regulation on Synchronous Machine Stability," L. J. Jacovides 

and B. Adkins. Proc. IEE Vol 113, #6, pp. 1021-1033 (June 1966). 

11. "The Effect of Regulation of Excitation on the Stability of Synchronous Machines." 

Ph.D. Thesis, Imperial College, University of London, August, 1965. 

12. "The Inductance Matrices of the Salient Pole Synchronous Machine," M.Sc. Thesis, 

University of Glasgow, Scotland, September, 1962. 

Patents 

Induction Motor Fabrication Method 3,705,971 Dec. 12, 1972 

Method of Induction Brazing a Complex Assembly 4,443,678, Apr. 17, 1984 

Reports

There are several research reports that are GM or Delphi confidential. However the 

titles of three recent ones may be relevant. 

1. Alternative Fuels and the Impact on Delphi - Global Issues. Delphi Research Labs 

report No 385 2006 

2. Alternative Fuels and the Impact on Delphi – Regional Assessment. Delphi Research 

Labs report No 400. 2006 

3. Fuel Economy – Strategic Analysis. Assessment of Delphi’s Strategy to improve 

vehicle fuel economy. Innovation Technology Office 2008 

Linos Jacovides 4 1/12/2011 
 

 

 

 

 

 

 

 

LINDA M. MILLER 

miller1249@comcast.net 

27500 West River Road Residence: 734-692-2621 

Grosse Ile, Michigan 48138 Cellular: 313-218-6075 

CAREER SUMMARY 

A results-driven senior manufacturing executive with extensive experience in automotive 

component manufacturing, business planning and supply base development. Demonstrated 

ability to build consensus among diverse groups through creation of common goals and 

objectives. Significant experience in global operations management, operations consolidation 

and new program management. A strong track record of delivering objectives through the 

effective development of people, ability to handle difficult Union relationships and effective 

communication skills. 

PROFESSIONAL EXPERIENCE 

FORD MOTOR COMPANY, Dearborn, MI 1973-2007 

Automotive Manufacturer 

Director of Manufacturing, Powertrain Operations 2005-2007 

Responsible for the performance of 9 engine, casting, forging and electronic components 

plants in the United States, Mexico and Canada with a combined business of $950M. 

•	 Developed a strategic plan for standardization of key systems across all plants that 

delivered 15-20% annual improvement in cost and quality performance metrics. 

•	 Led Union negotiations around out-sourcing of non-critical indirect labor and streamlining 

of classifications that resulted in reduced operating costs. 

•	 Championed the Powertrain Environmental and Quality Councils and Six Sigma efforts 

working to achieve common operating systems across all powertrain plants. 

o	 Key elements of operating systems were agreed upon and are under 

implementation. 

•	 Chaired the Powertrain People Development Committee ( PDC ) and Manufacturing 

Leadership Program that led to identification and development of a diverse group of high 

potential employees. 

•	 Acted as Co-chair of the steering committee for Women in Manufacturing and through 

participation in the Executive Council on Diversity was the formal / informal mentor for 

over 25 men and women in manufacturing. 

Director of Manufacturing, V-Engine and Casting, 2002-2005
 

Powertrain Operations
 

Responsible for the performance of seven engine and casting plants in Canada and the 

United States with a combined business of $700M. 

•	 Developed cost, quality and safety processes resulting in cost improvements that 

averaged 8% annually across all plants, warranty and internal quality improved over 

10% per year and safety metrics improved over 15% annually. 

•	 Successfully negotiated and led implementation of the idling of a forging plant and an 

aluminum casting plant. 

•	 Led a cross-functional task force that enabled development and production of a cost – 

effective all new 3.5L engine. Innovative engineering design and manufacturing 

processes saved $1,800 per unit. 

•	 Teamed with the Group Vice-president of Manufacturing to develop and launch the 

Women in Manufacturing organization as one of Ford’s employee resource groups. 
 

 

 

 

 

 

 

 

 

 

 

Linda M. Miller	 Page 2 

FORD MOTOR COMPANY, ( continued ) 

Director of Manufacturing, Casting Operations,	 2000-2002 

Powertrain Operations 

Responsible for the performance of all eleven casting and forging plants world-wide with a 

combined business of $400M. In addition, responsible for divesture and / or consolidation of 

facilities wherever feasible. 

•	 Initiated lean manufacturing principles which enabled the US and Canadian plants to 

achieve 5% performance improvements annually and meet operating budget for the first 

time. 

•	 Led divestiture or joint venture partnerships for plants in Argentina, New Zealand and the 

aluminum plants in Canada and created strategy for the closure of four plants in the US 

and Canada that resulted in closure of three and pending closure of 4th. 

•	 Managed the Staff Castings Manufacturing Engineering Group responsible for 

development of new manufacturing technology and for providing manufacturing technical 

assistance for supply base. 

o	 Teamed with outside supplier and product engineering that developed the first 

high volume, high pressure die cast aluminum cylinder block for Ford. 

•	 Ford Senior Representative in the American Foundryman’s Society. 

o	 Led the effort for the society to become more inclusive by changing the name to 

American Foundry Society. 

o	 Advanced the development of student education through participation in the 

Foundry Education Foundation ( FEF ) seminars as a keynote speaker. 

Director, Manufacturing Business Office, Ford Motor Company 1998-1999 

Directed the work of the world-wide business offices for vehicle and powertrain 

manufacturing in the development of a world-wide manufacturing business plan that would 

complement the global product development cycle plan. 

•	 Achieved economies of scale by moving all four cylinder engine manufacturing 

development to Europe and consolidating v-engine work in the United States.
 

•	 Identified opportunities for the introduction of flexible manufacturing technologies that 

maximized the ability of manufacturing to react to late cycle plan changes. 

•	 Assessed the proposed manufacturing plans for South America, India and China and 

achieved maximum asset utilization. 

•	 Developed the supplier park concept for Ford of Europe that reduced logistic and hourly 

workforce costs. 

Director, Supplier Technical Assistance, Ford Purchasing 1995-1998 

Responsible for globalizing and consolidating the various supplier quality and technical 

support groups in Ford world-wide. 

•	 Developed and implemented a common system of supplier evaluation and performance 

measurement that enabled effective sourcing of product based on quality and cost. 

•	 Streamlined the organization by eliminating multiple interface points with the same 

supplier resulting in a 30% reduction in staffing. 

•	 Developed a supplier accessible electronic data base for performance metrics that 

allowed suppliers to react more quickly to quality trends. 

o	 Improved supplier quality 40% over three year period. 

•	 Led a team of key suppliers and internal personnel that developed a methodology for 

warranty sharing between Ford and suppliers which became a benchmark in the industry 

and significantly reduced Ford warranty costs. 
 

 

 

 

 

 

 

 

Linda M. Miller	 Page 3 

FORD MOTOR COMPANY, ( continued ) 

Plant Manager, Dearborn Engine and Fuel Tank Plant 1993-1994 

Managed a three shift plant manufacturing four cylinder engines and all of the steel fuel 

tanks for Ford cars and trucks. Employment of 1500 union and salary employees. 

Responsibility also included design cost reduction and new program implementation. 

•	 Negotiated unique operating patterns and developed new technology applications to 

reduce the original planned investment in a new engine program by 35%. 

•	 Reduced operating costs by 10% while improving engine warranty costs by 11% and 

becoming the first Ford plant to achieve the Total Quality Excellence award. 

•	 Improved results in the Plant Leadership Behavior Survey by 40% through a series of 

actions recognizing employee contributions and instituting quarterly small group 

meetings with all salary personnel with an emphasis on candid dialogue. 

Asst. Plant Manager, Cleveland Engine Plants	 1991-1993 

Responsible for running Cleveland Engine Plant 1 manufacturing the 4.9 and 5.0L engines. 

Manufacturing Manager, Essex and Windsor Engine Plants 1989-1991 

Responsible for production, quality and manufacturing engineering at the Windsor and 

Essex Engine plants. 

Manufacturing and Plant Engineering Manager,	 1987-1989 

Dearborn Engine Plant
 

Quality Control Manager, Dearborn Engine Plant 1985-1987
 

Supervisor, Planning and Material Cost Reduction, 1983-1985
 

Engine Division
 

Production Superintendent, Dearborn Engine Plant 1982-1983
 

Inspection Superintendent, Dearborn Engine Plant 1979-1982
 

Quality Control Engineer, Engine Division 1978-1979
 

Supplier Quality Assurance Representative, Engine Division 1976-1978
 

Quality Control Analyst, Engine Division 1973-1976
 

EDUCATION 

MBA, Management, University of Detroit, Detroit, MI 1981 

MA, Mathematics, University of Kansas, Lawrence, KS 1972 

BS, Mathematics, Northeast Missouri State University, Kirksville, MO. 1970 

MEMBERSHIPS / AFFILIATIONS 

President, University of Detroit-Mercy Business School Advisory Board 1999-present 

President, Truman State University Foundation Board 2004-present 

Co-Chair, Board of Trustees, Wayne State University / Ford Motor 2000-2006 

Engineering Management Master’s Program 

Member, Women’s Automotive Association International 2004-present 

Member, American Foundry Society 2000-2006 

Member, Board of Directors, Cleveland Opera 1991-1993 

Member, United Way Leadership Giving Council, Canada 1989-1991 

AWARDS AND RECOGNITION 

Distinguished Alumni Award, University of Detroit-Mercy, Business School 2005 

100 Leading Women in the Automotive Industry, Automotive News 2000 & 2005 

Spirit of Leadership Award, Women’s Automotive Association International 2004 

Alumni of the Year, Truman State University 2002 

Magnificent Seven Award, Business and Professional Women’s Club 1997 

Pilliod Lecturer, Kent State University 1995 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

DEEPA RAMASWAMY, PH.D. 

(734) 507-9302 

http://www.hybridchakra.com deepa@hybridchakra.com 

SUMMARY OF QUALIFICATIONS 

Extremely motivated and results-driven management, engineering and business development professional with 

exceptional oral and written communication skills and an extensive background in the following broad-based 

competencies: 

BUSINESS DEVELOPMENT ENGINEERING CONSULTING	 HYBRID SYSTEMS 

PRODUCT DEVELOPMENT PROGRAM MANAGEMENT	 BATTERY SYSTEMS 

RESEARCH & DEVELOPMENT SYSTEMS ENGINEERING CONTROLS & ELECTRONICS 

MODEL-BASED ENGINEERING SALES & NEGOTIATION RAPID PROTOTYPING SYSTEMS 

DESIGN VERIFICATION & VALIDATION EMBEDDED SYSTEMS FAILURE MODES & EFFECTS ANALYSIS 

 One of only a handful of people who have been integrally involved with an OEM production hybrid 

program from program inception to launch. 

 Extensive and professionally recognized engineering and business development skills in the areas of hybrid 

systems, plug-in hybrids, battery systems and controls and electronics. 

 Demonstrated project leadership and program management skills with ability to build talented teams and 

generate high customer satisfaction. 

 Proven capacity to lead large engineering teams in fast-paced product development environments and 

expeditiously deliver novel complex systems. 

 Deep technical expertise in electrical engineering and control systems with the ability to combine project 

and team management skills with technical expertise to develop and implement high quality solutions. 

PROFESSIONAL EXPERIENCE 

HYBRID CHAKRA CONSULTING, LLC. – Canton, Michigan	 May 2009-Present 

Founder and CEO 

Founded a consulting company that offered services in the hybrid vehicle, plug-in hybrid vehicle, electric vehicle 

and alternative energy domains. 

 Provided program management, systems engineering, systems architecture, modeling & analysis and 

embedded controls design consulting support to OEMs, Tier 1s, suppliers and other entities. 

 Provided independent reviews of proposals, analyses and reports created by other entities (suppliers, 

service providers) in these domains. 

 Completed projects in the area of battery system management, vehicle control system development and 

simulation analysis of hybrid system architectures. 

 Offered market/technology survey services. 

 Offered training in the areas of hybrid controls, hybrid architectures and plug-in hybrids. 

 Offered business development services in above listed domains. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

DEEPA RAMASWAMY, PH.D. 

(734) 507-9302 

http://www.hybridchakra.com deepa@hybridchakra.com 

RICARDO, INC. – Van Buren, Michigan	 July 2007-April 2009 

Chief Engineer, Hybrid Systems, Controls & Electronics 

Performed business development and engineering consulting in the domains of hybrid systems, battery systems and 

controls and electronics. With high-level contacts from over 150 companies nationwide in these fields, developed 

leads, authored proposals, conducted negotiations and led numerous projects to completion. As a result of 

exceptional performance, selected to head up the hybrid activities for Ricardo in the US. 

 Demonstrated excellent business development ability by winning $6.6 million of order intake during 

tenure. 

 Won Employee of the Month Award for managing a $5 million project and received a very high “Voice 

of the Customer” rating of 9.6/10 from the customer. 

 Recognized as a top performer and received an “Exceptional” performance review rating during annual 

performance review. 

 Identified a market need for Battery Systems development and supported development of business case for 

the establishment of a $2 million state of the art Battery Systems Development Center and organized the 

well attended Open House. 

 Authored numerous proposals in the following topics: hybrid system development, vehicle integration, 

Plug in Hybrid Electric Vehicle (PHEV) development, battery pack development, battery management 

systems, active safety control systems, PHEV market studies, model based control system design, 

electronics development, modeling , simulation of vehicles, design verification and production validation 

(DV/PV) of components and systems, Hardware in the loop (HIL) testing, dyno testing, vehicle testing. 

 Led technological aspects of proposal development for DOE Funding Opportunity Announcement on 

Transportation Electrification (DE-FOA-0000028), including partner selection and concept definition. 

 Developed workplans, established budgets, conducted negotiations with customers and executed projects to 

maximize the return to the company and to provide high value to the customer. 

 Won and led projects including the following: 

o	 Active Safety Control System development for a major automotive OEM. 

o	 Conversion of a hybrid vehicle to a PHEV for a major commercial vehicle Tier 1. 

o	 Market study of the US PHEV market for a major automotive OEM and recommendation of 

PHEV type and timing. 

o	 Training in battery technology and systems for a major commercial vehicle Tier 1. 

o	 Simulation of propulsion systems for a marine Tier 1. 

o	 Investigation of state of the art communication protocols in a Battery Management System for a 

Battery Tier 1. 

 Provided technical expertise and knowledge to support projects including the following: 

o	 Review and update of the hybrid technology decision tree on the NHTSA Notice for Proposed 

Rulemaking (NPRM) for CAFÉ standards for MY 2011-2015. 

o	 Virtual vehicle development environment for battery systems. 

o	 A Fuel Economy Demonstrator program for the military. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

DEEPA RAMASWAMY, PH.D. 

(734) 507-9302 

http://www.hybridchakra.com deepa@hybridchakra.com 

FORD MOTOR COMPANY – Dearborn, Michigan	 1995 – June 2007 

Supervisor, Research & Advanced Engineering	 2004 – June 2007 

Directly supervised a team of nine experts in the design of architecture and algorithms for next-generation hybrid 

control systems and guided the work of about 40 engineers in the department. Developed common global control 

systems across Ford, Jaguar, Land Rover and Volvo products. Ensured smooth technology transfers from advanced 

engineering to product development. Created work and resource plans to ready new technologies for 

implementation. Presented the program strategies to upper management. 

 Drove a common development process across global brands that maximized product re-use and minimized 

the resources required for product development with a projected resource reduction of 60%. 

 Proposed control system hardware architecture with maximum portability between vehicle configurations 

that allowed for easy migration across engine, transmission and brake technologies. 

 Instilled a sense of team discipline in all work by establishing clear processes, plans and deadlines; fostered 

strong relationships with production department that shifted team focus to delivering long-term solutions. 

 Recognized as Top Achiever on performance review rating; consistently received high performance 

review ratings. 

 Led development of an Integrated Modeling Environment, facilitating reuse of Legacy products and 

enabling model-based control system development, system level simulation and automatic C-code 

generation. 

Supervisor, North American Product Development	 2000 – 2004 

Promoted to lead development of the powertrain control system for the Ford Hybrid Escape SUV program. Built a 

superior team of engineers and coordinated interaction with other engineering teams and global suppliers to ensure 

timely delivery and high product quality. Managed capital, material and travel budget costs of $2 million and 

coordinated interaction with global suppliers from Japan and Europe. Analyzed impact of intellectual property 

issues. Reviewed designs, created work plans and employed multiple systems engineering tools. Supervised an 

engineering team of 17 to create specifications and design the control software for prototype vehicles. 

 Won the Henry Ford Technology Award in 2005 for leading the team that built the first production 

vehicle system controller for a U.S. automotive company. 

 Developed and launched the company’s most complex system in its vehicle lineup to control the hybrid

SUV that achieved a 50% improvement in fuel economy for a super ultra-low emissions and AT-PZEV 

rating; acknowledged with J.D. Power reviews for high quality. 

 Established six new processes for controller design and validation including the use of rapid prototyping 

that reduced development time by 70% and the use of hardware in the loop systems for design verification. 

 Formulated supplier strategies and secured the best possible quotes by negotiating statements of work with 

purchased service suppliers; identified ways to use existing resources that reduced purchase order amounts. 

 Featured as a key hybrid powertrain system supervisor in Fast Company and Global Auto Insider 

magazines. 

 Delivered a Ford First product on time that met high quality standards and allowed the company to launch a 

new product which won the 2005 North American International Auto Show Truck of the Year award. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

DEEPA RAMASWAMY, PH.D. 

(734) 507-9302 

http://www.hybridchakra.com deepa@hybridchakra.com 

Controls Engineer	 1998 – 1999 

Charged to develop the control system for the company’s first production hybrid electric vehicle. Designed high 

level programs using MATLAB and Simulink software and followed up with automatically generated C code to 

quickly test designs on actual prototypes. Pioneered the use of the dSPACE MicroAutoBox rapid prototyping 

system on a production vehicle program that significantly reduced control system development time. Transferred 

fledgling product technology from advanced research facilities smoothly into production. 

Automotive Electrical Engineer	 1995 – 1998 

Gained extensive exposure to the full spectrum of automotive engineering activities through a two-year rotation 

program. Benchmarked graphical user interface development tools. Created graphical user interfaces for engine 

simulation programs. Supported the electrical system launch for the Lincoln Continental’s 13 onboard computers.

Challenged to apply core engineering knowledge and skills by modeling several electromechanical vehicle 

components to support vehicle-level electrical simulation. 

BUSINESS EXPERTISE 

 Business Development: Identification of target markets, customer contact and lead development. 

 Proposal Development: Proposal technical writing, workplan development and resource allocation. 

 Sales and Negotiation: Review of terms and conditions, Purchase Orders (POs) and “closing the deal”

with a win-win attitude. 

 Program Management: Leading projects and managing within budgeted resources and with high 

customer satisfaction. 

TECHNICAL EXPERTISE 

 Hybrid and Battery Systems: System architecture, vehicle integration, system prototyping, development, 

verification and validation. 

 Control Systems: Algorithms, software and hardware embedded system controls for hybrids, batteries, 

powertrains and active safety. 

 Computer Modeling/Simulation: MATLAB, Simulink, C, C++, UML, UNIX, Microsoft Windows and 

Office, HTML, Saber, Modelica and Tcl/Tk. 

 Systems Engineering Tools: Requirements, design verification methods and plans, failure mode and 

effects analysis, robustness analysis, 8Ds, fishbone diagrams, fault tree analysis and design of experiments. 

PATENTS AND PUBLICATIONS 

 Received five patents with four additional patents pending. 

 Authored three SAE conference papers, one ASME conference paper, five IEEE conference papers and two 

IEEE journal publications. 

 Invited speaker at the Detroit Electrochemical Society meeting (joint meeting with Wayne State University 

COE) in November, 2010. 
 

 

 

 

 

 

DEEPA RAMASWAMY, PH.D. 

(734) 507-9302 

http://www.hybridchakra.com deepa@hybridchakra.com 

EDUCATION AND CERTIFICATION 

UNIVERSITY OF ILLINOIS AT URBANA-CHAMPAIGN Champaign, Illinois 

Doctor of Philosophy in Electrical Engineering 1995 

Master of Science in Electrical Engineering 1991 

INDIAN INSTITUTE OF TECHNOLOGY Madras, India 

Bachelor of Technology in Electrical Engineering; graduated 1st in class 1989 

FORD MOTOR COMPANY Dearborn, Michigan 

Six Sigma Greenbelt Certification 2003 

CITIZENSHIP 

U.S.
 
 

Appendix C. Peer Reviewer Comments As Submitted 

C-1
 
 

Appendix C. Peer Reviewer Comments As Submitted 

blank 

page 

B-2
 
 

 

 

 

 

 

 

 

 

 

 

 

 

U.S. Environmental Protection Agency (EPA) Peer Review 

of Draft Report, FEV 07-069-303F Dated February 22, 2011
 

“Light-Duty Technology Cost Analysis Power-split and P2 HEV Case Studies” 

Peer Review by Theodore Bohn
 

March 15, 2011
 

Overview of the Draft Report 

The “Light-Duty Technology Cost Analysis Power-split and P2 HEV Case Studies” describe FEV’s 

methodology for determining incremental, direct manufacturing costs to estimate the costs of technologies 

likely to be used in meeting future light-duty highway vehicle greenhouse gas (GHG) emissions standards. 

The methodology consists of the following approach: 

- Cost analysis of the production hardware systems was performed as follows: 

- Tear down of the production hardware systems 

- Evaluation on a part-by-part basis of observed differences in size, weight, materials, machining steps 

and other parameters affecting cost. 

- Use of databases for material costs, labor rates, manufacturing overhead rates, mark-up rates and packaging 

costs to calculate costs to fabricate individual parts and subsystems which are added together to provide 

the overall system costs. 

Following the costing methodology overview, the incremental cost impact of adding power-split hybrid electric 

vehicle (HEV) technology to a conventional baseline vehicle was discussed. The analysis is based on the detail 

teardown and costing of the hardware difference, applicable to the adaptation of power-split HEV technology, 

found between the 2010 Ford Fusion HEV, and an equivalent equipped 2010 Ford Fusion conventional 

powertrain vehicle. A description of the hardware required to create the power-split technology is highlighted 

and details on the costs are captured at various levels. 

Specific cost analysis was provided for Integrated Motor/Generator and clutch assembly system costs were 

broken out for the P2 configuration. 

The study concluded that the net incremental/assembly cost impact to the OEM was $ 3,435.01for the powersplit topology in the large vehicle segment (Ford Fusion sized chassis), and $3564.66 for the P2 configuration in 

the same size of chassis. 

This reviewer’s area of expertise concerns electric machine technology and control of electric machines as well 

as hybrid control systems. Remarks in this review are subjective and the reviewer’s knowledge of actual 

manufacturing costs vs engineering level component costs is limited to first hand procurement of prototype 

systems contrasted with cost/performance design goals for electric machines. 

1
 
 

 

 

 

 

 

 

 

 

 

 

 

In the format of the provided reviewer template, the following comments on the document are offered: 

1. Methodology/Results: 

Charge Question: Reviewer Comments: 

Is the methodology documented in the report generally • Overall, the draft document presents a generally reasonable 

reasonable and likely to yield accurate results? Is any methodology that is likely to yield accurate results. 

bias likely to be introduced to the results due to • The assumptions used for the P2 HEV system are somewhat 

methodological issues? If so, please indicate the subjective on adding the P2 functionality as an 80/20 power sharing 

direction of this bias and potential remedies. between engine and motor for peak conditions. This may introduce 

a bias in the results of the benefit vs the component cost, or in this 

case incremental costs. The assumption about engine downsizing is 

that the base vehicle and the P2 Hybrid will have equivalent 

performance with increased fuel economy. While peak 

performance is straight forward to assess for both the baseline and 

P2 Hybrid versions, the amount of engine blending, depth of 

discharge of the batteries, etc will affect the assessed fuel economy. 

• It is difficult to assess the direction of the bias (cost or 

performance/F.E. mismatch)- i.e. component sizing is cost sensitive 

and depending on the engine/motor torque blending, component 

cost may be over stated or understated based on blending 

assumptions and equivalence the to the base vehicle. 

• There is no simple remedy for this supposed bias since engine 

downsizing and component sizing are subjective based on the 

desired performance attributes to compare the hybrid version to the 

base vehicle. The assumptions made in the report (section A) are 

fair, and clearly stated. 

• As with many vehicle simulations, the component scaling 

methodologies need validation. In some industries, component 

scaling is limited to technology or performance ranges. For 

instance IGBT transistors versus MOSFET transistors are used for 

two different voltage ranges with some overlap. Even so, the 

scaling assumptions are bounded by the available voltage limit for 

the transistors. Scaling up power ratings on an inverter, or battery 

voltage have impacts on the scaled inverter costs, caused by (for 

instance) the boundary where one would use MOSFETs for lower 

voltage and IGBTs for high voltage. 

Please identify any general flaws inherent in the scope • The scope of the document is broad reaching. Expanding the scope 

of the study. Do you feel the results would be altered if of the study would likely introduce more variability with increased 

the scope were more limited or expanded? Please assumption. 

explain. • The scope does not need to be reduced since it covers many aspects 

on the cost of producing an automobile and reducing the scope 

would not necessarily increase the validity or accuracy of the study. 

Are all appropriate inputs for the study being • The scope and breadth of inputs used for the study and cost 

2
 
 

 

 

 

 

 

 

 

 

 

 

considered? Conversely, are all inputs considered in 

the study appropriate? Please cite any particular inputs 

or assumptions made by the study that you feel are 

inappropriate or likely to bias the results and how they 

could be remedied, with particular emphasis on sources 

of information used in determining labor rates, material 

prices, manufacturing burdens and other key factors. 

assessments are broad and apparently all encompassing. There are 

many input items on costs, such as labor rates and overhead on 

labor, which are outside the expertise of this reviewer. To the best 

of my knowledge, all the inputs used in this study are appropriate. 

•

Are the assumptions embedded in the model that affect • Comments in the boxes above discuss some of the bounded areas of 

projected cost or performance reasonable? Such assumptions that affect cost and/or performance, such as 

assumptions might include learning curve, economies engine/motor blending. 

of scale, scaling parameters such as weight and power, • A somewhat contentious point related to assumptions is the 

labor rates, plant scaling, and material costs. component rating system for electric machines. There is currently 

no published standard for electric machine rating methods in 

automotive applications. Peak ratings versus average versus steady 

state, as well as inlet cooling rates and losses at different operating 

points are tied up in the assumptions used to compare one electric 

machine to another after the scaling algorithm. 

• The model is very comprehensive, and according to the reviewer’s 

teleconference, the authors of this study validated many of the 

models and component scaling models. 

• To the best of this reviewer’s knowledge, the assumptions used in 

this study are reasonable. Inputs on materials cost for the study 

appear to be reasonable to this reviewer. 

Are the results expected of the study appropriate for the 

given scope, assumptions, and inputs? Are there other 

results that could be derived from the analysis that 

would support or contradict those cited by the study? Is 

appropriate validation made on the costing 

methodology and results? Please expand on any 

recommendations that you would make for analyses of 

study results. 

• Yes. The results expected of the study are reasonable given the 

scope, assumptions and inputs. 

• The net incremental cost for each of the vehicle sizes and two 

hybrid topologies seems intuitive on cost magnitude, if in fact 

performance is equivalent. 

• This reviewer cannot comment on other results that could be 

derived from the study. 

• Validation is a very subjective process with regard to the ‘level of 

validity’. After reading the study description, and listening to the 

authors during the reviewer’s teleconference where the validation 

process was described, it appears that reasonable validation was 

achieved on the costing results. 

Is the approach used in scaling the cost of power-split 

technology to other vehicle classes appropriate and 

likely to yield accurate results? Is the methodology for 

using the cost of power-split components in other 

hybrid technologies appropriate and likely to yield 

accurate results? 

• The approach used in scaling cost of the powersplit technology to 

other vehicle classes appears reasonable and shows no reason that it 

may be not accurate. The actual numbers placed into the scaling 

routines may be off, and result in turn may be off, but the approach 

is reasonable. 

• The methodology for using power-split component costs in other 

hybrid technologies is reasonably and appropriate since several 

components are common, but scaled. As mentioned above, there 

are currently no published electric machine rating standards for 

automotive applications. The electric machine in the P2 topology 

3
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

has (or likely may have) a different load profile than that used for 

the power-split topology where engine power is split through the 

two electric machines instead of just one in the P2. To that point 

using the normalized cost of the electric machines ($/peak watt) 

from the power-split in the P2 topology is reasonable, but the 

machine rating/sizing may not directly translate. The battery costs 

will be equivalent between the two on peak power/energy, scaled as 

described in the report. 

2. Editorial content: 

Charge Question: Reviewer Comments: 

Is sufficient detail provided in the body for a reader 

familiar with the subject report to understand the 

process and conclusions? Are appropriate appendices 

included? Please specify any specific content that you 

recommended be added or removed. 

• The report is sufficiently detailed for a reader familiar with the 

subject report to understand the process and conclusions. Each of 

the sections provides a very detailed, pedagogical approach on the 

rationale of systems and subsystem functions, components and 

assessed costs. 

• The tables inserted in the report are, of necessity, very small font 

with many values in a small area making it somewhat difficult to 

read in 8.5” x 11” printed format. The electronic format was easier 

to read and understand, zooming in on one column at a time. No 

change is needed for this in the report format, but possibly extracted 

column highlighting significant results would add clarity. A great 

deal of effort was expended to produce this space efficient report in 

a readable number of pages (sufficient detail without being too 

long.) 

• The appendices are appropriate. The cost model template is 

sufficient for the appendix. 

Please comment on any editorial issues that should be 

addressed in the report, including any comments on 

general organization, pagination, or grammar and 

wording. 

• There is a divergence in the electrical engineering world on the 

proper use of the term for electrical distribution ‘omnibus’. The 

classic spelling of the word has only one ‘s’ as in ‘bus’. The other 

spelling is also accepted as ‘buss’. There is no direct reference to 

point of divergence since the word ‘electrical bus’ was first used. 

No action required, just pointing out that there are two accepted 

spellings, the first coming from the origin of the word ‘omnibus’. 

The link below shows a survey of the percentage of respondents on 

their preference/where they were educated. 

• http://www.gearslutz.com/board/so-much-gear-so-little-time/15867­

buss-bus-where-you-learned-3.html 

• Pagination and grammar in general are very consistent and 

acceptable. 

4
 
 

 

 

 

No independent data analysis will be required for this review. Instead, EPA is seeking the reviewer’s expert 

opinion on the methodologies and cost results of this study, and whether they are likely to yield an accurate 

assessment of the true cost of the technology. We ask that each reviewer comment on all aspects of the report. 

Please organize all responses according to the charge questions for each of the two categories listed below. 

In preparing comments, please distinguish between recommendations for clearly defined improvements that can 

be readily made, based on data or literature reasonably available to EPA, and improvements that are more 

exploratory or dependent, which would be based on information not readily available to EPA. Comments 

should be clear and specific enough to EPA readers or other parties familiar with the report to allow a thorough 

understanding of the comment’s relevance to material provided for review. 

Additionally, EPA requests that the reviewers not release the peer review materials or their comments until the 

Agency makes its report/cost model and supporting documentation public. EPA will notify the reviewers when 

this occurs. 

If the reviewer has questions about what is required in order to complete this review or needs additional 

background material, please contact Susan Blaine at ICF International (SBlaine@icfi.com or 703-225-2471). If 

the reviewer has any questions about the EPA peer review process itself, please contact Ms. Ruth Schenk in 

EPA’s Quality Office, National Vehicle and Fuel Emissions Laboratory (schenk.ruth@epa.gov or 734-214­

4017). 

5
 
 

 

 

 

 

 

 

 

 

Peer Reviewer Report 

Preamble 

Accurate calculation of the cost of new technology is very important to EPA since 

it needs to relate it to fuel consumption reductions. The recent history of these efforts is 

summarized in three reports123 . Until recently the approach was to ask OEMs and 

suppliers the cost of technologies and by taking several samples and probing to create 

reasonable estimates of the cost to manufacture. This approach was taken in reference 1 

and also by an NRC Committee to study an “Assessment of Technologies for Improving 

Light-Duty Vehicle Fuel Economy”4. 

I was a member of this committee and during our discussions we thought that a 

better approach would be to take apart the components of a new technology and analyze 

how much each component would cost. Such an approach would include no only the cost 

of labor and materials but all other “manufacturing” costs. Reference 2 and 3 are 

examples of such an approach and deal with vehicles with conventional power trains and, 

in my view, confirm the accuracy of the process. 

The present report deals with hybrids and my evaluation will deal with the report 

as it calculates manufacturing costs. Of course in evaluating new technology EPA is 

charged to estimate not the manufacturing cost but the cost to the consumer to determine 

the cost to the consumer. Traditionally this was done using the so called Retail Price 

Equivalent (RPE) factor. The present report uses a factor called Indirect Cost (IC) 

multiplier. Establishing the multiplier is a highly controversial process and an EPA’s 

attempt is given in5

. The controversy as discussed in reference 4 is that EPA tends to 

come up with a small factor and OEM’s with a larger one. Also OEMs insist that a 

different factor should be used for technologies bought from suppliers and technologies 

manufacturer in house. Since the present report does not address this issue, I will limit 

my remarks to the estimation of the “manufacturing” costs as described. However since 

the EPA will use this factor in its regulatory process, the end result will likely 

underestimate the final cost to the consumer 

Detailed comments 

Methodology/Results: 

Section a. Is the methodology documented in the report generally reasonable and likely 

to yield accurate results? Is any bias likely to be introduced to the results due to 

methodological issues? If so, please indicate the direction of this bias and potential 

remedies. 

The methodology is clearly correct and could lead to correct results. As stated 

above, I am familiar with the approach because it was discussed during the NRC 

1 EPA420-R-08-008 March 2008 

2 EPA-420-R-10-010 April 2010 

3 EPA-420-R-09-020 December 2009 

4 http://www8.nationalacademies.org/cp/CommitteeView.aspx?key=48843 

5 EPA-420-R-09-003 February 2009 

Jacovides Page 1 3/24/2011 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

committee on “Improving the Fuel Economy of LDV” and in the references listed earlier. 

The report, under review, represents a superb implementation of the concept. 

The analysis of the Ford Hybrid and cost comparisons with its ICE equivalent is 

done very carefully and correctly without any bias that I can detect. Interestingly the 

increase in cost of $3435 that this report comes up with is almost identical to the one we 

came up for the Prius in the NRC study of $3385. We did that by talking to OEM’s and 

suppliers. However I want to emphasize that the approach taken by this report is far 

superior. As long as a detailed design or an actual vehicle is available this is the way to 

do it. It does require a great deal of industrial engineering skill to estimate the amount of 

labor, and cost of materials but in the hands of FEV this has produced excellent results. 

It should be pointed out that the methodology is limited to the two architectures 

studied viz. split power hybrids as implemented by Toyota and Ford and to a limited 

extend on the P2 architecture as implemented by Hyundai. I say limited since there was 

no design available for the electrical machine in this case. The battery for the P2 was 

properly analyzed by tear down of an actual unit. Nevertheless the analysis can be 

extended to other hybrids such as the two types made by GM (two mode and the Malibu 

ISG) and the Honda Insight 

Section b. Please identify any general flaws inherent in the scope of the study. Do you 

feel the results would be altered if the scope were more limited or expanded? Please 

explain. 

The results of this study cannot properly be evaluated without knowledge of what 

EPA considers the IC factor to be. I realize that this is not in the scope of the report. 

However IC factors range from 1.02 to 1.45 as stated in reference 5. Industry RPE 

factors were estimated in Reference 4 to be 1.5 or 2.0 depending on whether parts were 

bought or made in house. One can calculate manufacturing costs to the penny but then 

the end result can vary by a factor of up to two depending on the multiplier 

The results for the P2 may be directionally correct, but I am concerned about the 

sizing of the power electronics and the electrical machine. FEV should have bought a 

Honda Insight (IMA), available in the US in the spring of 2010, or a GM Malibu (ISG) 

for a tear down of the electrical system (Power electronics and machine). The duty cycle 

of the electrical system is very different than that of the power split and so the ratios of 

copper to iron to magnets will likely be different. Also it seems from Table F2 that the 

electrical machine was sized based on power. As discussed below torque and duty cycle 

are the primary determinants of size and hence cost. It should be pointed out that P2 has 

a clutch which provides two features that the Insight and the Malibu do not have. The 

clutch can disconnect the engine so that regenerative braking does not have to be reduced 

to provide for engine friction and can provide an all electric range (AER). The 32.4kW 

power of the electrical machine will not provide the required torque and power. There 

should be a statement to the effect that the P2 is not designed to provide an AER 

Another problem is the assumption of a 20% vehicle curb weight reduction for 

the P2 architecture and for all vehicle segments. Such a reduction does not come 

for free and I found no rationale for this. In reference 4 we found that a 10% 

reduction in a 3600 lbs vehicle would add around $700. During the conference 

call it was implied that the P2 electrical systems is lighter. This may not be so and 

certainly not by 20%. The speed of the P2 electrical machine is not an 

Jacovides Page 2 3/24/2011 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

independent variable and it is much lower than the speeds of the two power split 

machines. The size of electrical machines is determined by torque and not power 

and so a slower speed machine will be heavier. Clearly getting an Insight or a 

Malibu would have given a better estimate. 

Another flaw of the study is that it depends on the ability of the people using the 

study to turn the crank for other vehicles or for vehicles without the detail provided by a 

teardown. Clearly FEV has demonstrated that it is developing that knowledge, although I 

am not sure about the accuracy of the electrical systems numbers for the P2. The 

question then becomes “will EPA need FEV in the future in order to use this work”. 

Based on the conference call with EPA, FEV and the Reviewers, this study will not be 

used for other architectures so the above point is moot. However I would like to caution 

that any extension to other architectures needs to be done by skilled manufacturing 

engineers and cost analysts. 

Section c. Are all appropriate inputs for the study being considered? Conversely, are all 

inputs considered in the study appropriate? Please cite any particular inputs or 

assumptions made by the study that you feel are inappropriate or likely to bias the results 

and how they could be remedied, with particular emphasis on sources of information used 

in determining labor rates, material prices, manufacturing burdens and other key factors. 

When it comes to the main part of the report i.e. the comparison between a hybrid 

and an ICE Fusion everything seems to be done very well. Possible exceptions are in 

estimating the following costs 

1.	 Development of control software. 

2.	 Integration of the electrical and mechanical parts. 

3.	 Calibration. Hybrid vehicles are more complex and to make performance 

transparent to the driver is expensive. Safety also requires extensive calibration. 

Toyota has recalled the 2010 Prius to fix software when braking on ice on bumpy 

roads. If this can happen to Toyota with 10 years experience on hybrids, it must 

be taken seriously. 

These are upfront engineering costs and by the time production volume has reached 450k 

units may not be significant. However they need to be added to the cost of the vehicle. 

Section d. Are the assumptions embedded in the model that affect projected cost or 

performance reasonable? Such assumptions might include learning curve, economies of 

scale, scaling parameters such as weight and power, labor rates, plant scaling, and 

material costs. 

These seem to me to be appropriate. A problem will arise with the next person 

who runs the model. Will they have the expertise of FEV, which I think is one of the 

premier automotive engineering firms? 

Section e. Are the results expected of the study appropriate for the given scope, 

assumptions, and inputs? Are there other results that could be derived from the analysis 

that would support or contradict those cited by the study? Is appropriate validation made 

on the costing methodology and results? Please expand on any recommendations that you 

would make for analyses of study results. 

Jacovides	 Page 3 3/24/2011 
 

 

 

 

 

 

 

 

 

 

 

 

The results are reasonable, not only because the actual number is the same as we 

got in our study but because the costs are estimated with great detail. I am aware of one 

other company that has used this approach to come up with detailed costs of automotive 

components6. However I am not aware of any similar results for hybrids. 

I realize that you cannot publish confidential information that you obtain from 

OEM’s, but I think it would be useful to show the results to Ford and Toyota before 

making the report public. They are much more likely to find errors than the review panel 

and it may prevent any arguments after the report is made public. I understand that this a 

policy matter, but getting their input seems reasonable to me 

Section f. Is the approach used in scaling the cost of power-split technology to other 

vehicle classes appropriate and likely to yield accurate results?, Is the methodology for 

using the cost of power-split components in other hybrid technologies appropriate and 

likely to yield accurate results? 

Scaling for a vehicle with identical architecture but with higher power is not as 

simple as it appears. Results are given on page 132 (pdf)7 for the HVAC system where 

the fixed cost of the electronics is, correctly, taken out. However the compressor cost 

appears to be scaled as the power. This is not correct since the material may indeed be 

scaled as the power but the labor is not. 

Similarly the cost of the electrical machines should not be scaled as power. As 

stated above scaling for the P2 should be made on the basis of torque and duty cycle. I 

understand that two designs were made for a 30kW generator and for a 60kW motor. It 

was said during the conference call that using these designs the data were extrapolated for 

different size vehicle. This can only be done if the motor and generator have identical 

torque and duty cycle profiles. This is highly unlikely and so someone with electrical 

machine design experience needs to develop parametric results for the motor and 

generator separately. Also as stated above one cannot use power for scaling a slow speed 

machine used for the P2 

The NiMH battery scaling is done correctly. A possible weakness is that as an 

alternative to reducing the number of cells to estimate a smaller system, one may choose 

to use a larger number of smaller cells. Regarding the electrical machines and the 

compressor I suggest that a separate small study be undertaken to determine the scaling 

factor. I suspect it will be between two extremes, .a) scale as power and b) scale material 

as power and leave labor and overhead the same. Things get even more complex if a 

different architecture is used. The approach used here for the P2 architecture is 

directionally correct but the results will not have the accuracy that the Ford Fusion 

comparison has with its ICE counterpart. 

The treatment of the Li-ion battery (LIB) raises a number of questions 

1.	 What is the available energy? Typically the SOC variation is limited in 

order to obtain life. For hybrids like the Prius the swing is from about 

50% to 60%. The GM Volt battery swing is 30 to 80%. Scaling the LIB 

to the same nominal kWh assumes that the life of the LIB will be 

comparable. Some discussion is needed that the life will not be 

6 Intellicosting LLC, 980 Chicago Road, Troy, MI 48083-4226 

7 Page numbers refer to the pdf not the pages in the report 

Jacovides	 Page 4 3/24/2011 
 

 

 

 

 

 

 

 

 

 

 

 

compromised 

2.	 It is not clear what size battery is costed for the P2. Page 126 (pdf) states 

that the battery from the Avante is 0.954 kWh and this battery was costed 

on table D13 at $1399. Increasing the energy by 270/180 and scaling the 

costs as energy the P2 battery should cost $2098. Please explain whether 

the cost of the P2 battery is $1399, $1798 or $2098. To add to my 

confusion table F2 shows a battery of 0.9117 kWh for the mid large 

(Fusion size vehicle). Also table A4 shows $1690.43 for the High Voltage 

Traction Battery Subsystem. I am sure I am missing something but it 

needs to be clarified for the reader 

3.	 The estimated cost of the cells given in D-13 for a 0.954 kWh battery of 

$1020 seems reasonable at roughly 1000 $/kWh 

Editorial content: 

Section a Is sufficient detail provided in the body for a reader familiar with the subject 

report to understand the process and conclusions? Are appropriate appendices included? 

Please specify any specific content that you recommended be added or removed. 

I would like to see a clear definition of what is assumed to be the Indirect cost 

(IC). Is everything not included in Step 7 MAQS on page 21 assumed to be covered by 

IC? I realize that assigning an IC factor is beyond the scope of this report but it should be 

made clear what is included. Also it should be made clear that no allowance was made 

for a different IC factor for parts sold by suppliers and made by the OEM’s. 

A minor editorial point deals with Page 10 figure A1. I would clarify the 

planetary gear set by showing ring, planets and sun clearly. Also remove the gap 

between the differential to show that the two gears mesh. Further label the output of the 

differential as going to vehicle wheels not coming from the wheels 

Page 9 makes a good point up front ...based on current automotive and/or

surrogate industry manufacturing operations and processes, it is 

acknowledged that a reduction to the costs presented is very likely

based on both product and manufacturing learning. Projected technology

cost reductions, as a result of learning, are not covered as part of

this analysis.

Page 21.Item #8, Market Place Crosscheck, is a good idea but needs further 

explanation and the report should show results. Comparison with FEV in house experts 

seems less than satisfactory. 

Page 37 uses labor rates from BLS. Since lithium ion batteries are not made in 

the US it would be good to say what labor rate was used for the Li-ion battery. Some of 

the operations need to be made in low grade clean room 

I would be interested to find out how the electrical machines are cooled for the 

split power. Oil cooling is used for the P2 and coolant fluid is used for the power 

electronics but I doubt that coolant was used for direct cooling of the motor and 

generators 

Section b. Please comment on any editorial issues that should be addressed in the 

Jacovides	 Page 5 3/24/2011 
 

 

 

 

 

 

 

 

 

 

report, including any comments on general organization, pagination, or grammar and 

wording. 

No comments- everything seems very well done 

Section c. In preparing comments, please distinguish between recommendations for 

clearly defined improvements that can be readily made, based on data or literature 

reasonably available to EPA, and improvements that are more exploratory or dependent, 

which would be based on information not readily available to EPA. Comments should be 

clear and detailed enough to EPA readers or other parties familiar with the report to allow 

a thorough understanding of the comment's relevance to material provided for review. 

Suggestions for next steps 

Here are some unsolicited improvements and possible next steps: 

1.	 As discussed above under f) have small study made on how to scale electrical 

machines and the compressor to distinguish between scalable and fixed costs. 

2.	 It would be good to check with Ford as to the accuracy of the results. Although 

their volume is not up to 450k they should be able to give you an estimate. For 

comparing the P2 costs check with Honda or GM, which produce similar 

architectures although, without a clutch between the engine and transmission. 

More problematic will be a check with the GM on their two mode hybrids. They 

have higher power and one additional gear, but they seem to be much more 

expensive. As I said earlier the numbers check with the Prius that we studied, but 

we were puzzled by the GM figures. Although the Fusion is bigger the Prius data 

are a couple of years old and Toyota had not reached the 450k volume. 

3.	 I would use the scaling exercise for the Volt and the Leaf. These are much 

different vehicles but have components that have been included in this study. 

Then check with GM and Nissan on costs. 

Respectfully submitted 

Linos J. Jacovides 

Director of the Delphi Research Labs (Retired) 

154 Touraine Rd 

Grosse Pointe Farms 

Michigan 48236 

Jacovides	 Page 6 3/24/2011 
 

 

 

 

 

 

 

 

 

 

 

 

 

U. S. Environmental Protection Agency (EPA) Peer Review 

Draft Report: FEV07-069-303F Dated 2/22/2011
 

Title: Light-Duty Technology Cost Analysis Power-split and P2 HEV
 

Case Studies
 

Reviewer: Linda M. Miller 

Review Date: March 14, 2011 

To facilitate use of this review, I will first provide some general observations and 

recommendations. More detail will be provided in the sections of this review that 

are organized in alignment with the topics and questions in the Peer Review Charge. 

General Observations: 

•	 It is clear that a great deal of detail and effort has gone into FEV‘s analysis 

and preparation of the report. 

•	 The use of vehicle/component teardowns is an integral part of the analysis 

and recognized by the industry as an excellent means of cost analysis. 

Likewise, the development of detailed process flow charts used in the detailed 

costing is a well accepted practice. 

•	 The report analysis relies heavily on a number of data bases and models that 

are necessarily quite complex. However, validity testing of the Munro & 

Associates software which is fundamental to the development of the cost 

estimates is not documented. Additionally, tests that have been performed to 

validate the FEV data bases and the costing algorithms are not included. 

Recommendation: Since these data bases are integral to the study, include the 

detailed methodology, including worked examples, used to validate these data 

bases. Hypothesis testing of assumptions concerning burden rates, product 

maturity, etc. and sensitivity analysis to demonstrate correlation to actual 

component costs should be a part of the study. It is recognized that providing all 

the supporting detail in a paper of this magnitude would be excessive. However, 

a link to the data could be included similar to the one for OTAQ documents (page 

126). If the data is considered proprietary, then examples tracing both a simple 

and a complex component/assembly through the process demonstrating how the 

various costs were derived should be included in an Appendix or as a separate 

document. 

•	 The process for defining and apportioning manufacturing burden costs such 

as front office salaries down to a single machine on the plant floor is 

questionable. 

Recommendation: It would be more acceptable to apply the developed burden 

rates at a manufacturing process/component level. 

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Comments by Charge Question: 

1. Methodology/Results 

Question: 

Is the methodology documented in the report generally reasonable and likely to 

yield accurate results? Is any bias likely to be introduced to the results due to 

methodological issues? If so, please indicate the direction of this bias and potential 

remedies. 

Response: 

•	 While the methodologies, for the most part, appear reasonable, there are 

some areas of concern. 

o	 There is a lack of documentation in the paper proving that the 

methodologies yield accurate results. While the paper references 

marketplace validation, no examples are given. 

Recommendation: Include examples taking developed costs for 

items such as fuel injector assemblies(Figure C-3, page 45, Sample 

MAQS Costing Worksheet); extrapolating these to a total cost using 

the approach outlined in the paper; and then comparing these costs 

to actual marketplace pricing for the example used. One or two 

worked examples of this nature would help to validate the overall 

methodology. Alternatively, include a table, detailed by component/ 

sub-assembly, showing the methodologies and comparisons used 

for costing each item. 

o	 The costing methodology, as presented, develops costs that are 

absolute. Given the complex nature of the end product and the 

manufacturing processes, it would have been appropriate to include 

sensitivity analysis in the costing detail. If sensitivity analysis has been 

performed on a sampling of costs, it is not shown in the paper. 

Recommendation: Assuming sensitivity analysis is available, show 

the impact of sensitivity analysis in the examples in the paper. If 

sensitivity analysis has not been performed, then this is an area of 

detail that needs to be completed. From a manufacturing 

perspective, sensitivity analysis on high dollar components needs to 

include scrap rates, mean time to repair of equipment, equipment 

uptime, etc. 

o	 The scaling methodology appears to be overly simplified. For example, 

scaling factors are applied to labor and manufacturing overhead. The 

cost of direct labor is more a factor of part complexity than one of size. 

Also, certain elements of overhead cost such as salaries and front 

office costs are not impacted, or at most minimally, by part size. 

2 
 

 

 

 

 

 

 

 

Recommendation: A deeper review of the approach to scaling 

needs to be undertaken to insure that costs are not under/overstated. Again, applying sensitivity tests may help determine whether 

or not these differences are significant. 

Without the documentation noted above, it is not possible to say whether or not 

bias has been created. 

Question:
 

Please identify any general flaws inherent in the scope of the study. Do you feel the
 

results would be altered if the scope were more limited or expanded? Please 

explain.
 

Response:
 

I do not see any general flaws inherent in the scope of the study. Extrapolation to 

other vehicle sizes could not be done without the basic underlying detailed studies.
 

However, once the component costs had been developed for the Fusion, the 

justification for the extensive use of scaling factors to approximate these costs for
 

other vehicle lines does not have the same level of detail as the rest of the study. 

Whether or not this has been impacted by the scope of the project can not be 

determined.
 

Recommendation: Review the application of scaling factors, especially for 

manufacturing cost and burden. The methodology described in the paper yields a 

result that should be considered as one end of a range estimate. The other end of 

the estimate should be developed by applying scaling factors to material cost and 

investment in equipment and holding the other costs constant. If it is necessary to 

state an absolute cost, the pick a middle ground between these two numbers based 

on expert opinion. 

Question: 

Are all appropriate inputs for the study being considered? Conversely, are all inputs 

considered in the study appropriate? Please cite any particular inputs or 

assumptions made by the study that you feel are inappropriate or likely to bias the 

results and how they could be remedied, with particular emphasis on sources of 

information used in determining labor rates, material prices, manufacturing burdens 

and other key factors. 

Response: 

Although, as explained in the conference call on March 8, 2011, it is EPA policy to 

perform studies of this nature independent of the OEM’s, it would have seemed 

appropriate to seek validation of the teardown costing from the manufacturer whose 

vehicle is the basis for this analysis. For a review of other assumptions that are of 

concern, see the response to the next Question. 

3 
 

 

 

 

 

 

 

 

 

 

Question:
 

Are the assumptions embedded in the model that affect projected cost or
 

performance reasonable? Such assumptions might include learning curve,
 

economies of scale, scaling parameters such as weight and power, labor rates,
 

plant scaling, and material costs.
 

Response:
 

While the majority of assumptions cited in the study are valid, there are a number of
 

assumptions that need to be re-considered. They are as follows:
 

•	 The technologies used are considered to be mature. It is more likely that the 

technology will continue to evolve requiring changes to manufacturing 

facilities and tooling. The assumption of maturity, for example, impacts a 

number of underlying cost elements and other assumptions: there are 

assumed to be no allowances for product/manufacturing learning, scrap rates 

are minimal, non-recovered E,D&T expense and capital costs are zero, and 

there are no allowances for equipment end of life costs. All of these stem 

from the assumption of maturity. At the same time, however, it is assumed that 

no new or modified equipment maintenance is required (See pages 16 & 17). 

This is not consistent with equipment at the end of its life cycle. All of the 

above will cause cost estimates to be understated. 

Recommendation: Review the costs impacted by the assumption of maturity. 

Uplift costs by a percentage factor where appropriate. If the assumption 

remains that equipment will be at the end of its useful life, then increase 

maintenance costs over time according to the equipment OEM’s guidelines. 

•	 It is assumed that “integration of new technology would be planned and 

phased in to minimize non-recoverable expenses”. This would indeed be the 

most cost effective decision. However, given the significant requirements for 

fuel economy improvements and emissions reductions, the need to implement 

new technology will likely be the over-riding consideration. 

Recommendation: Perform cost sensitivity analyses with non-recovered E,D&T 

and stranded capital in percent increments ranging from 10 to 30 %. Include the 

results in the paper. 

•	 End-item scrap includes quality defects, rework costs, and/or destructive test 

parts (page 29). The general mark-up varies from 0.3% to 0.7% depending on 

part complexity and size (page40, Table C-1). However, it is stated that 

exceptions are made depending on the part. Examples cited in Section 

C.4.5.2 include sand and investment casting. These are considered to be 

“generic” processes and the end-item scrap mark-up is uplifted to 5% in both 

cases. However, just as in Table C-1, this rate needs to vary dependent upon 

the part size and part complexity (I am assuming tolerance limits are 

considered part of part complexity. If not, tolerances need to be considered 

as another factor in determining scrap rates.) Without a part by part review of 

the assumptions, the impact to the cost analysis can not be determined. 

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Recommendation: To test the reasonableness of the scrap percentages, check 

a random sample of components and compare the end-item scrap rates for 

those processes to industry standards. Use complexity and size of the parts to 

adjust averaged rates. 

•	 All sourcing/manufacturing centers are assumed to be in the United States. 

As discussed in the March 8, 2011 conference call, this is not a valid 

assumption and can significantly impact cost either negatively or positively. 

Recommendation: Review present sourcing patterns, at least for the high cost 

components and sub-assemblies, and utilize these patterns as the basis for the 

cost analysis. 

•	 Labor Rates MAQS Costing Worksheet Example (page 46). It can not be 

determined whether or not any overtime costs were assumed in the labor 

cost/hour calculation. Overtime costs will vary manufacturer to manufacturer 

based on Union agreements and/or operating practices. However, in a 

number of cases (Ford Motor Company for one), shifts of 10 hours per day in 

the United States would generally include 2 hours of overtime pay. Afternoon 

shift also has an associated premium cost. 

Recommendation: Verify underlying assumptions in the labor rate models. 

•	 Packaging Assumptions: Based on the sample calculation (page 50, Figure C6), allowances for a percentage of pallets/racks out for cleaning and/or repair 

(generally around 5%) have not been included. This understates the 

packaging cost. 

Recommendation: Increase the # of packaging units required by 5% where 

returnable packaging is used. 

•	 Cost of Complexity Assumptions: Based on the volume assumption of 450K 

per year, although it is not stated in the report, it is assumed that the major 

complex assemblies: Engine and Transmission as well as Complex 

Subsystems are produced on dedicated lines. If not, then a cost of complexity 

factor needs to be added. The 75% combined utilization/efficiency 

assumption (calculated based on page 37) is reasonable. However, if hybrid 

components are assembled on the same lines as the baseline products, then 

this utilization/efficiency is over-stated due to the inherent inefficiencies 

caused by manufacturing complexity. Note: It should be assumed that hybrid 

and base vehicles will be assembled on the same line and so this added 

complexity must be factored into the utilization/efficiency calculation. 

Recommendation: Process flow diagrams for complex base-line vehicle 

assemblies/components should be compared to those developed for HEV vehicle 

5 
 

 

 

 

 

 

 

 

 

 

 

 

 

and adjustments made to the efficiency/utilization percents for HEV based on this 

comparison. 

•	 System Scaling Cost Analysis: While the use of ratios to develop sizing for 

HEV components such as traction motors, high traction batteries, etc. is 

appropriate and can be used to estimate material costs, the use of these 

ratios to determine other factors within manufacturing cost such as labor 

(page 126) is less valid. Part complexity influences these costs more than 

part size. The same concerns exist with establishing component costs for P2 

HEV powertrain components using manufacturing cost to component size 

ratios (page 127). 

Recommendations: 

•	 Re-evaluate the assumptions around use of a scaling factor to better define 

those costs which are scalable and those which are not. 

•	 Assuming the validity of the approach to costing using manufacturing cost to 

component size ratios, provide background data supporting this assumption. 

•	 As outlined above. review the application of scaling factors, especially for 

manufacturing cost and burden. The methodology described in the paper 

yields a result that should be considered as one end of a range estimate. The 

other end of the estimate should be developed by applying scaling factors to 

material cost and investment in equipment and holding the other costs 

constant. If it is necessary to state an absolute cost, the pick a middle ground 

between these two numbers based on expert opinion. 

Question: Are the results expected of the study appropriate for the given scope, 

assumptions, and inputs? Are there other results that could be derived from the 

analysis that would support or contradict those cited by the study? Is appropriate 

validation made on the costing methodology and results? Please expand on any 

recommendations that you would make for analyses of study results. 

Response: At best, the levels of assumptions that are made in a study of this 

magnitude provide costs that are directionally correct. During the conference call 

on March 8, 2011, it was stated that the study commissioned was for absolute costs 

as opposed to range estimates. However, this gives the study results more 

credence than the assumptions can support. It was also stated, in the same 

conference call, that a manufacturer had been asked to provide costs for one 

component and that the cost differential to that developed in this study was 5%. 

This further supports the concern with reporting the cost results of the analysis as 

absolutes. 

Concerns regarding validation have been stated consistently throughout this 

review. Teardown analysis, development of process flow diagrams, analysis of 

comparable parts where available, etc., are excellent methodologies. However, a 

number of assumptions have gone into the methodology used to develop the 

6 
 

 

 

 

 

 

 

 

 

 

manufacturing costs from these process flow diagrams and the validation of these 

assumptions are not documented in this paper. Of particular concern are the 

assumptions around sourcing (directed by the EPA), product maturity, development 

of burden rates by piece of equipment, direct labor cost calculations and the 

application of component size ratios as the primary scaling factor for manufacturing 

cost in other vehicle applications. 

Recommendations: 

•	 For those components/ assemblies which most impact vehicle cost, provide 

range estimates. Without looking at more detail, a proposal for these ranges 

can not be made. However, the cost developers for this study should be able 

to provide such ranges as are appropriate based on sensitivity testing. 

•	 Where components are most likely to be sourced outside the United States, 

costs need to be adjusted for sourcing pattern. The sourcing pattern may be 

a cost reduction or cost increase dependent upon a number of factors. 

•	 In the direct labor calculation of the mean manufacturing labor wage for a 

component or assembly (page 32), it is unclear whether or not the various 

labor wage rates are weighted by the calculated number of employees in that 

classification to obtain a weighted average. If this has not been done, direct 

labor costs need to be re-evaluated. There are significant wage differentials 

between the various classifications with general assembler being the lowest 

paid. (The same applies to the indirect labor costs.) 

Question: Is the approach used in scaling the cost of power-split technology to 

other vehicle classes appropriate and likely to yield accurate results? Is the 

methodology for using the cost of power-split components in other hybrid 

technologies appropriate and likely to yield accurate results? 

Response: 

•	 The use of ratios to develop sizing for HEV components such as traction 

motors, high traction batteries, etc. as described in the paper is appropriate 

and can be used effectively to estimate material costs and investment in 

equipment. 

•	 Concerns with using the size ratio scaling methodology for certain other cost 

estimates is documented in other sections of the response. For convenience, 

they are repeated here: 

o	 Certain elements of overhead cost such as salaries and front office 

costs are not impacted, or at most minimally, by part size. 

o	 Direct labor costs are more closely tied to part complexity than to part 

size. 

7 
 

 

 

 

 

 

 

o	 While part size will impact certain areas of indirect labor, such as 

material handlers, it will have a lesser impact on number of supervisors, 

quality inspectors, etc. Like direct labor, these numbers are more 

closely tied topart complexity than size. 

o	 The same concerns exist with establishing component costs for the P2 

HEV powertrain components using manufacturing cost to component 

size ratios (page 127). 

•	 The issues addressed above regarding scaling methodology apply equally to 

the P2 manufacturing cost calculations. 

Recommendations: 

•	 Re-evaluate the assumptions around use of a scaling factor to better define 

those costs which are scalable and those which are not. 

•	 Assuming the validity of the approach to costing using manufacturing cost to 

component size ratios, provide background data supporting this assumption. 

•	 As outlined above, review the application of scaling factors, especially for 

manufacturing cost and burden. The methodology described in the paper 

yields a result that should be considered as one end of a range estimate. The 

other end of the estimate should be developed by applying scaling factors to 

material cost and investment in equipment and holding the other costs 

constant. If it is necessary to state an absolute cost, the pick a middle ground 

between these two numbers based on expert opinion. 

2.	 Editorial Content 

Question: Is sufficient detail provided in the body for a reader familiar with the 

subject report to understand the process and conclusions? Are appropriate 

appendices included? Please specify any specific content that you recommended 

be added or removed. 

Response: Although a substantial amount of detail is included, there are a number 

of things that should be added to the report to substantiate the process and 

conclusions. As outlined in a number of questions above, these details are 

necessary to validate the processes and underlying assumptions used to arrive at 

the cost conclusions. These details include: 

•	 Validation of the Munro & Associates software including methodology and 

results 

•	 Validation and sensitivity testing (or results of the testing) of the FEV cost 

algorithms 

•	 Specific examples where validation testing has been done through 

marketplace analysis. These examples must show the FEV derived cost and 

the actual marketplace cost. 

8 
 

 

 

 

 

 

 

 

 

•	 A worked example showing the detail behind each number in the MAQS
 

costing sheet.
 

•	 Sensitivity analysis for a sampling of the components and assemblies in the 

cost analysis. 

•	 Data supporting the assumption that manufacturing costs can be calculated 

as a ratio of component size. 

• Clarification of the calculations for direct labor cost. 

With the exception of the last item, all of the appropriate documentation should be 

provided as appendices or as links to other papers/detailed analytical data. 

Question: Please comment on any editorial issues that should be addressed in the 

report, including any comments on general organization, pagination, or grammar 

and wording. 

Response: The general organization of the paper is clear. The following are areas 

where typographical errors or other editorial issues exist: 

•	 Page 16—Item 2 net to the last line. “Develop” should read “Development” 

•	 Page 35—next to the last paragraph references a template in Appendix E.4. 

This Appendix could not be found in my copy of the paper. This may just be a 

labeling error, but none of the pages in the appendix appeared to be the 

template referenced. 

•	 Page 42—Next to the last paragraph, 2cnd sentence. FOB (freight on board) 

is usually designated as FOB, destination—supplier pays the shipping costs or 

FOB Factory—customer takes control of the product and pays the shipping 

cost. Note that in Europe, FOB is always referred to as “Free on Board”. 

Assuming you mean the receiving company pays the freight, the more 

common term would be FOB Factory. 

This concludes my review. 

Respectfully submitted, 

Linda M. Miller 

9 
 

 

Review of Draft Report “Light Duty Technology Cost Analysis, Power Split 

and P2 HEV Case Studies, dated March 10th , 2011” 

By
 

Deepa Ramaswamy, Ph.D.,
 

Hybrid Chakra Consulting, LLC
 

This report contains the review of the draft report listed above. It

begins with a response to the specific charge questions from ICF. The first 

part of the report contains responses to the charge questions, and these 

are listed in Table 1 and Table 2. The next part of the report lists

additional review comments in certain specific categories. 

In general, FEV and Munro are to be commended for the detail that they have 

shown in this approach to determining hybrid system cost. The use of linked

MAQS worksheets that allow the component costs to be rolled up to subsystem 

and system costs is a powerful tool, that can be used to do sensitivity

analysis further down the line. However, the best system is only as good as 

the inputs/assumptions that drive it. Some of the assumptions used in this 

report(e.g. battery technology and size, manufacturing location, system 

power)that are key in determining overall system cost have to be carefully

thought through and considered during future rulemaking by the EPA. 

Methodology/Results: 

# Charge Question: Reviewer Comments: 

1 Is the methodology

documented in the report

generally reasonable and

likely to yield accurate

results? Is any bias likely

to be introduced to the 

results due to 

methodological issues? If

so, please indicate the

direction of this bias and 

potential remedies. 

The methodology for determining the costs

are generally reasonable, with some

significant exceptions that are listed

below. 

• The first is the engineering 

development cost, which appears to

have been not considered in detail 

in this report. An example of these 

are the costs to develop control

systems, be they battery control

systems or otherwise. They cannot be

lumped in with the indirect cost

multipliers (ICMs), because these

costs are not borne by the OEMs.

Rather, these are costs borne by the 

suppliers. The bias introduced by 

this is that the overall cost of 

some components is lower than it

should be. The remedy for this is to

revisit the engineering development

costs for the subsystems.

• What this report does not document 

sufficiently is the validation of

this methodology at a subsystem or a 

Date: March 11, 2011 Page 1 of 7 
 

system level. The bottoms up towards

cost that is employed by FEV is

certainly very detail oriented, but

there isn’t sufficient data in the 

report to show that the final

subsystem or system costs that they 

result in, are inline with those

developed or published by other

reasonable sources. 

2 Please identify any general

flaws inherent in the scope

of the study. Do you feel

the results would be 

altered if the scope were

more limited or expanded? 

Please explain. 

• Although not a flaw per se, it is 

not clear why the 20% power and

weight reduction was assumed for the

P2 hybrid. This was the direction

provided by the EPA to FEV, but the

rationale for this is not clear, and

this reviewer could not see why it 

is justified.

• Secondly, the reports stated that

the team felt that the Li Polymer

battery (as opposed to NiMH) is a

better long term solution for the P2

hybrid. It’s unclear if this was the

EPA team or the FEV team. Either 

way, there is no good rationale 

provided for such a statement, and

this reviewer has not seen data 

(even outside of this report) to

justify such a statement. 

3 Are all appropriate inputs

for the study being

considered? Conversely, are

all inputs considered in

the study appropriate? 

Please cite any particular

inputs or assumptions made

by the study that you feel

are inappropriate or likely

to bias the results and how 

they could be remedied,

with particular emphasis on

sources of information used 

in determining labor rates, 

material prices,

manufacturing burdens and

other key factors. 

• One of the major assumptions in this

study that is flawed is that the

high voltage battery will be

manufactured in the United States. 

NiMH batteries are not manufactured 

in volume in the United States, and 

although several companies have

plans to manufacture Li Ion

batteries, the cells typically come

from Asia. To assume that all this 

manufacturing is done in the US will

results in artificially high unit

costs for these systems. If this

information is then used by the EPA 

for downstream rule making, it will

have the effect of having hybrid

technologies show up in an

unfavorable light as compared to

other technologies. This inaccuracy 

could be remedied by a modification

of the assumptions in terms of where 

the battery will be manufactured.

• This study does not present

sufficient examples of independently

determined system/subsystem costs to

be used for validation of the costs 

that FEV/Munro calculates through

their process. Although the report

mentions this was done (section 

Date: March 11, 2011 Page 2 of 7 
 

C.7), examples of such validation

are not presented. These

independently determined

costs/sources should be additional

inputs to this process. 

4 Are the assumptions

embedded in the model that 

affect projected cost or

performance reasonable? 

Such assumptions might

include learning curve,

economies of scale, scaling

parameters such as weight

and power, labor rates,

plant scaling, and material

costs. 

• In general, the assumptions that are

utilized to calculate cost and 

performance are reasonable. One big 

exception (also mentioned in

question 6 below) is the scaling

parameter for the battery. Only two

paragraphs are devoted to it in the

report, and nowhere is a definition

of “a common run-time”, which is 

used in the scaling of the battery, 

provided. 

5 Are the results expected of

the study appropriate for

the given scope,

assumptions, and inputs?

Are there other results 

that could be derived from 

the analysis that would

support or contradict those

cited by the study? Is

appropriate validation made 

on the costing methodology

and results? Please expand

on any recommendations that

you would make for analyses

of study results. 

• The results of the study are

appropriate for the given scope,

assumptions and inputs.

• The description/report of the 

validation of the costing methodolgy

is not sufficient. The report does

say that experts have been consulted

in determining the costs of various

components, but little validation

has been shown (in the report) of

cost validation at a subsystem or

system level. The overall costs 

developed by FEV would present a

greater punch if there were examples

of the comparison of their

system/subsystem costs with other 

costs that have been published in

literature. 

• FEV and Munro have the tools 

necessary to do a sensitivity 

analyses of the costs with respect

to different variables of interest. 

Further analyses could include

refinement/correction of some of the

assumptions around this study (as

mentioned in this review) and

studying how the overall system

costs are impacted by those changes. 

6 Is the approach used in

scaling the cost of powersplit technology to other

vehicle classes appropriate

and likely to yield

accurate results? Is the 

methodology for using the

cost of power-split 

components in other hybrid

technologies appropriate 

• For most of the components, the

approach used in scaling the cost of

power split technology to other

vehicle classes is reasonable and 

likely to yield reasonable results.

The one potential exception (and it 

is stated as potential, because the

approach is not well explained in

the report) is the scaling of the 

high voltage battery parameters 

Date: March 11, 2011 Page 3 of 7 
 

and likely to yield

accurate results? 

across the the different vehicle 

classes. This needs to be better 

explained and justified,

particularly because this one 

component is responsible for the

bulk of the cost of the hybrid

powertrain. Given that the overall

cost of the hybrid powertrain is so

sensitive to this one component,

this reviewer feels that greater

care is needed in developing this

cost. Conversely, there is 

considerable detail in the report on

the costs for much more minor 

components, and although that is not

a bad thing, the appropriate scaling

of the battery system needs to have

more effort put into it. 

Table 1 Charge Questions – Methodology/Results 

Editorial content: 

Charge Question: Reviewer Comments: 

Is sufficient detail provided In most cases, sufficient detail has been

in the body for a reader provided for a reader familiar with the

familiar with the subject subject report to understand the process

report to understand the and conclusions. Exceptions are:

process and conclusions? Are • Rationale for assuming the high appropriate appendices voltage battery is manufactured in included? Please specify any the United States 

specific content that you

recommended be added or 

removed. 

• Development of the ED&T costs for

different subsystems, particularly 

that for control systems 

• Validation of the calculated costs 

at a subsystem/system level

• Scaling of the battery system across 

different vehicle classes 

• Cost for the high voltage DC/DC

converter doesn’t appear to be

included 

Please comment on any editorial The overall report is well organized.

issues that should be addressed There are a few minor 

in the report, including any typographical/grammatical issues. These 

comments on general are included in detail in section 

organization, pagination, or “Grammatical/Typographical Errors”. 

grammar and wording. 

Table 2 Charge Questions - Editorial Content 

Date: March 11, 2011 Page 4 of 7 
 

Additional Review Comments 

The following sections provide additional review comments on the FEV

report. 

Battery Manufacturing 

The report assumes that the battery will be manufactured in locations in

North America. Although this reviewer understands this to be a constraint 

from the EPA, this is not a reasonable assumption. There is no large scale

automotive NiMH manufacturing in North America currently and there are few

plans for the same. Although there are more examples of Li Ion battery 

manufacturing in North America, it is questionable if Li Ion will be the

battery of choice for hybrid vehicles. In this reviewer’s

experience/knowledge, the NiMH battery will continue to dominate the HEV

market, while Li Ion will dominate the PHEV/EV market. 

Applicability of the Power Split System to Vehicle Segments 

The report talks about the applicability of the power split hybrid system

to the sub-compact, small, large and minivan vehicle segments. It should be 

clarified that this group covers small SUVs, such as the Ford Hybrid 

Escape, which is one platform that clearly already supports this hybrid

platform. 

P2 Hybrid System 

1. Although the EPA provided the direction to reduce the maximum system

torque/power by 18-19%, the rationale for this isn’t clear. Without 

this rationale, a meaningful comparison between the cost figures for

the power split system and those for the P2 system cannot be made.

2. Why was it felt that the Li Ion battery would be more appropriate for 

the P2 hybrid? Li Ion batteries have much better energy density than 

NiMH batteries, so for applications that require large battery energy

(such as PHEVs or EVs), it is understandable to use Li Ion packs. 

However, for the P2 application, the required kWH of the battery (from 

Table F-2) was less than that for the power split application (from 

Table E-2). Given this, the selection of the Li Ion technology for the 

P2 system is not well justified. 

Cost Analysis Process 

1. In Figure B-1, why isn’t the BOM updated after step 6, when additional 

information has been gained about the component after its disassembly?

2. Page 50, first paragraph refers to 19,149 parts, and it wasn’t clear

what the 19,149 parts stand for? Are these 19,149 battery packs?

3. It isn’t too clear how the engineering design costs for various 

components/systems have been calculated.

a. For example, in section D.2.2, how has the engineering design

cost for the Atkinson engine and the control system for it, and

the calibration for it been calculated/estimated?

b. Similarly, how is the engineering design cost for the electronics 

controllers, for the software for the battery system, for the

mechanical design of the battery system been estimated? The

actual numbers that have been presented in the tables appear to

be too low. 

Date: March 11, 2011 Page 5 of 7 
 

 

c. In Table D-11, why is the ED&T for the traction battery assembly 

so high ($49) compared to that for the control module (listed as 

$4)? The relative engineering effort for the control module is 

not 12 times less than that for the design of the mechanical

assembly. 

System Scaling and Sizing 

1. Although the scaling for the most of the components across the

different vehicle classes seems reasonable, one big item that is not

explained clearly is the high voltage battery. Given that it is the

single most expensive subsystem within the hybrid powertrain, more 

care needs to be put into ensuring that this is done in a reasonable

manner, and the report needs to explain how this was done. The last

paragraph on page 132 talks about the “common run-time” parameter that 

is used to scale the battery system across vehicle segments. This 

parameter needs to be defined, and the report should have more of an

explanation why the value of 0.0168 hours was used, and how it

translates to the other parameters (power rating, energy rating) that

define a battery.

2. In Table E-2, the nominal pack voltage for the subcompact passenger 

vehicle is quite low, namely 148V. Could other, potentially cheaper

power electronics technologies be used at this battery voltage?

3. There is a small discrepancy between some of the numbers in Table E-2 

as compared to those in Table D-3. For example, for the Fusion Hybrid, 

Table D-3 lists the net power as 142kW, whereas Table E-2 lists it as 

140.6kW. Similarly, the engine power is listed as 116kW in Table D-3, 

but as 114.8kW in Table E-2. Even a rounding of the numbers doesn’t 

make them the same. 

Miscellaneous 

1. Table A-1 has a calculation of the percent decrease/increase in cost 

of adding the power split system to different vehicle segments. It

would be more appropriate to calculate the percentage increase as 

compared to the base non-hybrid vehicle cost, instead of calculating 

the increase with respect to the mid/large size vehicle segement cost.

2. Nowhere in the paper (for example, section D.7.1 makes no mention of 

it, and neither do Tables D-5 or D-6) could this reviewer find the 

mention of the high voltage DC/DC converter (which converts the 

voltage from approx 300V to approx 600V, and subsequently utilized by 

the traction motor and generator), which is used in the Fusion Hybrid. 

The corresponding cost for this part is also not mentioned. 

Grammatical/Typographical Errors 

1. Page 10, 2nd line, replace “advance” with “advanced”

2. Page 11, 3rd line, replace “value” with “valve”

3. Page 18, 3rd line, replace “standardize” with “standardized”

4. Page 18, paragraph 2, 1st line, replace “very” with “vary”

5. Page 19, paragraph3, 5th line from bottom, replace “develop” with

“developed”

6. Page 21, extra bullet point in Scenario #2

7. Page 52, last paragraph, replace “Too” with “To”

8. Page 52, last paragraph, replace “truck” with “trunk”

9. Page 56, 2nd paragraph, replace “approximate” with “approximately”

10. Page 91, 3rd paragraph, replace “acknowledge” with “acknowledged”

11. Page 97, 1st paragraph, replace “VEV” with “HEV” 

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