Interim Joint Technical Assessment Report:

 Light-Duty Vehicle Greenhouse Gas Emission 

Standards and Corporate Average Fuel Economy Standards

for Model Years 2017-2025 

Office of Transportation and Air Quality 

U.S. Environmental Protection Agency 

Office of International Policy, Fuel Economy, and Consumer Programs 

National Highway Traffic Safety Administration

U.S. Department of Transportation 

California Air Resources Board

California Environmental Protection Agency 

September 2010 

 
2017-2025 Technical Assessment

ii

Table of Contents

Executive Summary .................................................................................................... v

1 Introduction .................................................................................................... 1-1

1.1 Purpose of this Report ........................................................................................................ 1-1

1.2 National Program for Model Years 2012 - 2016 ................................................................ 1-2

1.3 Standards for 2017 and Beyond ......................................................................................... 1-4

1.4 Future Technical Work and Analysis for the Joint Federal Rulemaking ........................... 1-5

Chapter 1 References ................................................................................................................... 1-7

2 Technical Input from Stakeholders .............................................................. 2-1

2.1 Overview of Stakeholder Outreach Process ....................................................................... 2-1

2.2 Input from Various Stakeholder Groups ............................................................................ 2-1

2.2.1 Automobile Original Equipment Manufacturers ..................................................... 2-1

2.2.2 Automotive Suppliers .............................................................................................. 2-8

2.2.3 Non-Governmental Environmental Organizations .................................................. 2-9

2.2.4 State and Local Government Organizations .......................................................... 2-10

2.2.5 Infrastructure Providers ......................................................................................... 2-11

2.2.6 Labor Unions ......................................................................................................... 2-11

Chapter 2 References ................................................................................................................. 2-13

3 Technology, Cost, Effectiveness and Lead-time Assessment ...................... 3-1

3.1 What technologies did the Agencies Consider? ................................................................. 3-1

3.2 How did the Agencies Determine the Costs and Effectiveness of Each of These 

Technologies? .............................................................................................................................. 3-1

3.2.1 How are Cost and Effectiveness Estimates Different from the 2012-2016 Rule? ... 3-1

3.2.2 Costs from Tear-down Studies................................................................................. 3-2

3.2.3 Costs of HEV, PHEV, EV, and FCEV .................................................................... 3-4

3.2.4 Mass Reduction Impacts and Costs ......................................................................... 3-7

3.2.5 Indirect Cost Multipliers ........................................................................................ 3-11

3.2.6 Cost Adjustment to 2008 Dollars ........................................................................... 3-12

3.2.7 Costs Effects due to Learning ................................................................................ 3-13

3.2.8 Cooled EGR Cost and Effectiveness ..................................................................... 3-13

3.2.9 HEV Effectiveness ................................................................................................. 3-14

3.2.10 Ongoing Vehicle Simulation to Update Effectiveness .......................................... 3-14

3.3 Vehicle Manufacturer Lead Time .................................................................................... 3-15

3.4 Other Technologies Assessed ........................................................................................... 3-19

3.4.1 Types of engine technologies that improve fuel economy and reduce CO2 emissions 

include the following: ........................................................................................................... 3-19

3.4.2 Types of transmission technologies considered include: ....................................... 3-22

3.4.3 Types of vehicle technologies considered include: ............................................... 3-23

3.5 Technology Packages in OMEGA ................................................................................... 3-27

Chapter 3 References ................................................................................................................. 3-29
2017-2025 Technical Assessment

iii

4 Infrastructure Assessment ............................................................................. 4-1

4.1 Overview ............................................................................................................................ 4-1

4.2 Electric Vehicle Infrastructure ........................................................................................... 4-2

4.2.1 DOE Charging Infrastructure Projects Underway ................................................... 4-2

4.2.2 Home Charging Adequacy ....................................................................................... 4-6

4.2.3 Charging System Cost.............................................................................................. 4-9

4.2.4 Battery End-of-Life Value Assessment and Secondary Use Applications ............ 4-12

4.2.5 Potential Impacts on the Electric Utility and Distribution Infrastructure .............. 4-12

4.2.6 Voluntary Standards to Support PHEV & EV Infrastructure ................................ 4-14

4.3 Hydrogen Infrastructure Overview .................................................................................. 4-17

4.3.1 Status Today........................................................................................................... 4-17

4.3.2 Prospects for Cost and Technology Improvement ................................................. 4-21

4.3.3 Infrastructure Rollout Strategy .............................................................................. 4-21

4.3.4 Policies and Partnerships ....................................................................................... 4-22

4.4 Conclusions ...................................................................................................................... 4-24

Chapter 4 References ................................................................................................................. 4-25

5 Incentives and Flexibilities ............................................................................ 5-1

5.1 Overview of Existing Incentives and Flexibilities in the MYs 2012-2016 Program ......... 5-1

5.2 Potential Credit Programs, Incentives, and Other Flexibilities for 2017 and Later ........... 5-4

5.3 Input on Non-regulatory Incentives from Stakeholders ..................................................... 5-7

Chapter 5 References ................................................................................................................. 5-10

6 Analysis of Scenario Costs and Impacts ....................................................... 6-1

6.1 Context ............................................................................................................................... 6-1

6.2 Analytic Approach ............................................................................................................. 6-1

6.3 Development of Technology Pathways .............................................................................. 6-6

6.3.1 Model Years Considered.......................................................................................... 6-6

6.3.2 Scenario Stringencies Assessed ............................................................................... 6-7

6.3.3 Technology Pathways Considered ........................................................................... 6-8

6.4 Other Key Inputs to the Analysis ..................................................................................... 6-11

6.5 Results of Analysis ........................................................................................................... 6-13

6.6 PHEV and EV Battery Cost Sensitivity Assessment ....................................................... 6-28

Chapter 6 References ................................................................................................................. 6-30

7 Other Key Factors .......................................................................................... 7-1

7.1 Potential Impacts on the Economy and Employment ........................................................ 7-1

7.1.1 Impacts on Auto Manufacturers, Suppliers, and Auto Industry Employment ......... 7-1

7.1.2 Impacts on Vehicle Sales ......................................................................................... 7-2

7.1.3 Summary .................................................................................................................. 7-2

7.2 Upstream GHG Emissions ................................................................................................. 7-3 

Chapter 7 References ................................................................................................................... 7-4 

Appendix A: The Baseline and Reference Vehicle Fleet................................ A-1 
2017-2025 Technical Assessment

iv

Appendix B: Package Cost and Effectiveness...........................................................B-1 

Appendix C: Reserved........................................................................C-1 

Appendix D: Air Conditioning..................................................................................D-1 

Appendix E: Key Inputs to the Analysis...................................................E-1 

Appendix F: EPA Documentation of OMEGA model Analysis........................F-1 

Appendix G: Infrastructure..................................................................G-1 
2017-2025 Technical Assessment

v 

Executive Summary

The Environmental Protection Agency (EPA) and the National Highway Traffic Safety 

Administration (NHTSA, a modal administration within the Department of Transportation) (“the 

agencies”) are collaborating with the California Air Resources Board (CARB) to build on the 

success of the first phase of the National Program to regulate fuel economy and greenhouse gas 

(GHG) emissions from U.S. light-duty vehicles. The strong and coordinated first phase of 

standards for model years (MY) 2012-2016 was completed in April 2010, ensuring that all 

manufacturers can build a single fleet of U.S. vehicles to meet the new harmonized standards. 

On May 21, 2010, the President called on the agencies to take additional coordinated 

steps to bring about a new generation of clean vehicles.1

In his May 2010 memorandum, the President recognized that, by acting expeditiously, 

our country could take a leadership role in addressing these global challenges. He stated that, 

“America has the opportunity to lead the world in the development of a new generation of clean 

cars and trucks through innovative technologies and manufacturing that will spur economic 

growth and create high-quality domestic jobs, enhance our energy security, and improve our 

environment.” The effort described in the Presidential Memorandum represents a continuation 

of the National Program to control GHGs and reduce oil consumption from the transportation 

sector. As directed by the President, NHTSA and EPA, in close coordination with CARB are 

working together under a carefully coordinated set of steps to further control GHG emissions and 

reduce oil consumption from the transportation sector. 

 Among other things, the agencies were 

tasked with researching and then developing standards for MY 2017 through 2025 that would be 

appropriate and consistent with EPA’s and NHTSA’s respective statutory authorities, in order to 

continue to guide the automotive sector along the road to reducing its fuel consumption and 

GHG emissions, thereby ensuring the corresponding energy security and environmental benefits. 

During the public comment period for the MY 2012-2016 proposed rulemaking, many 

stakeholders encouraged EPA and NHTSA to begin working toward standards for MY 2017 and 

beyond that would maintain a single nationwide program. Several major automobile

manufacturers and CARB sent letters to EPA and NHTSA in support of a 2017 to 2025 MY 

rulemaking initiative outlined in the President’s May 21st announcement. 

In response to the President’s request and to craft a clear regulatory path for the 

automobile industry, the agencies have collaborated with CARB to prepare this joint Technical 

Assessment Report to inform the rulemaking process and provide an initial technical assessment 

for that work. In accordance with the Presidential Memorandum, the agencies are also issuing a 

joint Notice of Intent to Issue a Proposed Rulemaking (NOI). The NOI announces plans for 

initiating a joint rulemaking which will be designed to improve the fuel efficiency and reduce the 

 

1 Presidential Memorandum: “Improving Energy Security, American Competitiveness and Job Creation, and 

Environmental Protection Through a Transformation of Our Nation’s Fleet of Cars And Trucks,” Issued May 21, 

2010, published at 75 Fed. Reg. 29399 (May 26, 2010), also available at http://www.whitehouse.gov/the-pressoffice/presidential-memorandum-regarding-fuel-efficiency-standards. 
2017-2025 Technical Assessment

vi 

GHG emissions of passenger cars and light-duty trucks built in MYs 2017-2025. The joint 

federal rulemaking will undergo a full notice-and-comment process, consistent with law and 

Administration policies on openness, transparency, and sound science. 

EPA, NHTSA, and CARB are issuing this joint Technical Assessment Report in response 

to Section 2(a) of the Presidential Memorandum. Section 2(a) of the Presidential Memorandum 

requests that EPA and NHTSA “Work with the State of California to develop by September 1, 

2010, a technical assessment to inform the rulemaking process, reflecting input from an array of 

stakeholders on relevant factors, including viable technologies, costs, benefits, lead time to 

develop and deploy new and emerging technologies, incentives and other flexibilities to 

encourage development and deployment of new and emerging technologies, impacts on jobs and 

the automotive manufacturing base in the United States, and infrastructure for advanced vehicle 

technologies.” This report provides an overview of key stakeholder input and addresses the 

topics noted in the memorandum, and presents the agencies’ initial assessment of a range of 

stringencies of future standards. Chapter 1 of this report provides a further introduction and 

overview of the light-duty vehicle related sections of the May 21, 2010 Presidential 

Memorandum, and also of the final rule establishing CAFE and GHG standards for MYs 2012-

2016 light-duty vehicles.

During June through August 2010, EPA, NHTSA, and CARB held numerous meetings 

with a wide variety of stakeholders to gather input to consider in developing this Technical 

Assessment Report, and to ensure that the agencies had available to them the most recent 

technical information. These stakeholders included the automobile original equipment 

manufacturers (OEMs), automotive suppliers, non-governmental organizations, states and state 

organizations, infrastructure providers, and labor unions. The agencies sought these 

stakeholders’ technical input and perspectives, consistent with the President’s request, on the key 

issues that should be considered in assessing a national program to reduce greenhouse gas 

emissions and improve fuel economy for light-duty vehicles in model years 2017-2025. 

The agencies requested the OEMs’ input regarding several key areas including 

technology development, key regulatory design elements, infrastructure issues, perspective on 

the impacts on the U.S. manufacturing base and jobs, and potential regulatory incentives and 

flexibilities. The OEMs presented detailed and confidential technical information to the agencies 

addressing these topics. A common theme across the auto firms is they are all heavily investing 

in advanced technologies including hybrids, plug-in hybrid electric vehicles, electric vehicles,

including fuel cell vehicles, next generation internal combustion engines, and mass reduction 

technologies, and companies expect to increase their offerings and sales of these technologies 

significantly in the future. The companies generally stated, however, that the degree to which 

these advanced technologies will penetrate the U.S. market in the 2017-2025 time frame depends 

upon a number of challenges and factors, as discussed in Chapter 2 of this report. EPA, NHTSA 

and CARB also met with a cross section of automotive suppliers to seek their input on the 

advanced technologies they are developing which could be implemented in the 2017-2025 timeframe. The agencies further received input from infrastructure providers. Many of the 

automakers and automotive suppliers provided input on the need for vehicle charging locations 

needed for the electrical charging of EVs and PHEVs to support their introduction into the 
2017-2025 Technical Assessment

vii 

market. Chapter 2 aggregates and summarizes information gathered from the OEM, automotive 

supplier, and infrastructure provider meetings and describes how the agencies used the 

information to inform this report. 

The agencies also received input from numerous non-governmental organizations, 

including environmental organizations; representatives from the National Association for Clean 

Air Agencies (NACAA), the Northeast States for Coordinated Air Use Management 

(NESCAUM), and approximately 10 individual state and local governments; and the United 

Auto Workers (the UAW). All of these stakeholders strongly supported the President’s call for 

continuing the National Program approach and setting new fuel economy and greenhouse gas 

standards for light-duty vehicles for the 2017-2025 model years. Chapter 2 also provides an 

overview of issues that were raised during discussions with the states, non-governmental 

organizations, and the UAW. 

As discussed in Chapter 3, the agencies have conducted an initial technology cost, 

effectiveness and lead-time assessment for MYs 2017-2025. The agencies assessed the cost, 

effectiveness, and availability of over 30 vehicle technologies that manufacturers could use to 

improve the fuel economy and reduce CO2 emissions of their vehicles during MYs 2017-2025. 

The chapter describes technologies that are readily available today, but also other technologies 

that are not currently in production but are beyond the research phase and under development, 

and which are expected to be in production in the 2017-2025 timeframe. The technologies 

considered in this report fall into five broad categories: engine technologies, transmission 

technologies, vehicle technologies, electrification/accessory technologies, electric drive 

technologies including hybrid technologies and mass reduction. 

Consistent with stakeholder input obtained over the summer, Chapter 3 identifies how 

electric drive vehicles can be an important part of the vehicle mix that will likely be used to meet 

increasingly stringent fuel economy and GHG emission standards. Electric drive vehicles 

including hybrid electric vehicles (HEV), battery electric vehicles (EVs), plug-in hybrid electric 

vehicles (PHEVs) and hydrogen fuel cell vehicles (FCVs), can dramatically reduce petroleum 

consumption and GHG emissions compared to conventional technologies. Additionally, given 

their use of fuels that can eventually be derived from entirely renewable and zero carbon 

resources, the agencies note that these technologies have significant potential to transform the 

vehicles of the future to a low carbon fleet.

Stakeholders, particularly the OEMs, emphasized to the agencies that the future rate of 

penetration of these technologies into the vehicle fleet is not only related to future GHG and 

CAFE standards, but also to future gasoline fuel prices, future reductions in HEV/PHEV/EV 

battery costs, the overall performance and consumer demand for the advanced technologies, 

access to electric vehicle recharging locations and, for fuel cell vehicles the development of a 

hydrogen refueling infrastructure. In the case of EVs and PHEVs, electric charging locations are

needed in the form of charging systems, most often at home, but potentially also at the workplace 

and other locations such as stand-alone facilities and public parking locations in order to 

facilitate significant, wide-spread penetration of these vehicle technologies. In the case of FCVs, 

hydrogen fueling stations are needed to support commercialization. Chapter 4 provides a 
2017-2025 Technical Assessment

viii

description and assessment of current activities and technologies, discussion of costs, and 

prospects for technology improvement, as well as a summary of needs for successful 

infrastructure deployment to support electric drive vehicle commercialization. The agencies 

worked closely with the Department of Energy (DOE) in our assessment of electric vehicle 

charging requirements and issues and DOE was a contributor to this Chapter, in addition to other 

technical aspects of this report.

The final rule for MYs 2012-2016 provides for several flexibilities, including averaging, 

banking and trading provisions for credit carry-forward and carry-back, various additional credits 

opportunities, and advanced technology incentives. The MYs 2012-2016 program also includes 

additional leadtime flexibilities under the CAA for smaller volume manufacturers. Several 

stakeholders provided input on the need to continue many of these flexibilities for the MYs 

2017-2025 program. Chapter 5 provides an overview of these flexibilities as they exist in the 

MYs 2012-2016 rule as well as the stakeholder input the agencies have received regarding their 

potential applicability in the MYs 2017-2025 program. Also, Chapter 5 provides an overview of 

non-regulatory approaches that can promote the commercialization of low-GHG light-duty 

vehicle technologies. 

Chapter 6 presents an analysis of future levels of control of GHG emissions conducted 

for this Technical Assessment Report.2

 

2 These GHG emissions levels can be translated to mpg-equivalent levels through simple math, but we note that they 

would not necessarily translate directly into equivalent CAFE standards due to their inclusion of credits for A/C 

improvements, which is permissible for CAA standards but not for CAFE standards.

 Four scenarios of future stringency are analyzed for 

MYs 2020 and 2025, starting with a 250 gram/mile estimated fleet-wide level in MY 2016 and 

lowering CO2 scenario targets at the rates of 3% per year, 4% per year, 5% per year, and 6% per 

year, respectively. For each of those rates of increase in stringency, the agencies considered the 

effects of the industry following four potential “technology pathways,” “A,” “B,” “C,” and “D.” 

The agencies developed these different technology pathways in order to capture both the current 

levels of uncertainty regarding the potential rate of penetration of various advanced technologies 

and to illustrate more than one approach that the auto industry could take in responding to future 

targets. This approach was also informed by our meetings with the auto companies, whom are 

pursuing a range of different technology paths for the future, with different companies placing 

relative emphasis on different technologies. The agencies present the results of this assessment 

in terms of six broad metrics: per-vehicle cost increase, net lifetime vehicle owner savings, 

payback period to the consumer, net reduction in GHG emissions, net reduction in fuel 

consumption, and vehicle technology penetration mix, as shown in the tables below. Chapter 6 

presents the results of this initial analysis for projected costs, emissions reductions, and lifetime 

fuel savings, and also provides the technology projections that were used in the analyses. 

Chapter 6 also discusses the fact that this preliminary assessment does not include consideration 

of all statutory requirements and other factors that will be assessed in the upcoming Federal 

rulemaking. Consideration of these factors is expected to affect cost assessments and may affect 

the proposed standards. 
2017-2025 Technical Assessment

ix

The following summary tables show the fundamental quantitative conclusions from this 

initial assessment. As shown in Table ES-1, automotive technologies are available, or can be 

expected to be available, to support a reduction in greenhouse gas emissions, and commensurate 

increase in fuel economy, of up to 6 percent per year in the 2017-2025 timeframe. Greater 

reductions come at greater incremental vehicle costs. The per vehicle cost increase ranges from 

slightly under $1,000 per new vehicle for a 3 percent annual GHG reduction, increasing to as 

much as $3,500 per new vehicle to achieve a 6 percent annual GHG reduction. Consumer 

savings would increase with the lower GHG emissions and higher fuel economy. For the 

different scenarios analyzed, the net lifetime savings to the consumer due to increased vehicle 

efficiency range from $4,900 to $7,400. The initial vehicle purchaser will find the higher vehicle 

price recovered in 4 years or less for every scenario analyzed. 

Table ES-1: Projections for MY 2025 Per-Vehicle Costs, Vehicle Owner Payback, 

and Net Owner Lifetime Savings 1, 2

Scenario New Fleet 

g/mile CO2 

Target 

(MPGe)2

Tech

Path 

Per-Vehicle 

Cost 

Increase ($)

Payback 

Period 

(years)

Net Lifetime 

Owner 

Savings ($) 

3%/year 190 (47) A $930 1.6 $5,000 

B $850 1.5 $5,100 

C $770 1.4 $5,200 

D $1,050 1.9 $4,900

4%/year 173 (51) A $1,700 2.5 $5,900 

B $1,500 2.2 $6,000 

C $1,400 1.9 $6,200 

D $1,900 2.9 $5,300

5%/year 158 (56) A $2,500 3.1 $6,500 

B $2,300 2.8 $6,700 

C $2,100 2.5 $7,000 

D $2,600 3.6 $5,500

6%/year 143 (62) A $3,500 4.1 $6,200 

B $3,200 3.7 $6,600 

C $2,800 3.1 $7,400 

D $3,400 4.2 $5,700

1. Per-vehicle costs represent the increase in costs to consumers from the MY 2016 standards. Payback period and 

lifetime owner savings use a 3% discount rate and AEO 2010 reference case energy prices. The gasoline price used 

for this estimate is $3.49/gallon in 2025 and increases over time to a maximum of $4.34/gallon in 2050. Per-vehicle 

costs represent the estimated cost to the consumer, including the direct manufacturing costs for the new 

technologies, indirect costs for the auto manufacturer (e.g., product development, warranty) as well as auto 

manufacturer profit, and indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of indirect 

costs.

2. The targets evaluated were CO2 targets which could be meet through reductions in CO2 as well as through air 

conditioning system hydroflurocarbon reductions converted to a CO2 equivalent value. MPGe is the equivalent 

MPG value if all of the CO2 reductions came from fuel economy improvement technologies. Real-world CO2 is 
2017-2025 Technical Assessment

x 

typically 25 percent higher and real-world fuel economy is typically 20 percent lower. Thus, the 3% to 6% range 

evaluated in this assessment would span a range of real world fuel economy values of approximately 37 to 50 mpg, 

which correspond to the regulatory test procedure values of 47 and 62 mpg, respectively. 

As shown in Table ES-2, the increased vehicle efficiency would result in substantial 

societal benefits in terms of the GHG emission reductions and the petroleum use reductions. In 

the analyzed scenarios for 2025 model year vehicles, lifetime GHG emissions would be reduced 

from 340 million metric tons (3 percent annual improvement scenario) to as much as 590 million 

metric tons for a 6 percent annual improvement scenario. For the same range of scenarios, 

lifetime fuel consumption for this single model year of vehicles would be reduced by 0.7 to 1.3 

billion barrels.

Table ES-2: Estimated CO2e and Fuel Reductions for the Lifetime of MY 2025 

Vehicles1,2

Scenario Lifetime CO2e Reduction 

(million metric tons, MMT)

Lifetime Fuel Reduction 

(Billion Barrels)

3%/year 340 0.7

4%/year 410-440 0.9 

5%/year 440-530 1.1

6%/year 470-590 1.3 

1. Fuel reductions are the same for each of the four technology pathways, but CO2e reductions vary as a function of 

the penetration of EVs and PHEVs in each of the four technology pathways evaluated (due to an increase in 

upstream emissions). 

2. For reference, the National Program in MY 2016 is projected to reduce 0.6 billion barrels of fuel and 325 MMT 

CO2e over the lifetime of MY2016 vehicles.

Table ES-3 illustrates the levels of technology required to achieve the different GHG and 

fuel economy levels that were analyzed by the agencies. The types of vehicle technologies sold 

in 2025 to meet more stringent emission and fuel economy standards depends on the stringency 

of the adopted standards, the success in fully commercializing at a reasonable cost emerging 

advanced technologies, and consumer acceptance. The analysis for this report illustrates a wide 

range of possible outcomes, and these will likely vary by vehicle manufacturer. The potential 

fleet penetrations for gasoline and diesel vehicles, hybrids, plug-in electric vehicles, or electric 

vehicles also may vary greatly depending on the agencies’ assumptions about what technology 

pathways industry choose. 

As shown in Table ES-3, at the 3 or 4 percent annual improvement scenarios, advanced 

gasoline and diesel powered vehicles that do not use electric drivetrains may be the most 

common vehicle types available in 2025. In the 3 percent to 4 percent annual improvement 

range, all pathways use advanced, lightweight materials and improved engine and transmission 

technologies. Table ES-3 also shows that hybrid vehicle penetration under the 3 and 4 percent 

annual improvement scenarios vary widely due to the assumptions made for each technology 

pathway, ranging from roughly 3 to 40 percent of the market in 2025. 
2017-2025 Technical Assessment

xi

Under the 5 or 6 percent annual improvement scenarios hybrids could make up from 40 

percent to 68 percent of the market. In Paths A through C, PHEVs and EVs penetrate the market 

substantially only at the 6 percent annual improvement scenario. In Path D, where a 

manufacturer makes no improvement in gasoline and diesel vehicle technologies beyond MY 

2016, PHEVs and EVs begin to penetrate the market at the 4 percent annual improvement rate 

and may have as high as a 16 percent market penetration under the 6 percent annual 

improvement scenario. 

Table ES-3: Technology Penetration Estimates for MY 2025 Vehicle Fleet

Scenario

Technology 

Path

New Vehicle Fleet Technology Penetration

Mass 

Reduction1

Gasoline & 

diesel vehicles HEVs PHEVs2 EVs

3%/year Path A 15% 89% 11% 0% 0%

Path B 18% 97% 3% 0% 0%

Path C 18% 97% 3% 0% 0%

Path D 15% 75% 25% 0% 0%

4%/year Path A 15% 65% 34% 0% 0%

Path B 20% 82% 18% 0% 0%

Path C 25% 97% 3% 0% 0%

Path D 15% 55% 41% 0% 4%

5%/year Path A 15% 35% 65% 0% 1%

Path B 20% 56% 43% 0% 1%

Path C 25% 74% 25% 0% 0%

Path D 15% 41% 49% 0% 10%

6%/year Path A 14% 23% 68% 2% 7%

Path B 19% 48% 43% 2% 7%

Path C 26% 53% 44% 0% 4%

Path D 14% 29% 55% 2% 14%

1. Mass reduction is the overall net reduction of the 2025 fleet relative to MY 2008 vehicles.

2. This assessment considered both PHEVs and EVs. These results show a higher relative penetration of EVs 

compared to PHEVs. The agencies do believe PHEVs may be used more broadly by auto firms than 

indicated in this technical assessment.

Chapter 7 discusses other key factors for the MYs 2017-2025 light-duty vehicle 

rulemaking that the agencies are considering, including the potential impact on the employment 

and vehicle sales and upstream GHG emissions. 

In conclusion, the three agencies have received important input from a range of 

stakeholders to inform the extension of the National Program to MYs 2017-2025. Auto 

manufacturers, states, environmental groups and the United Auto Workers have expressed 

support for a continuation of the National Program. All auto firms are heavily invested in 

developing advanced technologies which can reduce fuel consumption and GHGs significantly 
2017-2025 Technical Assessment

xii

beyond the MYs 2012-2016 standards. Manufacturers are developing many technologies that 

would enable them to eventually achieve appreciable improvements in fuel economy levels, 

including advanced gasoline engines, hybrid electric vehicles, EVs, and PHEVs. The three 

agencies have performed an initial assessment of potential future standards (annual reductions in 

the range of 3 to 6% per year, or 47 to 62 mpg in 2025 if the industry achieved all of the 

increases through fuel economy improvements), which demonstrates that advanced technologies 

can be used to achieve substantial reductions in fuel consumption and GHGs. The agencies 

analyzed four technology pathway scenarios that the industry could pursue to achieve more 

stringent targets, recognizing there are a wide range of pathways individual manufacturers could 

pursue. One pathway scenario relied upon significant mass reduction and advanced next 

generation gasoline vehicles, the second focused on hybridization and electrification of the fleet 

(HEVs, PHEVs, EVs), and the third was a blend of the first two. The fourth pathway 

emphasizes an EV and PHEV focused approach, with a lesser degree of emphasis on advanced 

gasoline, HEV, and mass reduction approaches. Based on this analysis and the assumptions 

employed, the agencies found that the per-vehicle cost increases for a 2025 vehicle ranged from 

$770 to $3,500 across the range of stringency targets and technology pathways. The fuel savings 

achieved by MY 2025 vehicles meeting these more stringent targets would result in a net lifetime 

savings of between $4,900 and $7400. The GHG reductions ranged from 340 to 590 million 

metric tons and fuel reduction ranged from 0.7 to 1.3 billion barrels over the lifetime of MY 

2025 vehicles. We emphasize that this Technical Assessment Report reaches no specific 

conclusions regarding the levels of stringency to propose for MYs 2017-2025. The report is an 

important step in a continuation of the National Program, but significant work remains to be 

done to support a future federal rulemaking. 
2017-2025 Technical Assessment

1-1 

1 Introduction 

1.1 Purpose of this Report

The Environmental Protection Agency (EPA) and the National Highway Traffic 

Safety Administration (NHTSA, a modal administration within the Department of 

Transportation) (“the agencies”) are collaborating with the California Air Resources Board 

(CARB) to build on the success of the first phase of the National Program to regulate fuel 

economy and greenhouse gas (GHG) emissions from U.S. light-duty vehicles. The strong and 

coordinated first phase of standards for model years (MY) 2012-2016 was completed in April 

2010, ensuring that all manufacturers can build a single fleet of U.S. vehicles to meet the new 

harmonized standards. 

On May 21, 2010, following the completion of the first phase of the National Program, 

the President called on the agencies to take additional coordinated steps to bring about a new 

generation of clean vehicles.1

The President called on the agencies to begin the next phase of the National Program 

in response to the urgent and closely intertwined challenges faced by our nation of 

dependence on oil, energy security, and global climate change. Reducing total petroleum use 

by U.S. light-duty vehicles decreases our economy’s vulnerability to oil price shocks. 

Reducing dependence on oil imports from regions with uncertain conditions enhances our 

energy security. The need to reduce energy consumption is more crucial today than it was 

when the Energy Policy and Conservation Act was enacted in the mid-1970s. Net petroleum 

imports now account for approximately 57 percent of U.S. domestic petroleum consumption,

 Among other things, the agencies were tasked with researching 

and then developing standards for MY 2017 through 2025 that would be appropriate and 

consistent with EPA’s and NHTSA’s respective statutory authorities, in order to continue to 

guide the automotive sector along the road to reducing its fuel consumption and GHG 

emissions, and to ensure the corresponding energy security and environmental benefits. 

Following the President’s announcement, several major automobile manufacturers and CARB

sent letters to EPA and NHTSA in support of a 2017 to 2025 rulemaking initiative as outlined 

in the President’s Memorandum. In addition to the President’s directive, many stakeholders 

in their comments during the MYs 2012-2016 rulemaking encouraged EPA and NHTSA to 

maintain a single nationwide program, and to extend the National Program beyond the first 

phase by beginning to work toward standards for MY 2017 as soon as practicable. 

2

and the share of U.S. oil consumption for transportation is approximately 72 percent.3 

Moreover, world crude oil production continues to be highly concentrated, exacerbating the 

risks of supply disruptions and their negative effects on both the U.S. and global economies. 

Light-duty vehicles also account for about 41 percent of all U.S. oil consumption,B

 making 

them the largest single oil-consuming transportation segment in the U.S. Light-duty vehicles 

emit four GHGs—carbon dioxide (CO2), methane (CH4), nitrous oxide (NOX), and 

hydrofluorocarbons (HFCs) – and are responsible for nearly 60 percent of all mobile source 

GHGs and over 70 percent of Section 202(a) mobile source GHGs. In 2007, CO2 emissions 

represented about 94 percent of total GHG emissions from light-duty vehicles (including 

HFCs), and the CO2 emissions measured by EPA fuel economy compliance tests represented

about 90 percent of all light-duty vehicle GHG emissions.4,5

 
Chapter 1 

1-2 

In his May 2010 memorandum, the President recognized that by acting expeditiously, 

our country could take a leadership role in addressing these global challenges, stating that 

“America has the opportunity to lead the world in the development of a new generation of 

clean cars and trucks through innovative technologies and manufacturing that will spur 

economic growth and create high-quality domestic jobs, enhance our energy security, and 

improve our environment.” NHTSA and EPA, in close coordination with CARB, have started 

the process, through this report, to evaluate the potential for cleaner and more efficient 

vehicles that would transform our nation’s fleet of cars and trucks in the future. Our work 

would extend the National Program and would entail a carefully coordinated set of steps to 

further control GHG emissions and reduce oil consumption from the transportation sector. 

To answer the President’s call and to craft a clear regulatory path for the automobile 

industry, the agencies have collaborated with CARB to prepare this Technical Assessment 

Report to inform EPA’s and NHTSA’s upcoming rulemaking process and provide an initial 

technical assessment for that work. Section 2 of the President’s Memorandum states that this 

Technical Assessment Report should reflect stakeholder input on relevant factors including: 

“viable technologies, costs, benefits, lead time to develop and deploy new and emerging 

technologies, incentives and other flexibilities to encourage development and deployment of 

new and emerging technologies, impacts on jobs and the automotive manufacturing base in 

the United States, and infrastructure for advanced vehicle technologies.” This report 

provides an overview of key stakeholder input received to date, and addresses the applicable 

topics noted in the May 2010 Presidential Memorandum. 

Section 2 of the President’s Memorandum also states that EPA and NHTSA should 

issue a joint Notice of Intent to Issue a Proposed Rulemaking (NOI) following the Technical 

Assessment Report announcing plans to promulgate a next phase of standards for this sector, 

including plans for “gathering any additional information needed to support regulatory 

action.” The NOI is also to include “potential standards that could be practicably 

implemented nationally for the 2017-2025 model years and a schedule for setting those 

standards as expeditiously as possible, consistent with providing sufficient lead time to 

vehicle manufacturers.”6

1.2 National Program for Model Years 2012 - 2016 

 The joint federal rulemaking initiated with the NOI will be designed 

to improve the fuel economy and reduce the GHG emissions of passenger cars and light 

trucks built in MYs 2017-2025, and will follow the full notice-and-comment process, 

consistent with law and Administration policies on openness, transparency, and sound 

science.

The National Program came about, in part, because of a historic agreement between 

diverse interests to set in motion a national fuel efficiency policy announced by the President 

on May 19, 2009.7

On April 1, 2010, NHTSA and EPA issued joint final rules establishing standards for 

GHG emissions and fuel economy for passenger cars, light-duty-trucks, and medium-duty 

 Several automakers and their trade associations also announced their 

support for the National Program at that time. In collaborating between the public and private 

sector, the United States has already shown leadership through enactment of the first-ever 

harmonized GHG emissions and fuel economy standards for light-duty vehicles.
2017-2025 Technical Assessment

1-3 

passenger vehicles (“light-duty vehicles”), which we referred to collectively as the National 

Program.8

EPA and NHTSA established two separate sets of standards, each under its respective 

statutory authority. EPA set national CO2 emissions standards for light-duty vehicles under 

section 202 (a) of the Clean Air Act. These standards will require the fleet of vehicles to meet 

an estimated combined average emissions level of 250 grams/mile of CO2 in model year 

(MY) 2016, which the agencies explained is equivalent to a fuel economy level of 35.5 miles 

per gallon if all the reductions were achieved through improvements in fuel economy, 

although the CO2 standards also gave credit for air conditioning improvements that reduced 

GHGs other than carbon dioxide. NHTSA, in turn, set CAFE standards for passenger cars 

and light trucks under EPCA, as amended by EISA.

 The agencies found that this first phase of the National Program will achieve 

substantial reductions of GHG emissions and improvements in fuel economy from the lightduty vehicle part of the transportation sector, based on technology that is already being 

commercially applied in most cases and that can be incorporated at a reasonable cost. 

9

The MY 2012-2016 standards are together expected to result in approximately 960 

million metric tons of total carbon dioxide equivalent emissions reductions and approximately 

1.8 billion barrels of oil savings over the lifetime of vehicles sold in 2012 through 2016. In 

total, the combined EPA and NHTSA 2012-2016 standards will reduce GHG emissions from 

the U.S. light-duty fleet approximately 21 percent by 2030 over the level that would occur in 

the absence of the National Program. These actions also will provide important energy 

security benefits, as light-duty vehicles are about 95 percent dependent on oil-based fuels and 

much of the petroleum consumed by the U.S. is imported. 

 These standards will require 

manufacturers of those vehicles to meet an estimated combined average fuel economy level of 

34.1 mpg in model year 2016, which is the maximum feasible amount of improvement that 

the agencies estimated could be required using fuel economy-improving technology alone, 

without regard to the A/C credits permitted by EPA under the CAA. The standards for both 

agencies begin with the 2012 model year, with standards increasing in stringency through 

model year 2016. They represent a harmonized approach that will allow industry to build a 

single national fleet that will satisfy both the GHG requirements under the CAA and CAFE 

requirements under EPCA/EISA. 

The National Program for MYs 2012–2016 was developed in close coordination with 

many key stakeholders including California and several other states. In 2004, CARB

approved standards for new light-duty vehicles, which regulate the emission of not only CO2, 

but also other GHGs. Since then, thirteen states and the District of Columbia, comprising 

approximately 40 percent of the light-duty vehicle market, have adopted California’s 

standards. On June 30, 2009, EPA granted California’s request for a waiver of preemption 

under the CAA.10

To promote the National Program for MYs 2012-2016, in May 2009, California 

agreed to accept compliance with the national standards as meeting its requirements. This 

action allows the single national fleet produced by automakers to meet the two Federal 

requirements and to meet California requirements as well. 

 The granting of the waiver permits California and the other states to 

proceed with implementing the California emission standards. These standards apply to 

model years 2009 through 2016. 
Chapter 1 

1-4 

The MYs 2012-2016 standards adopted by NHTSA and EPA for passenger cars and 

light trucks are attribute-based standards, specifically based on vehicle footprint. Each 

manufacturer will have a GHG and a CAFE standard unique to its each of its fleets, 

depending on the footprints of the vehicle models and the volumes produced by that 

manufacturer. A manufacturer will have separate footprint-based standards for cars and light

trucks. With the footprint-based standard approach, EPA and NHTSA believe there should be 

no significant effect on the relative distribution of different vehicle sizes in the fleet, which 

should mean that consumers will still be able to purchase the size of vehicle that meets their 

needs. 

As described in the final rule, EPA and NHTSA expect that automobile manufacturers 

will meet the MYs 2012-2016 CAFE and GHG standards by utilizing currently-available

technologies. Although many of these technologies are available today, the emissions 

reductions and fuel economy improvements will involve more widespread use of these 

technologies across the light-duty vehicle fleet. These include improvements to engines, 

transmissions, and tires, increased use of start-stop technology, improvements in air 

conditioning systems, increased use of hybrid and other advanced technologies, and the initial 

commercialization of electric vehicles and plug-in hybrids. NHTSA’s and EPA’s assessment 

of likely vehicle technologies that manufacturers will employ to meet the MYs 2012-2016 

standards is discussed in the final rule and in the Joint TSD for the final rule. 

The MYs 2012-2016 standards also provide a number of compliance flexibilities to 

manufacturers. While the flexibilities vary in their compliance applicability based on whether 

the manufacturer is meeting the CAFE standard or the GHG standard, both standards also 

allow some of the same flexibilities. These flexibilities are discussed further in Chapter 5 

below. 

1.3 Standards for 2017 and Beyond 

In response to the President’s call to continue and expand a strong, coordinated 

National Program, and in order to achieve critical additional reductions in oil consumption 

and GHG emissions from light-duty vehicles, a number of stakeholders stepped up to offer 

their support and commitment to fulfilling the President’s vision. After release of the 

President’s May 2010 Memorandum, CARB issued a letter supporting the rulemaking process 

to establish MY 2017-2025 standards.11

Several manufacturers also sent letters of support for the 2017-2025 rulemaking 

initiative following the President’s announcement, committing to engaging in a process to 

continue a single national program beyond 2016.

 In its letter, CARB committed to work in partnership 

with EPA and NHTSA to: (1) evaluate technologies; (2) engage with manufacturers and other 

stakeholders to fully explore the capability of technologies; (3) evaluate possible approaches 

to increase in the marketplace the use of advanced technologies; and (4) identify potential 

GHG emissions standards with the expectation that the annual rate of improvement would be 

in the 3 to 6 percent range. 

12 The letters generally stated the 

manufacturers’ agreement with a set of guiding principles, developed by the agencies, for the 

rulemaking process. These guiding principles include: (1) that EPA and NHTSA will work to 

develop strong, coordinated national GHG emissions and CAFE standards for light-duty 
2017-2025 Technical Assessment

1-5 

vehicles manufactured in MY 2017-2025 that enable manufacturers to build a single lightduty national fleet that satisfies all federal and state requirements; (2) that EPA and NHTSA 

will seek input from an array of stakeholders including automobile manufacturers, 

infrastructure providers, labor unions, and environmental organizations, and the agencies will 

work with the State of California and other states in this process; (3) that the agencies and 

CARB will develop a technical assessment to inform the rulemaking process; (4) that a midterm technology review would be appropriate; and, (5) that the future regulatory program 

should enable consumers to still have a full range of vehicle choices. 

The guiding principles also included a description of the process for developing this 

Technical Assessment, including: (1) meeting with stakeholders individually to gather 

currently available information on viable technologies, costs, benefits, lead times, incentives 

and other flexibilities and to evaluate other relevant factors, such as infrastructure; (2) 

evaluating emerging technologies to further reduce GHG emissions and improve fuel 

economy; (3) identifying the capabilities to commercialize new and existing GHG and fuel 

economy technologies, including potential costs and market barriers associated with such 

technologies; and, (4) evaluating possible approaches to help establish in the marketplace an 

increase in the use of advanced technologies, including, but not limited to, plug-in hybrid, 

battery electric and fuel cell vehicles. 

1.4 Future Technical Work and Analysis for the Joint Federal Rulemaking

This report represents EPA, NHTSA, and CARB’s initial assessment of the costs, 

effectiveness, and lead-time considerations for a range of advanced vehicle technologies that 

can significantly increase fuel economy and decrease GHG emissions and it includes new 

information that has been gathered since the 2012 – 2016 federal final rule. As discussed 

above, and presented in the Executive Summary and in detail in Chapter 6, the report also 

presents an analysis for a range of increasing levels of potential stringency for 2020 and 2025, 

along with costs and benefits for using certain advanced technologies for achieving those 

targets. This is an important first step for EPA and NHTSA in meeting the requirements of 

the President’s Memorandum, which will also include the agencies issuing a Joint Notice of 

Intent, a Joint Notice of Proposed Rulemaking, and a Joint Final Rule in the future. 

Being the first step, it is important to note that this Technical Assessment must be 

viewed in the context of the additional work NHTSA and EPA will do going forward. The 

two agencies have a number of significant, on-going projects which will inform the future 

joint Federal rulemaking. As discussed in Chapter 3, these include: new technical 

assessments of advanced gasoline, diesel, and hybrid vehicle technology effectiveness being 

conducted with Ricardo, Inc.; several new projects to evaluate the cost, feasibility, and safety 

impacts of mass reduction from vehicles; and an on-going project with FEV & Munro to 

improve our cost estimations for advanced technologies; further consideration of battery life, 

durability, cost and safety; consideration of several technology cost factors including Indirect 

Cost Multiplier values, time based learning over extended periods of time; maintenance costs; 

and further review of the leadtime needed to implement advanced technologies. An analysis 

of the effects of mass reduction on vehicle safety has not been included in this Technical 

Assessment. For the 2017-2025 NPRM, NHTSA and EPA will conduct an analysis of the 

effects of the proposed rulemaking on vehicle safety, including societal effects. CARB is 
Chapter 1 

1-6 

undertaking a study of the safety effects of a future vehicle designed for high levels of mass 

reduction, and CARB is coordinating with EPA and NHTSA on that study. In addition, EPA 

and NHTSA will continue to meet with and consider input from the full range of stakeholders 

as we develop the joint Federal rulemaking. All of this future information will enhance the 

accuracy of our technological assessment.

In addition, the assessment of scenarios and the accompanying results presented in 

Chapter 6 of this report should be considered an initial analysis because it does not consider 

the full range of factors which EPA and NHTSA must consider for a rulemaking under our 

respective statutory authorities. As discussed in Chapter 6, these include (but are not limited 

to): consideration of the full range of societal benefits, including consumer welfare effects, 

specific evaluation of potential safety implications of future standards, consideration of the 

costs and feasibility of the standards for individual automotive firms, and the development of 

separate attribute-based standards for passenger cars and light-duty trucks for each model year 

covered by the rulemaking. 
2017-2025 Technical Assessment

1-7 

Chapter 1 References

1 Presidential Memorandum: “Improving Energy Security, American Competitiveness and Job Creation, and 

Environmental Protection Through a Transformation of Our Nation’s Fleet of Cars And Trucks,” Issued May 21, 

2010, published at 75 Fed. Reg. 29399 (May 26, 2010), also available at http://www.whitehouse.gov/the-pressoffice/presidential-memorandum-regarding-fuel-efficiency-standards. 

2 Source; Transportation Energy Data Book Edition 28 

3

 Source: EIA Annual Energy Outlook 2010 released May 11, 2010.

4

 U.S. Environmental Protection Agency. 2009. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-

2007. EPA 430-R-09-004. 

5 U.S. Environmental Protection Agency (2010). Regulatory Impact Analysis: Final Rulemaking to Establish 

Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards,

Chapter 2, page 2-4. EPA-420-R-10-009. Available at: http://www.epa.gov/otaq/climate/regulations.htm.

6 Presidential Memorandum, See Note 1.

7

 Remarks by the President on National Fuel Efficiency Standards, May 19, 2009, available at 

http://www.whitehouse.gov/the-press-office/president-obama-announces-national-fuel-efficiency-policy, see 

also http://www.whitehouse.gov/the-press-office/remarks-president-national-fuel-efficiency-standards

8 75 FR 25324 (May 7, 2010).

9 49 U.S.C. 32902 

10 74 FR 32744 (July 8, 2009). 

11 The California Air Resources Board commitment letter is available at: 

http://www.epa.gov/otaq/climate/regulations.htm.

12 The manufacturer commitment letters are available at: http://www.epa.gov/otaq/climate/regulations.htm.

2017-2025 Technical Assessment

2-1 

2 Technical Input from Stakeholders

2.1 Overview of Stakeholder Outreach Process

As mentioned above, the May 21, 2010 Presidential Memorandum requests that EPA 

and NHTSA, working with the State of California, develop a Technical Assessment to inform 

the rulemaking process “reflecting input from an array of stakeholders on relevant factors, 

including viable technologies, costs, benefits, lead time to develop and deploy new and 

emerging technologies, incentives and other flexibilities to encourage the development and 

deployment of new and emerging technologies, impacts on jobs and the automotive 

manufacturing base in the United States, and infrastructure for advanced vehicle 

technologies....”13

To fulfill that request, during June through August 2010, EPA, NHTSA, and CARB 

held numerous meetings with a wide variety of stakeholders to gather input to consider in 

developing this Technical Assessment Report, and to ensure that the agencies had available to 

them the most recent technical information directly from the stakeholders themselves. These 

stakeholders included many automobile original equipment manufacturers (OEMs), 

automotive suppliers, non-governmental organizations, states and state organizations, 

infrastructure providers, and labor unions. For many of the meetings with the OEMs, as well 

as labor unions, representatives from the federal Council of Environmental Quality and the 

White House Office of Energy and Climate Change also participated. The agencies sought 

these stakeholders’ technical input and perspectives on the key issues that should be 

considered, as the President’s memo identified, in assessing a national program to reduce 

greenhouse gas emissions and improve fuel economy for light-duty vehicles in model years 

2017-2025. NHTSA and EPA anticipate continuing the productive dialogue with 

stakeholders as our joint federal rulemaking to develop the new national program proceeds, in 

order to continue to ensure that our analysis reflects the best available information.

2.2 Input from Various Stakeholder Groups

2.2.1 Automobile Original Equipment Manufacturers 

EPA, NHTSA and CARB met with twenty different automotive OEMs to discuss the 

development of a national program for MYs 2017-2025. As discussed below, these include 

very large firms which sell large volumes of vehicles in the U.S. (and in most cases around 

the world), small and medium sized firms who sell relatively low volumes of vehicles in the 

U.S., and three relatively new “start-up” automotive firms whose business strategy for the 

U.S. market is focused on the production of all electric vehicles and/or plug-in hybrid electric 

vehicles. These meetings included senior management and staff from both the companies and 

the three agencies.

EPA, NHTSA and CARB met with eleven of the manufacturers with the largest U.S. 

vehicle sales volume to seek their input on both the key technical and policy issues that the 

agencies should consider in developing the MYs 2017-2025 technical assessment. The 
Chapter 2

2-2 

agencies met individually with the following companies: General Motors, Ford, Chrysler, 

Toyota, Honda, Nissan, Hyundai, Kia, Volkswagen, BMW, and Daimler. These 

manufacturers account for more than 90 percent of the vehicles produced for sale in the 

United States. While the views they expressed and the forecasts they shared for the future 

vehicle market covered a considerable range, especially in terms of specific details, the 

agencies view this range as unsurprising, considering uncertainty regarding key factors (e.g., 

fuel prices) in the 2017-2025 time frame, the relatively long-time frame over which requested 

companies to consider (15 years into the future) and considering manufacturers’ various 

strategies for competing in the automotive market. A number of messages were stressed by 

all or nearly all manufacturers and we have summarized those below. The agencies have 

carefully considered the information and views these manufacturers have shared, and NHTSA 

and EPA will continue to do so as part of the formal rulemaking process for post-2016 CAFE 

and GHG emissions standards. 

In addition, the agencies met with several medium to smaller volume manufacturers, 

including Mitsubishi, Jaguar Land-Rover, Ferrari, Aston-Martin, Lotus, and McLaren. These 

medium and smaller volume manufacturers may face unique compliance challenges because 

they sell a limited number of vehicle types in the U.S., and/or they serve relative small market 

segments that tend to value highly priced luxury vehicles with very high levels of vehicle 

performance (e.g., vehicles with very rapid acceleration and top vehicle speeds) much more 

highly than fuel economy, such that fuel-saving technologies (e.g., turbochargers), even when 

applied, are often used to increase performance rather than to increase fuel economy. Several 

of these manufacturers have traditionally been “fine-payers” under the CAFE system, and like 

all manufacturers—including those that do comply with CAFE standards—are required to pay 

“gas guzzler” taxes for specific models with especially low fuel economy levels. The input 

from these medium and smaller volume manufacturers will be important to the agencies in 

determining how to structure the national program for MYs 2017-2025. 

The agencies also met with new entrants to the automotive industry who are focusing 

on development of electric vehicles and/or plug-in hybrid electric vehicles, including Fisker, 

Tesla, and BYD. These electric vehicle manufacturers provided input regarding the cost of 

key EV technologies (e.g., batteries), the outlook for expanding the EV market, and the need 

for infrastructure and public incentives to support PHEV and EV purchase and operation. 

The agencies requested the OEMs’ input in the following key areas, consistent with 

the President’s memorandum: 

• Technology development status for MYs 2017-2025. For each major 

technology development area we requested details regarding effectiveness, 

costs, technology development and future product introduction plans, and 

the anticipated market penetration in the 2017-2025 timeframe. The major 

technology areas in which the agencies specifically sought information 

included powertrain improvement for advanced gasoline and diesel engines 

and transmissions, hybrid vehicles (HEVs), plug-in hybrid electric vehicles 

(PHEVs) and electric vehicles (EVs) (with a focus on battery technology 

for HEV/PHEV/EVs), fuel cell vehicles, and vehicle mass reduction, as 
2017-2025 Technical Assessment

2-3 

well as thermal management technologies including air conditioning 

improvements. 

• Key regulatory design elements

• Infrastructure issues

• Perspective on the impacts on the U.S. manufacturing base and jobs 

• Potential incentives and flexibilites

In response, the automotive OEMs presented detailed technical information to the 

agencies addressing these topics, and requested confidential treatment for much of it. In order 

to respect these requests for confidentiality, the agencies cannot reveal specific details of the 

business information provided at these meetings, but taken in the aggregate, the following 

summarizes information gathered from the OEM meetings. It is important to note that while 

we requested information for the 2017-2025 time frame, nearly every manufacturer indicated 

that they do not have detailed product development and launch plans which extend 15 years 

into the future. In general, the firms’ plans for 2010-2015 are fairly well defined, most firms 

do have product plans which extend into the 2016-2020 time frame, and no firm had product 

plans of any significant detail which cover the 2021-2025 time frame. Below we summarize 

the general trends we heard from the OEMs in the following broad areas: advanced 

gasoline/diesel engine and transmission technologies; vehicle mass reduction technologies; 

HEV, PHEV, EV technologies; fuel cell vehicle technologies; air conditioning and other 

technologies; regulatory program design; electric vehicle charging infrastructure, and; 

perspectives on US manufacturing and automotive-related jobs.

Nearly universally, the manufacturers agreed with the agencies’ projections in the 

MYs 2012-2016 final rule that the following technologies will be much more prevalent in 

2016 and beyond than they are today. These unclude more efficient turbocharged direct 

injection downsized gasoline engines (turbo-GDI engines) as well as, for larger displacement 

engines, a mix of turbo-GDI engines and some products with GDI coupled with cylinder 

deactivation and advanced valve timing control - all matched with more efficient 6+ speed 

automatic or dual-clutch transmissions.

Advanced gasoline/diesel engine and transmission technologies

C

 However, beyond this particular combustion and 

transmission technologies, OEM feedback with regard to what technologies would be 

employed to meet future more stringent CAFE and GHG standards was mixed. Companies 

indicated that they intended to pursue a variety of different strategies, including diesel, lean 

burn gasoline direct injection, homogeneous charge compression ignition, high Brake Mean 

Effective Pressure (BMEP)D

 

C See, e.g., id. at 25621-25624.

 turbocharged/cooled exhaust gas recirculation systems, and 

D Brake Mean Effective Pressure is the average amount of pressure in pounds per square inch (psi) that must be 

exerted on the piston to create the measured horsepower. This indicates how effective an engine is at filling the 
Chapter 2

2-4 

other advanced engine configurations. Some of these technologies are still in development, 

and OEM comments usually noted that while they remain promising advanced powertrains, 

further development will still be needed to bring them to production. For example, while 

manufacturers were often optimistic about upcoming advanced gasoline engine technologies, 

some also cited concerns such as launch performance of highly-downsized turbocharged 

engines (though most of those manufacturers also stated they are working to resolve this 

issue), or the sensitivity of emission controls on lean-burn engines to gasoline sulfur content. 

Several manufacturers also indicated that nationwide increases in gasoline minimum octane 

levels could be important to attain the maximum potential fuel efficiency and GHG emissions 

improvements for advanced gasoline engines while avoiding driver dissatisfaction with not 

being able to use regular octane fuel. While there was general consensus that more can be 

done for gasoline engines, there was no general consensus, and in some cases no projections 

were provided, regarding the projected costs of these technologies in the 2020 to 2025 time 

frame.

Nearly all OEMs had strategies for reducing the mass of their vehicles, that in many 

cases were described as a new or improved technical approach. Some firms stated that they 

would also be taking advantage of opportunities to reduce engine size without compromising 

vehicle power/weight ratios and thus maintain or increase vehicle performance. The majority 

of manufacturers stated that they were making every effort to remove weight from their 

vehicles through careful redesigns, material substitution, and mass reduction compounding 

going forward. Nearly every automotive firm indicated that vehicle mass will actually 

decrease over the 2010 to 2025 time frame, though the level predicted level of mass decrease 

varied significantly across the firms. Nevertheless, several OEMs indicated that vehicle 

safety technologies, both those driven by regulation and those planned by the firms to meet 

internal company objectives or voluntary standards, would add mass to vehicles in the future 

and this would partially off-set the gains they would see if the focus were only on mass 

reduction and the current status-quo with respect to vehicle safety related technology. A few 

firms also speculated that future criteria pollutant emission standards may also result in a 

small increase in mass that would partially offset the other mass reduction technologies being 

considered by the companies. 

Vehicle mass reduction technologies

Manufacturers cited varied plans to change vehicle designs and/or increase the use of 

high-strength steel (HSS), ultra-high strength steel, aluminum, composites, and/or other 

materials in order to offset these increases and achieve further mass reduction. 

Manufacturers generally indicated that universal material substitution (such as a 

complete switch from steel to aluminum body-in white structures) would not be feasible to 

implement across the majority of their high volume vehicle product lines in the 2017-2025 

time frame due to cost constraints as well as many other engineering and manufacturing 

challenges. Therefore, while more lighter-weight materials might be seen in the future, most 

 

combustion chamber with an air/fuel mixture, compressing it and achieving the most power from it. A higher 

BMEP value contributes to higher overall efficiency.
2017-2025 Technical Assessment

2-5 

OEMs expressed that they still saw the need to continue utilizing steel on many of the 

structural components of vehicles. Also, most manufacturers indicated they either currently 

use significant levels of HSS and/or plan to increase use of HSS in response to recentlypromulgated MYs 2012-2016 standards, which some emphasized could mean that further 

mass reduction through MYs 2017-2025 would necessitate more aggressive (and, therefore, 

potentially more expensive) strategies. Balancing all of these factors, most manufacturers 

generally estimated the potential to reduce actual vehicle mass ranges from 10% to 15% 

between today (2010) and 2025. 

A number of firms also discussed the more advanced light-weight materials such as 

carbon fiber and magnesium. While these materials can offer very significant mass reduction, 

in general these materials are only used on more exotic luxury or high performance vehicles. 

There are, of course, examples of vehicles today which use carbon fiber, but they tend to be 

very expensive, ultra-high performance vehicles (such as the limited edition Ferrari Enzo, or 

the Mercedes SLR MacLaren) or in other cases the amount of carbon fiber in the vehicle is for 

a few select components (such as in the high performance Corvette ZR1 or the high 

performance Lexus ISF). A number of automotive firms are exploring the ability to produce a 

less expensive automotive grade carbon fiber, but in general companies did not see carbon 

fiber, or for that matter magnesium, as playing a major role in the 2017-2025 time frame. 

Virtually all of the manufacturers are planning for greater electrification of their fleet, 

although there were varying degrees of this: from 12 volt stop-start systems, to full hybrid 

electric vehicles (HEV), to plug-in HEVs (PHEV), to electric vehicles (EV). OEMs stated 

that the relative penetration of these technologies varied greatly depending on a number of 

factors, including, future gasoline fuel prices, future decreases in battery costs, anticipated 

regulatory fuel economy/GHG requirements. In particular for PHEV and EVs, OEMs also 

identified the charging infrastructure development and costs as well as external (federal, state 

and local) incentives, and consumer demand/acceptance of vehicles requiring recharging and 

which may have reduced range (in the case of EVs) as additional factors which will impact 

the future penetration of these technologies. For example, with regard to consumer demand, a 

number of OEMs expressed reservations regarding the potential, without government 

assistance, to increase significantly the market for PHEVs and EVs, much beyond the likely 

first-adopters who have already indicated interest in purchasing these vehicles. Nevertheless 

a number of the firms suggested that in the 2020 time frame their U.S. sales of HEVs, PHEVs, 

and EVs combined could be on the order of 15-20% of their production, and while not all 

firms provided forecasts out to 2025, some did indicate that this percent of production could 

grow to be on the order of 40-50%, depending on the factors described above. Other firms 

provided lower projections for the 2020 to 2025 time frame, or no projection at all. 

HEV, PHEV, EV technologies

All of the major OEMs recognize that for PHEV and EV vehicles, the battery costs are 

by far the most significant contributor to the cost increase over a gasoline vehicle. 

Universally the OEMs believe that large-format lithium-ion batteries offer the most promising 

trade-off between battery performance, weight, size, and costs. A large number of lithium-ion 

battery chemistries and designs are being explored and considered for commercialization. 

With respect to costs, there also was a wide range in OEM-projected battery-pack cost in the 
Chapter 2

2-6 

2020 to 2025 timeframe, with the majority of estimates in the $300/kW-hour to $400/kWhour range for 2020 and $250 to $300/kW-hour range for 2025. 

A number of the larger automotive firms described active research and product 

development programs they have underway with respect to fuel cell vehicles. Several 

companies have planned limited product introductions for California within the next several 

years. The companies that discussed such programs identified two major challenges for fuel 

cell vehicles: reducing vehicle system costs and the development of a refueling infrastructure.

Fuel cell vehicle technologies

With respect to costs, several of the firms had specific technology development 

roadmaps which they estimated could significantly lower the costs of fuel cell vehicles over 

the next ten to fifteen years, which they indicated could potentially make fuel cell vehicle 

incremental costs competitive with all electric vehicles in the 2020 to 2025 time frame.

With respect to infrastructure, while the OEMs noted that California is actively 

working to develop and expand a hydrogen refuel infrastructure centered in Southern 

California, they also stressed that without a significant development in other regions of the 

U.S., fuel cell vehicles will not be able to penetrate the market beyond limited, centrally 

fueled fleet programs.

For the U.S. market, most major firms expressed a belief that fuel cell vehicles will 

play a significant role in the longer-term. Several firms expect that this will be in the time 

frame beyond 2025 for the nation as a whole, outside of specific geographic areas (such as 

California) where a refueling infrastructure is being developed. 

Many of the OEMs stated that they were anticipating switching air conditioner (A/C) 

refrigerant from the current R134a (with its high global warming potential, GWP) to the much 

lower HFO1234yf as soon as they could, with most firms projecting this would occur between 

now and approximately 2018. Many OEMs noted, however, that this switch is dependent on 

EPA SNAP approval,

Air conditioning and other technologies

E

With regard to other vehicle technologies, each of the companies had their own suite 

of other technologies that would improve efficiency based on their unique expertise and 

as well as availability and price from suppliers for the new refrigerant. 

Manufacturers noted that these two issues had the potential to delay much of the switchover to 

HFO1234yf, with the period of the delay depending upon the specifics of EPA’s future action 

and how the market place forces play out with respect to the supply and demand for the new 

refrigerant.. 

 

E The Significant New Alternatives Policy (SNAP) Program is EPA's program to evaluate and regulate 

substitutes for the ozone-depleting chemicals that are being phased out under the stratospheric ozone protection 

provisions of the Clean Air Act (CAA). Before any new or substitute refrigerant can be utilized in mobile A/C 

applications, EPA must receive a SNAP submission and reach a determination. If EPA finds the substitute 

acceptable, its use must comply with conditions set forth in the SNAP determination. 
2017-2025 Technical Assessment

2-7 

product plans. These included aerodynamic improvements, friction reduction, further 

reductions in tire rolling resistance, and a number of other technologies that cannot be 

described in detail given confidentiality restrictions. 

Regulatory program design input

Specific company suggestions for the appropriate design of regulatory programs, often 

relating to OEM-specific strategies for coming into compliance under various scenarios and 

their particular desired program flexibilities, were considered to be confidential business 

information by all of the manufacturers. These suggestions varied greatly depending on the 

specific company, as did manufacturers’ plans for future compliance. However, there was 

universal consensus that a national program should continue, and that a single national fleet 

should be able to comply with California and federal GHG standards as well as federal CAFE 

standards. 

 

Several OEMs also discussed the importance of a mid-term technology review which 

would occur after the 2017-2025 standards are promulgated. The May 19, 2010 support 

letters from all of the OEMs and the two major automotive trade associations also supported 

the concept of a mid-term technology review. In addition, several OEMs were supportive of 

the continuation of attribute-based standards and of separate standards for cars and trucks. 

 A number of the automakers provided input on the electrical vehicle charging systems 

needed for EVs and PHEVs. The OEMs generally agreed that most charging will occur at 

home and will be Level 1 or Level 2, with a greater likelihood of Level 2 charging as vehicle 

range and size increases.

Electric vehicle charging systems

F

A number of OEMs also indicated that they believe that federal and state incentives 

are helpful in encouraging charging system development and charge point deployment. In 

addition, stakeholders emphasized that standardization of charging facilities and codes for 

 OEMs suggested that workplace charging, if available, could 

significantly increase the vehicle’s daily driving range (under the assumption the vehicle can 

be charge two times in a day, once at home in the morning, and once at work during the day) 

and may help to increase market appeal of EVs and PHEVs. OEMs also indicated that public 

charging (Level 2 or Level 3 quick charging) could provide additional comfort to EV/PHEV 

owners and may help to facilitate the mass adoption of these vehicles. OEMs also generally 

agreed that costs of electric vehicle service equipment installation will vary widely by the age 

of the house, location of the charging equipment, and difficulty of installation. Some urban 

locations without dedicated parking, such as apartments and townhouses with street parking, 

may present charging challenges. These issues are discussed in more detail in Chapter 4 

below. 

 

F Details regarding EV and PHEV charging levels are included in Chapter 4 of this report. In general, Level 1 

charging uses a lower voltage than Level 2. Level 1 chargers require more time for battery charging than Level 

2. As discussed in Chapter 4, there is also a Level 3 charging approach, sometimes called “quick charging”, 

which uses even higher voltages and takes even less time than Level 1 or Level 2.
Chapter 2

2-8 

installing equipment will streamline and encourage the widespread deployment of charging 

infrastructure and promote the adoption of PHEVs and EVs. Some OEMs also suggested that 

so-called “smart metering” equipment and strategies could enable consumers and utilities to 

choose the best time to charge vehicles for the lowest cost while maintaining maximum 

vehicle availability. 

Not all manufacturers discussed potential impacts on jobs and the U.S. manufacturing 

base, but of those that did, many were optimistic about the opportunities to build fuel-efficient 

cars in the United States and the concurrent boost to the U.S. job market. Most OEMs were 

predicting significant increase in sales after the drop in 2009, and further sales increases into 

2017+, with concomitant increases in U.S. manufacturing jobs. Further, OEMs stated that 

increased technological content in vehicles will likely require more development, testing, and 

additional manufacturing requirements and thus potentially lead to more jobs in the supplier 

chain, both in the U.S. as well as abroad. Several manufacturers noted that Federal 

government stimulus bill investments, as well as additional incentives provided by a number 

of state and local governments, were an important factor in locating manufacturing operations 

for electrification components (including new battery, electric motor, and power electronic 

manufacturing facilities) in the U.S., and that continuation of this type of investment would be 

an important consideration to locating future facilities in the U.S.

Perspectives on US manufacturing and automotive-related jobs

2.2.2 Automotive Suppliers 

EPA, NHTSA and CARB met with a cross section of automotive suppliers to seek 

their input on a number of key technical issues. Suppliers conduct their own research and 

development on a wide variety of automotive products that directly and indirectly influence 

the fuel economy and CO2 emissions of vehicles. The agencies met individually with the 

following companies and associations: Delphi, Bosch, Denso, Borg Warner, Honeywell, 

Valeo, Johnson Controls, A123, BYD, Dupont, the American Iron and Steel Institute and a 

number of their member companies, the Aluminum Transportation Group (a part of the 

Aluminum Association) and a number of their member companies, and the Rubber 

Manufacturers Association and a number of their tire manufacturing company members. We 

note that there are a very large number of automotive suppliers, making it impossible to meet 

with even all of the major companies given the time frame for this technical assessment 

report. The companies and associations with whom we met represent a small but significant 

fraction of these suppliers, given their importance in the market and/or the uniqueness of their 

product offerings. 

The agencies requested input in the following key areas: expected technology 

development status for MYs 2017-2025, cost, effectiveness, and potential limitations of 

technologies, and impact on jobs. In response, as with the automotive OEMs, the supplier 

companies presented detailed technical information to the agencies addressing these topics, 

and requested confidential treatment for much of it. In order to respect these requests for 

confidentiality, the agencies cannot reveal specific details of the business information 

provided at these meetings, but taken in the aggregate, the following summarizes information 

gathered from the supplier meetings. 
2017-2025 Technical Assessment

2-9 

In general, the suppliers were optimistic that supplier-developed advanced 

technologies could play a critical role in 2017-2025 vehicles, and they were actively engaged 

with OEMs for not only application of near-term technologies but also collaborative 

development of production road maps for technologies currently in the R&D phases within 

their organizations. Generally the suppliers stated that future R&D activities would allow 

them to decrease costs, increasing production capacity, and produce innovative solutions for 

OEM needs. However, suppliers also independently discussed some of OEMs key issues — 

such as the potential future penetration and challenges for large market adoption of HEVs, 

PHEVs, EVs, and FCVs. Some suppliers’ cost estimates were more consistent with or even 

lower than the figures used by the agencies in the present analysis. The steel and aluminum 

industry emphasized that weight can be reduced in vehicles without sacrificing safety, 

although the agencies note that the assessment of safety identified by these industries does not 

include the type of detailed aggregate societal impacts assessment that NHTSA and EPA will 

conduct for the upcoming joint Federal rulemaking. 

On the issue of potential job impacts, suppliers strongly supported the recent federal 

funding for advanced battery development. Suppliers stated that this has already led to many 

engineering and manufacturing jobs created in the U.S., in part due to Federal stimulus 

funding, and expressed confidence that this sector will continue to grow. 

On the issue of infrastructure, some of the suppliers did discuss issues regarding 

EV/PHEV vehicle infrastructure. In general, their themes on this topic were consistent with 

what we also heard from the OEMs discussed above.

2.2.3 Non-Governmental Environmental Organizations 

The agencies also received input from numerous environmental organizations, 

including the Natural Resources Defense Council, Union of Concerned Scientists, 

Environmental Defense, Sierra Club, the American Council for an Energy-Efficient Economy, 

Safe Climate Campaign, Environment America, and the National Wildlife Federation. These 

environmental organizations stated that they are very supportive of the President’s call for 

setting new fuel economy and greenhouse gas standards for light-duty vehicles for the 2017-

2025 model years. These groups believe this will help to cut U.S. oil dependency and move 

the nation toward a clean energy economy. The groups stated that they support setting 

standards at the maximum technically feasible level in order to bring new technologies to the 

marketplace, calling on the agencies generally to establish future standards which would push 

efficiency limits on conventional internal combustion engine vehicles, bring hybrids into 

mainstream commercial production, and pull advanced electric-drive vehicles into the market. 

These organizations requested that the agencies establish standards for 2017-2025 which 

would put light-duty vehicles on a path to achieve an 80 percent reduction (from 2005 levels) 

in global warming emissions by 2050. The groups also encouraged EPA and NHTSA to work 

quickly to propose and finalize the new standards. 

The environmental groups emphasized that the rulemaking process be open and 

transparent to the public. They commended the transparency of the process thus far, and 

expect it to be continued moving forward. The environmental groups stated that transparency 

is critical in several specific areas, including manufacturers’ compliance, test data, technology 
Chapter 2

2-10 

costs, modeling of technology adoption (e.g., EPA’s OMEGA model and NHTSA’s Volpe 

model), vehicle safety assessments, assumptions of advanced vehicle adoption, and 

accounting for electric vehicle upstream emissions and other off-cycle factors.

Another issue raised by the environmental groups was the concept of a mid-term 

technology review, as indicated in the auto manufacturers’ letters supporting the President’s 

memorandum. The environmental groups emphasized that any mid-term technology review, 

if conducted, should not undermine innovation, should be very narrow in scope, and be a onetime review after 2020. They stated that a technology review should not create uncertainty 

regarding the requirements established by the agencies, or be considered an “escape route” to 

delaying requirements. They also stated that a technology review may be unnecessary if the 

2017-2025 standards can be achieved by using multiple technology pathways, as opposed to a 

single, “silver-bullet” technology. 

The environmental groups requested that EPA and NHTSA continue to rely on what 

they characterized as reasonable discount rates when evaluating the consumer benefits of fuel 

savings, so as to not undervalue the consumer benefits of higher fuel economy standards. 

The groups reiterated prior arguments that discount rates higher than the 3 and 7 percent rates 

recommended in OMB guidance documents are inappropriate, due to the highly imperfect 

automobile market, with limited information, uncertainty of future gasoline prices, and a 

limited set of options with regard to fuel economy. The groups expressed interest in working 

on the discount rate issue with EPA, NHTSA, and others during the upcoming joint federal 

rulemaking process. 

These groups stated that the standards should rely on an updated and accurate safety 

analysis, consistent with EPA and NHTSA’s discussion of this issue in the final rule for the 

MY2012-2016 standards. The environmental groups stated that their understanding of the 

analysis in the MYs 2012-2016 rule is that vehicle mass reduction can be applied in a way 

that saves lives while also cutting fuel consumption and GHG emissions. The groups 

expressed support for the commitments made by NHTSA in the MYs 2012-2016 final rule, as 

discussed below in Chapter 3, to collaborate with EPA, CARB and the Department of Energy, 

in conducting further safety and mass reduction research. 

Finally, the environmental groups stated that the tailpipe compliance calculation for 

electric-drive vehicles should account for upstream GHG emissions due to electricity and 

hydrogen generation. Their concern is that if manufacturers are allowed to treat EVs (or the 

electric portion of a PHEV) as 0 grams of CO2/mile for compliance purposes, they may be 

able to meet the standards through producing only a small number of electric-drive vehicles, 

while avoiding fuel economy improvements in conventional vehicles. Further discussion of 

this issue is contained in Chapter 7. 

2.2.4 State and Local Government Organizations

The agencies met with representatives from the National Association for Clean Air 

Agencies (NACAA), the Northeast States for Coordinated Air Use Management 

(NESCAUM), and approximately 10 individual state and local governments. The state and 

local organization stressed broad objectives, and generally expressed strong support of the 
2017-2025 Technical Assessment

2-11 

agencies’ efforts to develop a national program for the 2017-2025 timeframe. The states 

emphasized, consistent with California’s letter supporting the Presidential memorandum, that 

the agencies should evaluate a range of potential standards of 3 to 6 percent annual increases 

in stringency for the 2017-2025 time frame. The states expressed a strong preference toward 

the higher stringencies in that range, stating that the standards must be technology forcing in 

order to help them achieve their individual and regional GHG reduction goals. 

The states also strongly supported the collaborative process in which EPA, NHTSA, 

and CARB are engaging in order to assess the technical information going into the 2017-2025 

assessment. Several states mentioned activities they have underway to develop the 

infrastructure needed to support electrified vehicles. The states also expressed support for 

transparency in the process of developing the technical assessment, and the eventual proposed 

rulemaking, and an interest in continued dialogue. 

2.2.5 Infrastructure Providers

The agencies met with representatives from the Electric Power Research Institute 

(EPRI) and charging infrastructure providers. EPRI believes the focus for EV and PHEV 

charging systems should be on home charging, with a goal of a seamless installation process 

(permitting, electrical installation, inspection) for homeowners. However, EPRI recognizes 

that home charging infrastructure is expensive, estimating an average cost of about $1,500 for 

home charging installations. Some charging infrastructure providers see a more important role 

for public charging, which could expand EV/PHEV markets to people who live in apartments, 

condominiums, or otherwise do not have garage access for convenient home charging. EPRI 

believes more work is needed to assess how workplace and public charging infrastructure 

should be developed, both in terms of where to best locate stations for consumers’ 

convenience and who should own the them (e.g., municipalities, private sector, employers, 

utilities). 

EPRI believes that overall electric utilities will be able to support the rollout of EVs 

and PHEVs. However, there is a possibility of isolated impacts on some residential 

transformers, particularly in neighborhoods with older distribution systems. To mitigate these 

potential impacts, EPRI suggests that early notification to the local utilities of EV/PHEV 

charging plans would help the utilities assess any potential need for upgrades to the electric 

power delivery system. EPRI also believes that potential stresses on power delivery systems 

can be mitigated by the wise application of smart charging, which has the potential to even 

out charging loads. Charging infrastructure providers generally agreed with this assessment. 

EPRI is currently examining these issues. 

2.2.6 Labor Unions 

EPA, NHTSA and CEQ met with representatives of the United Auto Workers (the 

UAW). The UAW was supportive of continuing the National Program for 2017 and beyond. 

The UAWs overarching concern was how the future development and market penetration of 

advanced vehicle technologies will impact automotive industry manufacturing employment in 

the United States. The UAW stated their general belief that a high percentage the subsystems and vehicle assembly for hybrid electric vehicles sold in the U.S. today are not 
Chapter 2

2-12 

manufactured in the United States. The UAW is concerned that this trend could continue, and 

that the potential future introduction of plug-in hybrid electric vehicles and electric vehicles in 

addition to the potential future expansion of hybrid electric vehicles could results in an overall 

decline in the automotive manufacturing jobs in the United States. The UAW stated that the 

government funding for advanced technology vehicles had made an important difference in 

the past year, resulting in many companies deciding to manufacturer batteries, electric motors, 

and vehicle assembly plants in the U.S.; the UAW was concerned that without the continued 

economic support from the federal government, future manufacturing facilities for these 

advanced technology vehicles may not occur in the U.S. 

In addition to this important issue, the UAW made two specific requests which they 

would like the federal government to consider in the development of the 2017-2025 joint 

federal rulemaking. The UAW believes it is important for the agencies to analyze and report 

the net domestic employment effects of any future proposed standards. In addition, the UAW 

requested that future regulations include provisions with respect to GHG emissions from 

automobiles other than the CO2 captured by the CAFE program for the eventual integration 

of those emissions regulations with any broader national GHG program that might be 

developed by Congress or that may be proposed by EPA under the Clean Air Act in the 

future. Specifically the UAW was referring to methane, nitrous oxide, and hydroflurocarbon 

emissions, as well as CO2 emissions related to a vehicles air conditioning system operation, 

which is not capture under today’s CAFE test procedures. Finally, the UAW raised some 

concerns with the future projections contained in the Energy Information Administration’s 

Annual Energy Outlook reports and the accuracy of those reports projections regarding future 

improvements in fuel economy absent new standards. 
2017-2025 Technical Assessment

2-13 

Chapter 2 References

13 75 Fed. Reg. 29399 (May 26, 2010).

2017-2025 Technical Assessment

3-1 

3 Technology, Cost, Effectiveness and Lead-time Assessment

3.1 What technologies did the Agencies Consider?

The agencies assume, in this analysis, that manufacturers will add a variety 

technologies to each of their vehicle model platforms in order to improve their fuel economy 

and GHG performance. In order to analyze a variety of regulatory control scenarios (as we 

do in this report), it is thus essential to understand what is feasible within the timeframe of the 

rule. Technical feasibility of potential standards requires a thorough study of the technologies 

available to the manufacturers. This study includes an assessment of the cost, effectiveness, 

as well as the lead time of the technologies. The lead time relates to the availability, 

development time, and manufacturability of the technology within the normal redesign 

periods of a vehicle line (or in the design of a new vehicle). As we describe below, lead time 

issues can in turn affect the cost as well as the technology penetration rate (or caps) that are 

assumed in the analysis. 

The agencies considered over 30 vehicle technologies that manufacturers could use to 

improve the fuel economy and reduce CO2 emissions of their vehicles during the 2017-2025 

timeframe. A majority of the technologies described in this chapter are readily available 

today, are well known, and could be incorporated into vehicles once product development 

decisions are made. These are “near-term” technologies and are identical to those applied in 

the 2012-2016 light-duty rule. Other technologies considered may not currently be in 

production, but are beyond the initial research phase, under development and are expected to 

be in production in the next few years. These are technologies which can, for the most part, 

be applied both to cars and trucks, and which are capable of achieving significant 

improvements in fuel economy and reductions in CO2 emissions at reasonable costs in the 

2017 to 2025 timeframe. The agencies did not consider technologies that are currently in an 

initial stage of research because of the uncertainty involved in the lead time available to 

implement the technologies with significant penetration rates for this assessment. 

3.2 How did the Agencies Determine the Costs and Effectiveness of Each of These 

Technologies?

3.2.1 How are Cost and Effectiveness Estimates Different from the 2012-2016 Rule? 

Virtually all of the technologies considered in this analysis are identical to those 

described in the 2012-2016 light-duty CAFE and GHG final rule. Those that are new or 

modified are described in greater detail in this chapter. In general, the costs of fuel 

consumption improvement technologies considered in this assessment are taken straight from 

the 2012-2016 light-duty CAFE and GHG final rule, with six exceptions that impact 

individual technology costs in different ways. The first exception is that the agencies have 

reconsidered the costs for several technologies for which extensive tear-down studies were 

completed during development of the MYs 2012-2016 final rule. These teardown studies 

were conducted under the continuing EPA contract with FEV and Munro in support of that 

rulemaking and were discussed in detail in the Technical Support Document.14 The second
Chapter 3

3-2 

exception is that the agencies have reconsidered the costs for hybrid electric vehicles (HEV), 

plug-in hybrid (PHEV), electric vehicles (EV), and fuel cell electric vehicles (FCEV), due in 

part to the rapid changes taking place in battery technology and cost estimation methods 

based on the expert judgment of the Department of Energy (DoE), EPA, CARB, and NHTSA 

and using updated costs as compared to the 2012-2016 light-duty rule. The third exception is 

that the agencies have updated the cost for mass reduction based on more recent studies. The 

fourth exception is that the indirect cost markups (ICM) used in the 2012-2016 light-duty 

rulemaking and have added an additional factor of 0.06 to each. This factor has been added to 

reflect return on capital of 6% in the automotive industry, described further below.15

Most of the effectiveness numbers of the technologies have also not changed from the 

previous final rule. The few changes that were made are also described below. The agencies 

are pursuing additional work to update the effectiveness of virtually all of the technologies 

listed in this chapter. 

 The fifth 

exception is that cost estimates have been updated to reflect 2008 dollars while the 2012-2016 

light-duty rule expressed costs in terms of 2007 dollars. This update was done using a ratio of 

GDP price deflators in a manner consistent with the procedure used in the 2012-2016 lightduty rule. The sixth exception is that learning effects have been allowed to continue beyond 

the 2016 model year so that the individual piece costs in the 2017 and later model years will, 

in general, be lower than the costs estimated for the 2012-2016 model years. We note, 

however, that the type of learning – volume-based or time-based, as described in the 2012-

2016 light-duty rule – has not changed. Each of these exceptions is discussed in more detail 

below and in Appendix B. 

3.2.2 Costs from Tear-down Studies 

The agencies have updated costs of certain technologies that had been based on teardown studies conducted during the 2012-2016 rulemaking. The agencies believe that the best 

method to derive technology cost estimates is to conduct studies involving tear-down and 

analysis of actual vehicle components. A “tear-down” involves breaking down a technology 

into its fundamental parts and manufacturing processes by completely disassembling vehicles 

and vehicle subsystems and precisely determining what is required for its production. More 

details about tear down studies can be found in the studies supporting the 2012-2016 lightduty rule as well as the FEV and Munro Associates report for EPA.16,17

To-date, such tear-down studies have been completed on the six technologies listed 

below. These completed tear-down studies provide a thorough evaluation of the component 

or system cost relative to their baseline (or replaced) technologies. A more detailed 

description of these technologies can be found in the Technical Support Document prepared 

for the 2012-2016 light-duty final rule.

 This tear-down 

method of costing technologies is often used by manufacturers to benchmark their products 

against competitive products. Historically, vehicle and vehicle component tear-down has not 

been done in large scale by researchers and regulators due to the expense required for such 

studies. 

14 For these technologies, the agencies have relied on 

the tear-down data available and scaling methodologies used in EPA’s ongoing study with 

FEV. Note, this costing methodology has been published and has been peer reviewed. 18
2017-2025 Technical Assessment

3-3 

1. StoichiometricG

2. Stoichiometric gasoline direct injection and turbo charging with engine 

downsizing for a SOHC (single overhead cam) 3 valve/cylinder V8 engine to a 

SOHC V6 engine. 

 gasoline direct injection and turbo charging with engine 

downsizing (T-DS) for a large DOHC (dual overhead cam) 4 cylinder engine to a 

smaller DOHC 4 cylinder engine.

3. Stoichiometric gasoline direct injection and turbo charging with engine 

downsizing for a DOHC V6 engine to a DOHC 4 cylinder engine. 

4. 6-speed automatic transmission replacing a 5-speed automatic transmission.

5. 6-speed wet dual clutch transmission (DCT) replacing a 6-speed automatic 

transmission.

 In addition, FEV and EPA extrapolated the engine downsizing costs for the following 

scenarios that were based on the above study cases: 

1. Downsizing a SOHC 2 valve/cylinder V8 engine to a DOHC V6. 

2. Downsizing a DOHC V8 to a DOHC V6.

3. Downsizing a SOHC V6 engine to a DOHC 4 cylinder engine. 

4. Downsizing a DOHC 4 cylinder engine to a DOHC 3 cylinder engine.

In the 2012-2016 light-duty rule, the agencies relied on the findings of FEV in part for 

estimating the cost of these technologies. However, for some of the technologies, NHTSA 

and EPA modified FEV’s actual estimated costs. This was done because FEV based their 

costs on the assumption that these technologies would be mature when produced in large 

volumes (450,000 units or more). The agencies believed that there was some uncertainty 

regarding each manufacturer’s near-term ability to employ the technology at the volumes 

assumed in the FEV analysis with fully learned costs. There was also the potential for near 

term (earlier than 2016) supplier-level Engineering, Design and Testing (ED&T)H costs to be 

in excess of those considered in the FEV analysis because existing equipment and facilities 

need to be converted to the production of new technologies and may lead to stranded capital I

 

G Stoichiometric Gasoline Direct Injection refers to a gasoline fueled spark-ignition internal combustion engine 

with direct fuel injection into the combustion chamber that is designed to operate primarily at a chemically 

balanced ratio of air and fuel thus allowing the effective use of standard precious-metal based (Rh combined 

with Pd and/or Pt) three-way exhaust catalysts for control of criteria pollutants 

if done too rapidly. The agencies consider the FEV results to be generally valid for the 2017-

2025 timeframe because the factors considered in the 2012-2016 light-duty rule should no 

longer exist and sales volumes of 450,000 units are likely due to, at least in part, the new 

GHG and fuel economy requirements. More detail on which specific technologies are 

H Product Development Costs are the ED&T costs incurred for development of a component or system. These 

costs can be associated with a vehicle specific application and/or be part of the normal research and development 

(R&D) performed by companies to remain competitive. In the cost analysis, the product development costs for 

suppliers are included in the mark-up rate as ED&T suppliers. I

Stranded Capital is defined as manufacturing equipment and facilities owned by a vehicle manufacturer that 

cannot be used in the production of a new technology.
Chapter 3

3-4 

impacted by this change is presented in Appendix B. The agencies will continue to review the 

FEV results and methodology as necessary in the upcoming federal rulemaking. 

3.2.3 Costs of HEV, PHEV, EV, and FCEV 

The agencies have also reconsidered the costs for HEVs, PHEVs, EVs, and FCEVs as 

the result of two issues: The first issue is that there is a rapid development taking place on 

electrified vehicle technologies and an effort has been made to capture the results from the 

most recent analyses. The second issue is that the 2012-2016 rule employed a single $/kWhr 

estimate and did not consider the specific vehicle and technology application for the battery 

when we estimated the cost of the battery. Specifically, batteries used in HEVs versus EVs 

need to be considered appropriately to reflect the design differences and differences in cost 

per kW-hr as the power to energy ratio of the battery changes for different applications. For 

this assessment, the agencies have used a battery cost model developed by Argonne National 

Laboratory (ANL) for the Vehicle Technologies Program of the U.S. Department of Energy 

(DoE) Office of Energy Efficiency and Renewable Energy. The model developed by ANL 

provides unique battery pack cost estimates for each of the three major types of electrified 

vehicles. The DoE has established long term industry goals and targets for advanced battery 

systems as it does for many energy efficient technologies. ANL was funded by DoE to 

provide an independent assessment of Li-ion battery costs because of their expertise in the 

field as one of the primary DoE National Laboratories responsible for basic and applied 

battery energy storage technologies for future HEV, PHEV and EV applications. A basic 

description of the ANL Li-ion battery cost model and initial modeling results for PHEV 

applications were published in a peer-reviewed technical paper presented at EVS-2419. ANL 

has extended modeling inputs and pack design criteria within the battery cost model to 

include analysis of manufacturing costs for EVs and HEVs as well has PHEVs.20

The agencies have decided to use the ANL model for estimating large-format lithiumion batteries for this assessment for the following reasons. The ANL model has been 

described and presented in the public domain and does not rely upon confidential business 

information (which would therefore not be reviewable by the public). The model was 

developed by scientists at ANL who have significant experience in this area. The model uses 

a bill of materials methodology which the agencies believe is the preferred method for 

developing cost estimates. The ANL model appropriately considers the vehicle applications 

power and energy requirements, which are two of the fundamental parameters when designing 

a lithium-ion battery for an HEV, PHEV, or EV. The ANL model can estimate 

 A complete 

peer-review of the model and its inputs and results for HEV and EV applications is pending, 

and ANL expects to have a peer review completed within 1 year. NHTSA and EPA will 

consider the results of the peer review as we develop the future joint federal notice of 

proposed rulemaking. The agencies expect to continue to work with DOE and ANL (as well 

as battery manufacturers, OEMs, and other stakeholders) to get the most up to date 

information for the upcoming NPRM. 

high volume

production costs, which the agencies believe is appropriate for the 2025 time frame. Finally, 

the ANL model’s cost estimates, while generally lower than the estimates we received from 

the OEMs, is consistent with some of the supplier cost estimates the agencies received from 

large-format lithium-ion battery pack manufacturers. A portion of the data was received from 

on-site visits done by the EPA. 
2017-2025 Technical Assessment

3-5 

The ANL battery cost model is based on a bill of materials approach in addition to 

specific design criteria for the intended application of a battery pack. The costs include 

materials, manufacturing processes, the cost of capital equipment, plant area and labor for 

each manufacturing step as well as the design criteria include a vehicle application’s power 

and energy storage capacity requirements, the battery’s cathode and anode chemistry, and the 

number of cells per module and modules per battery pack. The model assumes use of a 

laminated multi-layer prismatic cell and battery modules consisting of double-seamed rigid 

containers. The model also assumes that the battery modules are air-cooled. The model takes 

into consideration the cost of capital equipment, plant area and labor for each step in the 

manufacturing process for battery packs and places relevant limits on electrode coating 

thicknesses and other processes limited by existing and near-term manufacturing processes. 

The ANL model also takes into consideration annual pack production volume and economies 

of scale for high-volume production.

The cost outputs from the ANL model used by the Agencies to determine 2025 HEV, 

PHEV and EV battery costs were based upon 500,000 packs/year production volume and the 

use of a common cathode and anode chemistry, LiMn2O4-spinel for the cathode and graphite 

for the anode. The agencies assumed a change in battery state of charge (% SOC) of 50% for 

HEVs, 70% for PHEVs and 80% for EVs in 2025. The agencies also estimated 2020 HEV, 

PHEV and EV battery costs based upon the same battery chemistry and a production volume 

of 100,000 packs/year. EPA considered one other battery chemistry, LiFePO4-graphite. While 

it is expected that other Li-ion battery chemistries with higher energy density, higher power 

density and lower cost will likely be available in the 2017-2025 timeframe, the specific 

chemistry used for the cost analysis was chosen due to its known characteristics and to be 

consistent with publicly available information on current and near term HEV, PHEV and EV 

product offerings from Hyundai, GM and Nissan.21,22,23,24

Table 3.2-1

 The cost of active materials is 

somewhat higher for LiMn2O4-spinel than for LiFePO4, but battery pack costs are generally 

higher for LiFePO4 when comparing battery packs with the same energy and power 

requirements. This is due primarily to the lower energy density of LiFePO4 relative to 

LiMn2O4-spinel. We expect that incremental improvements in battery energy density will 

continue through 2025 and thus the higher energy density represented by the choice of a 

LiMn2O4-spinel cathode/graphite anode within the ANL cost model is more appropriate for 

determining the future cost of batteries in the 2017-2025 timeframe. Examples of the cost 

outputs from the ANL model used by the agencies in this analysis are shown in 

and Table 3.2-2. A more detailed discussion of battery pack costs is contained in Appendix 

B. The agencies note that costs used in the analysis are lower than the costs generally 

reported in stakeholder meetings, which ranged from $300/kW-hour to $400/kW-hour range 

for 2020 and $250 to $300/kW-hour range for 2025. Because of uncertainty with regard to 

future battery costs, the agencies also conducted a sensitivity study using PHEV and EV 

battery pack costs approximately $100/kW-hr higher and $50/kW-hr lower than the costs 

estimates from the ANL battery cost model. Further details regarding the sensitivity analysis 

are described Chapter 6 of this report and in Appendix B, section B4.2.1.3. 
Chapter 3

3-6 

Table 3.2-1: Direct Manufacturing Costs on a $/kWh-basis for Large Car HEVs, PHEVs 

and EVs (2008 dollars, markups not included).

Application Direct Manufacturing Cost, MY2020

(100,000 packs/year volume)

Direct Manufacturing Cost, MY2025

(500,000 packs/year volume)

$ $/kW-hr $ $/kW-hr

P2 HEV Battery Pack $801 $1,214 $641 $971

PHEV20 Battery Pack $2,916 $324 $2,333 $259

PHEV40 Battery Pack $4,285 $238 $3,428 $190

EV75 Battery Pack $5,847 $217 $4,678 $173

EV100 Battery Pack $7,443 $191 $5,954 $153

EV150 Battery Pack $11,005 $175 $8,804 $140

Table 3.2-2: Direct Manufacturing Costs on a $/kWh-basis for subcompact HEVs, 

PHEVs and EVs (2008 dollars, markups not included). 

Application Direct Manufacturing Cost, MY2020

(100,000 packs/year volume)

Direct Manufacturing Cost, MY2025

(500,000 packs/year volume)

$ $/kW-hr $ $/kW-hr

P2 HEV Battery Pack $541 $1,177 $433 $941

PHEV20 Battery Pack $2,187 $347 $1,749 $278

PHEV40 Battery Pack $3,244 $251 $2,595 $201

EV75 Battery Pack $4,013 $197 $3,211 $157

EV100 Battery Pack $5,143 $184 $4,115 $147

EV150 Battery Pack $7,666 $170 $6,133 $136

The potential for future reductions in battery cost and improvements in battery 

performance will play a major role in determining the overall cost and performance of future 

PHEVs and EVs. The U.S. Department of Energy manages major battery-related R&D 

programs and partnerships, and has done so for many years, including the ANL model utilized 

in this report. DOE has reviewed the battery cost projections underlying today’s TAR. DOE 

supports the cost projections, and while the overall projections are in some cases optimistic, 

DOE believes they are reasonable for a long-term, technology-based assessment as utilized in 

this report. In addition, as discussed above, DOE intends to work with ANL to ensure the 

ANL model undergoes a thorough peer review. Finally, DOE recommends that the agencies 

consider evaluating a range of assumptions for rulemaking, including the evaluation of other 

battery cost estimation models as appropriate. NHTSA and EPA intend to conduct additional 

analysis for the NPRM and final rule that is consistent with these recommendations from 

DOE. 

The agencies have also carefully reconsidered the power and energy requirements for 

each electrified vehicle type, which has a significant impact on the cost estimates for HEVs, 

PHEVs, and EVs as compared to the estimates used in the 2012-2016 rulemaking. In 

addition, the agencies have considered battery pack costs separately from the remainder of the 

systems added to each type of electrified vehicle. The advantage of separating the battery 

pack costs from other system costs is that it allows each to carry unique indirect cost 
2017-2025 Technical Assessment

3-7 

multipliers and learning effects which are important given that battery technology is an 

emerging technology, while electric motors and inverters are more stable technologies. We 

note that, for this analysis, the agencies have assumed batteries will be capable of lasting the 

lifetime of the vehicleJ

A P2 hybrid is a vehicle with an electric drive motor coupled to the engine crankshaft 

via a clutch. The engine and the drive motor are mechanically independent of each other, 

allowing the engine or motor to power the vehicle separately or combined. This is similar to 

the Honda HEV architecture with the exception of the added clutch, and larger batteries and 

motors. Examples of this include the soon-to-be sold Hyundai Sonata, Elantra and the Nissan 

Fuga (expected to be rebadged as an Infiniti product for the North American market). The 

agencies believe that the P2 is an example of a “strong” hybrid technology that is typical of 

what we will see in the timeframe of this rule. The agencies could have equally chosen the 

power-split architecture as the representative HEV architecture. These two HEV’s have 

similar average effectiveness values (combined city and highway fuel economy), though the 

P2 systems may have lower cost due to the lower number of parts and complexity. 

, which is consistent with what manufacturers have shared with us are 

the expected customer demands from this technology. Manufacturers have acknowledged, 

however, that there may be some performance degradation in the batteries over time. For the 

NPRM, the agencies may analyze the maintenance cost differences among technologies, 

including batteries. Lastly, the agencies have focused attention on an emerging HEV 

technology known as a P2-hybrid, a technology not considered in the 2012-2016 light-duty 

rule. 

The effectiveness used for vehicle packages with the P2-hybrid configuration within 

this analysis reflects a conservative estimate of system performance. Vehicle simulation 

modeling of technology packages using the P-2 hybrid configuration is currently underway 

under contract with Ricardo Engineering. The agencies plan to update the effectiveness of 

hybrid electric vehicle packages using the new Ricardo vehicle simulation modeling runs 

prior to the NPRM. 

The agencies have also considered, for this analysis, the costs associated with in-home 

chargers expected to be necessary for PHEVs and EVs. Further details on in-home chargers 

and their estimated costs are presented in Section 4.2.3 and Appendix B. Details of the 

updated HEV, PHEV, EV and FCEV costs are presented in Appendix B. 

3.2.4 Mass Reduction Impacts and Costs 

Mass reduction encompasses a variety of techniques ranging from improved design, and 

increased component integration to the application of lighter and higher-strength materials. 

Initial mass reduction can be further compounded by reductions in engine power and ancillary 

systems (transmission, steering, brakes, suspension, etc.) to provide increased vehicle mass 

reduction overall. The agencies recognize there is a wide diversity and range of complexity 

 

J Median life of a passenger vehicle is 13.8 years and 14.5 years for light trucks. Lu, S., NHTSA, Regulatory 

Analysis and Evaluation Division, “Vehicle Survivability and Travel Mileage Schedules,” DOT HS 809 952, 8-

11 (January 2006). Available at http://www-nrd.nhtsa.dot.gov/Pubs/809952.pdf (last accessed March 1, 2010).
Chapter 3

3-8 

for mass reduction and material substitution technologies, and that there are many techniques 

that automotive and other industry suppliers and manufacturers are using or plan to use to 

achieve the levels of this technology that the agencies model in our analysis. Manufacturers’ 

opinions in stakeholder meetings over the summer varied widely as to how much mass 

reduction could be realized and at what cost in the time frame of 2017-2025, ranging from 

some mass increase to 10-15 percent mass reduction. While the agencies limited the amount 

of mass reduction in our analysis for the MYs 2012-2016 final rule to 10 percent, for the 

purposes of this Technical Assessment Report the agencies have considered three levels of 

mass reduction that could be achieved in 2025 compared to a baseline 2008 vehicle: one 

pathway with less aggressive mass reduction of 15 percent, one with 20 percent mass 

reduction, and one with technology forcing mass reduction of 30 percent. The agencies 

assume, as part of these reduction amounts, that vehicle size and full functionality are 

maintained. We note the ability of the industry to reduce mass beyond 20% while 

maintaining vehicle size and functionality is an open technical issue, which the agencies are 

carefully evaluating and will continue to as we move forward. We also note, as discussed in 

the MYs 2012-2016 final rule, that the agencies believe that the effects of vehicle mass 

reduction on safety should be evaluated from a societal perspective (including an analysis or 

fatalities and casualties), which could affect the maximum levels used for rulemaking. This 

analysis has not been included in this report. NHTSA and EPA will include a thorough safety 

assessment of mass reduction for the upcoming joint federal NPRM and final rule. 

With respect to the feasibility of reducing mass by 15-30 percent by 2025, the 

agencies discussed the application of mass reduction technologies at length in meetings with 

vehicle manufacturers in preparation for this Technical Assessment Report. One of the 

challenges the manufacturers identified with respect to mass reduction was the feasibility of 

substituting some lower density materials for higher density materials. These material 

substitution issues included material availability, forming, joining, painting, corrosion, 

reparability, and impact performance. The agencies have established a collaborative team 

among DOT/NHTSA, DOE and EPA to address vehicle mass reduction and mass/safety 

issues generally, and have undertaken work on several tasks to begin addressing these 

particular issues identified by the manufacturers, including 1) a peer review of the Lotus 

Engineering report25 regarding holistic vehicle mass reduction opportunities, 2) a 2nd phase of 

analysis by Lotus Engineering using computer aided engineering (CAE) to assess phase 1 

designs for functional and safety performance, to modify designs as necessary to achieve 

performance levels similar to the baseline vehicle, and to determine the mass reduction that is 

feasible, 3) a DOE funded project investigating the amount of mass reduction that is 

technologically feasible, and 4)a DOE funded project consisting of an actual vehicle build 

(Multi Material Vehicle – MMVK

 

K DOE Notice of Intent to Issue Funding Opportunity Announcement N.:DE-FOA-000239. 

http://www.netl.doe.gov/business/solicitations/NOTICE%20OF%20INTENT.pdf

). NHTSA and EPA may fund other studies to explore the 

feasible amount of mass reduction and cost for MY 2017-2025 separately from the study 

contracted to Lotus engineering by CARB. Computer Aided Engineering (CAE) tools would 

be used to analyze the structure of the vehicle. The proposed design should meet at least the 
2017-2025 Technical Assessment

3-9 

same functional objectives as the baseline vehicle. If funded, this study would be finished in 

time for the final rule for MYs 2017-2025. 

With respect to cost, in the MYs 2012-2016 final rule, NHTSA and EPA applied a 

cost of $1.32 per pound of mass reduction, and the limit of mass reduction (penetration cap) 

was set to 10%14. This cost estimate was based on three studies: 2002 NAS report26, Sierra 

Research27, and MIT28. For the purposes of this Technical Assessment Report, however, the 

agencies expect based on the meetings this summer with OEMs, that manufacturers will be 

capable of mass reduction levels greater than 10 percent net in the 2017-2025 timeframe. The 

agencies recognize that higher percentages of mass reduction may result in higher costs and 

that these costs are likely to increase non-linearly with increasing mass reduction levels. 

Furthermore, the agencies and OEMs also recognize that there is some initial amount of mass 

reduction which can be accomplished with zero or very little cost (much lower than that 

estimated in the 2012-2016 rule). Thus, in this report, the agencies have begun updating their 

mass reduction cost model to reflect this progressively increasing level of cost. A preliminary 

non-linear cost model employed for this current analysis is shown in the figure below. The 

figure shows the present cost model in comparison to the costs used for the 2012-2016 final 

rule. The agencies have relied on a parabolic shape for the cost curve – where the cost per 

pound increases as the square of the percentage mass reduction. The endpoint of the model is 

based on an average of the final rule costs and the results from the Lotus Engineering mass 

reduction study. A more complete description of how this cost model was developed is 

described in Appendix B. For the purposes of the upcoming federal rulemaking, the agencies 

intend to improve the model using additional studies that are expected to be complete before 

the NPRM and final rule – the agencies do not intend for this preliminary model to be the 

final cost model used. The federal interagency mass/safety team has initiated several work 

tasks to inform and update the cost model, including meeting with vehicle manufacturers, 

updating DOE’s 2007 study on feasibility and cost, and EPA funding a 3rd party cost 

assessment of the Lotus Report. 
Chapter 3

3-10 

Figure 3.2-1: Mass Reduction Cost Model in Dollars per Pound in Model Year 2020 

Compared to the Lotus Results and 2012-2016 Final Rule Cost.

With respect to the effects of net vehicle mass reduction amounts of 15-30 percent on 

overall societal safety, the federal interagency mass/safety group has been meeting several 

times a week since shortly after the MY 2012-2016 rule was released to coordinate study of 

the effects of mass reduction and vehicle size on societal safety. This work will be used to 

update the safety model for future federal rulemaking. The agencies are conducting several 

statistical studies using a common database with updated historical crash data (MY 2000-

2007 FARS data, common state accident data and updated vehicle attributes). The studies 

include an updated NHTSA study of the relationship between vehicle mass, size and safety, 

two separate DOE funded fatality and casualty vehicle mass, size and safety analyses to be 

performed by Lawrence Berkeley National Laboratory, and peer reviews of the 

methodologies used in over 20 significant reports published. 

NHTSA is also looking into conducting two additional studies of crash compatibility 

that may help inform the effects of mass reduction and design on societal safety. If 

conducted, these studies may use vehicle models developed for the CARB funded Lotus 

phase 2 study and/or the potential NHTSA and EPA study for the feasible amount of mass 

reduction and cost for MY 2017-2025. These studies may inform how designs that 

incorporate lower density or higher strength materials, meet FMVSS regulations, and 

perform well in NCAP and IIHS tests, affect vehicle crash compatibility. The findings may 

be used to help inform the effects of mass reduction on societal safety. Because this study 

$(2.50)

$(2.00)

$(1.50)

$(1.00)

$(0.50)

$-

$0.50 

$1.00 

$1.50 

0% 5% 10% 15% 20% 25% 30% 35% 40%

$ per pound Cost (w/o ICM)

% Mass Reduction

Lotus Results

2012-2016 Cost Model

2017-2025 Cost Model
2017-2025 Technical Assessment

3-11 

cannot begin until the Lotus or NHTSA/EPA studies have been completed, and this study 

requires significant modeling work, there is some risk the study will not be completed in time 

to inform a final rule.

3.2.5 Indirect Cost Multipliers

Since the 2012-2016 rulemaking, the agencies have reconsidered the indirect cost 

multiplier approach and believe it to be more appropriate to include in the ICM a factor to 

reflect return on invested capital. In the automotive industry, this is on the order of 6%.29

Table 3.2-3

 To 

account for this, the agencies added a 0.06 factor added to the ICMs used in the rulemaking. 

These values are shown in . A note of clarification on the table, the low, medium 

and high complexity levels are meant to account for the complexity of integrating a 

technology into a vehicle. For example, adding variable valve timing to an engine is 

relatively not difficult and, for that reason, we would consider it a low complexity technology. 

By contrast, converting to a hybrid powertrain is considerably more complex to do and, for 

that reason, we would consider it a high complexity technology. The indirect costs are higher 

for the high complexity technology given the higher level of effort (and therefore costs) that 

would be incurred to implement the technology. The near term and long term values reflect 

the way that indirect costs are expected to change over time as new technologies are 

implemented. In the near term, the indirect costs are highest because the development effort 

is underway, the warranty costs are higher, etc. In the long term, many of these costs are no 

longer attributable to regulatory changes and, therefore, are no longer applied. Similarly, the 

warranty costs, while still present, have come down because the technology has achieved 

mature status and those costs have returned to an average level. For this assessment, the near 

term and long term cutoff points are different for different technologies. In short, 

conventional gasoline technologies are considered long term beginning in 2017, hybrid 

technologies are considered long term beginning in 2020, advanced gasoline technologies and 

both range extended and full electric vehicles are considered long term beginning in 2022. 

Table 3.2-3 Comparison of Indirect Cost Multipliers used in the 2012-2016 Rulemaking 

versus this Assessment Report

Complexity 2012-2016 Rulemaking Assessment Report

Near term Long term Near term Long term

Low 1.11 1.07 1.17 1.13

Medium 1.25 1.13 1.31 1.19

High 1 1.45 1.26 1.51 1.32

High 2 1.64 1.39 1.70 1.45

For this analysis, the indirect costs are estimated by applying indirect cost multipliers 

(ICM) to direct cost estimates. ICMs were developed by EPA during the 2012-2016 lightduty rulemaking as a basis for estimating the impact on indirect costs of individual vehicle 

technology changes that would result from regulatory actions. Separate ICMs were derived 

for low, medium, and high complexity technologies, thus enabling estimates of indirect costs 

that reflect the variation in research, overhead, and other indirect costs that can result from the 

application of various technologies in direct response to a regulatory action. 
Chapter 3

3-12 

Previous NHTSA and EPA rulemakings applied a retail price equivalent (RPE) factor 

to estimate indirect costs and mark up direct costs to the retail level. Retail Price Equivalents 

are estimated by dividing the total revenue of a manufacturer by their direct manufacturing 

costs. As such, it includes all forms of indirect costs for a manufacturer, regardless of 

whether all of those costs change in response to the regulatory action and assumes that the 

ratio applies equally for all technologies. ICMs, in contrast, are based on RPE estimates that 

are then modified to reflect only those elements of indirect costs that would be expected to 

change in response to a regulatory action. For example, warranty costs would be reflected in 

both RPE and ICM estimates since new technologies, whether added in response to a 

regulatory action or other reason, will almost always incur some level of warranty expense. 

In contrast, marketing costs might only be reflected in an RPE estimate and not an ICM 

estimate for a particular technology if the new technology added in response to a regulatory 

action is not one expected to be expressly marketed to consumers. Because the ICMs 

developed for the 2012-2016 rulemaking are for individual technologies, many of which are 

relatively simple to implement (e.g., variable valve timing), they often reflect a subset of RPE 

costs; as a result, the RPE is typically higher than an ICM. This is not always the case, as 

ICM estimates for complex technologies may reflect higher than average indirect costs due 

perhaps to increased R&D and/or integration demands, with the resulting ICM larger than the 

averaged RPE for the industry. 

Precise association of ICM elements with individual technologies based on the varied 

accounting categories in company annual reports is difficult. Hence, there is a degree of 

uncertainty in the ICM estimates. The agencies are continuing to study ICMs and the most 

appropriate way to apply them, and it is possible revised ICM values may be used for the 

upcoming NPRM. For that reason, the agencies have considered the range of data in the 

survey responses used to develop the ICMs used in the 2012-2016 rule.30

As mentioned earlier, the agencies have also conducted some sensitivity surrounding 

the issue of battery costs. A more complete discussion of this is presented in Chapter 6. 

 The survey data 

showed a standard deviation of 0.14 to 0.21 on the short term ICMs against average values 

ranging from 1.16 (for the low ICM) to 1.64 (for the high ICM). The coefficient of variance 

(the standard deviation divided by the average) would then be roughly 12% for the low ICM 

and 13% for the high ICM. Based on these results, the ICM values could range from 13% 

lower to 13% higher than the primary ICM values. Using the range of cost estimates 

presented in Chapter 6 for future potential scenarios, this range of ICMs could result in an 

approximate change in 2025 costs between +/- $100 to as much as +/- $450, depending on the 

overall level of the 2025 targets analyzed. 

3.2.6 Cost Adjustment to 2008 Dollars 

As noted above, the costs presented in the 2012-2016 rule have been updated from 

2007 dollars to 2008 dollars using the Gross Domestic Product (GDP) Price Deflator. The 

GDP Price Deflator is one means of adjusting the value of the dollar in different years. The 

data we have used, which is indexed to 2005, shows that it takes $1.062 in 2007 dollars and 

$1.085 in 2008 dollars to purchase a $1 item in 2005.31 Therefore, we have adjusted all of 

the 2012-2016 costs, valued in 2007 dollars, by a factor of 1.022 (1.085/1.062) to express 

costs in 2008 dollars. 
2017-2025 Technical Assessment

3-13 

3.2.7 Costs Effects due to Learning 

The agencies have also reconsidered learning effects. For this assessment, we 

continue to reflect the phenomenon of volume-based learning curve cost reductions in our 

modeling using two algorithms – “volume-based” for newer technologies and “time-based” 

for mature technologies. The observed phenomenon in the economic literature which supports 

manufacture learning cost reductions are based on reductions in costs as production volumes 

increase, and the economic literature suggests these cost reductions occur indefinitely, though 

the absolute magnitude of the cost reductions decrease as production volumes increase (with 

the highest absolute cost reduction occurring with the first doubling of production).32

3.2.8 Cooled EGR Cost and Effectiveness

 The 

agencies use the terminology “volume-based” and “time-based” to distinguish among newer 

technologies and more mature technologies, and how we apply learning cost reductions in our 

assessment. Our volume-based learning algorithm applies for the early, steep portion of the 

learning curve and is estimated to result in 20 percent lower costs after two full years of 

implementation (i.e., a 2014 MY cost would be 20 percent lower than the 2012 and 2013 

model year costs for a new technology being implemented in 2012). Our time-based learning 

algorithm applies for the flatter portion of the learning curve and is estimated to result in 3 

percent lower costs in each of the five years following first introduction of a given 

technology. Once two volume-based learning steps have occurred (for technologies having 

volume-based learning applied), time based learning would begin. For technologies to which 

time based learning is applied, learning would begin in year 2 at 3 percent per year for 5 

years. Beyond 5 years of time-based learning at 3 percent per year, 5 years of time-based 

learning at 2 percent per year, then 5 at 1 percent per year become effective. Going forward, 

the agencies intend to investigate industry learning curves in more detail including to what 

extent “volume-based” and “time-based” come from the same observed phenomenon and 

whether learning should continue to be applied indefinitely, or whether cost reductions due to 

learning should go to zero after some period of time. The learning curve used in this 

assessment may be modified for the rule making. 

While not considered in the 2012-2016 light-duty rule, the agencies have considered 

an emerging technology referred to as cooled exhaust gas recirculation (cooled-EGR) as 

applied to downsized, turbocharged GDI engines. The agencies have considered this 

technology as an advanced gasoline technology since, as noted, it is emerging and not yet 

available in the light-duty gasoline market. While a cooled or “boosted” EGR technology was 

discussed in the 2012-2016 light-duty rule, the technology considered here is comparatively 

more advanced than the one considered previously, and as such, the agencies have considered 

new costs and new effectiveness values for it. The details behind those updated costs and 

effectiveness values are presented in Appendix B. The effectiveness values used for vehicle 

packages with cooled EGR within this analysis reflect a conservative estimate of system 

performance at approximately 24-bar BMEP. Vehicle simulation modeling of technology 

packages using the more highly boosted and downsized cooled EGR engines (up to 30-bar 

BMEP) with dual-stage turbocharging is currently underway as part of EPA’s contract with 

Ricardo Engineering as described below. The agencies plan to update the effectiveness of 

vehicle packages with cooled EGR using the new Ricardo vehicle simulation modeling runs 

prior to the NPRM. 
Chapter 3

3-14 

3.2.9 HEV Effectiveness

At time of this publication, the effectiveness of HEVs requiring equivalent towing 

capacity to their traditional, gasoline powered counterpart (large pick-up trucks for example) 

is similar to those used in the 2012-2016 light-duty rule for vehicles. For several other 

subclasses, the agencies increased HEV effectiveness by approximately 2% based on 

published data for new HEVs that have entered production since the last study was complete 

(including the new Toyota Prius, Ford Fusion hybrid and othersL

). In addition, for the Large 

Car, Minivan and Small Truck subclasses, the agencies further increased HEV effectiveness 

by assuming that towing capacity could be reduced from their current ratingM to 

approximately 1,500 pounds for some vehicles in these subclasses without significantly 

impacting consumers’ need for utility in these vehicles.N The agencies believe that the 

towing capacity in these HEV classes was maintained at an overly stringent performance level 

in the technical analysis of the 2012-2016 rule. The agencies believe that consumers who 

require higher towing capacity could acquire it by purchasing a vehicle with a more capable 

non-hybrid powertrain (as they do today).O

A reduction in towing capacity allows greater engine downsizing, which increases 

estimated overall HEV system incremental effectiveness by 5 to 10 percent and brings 

estimated absolute HEV system effectiveness to approximately 30 percent for Large Cars, 

Minivans, and Small Trucks, similar to the HEV effectiveness value assumed for Small Cars 

and Compact Cars.

 Moreover, it is likely that some fraction of 

consumers who purchase the larger engine option do so for purposes of hauling and 

acceleration performance, not just maximum towing. 

P

 

L The agencies will continue to evaluate hybrid effectiveness estimates through vehicle simulation research 

currently underway but will not be completed as of the publication of this NOI and TAR. 

 Refer to Appendix B for a more detailed summary of the effectiveness 

values assumed for both towing and relaxed towing HEVs.

M Current small SUVs and Minivans have an approximate average towing capacity of 2000 lbs (without a towing 

package), but range from no towing capacity to 3500 pounds. N We note that there are some gasoline vehicles in the large car/minivan/small truck segments sold today which 

do not have any towing rating. 

O The agencies recognize that assuming that certain consumers will choose to purchase non-hybrid vehicles in 

order to obtain their desired towing capacity could lead to some increase in fuel consumption and CO2 emissions 

as compared to assuming that towing capacity is maintained for hybrid vehicles across the board and all vehicles 

are therefore hybrids. However, the agencies think it likely that the net improvement in fuel consumption and 

CO2 emissions due to the increased numbers of hybrids available for consumers to choose will offset any 

potential increase in fuel consumption and CO2 emissions resulting from consumers selecting the higherperformance non-hybrid powertrain vehicles. P The effectiveness of HEVs for heavier vehicles which require conventional towing capabilities is markedly less 

because the rated power of the IC engine must be similar to its non-hybrid brethren. As such, there is less 

opportunity for downsizing with these vehicles.
2017-2025 Technical Assessment

3-15 

3.2.10 Ongoing Vehicle Simulation to Update Effectiveness

The other critical factor in the assessment of the cost-effectiveness of technologies is 

the effectiveness valueQ

To assess the effectiveness of emerging technologies and advances in conventional 

technologies in the 2017 to 2025 timeframe, EPA also commissioned an extension of earlier 

vehicle simulation modeling work with Ricardo, Inc. Besides updating the technology 

effectiveness estimates of the previous work, the present study substantially broadened the 

scope to include two new vehicle classes and several advanced technologies, including P2 and 

other HEVs. Among the major additions: 

 associated with a particular technology. The agencies have, in 

general, used the same effectiveness estimates used in the 2012-2016 light-duty rule. 

1. Two new vehicle classes intended for use in EPA’s OMEGA model: a 

subcompact car and a light heavy-duty truck 

2. Highly-boosted and significantly downsized direct injection gasoline engines, 

including lean-burnR

3. 8-speed automatic and dual-clutch transmissions 

and stoichiometric/cooled-EGR variants

4. Advanced hybrids, including P2 and powersplitS

5. Vehicle mass reduction, in conjunction with engine downsizing 

 hybrids 

The Ricardo study has not been completed to a degree that allow results to be used for 

this analysis, but EPA and NHTSA expect to use the findings from this work to inform the 

estimates of technology effectiveness used for the model year 2017-2025 NPRM.

3.3 Vehicle Manufacturer Lead Time

With respect to the practicability of the standards in terms of lead time, during MYs 

2017-2025 manufacturers are expected to go through the normal automotive business cycle of 

redesigning and upgrading their light-duty vehicle products, and in some cases introducing 

entirely new vehicles not in the market today. This assessment allows manufacturers the time 

needed to incorporate technology to achieve GHG reductions and improve fuel economy 

during the vehicle redesign process. This is an important aspect of the assessment, as it 

avoids the much higher costs that would occur if manufacturers need to add or change 

technology at times other than their scheduled redesigns. This time period also provides 

manufacturers the opportunity to plan for compliance using a multi-year time frame, again 

consistent with normal business practice. Over these 9 model years, there will be an 

opportunity for manufacturers to evaluate, presumably, every one of their vehicle model 

platforms and add technology in a cost effective way to control GHG emissions and improve 

fuel economy. This includes all the technologies considered here and redesign of the air 

 

R Lean-burn simply means less fuel per unit air than would be used under stoichiometric combustion. Lean burn 

operation is a way to reduce throttling losses and allows for higher compression ratios and, thus, better 

performance and/or fuel efficiency. S This is the HEV architecture initially developed by Toyota and now more widely used in several models. 
Chapter 3

3-16 

conditioner systems in ways that will further reduce GHG emissions and improve fuel 

economy. Most vehicles would likely undergo two redesigns during this period. 

Even with multiple redesign periods, it is still likely that some of the more advanced 

and costly technologies (such as cooled boosted EGR engines, or advanced (P)HEVs) may 

not be able to be fully implemented within the timeframe of this rule. These limitations are 

captured in “maximum technology penetration rates” within the modeling analysis. 

In order to assess the four technology pathways, we developed “Maximum 

Technology Penetration Rates” which we could implement within the OMEGA model in 

order to represent the four pathways. Each technology path was defined by these maximum 

technology penetration rates, which were specified as the maximum modeled fleet penetration 

of classes of technology into the new vehicle fleet in MY 2020 and MY 2025 (these broad 

classes of technology as described in detail below). We developed these penetration rates 

based on agency expert judgment with regard to a number of factors such as manufacturer 

production capacity, vehicle suitability, technical feasibility considerations, as well as our 

goal of purposely analyzing multiple potential pathways for this technical assessment. The 

maximum technology penetration rates serve as exogenous limits on technology application 

within the OMEGA model and are shown in Table 3.3-1. 
2017-2025 Technical Assessment

3-17 

Table 3.3-1 Scenario Maximum Technology Penetration Rates 

Technology MY 20203 MY 2025

Path A Path B Path C Path A Path B Path C Path D

Conventional SI 100% 100% 100% 100% 100% 100% 100%

Advanced SI 10% 30% 40% 50% 75% 100% 0%

Hybrid vehicles 40% 30% 40% 75% 50% 75% 60%

Electric Vehicle 4% 4% 8% 8% 8% 15% 20%

Plug-in Hybrid 4% 4% 8% 8% 8% 15% 20%

Mass 

Reduction1,2 15% 15% 25% 15% 20% 30% 15% 

1 The mass reduction shown is with respect to the 2008 MY.

2 The mass reduction shown is not an actual phase-in cap, but the maximum amount of mass reduction which 

could be allowed on any vehicle.

3

Technology Path D was not run in MY 2020, please see chapter 6 for a discussion of this topic.

The broad technology classes evaluated for purposes of this analysis are defined below 

and a brief discussion of the limiting factors considered are presented. For a more detailed 

discussion of any individual technology, please see the joint Technical Support Document for 

the 2012-2016 rule and Appendix B of this report: 

• Conventional Spark Ignition (SI) - This technology category includes all technologies 

that are not contained in other categories such as gasoline direct injection engines, 

cylinder deactivation, six and eight speed automatic and dual clutch transmissions, and 

start-stop micro-hybrid technology. Most of these technologies were anticipated as 

being available in the MY 2012-2016 time frame in the recent NHTSA and EPA final 

rule, and it is expected manufacturers could expand production to all models by model 

year 2025, and therefore the maximum technology penetration rate is set at 100% for 

all four pathways. 

• Advanced SI - This technology includes gasoline spark ignition engines which are 

currently under development by OEMs and suppliers and are not anticipated to be 

widely used in the 2012- 2016 time frame. For purposes of this analysis, based on 

agency expert judgment to define these advanced SI engines, we modeled a direct 

injection gasoline engine with cooled exhaust gas recirculation, and with a larger 

degree of engine downsizing and higher level of turbocharging as compared to the 

turbo-downsized engines included in our analysis for the MYs 2012-2016 final rule. 

This technology is discussed in more detail above and the appendix B, and is similar 

to the technologies that many OEMs indicated were underdevelopment and which they 

anticipate will be introduced into the market in the 2017-2025 time frame. As there 

are no production vehicles presently using these technologies, we set the maximum 

technology penetration rate for these technologies at less than 100% in MY 2025 for 

Paths A and B. 

• Hybrid – While the agencies recognize there are many types of full-hybrids either in 

production or under development, for the purposes of this analysis we have 

specifically modeled two types of hybrids, P-2 and 2-Mode type hybrids. These 
Chapter 3

3-18 

technologies are discussed in detail in Chapter 3. While the agencies expect the 

proliferation of these vehicles to increase in this timeframe, the maximum technology 

penetration rate are set at less than 100% due to potential battery supply constraints, as 

well as industry-wide engineering and capacity constraints, for converting the entire 

new vehicle fleet to strong hybrids in this time frame. The four path ways using 

varying levels in order to capture both the current uncertainty with how rapidly these 

technologies can penetrate into the new vehicle fleet in the 2017-2025 time frame as 

well as the potentially different strategies auto companies may choose with respect to 

the degree of HEV penetration they may pursue. 

• Plug-in Hybrid (PHEV) - This technology includes PHEV’s with a range of 20 and 40 

miles and is discussed above. The maximum technology penetration rates are set at 

less than 100% due to the same general potential constraints as listed for the HEVs, 

but are lower for PHEVs due to the current status of the development of these 

advanced vehicles. Further, as discussed in Appendix B, we project that PHEV 

technology is not available to some vehicle types, such as large pickup. While it is 

possible to electrify such vehicles, there are tradeoffs in terms of cost, electric range, 

and utility that would reduce the appeal of the vehicle to a narrower market. 

• Electric Vehicle (EV) - This technology includes vehicles with actual on-road ranges 

of 75, 100, and 150 miles. The actual on-road range was calculated using a projected 

30% gap between two-cycle and on-road range. These vehicles are powered solely by 

electricity and are not powered by any liquid fuels. The maximum technology 

penetration rates are set at less than 100% due to the same general potential constraints 

as discussed for PHEVs. Further, as with PHEVs, and as discussed in Appendix B, 

we assume that EV technology is not available to some vehicle types, such as large 

pickups. While it is possible to electrify such vehicles, there are tradeoffs in terms of 

cost, range, and utility that would reduce the appeal of the vehicle to a narrower 

market. These trade-offs are expected to reduce the market for other vehicle types as 

well, and for this analysis we have considered this in the development of the 

maximum technology penetration rates we use for the four pathways. Although the 

agencies have assumed that range limitations would entail no loss in value to EV 

owners, we will further consider the reasonableness and applicability of this 

assumption, and will conduct our analyses for the forthcoming NPRM accordingly.T

• Mass Reduction - This technology includes material substitution, smart design, and 

mass reduction compounding. The actual amount of reduction from the 2008 baseline 

was determined based on confidential business information provided by vehicle 

manufacturers, assessments provided by material suppliers, and existing studies in the 

literature, including the 2010 report from Lotus Engineering. As discussed above as 

well as in Chapter 1 and Appendix B, NHTSA and EPA intend to conduct a thorough 

 

T If the agencies determine that the loss of range does entail some loss in value to vehicle owners, we anticipate 

that accounting for this loss in value would affect our estimates of potential EV application rates and our 

estimates of the private and social benefits of new standards that could lead to increases in EV application rates.
2017-2025 Technical Assessment

3-19 

assessment of the levels of the levels of mass reduction that could be achieved which 

is both technologically feasible and which can be implemented in a safe manner for 

the joint federal NPRM.

3.4 Other Technologies Assessed 

In addition to the technologies already mentioned, the technologies generally 

considered in the agencies’ analysis are briefly described below. They fall into five broad 

categories: engine technologies, transmission technologies, vehicle technologies, 

electrification/accessory technologies, hybrid technologies and mass reduction. For a more 

detailed description of each technology and their costs and effectiveness, we refer the reader 

to Chapter 3 of the Joint TSD, Chapter III of NHTSA’s FRIA, and Chapter 1 of EPA’s final 

RIA.33

3.4.1 Types of engine technologies that improve fuel economy and reduce CO2

emissions include the following: 

 Technologies to reduce CO2 and HFC emissions from air conditioning systems are 

discussed in Appendix D. We note that not all of these technologies were actually modeled in 

the analysis for this Technical Assessment Report given the agencies’ decision to simplify 

that analysis as discussed further below in Section 3.5 and in Chapter 6, but all of the 

technologies will be available for the models in the upcoming rulemaking analysis. 

• Low-friction lubricants – low viscosity and advanced low friction 

lubricants oils are now available with improved performance and better 

lubrication. If manufacturers choose to make use of these lubricants, they 

would need to make engine changes and possibly conduct durability testing 

to accommodate the low-friction lubricants. The cost and GHG and fuel 

economy effectiveness is unchanged from estimates used for 2016 model 

year vehicles in the 2012-2016 final rule. 

• Reduction of engine friction losses – can be achieved through low-tension 

piston rings, roller cam followers, improved material coatings, more 

optimal thermal management, piston surface treatments, and other 

improvements in the design of engine components and subsystems that 

improve engine operation. The cost and GHG and fuel economy 

effectiveness is unchanged from estimates used for 2016 model year 

vehicles in the 2012-2016 final rule. 

• Conversion to dual overhead cam with dual cam phasing – as applied to 

overhead valves designed to increase the air flow with more than two 

valves per cylinder and reduce pumping losses. The GHG and fuel 

economy effectiveness is unchanged from estimates used for 2016 model 

year vehicles in the 2012-2016 final rule. The cost has changed only in 

that learning effects have continued to decrease piece costs.

• Cylinder deactivation – deactivates the intake and exhaust valves and 

prevents fuel injection into some cylinders during light-load operation. 

The engine runs temporarily as though it were a smaller engine which 
Chapter 3

3-20 

substantially reduces pumping losses. The GHG and fuel economy 

effectiveness is unchanged from estimates used for 2016 model year 

vehicles in the 2012-2016 final rule. The cost has changed only in that 

learning effects have continued to decrease piece costs.

• Variable valve timing – alters the timing of the intake valve, exhaust valve, 

or both, primarily to reduce pumping losses, increase specific power, and 

control residual gases. The GHG and fuel economy effectiveness is 

unchanged from estimates used for 2016 model year vehicles in the 2012-

2016 final rule. The cost has changed only in that learning effects have 

continued to decrease piece costs.

• Discrete variable valve lift – increases efficiency by optimizing air flow 

over a broader range of engine operation which reduces pumping losses. 

Accomplished by controlled switching between two or more cam profile 

lobe heights. The GHG and fuel economy effectiveness is unchanged from 

estimates used for 2016 model year vehicles in the 2012-2016 final rule. 

The cost has changed only in that learning effects have continued to 

decrease piece costs.

• Continuous variable valve lift – is an electromechanical or electrohydraulic 

system in which valve timing is changed as lift height is 

controlled.34,35,36,37

• Stoichiometric gasoline direct-injection technology – injects fuel at high 

pressure directly into the combustion chamber to improve cooling of the 

air/fuel charge within the cylinder, which allows for higher compression 

ratios and increased thermodynamic efficiency. The GHG and fuel 

economy effectiveness is unchanged from estimates used for 2016 model 

year vehicles in the 2012-2016 final rule. The costs for this technology 

differ from those used in the 2012-2016 light-duty rule (refer to Table 3.2-

1).

 This yields a wide range of performance optimization 

and volumetric efficiency, including enabling the engine to be valve 

throttled. The GHG and fuel economy effectiveness is unchanged from 

estimates used for 2016 model year vehicles in the 2012-2016 final rule. 

The cost has changed only in that learning effects have continued to 

decrease piece costs.

• Turbocharging and downsizing – increases the available airflow and 

specific power level, allowing a reduced engine size while maintaining 

performance. Engines of this type use gasoline direct injection (GDI) and 

dual cam phasing. This reduces pumping losses at lighter loads in 

comparison to a larger engine. The GHG and fuel economy effectiveness 

changed from estimates used for 2016 model year vehicles in the 2012-

2016 final rule. The current estimates reflect engines that are now entering 

the light-duty vehicle market38 or are under advanced development.39,40,41 

We now estimate an effectiveness of approximately 15% relative to a 2008 
2017-2025 Technical Assessment

3-21 

baseline engine technology. The costs for this technology also differ from 

those used in the 2012-2016 light-duty rule (refer to Table 3.2-1). 

• Turbocharging and downsizing with cooled exhaust-gas recirculation 

(EGR) – additional charge dilution reduces the incidence of knocking 

combustion and obviates the need for fuel enrichment at high engine 

power. This allows for higher boost pressure and/or compression ratio and 

further reduction in engine displacement and both pumping and friction 

losses while maintaining performance. Engines of this type use GDI and 

both dual cam phasing and discrete variable valve lift. The EGR systems 

considered in this assessment would use a dual-loop system with both high 

and low pressure EGR loops and dual EGR coolers. The engines would 

also use single-stage, variable geometry turbocharging with higher intake 

boost pressure available across a broader range of engine operation than 

conventional turbocharged SI engines. Such a system is estimated to be 

capable of an additional 5% effectiveness relative to a turbocharged, 

downsized GDI engine without cooled-EGR.39, 42,43 The agencies are also 

considering a more advanced version of such a cooled EGR system that 

would employ very high combustion pressures by using dual stage 

turbocharging. The agencies have at our disposal only very preliminary 

effectiveness estimates for this approach as modeling efforts are ongoing 

via vehicle simulation modeling by Ricardo Engineering. The simulation 

modeling is similar to work that Ricardo conducted for EPA for its 2008 

staff report on GHG effectiveness of light-duty vehicle technologies.44

• Diesel engines – have several characteristics that give superior fuel 

efficiency, including reduced pumping losses due to lack of (or greatly 

reduced) throttling, and a combustion cycle that operates at a higher 

compression ratio and with a very lean air/fuel mixture relative to an 

equivalent-performance gasoline engine. This technology requires 

additional enablers, such as a NOx adsorption catalyst system or a 

urea/ammonia selective catalytic reduction system for control of NOx 

emissions during lean (excess air) operation. For purposes of this current 

assessment, we have not included advanced diesel engines in our modeling 

scenarios. During our meetings with the automotive companies, a few 

companies did indicate that diesel technology would represent a 

meaningful portion of their future product offerings in the US, and these 

companies commented that there are opportunities for improving the fuel 

economy/reducing CO2 from diesel in the 2017 to 2025 time frame which 

they are pursuing. For today’s assessment, the three agencies did not have 

sufficient time to further investigate these potential improvements for 

diesels, both the improvements in effectiveness and the potential costs 

associated with those improvements. Therefore, we did not include diesel 

The 

agencies will reconsider this more advanced cooled EGR approach in the 

upcoming NPRM when the Ricardo simulation work should be complete. 

The costs for the cooled EGR system considered in this assessment (i.e., 

single stage turbocharging) are presented in Appendix B. 
Chapter 3

3-22 

engines in our modeling assessment presented in Chapter 6. This does not 

mean that the agencies do not see a role for diesels in the future fleet since 

we fully expect some manufacturers will rely on diesels as part of their 

future strategy. We intend to continue to work on this area of our 

assessment and expect to perform additional evaluations in the future 

regarding diesel engine technology. 

3.4.2 Types of transmission technologies considered include: 

• Improved automatic transmission controls – optimizes shift schedule to 

maximize fuel efficiency under wide ranging conditions, and minimizes 

losses associated with torque converter slip through lock-up or modulation. 

The GHG and fuel economy effectiveness is unchanged from estimates 

used for 2016 model year vehicles in the 2012-2016 final rule. The cost has 

changed only in that learning effects have continued to decrease piece 

costs.

• Six-, seven-, and eight-speed automatic transmissions – the gear ratio 

spacing and transmission ratio are optimized to enable the engine to 

operate in a more efficient operating range over a broader range of vehicle 

operating conditions. While a six speed transmission application was most 

prevalent for the 2012-2016 final rule, eight speed transmissions are 

expected to be readily available and applied in the 2017 through 2025 

timeframe. We applied the six speed transmission GHG and fuel economy 

effectiveness estimates used from 2016 model year vehicles in the 2012-

2016 final rule. We plan to conduct further analysis to determine the 

effectiveness of increasing the number of available gear ratios beyond six 

speeds and increasing the ratio spread prior to the 2017-2025 notice of 

proposed rulemaking. The costs for a 6-speed automatic transmission 

differ from those used in the 2012-2016 light-duty rule (refer to Table 3.2-

1). The agencies have estimated new costs for an 8-speed automatic 

transmission, which are presented in Appendix B. 

• Dual clutch or automated shift manual transmissions – are similar to 

manual transmissions, but the vehicle controls shifting and launch 

functions. A dual-clutch automated shift manual transmission uses 

separate clutches for even-numbered and odd-numbered gears, so the next 

expected gear is pre-selected, which allows for faster and smoother 

shifting. The 2012-2016 final rule limited DCT applications to a maximum 

of 6-speeds. We applied the GHG and fuel economy effectiveness 

estimates used from 2016 model year vehicles in the 2012-2016 final rule. 

We plan to conduct further analysis to determine the effectiveness of 

increasing the number of available gear ratios beyond six speed and 

increasing the ratio spread prior to the 2017-2025 notice of proposed 

rulemaking. The costs for a DCT differ from those used in the 2012-2016 

light-duty rule (refer to Table 3.2-1).
2017-2025 Technical Assessment

3-23 

• Continuously variable transmission – commonly uses V-shaped pulleys 

connected by a metal belt rather than gears to provide ratios for operation. 

Unlike manual and automatic transmissions with fixed transmission ratios, 

continuously variable transmissions can provide fully variable and an 

infinite number of transmission ratios that enable the engine to operate in a 

more efficient operating range over a broader range of vehicle operating 

conditions. CVTs have not been considered in this assessment. 

• Manual 6-speed transmission –offers an additional gear ratio, often with a 

higher overdrive gear ratio, than a 5-speed manual transmission. The GHG 

and fuel economy effectiveness is unchanged from estimates used for 2016 

model year vehicles in the 2012-2016 final rule. The cost has changed only 

in that learning effects have continued to decrease piece costs.

3.4.3 Types of vehicle technologies considered include:

• Low-rolling-resistance tires – have characteristics that reduce frictional 

losses associated with the energy dissipated in the deformation of the tires 

under load, thereby improving fuel economy and reducing CO2 emissions. 

The costs and GHG and fuel economy effectiveness is unchanged from 

estimates used for 2016 model year vehicles in the 2012-2016 final rule. 

This is conservative as reducing rolling resistance in tires is something that 

can likely continue to improve. The agencies may consider adding a 

second level of improvement in tire rolling resistance for the upcoming 

NPRM. 

• Low-drag brakes – reduce the sliding friction of disc brake pads on rotors 

when the brakes are not engaged because the brake pads are pulled away 

from the rotors. The costs and GHG and fuel economy effectiveness is 

unchanged from estimates used for 2016 model year vehicles in the 2012-

2016 final rule. 

• Front or secondary axle disconnect for four-wheel drive systems – provides 

a torque distribution disconnect between front and rear axles when torque 

is not required for the non-driving axle. This results in the reduction of 

associated parasitic energy losses. The costs and GHG and fuel economy 

effectiveness is unchanged from estimates used for 2016 model year 

vehicles in the 2012-2016 final rule. 

• Aerodynamic drag reduction – This can be achieved via two approaches, 

either reducing the drag coefficients or reducing vehicle frontal area. To 

reduce drag coefficients, skirts, air dams, underbody covers, and more 

aerodynamic side view mirrors can be applied. In addition to the standard 

aerodynamic treatments, the agencies have included a second level of 

aerodynamic technologies which could include active grille shutters, rear 

visors, and larger under body panels. The GHG and fuel economy 

effectiveness is unchanged from estimates used for 2016 model year 
Chapter 3

3-24 

vehicles in the 2012-2016 final rule. This second level of aerodynamic 

technologies was not considered in the 2012-2016 light-duty rule and, as 

such, the estimated costs are new and are presented in Appendix B. 

• Mass Reduction – Already mentioned above. 

Types of electrification/accessory and hybrid technologies considered include: 

• Electric power steering (EPS)/ Electro-hydraulic power steering (EHPS) – 

is an electrically-assisted steering system that has advantages over 

traditional hydraulic power steering because it replaces a continuously 

operated hydraulic pump, thereby reducing parasitic losses from the 

accessory drive. Manufacturers have informed the agencies that full EPS 

systems are being developed for all light-duty vehicles applications, 

including large trucks. The GHG and fuel economy effectiveness is 

unchanged from estimates used for 2016 model year vehicles in the 2012-

2016 final rule. The cost has changed only in that learning effects have 

continued to decrease piece costs.

• Improved accessories (IACC) – may include high efficiency alternators, 

electrically driven (i.e., on-demand) water pumps and cooling fans. This 

excludes other electrical accessories such as electric oil pumps and 

electrically driven air conditioner compressors. The GHG and fuel 

economy effectiveness is unchanged from estimates used for 2016 model 

year vehicles in the 2012-2016 final rule. The cost has changed only in that 

learning effects have continued to decrease piece costs.

• Air Conditioner Systems – These technologies include improved hoses, 

connectors and seals for leakage control. They also include improved 

compressors, expansion valves, heat exchangers and the control of these 

components for the purposes of improving tailpipe CO2 emissions and fuel 

economy as a result of A/C use. The GHG and fuel economy 

effectiveness is unchanged from estimates used for 2016 model year 

vehicles in the 2012-2016 final rule. We have estimated new costs for A/C 

systems which are presented in Appendix D.

• 12-volt micro-hybrid (MHEV) – also known as idle-stop or start-stop and 

commonly implemented as a 12-volt belt-driven integrated startergenerator, is the most basic hybrid system that facilitates idle-stop 

capability. Along with other enablers, this system replaces a common 

alternator with a belt-driven enhanced power starter-alternator, and a 

revised accessory drive system. These systems incorporate an additional 

battery, ELDC or other subsystems to prevent voltage-droop on restart, one 

of the shortcomings of previous 12V micro-hybrid sytems relative to 

higher voltage systems. Such a system is estimated to be capable of 

roughly 1.5% to 2.5% effectiveness. The cost has changed only in that 

learning effects have continued to decrease piece costs.
2017-2025 Technical Assessment

3-25 

• Higher Voltage Stop-Start/Belt Integrated Starter Generator (BISG) – 

provides idle-stop capability and uses a higher voltage battery with 

increased energy capacity over typical automotive batteries. The higher 

system voltage allows the use of a smaller, more powerful electric motor. 

This system replaces a standard alternator with an enhanced power, higher 

voltage, higher efficiency starter-alternator, that is belt driven and that can 

recover braking energy while the vehicle slows down (regenerative 

braking). The GHG and fuel economy effectiveness is unchanged from 

estimates used for 2016 model year vehicles in the 2012-2016 final rule. 

The cost has changed only in that learning effects have continued to 

decrease piece costs.

• Integrated Motor Assist (IMA)/Crank integrated starter generator (CISG) – 

provides idle-stop capability and uses a high voltage battery with increased 

energy capacity over typical automotive batteries. The higher system 

voltage allows the use of a smaller, more powerful electric motor and 

reduces the weight of the wiring harness. This system replaces a standard 

alternator with an enhanced power, higher voltage, higher efficiency 

starter-alternator that is crankshaft mounted and can recover braking 

energy while the vehicle slows down (regenerative braking). The GHG and 

fuel economy effectiveness is unchanged from estimates used for 2016 

model year vehicles in the 2012-2016 final rule. The cost has changed only 

in that learning effects have continued to decrease piece costs.

• P2 Hybrid – A newly emerging hybrid technology that uses a transmission 

integrated electric motor placed between the engine and a gearbox or CVT, 

much like the IMA system described above except with a wet or dry 

separation clutch which is used to decouple the motor/transmission from 

the engine. In addition, a P2 Hybrid would typically be equipped with a 

larger electric machine. Engaging the clutch allows all-electric operation 

and more efficient brake-energy recovery. Disengaging the clutch allows 

efficient coupling of the engine and electric motor and, when combined 

with a DCT transmission, reduces gear-train losses relative to PSHEV or 

2MHEV systems. This technology was not included in the 2012-2016 

GHG and CAFE rulemaking technical analysis. We have estimated new

costs for this technology which are presented in Appendix B. 

• 2-mode hybrid (2MHEV) – is a hybrid electric drive system that uses an 

adaptation of a conventional stepped-ratio automatic transmission by 

replacing some of the transmission clutches with two electric motors that 

control the ratio of engine speed to vehicle speed, while clutches allow the 

motors to be bypassed. This improves both the transmission torque 

capacity for heavy-duty applications and reduces fuel consumption and 

CO2 emissions at highway speeds relative to other types of hybrid electric 

drive systems. The GHG and fuel economy effectiveness is unchanged 

from estimates used for 2016 model year vehicles in the 2012-2016 final 
Chapter 3

3-26 

rule. We have estimated new costs for this technology which are presented 

in Appendix B. 

• Power-split hybrid (PSHEV) – a hybrid electric drive system that replaces 

the traditional transmission with a single planetary gearset and a 

motor/generator. This motor/generator uses the engine to either charge the 

battery or supply additional power to the drive motor. A second, more 

powerful motor/generator is permanently connected to the vehicle’s final 

drive and always turns with the wheels. The planetary gear splits engine 

power between the first motor/generator and the drive motor to either 

charge the battery or supply power to the wheels. Power-split hybrids have 

not been considered in this assessment. 

• Plug-in hybrid electric vehicles (PHEV) – are hybrid electric vehicles with 

the means to charge their battery packs from an outside source of 

electricity (usually the electric grid). These vehicles have larger battery 

packs with more energy storage and a greater capability to be discharged 

than other hybrid electric vehicles. They also use a control system that 

allows the battery pack to be substantially depleted under electric-only or 

blended mechanical/electric operation and batteries that can be cycled in 

charge sustaining operation at a lower state of charge than is typical of 

other hybrid electric vehicles. The GHG and fuel economy effectiveness is 

unchanged from estimates used for 2016 model year vehicles in the 2012-

2016 final rule. We have estimated new costs for this technology which are 

presented in Appendix B along with estimates of their electricity usage per 

mile. Battery costs assume that battery packs for PHEV applications will 

be designed to last for the full useful life of the vehicle at a useable state of 

charge equivalent to 70% of the nominal battery pack capacity. 

• Electric vehicles (EV) – are vehicles with all-electric drive and with 

vehicle systems powered by energy-optimized batteries charged primarily 

from grid electricity. While the 2016 FRM did not anticipate a significant 

penetration of EV’s, in this analysis, EV’s with several ranges have been 

included. The GHG and fuel economy effectiveness is unchanged from 

estimates used for 2016 model year vehicles in the 2012-2016 final rule. 

We have estimated new costs for this technology which are presented in 

Appendix B along with estimates of their electricity usage per mile. 

Battery costs assume that battery packs for EV applications will be 

designed to last for the full useful life of the vehicle at a useable state of 

charge equivalent to 80% of the nominal battery pack capacity. 

• Fuel cell electric vehicles (FCEVs) – utilize a full electric drive platform 

but consume electricity generated by an on-board fuel cell and hydrogen 

fuel. Fuel cells are electro-chemical devices that directly convert reactants 

(hydrogen and oxygen via air) into electricity, with the potential of 

achieving more than twice the efficiency of conventional internal 

combustion engines. High pressure gaseous hydrogen storage tanks are 
2017-2025 Technical Assessment

3-27 

used by most automakers for FCEVs that are currently under development. 

The high pressure tanks are similar to those used for compressed gas 

storage in more than 10 million CNG vehicles worldwide, except that they 

are designed to operate at a higher pressure (350 bar or 700 bar vs. 250 bar 

for CNG). We have estimated new costs for this technology which are 

presented in Appendix B. Due to the uncertainty of the future availability 

for this technology, FCEVs were not included in any OMEGA runs. 

3.5 Technology Packages in OMEGA 

The large number of possible technologies to consider and the breadth of vehicle 

systems that are affected mean that consideration of the manufacturer’s design and production 

process plays a major role in assessing the ability of the US fleet to achieve various GHG 

levels and fuel economy, and the costs associated with achieving those levels. Vehicle 

manufacturers typically develop their many different individual vehicle models by basing 

them on a limited number of vehicle platforms. Several different models of vehicles may be 

produced using a common platform, allowing for efficient use of design and manufacturing 

resources. The platform typically consists of common vehicle architecture and structural 

components, such as the underbody, chassis and suspension. Given the very large investment 

put into designing and producing each vehicle model, manufacturers cannot reasonably 

redesign any given vehicle every year or even every other year, let alone redesign all of their 

vehicles every year or every other year. At the redesign stage, the manufacturer will typically 

upgrade or add all of the technology and make all of the other changes needed so the vehicle 

model will meet the manufacturer’s plans for the next several years. This includes meeting all 

of the fuel economy, emissions, safety, and other requirements that would apply during the 

years before the next major redesign of the vehicle. This is in contrast to what would be a 

much more costly approach of trying to achieve small increments of reductions over multiple 

years by adding technology to the vehicle piece by piece outside of the redesign process. 

However, making all of these changes at once typically involves significant 

engineering, development, manufacturing, and marketing resources to create a new product 

with multiple new features. In order to leverage this significant upfront investment, 

manufacturers plan vehicle redesigns with several model years’ of production in mind. 

That said, vehicle models are not completely static between redesigns as limited 

changes are often incorporated for each model year. This interim process is called a “refresh” 

of the vehicle. It generally does not allow for major technology changes although more minor 

ones can be done (e.g., aerodynamic improvements, valve timing improvements), usually 

aimed at improving the vehicle’s market appeal. We note, though, that more major 

technology upgrades that affect multiple systems of the vehicle thus occur at the vehicle 

redesign stage and not in the time period between redesigns.

In determining the projected technology needed to meet the standards, and the cost of 

those technologies, EPA is using an approach that accounts for and builds on this redesign 

process and bundles technologies into “packages” to capture synergistic aspects and reflect 

progressively larger CO2 reductions with additions or changes to any given package. As an 

input to this approach, EPA groups technologies into packages of increasing estimated cost 
Chapter 3

3-28 

and effectiveness. EPA determined that 19 different vehicle types provided adequate 

resolution required to accurately model the entire fleet. We discuss the approach to 

developing packages and how those packages are used in the OMEGA model in Appendix B. 

For the reader’s reference, we note that NHTSA’s CAFE Compliance and Effects 

Model (often referred to as “the Volpe model”), which NHTSA uses for CAFE rulemaking 

analysis was not used for purposes of this Technical Assessment Report, also assumes 

manufacturers add most technology to vehicles as part of the vehicle redesign and freshening 

process. While the CAFE model considers technologies similar to those considered by EPA’s 

OMEGA model, the CAFE model accumulates discrete technologies incrementally, taking 

into account model-estimated cost effectiveness, as well as engineering and other constraints. 

While the CAFE model does not require that packages be determined exogenously, in the 

analysis supporting the MYs 2012-2016 CAFE standards, the CAFE model often formed 

packages similar to those included in EPA’s analysis supporting the MYs 2012-2016 GHG 

emissions standards. Although NHTSA is not, in today’s report, presenting analysis 

performed using the CAFE model, the agency will do so in support of the upcoming NPRM 

for post-MY 2016 CAFE standards. 
2017-2025 Technical Assessment

3-29 

Chapter 3 References 

14 Joint Technical Support Document: Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission 

Standards and Corporate Average Fuel Economy Standardsfor EPA and NHTSA 2012-2016 GHG and CAFE

Rule. EPA-420-R-10-901, April, 2010.

15 Rogozhin, A., et al., Using indirect cost multipliers to estimate the total cost of adding new technology in the 

automobile industry. International Journal of Production Economics (2009), doi:10.1016/j.ijpe.2009.11.031. 

16 75 FR 25324, 25382-396, May 7, 2010.

17 U.S. Environmental Protection Agency, “Light-Duty Technology Cost Analysis Pilot Study,” Contract No. 

EP-C-07-069, Work Assignment 1-3, December 2009, EPA-420-R-09-020, Docket EPA-HQ-OAR-2009-0472- 

11282; peer review report dated November 6, 2009, is at EPA-HQ-OAR-2009-0472-11285; “Light-duty 

Technology Cost Analysis – Report on Additional Case Studies,” EPA-HQ-OAR-2009-0472-11604

18 U.S. Environmental Protection Agency, “Light-Duty Technology Cost Analysis Pilot Study,” Contract No. 

EP-C-07-069, Work Assignment 1-3, December 2009, EPA-420-R-09-020, Docket EPA-HQ-OAR-2009-0472- 

11282; peer review report dated November 6, 2009, is at EPA-HQ-OAR-2009-0472-11285; “Light-duty 

Technology Cost Analysis – Report on Additional Case Studies,” EPA-HQ-OAR-2009-0472-11604

19 Nelson, P.A., Santinit, D.J., Barnes, J. “Factors Determining the Manufacturing Costs of Lithium-Ion Batteries 

for PHEVs,” 24th World Battery, Hybrid and Fuel Cell Electric Vehicle Symposium and Exposition EVS-24, 

Stavenger, Norway, May 13-16, 2009 (www.evs24.org).

20 Santini, D.J., Gallagher, K.G., and Nelson, P.A. “Modeling of Manufacturing Costs of Lithium-Ion Batteries 

for HEVs, PHEVs, and EVs,” Paper to be presented at the 25th World Battery, Hybrid and Fuel Cell Electric 

Vehicle Symposium and Exposition, EVS-25, Shenzhen, China, November 5-9, 2010 (www.evs25.org). 

Advance draft provided by D.J. Santini, Argonne National Laboratory, August 24, 2010.

21 “Hyundai ups tech ante with Sonata Hybrid,” Automotive News, August 2, 2010.

22 “Chevrolet Stands Behind Volt With Standard Eight-Year, 100,000-Mile Battery Warranty,” GM Press release 

(http://media.gm.com/content/media/us/en/news/news_detail.brand_gm.html/content/Pages/news/us/en/2010/Jul

y/0714_volt_battery)

23 “Nissan’s new 2012 hybrid system aims for 1.8-L efficiency with a 3.5-L V6,” SAE Automotive Engineering 

Online, February 15, 2010.

24 “Lithium-ion Battery,” Nissan Technological Development Activities (http://www.nissanglobal.com/EN/TECHNOLOGY/INTRODUCTION/DETAILS/LI-ION-EV/), 2009. 

25 Lotus Engineering, Inc. “An Assessment of Mass Reduction Opportunities for a 2017 – 2020 Model Year 

Vehicle Program,” Published by the The International Council on Clean Transportation and available on the 

Internet at http://www.theicct.org/2010/03/lightweight-future/, March 30, 2010.

26 Effectiveness and Impact of Corporate Fuel Economy Standards, NAS, 2002.

27 Basic Analysis of the Cost and Long-Term Impact of the Energy Independence and Security Act Fuel 

Economy Standard, Sierra Research, 2008.

28 The Impact of Mass Decompounding on Assessing the Value of Vehicle Lightweighting, MIT 2008.

29 Rogozhin, A., et al., Using indirect cost multipliers to estimate the total cost of adding new technology in the 

automobile industry. International Journal of Production Economics (2009), doi:10.1016/j.ijpe.2009.11.031.
Chapter 3

3-30 

30 Gloria Helfand and Todd Sherwood, ‘‘Documentation of the Development of Indirect Cost Multipliers for 

Three Automotive Technologies,’’ Office of Transportation and Air Quality, U.S. EPA, August 2009 (Docket 

EPA–HQ–OAR–2009–0472).

31 Bureau of Economic Analysis, US Department of Commerce, National Income and Product Accounts Table 

1.1.4; accessed via www.bea.gov on May 27, 2010.

32 See “Learning Curves in Manufacturing”, L. Argote and D. Epple, Science, Volume 247; “Toward Cost Buy 

down Via Learning-by-Doing for Environmental Energy Technologies, R. Williams, Princeton University, 

Workshop on Learning-by-Doing in Energy Technologies, June 2003; “Industry Learning Environmental and the 

Heterogeneity of Firm Performance, N. Balasubramanian and M. Lieberman, UCLA Anderson School of 

Management, December 2006, Discussion Papers, Center for Economic Studies, Washington DC.

33 Joint Technical Support Document: Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission 

Standards and Corporate Average Fuel Economy Standardsfor EPA and NHTSA 2012-2016 GHG and CAFE 

Rule. EPA-420-R-10-901, April, 2010; Regulatory Impact Analysis, U.S. EPA, EPA-420-R-10-009, April 2009.

34 Luttermann, C., Schünemann, E., Klauer, N. “Enhanced VALVETRONIC Technology for Meeting SULEV 

Emission Requirements,” SAE Technical Paper Series, No. 2006-01-0849, 2006.

35 Murphy, T. “Fiat Breathing Easy with MultiAir,” Wards Auto, March 26, 2010.

36 “Fiat Multiair,” SAE Automotive Engineering International, June 2009, p. 48.

37 Battistonic, M., Foschini, L., Postrioti, L., Cristiani, M. “Development of an Electro-Hydraulic Camless VVA 

System,” SAE Technical Paper Series, No. 2007-24-0088, 2007.

38 Yi., J., Wooldridge, S., Coulson, G., Hilditch, J., Iyer, C., Moilanen, P., Papaioannou, G., Reiche, D., Shelby, 

M. VanDerWege, B., Wearver, C., Xu, Z., Davis, D., Hinds, B., Schamel, A. “Development and Optimization of 

the Ford 3.5L V6 EcoBoost Combustion System,” SAE Technical Paper Series, No. 2009-01-1494. 

39 Turner, J.W.G., Pearson, R.J., Curtis, R. Holland, B. “Sabre: a cost effective engine technology combination 

for high efficiency, high performance and low CO2 emissions,” Low Carbon Vehicles 2009: Institution of 

Mechanical Engineers conference proceedings, May 2009.

40 Lumsden, G. OudeNijeweme, D., Fraser, N., Blaxill, H. “Development of a Turbocharged Direct Injection 

Downsizing Demonstrator Engine,” SAE Technical Paper Series, No. 2009-01-1503, 2009.

41 Kirwan, J.E., Shost, M., Zizelman, J. “3-Cylinder Turbocharged Gasoline Direct Injection: A High Value 

Solution for Low CO2 and Low NOx Emissions,” SAE Technical Paper Series, No. 2010-01-0590, 2010.

42 Kaiser, M., Krueger, U., Harris, R., Cruff, L. “Doing More with Less - The Fuel Economy Benefits of Cooled 

EGR on a Direct Injected Spark Ignited Boosted Engine,” SAE Technical Paper Series, No. 2010-01-0589.

43 Kapus, P.E., Fraidl, G.K., Prevedel, K., Fuerhapter, A. “GDI Turbo – The Next Steps,” JSAE Technical Paper 

No. 20075355, 2007.

44 “EPA Staff Technical Report: Cost and Effectiveness Estimates of Technologies Used to Reduce Light-duty 

Vehicle Carbon Dioxide Emissions,” EPA420-R-08-008, March 2008, Docket EPA-HQ-OAR-2009-0472-0132.
2017-2025 Technical Assessment

4-1 

4 Infrastructure Assessment

4.1 Overview

The May 21, 2010 Presidential Memorandum specifically requests that the EPA, 

NHTSA, and CARB’s joint technical assessment include an assessment of infrastructure for 

advanced technology vehicles. Section 3 of the Memorandum requests the Department of 

Energy (DOE) to promote the deployment of advanced technology vehicles by providing 

technical assistance to cities preparing for deployment of electric vehicles, including plug-in 

hybrids and electric vehicles. The Memorandum also asks DOE to work with stakeholders on 

the development of voluntary standards to facilitate the robust development of advanced 

vehicle technologies and coordinate these efforts with DOT/NHTSA and EPA. Because of 

DOE’s key role in these areas, EPA, NHTSA, and CARB have closely collaborated with DOE 

in developing our assessment of infrastructure issues, and DOE contributed significantly to 

this chapter. 

This technical assessment report identifies electric drive vehicles as an important part 

of the vehicle mix that will likely be used to meet fuel economy and GHG emission reduction 

standards. Electric drive vehicles, including battery electric vehicles (EVs), plug-in hybrid 

electric vehicles (PHEVs), and hydrogen-fueled fuel cell electric vehicles (FCEVs), have the 

potential to dramatically improve fuel economy and reduce GHG emissions compared to 

conventional technologies. Further, given their use of fuels that eventually could be derived 

from entirely renewable and zero carbon resources, they have a large potential to transform 

the vehicle future to a low carbon fleet and significantly reduce U.S. petroleum imports. 

These technologies require new infrastructure to become a significant part of the 

vehicle fleet. In the case of EVs and PHEVs, electric charging infrastructure is needed in the 

form of charging stations, most often at home, but also at the workplace or other public 

locations, such as parking lots or retail stores. While at present, few public charging points 

are available, there are significant projects underway to deploy new electric-drive vehicle 

charging infrastructure across the U.S. and to collect data to facilitate analyses of future 

needs. In the case of FCEVs, hydrogen fueling stations analogous to gasoline stations are 

needed to support commercialization. 

DOE has begun efforts to support a shift to electric-drive vehicles by coupling a long 

history of advanced vehicle research and development with more recent efforts to develop a 

holistic view of electric-vehicle infrastructure by compiling internal expertise, seeking input 

from outside experts and stakeholders and identifying areas where further investigation is 

needed. These combined efforts indicate that most electric vehicle owners will charge at 

home using equipment they pay to install and electricity from a grid that utility providers are 

capable of upgrading, where necessary, to meet charge demand. It is expected that 97 to 99% 

of charging energy will be delivered at home.45 Home charging capability is not seen as a 

hurdle to electric vehicles in the near future. However, driver demand for and interaction with 

public infrastructure is not as well understood, so several DOE-supported projects will deploy 

public charging stations and collect data to inform an analyses of the role that public 

infrastructure will play nationally. These projects are currently underway and will be 

completed within the next 3-4 years. Additionally, DOE is coordinating government 
Chapter 4

4-2 

interaction with cities to share best practices. DOE is further coordinating with both national 

and international organizations, and with other federal agencies, to ensure that the 

development of codes and voluntary standards for electric-vehicles and support infrastructure 

happens as smoothly and quickly as possible. 

This chapter provides an assessment of both electric charging infrastructure needed to 

support electric vehicles (EVs) and plug-in hybrid electric vehicles (PHEVs) and the 

hydrogen infrastructure needed to support fuel cell electric vehicles (FCEVs). The electric 

vehicle infrastructure section summarizes current activities to demonstrate and deploy electric 

recharging infrastructure, the current availability and future potential of home recharging, the 

costs of charging systems, the potential impacts on the electric grid and distribution network, 

and government cooperation in developing voluntary codes and standards. The hydrogen 

infrastructure section discusses the current status of hydrogen fueling stations, the costs of 

hydrogen and refueling stations, prospects for cost and technology improvement, a strategy 

for how a hydrogen infrastructure could roll out to support fuel cell vehicle introductions, and 

potential policies and public/private partnerships that could further facilitate infrastructure 

development. 

4.2 Electric Vehicle Infrastructure

A shift from petroleum-powered to electric-drive vehicles will involve a parallel shift 

in refueling: Where gasoline and diesel fuel vehicles refill at a gas station, electric-drive 

vehicles recharge at a charging station. Three charging levels are currently under 

consideration.46

This electric vehicle infrastructure section summarizes current activities to 

demonstrate and deploy electric recharging infrastructure, the current availability of home 

recharging, the cost of electric vehicle support equipment (EVSE), the potential impacts on 

the electric grid and distribution network, and government cooperation in developing 

industry-recognized electric vehicle support equipment standards. 

 Level 1 charging uses a standard 120 volt (V), 15-20 amps (A) rated (12-16 

A usable) circuit and is available in standard residential and commercial buildings. Level 2 

charging uses a single phase, 240 V, 20-80 A circuit and allows much shorter charge times. 

Level 3 charging—sometimes colloquially called “quick” or “fast” charging—uses a 480 V, 

three-phase circuit, available in mainly industrial areas, typically providing 60-150 kW of offboard charging power. 

4.2.1 DOE Charging Infrastructure Projects Underway 

The Department of Energy (DOE) recognizes the importance of the variety of factors 

that will contribute to the success of grid-connected vehicles and is currently undertaking 

numerous activities to study and address them. Through the American Recovery and 

Reinvestment Act of 2009 (ARRA), DOE has awarded cost-shared grants to companies under 

the Transportation Electrification Initiative to establish development, demonstration, 

evaluation, and education projects to accelerate the market introduction and penetration of 

advanced electric drive vehicles. The Transportation Electrification Initiative, its component 

projects, and other DOE electric-drive vehicle infrastructure activities are discussed below. 
2017-2025 Technical Assessment

4-3 

4.2.1.1 American Recovery and Reinvestment Act: Transportation Electrification 

Initiative

Funded through the ARRA, the Transportation Electrification Initiative provides 

approximately $400 million in federal funding, leveraged through cost-shared grants with 

industry and educational institutions, to develop, demonstrate, and evaluate electric drive 

vehicles and charging infrastructure. Through the projects funded under this activity, over 

13,000 electric-drive vehicles will be deployed in conjunction with nearly 23,000 charging 

stations, starting in 2010 and to be completed in the next 3-4 years, in residential, commercial, 

and public locations, in numerous and diverse geographic locations nationwide. 

The majority of the vehicles deployed through Transportation Electrification projects 

will be privately-owned light-duty vehicles; however, many medium-duty trucks 

incorporating advanced electric and plug-in hybrid electric powertrains will be developed and 

demonstrated in a wide range of geographic, climatic, and operating environments. 

Additionally, the vast majority of electric vehicle charging infrastructure deployed through 

these projects will be Level 2 (220V), 3.3-6.6 kW charging stations, though several hundred 

Level 3 DC “fast” chargers will also be deployed along corridors linking cities within 

deployment areas. For privately-owned vehicles and commercial fleet vehicles, Level 2 

chargers will be installed at the vehicle owners’ residences or the central fleet parking area, 

where the vehicles will most likely be domiciled for overnight charging. Many more Level 2 

charging stations will be deployed in commercial and public locations, which may provide 

vehicle owners the opportunity to travel in expanded geographic areas without the “range 

anxiety” that could otherwise limit electric vehicles’ utility. The effect of charging station 

availability (Level 1, 2 and 3) on driver behavior will be studied as part of this initiative. 

Some researchers believe the duration of a driver’s experience with an EV has more to do 

with reducing range anxiety than public charging, and that public charging may reduce 

“purchase anxiety” instead.47

The coordinated deployment of electric drive vehicles and charging infrastructure 

under the Transportation Electrification Initiative will facilitate DOE’s collection and analysis 

of a comprehensive set of data from both the vehicles and the charging stations.U

 

U A condition of participating in the program will be that participants agree to data collection.

 Vehicle 

data collected will include parameters such as vehicle miles driven, battery state-of-charge, 

GPS location, and, in the case of PHEVs and FCEVs, the liquid fuel consumption. 

Infrastructure data collected will include parameters such as charger connect/disconnect 

times, charge event start/stop times, average and peak power delivered, and total energy 

delivered per charge event. Evaluation of this data, managed by Idaho National Laboratory, 

will provide critical information regarding the influences on vehicle and charging 

infrastructure use, performance, and location suitability. These data collection and analysis 

activities will identify how consumers use electric drive vehicles; where, when, and how 

frequently they charge the vehicles; how usage and charging behavior impact the performance 

of the vehicle; what the impacts are to the electric grid; how consumers respond to pricing 

signals with respect to vehicle charging; and a myriad of other questions related to consumer 
Chapter 4

4-4 

acceptance and market viability of grid-connected vehicles. After the projects are completed 

in the 2013-2014 timeframe, this information will then be used to guide the much broader 

deployment of electric drive vehicles and charging infrastructure in the future. 

A summary of infrastructure-related projects funded through the Transportation 

Electrification Initiative follows in Table 4.2-1, which shows, for each project: the number of 

charging stations and electric vehicles to be deployed, the targeted locations and timeframe 

for deployment and data collection, and the intended benefit of the data to be collected. 

Additional information about each of these projects is in Appendix G. 

Table 4.2-1 ARRA Transportation Electrification Initiative and Clean Cities Projects 

Summary

Project

Level 2 

Charging 

Stations 

Deployed

Vehicles Location Timeframea Data Collected

ECOtality 

North 

America 

($115M) 

14,850 

(and 320 

Level 3)

8,500 

lightduty cars 

AZ, CA, DC, 

OR, TN, TX

2010-

2013 

operational and 

charging behavior of 

electric-drive vehicle 

owners 

Coulomb 

Technologies 

($15M) 

5,000 2,600 

lightduty cars 

CA, DC, FL, MI, 

NY, TX, WA

2010-

2014 

operational and 

charging behavior of 

electric-drive vehicle 

owners

Navistar 

($39M) 

950 950 

mediumduty 

trucks 

CA 2010-

2013 

performance and 

suitability of mediumduty electric vehicles

and support 

infrastructure required

General 

Motors 

($30M) 

650 125 lightduty cars CA, FL, MI, NY, 

NC, SC, TX, 

VA, DC

2010-

2013 

light-duty vehicle 

usage and operational 

needs, supporting 

vehicle design and 

infrastructure planning

Smith 

Electric 

Vehicles 

($32M) 

500 500 

mediumduty 

trucks 

CA, GA, MO, 

NJ, NY, OH, 

OR, TX, DC

2011-

2013 

applicability of 

electric-drive 

powertrains in 

vocational mediumduty trucks 

South Coast 

Air Quality 

Management 

District 

($45M) 

378 378 

mediumduty 

trucks 

and 

shuttle 

CA, CT, GA, HI, 

KY, LA, MD, 

MI, MO, NJ, 

NY, OH, OR, 

PA, TN, TX, WI, 

DC

2010-

2013 

PHEV technologies 

for Class 4/5 vehicles 
2017-2025 Technical Assessment

4-5 

buses

Chrysler 

Group LLC 

($48M) 

153 153 lightduty 

trucks 

AZ, CA, CO, HI, 

MA, MI, MO, 

NV, NY, ND, 

TX

2011-

2013 

real-world product 

viability and 

quantified benefits 

Clean Cities 

($115M) 

500-550 100 lightduty and 

280 

heavyduty 

vehicles

CT, IL, MI, MO, 

NC, NY, OH, 

TX, UT, WA, 

WI

2010-

2011 

charging station usage

a Timeframe is approximate. More details about all Transportation Electrification Initiatives are found in 

Appendix G.

Smart Grid

The ARRA authorizes DOE’s Office of Electricity to administer the Smart Grid 

Investment Grant (SGIG), which supports projects to update today’s electric grid to a “smart 

grid”—a modernized electric grid utilizing real-time two-way communication for improved 

reliability, efficiency, security, and safety and the possibility of dynamic pricing and even 

vehicle-to-grid energy exchange (in which a charged vehicle battery provides energy to the 

grid). As part of the projects supported with these grants, 12 awardees plan to deploy 

approximately 100 charging stations. Additionally, under DOE’s Smart Grid Regional 

Demonstrations, electric vehicles (EVs) and plug-in hybrid electric vehicles (PHEVs) are part 

of several smart grid technology demonstrations projects. In most of the regional 

demonstration projects, grid-connected vehicles are integrated in broader smart grid 

technology deployment activities. Because EV/PHEVs are a relatively nascent technology, 

their contribution to the overall smart grid technology deployment and regional demonstration 

activities is likely to be small, particularly in the early years of the multi-year deployment and 

demonstration programs. 

4.2.1.2 Other Projects

Through its national laboratories, DOE also supports other various projects aimed at 

overcoming barriers related to electric drive vehicles and their interaction with the electric 

grid. These projects target the development of codes and standards that govern the vehiclegrid interface, including communications between the vehicle, the charging infrastructure, and 

the electric grid. Additional projects are intended to streamline the process of deploying 

electric vehicle charging infrastructure and minimize the impact on electricity generation, 

transmission, and distribution resources. Together, activities conducted through the national 

laboratories will help speed the wide-spread adoption of electric drive transportation 

technologies. 

Many stakeholders have expressed the need for timely and standardized local 

permitting procedures for installing electrical vehicle supply equipment. The National 

Electric Vehicle Infrastructure Permitting Project at the National Renewable Energy Lab 

(NREL) seeks to standardize local permitting procedures to speed the deployment of EVSE 
Chapter 4

4-6 

across the U.S. NREL has drafted a National Electric Vehicle Charging Station Permit 

template,48 which conforms to Article 625 of the National Electric Code, and is engaging 

select cities to promote the use of this permit to streamline the process of installing electric 

vehicle supply equipment. This draft permit is intended to establish a mechanism for local 

jurisdictions to provide a simplified approval process for the installation and operation of 

electric vehicle charging equipment, rather than the existing wide variety of permitting 

procedures that currently exist at the local level. Adoption of the draft permit could reduce 

the typical administrative delays that might otherwise impede the deployment of charging 

infrastructure and slow the market adoption of grid-connected vehicles. This draft permit was 

created with input from industry and electrical contractors, and will allow electric vehicle 

charging stations to be installed quickly and safely in the municipalities where the process is 

adopted. Other organizations have published similar documents: Pacific Gas & Electric’s 

(PG&E) released an “Electric Vehicle Infrastructure Installation Guide” in 1999,49 and the 

Electric Power Research Institute (EPRI) published “Plug-in Electric Vehicle Infrastructure 

Installation Guidelines” in 2009.50

4.2.2 Home Charging Adequacy

 

 Charging availability affects consumer value and the development of the EV/PHEV 

market.51,52 Understanding the number of American consumers who can plug-in a vehicle at 

home is instructive in estimating the number of who might choose to own an electric drive 

vehicle. More charging points enable more potential EV/PHEV buyers, but the role of an 

additional charging point depends on whether it is attached to a home, a workplace or a public 

place. A home charging point may enable a new EV/PHEV buyer, while a workplace charge 

point may make the prospective car buyer who already has home charging availability more 

determined to own a PHEV or EV. Availability of adequate home recharging will likely have 

the most impact on deployment, because home is usually where a vehicle parks the most often 

and longest, resulting in more recharging energy and fuel-saving benefit. Based on past 

experience, 97%-99% of charging energy is delivered at home.53 Even with available 

workplace or public charging, consumers will probably feel it is more convenient and less 

stressful to charge at home. Surveys show that consumers state stronger preferences for home 

recharging.54 Other surveys show that EV users with home recharging rarely use public 

recharging55 and some PHEV users choose not to use available public recharging during 

weekdays because of the inconvenience they perceive.56

There may be opportunities for supplemental charging outside the home. Public 

charging stations with Level 2 or Level 3 charging, possibly offered by restaurants, 

supermarkets, gyms, or health centers, can extend the electric range in an equivalent sense, 

which may be especially important for a EV driver in an unexpected long distance trip. The 

ability of a charging point to extend the electric range depends on both the length of available 

charging time and the charging speed. Higher charging speed may be more necessary in 

public places where consumers usually do not park their vehicles as long as at home or the 

workplace. But for consumers with home charging and typical driving patterns, topping off 

partially a depleted battery can be more desirable than recharging a fully depleted one, which 

reduces the need for high charging speed. For home or workplace charging, the usual long 

parking time makes expensive upgrades to faster charging less necessary, especially for 

PHEVs with a small battery.
2017-2025 Technical Assessment

4-7 

As described above, three charging levels are currently under consideration.57 Level 1 

charging uses a standard 120 V, 15-20 amps (A) rated (12-16 A usable) circuit and is 

available in standard residential and commercial buildings. Level 1 charging for 7-9 hours of 

home nighttime is sufficient to fully charge a small PHEV20.V,W

Nevertheless, Level 3 charging may be more beneficial to EV owners who lack the 

hybrid-drive backup of a PHEV. An EV midsize car with 150-mile driving range will likely 

require more than 10 hours of Level 2 charging to reach a full recharge, but only 2-3 hours 

with Level 3 charging. Fast-charging an EV with 100-mile driving range can provide 80 

miles of urban-driving range in less than 30 minutes.

 Level 2 charging uses a 240 

V, 20-80 A circuit, enabling a much shorter charge time. With Level 2 charging, a full 

recharge requires less than 4 hours for a PHEV40 SUV and about half hour for a PHEV10 

small car. Level 3 charging uses a 480 V, three-phase circuit, typically providing 60-150 kW 

of off-board charging power. Level 3 charging for PHEVs is probably not necessary due to 

small battery capacity and the vehicles’ internal combustion engine range extended design. 

For this reason, it is not envisioned that manufacturers will equip all PHEVs with capability 

for accepting Level 3 charging. In addition, due to the relatively small battery when 

compared to an EV, battery charge can be completed at home or workplace where vehicle 

parking duration is normally long. High cost, lack of 3-phase power, and potential safety 

concerns also make Level 3 implementation in these places unlikely, at least for the near term. 

58 In commercial places where drivers 

park and conduct personal or business activities, 1-2 hours of Level 3 charging is sufficient to 

provide an 80% rechargeX,59

Level 1 charging may prove to be appropriate for a significant fraction of the initial 

EV market. Tesla has reported that, based on their experience, there is potential for 

approximately 25% of the 244-mile range Tesla Roadster EV to make use of Level 1

charging.

for most EVs. 

60

 

V For the purposes of estimating charging times, it is assumed that a small EV consumes ~200 AC Wh/mile, 

mid-size EV or PHEV is 300 AC Wh/mile, and larger PHEV SUV is 350 AC Wh/mile; Level 1 charging power 

is assumed to be 1.44 kW nominal; Level 2 is 3.3 kW nominal on 20 A rated circuits (208 x 16); and Level 2 

charging is 6.6 kW nominal on 40 A circuits (208 x 32).

 It may also be more appropriate to consider average charge times that correspond 

to normal daily use instead of what is required for the exceptional circumstance to charge a 

fully depleted EV. At the national average of 28 miles of driving per day, a small EV would 

only require ~7 kWh to charge. This would require less than 5 hours with a standard Level 1 

cordset. An important feature available on many Level 1 cordsets or grid-connected vehicles 

is the ability for the user to select a lower-than-usual charge rate so that users may make use 

of lower-capacity, non-dedicated Level 1 circuits until a dedicated circuit is installed.

W A PHEV20 is a PHEV with a 20-mile charge-depleting range, or, the range of battery operation over which 

energy is consumed from the battery at a greater rate than it is recharged through regenerative breaking. Once 

the battery is sufficiently depleted, the vehicle operates in charge sustaining mode, during which time the energy 

captured through regenerative breaking is roughly equivalent to the rate of battery energy consumption; this 

mode is identical to the operation of a grid-independent HEV. The nomenclature is analogous for PHEV with 

larger (e.g., PHEV40 has a 40-mile charge-depleting range) or smaller (PHEV10 has a 10-mile charge-depleting 

range) batteries.

X OEMs have indicated that fast charging is expected to replace 80% of max state-of-charge
Chapter 4

4-8 

Currently, there are approximately 1,000 charging stations in the United States.61 

Most of these stations allow public access, while the rest are restricted for workplace use. 

Home charging, which is not included in this count, is considered more important for 

EV/PHEV market success,62

Although there is not clear data indicating home charging capacity, two indicators of 

charging readiness are the availability of a garage or carport, where the electric circuit is 

usually equipped, and the proximity of an electrical outlet. Having a garage or carport does 

not necessarily mean charging readiness, as a garage may lack parking functionality.

 which is understandable since home is where a vehicle parks the 

most often and longest. 

Y For 

example, garages in old homes can be too small to hold today’s large vehicles, forcing the 

owners to park their vehicles on the driveway, and some garages may mainly be used for nonparking purposes. One alternative measurement of home charging readiness is the availability 

of an electric outlet where the vehicle is usually parked when arriving home. According to a 

survey conducted by University of California, Davis (UCD),

63,64 61%, 52%, 44%, and 36% of 

the U.S. new vehicle buying households have an electric outlet within 50, 25, 15, and 10 feet, 

respectively, from the home parking location.Z

The home charging availability for a specific consumer will need to be differentiated 

among EV/PHEVs with different battery capacity. The electric outlets in existing homes are 

most likely ready for Level 1 charging, which is about sufficient for fully recharging a 

PHEV20 SUV during normal nighttime, provided the outlet is not being heavily utilized by 

other loads. Shorter available charging time or owning a vehicle with a larger battery make 

the capability to fully charge overnight with a Level 1 system less likely, but upgrading to a 

Level 2 system in such cases will allow full recharge to happen more quickly. 

 These percentages are slightly lower than the 

garage ownership share in the American Housing Survey or the share of detached single 

house in the 2001 National Household Travel Survey data. 

The DOE-supported infrastructure projects described above in section 4.2.1 will 

collect data that significantly improve the understanding of how consumers interact with 

electric-vehicle support infrastructure. With respect to the availability of home charging, 

these data collection and analysis activities will identify how consumers use electric drive 

vehicles and infrastructure and how consumers respond to pricing signals with respect to 

vehicle charging as well as a myriad of other questions related to consumer acceptance and 

market viability, which can eventually be used to guide the much broader deployment of 

electric drive vehicles and charging infrastructure in the future. 

 

Y Based on the 2001 National Household Travel Survey (NHTS), 63.8% of the U.S. households live in detached 

single houses. According to the American Housing Survey (AHS), 62.5% of homes in the U.S., regardless of 

home type, include a garage or carport. The share is a little higher (65.4%) for year-round occupied homes, much 

lower (45.1%) for vacant homes and much higher (81.5%) for new constructions up to 4 years old. The closeness 

between the share of detached single houses from the 2001 NHTS data and the share of garage ownership from 

the AHS data should not be interpreted as that the form of detached single house is an equivalent indicator of 

garage ownership. The estimation closeness is more likely a coincidence, since not all detached houses include a 

garage or carport, and some homes with a garage or carport are attached homes.

Z These estimates are based on the one-day 24-hour travel diary completed by respondents from 2,373 U.S. 

households that represent U.S. new vehicle buying households. 
2017-2025 Technical Assessment

4-9 

4.2.3 Charging System Cost

Charging an electric vehicle or plug-in hybrid will generally require specialized 

equipment, including: 

A charger that converts electricity from alternating current (AC) from the electricity 

source to direct current (DC) required for the battery, and also converts the incoming 120 or 

240 volt current to 300 or higher volts. Grid-connected vehicles carry an on-board charger 

capable of accepting AC current from a wall plug (Level 1 circuit) or, from a Level 2 

charging station. On-board charger power capability ranges from 1.4 to 10 kW and is usually 

proportional to the vehicle’s battery capacity.AA The lowest charging power,BB

The charging station needed to safely deliver energy from the electric circuit to the 

vehicle, called electric vehicle support equipment (EVSE). The EVSE may at a minimum, be 

a specialized cordset that connects a household Level 1/120V socket to the vehicle; otherwise, 

the EVSE will include a cordset and a charging station (a wall or pedestal mounted box 

incorporating a charger and other equipment). Charging stations may include advanced 

features such as timers to delay charging until off-peak hours, communications equipment to 

allow the utility to regulate charging, or even electricity metering capabilities. Stakeholders 

are working on which features are best located on the EVSE or on the vehicle itself, and it is 

possible that redundant capabilities and features may be present in both the vehicle and 

EVSEs in the near future until these issues are worked out. EVSE and vehicle manufacturers 

are also working to ensure that current SAE-compliant “basic” EVSEs are charge-compatible 

with future grid-connected vehicles.

 1.4 kW, is 

expected only when grid-connected vehicles are connected to 120 volt (Level 1) outlets, and 

all currently known PHEV and EV on-board chargers are expected to provide at least 3.3 kW 

charging when connected to a Level 2 (220 volt, 20+ A) charging station. The latest SAE 

connection recommended practice, J1772, allows for delivery of up to ~19 kW to an on-board 

vehicle charger. For higher capacity charging, a charging station that delivers DC current to 

the vehicle is incorporated off-board in the wall or pedestal mounted. 

Some public charging stations will likely include fee collection equipment or will be

networked with nearby fee-collection equipment already in use for parking fee collection. 

Under some local regulations, owners of charging stations cannot resell electricity;CC

 

AA Current mini-e’s and Tesla Roadsters presently have 11-19 kW on-board charger capability, though such high 

on-board power levels are not expected to be common in the majority of upcoming EV/PHEVs.

 unless 

the utility itself owns the stations or can directly bill the vehicle owner, the station owner can 

only charge a flat or time-based fee to the vehicle driver. This may require credit/debit card 

readers, pay-to-park kiosks or standard parking meters (in a commercial parking lot, kiosks or 

meters could already be available, so no additional equipment may be needed), or radiofrequency ID cards linked to a subscription service. For the utility to directly bill the vehicle 

BB Some EVs will have an 840W charge setting to allow for a shared Level 1 circuit CC One exception is provided by the California Public Utilities Commission; it concluded in July 2010 that 

companies that sell electric vehicle charging services to the public will not be regulated as public utilities.
Chapter 4

4-10 

owner, the charging station or vehicle must include a communication link to the utility that 

will identify the vehicle or owner. 

An electric circuit located close to where the vehicle parks. A Level 1 circuit is 

standard household current, 120V AC, rated at 15 or 20 A (12 or 16 A usable). A Level 2 

circuit is rated at 208 to 240V and up to 80 A and is similar to the type of circuit that powers 

electric stoves (up to 50 A) and dryers (usually 30 A). Generally, level 1 and 2 circuits used 

for electric vehicle recharging must be dedicated circuits,DD

Optionally, separate metering (EUMD, end use measuring device) for the EV charger 

to allow time-of-day rates for EV recharging; otherwise, homeowners may choose to pay 

standard rates for EV charging or to have all household electricity on time-of-day rates, either 

option with a single meter. 

i.e., there cannot be other 

appliances on that circuit. For a Level 2 circuit, the homeowner or other user must install a 

charging station and will need a permit.

Protection for the charging stations, including wheel stops, protective bollards, etc. 

Where vandalism is a concern, additional costs may be incurred for fencing or security 

equipment. 

In addition to the costs of purchasing and installing charging equipment, charging 

station installation may include the costs of upgrading existing electrical panels and installing 

the electrical connection from the panel to the desired station location. These costs may be 

dramatically lowered if new construction incorporates the panel box and wiring required for 

charging stations, or even includes charging stations or outlets for charging stations as 

standard equipment. 

In addition to Level 1 and 2 charging stations, “Level 3” commercial recharging 

stations may be installed in areas where 3-phase power is available; these can deliver 300V600V, 3-phase 150-400 A DC power for rapid charging of EVs. These may be viewed as 

equivalent to gas station pumps due to a similar look. 

The current costs of charging stations are highly variable depending on the level of 

service (Levels 1 through 3, and alternative power capabilities within these categories), 

location (individual residence, grouped residences, retail or business, parking lot or garage), 

level of sophistication of the station, and installation requirements, including electrical 

upgrading requirements. Estimated costs for charging stations are included in table below. 

Table 4.2-2 Estimated Costs for Charging Stations65,66,67,68

Level

,a

Location Equipment Installation 

 

DD Some manufacturers are planning for lower-power level 1 charging which can be accomplished on a shared 

120V circuit.
2017-2025 Technical Assessment

4-11 

1 Single 

Residence

$30- $200 (charge cord only, 

included at no cost to consumer 

with EV/PHEV) when an 

accessible household plug (e.g., 

in a garage or adjacent to a 

driveway) with a ground fault 

interrupter is already available

$400-$1000+ may be necessary 

depending on difficulty of 

installing a new circuit at the 

desired location, but in most 

cases, owners with sufficient 

panel capacity would opt for a 

more capable 220 VAC Level 2 

installation instead of a Level 1 

dedicated circuit because the 

additional installation cost is 

only marginally higher 

2 Residential, 

Apartment 

Complex, 

or Fleet 

Depotb

3.3 kW EVSE (each): $300-

$4,000 

6.6 kW EVSE (each): $400- 

$4,000 

3.3- 6.6 kW installation cost: 

$400-$2,300 without 

wiring/service panel upgrade, or 

$2,000-$5,000 with panel 

upgrade 

2 Public $400-$3,800+ for each EVSE $3,000- $7,000+ installation 

cost, varying significantly with 

distances from service entrance 

and number of EVSEs installed 

3 Public $8,000-$50,000 a Detailed information on charger cost for each charging level and location and specific sources for cost 

estimates are available in Appendix G.

b Level 2 EVSE installation costs vary considerably for single-family residences, multi-family residences, and 

fleet depots, depending upon the need for wiring and service panel upgrades. The range depicted here reflects 

the anticipated variability of these costs. However, EPRI estimates that the typical residential Level 2 

installation costs to be approximately $1,500. See Appendix G for additional information.

For the 2017-2025 period, there is a major potential for cost reduction in EVSEs if 

either or both PHEVs and EVs enter the market in substantial numbers – particularly if strong 

markets for these vehicles develop, as expected, in Europe and Asia and EVSEs are 

manufactured globally and compete for market share in this country. Although the reduction 

potential for installation costs would likely be somewhat smaller than for equipment costs, 

installation costs may also be reduced by incorporating EV requirements into building codes 

for new construction, and through standardization of procedures and better training and 

availability of installers. For purposes of the analysis presented in Chapter 6, the agencies’ 

estimated costs for Level 1 and Level 2 in-home charging equipment for the 2017 to 2025 

time frame is within the range of the values shown above and is detailed in Appendix 

B4.2.2.6. 
Chapter 4

4-12 

4.2.4 Battery End-of-Life Value Assessment and Secondary Use Applications

 At the end of an EV/PHEVs useful life, the battery will likely not be fully exhausted 

and could be used for a number of other tasks. Such a used battery would have a secondary 

use value and this expected value could be applied to the original purchase price of the 

vehicle (minus an appropriate discount rate) to lower the overall cost, making electric vehicles 

more affordable for the American public. These batteries could be used in utility peak load 

reduction and management, substation upgrade deferrals, and grid stabilization applications, 

as well as renewable energy installations to store solar and/or wind power.69

This is a field being intensely studied at the present time and there is some uncertainty 

as to the extent of the market, as well as the value to the original vehicle purchaser. A 

summary of one such forthcoming study supported by DOE is in Appendix G. 

 Several electric 

utilities currently use large sodium-sulfer (NaS) batteries for these purposes and are exploring 

used EV/PHEV batteries as substitutes. These applications have specific requirements that 

could possibly be met by used automotive batteries. 

4.2.5 Potential Impacts on the Electric Utility and Distribution Infrastructure

The overall distribution system capacity is expected to be adequate for EV charging. 

However, the effect of EV charging on specific circuits within the localized distribution 

system has not been fully evaluated and the impacts are not clearly understood; though, this 

issue is under study by EPRI, DOE, and several electric utilities.

70

Distribution system components which may be at risk due to the increased loading are 

substations, primary and laterals feeders, and distribution transformers. Distribution 

transformers are of primary concern. Distribution transformers may be impacted by several 

factors, including total EV penetration, EV clustering, time of charging, ambient operating 

conditions and thermal characteristics of the transformer, the prevalence of air conditioning, 

and the topography and age of the distribution system. These factors affect the cumulative 

thermal history of transformers, leading to their increased “thermal aging” and potential loss 

of transformer life. DOE and others are studying the effect of PHEV/EV charging on thermal 

aging of distribution transformer insulation.

 Understanding the 

relationships between EV charging and the distribution system allows utilities to plan for 

additional stresses placed upon their systems as a result of EV charging.

Transformers are also impacted differently under Level 2 versus Level 1 charging. 

With more OEMs making public announcements to offer EVs, which are generally more 

likely to utilize Level 2 charging than PHEVs, there is further discussion of potential impacts 

to the infrastructure. Since Level 2 charging allows for charging power up to 14 times that of 

Level 1 charging, the distribution system impacts could be much more severe under Level 2 

charging assumptions. 
2017-2025 Technical Assessment

4-13 

Load diversityEE

Potential distribution system impacts reported in the literature indicate that overall 

and, particularly, in newer residential developments (30 years and younger) and rural areas, 

distribution system capacity is expected to be adequate for EV charging. However, the 

potential for distribution system overloading exists with higher concentrations of charging 

vehicles in older residential neighborhoods, such as those in some coastal or mid-western 

metropolitan areas.

 becomes an issue further upstream in radial distribution systems. 

With diversified load profiles, peaks by individual loads are averaged out. The secondary 

transformer is the first distribution system component that will be exposed to the large 

current. Thus, it is expected that EV/PHEV charging will have the greatest impact on those 

components. The diversity of distribution system component vintages, sizing, and design 

practices varies greatly across the U.S. Older distribution systems, which were initially 

designed to support lower per-customer demand, are more likely to be affected by PHEV/EV 

charging than newer distribution systems, which were designed to support higher percustomer demand. 

71

Time-of-use (TOU) rates

 These areas may be of concern to utility infrastructure planners. 

FF

The preceding discussion yields several important conclusions about the potential 

impacts on the electric utility and distribution infrastructure:

may incentivize customers to delay charging to off-peak 

periods later at night. While TOU rates are likely to shift loads, they will not alleviate 

potential negative impacts on the distribution infrastructure. Smart load control technologies 

may be required in order to sequence charging or to perform load coordination strategies for 

charging vehicles in order to mitigate possible distribution transformer impacts.

• The overall electrical distribution system capacity is expected to be 

adequate for EV/PHEV charging.

• There is some potential for localized impacts on distribution transformers, 

especially in older neighborhoods, depending on EV/PHEV charging load 

concentrations. However, the success of electric vehicles will not be 

limited by possible disruptions in the distribution system. Additional 

research is required to understand the magnitude and extent of the issue. 

• Smart load control technologies that include sequencing and coordinating 

the charging of vehicles for Level 2 charging could help mitigate possible 

transformer impacts.

 

EE Load diversity refers to electric loads which come online at random times. Non-diversified loads come online 

at the same time. So, if EV owners come home at 6:00 PM and plug in to charge, the load is not diversified. FF TOU pricing is a special electric rate feature under which the price per kilowatt-hour depends on the time of 

day; prices can be adjusted upward during periods of peak demand and downward during off-peak periods.
Chapter 4

4-14 

4.2.6 Voluntary Standards to Support PHEV & EV Infrastructure 

DOE has several ongoing activities to support the development of voluntary standards. 

These activities can be expected to accelerate under the May 21, 2010 Presidential 

Memorandum’s request for DOE to work with stakeholders on the development of voluntary 

standards and coordinate its efforts with the Department of Transportation, NHTSA, and the 

EPA.72

On a conceptual level, electric-drive vehicles differ from conventional gasoline 

vehicles in the way they are repowered: conventional vehicles are refueled and electric 

vehicles are recharged. But, on a practical level, the means by which repowering happens is 

also very different. Where gasoline pumps and measurement standards are already well 

established, the equipment and measurement devices facilitating and governing electric-drive 

vehicle recharging are still being discussed. Coordination of the means by which EVs and 

PHEVs communicate with the grid—both in terms of hardware and software—offers the 

benefit of assuring that all electric-drive vehicles can plug in almost anywhere. 

 While these efforts on voluntary standardization are important in enhancing longterm success of EV/PHEVs, they are not a prerequisite for a successful near-term market 

launch. 

The primary link between the DOE vehicle technology activity and industry standards 

is the Society of Automotive Engineers (SAE). The most significant development to date has 

been the adoption of the voluntary standard SAE J1772, specifications for the electrical 

connector between EV/PHEVs and electric vehicle supply equipment (Levels 1 and 2 

charging). DOE national laboratories have provided expertise, development and testing 

resources to support new SAE standards, as discussed further in the following sections. 

4.2.6.1 Opportunities for Voluntary Standardization 

There are numerous opportunities for standardization (or harmonization) in the plug-in 

vehicle-grid system, including hardware, software, communication and the human-machine 

interface (the device through which a driver interacts with the smart grid and/or charging 

device) – as exemplified in the following figure: 
2017-2025 Technical Assessment

4-15 

Figure 4.2-1 Opportunities for Standardization/Harmonization in the Plug-in VehicleGrid System

Several opportunities for standardization/harmonization are identified in the preceding 

simplified concept of vehicle-grid interaction (and, others are possible). Starting from the 

vehicle and moving upstream to the utility, the first opportunity is the charge coupler—the 

physical connector and vehicle receptacle for hybrid and electric vehicle charging and the 

means by which the vehicle interacts with EVSE. Several additional opportunities are within 

the EVSE: first, the permitting process to facilitate the installation of EVSEs, to be 

coordinated at the local government level; second, the compact metrology, or small device the 

EVSE uses to measure energy consumption; and, third, the method of communication—both 

in terms of hardware (wired and wireless universal communication technologies) and 

software/protocols (grid operator-home-vehicle communication). At the utility, software can 

be standardized or harmonized to facilitate grid-wide smart management with targeted goals 

such as balancing supply and demand and sequencing vehicle charging. 

4.2.6.2 Defining voluntary standards 

“Voluntary” standards, i.e., those not required by regulation,GG

 

GG Although voluntary in some regions of the US, SAE J1772 is essentially a regulatory requirement in 

California and many other states that have adopted the CA ZEV Regulation because California requires vehicles 

to comply with J1772 in order to earn ZEV credit.

address essentially all 

aspects of automobiles and are issued by several organizations around the world; for example 

the Society of Automotive Engineers (SAE) in the US, the International Organization for 

Home

Gateway Smart

Meter

35779

Human Machine Interface (HMI)

In-vehicle and remote communication;

Behavioral feedback

Opportunities for Standardization/Harmonization

in the Plug-in Vehicle-Grid System

Compact metrology

Low cost revenue-grade

sub-metering

Universal communication technologies

Wired (Power Line Communication-PLC);

Wireless (e.g., GPRS, internet, Software Defined Radio-SDR)

Producers

Utilities

Grid Operators

Grid operator-home-vehicle communication

Protocols for 2-way secure communication

-Vehicle ID, location, charge requirements/preferences

-Power available, price, charge time, recommendations

Comprehends smart grid interoperability standards

Back office software

Comprehends vehicle roaming;

Integrates vehicles in smart grid; 

Balances supply and demand

Electric Vehicle Supply Equipment (EVSE) 

Streamlined residential permitting and installation process; 

Consistent application of National Electrical Code (NEC)

EVSE

Charge couplers

Configuration;

Functionality;

Global interoperability

KH_ANL
Chapter 4

4-16 

Standardization (ISO) or the International Electrotechnical Commission (IEC) in Europe and 

the Japan Automobile Research Institute (JARI) in Asia. The electrical content of 

automobiles adheres to standards developed by the Institute of Electrical and Electronics 

Engineers (IEEE) and, as plug-in vehicles and EVSE utilize the electric power grid, they are 

subject to standards by Underwriters Laboratories (UL) as well as the fire and building safety 

standards by the National Fire Protection Association (NFPA) including the National 

Electrical Code (NEC). 

4.2.6.3 Standards for Electric Vehicle to Grid Interface

The Grid Interaction Technical Team (GITT) was initiated in 2009 to identify issues 

regarding vehicle electrification and related grid impacts, set functional requirements for the 

vehicle-grid interface and cooperate on key issues/projects to enable plug-in vehicles (PHEVs 

and EVs). The members include DOE (the Vehicle Technologies Program and the Office of 

Electricity Delivery and Energy Reliability), the domestic auto industry and selected electric 

utilities. Current DOE-funded projects under the auspices of the GITT focus on some of the 

immediate needs of the vehicle-grid interface, including: 

• A draft national template to streamline the permitting and installation 

process of electric vehicle supply equipment 

• The human-machine interface (HMI) for charger-grid communication 

standards validation 

• Technology development to support universal vehicle-grid communication 

• Standards for PHEV/EV Communications Protocol 

4.2.6.4 SAE Standards Development 

SAE is working with stakeholders to develop EV/PHEV and infrastructure-related 

standards. SAE J1772 is a standard for the “Electric Vehicle and Plug-in Hybrid Electric 

Vehicle Conductive Charge Coupler,” and describes the physical, electrical, functional, and 

performance requirements for all grid-connected vehicles in North America. Work is also 

progressing towards the development of improved grid connectivity for electric vehicle 

charging infrastructure through lower cost, secure, universalized wired and wireless 

communications technologies. 

SAE is working with organizations and consortia such as the International 

Organization for Standardization (ISO), International Electrotechnical Commission (IEC), 

utility companies, the Institute of Electrical and Electronics Engineers (IEEE), Electric Power 

Research Institute (EPRI), ZigBee Alliance, HomePlug Power Alliance, automotive OEMs 

and suppliers, and many others in the development of specifications and standards to address 

the requirements of the SmartGrid strategy. Several national laboratories directly support the 

committee activities, including Argonee National Lab, Idaho National Lab, National 

Renewable Energy Lab, Oak Ridge National Lab, and Pacific Northtwest National Lab. 
2017-2025 Technical Assessment

4-17 

A full list of applicable SAE standards—both completed and upcoming—is provided 

in Appendix G. 

4.2.6.5 International Cooperation and Activities 

Increasingly, vehicles are being developed to compete in a worldwide market. A 

manufacturer can realize significant cost savings by building a large number of standardized 

vehicles in several countries. International harmonization of EV/PHEV charging equipment 

and protocols can help speed the market penetration of these vehicles by more rapidly 

lowering the costs of these components. 

International cooperation relies on the members and projects of the joint DOE-auto 

industry-utility Grid Interaction Tech Team (see previous section) as well as national 

laboratory personnel that directly support the SAE standards committees to interact to 

promote global vehicle-grid interoperability through outreach and programmatic support for 

harmonization of US, European and Asian codes & standards in selected international venues. 

Specific support is provided to the Administration’s EU and China initiativesHH as well as the 

Departments of Commerce and State.II As mentioned in the preceding description of the SAE 

activities, there are U.S. Technical Advisory Groups (USTAGS) to the ISO activities, with all 

the groups listed on the SAE website.JJ

4.3 Hydrogen Infrastructure Overview

 

When run on hydrogen, fuel cell electric vehicles (FCEVs) produce zero tailpipe 

emissions making hydrogen an attractive alternative fuel. When produced from the 

reformation of natural gas (the method used for the vast majority of H2 currently produced) 

hydrogen reduces well-to-wheel (WTW) GHG (CO2 equivalent) emissions by approximately 

50 percent.73

4.3.1 Status Today 

 Unlike infrastructure for EVs and PHEVs, where the option of home charging 

exists, the successful rollout of FCEVs depends on the early and strategic placement of 

publicly accessible infrastructure to enable market penetration. This section of the report 

includes discussion on hydrogen infrastructure status today, costs and projections for 

technology improvement, rollout strategies, policies, and conclusions. 

4.3.1.1 Infrastructure Technologies

Hydrogen is produced through a variety of processes. Some are more suited for large 

scale centralized production; others are more often associated with on-site distributed 

production at traditional fueling stations. Most common technologies utilized today include: 

 

HH e.g., Smart Grid-EV Working Group of the EU-US Energy Council, EU-US Transatlantic EV Workshop, USChina Vehicle and Battery Technology Workshop

II e.g., EU ‘green’ trade mission, COP 15 and COP 16 UN Framework Conventions on Climate Change JJ See http://www.sae.org/servlets/works/
Chapter 4

4-18 

• Steam methane reformation - The U.S produces over 9 million tons of hydrogen annually. 

Ninety Five percent of that amount is produced from natural gas by steam methane 

reformation (SMR) at large scale centralized plants. Most is used at petroleum refineries, 

for food processing and other industrial uses. Renewable hydrogen may also be reformed 

from biogas, landfill gas and ethanol for example. High daily throughput stations (100+ 

kg/day) with ample space can utilize onsite steam reforming on-site. 

• Electrolysis - Electrolysis systems use electricity to split water into hydrogen and oxygen. 

The technology is compact, reliable, and has been used for decades in industrial, military 

and space applications. Today’s typical station electrolyser produces 60 kg/day and 

requires approximately 55kW-hr of electricity to generate a kilogram of hydrogen. A 

clean, renewable electricity source (such as hydro, wind, photovoltaic or natural gas fired 

plant) can minimize upstream GHG emissions from electrolysis. 

• Delivery - For those stations not producing hydrogen onsite, typically high pressure 

gaseous product can be delivered to the site in batches that can supply the station for a few 

days or even weeks, depending on station throughput. This method is easy to build but 

needs refilling regularly. Another common delivery method is trucked cryogenic liquid 

hydrogen, which is stored in much larger quantities at the station. 

• Pipeline – There are over 300 miles of hydrogen pipeline in Texas, Louisiana and 

California serving industrial demand. The hydrogen is not fuel cell grade and is of 

relatively low pressure (350 – 1500 psi typically). With minimal clean-up and added 

storage, compression, and dispensing equipment, this option can be an economical source 

for hydrogen infrastructure placement, where pipelines exist. 

• Co-generation - High temperature fuel cells for stationary or ancillary grid electricity 

production (hydrogen energy stations) can provide a fuel source for a hydrogen 

infrastructure. A jointly funded DOE/CARB/South Coast Air Quality Management 

District (SCAQMD) project at a waste water treatment plant near Los Angeles features a 

molten carbonate fuel cell run on treated anaerobic digester gas. The fuel cell produces 

electricity to run the plant, and tail gas from the anode will be further cleaned, compressed 

and dispensed at the on-site hydrogen station for FCEVs.74

4.3.1.2 Federal Demonstration Programs 

 

The map below shows locations of hydrogen stations (includes lift trucks and transit 

bus stations) in the U.S.75 Since 2004 the U.S. DOE Hydrogen Program has worked with 

multiple partners in several states including California, New York, Florida, Michigan and 

Washington D.C. to demonstrate FCEVs and infrastructure. The program worked in 

partnership with industry, academia, national laboratories, and Federal and international 

agencies to help overcome technical barriers through research and development of hydrogen 

production, delivery, and storage technologies, as well as to address safety concerns and 

develop model codes and standard. NREL has reported that over 130,000 kg of hydrogen has 

been produced or dispensed in 23 of the Nation’s 56 stations. 
2017-2025 Technical Assessment

4-19 

4.3.1.3 California Demonstration Programs

Although there is much FCEV activity ongoing throughout the U.S. many OEMs are 

focusing their pre-commercial vehicle rollouts in California. The state’s Zero Emission 

Vehicle (ZEV) regulation requires large volume automakers to produce a certain number of 

“pure” zero emission and “near zero” emission vehicles for sale in California as a percentage 

their overall sales.76

The SCAQMD which includes the greater Los Angeles area has been operating its 

“Five Cities” hydrogen stations for over five years now. Each fueling station supports OEM 

FCEVs and a fleet of five gas/electric hybrid vehicles that have been converted to run on 

hydrogen. The aim of the project is to stimulate demand for hydrogen fueling, accelerate the 

expansion of the region’s hydrogen fueling network, and educate the public on hydrogen 

powered vehicles. City officials and staff have used the converted hybrids in everyday city 

fleet driving and showcased them to community groups, neighborhood associations and 

schools. 

 To date, over 250 fuel cell vehicles have been deployed in the State 

fueling at over 26 limited access, private and public access fueling stations. 

To support continued roll out of FCEVs in California, the state has committed to 

partnering with infrastructure providers to develop a network of stations in the greater Los 

Angeles area, Sacramento and in the San Francisco Bay Area. The following chart shows 

infrastructure and co-funding amounts for stations supporting OEM FCEV rollouts. Cost 

share in most cases varied between 50-70% of expected station costs.

Table 4.3-1 Public Access Stations Nearing Completion in California 
Chapter 4

4-20 

Location & Station 

Proposer 

State 

Funds

(Millions)

Total Cost 

Estimated

(Millions)

Capacity

Kg H2/

day

Technology

Emeryville $2.7 $5.56 60 Electrolyzer

100 % renewable

Oakland $4.1 $ 5.96 180+ Liquid Delivery

33 % Biogas credits

San Francisco Airport $1.7 $2.41 120 Liquid Delivery

Burbank $300K/yr Not Available 100 Gas deliver and On-site Steam 

Methane Reformation

Los Angeles - CSULA $2.7 $4.4 60 Electrolyzer

100% renewable 

Los Angeles - UCLA $1.7 $4.32 140 On-site Steam Methane 

Reformation

Torrance $0 Not Available 50 Pipe line supplied

Harbor City $1.7 $2.47 100 High pressure delivered Hydrogen 

Fountain Valley $2.7 $8.19 100 High Temperature Fuel Cell; 100 % 

renewable from digester gas

Newport Beach $1.7 $4.03 100 On-site Steam Methane 

Reformation

4.3.1.4 Station and Hydrogen Costs 

The following chart shows actual and estimated ranges of costs to build 350/700 bar 

demonstration pre-commercial hydrogen stations in California. The figures include: site 

preparation, permits, engineering, capital equipment, utility connections, construction, 

renewables, and installation. It excludes operation and maintenance and real-estate. The third 

column figures are predicted cost ranges determined from an Institute of Transportation 

Studies (ITS) workshop held at the University of California, Davis. Appendix G shows 

information regarding the cost of hydrogen in the U.S. through 2050. 

Table 4.3-2 Actual and Estimated Station Costs by Technology 

Technology Station capacity 

kg/day

CARB Cost

$M 2008-11

ITS Est Cost 

$M 2012-1777

Tube trailer delivery 100 1 0.4-1.0

High pressure composite 

delivery 100 1.0-1.7 0.8-1.0 

Liquid delivery 100+ 1.7 - 2.7 1.1-1.4

Onsite electrolyzer(s) 60 - 130 2.0 - 4.0

(renewable) 1.4-2.0 

Onsite SMR 100-140 2.5 - 4.0 1.4-2.0

Energy station/gasifier 100+ 6.0 - 8.5

(renewable) n/a 
2017-2025 Technical Assessment

4-21 

4.3.2 Prospects for Cost and Technology Improvement 

Over the past several years, the DOE Hydrogen Program has tracked, set targets, 

researched and funded studies to better predict the costs to transition to different alternative 

fuels. The DOE 2009 target infrastructure performance metrics for hydrogen were set at 

$3/gasoline gallon equivalent (gge) with a target average hydrogen fueling rate of 1.0 

kg/minute. NREL reported that average fueling rates have improved from 0.66 kg/min in 

2006 to 0.77 kg/min in 2009, and early market hydrogen costs at an on-site natural gas 

reformation station ranged from $7.70 – $10.30, and onsite electrolysis ranged from $10.00 – 

$12.90 /gge.78 In this NREL study, the number of refuelings by all OEMs with both 

Generation 1 and Generation 2 vehicles totaled 25,811.79 However, independent of this 

project, industry panels concluded that at 500 replicate 1500 kg/day stations/year, distributed 

natural gas reformation could produce $2.75 – $3.50/kg and distributed electrolysis at $4.90 - 

$5.70/kg.80

4.3.3 Infrastructure Rollout Strategy 

 With the increased efficiency of FCEV relative to conventional vehicles, this 

makes hydrogen potentially competitive to conventional fuels such as gasoline. 

To help ensure that hydrogen infrastructure is in place to match planned vehicle 

rollouts, CARB and the California Energy Commission (CEC) conducted a confidential 

survey of OEMs. The following table shows the estimated number and timing of FCEV 

releases through the year 2017. The survey, conducted in late 2009, included an additional 

breakdown of regions and cities/clusters in both northern and southern California. 

Table 4.3-3 California Hydrogen Fuel Cell Vehicle Rollout Estimates

Year/Period 2010 2011 2012 2013 2014 2015-2017

Cumulative Number of 

Vehicles 

CARB/CEC 2009 Survey 

92 30 95 69 839 44,706 

4.3.3.1 Station Location Strategy

Pre-commercial hydrogen infrastructure will roll out in phases consisting of “clusters.” 

A Hydrogen Cluster could be a city or group of cities, group of neighborhoods or 

unincorporated areas that are or will be targeted as a unit in which OEMs plan to place 

FCEVs. Clusters have already been developed in southern California. The Santa 

Monica/West Los Angeles area, the Torrance/Redondo Beach areas, the Hollywood area, and 

the Irvine/Newport Beach areas each have at least one station operating with more under 

construction to ensure increased convenience, sufficient redundancy, and increased capacity 

for future vehicle rollouts.81

Depending on availability and customer acceptance, as vehicle numbers increase, 

station number and capacity will increase within the Clusters. Bridging stations connecting 
Chapter 4

4-22 

the clusters and regions as well as destination (vacation cities for example) will be added to 

the infrastructure. Infrastructure will expand and “secondary Clusters” will develop as the 

FCEV market expands and the vehicles become more main stream. 

4.3.3.2 Station Specifications

Pre-commercial hydrogen stations have made the transition from being “behind the 

fence,” to a near full retail experience. Station performance specifications now include 3 – 5 

minute back-to-back fills, both 350 and 700 bar dispensers, convenient 24/7 hours, with no 

attendant required and easy pay pumps. Extensive Codes and Standards have been developed 

to help ensure stations are designed and built to a consistently high standard, are safe and are 

compatible with all OEM vehicles. Appendix G provides a list of Codes and Standards that 

have been developed for hydrogen infrastructure. 

4.3.4 Policies and Partnerships 

Government policies and partnerships can assist in focusing work on the most 

important tasks needed for implementation of hydrogen infrastructure. Foremost in any 

alternative fuel vehicle rollout, timing and execution of alternative fuel infrastructure is 

difficult to achieve without help. A classic chicken and egg dilemma exists, more so with 

hydrogen than with most alternative fuels because of the newness of the fuel and the initial 

investment needed. 

4.3.4.1 Partnerships 

Partnerships such as the California Fuel Cell Partnership, made up of OEMs, energy 

companies, industrial suppliers, academia and government, have created important tools, 

communication pathways and served to build relationships between OEMs and fuel suppliers 

specific to hydrogen and fuel cell implementation efforts. Memoranda of Understanding 

(MOUs) like “H2 Mobility” in Germany for example are also being explored as a useful way 

to bridge the uncertainty regarding fueling needs and vehicle rollout plans. These MOUs 

between partners such as auto manufacturers, energy companies and local governments can 

formalize vehicle/infrastructure strategies and or goals surrounding vehicle volumes, timing, 

location and necessary fueling capacity. MOUs in Germany and Japan between major energy 

companies and OEMs will help define the business case for hydrogen stations and prepare for 

vehicle introductions. 

4.3.4.2 Government Funding

Federal, State and local co-funding for both vehicle incentives and infrastructure costs 

will likely be necessary for some years as a way of sharing risk with early adopters of FCEVs. 

For example, in California, Assembly Bill 118 (2008) added a vehicle registration fee to 

motorists to generate a fund for alternative fuel investments to help reach energy, GHG and 

air quality goals. An annual investment plan is developed and serves as a guidance document 

for the allocation of funding. Funding from this program has been made available for many 

alternative fuels, including hydrogen infrastructure.82
2017-2025 Technical Assessment

4-23 

Table 4.3-4 Scenarios of Government Support for Hydrogen Fuel Cell Vehicles and 

Infrastructure: Three Policy Cases*

* This table is for illustrative purposes only and does not necessarily reflect a recommendation that 

specific policies should be adopted at this time. 

4.3.4.3 Regulatory Incentives and Requirements

Short of the government support for development of new hydrogen stations to kick 

start the market sufficiently so that station volumes grow on their own, other policies or 

requirements may be necessary as shown in the three scenario table above.83

California’s Low Carbon Fuel Standard: Adopted in 2009, the Low Carbon Fuel 

Standard (LCFS) requires producers and importers of gasoline to ensure that the mix of fuel 

they sell into the California market meets, on average, a declining standard for GHG 

emissions. The standard is measured on a lifecycle basis in order to include all emissions from 

fuel consumption and production, including the “upstream” emissions that are major 

contributors to the global warming impact of transportation fuels. Because hydrogen has a 

very low well to wheel carbon content, some regulatory incentive exists for energy companies 

to provide hydrogen as part of their compliance strategy. 

 California is 

exploring a variety of approaches including both regulatory incentives and possible 

requirements for installation of stations to ensure that enough stations are available to market 

FCEVs successfully.
Chapter 4

4-24 

Clean Fuels Outlet: In the 1990s when it was thought that California’s Low Emission 

Vehicle regulation would need alternative fuel vehicles to meet the strict fleet average tailpipe 

standards, CARB adopted the Clean Fuels Outlet regulation that would require the installation 

of an alternative fuel pump if a specified number of alternative fuel vehicles needing that fuel 

were marketed in California. This was California’s approach to ensuring alternative fuel 

would be available when vehicles came to market. The thresholds that would trigger this 

program have not yet been reached. The program is currently being reviewed in the context 

of how it might be used to ensure sufficient hydrogen fueling stations. 

4.4 Conclusions

The combined understanding of home recharging, electric vehicle charging system

costs, and ongoing work to develop voluntary standards indicate that infrastructure to support 

electric-drive vehicles will be adequate to support EV/PHEV rollout in the near term. For 

areas where relative inexperience implies uncertainties—such as the need for and use of 

public infrastructure, and vehicle battery secondary uses—DOE activities have been designed 

and are underway to inform future decisions: Infrastructure deployment projects are 

underway and over the next 3-4 years will establish regional public charging networks and 

collect data on how and when consumers use them to clarify the future role of public charging 

in the U.S. In addition to confronting these technology challenges, DOE will continue to 

support a communication and information campaign at the local, national, and international 

levels. At the local level, DOE will continue to share information and best practice examples 

to ensure that cities and local planning organizations receive the best methods for facilitating 

vehicle electrification and the infrastructure to support it. At the national and international 

levels, DOE will continue to coordinate government activities to ensure that national and 

international voluntary standards for electric vehicles and support infrastructure work for U.S. 

auto manufacturers, utilities, and consumers. 

Regarding hydrogen, the considerable learnings brought about by DOE and other 

programs, and the leadership, partnerships and funding commitment of California have 

enabled pre-commercial hydrogen infrastructure to be built today. OEMs are sharing FCEV 

rollout strategies with government leaders so public resources can be paired with private 

sector investment. A number of automobile manufacturers have stated publicly that initial, 

early commercial production of FCEVs could begin as early as 2015 if infrastructure is ready. 

A general understanding has been achieved regarding how to create hydrogen station 

networks using clusters in specific first markets. Government policies including regulations 

and incentives are being developed to support and help guide the progress and help ensure 

success.
2017-2025 Technical Assessment

4-25 

Chapter 4 References

45 Woodard, Tracy, representing Nissan Motor Co., Ltd. (2010). Department of Energy Plug-In Vehicle and 

Infrastructure Workshop, Washington, DC. July 22, 2010.

46 Morrow, Kevin, Donald Karner, James Francfort. Plug-in Hybrid Electric Vehicle Charging Infrastructure 

Review (2008). Idaho National Laboratory report INL/EXT-08-15058. November 2008.

47 BMW (2009), Presentation by Dr. Thomas Becker given at United Nations Climate Change Conference, 

Copenhagen Denmark, December 2009.

48 Rivkin, Carl (2010), National Electric Vehicle Charging Station Permit Template, NREL (Golden, CO).

49 Pacific Gas and Electric Company (1999), “Electric Vehicle Infrastructure Installation Guide”, 

<http://www.pge.com/includes/docs/pdfs/about/environment/pge/electricvehicles/vehicle.pdf>, Accessed Aug 

17, 2010.

50 Electric Power Research Institute. Plug-in Electric Vehicle Infrastructure Installation Guidelines. September 

25, 2009.

51 National Research Council (2010). Transitions to Alternative Transportation Technologies--Plug-in Hybrid 

Electric Vehicles. Committee on Assessment of Resource Needs for Fuel Cell and Hydrogen Technologies.

52 Lin, Zhenhong and David Greene. PHEV Market Projection with Detailed Market Segmentation. TRB Annual 

Meeting CD-ROM, January 2010.

53 Woodard, Tracy, representing Nissan Motor Co., Ltd. (2010). Department of Energy Plug-In Vehicle and 

Infrastructure Workshop, Washington, DC. July 22, 2010.

54 Characterizing Consumers' Interest in and Infrastructure Expectations for Electric Vehicles: Research Design 

and Survey Results. EPRI, Palo Alto, CA and Southern California Edison, Rosemead, CA: 2010. 1021285.

55 BMW (2010). Presentation by Andreas Klugescheid given at the 18th Annual Meeting of the UN Planning 

Commission on Sustainable Development, New York, NY. May 12, 2010.

56 Kurani, Kenneth S., Jonn Axsen, Nicolette Caperello, Jamie Davies, Tai Stillwater (2009) Learning from 

Consumers: Plug-In Hybrid Electric Vehicle (PHEV) Demonstration and Consumer Education, Outreach, and 

Market Research Program. Institute of Transportation Studies, University of California, Davis, Research Report 

UCD-ITS-RR-09-21.

57 Morrow, et. al. (2008).

58 Alternative Fuels & Advanced Vehicle Data Center. Advanced Vehicle Testing Activity: Battery Chargers for 

Electric Vehicles. 

<http://www1.eere.energy.gov/vehiclesandfuels/avta/light_duty/fsev/fsev_battery_chargers.html>. Accessed 

Aug 17, 2010.

59 Nissan (2010). “Nissan Leaf, General Answers.” <www.nissanusa.com/leaf-electric-car/faq/list/general>, 

Accessed Aug 17, 2010.

60 JB Straubel, Tesla Motors Inc. CTO (2009), “Vehicle Fleet Experience Overview”, 2009 ARB ZEV 

Technology Symposium, Sept 21-22, 2009, 

<http://www.arb.ca.gov/msprog/zevprog/2009symposium/presentations/straubel.pdf>, Accessed Aug 17, 2010.
Chapter 4

4-26 

61 The U.S. Department of Energy (DOE) (2010). Electric Charging Station Locations. 

<www.afdc.energy.gov/afdc/fuels/electricity_locations.html>. Accessed on Aug 07, 2010.

62 Childers, Craig (2010). “Infrastructure Support: Experience and Installation.” Presentation at Plug-In 2010, 

San Jose, CA. July 28, 2010.

63 Axsen, Jonn and Kenneth S. Kurani (2010) Anticipating plug-in hybrid vehicle energy impacts in California: 

Constructing consumer-informed recharge profiles. Transportation Research Part D 15 (2010) 212–219.

64 Kurani, 2009.

65 Morrow, et. al. (2008).

66 May, James W. and Matt Mattila (2009). “Plugging In: A Stakeholder Investment Guide for Public ElectricVehicle Charging Infrastructure.” Rocky Mountain Institute. July 2009.

67 Electric Transportation Engineering Corporation (ETEC), 2009. Electric Vehicle Charging Infrastructure 

Deployment Guidelines British Columbia, July..

68 Electrification Coalition (2009). “Electrification Roadmap” accessible from 

http://www.electrificationcoalition.org.

69 Technical and Economic Feasibility of Applying Used EV Batteries in Stationary Applications, Sandia 

National Laboratories, Albuquerque, NM: 2002. 

70 Kintner-Meyer, M; K. Schneider; R. Pratt (2007). Impacts Assesment of Plug-In Hybrid Vehicles on Electric 

Utilities and Regional U.S. Power Grids. Part 1: Technical Analysis, Journal of EUEC, Volume 1, 2007. Electric 

Utility Environmental Conference, Tucson, AZ. January 22-24, 2007; Electric Power Research Institute (2010). 

18 Utility EV Charging Study.

71 Gerkensmeyer, C., MCW Kintner-Meyer, and JG DeSteese (2010). Technical Challenges of Plug-In Hybrid 

Electric Vehicles and Impacts to the US Power System: Distribution System Analysis. PNNL-19165. Pacific 

Northwest National Laboratory (Richland, WA).

72 Presidential Memorandum Regarding Fuel Efficiency Standards, May 21, 2010, Available 

http://www.whitehouse.gov/the-press-office/presidential-memorandum-regarding-fuel-efficiency-standards

73Hydrogen Pathways: Cost, Well-to-Wheels Energy Use, and Emissions for the Current Technology Status of 

Seven Hydrogen Production, Delivery, and Distribution Scenarios, NREL /TP-6A1-46612, September 2009.

74 “Validation of an Integrated Hydrogen Energy Station” DOE Hydrogen Program, FY 2009 Annual Progress 

Report.

75 NREL, www.afdc.energy.gov/afdc/fuels/hydrogen_locations.html.

76 “Frequently Asked Questions – The California Zero Emission Regulation”, California Environmental 

Protection Agency, Air Resources Board April 2010.

77 Institute of Transportation Studies, University of California Davis, Workshop, Roadmap for Hydrogen and 

Fuel Cell Vehicles in California: A Strategy through 2017, May 5, 2009.

78 http://nrel.gov/hydrogen/proj_learning_demo.html.

79 “Controlled Hydrogen Fleet Infrastructure Demonstration and Validation Project”, NREL, Composite Data 

Project Spring 2010.
2017-2025 Technical Assessment

4-27 

80 “Current (2009) State of the Art Hydrogen Production Cost Estimate Using Water Electrolysis”, NREL 

September 2009. http://hydrogen.energy.gov/pdfs/46676.pdf and Distributed Hydrogen Production From Natural 

Gas: Independent Review, National Renewable Energy laboratory, October 2006. 

www.hydrogen.energy.gov/pdfs/40382.pdf.

81 “Hydrogen Fuel cell Vehicle and Station Deployment Plan: A Strategy for Meeting the Challenge Ahead,” 

California Fuel Cell Partnership February 2010.

82 “2010-2011 Investment Plan for the Alternative Renewable Fuel and Vehicle Technology Program,” 

California Energy Commission, CEC-600-2010-001-CTD.

83 “Analysis of the Transition to Hydrogen Fuel Cells & the Potential Hydrogen Energy Infrastructure 

Requirements” ORNL/TM-2008/30.

Additional References

FreedomCAR and Fuel Partnership Codes and Standards Technical Team. Codes and Standards RD&D 

Roadmap – 2008. 

http://www1.eere.energy.gov/vehiclesandfuels/pdfs/program/cstt_roadmap.pdf

MYPP (Multi-Year Research, Development, and Demonstration Plan) 2007. Hydrogen Codes and Standards. 

Washington, D.C.: U.S. Department of Energy, Energy Efficiency and Renewable Energy.

http://www1.eere.energy.gov/hydrogenandfuelcells/mypp/pdfs/codes.pdf 

NRC (National Research Council) 2010. Review of the Research Program of the FreedomCAR and Fuel 

Partnership: Third Report. Washington, D.C.: The National Academies Press. 

http://www.nap.edu/catalog.php?record_id=12939 

NREL (National Renewable Energy Laboratory) 2010. Vehicle Codes and Standards: Overview and Gap 

Analysis. Washington, D.C.: U.S. Department of Energy, Energy Efficiency and Renewable Energy. 

www.nrel.gov/docs/fy10osti/47336.pdf. 

2017-2025 Technical Assessment

5-1 

5 Incentives and Flexibilities

This Chapter includes three sections. Chapter 5.1 provides an overview of the 

regulatory flexibilities and incentives contained in the MYs 2012-2016 final rule for the 

National Program. Chapter 5.2 includes a discussion of the potential regulatory flexibilities 

and incentives for MYs 2017 and later which the agencies received input on during our 

meetings with stakeholders. Chapter 5.3 contains a summary of the non-regulatory incentives 

which the agencies received input on during our meetings with stakeholders. We note that 

some of the flexibilities discussed in this Chapter were used in our analysis of future scenarios 

in Chapter 6, though not all. As a result, when EPA and NHTSA undertake analysis for the 

upcoming federal rulemaking, we would not project additional per-vehicle cost reduction 

potential attributable to the flexibilities that have already been used to the current analysis. 

Chapter 6 contains a detailed discussion of the flexibilities we considered in the analytical 

assessment.

5.1 Overview of Existing Incentives and Flexibilities in the MYs 2012-2016 Program

EPA’s and NHTSA’s programs for MYs 2012 – 2016 provide compliance flexibilities 

to manufacturers, some indefinitely (such as those required by statute), and some that are 

designed, pursuant to agency discretion, to ease the transition during the early years of the

National Program to increasingly stringent regulations. These flexibilities are intended to 

help provide sufficient lead time for most manufacturers to make necessary technological 

improvements and reduce the overall cost of the program, without compromising overall 

environmental and fuel economy objectives. 

Under the CAFE program, Congress required through EPCA and EISA that NHTSA 

provide three specific types of compliance flexibilities – credits earned for over-compliance 

with a given standard, credits available due to production of alternative fuel vehicles, and the 

option of paying civil penalties in lieu of compliance.KK

 

KK We note that small volume manufacturers (i.e., those that produce less than 10,000 vehicles for sale 

worldwide) may also petition NHTSA for an exemption from the generally-applicable CAFE standards and 

potentially obtain their own individual fuel economy standards under 49 U.S.C. 32902(d), but NHTSA does not 

consider this a generally-available compliance flexibility like the others listed above, given the production 

volume limit.

 For the CAFE program, 49 U.S.C. 

32903 allows manufacturers to earn credits (denominated in tenths of a mpg) if their fleet 

average fuel economy for either passenger cars or light trucks exceeds an applicable CAFE 

standard. Credits may be applied to compliance with a standard in any of the 3 consecutive 

model years immediately before the model year in which the credits were earned (referred to 

as “carry-back”), or in any of the 5 model years immediately after the credits were earned 

(referred to as “carry-forward”). Credits may also be transferred by a manufacturer from one 

of their fleets to another, or traded (sold) to other manufacturers. Credits may not, however, 

be used to comply with the domestic minimum passenger car standard, and transferred credits 

are subject to a statutory cap, preventing manufacturers from increasing a fleet CAFE level by 

more than 1-2 mpg with transferred credits, depending on the model year. For purposes of the 

MYs 2012-2016 GHG standards, EPA adopted similar averaging, banking, and trading 
Chapter 5

5-2 

provisions allowing manufacturers to bank over-compliance credits, transfer the credits 

between their passenger car and light truck fleets, and trade them to other manufacturers. 

EPA, did not include the EISA cap on transfers – thus, for purposes of GHG compliance, 

manufacturers may transfer credits infinitely between their passenger car and light truck 

fleets.

EPCA has also long contained manufacturing incentives for alternative fuel 

automobiles. “Dedicated” (i.e., “pure”) alternative fuel vehicles and “dual-fueled” (i.e., 

“flexible-fuel” or “flex-fuel”) alternative fuel vehicles both receive special calculations to 

boost their fuel economy levels for compliance purposes under 49 U.S.C. 32905 and 32906. 

In EISA, Congress provided for a phase-out of the alt-fuel credit, so that while manufacturers 

can raise their CAFE levels up to 1.2 mpg using the alt-fuel credit through model year 2014, 

the amount of possible increase due to the credit decreases by 0.2 mpg each year until it 

phases out entirely after MY 2019. For purposes of the MYs 2012-2016 GHG standards, 

EPA will allow FFV credits in line with CAFE program limits, but only during the period 

from MYs 2012 to 2015. In MY 2016 and later, EPA will allow manufacturers to incorporate 

the emissions performance on alternative fuels by basing the FFV’s compliance value on test 

values for both gasoline and the alternative fuel, weighted according to data provided by 

manufacturers demonstrating that the alternative fuel is actually being used by FFVs in-use. 

The final compliance flexibility mandated by statute for the CAFE program, at 49 

U.S.C. 32912, is the option of paying civil penalties in lieu of compliance with an applicable 

CAFE standard in a given model year. Some manufacturers face unique compliance 

challenges because they serve relatively small market segments that tend to value vehicle 

performance and utility much more highly than fuel economy. For these manufacturers, fuelsaving technologies (such as, e.g., turbochargers), even when applied, are often used to 

increase performance or utility rather than to increase fuel economy. Some of these 

manufacturers have relied on this flexibility in past and recent model years, and for CAFE 

purposes, some manufacturers may continue to do so in the future. The CAA does not have a 

similar civil penalty flexibility – manufacturers who do not comply with applicable standards 

may not certify their vehicles for sale in the U.S.

For CAFE purposes, EPCA and EISA are fairly prescriptive with regard to what 

compliance flexibilities may be offered, but for GHG purposes, the CAA gives EPA broader 

authority to craft compliance flexibilities through regulation. The following paragraphs detail 

the flexibilities developed by EPA for the MYs 2012-2016 GHG program, in addition to the 

averaging, banking, and trading provisions and FFV credits noted above. 

EPA Air Conditioning System Credits: Air conditioning (A/C) systems contribute to 

GHG emissions in two ways. First, hydrofluorocarbon (HFC) refrigerants, which are 

powerful GHGs, can leak from the A/C system (direct A/C emissions). Second, operation of 

the A/C system also places an additional load on the engine, which results in additional CO2 

tailpipe emissions (indirect A/C related emissions). EPA allows manufacturers to generate 

credits by reducing either or both types of GHG emissions related to A/C systems. 

EPA Temporary Lead-time Allowance Alternative Standards (TLAAS): Manufacturers 

with limited product lines may be especially challenged in the early years of the National 
2017-2025 Technical Assessment

5-3 

Program, and need additional lead time. Manufacturers with narrow product offerings may 

not be able to take full advantage of averaging or other program flexibilities due to the limited 

scope of the types of vehicles they sell. For example, some smaller volume manufacturer 

fleets consist entirely of vehicles with very high baseline CO2 emissions. Their vehicles are 

above the CO2 emissions target for that vehicle footprint, but do not have other types of 

vehicles in their production mix with which to average. Often, these manufacturers pay fines 

under the CAFE program rather than meet the applicable CAFE standard. EPA believes that 

these technological circumstances call for more lead time in the form of a more gradual 

phase-in of standards. For these reasons, EPA included a temporary lead-time allowance for 

manufacturers that sell vehicles in the U.S. in MY 2009 and for which U.S. vehicle sales in 

that model year are below 400,000 vehicles. This allowance will be available only during the 

MY 2012-2015 phase-in years of the program. A manufacturer that satisfies the threshold 

criteria will be able to treat a limited number of vehicles as a separate averaging fleet, which 

will be subject to a less stringent GHG standard.LL

EPA Early Credits: EPA established opportunities for early credits in MYs 2009-2011 

through over-compliance with a baseline standard. The baseline standard is set to be 

equivalent, on a national level, to the California standards. Credits can be generated by overcompliance with this baseline in one of two ways – over-compliance by the fleet of vehicles 

sold in California and the CAA section 177 states (i.e., those states adopting the California 

program), or over-compliance with the fleet of vehicles sold in the 50 states. EPA is also 

providing for early credits based on over-compliance with CAFE, but only for vehicles sold in 

states outside of California and the CAA section 177 states. Under the early credit provisions, 

no early FFV credits are allowed, except those achieved by over-compliance with the 

California program based on California’s provisions that manufacturers demonstrate actual 

use of the alternative fuel. EPA’s early credits provisions are designed to ensure that there 

would be no double counting of early credits. Credits for over-compliance with CAFE 

standards during MYs 2009-2011 will still be available to be carried forward for 

manufacturers to use toward compliance with CAFE in future model years, just as before. 

 Specifically, a standard of 25 percent 

above the vehicle’s otherwise applicable footprint target level will apply to up to 100,000 

vehicles total, spread over the four year period of MY 2012 through 2015. In addition, 

manufacturers with between 5,000 and 50,000 U.S. vehicle sales in MY 2009 will have an 

increased allotment of vehicles, a total of 250,000, compared to 100,000 vehicles (for other 

TLAAS-eligible manufacturers). In addition, the TLAAS program for these manufacturers 

would be extended by one year, through MY 2016, for a total of five years of eligibility. For 

the smallest volume manufacturers, those with below 5,000 U.S. vehicle sales, EPA did not 

set standards but instead deferred standards until a future rulemaking. 

EPA Advanced Technology Incentive: EPA provides an additional temporary incentive 

to encourage the commercialization of advanced GHG/fuel economy control technologies--

including electric vehicles (EVs), plug-in hybrid electric vehicles (PHEVs), and fuel cell 

 

LL EPCA does not permit such an allowance. Consequently, manufacturers who may be able to take advantage 

of a lead-time allowance under the GHG standards would be required to comply with the applicable CAFE 

standard or be subject to penalties for non-compliance, unless they qualified for an exemption/alternative CAFE 

standard under 49 U.S.C. 32902(d).
Chapter 5

5-4 

vehicles (FCVs)--for model years 2012-2016. The advanced technology vehicle incentive 

program includes a zero gram/mile emissions compliance value for EVs and FCVs, and the 

electric portion of PHEVs, for up to the first 200,000 EV/PHEV/FCV vehicles produced by a 

given manufacturer during MY 2012-2016 (for a manufacturer that produces less than 25,000 

EVs, PHEVs, and FCVs in MY 2012), or for up to the first 300,000 EV/PHEV/FCV vehicles 

produced during MY 2012-2016 (for a manufacturer that produces 25,000 or more EVs, 

PHEVs, and FCVs in MY 2012). For any production of EV/PHEV/FCV vehicles greater than 

this amount, the compliance value for the vehicle will be greater than zero gram/mile, set at a 

level that reflects the vehicle’s net increase in upstream GHG emissions in comparison to the 

gasoline vehicle it replaces.MM The Final Rule notes: “EPA will reassess the issue of how to 

address EVs, PHEVs, and FCVs in rulemakings for model year 2017 and beyond, based on 

the status of advanced technology vehicle commercialization, the status of upstream GHG 

emissions control programs, and other relevant factors.” 84

EPA Off-cycle Credits: EPA is also providing an option for manufacturers to generate 

credits for employing new and innovative technologies that achieve GHG reductions that are 

not reflected on current test procedures. Examples of such potential “off-cycle” technologies 

might include solar panels on hybrids, adaptive cruise control, and active aerodynamics, 

among other technologies. This optional credit opportunity is currently available through the 

2016 model year. Credits must be based on real additional reductions of CO2 emissions and 

must be quantifiable and verifiable with a repeatable methodology. 

5.2 Potential Credit Programs, Incentives, and Other Flexibilities for 2017 and Later 

During the agencies’ outreach with stakeholders, manufacturers provided early input 

that several of the flexibility provisions in place for MYs 2012-2016 should be retained for 

MY 2017 and later. Environmental groups also provided early input, as discussed below. As 

EPA and NHTSA develop the proposed rule for MY 2017 and beyond standards, the agencies 

will continue to consider the potential need for incentives and flexibilities in the 2017 and 

later program, including whether and how some of EPA’s MYs 2012-2016 provisions could 

be applied to the new program, as well as whether any additional provisions would be 

appropriate to address lead-time issues. Changes to flexibilities provided under EPCA/EISA 

would require new legislation; NHTSA intends to develop any proposed standards within the 

context of its statutory framework.

Most manufacturers support EPA continuing 3-year credit carry-back to cover prior 

debits, 5-year credit carry-forward for use in future years, credit transfers between car and 

truck categories, and credit trading between manufacturers. One manufacturer noted support 

for unlimited credit carry-forward. These provisions, collectively known as Averaging, 

Banking, and Trading (ABT), have been an important part of many mobile source programs 

under CAA Title II, both for fuels programs as well as for engine and vehicle programs. EPA 

believes, and manufacturers have confirmed, that ABT is important because it can help to 

address many issues of technological feasibility and lead-time, as well as considerations of 

 

MM See 75 FR 25436-25437.
2017-2025 Technical Assessment

5-5 

cost.NN

While not a flexibility in the same sense as other credit programs and incentives 

discussed in this chapter, several manufacturers supported the continued use of attribute-based 

standards using the vehicle’s footprint for setting GHG standards, consistent with EISA’s 

requirement that CAFE standards be attribute-based. A number of manufacturers also 

supported the use of separate passenger car and light-truck standards for the GHG standards, 

consistent with EISA’s requirement that CAFE standards for cars and trucks be separate, 

though one manufacturer indicated a single combined passenger car and truck standard 

(though still attribute-based) should be considered. 

 EPA will strongly consider proposing to continue these provisions in the MY 2017 

and later program, as these types of compliance flexibilities will remain important as 

standards become more stringent. As discussed above in Section 5.1, these provisions are 

required by EPCA and EISA for the CAFE program. 

Several smaller volume manufacturers have expressed continued concerns regarding 

lead-time, and support for additional flexibility to address the unique needs of small volume 

manufacturers such as the TLAAS program described above. In the MYs 2012-2016 Final 

Rule, EPA determined that smaller volume manufacturers needed additional lead time to meet 

the standards because their CO2 baselines are significantly higher and their vehicle product 

lines are limited, reducing their ability to average across their fleets compared to larger 

manufacturers. The need for this type of flexibility is tied closely to the level of stringency of 

the standards to be proposed, and will be analyzed in that context. 

EPA deferred small volume manufacturers (SVMs) with annual U.S. sales less than 

5,000 vehicles from the MYs 2012-2016 standards. EPA plans to consider establishing 

standards for these very small volume manufacturers as part of the MYs 2017-2025 

rulemaking. SVMs noted in discussions that SVMs only produce one or two vehicle types but 

must compete directly with brands that are part of large manufacturer groups that have far 

more resources available to them. There is often a time lag in the availability of technologies 

from suppliers between when the technology is supplied to large manufacturers and when it is 

available to small volume manufacturers. Also, incorporating new technologies into vehicle 

designs costs the same or more for small volume manufacturers, yet the costs are spread over 

significantly smaller volumes. Therefore, SVMs typically have longer model life cycles in 

order to recover their investments. SVMs further noted that despite constraints facing them, 

SVMs need to innovate in order to differentiate themselves in the market and often lead in 

incorporating technological innovations, particularly lightweight materials. Under the CAFE 

program, manufacturers who manufacture less than 10,000 passenger cars worldwide 

annually may petition for an exemption from generally-applicable CAFE standards, in which 

case NHTSA will determine what level of CAFE would be maximum feasible for that 

particular manufacturer if the agency determines that doing so is appropriate.85

 

NN NHTSA notes that it is statutorily prohibited from considering availability of credits (including the fuel 

economy credits for alternative fuel capability) in determining what levels of CAFE stringency would be 

maximum feasible for a given model year. 49 U.S.C. 32902(h).
Chapter 5

5-6 

Several manufacturers have also expressed support for the continuation of A/C system 

credits. EPA is strongly considering A/C credits for MYs 2017-2025. EPA has included A/C 

credits in the initial emissions modeling done to support this report, as described in Chapter 6 

and Appendix D. EPA plans to further evaluate the methodology used to determine credits, 

including A/C-related test procedures. 

Some manufacturers have also expressed support for the continuation of EPA’s offcycle credits program. The off-cycle credits for new and innovative technologies are 

currently available only through MY 2016. Manufacturers have noted that as long as the 

credits represent real-world off-cycle emissions reductions, the credits should be able to be 

generated beyond MY 2016. One manufacturer noted that company innovations do not end 

with MY 2016 and that technologies will always exist which do not show up on the test 

cycles. Also, credits give additional incentives for company investments in R&D and 

innovations. EPA understands this perspective and will evaluate the off-cycle credits 

provisions in the context of the MYs 2017-2025 program, including the potential need to 

update the technology eligibility criteria for determining whether a technology qualifies as 

new and innovative. 

Some manufacturers encouraged EPA to continue to offer FFV credits. EPA finalized 

provisions in the MYs 2012-2016 Final Rule to treat MY 2016 and later FFVs similarly to 

conventional fueled vehicles, in that FFV emissions would be based on actual CO2 results 

from emissions testing on the fuels on which it operates. In calculating the emissions 

performance of an FFV, manufacturers may base FFV emissions in part on vehicle emissions 

test results on the alternative fuel, if they can demonstrate that the alternative fuel is actually 

being used in the vehicles. Performance will otherwise be calculated assuming use only of 

conventional fuel. The manufacturer must establish the ratio of operation that is on the 

alternative fuel compared to the conventional fuel. The ratio will be used to weight the CO2

emissions performance over the 2-cycle test on the two fuels. EPA will consider whether it is 

appropriate to retain this approach in the MYs 2017-2025 rulemaking. In addition, one 

manufacturer raised the concept of providing credits for CNG vehicles and vehicles operating 

on E-25 and other bio-fuels.

 In the MYs 2012-2016 Final Rule, EPA established four pathways for manufacturers 

to earn early credits prior to MY 2012, and established baselines against which manufacturers 

can earn credits. For MY 2017 and later, we believe the credit carry-forward provisions are 

sufficient to provide manufacturers with credits for achieving reductions beyond those 

required by the MYs 2012-2016 standards. No additional baselines or other provisions would 

be needed if the credit carry-forward provisions remain in place. 

 For advanced technology vehicles, manufacturers support an advanced technology 

vehicle incentive in the form of a 0 g/mile compliance value for electric operation for MYs 

2017 and later. Two manufacturers also expressed support for additional credits in the form 

of “bonus” credits or multipliers for advanced technology vehicles. EPA proposed a credit 

multiplier for MYs 2012-2016 advanced technology vehicles but did not finalize it for reasons 

described in the Final Rule.86 Some environmental and public interest groups expressed 

concern that the 0 g/mi value does not adequately capture upstream emissions from the 

charging of electrified vehicles, and believe an upstream emissions factor should be included 
2017-2025 Technical Assessment

5-7 

in the compliance calculation for electrified vehicles. For CAFE compliance purposes, the 

fuel economy of such vehicle models is determined consistent with petroleum equivalency 

factors (PEFs) issued by DOE.87

5.3 Input on Non-regulatory Incentives from Stakeholders

 Current EVs do not receive infinite fuel economy ratings 

that would be equivalent to a 0 g/mi CO2 emission rate; for example, the MY 2008 Tesla 

Roadster received a fuel economy ratings of 248 mpg (equivalent to about 36 g/mi CO2 based 

on gasoline). EPA understands that the treatment of upstream emissions for EVs, fuel cell 

vehicles, and the electric portion of PHEVs is a critical issue for the upcoming rulemaking, 

and this issue is further discussed in Chapter 7. 

In addition to the regulatory incentives and flexibilities discussed in the previous 

section, the agencies recognize that there are many non-regulatory approaches that can 

promote the commercialization of low-GHG light-duty vehicle technologies. These 

approaches are outside the regulatory authority for NHTSA and EPA, but were raised in 

many of our stakeholder meetings (in particular the OEMs and the automotive supply firms) 

as potentially important drivers in the development and commercialization of advanced 

technology vehicles. This section will only identify and briefly discuss those non-regulatory 

strategies which were raised by stakeholders in our recent meetings. This is by no means a 

comprehensive list or discussion of the potential non-regulatory policies and incentives which 

could encourage low GHG/high fuel economy vehicles. 

The federal government performs automotive research and development (R and D) 

that is ultimately transferred to the private sector. Several of the OEMs identified this type of 

R and D support as an important the development of advanced vehicle technologies. The 

Department of Energy (DOE) is the federal lead on automotive R and D with extensive 

programs carried out at its national laboratories. DOE’s FY2010 budget for the Vehicles 

Technologies Program is $311 million, with major technology focuses on hybrid electric 

systems, advanced engines, lightweight materials, and fuels technologies. Other federal 

agencies have smaller programs, such as EPA which has a FY2010 budget of about $16 

million. One major focus of EPA’s program has been hydraulic hybrids, which are currently 

being commercialized in heavy-duty vehicles. The Federal Transit Administration (FTA) of 

the Department of Transportation (DOT) has a number of ongoing research and development 

activities focusing on leading edge propulsion systems for buses designed to reduce operating 

costs and harmful emissions. These activities include studies and demonstrations on vehicles 

using plug-in hybrid electric, fuel cell, battery-dominant, and hydraulic hybrid technology.

Federal research and development

88 

Several of the OEMs and the automotive supply companies suggested that federal 

assistance for R and D programs, as well as for capital investment, can play an important role 

for the introduction of advanced technology vehicles. Historically, the federal government 

has periodically provided financial assistance for private sector R and D through favorable tax 

policies. More recently, the federal government has taken a much more proactive role in 

stimulating private sector investments in new technologies by providing grants and lowFederal financial assistance for private sector R and D and capital investment
Chapter 5

5-8 

interest loans to automakers and suppliers for R and D and capital investment in breakthrough 

technologies with the potential to reduce fuel consumption and GHG emissions. For example, 

DOE has an Advanced Technology Vehicles Manufacturing Loan Program that has received 

appropriations of $7.5 billion for grants and loans to support the development of advanced 

technology vehicles and associated components in the United States.89 The FTA has provided 

approximately $100 million and plans to award an additional $75 million in FY 2010 under 

the Transit Investments for Greenhouse Gas and Energy Reduction (TIGGER) Program.90 

Through this Program, public transit agencies partner and contract with private sector 

organizations, manufactures, system designers and integrators in acquiring and deploying new 

technologies and systems that reduce energy and greenhouse gases. Additionally, through the 

National Fuel Cell Bus Program (NFCBP), the FTA is leading a $50 million Federal effort 

with the support and leverage of an additional $50 million in local and private contributions 

for the innovative design and demonstration of fuel cell powered vehicles that have zero or 

near-zero emissions. The ultimate objective of the NFCBP is the commercialization of fuel 

cell buses. An additional $13.5 million has been appropriated under the Program in FY 2010. 

Some automakers told the agencies that the federal and state tax credits and grants

played an important role in sparking the initial hybrid vehicle market, and could play an even 

more important role in promoting PHEVs and EVs in the future. Advanced technology 

vehicles often have higher up-front costs, due to more expensive components and/or lower 

production volumes, and any strategy that can reduce or offset the higher up-front cost to 

consumers can remove one of the most important barriers to greater consumer demand. The 

Energy Policy Act of 2005 established temporary federal income tax credits for buyers of new 

hybrid, diesel, dedicated alternative fuel, and fuel cell vehicles that meet certain requirements. 

For example, while available, consumers who purchased new hybrid vehicles received federal 

tax credits that ranged from a few hundred dollars to as much as approximately $3,000 for the 

Toyota Prius, the hybrid vehicle with the highest fuel economy. The federal hybrid vehicle 

tax credit has been phased out for many manufacturers who have exceeded the cumulative 

60,000 production cap per manufacturer for hybrids and diesel vehicles. More recently, the 

American Recovery and Reinvestment Act of 2009 extended the tax credits to PHEVs and 

EVs, which are now eligible for a federal tax credit up to $7,500 per vehicle for the first 

200,000 cumulative vehicle production per manufacturer. 

Economic incentives for low-GHG vehicles

Some states, such as California, have also adopted state grants for certain advanced 

technology vehicles. To date, both federal and state tax credits and grants for new vehicle 

purchases have been provided to consumers, but it is also possible for tax credits to be 

directed to manufacturers who sell advanced technology and/or low-GHG vehicles.

Another direct approach for reducing the up-front cost of advanced technology or lowGHG vehicles to consumers would be a state sales tax exemption for buyers of vehicles that 

meet certain requirements. Of course, without limitations such as cumulative production 

caps, federal tax credits and exemptions from state sales taxes could have important impacts 

on government revenues. 

Non-economic incentives for owners of low-GHG vehicles
2017-2025 Technical Assessment

5-9 

Some automakers have specifically indicated that high occupancy vehicle (HOV) 

access has been an important incentive for hybrid-electric vehicle owners, and could 

potentially be for EV and PHEV owners as well. By providing two important incentives—

reduced travel time and improved trip time reliability—HOV lane access can be a big 

incentive in some urban areas. The Safe, Accountable, Flexible, Efficient Transportation 

Equity Act (SAFETEA-LU) of 2005 allows an exemption from the HOV occupancy 

requirement for vehicles certified as “low emission and energy-efficient.” Some state and 

local governments have allowed drivers of certain advanced technology vehicles to use HOV 

lanes regardless of the number of vehicle occupants. Analyses have suggested that HOV 

access has been an effective incentive in promoting hybrid vehicle sales in certain urban 

areas.

OO

One way to promote grid electricity use in EVs and PHEVs would be financial support 

for vehicle recharging infrastructure. The American Reinvestment and Recovery Act 

provides for a 50% tax credit on the installation of home charging equipment, up to a 

maximum cost of $2,000, and on installation of commercial equipment up to a maximum cost

of $50,000. This tax credit expires at the end of 2010. Current home recharging systems cost 

on the order of $2000 or so. These costs are expected to drop as charging systems become 

more widespread and in higher volumes, as discussed further in Chapter 4. Public highvoltage quick charging systems cost much more. Federal grants and/or tax credits to reduce 

this cost would address another barrier to consumer demand. Many automakers have also 

raised the practical challenges involved in the permitting process for charging stations. 

Federal coordination to establish streamlined standards and codes for permitting processes 

could assist in EV and PHEV commercialization.

Economic incentives for electric vehicle recharging systems/installation

PP Several of the OEMs and automotive 

suppliers suggested that these types of financial incentives for electric vehicle recharging 

systems can play an important role in encouraging the purchase of PHEVs and EVs. 

There are a number of tax incentives and disincentives that could be considered as part 

of an overall strategy to promote low-GHG light-duty vehicle technology, such as higher 

gasoline taxes (which would improve the relative economics of other fuels), a gasoline price 

floor (which would preclude the risk of extremely low gasoline prices undercutting other 

vehicle fuels), and reduced or zero alternative fuel taxes (for example, electricity currently 

pays no excise/road tax, and there is uncertainty about whether this would be maintained if 

and when EVs and PHEVS gain greater market share). A few of the OEMs suggested that 

higher fuel taxes could be used to encourage the purchase of high fuel economy/low GHG 

vehicles.

Tax incentives or disincentives

 

OO See, for example, “Impact of High Occupancy Vehicle (HOV) Lane Incentives for Hybrid Vehicles in 

Virginia,” David Diamond, LMI Research Institute, in Journal of Public Transportation, Vol. 11, No. 4, 2008, 

pages 39-58. Accessed at http://www.nctr.usf.edu/jpt/pdf/JPT11-4Diamond.pdf. PP See discussion in Chapter 4.
Chapter 5

5-10 

Several stakeholders have emphasized the need for the federal government to educate 

consumers about the energy and environmental performance of vehicles in general and 

advanced technology vehicles in particular. On August 30, 2010, EPA and NHTSA jointly 

announced proposed changes to the current fuel economy label for MY 2012 and beyond that 

will provide new information (such as tailpipe CO2 emissions) that will help consumers make 

more informed purchase decisions.

Vehicle Labeling

91

 

 Among other changes, the joint proposal includes 

several potential new label designs for PHEVs and EVs. 

Chapter 5 References

84 75 Fed. Reg. 25435, 25341 (May 7, 2010).

85 49 U.S.C. 32902(d).

86 75 Fed. Reg. 25434, (May 7, 2010).

87 65 Fed. Reg. 36986-36992 (June 12, 2000). See also 49 U.S.C. 32904(a).

88 See, e.g., http://www.fta.dot.gov/documents/HydrogenandFuelCellTransitBusEvaluations42781-1.pdf.

89 http://www.atvmloan.energy.gov/

90 See http://www.fta.dot.gov/planning/planning_environment_11424.html for more information on FTA’s 

TIGGER Program.

91 Revisions and Additions to Motor Vehicle Fuel Economy Label, Proposed Rule, 

http://www.epa.gov/fueleconomy/regulations.htm#sticker.
2017-2025 Technical Assessment

6-1 

6 Analysis of Scenario Costs and Impacts

6.1 Context 

The President’s May 21 memorandum indicates that today’s technical assessment 

should inform the rulemaking process, and that the subsequent (to the technical assessment) 

Notice of Intent (NOI) to Issue a Proposed Rule should describe, among other things, 

potential standards that could practicably be implemented for the 2017-2025 model years. 

For today’s technical assessment, the agencies conducted an initial fleet-level analysis 

of improvements in overall average GHG emissions and fuel economy levels. We have 

analyzed a range of potential stringencies for model years 2020 and 2025 (i.e., progressively 

lower GHG targets). We have also analyzed more than one illustrative technological pathway 

by which these GHG targets could be met. We considered these different technology 

pathways in order to address the difficulties in forecasting a single pathway and a single cost 

estimate for the penetration of different advanced technologies into the light-duty vehicle fleet 

at this time. We also believe this approach reflects the diversity in strategies we heard from 

the OEMs during the stakeholder outreach meetings, who at this time indicated they are each 

pursuing a range of technologies which they may use in the 2017-2025 time frame. The 

agencies believe that the analyses presented in this technical assessment permit a reasonable 

initial and approximate evaluation of the relative potential costs and effects of the aggregate 

stringency levels evaluated in this report. 

This analyses began with methods and information developed and applied in support 

of the recently-promulgated GHG standards for the 2012-2016 model years, and also reflect 

updates to the forecast of the future light vehicle fleet, as well as updates to the range and 

characteristics of anticipated GHG and fuel-saving technologies (as discussed in Chapter 3). 

However, we note, as discussed further below, that several of the simplifications 

employed here would not be used for purposes of a full Federal rulemaking analysis. This 

includes the requirements for both EPA and NHTSA to promulgate standards which meet 

each agency’s statutory requirements. The agencies have therefore provided a number of 

caveats to today’s analysis, discussed at greater length below. 

6.2 Analytic Approach 

This report presents modeling results that provide the technical basis for the analysis 

provided by EPA, NHTSA, and CARB in this chapter. The modeling was performed by EPA 

using the OMEGA model, which EPA utilized in the MYs 2012-2016 light-duty vehicle 

rulemaking. The key inputs for the analysis (e.g., the technology costs and effectiveness) are 

a result of the joint technical assessment of EPA, CARB, and NHTSA, as described in 

Chapter 3 of this report. 

OMEGA is EPA’s vehicle greenhouse gas cost and compliance model, and it can be 

used to simulate how manufacturers might respond to a specified vehicle CO2 emission 

standard. Broadly, the model starts with a description of the future vehicle fleet, including 
Chapter 6

6-2 

different vehicle platforms,

QQ

For the purpose of this analysis, over 60 vehicle platforms were used to capture the 

anticipated important differences in vehicle and powertrain design and utility between now 

and model year 2025. The model is then provided with a list of technologies which are 

applicable to various types of vehicles, along with their cost and effectiveness and the 

percentage of vehicle sales which can receive each technology during the time frame of 

interest. The model combines this information with economic parameters, such as fuel prices 

and a discount rate, to project how technologies could be added to vehicles in order to meet 

various levels of GHG control. The result is a description of which technologies could be 

added to each vehicle platform, along with the resulting cost, in order to meet a specified 

GHG performance level.

sales, base CO2 emissions, attributes such as vehicle mass and 

the extent to which CO2 reducing/fuel saving technologies are already utilized. 

RR We note that for purposes of this Technical Assessment Report, 

NHTSA did not perform modeling using the CAFE model, also referred to as the Volpe 

modelSS

As discussed above, for this technical assessment, the vehicle fleet was analyzed as 

one single industry wide fleet, irrespective of individual manufacturer differences. The size 

and composition of the fleet is otherwise equivalent to our projection of the entire fleet 

through model year 2025.

, to help analyze potential fuel economy standards as NHTSA has in recent CAFE 

rulemakings. The Volpe model simulates how manufacturers might respond to potential fuel 

economy standards on a yearly basis and supports analysis of fuel economy improving 

technologies, economic effects, environmental effects and safety effects. For today’s 

technical assessment, the agencies decided to use the OMEGA model. In upcoming joint 

rulemaking, NHTSA and EPA plan to make use of the CAFE and OMEGA models, 

respectively, for purposes of examining potential future CAFE standards and GHG emissions 

standards. 

92

 

QQ Vehicle platforms represent aggregations of similar vehicle models built by a manufacturer – for example, the 

Dodge Caliber, Jeep Compass and Jeep Patriot are built from a single platform, and include a mix of passenger 

cars and light trucks.

 Treating the entire fleet as a single fleet assumes, for example, 

averaging GHG performance across all vehicle platforms is possible irrespective of who the 

individual manufacturer is for a particular vehicle platform. This can be thought of as 

analyzing the fleet as if there was a single large manufacturer, instead of multiple individual 

manufacturers. Alternatively, it is equivalent to an assessment that assumes there are no 

statutory limits on the ability to transfer credits between passenger car and light truck fleets 

(which is the case under the CAA, but not under EISA), there are no market limits on the 

ability to trade them between manufacturers, and that all manufacturers fully utilize such 

flexibilities and experience no transaction costs in doing so. 

RR A description of OMEGA’s specific methodologies and algorithms, as well as a copy of the peer review 

documentation, is on the EPA website at http://www.epa.gov/oms/climate/models.htm. SS DOT’s CAFE Compliance and Effects Modeling System (commonly referred to as “the Volpe model”) is 

available at http://www.nhtsa.gov/Laws+&+Regulations/CAFE+-

+Fuel+Economy/CAFE+Compliance+and+Effects+Modeling+System:+The+Volpe+Model, which also 

provides model documentation, source code, inputs and outputs from NHTSA’s MY 2012-2016 rulemaking 

analysis, and links to prior versions and analyses.
2017-2025 Technical Assessment

6-3 

This approach allows evaluation of multiple scenarios in the context of a long-term 

technology-driven assessment. It focuses the analysis on the technology itself, independent of 

the individual manufacturer, and produces a result that indicates how the fleet could 

hypothetically achieve greater GHG reductions and increased fuel economy in the most 

efficient manner. This approach also allows the assessment for this report to be performed 

without consideration of the particular shapes of the passenger car and light truck attributebased curves, which are required by statute for CAFE purposes and will define the future 

federal standards. The unlimited averaging that is modeled may reach the same result 

irrespective of any specific attribute curves, and as long as the curves are calibrated to the flat 

standard that is modeled here (without prejudging the outcome of those curves, which will be 

carefully evaluated as part of the federal rulemaking process), the same fleet average may be 

required. 

We note that while the single fleet analysis approach simplifies some aspects of the 

analysis and does offer some advantages, there are also important limitations which will be 

addressed during the formal rulemaking process. Some of these limitations are statutory – the 

requirements for CAFE under EPCA and EISA are more prescriptive than for GHG standards 

under the CAA. Some of these limitations are more informational in nature – for example, a 

simplified analysis leaves the agencies unable to consider certain information about the 

potential effects of standards that the public (and particularly, the regulated manufacturers) 

are accustomed to seeing in NHTSA and EPA analyses. The agencies recognize and 

emphasize again that today’s analysis, while reasonable at this early stage in developing a 

National Program for post-MY2016 standards, is a first step, and that much more work will 

need to be completed for the upcoming NPRM, including full modeling by both EPA and 

NHTSA that will address each of the limitations, as discussed further below. As with the 

MYs 2012-2016 final rule, the agencies’ analyses for the NPRM will examine attribute-based 

standards under which each manufacturer is subject to its own individual passenger car and 

light truck CAFE and CO2 requirements, where the standard for each manufacturer is based 

on the production-weighted average of its passenger car and light truck targets, with the 

targets established in the attribute-based curves. In the upcoming rulemaking both EPA and 

NHTSA will also consider more than the overall industry-wide perspective provided in this 

Report, and intend to analyze potential future CAFE and GHG standards in a manner similar 

to that done for the MYs 2012-2016 rulemaking. For further information on the kinds of 

comprehensive analyses performed for the MYs 2012-2016 rulemaking, see 75 Fed. Reg. 

25324 (May 7, 2010). 

EPCA as amended by EISA requires separate attribute-based CAFE standards for 

passenger cars and light trucks, for each model year, that are the maximum feasible standards 

for that fleet of vehicles in that model year.TT

 

TT 49 U.S.C. 32902.

 Today’s analysis combines the passenger car 

and light truck fleets, considers flat standards, and considers only a single model year out of 

the nine model years that will be covered by the rulemaking.
Chapter 6

6-4 

EPCA as amended by EISA allows manufacturers to pay fines in lieu of complianceUU

and subject to certain limitations allows manufacturers to earn, trade, and transfer credits (and 

also earn credits for production of alternative-fueled vehicles in addition to simple overcompliance with applicable standards),VV but does not allow the availability of credits to be 

considered in determining what standards would be maximum feasible.WW

In determining what passenger car and light truck standards would be maximum 

feasible in each model year, EPCA as amended by EISA requires NHTSA to consider and 

balance four statutory factors: technological feasibility, economic practicability, the effect of 

other motor vehicle standards of the Government on fuel economy, and the need of the United 

States to conserve energy. While the tables of information presented below concerning 

technology cost, effectiveness, and lead-time, fuel savings and GHG emissions avoided, and 

other things, would help to inform NHTSA’s consideration of many of the statutory factors, 

this information alone may not be sufficient for purposes of a full rulemaking analysis. Other 

pieces of information have historically been used to decide what standards would be 

maximum feasible for each fleet for each model year, as discussed below.

 Today’s analysis 

combines the passenger cars and light trucks of all manufacturers into a single fleet, which is 

equivalent to assuming fully efficient trading and transfer of credits but is not allowed under 

EPCA, and does not include the additional credit that manufacturers would get under EPCA 

and EISA for alternative-fueled vehicles.

By modeling a single fleet rather than separate fleets for different manufacturers, we 

show the most cost-effective hypothetical path for the industry, as a whole, to any specific 

overall average fuel economy level or GHG emission level. Differential impacts on 

individual manufacturers, based on the different standards applicable to them given the 

production-weighted average of their specific passenger car and light truck targets (with the 

targets established in attribute-based curves), are thus not reflected in the current analysis. In 

addition, in representing the market as a single fleet produced by a single manufacturer, 

today’s analysis exhausts available technologies only when, given input assumptions 

regarding technology applicability and phase-in potential, no further technology can be 

applied to any vehicle model. In contrast, in past rulemakings when the fleet is represented in 

terms of discrete manufacturers’ separate passenger car and light truck fleets, some 

manufacturers have been estimated to exhaust available technologies in some model years at

stringencies well below those that would cause the aggregated manufacturer of a combined 

fleet to do so. This occurs because manufacturers produce different mixes of vehicles, with 

different levels of baseline technology utilization.

This is information that has historically been relevant to NHTSA’s determinations of 

whether standards are economically practicable.XX

 

UU 49 U.S.C. 32912.

 Understanding and recognizing the 

VV 49 U.S.C. 32903, 32905, 32906. WW 49 U.S.C. 32902(h). XX For example, in its recent analysis of its final MY 2016 CAFE standards, NHTSA estimated that required 

CAFE levels for passenger cars would average 37.8 mpg, but would range from 34.2 mpg (for Jaguar) to 41.1 

mpg (for Porsche). Additionally, that same analysis estimated that passenger car cost increases (relative to 
2017-2025 Technical Assessment

6-5 

differential impact of standards on manufacturers is one of the issues with which NHTSA has

grappled in determining maximum feasible standards. While the agency should not key its 

standards to the least capable manufacturer, the agency should be aware of the impacts in 

making its decision, since economic practicability is determined in part by the effects of the 

standards on vehicle manufacturers. The results presented in this report represent what the 

three agencies expect a hypothetical comprehensive-line vehicle manufacturer could achieve, 

given the assumptions made here regarding the composition of the fleet and the availability, 

cost, and effectiveness of various technologies. Note that the results presented here assume 

trading between auto firms, which has not occurred in the past and may not occur in the 

future. Among actual full-line vehicle manufacturers, we expect that a manufacturer-specific 

assessment based on footprint-attribute standard curves will result in costs which are higher 

and lower for the actual full-line manufacturers than a fleet-wide average due to the 

differences among their product offerings. With respect to smaller volume manufacturers and 

very low volume manufacturers (many of whom only produce high-performance luxury 

vehicles), the agencies would expect that, in general, the level of technology they would 

require and the costs they would incur would be higher than presented today, all other things 

being equal. Thus, in future analysis done for the joint federal rulemaking NHTSA and EPA

would expect individual companies’ projected costs will be higher or lower than the costs 

shown here, depending on their particular fleet mixes. The results of this more detailed 

analysis which will look at individual manufacturers could potentially change NHTSA’s 

evaluation of what CAFE standards are maximum feasible.

In addition, today’s analysis includes estimates of cost increases associated with the 

application of additional fuel-saving technology, as well as estimates of the corresponding 

reductions in fuel consumption and CO2 emissions, but does not include estimates of the 

corresponding social benefits. In the rulemaking the agencies will consider a much broader 

ranges of impacts of the standards.YY

Finally, today’s analysis does not include an evaluation of potential safety effects of 

new standards. NHTSA has historically considered safety effects along with the four 

statutory factors in determining appropriate levels of CAFE stringency, a practice recognized 

approvingly in case law over several decades. EPA also considered the potential safety 

effects of the 2012-2016 GHG standards in that recent rulemaking. Although today’s analysis 

 Estimates of social benefits both reflect and inform 

NHTSA’s consideration of the four statutory factors, and are often a subject of great interest 

among commenters to CAFE and GHG rules. 

 

compliance with the MY 2011 standard) would average $907 in MY 2016, but would range from $126 for 

Toyota to $1,884 for Ford. NHTSA also found that, without using credits, instances of technology exhaustion 

among a number of manufacturers would increase rapidly as stringencies increase faster than 4% annually. The 

aggregated approach of today’s analysis would have shown almost no technology exhaustion among the 

regulatory alternatives considered by NHTSA in the MY 2012-2016 final rule. See, e.g., 75 Fed. Reg. at 25600 

(May 7, 2010).

YY For example, NHTSA’s and EPA’s analysis supporting the MYs 2012-2016 final rule include estimates of 

social benefits associated with fuel costs (setting aside taxes), economic impacts of petroleum dependence, the 

social cost of carbon dioxide emissions (and criteria pollutant emissions), social costs (e.g., additional highway 

congestion) and benefits (the value of additional travel) of additional travel demand induced by fuel economy 

increases, and other factors. 
Chapter 6

6-6 

considers significantly greater levels of mass reduction than considered for the MYs 2012-

2016 final rule, it does not yield estimates of the corresponding safety implications. As 

discussed in Chapter 3, NHTSA, EPA, and DOE have undertaken a number of important, new 

safety-focused analyses to inform the future joint Federal rulemaking. NHTSA and EPA will 

include a detailed assessment of safety impacts at that time. 

Section 202(a) of the Clean Air Act, in contrast, provides broad discretion regarding 

how EPA can consider relevant factors in establishing GHG emissions standards for lightduty vehicles. For example, in setting GHG standards, section 202(a) of the CAA allows for 

the consideration of the availability of transferred or traded credits earned for overcompliance, the availability of credits for the use of advanced technologies and for A/C, and 

other credit-generation mechanisms. This broader discretion to reflect anticipated 

manufacturer behavior in response to available compliance flexibilities could allow standards 

established under the CAA to be more stringent than could be established under EPCA as 

amended by EISA, because the CAA allowed analysis would be able to show that more 

stringent standards could be feasible when those flexibilities are taken into account. 

However, as noted in several other locations in this report, there is significant additional 

information and analysis which EPA (and NHTSA) believe are necessary in order to support 

the future federal rulemaking, and EPA intends to develop a detailed analysis similar to that 

performed for the MY2012-2016 standard setting rulemaking, and to consider many of the 

same kinds of factors as it did in that rulemaking. 

We emphasize again, however, that the upcoming rulemaking to develop the next 

phase of the National Program will be based on a full analysis that is consistent with both the 

statutory framework that provided under EPCA as amended by EISA, and the flexibilities that 

can be considered under the CAA, just as the detailed analysis for the MYs 2012-2016 was 

conducted. With these explanations and caveats, NHTSA and EPA believe today’s analysis 

provides a useful means of comparing the scenarios discussed below. 

6.3 Development of Technology Pathways 

The analysis for this Technical Assessment Report considers two model years – 2020 

and 2025; four “technology pathways” – “A,” “B,” “C” and “D;” and four potential rates of 

increase in fleetwide average stringency – 3%/year, 4%/year, 5%/year, and 6%/year. This 

section of Chapter 6 discusses each of these elements, 6.4 describes other key inputs 

employed in the analysis, 6.5 presents the results of the analysis., and in 6.6 we present a 

sensitivity assessment related to battery cost estimates.

6.3.1 Model Years Considered

The analysis for this Technical Assessment Report considered two model years, 2020 

and 2025. Vehicles are typically redesigned every 5 years on average, and tend to receive a 

more modest “refresh” between major redesigns. By assessing potential scenarios at a fiveyear increment, we base our assessment on an assumption of the efficient use of capital 
2017-2025 Technical Assessment

6-7 

investments, engineering, financing, and other resources.ZZ

6.3.2 Scenario Stringencies Assessed

 This approach predicts that 

manufacturers therefore have the opportunity to redesign vehicles by 2020, and again by 

2025. 

For each model year and each technology pathway (described below) we analyzed 

four potential GHG targets representing a 3, 4, 5 and 6% decrease in GHG levels -- that is, 

starting with a 250 gram/mile overall average requirement in MY 2016, the g/mile CO2

scenario fleet-wide target was lowered at the rates of 3% per year, 4% per year, 5% per year, 

and 6% per year.AAA The 3, 4, 5, and 6% annual stringency increases were chosen for 

evaluation because they represent a reasonably broad range of targets for this initial 

assessment and because the rates of increase are consistent with CARB’s letter of 

commitment in response to the President’s memorandum. The assessment for each scenario 

is characterized using four broad metrics: per-vehicle cost increase, vehicle technology mix, 

net reduction in GHG emissions, and net reduction in fuel consumption. BBB

The scenario stringencies are shown below in terms of the specific grams/mile CO2 

values analyzed for MY 2020 and 2025, and like the 250 g/mile standard, include the 

potential usage of air conditioning emissions reductions (

 

Table 6.3-1). Air conditioning 

emissions reduction in the 2025 time frame was estimated at 15 grams compared to a 2008 

baseline system for all four technology paths.CCC,93 The increase in estimated air conditioning 

reductions relative to those projected in the MYs 2012-2016 timeframe is largely due to an 

anticipated increase in the use of alternative refrigerants.DDD

 

ZZ The MYs 2012-2016 final rule discusses the 5-year vehicle redesign practice in much more detail; see 75 FR 

at 25445 and 25573.

 Note that EPA has not made any 

determination at this time whether reductions due to improvements in air conditioning should 

be treated as a credit or a requirement during the 2017-2025 timeframe. 

AAA For this assessment these future targets were modeled as a flat, or universal, standard, rather than as 

attribute-based standards. Since the difference between attribute-based and flat standards is that flat standards 

apply the same requirement to every manufacturer in the fleet, while attribute-based standards allow different 

requirements depending on the vehicles that each manufacturer produces for sale, modeling the entire new 

vehicle fleet as if it were a single automotive firm causes flat standards and attribute-based standards to produce 

the same average required stringencies. For the upcoming joint federal rulemaking, NHTSA and EPA will 

propose attribute-based standards. BBB Additional impacts from fuel economy/CO2 standards such as co-pollutants, the social cost of carbon, or 

energy security premiums could be quantified. While this text does not discuss these topics, as discussed above, 

they are extensively discussed in the recent 2012-2016 final rule and will be discussed in the upcoming joint 

federal rulemaking.

CCC While the air conditioning reductions were modeled in this analysis, their relative cost-effectiveness suggests 

that manufacturers will use them to meet any standard. As the MYs 2012-2016 final rule allowed for a similar 

crediting program, all costs and benefits from the A/C system control are present in the reference case (MY 

2016) as well. A more complete discussion of the potential reductions in leakage from air conditioning systems 

is presented in Appendix D to the Technical Assessment Report. 

DDD In this analysis, EPA anticipates that prior to the MY 2020 timeframe, low GWP refrigerants will be 

approved under the Significant New Alternatives Policy Final Rule (1994). The use of low GWP refrigerants in 

this analysis does not indicate a decision on behalf of EPA. 
Chapter 6

6-8 

Table 6.3-1: Modeled GHG Targets 

Scenario Title

CO2 Target (g/mile) 

in MY 2020 (MPG)

CO2 Target (g/mile) 

in MY 2025 (MPG)

3% per year 221 (40) 190 (47)

4% per year 212 (42) 173 (51)

5% per year 204 (44) 158 (56)

6% per year 195 (46) 143 (62)

Note: The targets evaluated were CO2 targets which could be meet through reductions in CO2 as well as 

through air conditioning system hydroflurocarbon reductions converted to a CO2 equivalent value. MPGe is the 

equivalent MPG value if all of the CO2 reductions came from fuel economy improvement technologies. Realworld CO2 is typically 25 percent higher and real-world fuel economy is typically 20 percent lower. Thus, the 

3% to 6% range evaluated in this assessment for MY 2025 would span a range of real world fuel economy 

values of approximately 37 to 50 mpg, which correspond to the regulatory test procedure values of 47 and 62 

mpg, respectively. 

The reference case GHG emissions scenario assumes no further improvements in CO2 

emissions from the 2016 final rule standards, which are projected to produce a fleet wide 

average of approximately 250 grams CO2 per mile. This projected fleet wide average is 

assumed to remain in place indefinitely. We also assume that the fleet mix, including market 

segmentation, is unchanged between scenarios, though it does change over time from 2016 to 

2025 as discussed in Appendix A. Additionally, we did not explicitly model any crediting 

schemes in this analysis, other than the air conditioning emission reductions which are a 

fundamental component of EPA’s MYs 2012-2016 program, and the allowance of unlimited

car-truck credit transfer and inter-manufacturer trading which result from combining 

individual manufacturers into a single industry-wide fleet. 

6.3.3 Technology Pathways Considered 

As discussed in the introduction to this Chapter, the use of distinct “technology 

pathways” illustrate that there are multiple mixes of advanced technologies which can achieve 

the range of GHG targets we analyzed. The approach of considering four technology 

pathways for this assessment was chosen for several reasons. First, in our stakeholder 

meetings with the auto manufactures, the companies described a range of technical strategies 

they were pursuing for potential implementation in the 2017-2025 time frame. For example, 

some firms are pursuing an HEV focused strategy and others a mass reduction and next 

generation gasoline/diesel engine focused strategy. Using multiple technology pathways 

allows the agencies to evaluate how different technical approaches could be used to meet 

progressively more stringent scenarios. 

Second, this approach helps to generally capture the uncertainties we see with 

forecasting the potential penetration of and costs of different advanced technologies into the 

light-duty vehicle fleet ten to fifteen years into the future at this time. As discussed in 

Chapter 3, there is significant on-going technology development work occurring at the auto 

companies and in the broader automotive supply base on a large range of advanced 

technologies. The three agencies also have on-going technology cost, safety, and 

effectiveness work which has not been completed. Therefore we believed it is appropriate for 

this initial technology assessment to consider more than one technology pathway. 
2017-2025 Technical Assessment

6-9 

• Pathway A is intended to portray a technology path focused on HEVs, with less 

reliance on advanced gasoline vehicles and mass reduction, relative to Pathways B and 

C.

What are the four technology pathways?

• Pathway C represents an approach where the industry focuses most on advanced 

gasoline vehicles and mass reduction, and to a lesser extent on HEVs. 

• Pathway B represents an approach where advanced gasoline vehicles and mass 

reduction are utilized at a more moderate level, higher than in Pathway A but less than 

Pathway C.

• Pathway D represents an approach focused on the use of PHEV, EV and HEV 

technology, and less reliance on advanced gasoline vehicles, mass reduction. 

For MY 2025, as will be seen in the following section which presents the results of the 

assessment, as the CO2 stringency scenario increases progressively from 3% per year to 6% 

per year, the extent of electrification of the fleet (the combined penetration of HEVs, PHEVs, 

and EVs) increases for each of the three pathways. However, the degree of electrification is 

highest for Pathways A and D, and the least for Pathway C. This occurs because under 

pathway C, there is a higher degree of mass reduction and a higher penetration of advanced 

gasoline, which means that the penetration of HEV/PHEV/EVs needed to achieve the CO2 

stringency is lower, as compared to Pathways A, B and D. This impact is seen clearly for the 

4%, 5%, and 6% per year stringency scenarios. However, for the 3% per year scenario the 

distinction between Pathways B and C are very small, because the level of stringency is low 

enough that it requires only a modest level of mass reduction and advanced gasoline vehicle 

technology and the degree of electrification needed to meet the CO2 target (190 g/mile CO2 

in MY 2025) for Pathways B and C is minimal. Pathway D has the highest level of EVs, and 

also high levels of HEVs, in particular when compared to Pathways B and C. 

For MY 2020, in contrast, there is little distinction between the technology projected 

for the technology pathways A, B, and C for the 3%, 4%, and 5% per year scenarios, because 

the overall level of stringency for each of these scenarios in MY 2020 is modest, and the 

overall difference between the MY2020 emission target for 3%, 4%, and 5% per year is small 

compared to in MY 2025. For example, the 3% and 4% per year targets in MY 2025 are 17 

g/mile CO2 apart, but in MY 2020, the 4% per year target is only 9 g/mile more stringent than 

the 3% per year scenario (See Table 6.3-1 above). The combination of the less stringent 

targets in MY 2020 and the smaller delta between the emission targets results in only small 

differences between Pathways A, B, and C for the 3%, 4%, and 5% per year targets for 

MY2020. Only with the most stringent scenario analyzed for MY 2020, the 6% per year 

scenario, is there a significant difference in the technology penetrations between Pathways A, 

B and C for MY 2020. Note that due to time constraints we were not able to assess MY2020 

for Pathway D.

All four of these pathways include significant amounts of mass reduction, relative to 

2008 model year vehicles, ranging from 15 to 30% in 2025. The ability of the industry to 
Chapter 6

6-10 

reduce mass at the higher end of this range is an open technical issue which the agencies are 

carefully evaluating and will continue to as we move forward. In addition, as discussed in the 

joint 2012-2016 NHTSA and EPA final rule, the effects of vehicle mass reduction on safety 

should be analyzed from a societal fatality perspective, which could affect the maximum 

levels used for the future joint federal rulemaking. Although those effects have not been 

included in this Report, the two agencies will consider them for the future joint federal 

rulemaking. As discussed in Chapter 3, NHTSA, EPA, and DOE have a number of on-going 

projects in this area which will inform the future joint federal rulemaking.

The agencies note that these pathways, of course, are meant to represent ways that 

manufacturers could respond to eventual standards, and do not represent ways that they must 

respond to those standards. EPA’s GHG standards and NHTSA’s CAFE standards are 

performance-based and not technology mandating – manufacturers have wide discretion to 

apply the technologies that they choose in meeting the standards. 

In order to analyze four distinct technology pathways, we developed maximum 

technology penetration rates which we could implement within the OMEGA model. These 

maximum technology penetration rates are discussed in Chapter 3. These penetration rates 

were informed by the range of technology approaches we heard from different auto 

companies, and represent the three agencies’ initial assessment of potential technology 

feasibility and lead time considerations for model year 2025. 

How are the different technology pathways implemented in the analysis?

 A large number of technologies were considered by the agencies and are used in this

analysis (see Chapter 3 for a detailed discussion of all the technologies considered). For the 

purposes of evaluating the four technical pathways, we assessed the impact of approaches 

which placed a different emphasis on broad technology classes. The broad technology classes 

evaluated for purposes of this analysis are defined below. For a more detailed discussion of 

any individual technology, please see Chapter 3 of this report: 

• Conventional Spark Ignition (SI) - This technology category includes all technologies 

that are not contained in other categories such as gasoline direct injection engines, 

cylinder deactivation, six and eight speed automatic and dual clutch transmissions, and 

start-stop micro-hybrid technology. 

• Advanced SI - This technology includes gasoline spark ignition engines which are 

currently under development by OEMs and suppliers and are not anticipated to be 

widely used in the 2012- 2016 time frame. For purposes of this analysis, based on the 

agencies expert judgment to define these advanced SI engines, we modeled a direct 

injection gasoline engine with cooled exhaust gas recirculation, and with a larger 

degree of engine downsizing and higher level of turbocharging as compared to the 

turbo-downsized engines included in our analysis for the MYs 2012-2016 final rule. 

This technology is discussed in detail in chapter 3, and is similar to the technologies 

that many OEMs indicated were underdevelopment and which they anticipate will be 

introduced into the market in the 2017-2025 time frame. 
2017-2025 Technical Assessment

6-11 

• Hybrid – While the agencies recognize there are many types of full-hybrids either in 

production or under development, for the purposes of this analysis we have 

specifically modeled two types of hybrids, P-2 and 2-Mode type hybrids. 

• Plug-in Hybrid (PHEV) - This technology includes PHEV’s with a range of 20 and 40 

miles and is discussed in Chapter 3. As discussed in Appendix B, we project that 

PHEV technology is not available to some vehicle types, such as large pickup. While 

it is possible to electrify such vehicles, there are tradeoffs in terms of cost, electric 

range, and utility that would reduce the appeal of the vehicle to a narrower market. 

• Electric Vehicle (EV) - This technology includes vehicles with actual on-road ranges 

of 75, 100, and 150 miles. The actual on-road range was calculated using a projected 

30% gap between two-cycle and on-road range. These vehicles are powered solely by 

electricity and are not powered by any liquid fuels. As with PHEVs, and as discussed 

in Appendix B, we assumes that EV technology is not available to some vehicle types, 

such as large pickup. While it is possible to electrify such vehicles, there are tradeoffs 

in terms of cost, range, and utility that would reduce the appeal of the vehicle to a 

narrower market. These trade-offs are expected to reduce the market for other vehicle 

types as well, and for this analysis we have considered this in the development of the 

maximum technology penetration rates we use for the three pathways as discussed in 

Chapter 3. Note that for this assessment, we modeled EVs and did not consider fuel 

cell vehicles (FCVs). An assessment could be done considering FCVs in addition to 

EVs. However, such an assessment would need to carefully consider the availability 

of the necessary infrastructure to support FCV penetration. 

• Mass Reduction - This technology includes material substitution, smart design, and 

mass reduction compounding. The actual amount of reduction from the 2008 baseline 

was determined based on CBI provided by vehicle manufacturers, assessments 

provided by material suppliers, and existing studies in the literature, including the 

2010 report from Lotus Engineering. As discussed above as well as in Chapter 1 and 

Chapter 3, NHTSA and EPA intend to conduct a thorough assessment of the levels of 

mass reduction that could be achieved which is both technologically feasible and 

which can be implemented in a safe manner for the joint federal NPRM.

Chapter 6.4 discusses additional key inputs used in our technical assessment, and Chapter 

6.5 presents the results of the assessment. 

6.4 Other Key Inputs to the Analysis 

In addition to the technology effectiveness and cost estimates detailed in Chapter 3, 

and the development of the four technology pathways discussed above, key inputs to today’s 

analysis are summarized below, and are discussed in more detail in Appendix E. 

Vehicle Sales – The vehicle sales projection is based upon output from the National Energy 

Modeling System (NEMS) which is maintained by the Department of Energy’s Energy 

Information Administration. As in the MYs 2012-2016 Final Rule, the car and truck split was 

drawn from NEMS, while market segmentation was drawn from CSM Worldwide’s 
Chapter 6

6-12 

forecasting tool. Total market size is estimated in 2025 at 17.0 million vehicles (58% cars). 

Cars, in the context of NEMS, are defined using the pre-MY 2011 CAFE definition. For this 

analysis the DOT Volpe Center produced a custom run of NEMS. This run generated the 

same overall vehicle sales as the Reference Case for the Energy Information Administration’s 

Annual Energy Outlook (AEO) 2010,94

On-road Fuel Economy Shortfall – The “on-road gap” is the difference between the fuel 

economy experienced and the CO2 emissions emitted in actual driving, as opposed to the 

higher fuel economy and lower emission level experienced on the specified emissions tests

(the FTP and the HFET). The gap includes the real-world effects of wind, road grade, air 

conditioning usage, and a variety of other factors. As in the MYs 2012-2016 final rule, we 

assume a 20% gap from certification results, similar to today’s vehicles for internal 

combustion engines, as determined in EPA’s 2006 fuel economy labeling rulemaking.

but a different sales split between cars and light 

trucks. A detailed discussion on this topic is presented in Appendix A. 

95

Fuel Prices – The gasoline and electricity prices used in today’s analysis are drawn from the 

Reference Case Scenario AEO 2010.

 

Based on engineering judgment, the 2006 labeling rule analysis, and Confidential Business 

Information, we estimated a larger, 30% gap from test results for power consumed by electric 

motors in PHEVs and EVs in-use compared to the emissions test procedure. 

96 The gasoline fuel prices were $3.49 in 2025 including 

all taxes.EEE

Vehicle Miles Traveled Assumptions, Survival rates– VMT schedules and survival rates 

are available in Appendix E. Expected lifetime VMT is approximately 207,000 miles for cars 

in the 2025 time frame and approximately 246,000 miles for trucks in the 2025 time frame. 

While long term trends for VMT growth are uncertain, these schedules reflect the same 

projection methodology used in the MYs 2012-2016 final rule.

 Electricity prices are projected at approximately $0.11 in 2025 and gradually 

increase beyond that point. Beyond 2035, fuel prices were extrapolated, and the details are 

discussed in Appendix E. 

97

VMT Rebound - Chapter Four of the Joint Technical Support Document to the recent MYs 

2012-2016 final rule surveys previous studies, summarizes recent work on the rebound effect, 

and explains the basis for the 10 percent rebound effect EPA and NHTSA are using in the 

current technical analysis.

 As in the 2012-2016 final 

rule, these values derive from assumptions made in AEO 2010. 

98 The use of a 10 percent rebound effect in this analysis reflects an 

assumption that the rebound effect applicable to the MYs 2012-2016 vehicles will remain 

applicable throughout future time periods.FFF

Upstream Emissions – The upstream emission factors for gasoline is the same as that used in 

the MYs 2012-2016 final rule (2,478 g CO2eq / gallon).

 The agencies plan to conduct new analysis of 

the expected rebound effect in this time frame in a future rulemaking. 

99

 

EEE Note fuel taxes are included when models select technology options and when conducting payback analysis. 

However fuel taxes are not used for calculating social benefits.

 For the present report, we rely 

FFF It should be noted, however, that CARB, when adopting its initial GHG standards for MYs 2009-2016, relied 

on a study that found that a rebound effect on the order of 3 percent was appropriate. 
2017-2025 Technical Assessment

6-13 

upon the electricity emission factors produced by the EPA Office of Atmospheric Programs 

for an analysis of the American Clean Energy and Security Act of 2009 (H.R. 2454).100

Global Warming Potentials –The global warming potentials (GWP) used in this analysis are 

consistent with the MYs 2012-2016 final rule and with the 2007 Intergovernmental Panel on 

Climate Change (IPCC) Fourth Assessment Report (AR4). These GWP values are 1430 for 

HFC, 298 for NO2, and 25 for CH4. 

 This 

scenario assumes no new power sector regulations, but does assume construction of new 

plants to replace older retired plants. In 2025, it is assumed that electricity generation at the 

plant is equivalent to 558 g CO2 eq/kwh. This value should be adjusted upwards for feedstock 

gathering, transmission losses, and losses while charging the vehicle. After adjustment, the 

2025 electricity emission factor is approximately 703 g CO2 eq for each kW-hour consumed 

from the battery pack. 

101

6.5 Results of Analysis 

 At this time, the 1996 IPCC Second Assessment 

Report (SAR) global warming potential values have been agreed upon as the official U.S. 

framework for addressing climate change and are used in the official U.S. greenhouse gas 

inventory submission to the United Nations climate change framework, which is consistent 

with the use of the SAR global warming potential values in current international agreements. 

There are slight differences between SAR and AR4 values, most notably a 10% increase in 

the value used for HFC. 

This section presents the results from our modeling assessment of future stringency 

scenarios using the four technology pathways described in Chapter 6.3. The inputs are 

discussed in Chapter 3 of this technical report, and a detailed description of the analytic 

methodology is provided in Appendix F. In addition, all of the modeling input and output 

files used for the assessment are available on the web.GGG

This section presents the assessment results for model year 2020 and 2025. First, we 

present results at a “fleet-wide” level, that is at an aggregated level for the new model year 

fleet in 2025, for the four technology pathways we analyzed. The four technology pathways 

are discussed in detail in Chapter 6.3. Second, we present results at a car-fleet and truck-fleet 

level, in order to show the range of costs and impacts at a more detailed level. This is 

followed by the fleet-wide level results for the MY2020 assessment.

The following tables show summaries of per-vehicle increases in costs, as well as fleet 

wide reductions in fuel consumption and GHG emission reductions. The costs, fuel savings, 

and GHG emission reductions are calculated against the reference fleet of MY 2025 vehicles 

complying with the MY 2016 standards. The listed reductions in GHG emissions and fuel 

consumption are cumulative over the lifetime of the selected model years, and are the delta 

between the GHG emissions and fuel consumption under the MY 2016 reference case and the 

selected emission control/fuel economy scenario. 

 

GGG The input files, modeling tool, and output files used for this Technical Assessment Report are available at 

http://www.epa.gov/oms/climate/models.htm
Chapter 6

6-14 

In the assessment of potential future ranges of stringency presented in this report, we 

based our compliance analysis on the tailpipe emissions from all vehicles – thus EVs were 

evaluated at a 0 gram/mile CO2 level and PHEVs were evaluated as 0 gram/mile for the 

electric drive portion of the vehicles operation. For the purposes of the GHG impacts, we 

have included the resultant increase in upstream CO2 from the use of PHEVs and EVs in our 

overall calculation of the net CO2 reductions for each of the scenarios evaluated. As a result, 

a single stringency scenario may have a range of CO2e impacts depending on the 

electrification of the fleet.

Based on our initial assessment in this report, we see that the conventional vehicle 

technologies are typically more cost effective than any of the other technology options, 

followed by advanced spark-ignition (SI) engines, hybrids, electric vehicles, and PHEVs (see 

Table 6.5-2 for example).

HHH Mass reduction, which is generally highly cost effective, is 

often among the first technologies chosen. In our modeling assessment, vehicle technologies 

are applied in a ranked manner that values cost-effective reductions in fuel consumption and 

CO2 emissions.

The cost of the MY 2025 scenarios for the entire new vehicle fleet ranges from $773 

(3%, Path C) to $3,455 (6%, Path A) per vehicle, as shown in Table 6.5-1. Technology 

pathway C, which relies upon advanced gasoline technology and greater mass reduction as 

compared to Pathway A and B, demonstrates the lowest costs. Pathway A and B show a 

greater electrification of the fleet and somewhat higher costs. 

The GHG reduction over the lifetime of the MY 2025 vehicles ranges from 343 

million metric tons (MMT) CO2e avoided in the 3% scenario to between 531MMT and 593 

MMT CO2e in the 6% scenario. The range in CO2 emission reduction is due to differing 

degrees of fleet electrification under the technology pathways. MY 2025 vehicles, over the 

course of their lifetimes, will reduce between 0.7 billion barrels of gasoline consumption 

under the 3% scenario to 1.3 billion barrels under the 6% scenario. For reference, the 

NHTSA & EPA National Program in MY 2016 is projected to reduce 0.6 billion barrels of 

fuel and 325 MMT CO2e over the lifetime of MY 2016 vehicles. 

Table 6.5-1: Assessment Projections for Model Year 2025 Vehicles by Technology Path 

New Fleet Target

Per-Vehicle Cost increase

($)

Scenario CO2 MPGe* Path A Path B Path C Path D

3%/year 190 46.8 $930 $850 $770 $1,050

4%/year 173 51.4 $1,700 $1,500 $1,400 $1,900

5%/year 158 56.2 $2,500 $2,300 $2,100 $2,600

6%/year 143 62.1 $3,500 $3,200 $2,800 $3,400

 

HHHWe did not assign an explicit monetary value to driving range, and as a consequence, the model typically 

chose shorter range electric vehicles (EV75) over longer range electric vehicles (EV150), as each produced the 

same statutory CO2 reduction. The agencies will consider this issue in the context of a future rulemaking.
2017-2025 Technical Assessment

6-15 

Lifetime

CO2e Reduction (MMT)

Lifetime

Gasoline Reduction (Billion Barrels)

Scenario Path A Path B Path C Path D Path A Path B Path C Path D

3%/year 340 340 340 340 0.7 0.7 0.7 0.7

4%/year 440 440 440 405 0.9 0.9 0.9 0.9

5%/year 520 520 530 440 1.1 1.1 1.1 1.1

6%/year 530 550 590 470 1.3 1.3 1.3 1.3

Note – these costs, CO2 reductions, and fuel savings are relative to the 2016 EPA GHG standards. Per-vehicle 

cost represented the estimated cost to the consumer, including the direct manufacturing costs for the new 

technologies, indirect costs for the auto manufacturer (e.g., product development, warranty) as well as auto 

manufacturer profit, and indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of 

indirect costs.

* MPGe is the MPG equivalent to the CO2 target if all CO2 reductions occur from fuel economy improvement 

technologies. Real-world CO2 is typically 25 percent higher and real-world fuel economy is typically 20 percent 

lower. Thus, the 3% to 6% range evaluated in this assessment would span a range of real world fuel economy 

values of approximately 37 to 50 mpg, which correspond to the regulatory test procedure values of 47 and 62 

mpg, respectively. For the technical assessment, we have estimated a reduction of 15 g/mile CO2 equivalent 

from air conditioning system improvements, which would not actually translate into MPG improvements. 

The penetration of HEVs, EVs, and PHEV in MY 2025 varies considerably depending 

on the technology pathway and scenario, as can be seen in Table 6.5-2. As discussed in 

Chapter 6.3, Technology Pathway A places greater focus on HEV technology and less 

emphasis on mass reduction and advanced gasoline engine technology. Thus, in the 3%/year 

scenario, Path A results in 11% HEV penetration, and the most stringent 6% scenario 

increases HEV penetration to 68% for Path A, all with approximately a 15% reduction in 

mass for the new vehicle fleet. 

Pathway C places greater emphasis on mass reduction and advanced gasoline vehicle 

technology, and therefore the penetration of HEVs ranges from 3% up to 44% of the new 

vehicle fleet. The penetration of gasoline and diesel vehicles for each of the stringency 

scenarios is highest for Pathway C, and the degree of mass reduction is also the highest 

among the four pathways, ranging from 18% to 26%. 

Pathway B shows a technology approach in between Paths A and C, with advanced 

gasoline technology and mass reductions higher than for Path A but lower than Path C, and 

HEV penetrations lower than Path A but higher than Path C. This trend is not as strong for 

the 3% per year stringency scenario because the level of stringency does not require enough 

advanced technology to show much of a difference between Pathways B and C. 

Pathway D places a greater emphasis on PHEV and EVs than the other three 

technology paths. As a consequence, there are lower penetrations of advanced gasoline 

engines and of mass reduction, but more electric vehicles than in the other three pathways.

Table 6.5-2: Assessment Projections for Model Year 2025 Vehicles

New Fleet Technology Penetration Estimates

Scenario Technology New Vehicle Fleet Technology Penetration
Chapter 6

6-16 

Gasoline & diesel 

vehicles HEV PHEV BEV

Net Mass 

ReductionIII

3%/year Path A 89% 11% 0% 0% 15%

Path B 97% 3% 0% 0% 18%

Path C 97% 3% 0% 0% 18%

Path D 75% 25% 0% 0% 15%

4%/year

Path A 65% 34% 0% 0% 15%

Path B 82% 18% 0% 0% 20%

Path C 97% 3% 0% 0% 25%

Path D 55% 41% 0% 4% 15%

5%/year

Path A 35% 65% 0% 1% 15%

Path B 56% 43% 0% 1% 20%

Path C 74% 25% 0% 0% 25%

Path D 41% 49% 0% 10% 15%

6%/year

Path A 23% 68% 2% 7% 14%

Path B 44% 47% 2% 7% 19%

Path C 53% 44% 0% 4% 26%

Path D 29% 55% 2% 14% 14%

Table 6.5-3 present estimates of payback period and net lifetime savings. Payback 

period is the number of years it takes for the higher initial cost of the vehicle to be off-set by 

the vehicle’s fuel savings. As discussed in Chapter 6.4, we used AEO 2010 reference case for 

fuel prices, including fuel taxes, and we discounted the fuel savings using a 3 percent discount 

rate. The net lifetime savings is the total lifetime fuel savings for the vehicle discounted at 3 

percent minus the initial vehicle cost increase. As can be seen in Table 6.5-3, all MY 2025 

scenarios, regardless of technology pathway, have a positive net lifetime fuel savings between 

approximately $4,900 and $7,400, and for MY 2025 all of the scenarios and technology 

pathways pay back in 4.2 years or less.

 

III Please note that we show net mass reduction relative to model year 2008 vehicles. In the case of PHEVs and 

EVs, the batteries increase the weight of the vehicle. This battery weight increase is combined with the mass 

reduction technology to calculate net mass reduction for those vehicles.
2017-2025 Technical Assessment

6-17 

Table 6.5-3: Estimated Consumer Payback and Lifetime Savings 

For Model Year 2025 Vehicles (3% Discount Rate)

Payback (years) Net Lifetime Savings ($s)

Scenario Path A Path B Path C Path D Path A Path B Path C Path D

3%/year 1.6 1.5 1.4 1.9 $5,032 $5,084 $5,174 $4,882

4%/year 2.5 2.2 1.9 2.9 $5,862 $6,041 $6,198 $5,329

5%/year 3.1 2.8 2.5 3.6 $6,450 $6,705 $6,959 $5,532

6%/year 4.1 3.7 3.1 4.2 $6,162 $6,564 $7,379 $5,705

Note – these estimates are relative to vehicle which comply with the 2016 EPA GHG 

standards

 The following discussion presents information regarding the assessment projections of 

technology application and per-vehicle cost increases at the car-fleet and truck-fleet level for 

MY 2025. We categorized passenger cars and light trucks using the same category definitions 

as contained in the 2012-2016 National Program final rule. The results are presented 

sequentially by technology pathway (i.e., Pathway A, Pathway B, Pathway C, and Pathway 

D). The costs and CO2 emission levels discussed in this section reflect the same parameters 

as the previous fleet level summaries (Section 6.5.1.1). The cost increases are relative to the 

same vehicles under the MY 2016 standard, and the CO2e and MPGe levels include 

improvements to the vehicle air conditioning system, but exclude outlet electricity. 

Table 6.5-4 presents vehicle segment level results for Technology Pathway A showing 

the CO2e target level by segment, the MPG-equivalent level by segment, and the average pervehicle cost increase by segment for the four scenario stringency levels. Table 6.5-5 presents 

the corresponding vehicle segment level technology penetration rates and mass reductions for 

model year 2025 under the Technology Pathway A. The results show that as would be 

expected, the smaller size vehicles (e.g., the subcompact/compact segment and the midsize 

car segment), which start off at a lower average CO2 level, also generally have the lowest 

CO2 levels under the four stringency scenarios. 

Car and Truck Fleet Information for Technology Path A for MY 2025

As can be seen in Table 6.5-5, mass reduction is very cost effective across all vehicle 

categories, and under all stringency scenarios is at or near the maximum 15% we allowed 

under Pathway A. The penetration of HEV technology is significantly higher in the truckfleet for the 3% and 4% per year scenarios, and more evenly distributed between the car and 

truck fleets for the 5% and 6% per year scenarios. EVs first penetrate the new vehicle fleet in 

the 5% per year stringency scenario at a low level, and for the 6% per year scenario EVs 

represent 10% of all passenger cars, and only 2% of all light-duty trucks. PHEV technology 

is generally selected last in our assessment, and does not enter the new fleet until the 

assessment of the 6% per year category.
Chapter 6

6-18 

Table 6.5-4: Technology Path A, Assessment Projections for Model Year 2025: 

CO2, MPG, and Per-Vehicle Costs for Car and Truck Fleets

Scenario Vehicle Segment CO2e Level 

(g/mile)* MPGe Level*

Per-Vehicle 

Cost Increase ($)

3%/year All Cars 174 51.2 $659

All Trucks 225 39.5 $1,485

Fleet 190 46.7 $927

4%/year All Cars 162 54.9 $1,184

All Trucks 197 45.0 $2,792

Fleet 173 51.3 $1,705

5%/year All Cars 141 62.9 $2,231

All Trucks 192 46.4 $3,106

Fleet 158 56.4 $2,515

6%/year All Cars 117 75.9 $3,629

All Trucks 198 45.0 $3,095

Fleet 143 62.0 $3,455

*note, the CO2e value includes 15 grams/mile of CO2-equivalent reduction from air conditioning 

related GHGs (CO2 and HFC reductions), and the MPGe level is equivalent MPG value if all CO2 

reductions come from fuel economy improvements. Real-world CO2 is typically 25 percent higher and 

real-world fuel economy is typically 20 percent lower. Per-vehicle cost represented the estimated cost 

to the consumer, including the direct manufacturing costs for the new technologies, indirect costs for 

the auto manufacturer (e.g., product development, warranty) as well as auto manufacturer profit, and 

indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of indirect costs. 

Table 6.5-5: Technology Path A, Assessment Projections for Model Year 2025: 

New Fleet Technology Penetration for Car and Truck Fleets

Scenario Vehicle Type

Net Mass 

Reduction 

(%)

Net Mass 

Reduction 

(lbs)

HEV 

(%)

PHEV 

(%)

EV 

(%)

Adv. SI

(%)

3%/year

All Cars 15% 491 6% 0% 0% 23%

All Trucks 15% 673 24% 0% 0% 49%

Fleet 15% 550 11% 0% 0% 31%

4%/year

All Cars 15% 491 20% 0% 0% 46%

All Trucks 15% 673 65% 0% 0% 18%

Fleet 15% 550 34% 0% 0% 37%

5%/year

All Cars 15% 491 60% 0% 1% 27%

All Trucks 15% 673 74% 0% 0% 14%

Fleet 15% 550 65% 0% 1% 23%

6%/year

All Cars

14% 467 71% 3% 10% 15%

All Trucks 15% 665 61% 1% 2% 35%

Fleet 14% 529 68% 2% 7% 22%
2017-2025 Technical Assessment

6-19 

Car and Truck Fleet Information for Technology Path B for MY 2025

Table 6.5-6 presents vehicle segment level results for Technology Pathway B showing 

the CO2e target level by car-truck fleet, the MPG-equivalent level by car-truck fleet, and the 

average per-vehicle cost increase by car-truck fleet for the four scenario stringency levels. 

Table 6.5-7 presents the corresponding car-truck fleet technology penetration rates and mass 

reductions for model year 2025 under the Technology Pathway B. 

As can be seen in Table 6.5-7, mass reduction is very cost effective across all vehicle 

categories, and under all stringency scenarios is at or near the maximum 20% we modeled 

under Pathway B. The penetration of HEV technology is generally more focused in the truckfleet, and increases overall as the level of stringency increases. In general, when compared to 

Pathway A, the penetration of HEVs in Pathway B is lower. 

EVs first penetrate the new vehicle fleet in the 5% per year stringency scenario, 

though at a low rate of 1% for the fleet. This increases to approximately 7% of the fleet under 

the 6% per year scenario, with most of these concentrated in the passenger car vehicles. 

PHEV vehicles are only seen in the 6% per year scenario, and represent 2% of the vehicle 

fleet for Pathway B.
Chapter 6

6-20 

Table 6.5-6: Technology Path B Assessment Projections for Model Year 2025:

CO2, MPG, and Per-Vehicle Costs for Car and Truck Fleets

Scenario Vehicle Type CO2e Level 

(g/mile) MPGe Level

Per-Vehicle 

Cost Increase ($)

3% All Cars 170 52.4 $753

All Trucks 233 38.2 $1,047

Fleet 190 46.7 $849

4% All Cars 160 55.7 $1,070

All Trucks 202 44.1 $2,465

Fleet 173 51.3 $1,522

5% All Cars 146 61.0 $1,748

All Trucks 183 48.6 $3,335

Fleet 158 56.3 $2,263

6% All Cars 130 68.5 $2,698

All Trucks 171 52.0 $4,327

Fleet 143 62.1 $3,227

*note, the CO2e value includes 15 grams/mile of CO2-equivalent reduction from air conditioning 

related GHGs (CO2 and HFC reductions), and the MPGe level is equivalent MPG value if all CO2 

reductions come from fuel economy improvements. Real-world CO2 is typically 25 percent higher and 

real-world fuel economy is typically 20 percent lower. Per-vehicle cost represented the estimated cost 

to the consumer, including the direct manufacturing costs for the new technologies, indirect costs for 

the auto manufacturer (e.g., product development, warranty) as well as auto manufacturer profit, and 

indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of indirect costs. 

Table 6.5-7: Technology Path B, Assessment Projections for Model Year 2025: 

New Fleet Technology Penetration for Car and Truck Fleets

Scenario

Vehicle 

Type

Net Mass 

Reduction 

(%)

Net Mass 

Reduction 

(lbs) HEV (%) PHEV (%) EV (%)

Adv. SI

(%)

3%/year

All Cars 17% 572 4% 0% 0% 46%

All Trucks 19% 848 2% 0% 0% 66%

Fleet 18% 658 3% 0% 0% 52%

4%/year

All Cars 20% 655 5% 0% 0% 72%

All Trucks 20% 897 45% 0% 0% 45%

Fleet 20% 733 18% 0% 0% 63%

5%/year

All Cars 20% 654 30% 0% 1% 62%

All Trucks 20% 897 72% 0% 0% 21%

Fleet 20% 733 43% 0% 1% 49%

6%/year

All Cars 19% 630 27% 2% 9% 60%

All Trucks 20% 887 88% 1% 2% 9%

Fleet 19% 712 47% 2% 7% 44%
2017-2025 Technical Assessment

6-21 

Table 6.5-8 presents car-fleet and truck-fleet level results for Technology Pathway C, 

specifically the CO2e target levels, the MPG-equivalent target levels, and the average pervehicle cost increase for the four scenario stringency levels. Table 6.5-9 presents the 

corresponding car-fleet and truck-fleet technology penetration rates and mass reductions for 

model year 2025 under the Technology Pathway C. The results show that as with Pathways A 

and B, the car fleet, which start off at a lower average CO2 level, also has a lower CO2 levels 

under the four stringency scenarios as compared to the truck fleet. The per-vehicle cost 

increase difference between the car-fleet and truck-fleet is on the order of $300 to $350 for 

the 3% and 4% per year scenarios, but increases to approximately $2,000 for the 5% per year 

scenario and $1,600 for the 6% per year scenario. 

Car and Truck Fleet Information for Technology Path C for MY 2025

As can be seen in Table 6.5-9, mass reduction is very cost effective across both the car 

and truck fleets, and is on the order of 18% for the 3% per year scenario, and between 25 and 

27% for the high stringency scenarios. The penetration of HEV technology is similar between 

the car and truck fleets for the 3% and 4% scenarios, but in the 5% and 6% per year scenarios 

is more weighted towards the truck-fleet. Technology Path C has the overall highest use of 

the advanced gasoline technologies, and as can be seen the mix between the car fleet and the 

truck fleet is very dependent upon the level of stringency, with higher levels under the 3% , 

5% and 6% per year scenario in the car-fleet, but similar levels between cars and trucks in the 

4% per year scenario.

 

EVs penetrate the new vehicle fleet only in the 6% per year stringency scenario for 

Pathway C, and overall are concentrated in the passenger cars fleet, representing 5% of all 

passenger cars, and only 1% of all light-duty trucks. PHEV technology is not required in this 

assessment under Technology Pathway C. 
Chapter 6

6-22 

Table 6.5-8: Technology Path C Assessment Projections for Model Year 2025:

CO2, MPG, and Per-Vehicle Costs for Car and Truck Fleets

Scenario Vehicle Type

CO2e Level 

(g/mile) MPGe Level

Per-Vehicle 

Cost Increase ($)

3%

All Cars 169 52.6 $674

All Trucks 233 38.1 $980

Fleet 190 46.8 $773

4%

All Cars 154 57.9 $1,255

All Trucks 213 41.8 $1,604

Fleet 173 51.4 $1,368

5%

All Cars 148 60.1 $1,420

All Trucks 178 49.9 $3,412

Fleet 158 56.3 $2,066

6%

All Cars 130 68.3 $2,316

All Trucks 170 52.4 $3,909

Fleet 143 62.2 $2,833

*note, the CO2e value includes 15 grams/mile of CO2-equivalent reduction from air conditioning 

related GHGs (CO2 and HFC reductions), and the MPGe level is equivalent MPG value if all CO2 

reductions come from fuel economy improvements. Real-world CO2 is typically 25 percent higher and 

real-world fuel economy is typically 20 percent lower. Per-vehicle cost represented the estimated cost 

to the consumer, including the direct manufacturing costs for the new technologies, indirect costs for 

the auto manufacturer (e.g., product development, warranty) as well as auto manufacturer profit, and 

indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of indirect costs. 

Table 6.5-9: Technology Path C Assessment Projections for Model Year 2025:

New Fleet Technology Penetration for Car and Truck Fleets

Scenario Vehicle Type

Net Mass 

Reduction 

(%)

Net Mass 

Reduction 

(lbs)

HEV 

(%)

PHEV 

(%)

EV 

(%)

Adv. SI

(%)

3%/year

All Cars 17% 569 4% 0% 0% 32%

All Trucks 19% 839 2% 0% 0% 76%

Fleet 18% 653 3% 0% 0% 46%

4%/year

All Cars 25% 809 4% 0% 0% 96%

All Trucks 25% 1,122 2% 0% 0% 98%

Fleet 25% 909 3% 0% 0% 97%

5%/year

All Cars 25% 818 8% 0% 0% 91%

All Trucks 25% 1,143 60% 0% 0% 39%

Fleet 25% 922 25% 0% 0% 74%

6%/year

All Cars 27% 868 31% 0% 5% 65%

All Trucks 26% 1,180 71% 0% 1% 28%

Fleet 26% 970 44% 0% 4% 53%
2017-2025 Technical Assessment

6-23 

Table 6.5-10 presents car-fleet and truck-fleet level results for Technology Pathway D, 

specifically the CO2e target levels, the MPG-equivalent target levels, and the average pervehicle cost increase for the four scenario stringency levels. Table 6.5-10 presents the

corresponding car-fleet and truck-fleet technology penetration rates and mass reductions for 

model year 2025 under the Technology Pathway D. The results show that as with the three 

other pathways, the car fleet, which starts off at a lower average CO2 level, also has a lower 

CO2 levels under the four stringency scenarios as compared to the truck fleet. The pervehicle cost increase difference between the car-fleet and truck-fleet is on the order of $500 to 

$1,000 depending on the stringency of the scenario, with the exception of the 3% per year 

scenario, where there is little cost difference between the car fleet and truck fleet. 

Car and Truck Fleet Information for Technology Path D for MY 2025

As can be seen in Table 6.5-10, mass reduction is very cost effective across both the 

car and truck fleets, though the level of mass reduction is no higher than the 15% we 

considered for this Pathway. The penetration of HEV technology is similar between the car 

and truck fleets in the 6% scenario, but in the 3%, 4%, and 5% scenarios are weighted more 

heavily towards the car fleet. Advanced gasoline engines were not allowed in this scenario, 

as we were trying to assess a hypothetical industry approach in which no advancements in 

gasoline powertrain systems are pursued beyond MY2016, and all of the industry resources 

are concentrated on HEV, PHEV, and EV technology. 

Relative to the other Technology Pathways, Technology Pathway D features a higher 

penetration of EVs and HEVs. The relatively high penetration of HEVs in the 3% scenario is 

due to the complete lack of advanced gasoline engines (that is, no improvement in gasoline 

engines and transmissions beyond what will be used in MY 2015). More stringent scenarios 

require relatively higher penetrations of EVs and HEVs. The penetration of PHEV 

technology remains relatively low, appearing only in the 6% scenario. 
Chapter 6

6-24 

Table 6.5-10: Technology Path D Assessment Projections for Model Year 2025: 

CO2, MPG, and Per-Vehicle Costs for Car and Truck Fleets

Scenario Vehicle Type

CO2e Level 

(g/mile) MPGe Level

Per-Vehicle 

Cost Increase ($)

3%

All Cars 166 53.4 $1,026 

All Trucks 238 37.4 $1,096 

Fleet 190 46.9 $1,049 

4%

All Cars 143 62.2 $2,215 

All Trucks 235 37.8 $1,203 

Fleet 173 51.4 $1,887 

5%

All Cars 127 69.8 $2,940 

All Trucks 222 40.0 $1,917 

Fleet 158 56.2 $2,608 

6%

All Cars 115 77.4 $3,555 

All Trucks 201 44.2 $3,061 

Fleet 143 62.3 $3,395 

*note, the CO2e value includes 15 grams/mile of CO2-equivalent reduction from air conditioning 

related GHGs (CO2 and HFC reductions), and the MPGe level is equivalent MPG value if all CO2 

reductions come from fuel economy improvements. Real-world CO2 is typically 25 percent higher and 

real-world fuel economy is typically 20 percent lower. Per-vehicle cost represented the estimated cost 

to the consumer, including the direct manufacturing costs for the new technologies, indirect costs for 

the auto manufacturer (e.g., product development, warranty) as well as auto manufacturer profit, and 

indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of indirect costs. 

Table 6.5-11: Technology Path D Assessment Projections for Model Year 2025: 

New Fleet Technology Penetration for Car and Truck Fleets

Scenario Vehicle Type Net Mass 

Reduction 

(%)

Net Mass 

Reduction 

(lbs)

HEV 

(%)

PHEV 

(%)

EV 

(%)

Adv. SI

(%)

3%/year All Cars 15% 491 30% 0% 1% 0%

All Trucks 15% 673 14% 0% 0% 0%

Fleet 15% 550 25% 0% 0% 0%

4%/year All Cars 15% 489 54% 0% 6% 0%

All Trucks 15% 673 13% 0% 1% 0%

Fleet 15% 549 41% 0% 4% 0%

5%/year All Cars 15% 482 59% 0% 13% 0%

All Trucks 15% 669 29% 0% 3% 0%

Fleet 15% 542 49% 0% 10% 0%

6%/year All Cars 14% 467 55% 2% 19% 0%

All Trucks 15% 657 57% 2% 4% 0%

Fleet 14% 528 55% 2% 14% 0%
2017-2025 Technical Assessment

6-25 

MY 2020 Results

We present here the fleet-wide results for our MY2020 assessment. The cost of the 

MY 2020 scenarios for the entire new vehicle fleet ranges from $289 (3%) to $1,057 (6%, 

Path A) per vehicle, as shown in Table 6.5-12. Technology pathway C, which relies upon 

advanced gasoline technology and greater mass reduction as compared to Pathway A and B, 

demonstrates the lowest costs. Pathways A and B show greater penetration of HEVs and 

somewhat higher costs. 

The GHG reduction over the lifetime of the MY 2020 vehicles ranges from 172 

million metric tons (MMT) CO2e avoided in the 3% scenario to between 306 MMT CO2e in 

the 6% scenario. MY 2020 vehicles, over the course of their lifetimes, will reduce between 

0.4 billion barrels of gasoline consumption under the 3% scenario to 0.6 billion barrels under 

the 6% scenario. For reference, the NHTSA & EPA National Program in MY 2016 is 

projected to reduce 0.6 billion barrels of fuel and 325 MMT CO2e over the lifetime of MY 

2016 vehicles. 

Table 6.5-12: Assessment Projections for Model Year 2020 Vehicles by Technology Path 

New Fleet Target

Per-Vehicle Cost increase

($)

Lifetime

CO2e Reduction 

(MMT)

Lifetime

Gasoline Reduction 

(Billion Barrels)

Scenario CO2 MPGe* Path A Path B Path C Path A Path 

B

Path 

C

Path A Path 

B

Path 

C

3%/year 221 40.2 $289 $289 $289 172 172 172 0.4 0.4 0.4

4%/year 212 41.9 $399 $399 $399 215 215 215 0.5 0.5 0.5

5%/year 204 43.6 $577 $583 $565 262 262 262 0.5 0.5 0.5

6%/year 195 45.5 $1,057 $1,035 $865 306 306 306 0.6 0.6 0.6

Note – these costs, CO2 reductions, and fuel savings are relative to the 2016 EPA GHG standards. Per-vehicle 

cost represented the estimated cost to the consumer, including the direct manufacturing costs for the new 

technologies, indirect costs for the auto manufacturer (e.g., product development, warranty) as well as auto 

manufacturer profit, and indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of 

indirect costs.

* MPGe is the MPG equivalent to the CO2 target if all CO2 reductions occur from fuel economy improvement 

technologies. Real-world CO2 is typically 25 percent higher and real-world fuel economy is typically 20 percent 

lower. Thus, the 3% to 6% range evaluated in this assessment would span a range of real world fuel economy 

values of approximately 32 to 36 mpg, which correspond to the regulatory test procedure values of 40.2 and 45.5 

mpg, respectively. For the technical assessment, we have estimated a reduction of 15 g/mile CO2 equivalent 

from air conditioning system improvements, which would not actually translate into MPG improvements

The penetration of HEVs, EVs, and PHEV in MY 2020 varies little depending on the 

technology pathway and scenario, as can be seen in Table 6.5-13. 

Pathway C places greater emphasis on mass reduction and advanced gasoline vehicle 

technology. Therefore, the degree of mass reduction is also the highest among the four 

pathways, ranging from 11% to 18%. 

Pathway B shows a technology approach in between Paths A and C, with advanced 

gasoline technology and mass reductions higher than for Path A but lower than Path C, and 

HEV penetrations lower than Path A but higher than Path C. This trend is not as strong in the 
Chapter 6

6-26 

MY 2020 results because the level of stringency does not require enough advanced 

technology to show much of a difference between Pathways B and C under most stringencies. 
2017-2025 Technical Assessment

6-27 

Table 6.5-13: Assessment Projections for Model Year 2020 Vehicles

New Fleet Technology Penetration Estimates

Scenario

Technology 

Path

New Vehicle Fleet Technology Penetration

Gasoline & diesel 

vehicles HEV PHEV BEV

Net Mass 

ReductionJJJ

3%/year

Path A 97% 3% 0% 0% 11%

Path B 97% 3% 0% 0% 11%

Path C 97% 3% 0% 0% 11%

4%/year

Path A 97% 3% 0% 0% 14%

Path B 97% 3% 0% 0% 14%

Path C 97% 3% 0% 0% 14%

5%/year

Path A 97% 3% 0% 0% 15%

Path B 97% 3% 0% 0% 15%

Path C 97% 3% 0% 0% 15%

6%/year

Path A 85% 15% 0% 0% 15%

Path B 87% 13% 0% 0% 15%

Path C 97% 3% 0% 0% 18%

Table 6.5-14 present estimates of payback period and net lifetime savings for MY 

2020 vehicles. Payback period is the number of years it takes the cost increase of the vehicle 

to be off-set by the vehicle’s fuel savings. As discussed in Chapter 6.4, we used AEO 2010 

reference case for fuel prices, including fuel taxes, and we discounted the fuel savings using a 

3 percent discount rate. The net lifetime savings is the total lifetime fuel savings for the 

vehicle discounted at 3 percent minus the initial vehicle cost increase. As can be seen in 

Table 6.5-14, all MY 2020 scenarios, regardless of technology pathway, have a positive net 

lifetime fuel savings between approximately $2,600 and $4,300, and for MY 2020 all of the 

scenarios and technology pathways pay back in 2.2 years or less.

Table 6.5-14: Estimated Consumer Payback and Lifetime Savings 

For Model Year 2020 Vehicles (3% Discount Rate)

Payback (years) Net Lifetime Savings ($s)

Scenario Path A Path B Path C Path A Path B Path C

3%/year 1.0 1.0 1.0 $2,632 $2,632 $2,632 

4%/year 1.1 1.1 1.1 $3,249 $3,249 $3,249 

5%/year 1.4 1.4 1.3 $3,854 $3,792 $3,823 

6%/year 2.2 2.2 1.8 $4,082 $4,105 $4,281 

Note – these estimates are relative to vehicles which comply with the 2016 EPA GHG 

standards

 

JJJ Please note that we show net mass reduction relative to model year 2008 vehicles. In the case of PHEVs and 

EVs, the batteries increase the weight of the vehicle. This battery weight increase is combined with the mass 

reduction technology to calculate net mass reduction for those vehicles.
Chapter 6

6-28 

6.6 PHEV and EV Battery Cost Sensitivity Assessment 

The agencies judged that there is uncertainty in the cost for EV and PHEV largeformat lithium-ion batteries in the 2025 time frame. As discussed in Chapter 3, the 

development of these batteries for automotive applications is occurring at a very rapid rate 

and the market is far from mature, thus our ability to accurately predict the costs for these 

technologies for the 2025 time frame is difficult. The cost of the battery pack is the single 

largest incremental cost difference between a gasoline vehicle and either a PHEV or an EV. 

Depending upon the vehicle range (and thus the size of the battery) and the time frame (e.g., 

today or the 2025 time frame), the battery pack cost can represent on the order of 60 to 80% 

or more of the incremental cost of a PHEV/EV. Given the uncertainty in the costs of lithiumion batteries in the 2025 time frame, and the significant portion of the PHEV and EV 

incremental costs the battery represents, the agencies believe it is appropriate to include a 

sensitivity analysis on battery pack costs. 

As discussed in Chapter 3, the agencies used a battery costing model developed by 

Argonne National Laboratory (ANL) which provides unique battery pack cost estimates for 

EV and PHEVs based on various variables such as production volume, battery cell chemistry 

material, battery capacity and power, useable fraction of the state-of-charge range, etc. There 

are also many economic projections used in the ANL model, such as cost of capital 

equipment, plant area, labor cost, etc. Based on 500,000 units per year production volume, 

and using an assumption there will be incremental improvements in battery cycle life such 

that the battery performance is maintained for the useful life of the vehicle, EPA derived a 

battery pack cost projection for 2025 EVs of approximately $160/kW-h for EV75, $150/kW-h 

for EV100, $140/kW-h for EV150, and of 2025 PHEVs of $180/kW-h for 40-mile PHEVs 

and $250/kW-h for 20-mile PHEVs assuming the use of LiMn2O4-spinel/graphite cell 

chemistry. We note that this cost is lower than the cost estimates projections obtained from 

our meetings with the OEMs, where the majority of the estimates were in the $300 to 

$400/kW-h range for 2020 and $250 to $300/kW-h range for 2025. 

Because of uncertainty in future battery costs, the agencies conducted a sensitivity 

assessment on the battery costs for 2025 by increasing all of the PHEV and EV battery-pack 

costs by $100/kW-hr. We also examined the potential impact of lower battery costs by 

reducing all of the PHEV and EV battery-pack costs by $50/kW-hr. The $100/kW-hr higher 

cost is comparable to commodity pricing for high-volume LiCoO2 cells for consumer 

applications. The $50/kW-hr lower cost assumes a breakthrough in battery design that would 

approximately triple cell energy density.

We selected the 5% per year and 6% per year targets under technology Pathway B for 

2025 as the scenario on which to assess the potential impact of these changes in Li-ion battery 

costs. The results show that for the higher battery cost estimates, the projected 2025 Pathway 

B costs for the 5% per year targets would increase by $36 per vehicle and for the 6% per year 

targets would increase by $397 per vehicle. For the lower battery cost estimates, the projected 

2025 Pathway B costs for the 5% per year targets would decrease by $18 per vehicle and for 

the 6% per year targets would decrease by $199 per vehicle. This impact on the fleet-wide 

average cost assessment is relatively modest because PHEVs and EVs represent on the order 

of 1% of the new vehicles under the Pathway B 5% per year scenario, and 9% under the 
2017-2025 Technical Assessment

6-29 

Pathway B 6% per year scenario. However, the impact on actual PHEVs and EVs can be 

large. For example, for a midsize EV passenger car with a real-world range of 100 miles (an 

EV100), the sensitivity analysis done by adding $100/kW-hr to the battery pack costs 

increased the cost of the midsize car EV100 on the order of $5,700, and the impact of 

lowering the EV100 battery pack costs by $50/kW-hr reduced the costs of the midsize car 

EV100 by $2,800. 
Chapter 6

6-30 

Chapter 6 References

92 Documented in Appendix A to this report.

93 See Appendix D to this report.

94 Energy Information Administration, Annual Energy Outlook 2010, Reference Case (May 2010 2009), Table 

12. Available at http://www.eia.doe.gov/oiaf/aeo/aeoref_tab.html

95 EPA. 2006, Final Technical Support Document. Fuel Economy Labeling of Motor Vehicle Revisions to 

Improve Calculation of Fuel Economy Estimates. EPA-HQ-OAR-2009-0472-0281

96 Energy Information Administration, Annual Energy Outlook 2010, Reference Case (May 2010 2009), Table 

12. Available at http://www.eia.doe.gov/oiaf/aeo/aeoref_tab.html

97 EPA. Final Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate 

Average Fuel Economy Standards. Joint Technical Support Document. Chapter 4. EPA-420-R-10-901 

http://www.epa.gov/otaq/climate/regulations/420r10901.pdf. Additional details on the projections used here can 

be found in Appendix E of this report.

98 Sorrell, S. and J. Dimitropoulos, 2007. “UKERC Review of Evidence for the Rebound Effect, Technical 

Report 2: Econometric Studies”, UKERC/WP/TPA/2007/010, UK Energy Research Centre, London, October 

and Greening, L.A., D.L. Greene and C. Difiglio, 2000. “Energy Efficiency and Consumption – The Rebound 

Effect – A Survey”, Energy Policy, vol. 28, pp. 389-401.

99 EPA. Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy 

Standards; Final Rule Regulatory Impact Analysis Chapter 5.

100 EPA. Analysis of H.R. 2454 in the 111th Congress. 

http://www.epa.gov/climatechange/economics/economicanalyses.html

101 EPA. Final Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate 

Average Fuel Economy Standards. Joint Technical Support Document. Chapter 4. EPA-420-R-10-901. 

http://www.epa.gov/otaq/climate/regulations/420r10901.pdf. Original data found in Intergovernmental Panel on 

Climate Change. Chapter 2. Changes in Atmospheric Constituents and in Radiative Forcing. September 2007. 

http://www.ipcc.ch/pdf/assessmentreport/ar4/wg1/ar4-wg1-chapter2.pdf. Docket ID: EPA-HQ-OAR-2009-0472-

0117
2017-2025 Technical Assessment

7-1 

7 Other Key Factors

7.1 Potential Impacts on the Economy and Employment 

The primary impacts of the use of advanced vehicle technologies on the economy are 

the net benefits that they produce. Positive net benefits result in improvements in economic 

welfare in the aggregate. Measures of net benefits, though, are not necessarily correlated with 

the effects of technologies on employment or on the auto manufacturing base in the U.S. This 

report does not provide a quantitative assessment of these effects. Instead, this section 

discusses the potential impacts of advanced technologies on the auto industry in general and 

employment in the auto sector. 

7.1.1 Impacts on Auto Manufacturers, Suppliers, and Auto Industry Employment 

The automotive market is becoming increasingly global. The U.S. auto companies 

produce and sell automobiles around the world, and foreign auto companies produce and sell 

in the U.S. As a result, the industry has become increasingly competitive. Staying at the 

cutting edge of automotive technology while maintaining profitability and consumer 

acceptance has become increasingly important for the sustainability of auto companies. 

Trends in the world automotive market suggest that investments in improved fuel 

economy and advanced technology vehicles are a necessary component for maintaining 

competitiveness in coming years. For instance, most companies are expanding hybrid-electric 

vehicle production to stay competitive while meeting more stringent fuel economy and 

emissions regulations. Fuel economy requirements in other developed countries are generally 

higher, and greenhouse gas (GHG) emissions standards tighter, than in the U.S. As 

automakers seek greater commonality across the vehicles they produce for the domestic and 

foreign markets, improving fuel economy and reducing GHGs in U.S. vehicles should have 

spillovers to foreign production, and vice versa, thus yielding the ability to amortize 

investment in research and production over a broader product and geographic spectrum. 

Auto companies are already conducting major research and investment activities in 

advanced technologies and improvements to conventional technologies to improve fuel 

economy and reduce GHG emissions. In addition, as discussed in Chapter 2, in recent 

meetings with auto firms, all expressed plans to increase significantly their offerings and sales 

of advanced technology vehicles in coming years. Successful research and investment 

activities can contribute to long-term gains in many directions. Companies that develop new 

technologies not only get the advantages of using them, but also the opportunity to license 

those technologies to other companies. Those technologies may have spinoffs into other 

sectors. For instance, research into new battery technologies may lead to improvements in 

other battery-intensive uses, such as storage of wind or solar energy when the quantity of 

electricity demanded is lower than the amount produced. 

The effects of the use of advanced technologies on U.S. auto sector employment 

depend on how the standards affect several factors: the number of vehicles produced 

(discussed below), the labor intensity of vehicle production, and any changes in market shares 

between domestically produced and imported vehicles and auto parts. 
Chapter 7

7-2 

Productivity in the auto industry has been increasing over time, as automakers have 

improved process efficiency and enhanced vehicle quality.102

Another variable affecting auto sector employment is where production takes place. 

The location of production will depend on how domestic production costs, especially for 

advanced technologies, compare to foreign production costs, and on the cost of transporting 

vehicles and parts between the U.S. and other countries. Investments in advanced technology 

production facilities, such as battery manufacturing and vehicle electrification projects, 

supported by the Recovery Act (for example) reduce the need for importing these parts from 

overseas.

 Improved productivity has the 

great benefit of providing better vehicles at lower prices to consumers; it also means fewer 

worker-hours needed per dollar of vehicle value. Higher productivity leads to more efficient 

vehicle manufacturing, which could result in less expensive and/or improved quality vehicles. 

Either outcome would likely give consumers greater purchasing power, and thus lead to 

higher vehicle sales. Even though higher productivity implies that worker-hours per vehicle 

may go down, increased vehicle sales may lead overall employment in the auto industry to 

increase, as it did in the 1990s (a time of both high productivity increases and employment 

increases). At this time it is not possible to predict the effect of production involving 

advanced vehicle technologies on labor needs. It is possible that the smaller-volume 

production likely in the early years for advanced technology vehicles may be more laborintensive than mass production, if scale economies of production are not exhausted. 

103

7.1.2 Impacts on Vehicle Sales

 These investments by the Department of Energy have created immediate jobs in 

building this capacity, and they also help ensure that these components can be produced in the 

U.S. Tax breaks and other manufacturing incentives provided by a number of local and state 

governments for advanced vehicle technologies, such as in Michigan, have also contributed 

incentives for domestic production. 

The effect of advanced technologies on vehicle sales depends on the attractiveness to 

consumers of the new technologies and improved fuel economy relative to the increased 

vehicle price. In the light-duty greenhouse gas/fuel economy rule covering 2012-2016, the 

very large fuel savings were estimated to recover the up-front technology costs in under three 

years. If consumers considered at least three years’ worth of fuel savings when purchasing a 

vehicle, then that rule was predicted to increase vehicle sales.104 The use of advanced 

technologies can be expected, as in that rule, to improve fuel economy and increase vehicle 

costs. Chapter 6 of this report shows that more stringent standards will provide fuel savings 

that exceed vehicle cost increases in four years or less. The weights that consumers put on 

these two factors will affect total vehicle sales.105

7.1.3 Summary

 

With increased globalization of auto markets, increased competitiveness in the 

industry, and higher fuel economy/lower GHG standards becoming the norm around the 

world, auto companies have already begun to invest in new technologies that will meet future 

standards. These new technologies will increase the purchase prices of new vehicles, at the 

same time that they reduce their fuel costs; the net effect on auto sales depends on how 

consumers trade off those attributes. The net effect on employment will be affected not only 
2017-2025 Technical Assessment

7-3 

by the effects of the proposed standards on auto sales, but also on the effects on productivity 

and location of production. These investments will help the U.S. auto sector to stay on the 

cutting edge of auto technology. 

For the forthcoming notice of proposed rulemaking for 2017-2025 GHG and CAFE 

standards, EPA and NHTSA will further investigate the impacts of the proposed standards on 

the auto industry, and employment. Further analysis requires information on the effects of the 

proposed standards on vehicle sales, on expected expenditures in the auto sector, and on any 

predictions of changes in location of manufacturing due to the specific standards in the 

forthcoming proposal. 

7.2 Upstream GHG Emissions

In the assessment of potential future ranges of stringency presented in Chapter 6 of 

this report, we based our analysis on the tailpipe emissions from all vehicles – thus EVs were

evaluated at a 0 gram/mile CO2 level and PHEVs were evaluated as 0 gram/mile for the 

electric drive portion of the vehicles operation. For the purposes of the GHG impacts 

presented in Chapter 6, we have included the resultant increase in upstream CO2 from the use 

of PHEVs and EVs in our overall calculation of the net CO2 reductions for each of the 

scenarios evaluated. As discussed in Chapter 6, the upstream CO2 emission factors from 

powerplants is based on a future business as usual case, 

The issue of upstream emissions will be considered in the MY 2017-2025 light-duty 

vehicle joint federal rulemaking. EPA has not considered upstream fuel-related emissions 

issues in the past with respect to the non-GHG emissions standards for motor vehicles. 

As discussed in Chapter 2, many stakeholders have expressed opinions on this topic, 

with most automakers supporting the tailpipe only or zero grams per mile approach and 

environmental groups typically supporting a net upstream GHG emissions accounting. 

EPA will be fully evaluating this issue for the MY 2017-2025 light-duty vehicle GHG 

emissions proposal based on the status of commercialization of EVs, PHEVs, and FCVs, the 

potential of these technologies to provide long-term GHG emissions savings, the status of and 

outlook for upstream GHG control programs, and other relevant factors. 
Chapter 7

7-4 

Chapter 7 References

102 Baily, Martin N., et al., “Increasing Global Competition and Labor Productivity: Lessons from the US 

Automotive Industry,” McKinsey Global Institute, November 2005, 

http://www.mckinsey.com/mgi/publications/us_autoindustry/index.asp , accessed 8/17/10.

103 “Recovery Act Awards for Electric Drive Vehicle Battery and Component Manufacturing Initiative” and 

“Recovery Act Awards for Transportation Electrification,” 

http://www1.eere.energy.gov/recovery/pdfs/battery_awardee_list.pdf

104 This result led to questions why private market interactions between auto producers and consumers had not 

led to incorporation of these technologies into vehicles in the absence of the rule. This issue was discussed in the 

Preamble for that rule, Federal Register 75(88) (Friday, May 7, 2010), in Section III.H.1, pp. 25510-25513, and 

IV.G.6, pp. 25651-25657.

105 Though a number of studies have included examination of the role of fuel economy in consumers’ purchases, 

the results appear to be highly varied. See Greene, David L., “How Consumers Value Fuel Economy: A 

Literature Review,” Report EPA-420-R-10-008, Office of Transportation and Air Quality, U.S. Environmental 

Protection Agency, March 2010. EPA-HQ-OAR-2009-0472-11465. 
2017-2025 Technical Assessment 

A-1 

A1 Appendix A: The Baseline and Reference Vehicle Fleet 

The passenger cars and light trucks sold currently in the United States, and those 

which are anticipated to be sold in the MYs 2017-2025 time frame, are highly varied and 

satisfy a wide range of consumer needs. From two-seater miniature cars to 11-seater 

passenger vans to large extended cab pickup trucks, American consumers have a great 

number of vehicle options to accommodate their utility needs and preferences. Recent 

volatility in oil prices and the state of the economy have demonstrated that consumer demand 

and choice of vehicles within this wide range can be sensitive to these factors. Although it is 

impossible for anyone or any organization to precisely predict the future, a characterization 

and quantification of the future fleet are required to assess the impacts of rules which would 

affect that future fleet. In order to do this, the various leading publicly-available sources are 

examined, and a series of models are relied upon that help us to project the composition of a 

reference fleet. This appendix gives a high level over view of the process to accomplish this 

and a simple analysis of the fleet’s characteristics, drawing extensively from the joint final 

TSD for the MYs 2012-2016 final rule. 

A1.1 Why do the agencies establish a baseline and reference vehicle fleet? 

In order to calculate the impacts of potential future EPA and NHTSA standards, it is 

necessary to estimate the composition of the future vehicle fleet absent those CAFE/GHG 

standards in order to conduct comparisons. EPA in consultation with NHTSA has developed 

a comparison fleet in two parts. The first step was to develop a baseline fleet based on model 

year 2008 data. EPA and NHTSA create a baseline fleet in order to track the volumes and 

types of fuel economy-improving and CO2-reducing technologies which are already present in 

today’s fleet. Creating a baseline fleet helps to keep, to some extent, the agencies’ models 

from adding technologies to vehicles that already have these technologies, which would result 

in “double counting” of technologies’ costs and benefits. The second step was to project the 

baseline fleet sales into MYs 2017-2025. This is called the reference fleet, and it represents 

the fleet that would exist in MYs 2017-2025 absent any change from current regulations. The 

third step was to add technologies to that MY 2008 fleet such that each manufacturer’s 

average car and truck CO2 levels are in compliance with their MY 2016 CAFE standards. 

This final “reference fleet” is the light duty fleet estimated to exist in MYs 2017-2025 without 

new CAFE/GHG standards. All of the agencies’ estimates of emission reductions/fuel 

economy improvements, costs, and societal impacts for purposes of this Technical 

Assessment Report are developed in relation to this reference fleet for MY 2016. This 

Appendix describes the first two steps of the development of the baseline and reference fleets. 

The third step of technology addition is developed separately by each agency as the outputs of 

the OMEGA and Volpe models; for purposes of this Technical Assessment Report, as 

discussed above, only the OMEGA model was employed for the main analysis, although both 

models will be run for the forthcoming federal rulemaking. The overall process for 

developing baseline and reference fleets for the agencies’ modeling is described in the MYs 

2012-2016 final rule in section II of the preamble and in each agency’s respective RIA. 
Appendix A 

A-2 

A1.2 The 2008 baseline vehicle fleet 

A1.2.1 Why did the agencies choose 2008 as the baseline model year? 

A baseline vehicle fleet was developed by EPA in consultation with NHTSA for the 

2012-2016 final rule. The baseline for the 2012-2016 final rule is comprised of model year 

2008 individual vehicle attribute data volumes along with projected volumes out to 2016. 

Model year 2008 vehicle data was again chosen to be the basis of the baseline fleet, but for 

different reasons than the final rule. Model year 2008 is now the most recent model year for 

which the industry had normal sales. Model year 2009 data was available, but the agencies 

believe that the model year was disrupted by the economic downturn and the bankruptcies of 

both General Motors and Chrysler. There was a significant reduction in the number of 

vehicles sold by both companies and the industry as a whole. These abnormalities made the 

agencies conclude that 2009 data was unsuitable for projecting the future fleet. Therefore, the 

agencies chose to use model year 2008 as the baseline since it was the latest representative 

transparent data set available. 

A1.2.1.1 On what data is the baseline vehicle fleet based? 

As part of the CAFE program, EPA measures vehicle CO2 emissions and converts 

them to mpg and generates and maintains the federal fuel economy database. Most of the 

information about the 2008 vehicle fleet was gathered from EPA’s emission certification and 

fuel economy database, most of which is available to the public. The data obtained from this 

source included vehicle production volume, fuel economy, carbon dioxide emissions, fuel 

type, number of engine cylinders, displacement, valves per cylinder, engine cycle, 

transmission type, drive, hybrid type, and aspiration. However, EPA’s certification database 

does not include a detailed description of the types of fuel economy-improving/CO2-reducing 

technologies considered in this final rule, because this level of information is not necessary 

for emission certification or fuel economy testing. Thus, EPA augmented this description 

with publicly-available data which includes more complete technology descriptions from 

Ward’s Automotive Group.1,A In a few instances when required vehicle information was not 

available from these two sources (such as vehicle footprint), this information was obtained 

from publicly-accessible internet sites such as Motortrend.com, Edmunds.com and other 

sources to a lesser extent (such as articles about specific vehicles revealed from internet 

search engine research.2,B 

For details on how the 2008 baseline fleet was constructed for the 2012-2016 final 

rule, please see the Chapter 1 of the Joint Technical Support Document for that rule. 

 

A

 Note that WardsAuto.com is a fee-based service, but all information is public to subscribers. 

B

 Motortrend.com and Edmunds.com are free, no-fee internet sites. 
2017-2025 Technical Assessment 

A-3 

A1.3 The MY 2017-2025 Reference Fleet 

The reference fleet aims to reflect the current market conditions and expectations 

about conditions of the vehicle fleet during the model years to which the agencies’ rules 

apply. Fundamentally, constructing this fleet involved projecting the MY 2008 baseline fleet 

into the 2017-2025 model years. It also included the assumption that none of the models had 

changes during this period, in terms of both the technology present in the vehicles themselves, 

and the vehicles present in the fleet. Projecting what the fleet will look like in the future is a 

process that is inherently uncertain. NHTSA and EPA therefore relied on many sources of 

reputable information to make these projections. 

A1.3.1 On what data is the reference vehicle fleet based? 

EPA and NHTSA have based the projection of total car and light truck sales on recent 

projections made by the Energy Information Administration (EIA). EIA publishes a 

projection of national energy use annually called the Annual Energy Outlook (AEO).3 EIA 

published its Annual Energy Outlook for 2010 in May 2010. Similar to the analyses 

supporting the MYs 2012-2016 rulemaking, the agencies have used the Energy Information 

Administration’s (EIA’s) National Energy Modeling System (NEMS) to estimate the future 

relative market shares of passenger cars and light trucks. However, the version of NEMS 

supporting EIA’s Annual Energy Outlook 2010 (AEO2010) contains a “dummy variable” that 

forces the passenger car market share to increase after 2007, to facilitate projected compliance 

with EISA’s requirement that the overall fleet achieve 35 mpg by 2020 (the car and truck 

volumes based on this analysis are shown in Table A1.3-1. Because we use our market 

projection as a baseline relative to which we measure the effects of new standards, and we 

attempt to estimate the industry’s ability to comply with new standards without changing 

product mix, the AEO2010 projected shift in passenger car market share as a result of 

legislatively required fuel economy improvements creates a circular logic. Therefore, for the 

current analysis, a new projection of passenger car and light truck sales shares was developed 

by running scenarios from the AEO2010 reference case that first deactivate the abovementioned dummy variable and holds post-2017 CAFE standards constant at MY 2016 levels. 

Incorporating these changes reduced the projected passenger car share of the light vehicle 

market by an average of about 5% during 2017-2025. This case is referred to as the Unforced 

Reference Case, and the values are shown below in Table A1.3-2. 

Table A1.3-1 AEO Original Reference Case Values 

Model Year Cars Trucks Total Vehicles

2017 9,329,656 6,855,287 16,184,943

2018 9,375,428 6,595,148 15,970,576

2019 9,640,245 6,482,139 16,122,384

2020 10,105,479 6,436,088 16,541,566

2021 10,156,471 6,303,343 16,459,813

2022 10,178,345 6,166,611 16,344,956

2023 10,293,661 6,118,791 16,412,452

2024 10,516,662 6,166,036 16,682,698
Appendix A 

A-4 

2025 10,761,857 6,204,297 16,966,155

Table A1.3-2 AEO Unforced Reference Case Values 

Model Year Cars Trucks Total Vehicles

2017 8,783,816 7,401,127 16,184,943

2018 8,728,990 7,241,586 15,970,576

2019 8,899,836 7,222,548 16,122,384

2020 9,230,279 7,311,287 16,541,566

2021 9,265,881 7,193,932 16,459,813

2022 9,282,884 7,062,072 16,344,956

2023 9,382,100 7,030,352 16,412,452

2024 9,588,366 7,094,332 16,682,698

2025 9,817,211 7,148,944 16,966,155

Using the unforced reference case, EIA projects that total light-duty vehicle sales 

gradually recover from their currently depressed levels by roughly 2013. In 2017, car and 

light truck sales are projected to be 8.8 and 7.4 million units, respectively. While the total 

level of sales of 16.1 million units is similar to pre-2008 levels, the fraction of car sales is 

projected to be higher than that existing in the 2000-2007 timeframe. Note that EIA’s 

definition of cars and trucks follows that used by NHTSA prior to the MY 2011 CAFE final 

rule. The MY 2011 CAFE final rule reclassified a number of 2-wheel drive sport utility 

vehicles from the truck fleet to the car fleet. EIA’s sales projections of cars and trucks for the 

2017-2025 model years under both the old NHTSA truck definition are shown above in Table 

A1.3-1 and Table A1.3-2.

In addition to a shift towards more car sales, sales of segments within both the car and 

truck markets have also been changing and are expected to continue to change in the future. 

Manufacturers are continuing to introduce more crossover models which offer much of the 

utility of SUVs but use more car-like designs and unibody structures. In order to reflect these 

changes in fleet makeup, EPA and NHTSA used a custom long range forecast purchased from

CSM Worldwide (CSM). CSM Worldwide (CSM) 4

is a well-known industry analyst, that 

provided the forecast used for the 2012-2016 final rule. NHTSA and EPA decided to use the 

forecast from CSM for several reasons. One, CSM agreed to allow us to publish their high 

level data, on which the forecast is based, in the public domain. Two, it covered all the 

timeframe of greatest relevance to this analysis (2017-2025 model years). Three, it provided 

projections of vehicle sales both by manufacturer and by market segment. Four, it utilized 

market segments similar to those used in the EPA emission certification program and fuel 

economy guide. As discussed further below, the CSM forecast is combined with other data 

obtained by NHTSA and EPA. 
2017-2025 Technical Assessment 

A-5 

A1.3.2 How do the agencies develop the reference vehicle fleet? 

The process of producing the 2017-2025 reference fleet involved combining the 

baseline fleet with the projection data described above. This was a complex multistep 

procedure, which is described in detail in the Joint Technical Support Document from the 

2012-2016 final rule with an abbreviated discussion in this section. 

A1.3.2.1 How was the 2008 baseline data merged with the CSM data? 

Merging the 2008 baseline data with the 2017-2025 CSM data required a thorough 

mapping of certification vehicles to CSM vehicles by individual make and model. One 

challenge the agencies faced when determining a reference case fleet was that the sales data 

projected by CSM had different market segmentation than the data contained in EPA’s 

internal database. In order to create a common segmentation between the two databases, sideby-side comparison of the specific vehicle models in both datasets was performed, and an 

additional “CSM segment” modifier in the spreadsheet was created, thus mapping the two 

datasets. The reference fleet sales based on the “CSM segmentation” was then projected. 

In the combined EPA certification and CSM database, all of the 2008 vehicle models 

were assumed to continue out to 2025, though their volumes changed in proportion to CSM 

projections. Also, any new models expected to be introduced within the 2011-2025 

timeframe are not included in the data. These volumes are reassigned to the existing models. 

All MY 2017-2025 vehicles are mapped to the existing vehicles by a process of mapping to 

manufacturer market share and overall segment distribution. 

A1.3.2.2 How were the CSM forecasts normalized to the AEO forecasts? 

The projected CSM forecasts for relative sales of cars and trucks by manufacturer and 

by market segment were normalized (set equal) to the total sales estimates of the AEO 2010 

reference case. NHTSA and EPA used projected car and truck volumes for this period from 

AEO 2010. However, the AEO projects sales only at the car and truck level, not at the 

manufacturer and model-specific level, which are needed for the analysis. The CSM data 

provided year-by-year percentages of cars and trucks sold by each manufacturer as well as the 

percentages of each vehicle segment. Using these percentages normalized to the AEOprojected volumes then provided the manufacturer-specific market share and model-specific 

sales for model years 2017-2025 (it is worth clarifying that the agencies are not using the 

model-specific sales volumes from CSM, only the volumes by manufacturer and segment). 

This process is described in greater detail in Chapter 1 of the Joint Technical Support 

Document for the 2012-2016 final rule. 

A1.3.3 What are the sales volumes and characteristics of the reference fleet? 

Table A1.3-3 and Table A1.3-6 below contain the sales volumes that result from the 

process above for MY 2008 and 2017-2020. Table A1.3-4 and Table A1.3-5 below contain 

the sales volumes that result from the process above for MY 2021-2025. 
Appendix A 

A-6 

Table A1.3-3 Vehicle Segment Volumesa

Reference Class 

Segment

Actual and Projected Sales Volume

2008 2017 2018 2019 2020

LargeAuto 557,693 381,148 361,437 361,164 406,604 

MidSizeAuto 3,097,859 3,472,360 3,456,168 3,501,241 3,603,571

CompactAuto 1,976,424 2,452,469 2,432,700 2,500,944 2,598,610

SubCmpctAuto 1,364,434 2,530,789 2,529,308 2,588,403 2,674,638

All Cars 6,971,256 8,783,816 8,728,990 8,899,836 9,230,279

LargePickup 1,581,880 1,521,906 1,452,047 1,404,242 1,413,451

SmallPickup 177,497 156,992 158,850 163,210 148,911 

LargeSUV 2,783,949 3,210,047 3,168,335 3,226,391 3,266,435

MidSizeSUV 1,263,360 1,365,334 1,316,762 1,286,724 1,311,146

SmallSUV 285,355 148,962 150,791 157,027 165,874 

MiniVan 642,055 758,207 743,808 727,994 728,384 

CargoVan 110,858 186,730 200,370 205,042 223,940 

All Trucks 6,870,108 7,401,127 7,241,586 7,222,548 7,311,287

a

 Volumes in this table are based on the pre-2011 NHTSA definition of Cars and Trucks. 

Table A1.3-4 Vehicle Segment Volumesa

Reference Class 

Segment

Actual and Projected Sales Volume

2021 2022 2023 2024 2025

LargeAuto 384,191 353,301 352,705 345,006 356,435 

MidSizeAuto 3,604,960 3,635,168 3,732,222 3,781,545 3,835,289

CompactAuto 2,629,933 2,645,629 2,651,598 2,756,463 2,847,781

SubCmpctAuto 2,704,376 2,708,913 2,708,098 2,770,523 2,843,941

All Cars 9,265,881 9,282,884 9,382,100 9,588,366 11,461,493

LargePickup 1,352,502 1,302,512 1,251,253 1,226,935 1,215,296

SmallPickup 148,400 142,033 145,507 149,188 149,308 

LargeSUV 3,274,899 3,245,920 3,281,687 3,353,515 3,395,154

MidSizeSUV 1,266,485 1,238,672 1,219,552 1,247,145 1,258,695

SmallSUV 165,290 163,744 163,691 167,086 169,425 

MiniVan 720,675 713,307 712,312 695,336 700,287 

CargoVan 208,102 195,757 193,828 189,957 194,544 

All Trucks 7,193,932 7,062,072 7,030,352 7,094,332 5,504,662

a

 Volumes in this table are based on the pre-2011 NHTSA definition of Cars and Trucks. 

Table A1.3-5 2011+ NHTSA Car and Truck Definition Based Volumes 

Vehicle Type Actual and Projected Sales Volume

2008 2017 2018 2019 2020

Trucks 5,620,847 5,846,663 5,703,588 5,667,948 5,714,586
2017-2025 Technical Assessment 

A-7 

Cars 8,220,517 10,338,280 10,266,989 10,454,435 10,826,981

Cars and Trucks 13,841,364 16,184,943 15,970,576 16,122,384 16,541,566

Table A1.3-6 2011+ NHTSA Car and Truck Definition Based Volumes 

Vehicle Type Actual and Projected Sales Volume

2021 2022 2023 2024 2025

Trucks 5,618,286 5,505,720 5,468,789 5,475,941 5,504,662

Cars 10,841,528 10,839,236 10,943,663 11,206,758 11,461,493

Cars and Trucks 16,459,813 16,344,956 16,412,452 16,682,698 16,966,155

Table A1.3-7 also shows how the change in fleet make-up may affect the footprint 

distributions over time. The resulting data indicate that footprint will not change significantly 

between 2008 and 2025. There will be an increase in the number of cars sold (as compared to 

trucks), which will cause the average footprints for cars and trucks combined to be slightly 

smaller (about 2%). This is the result of AEO projecting an increased number of cars, and 

CSM predicting that most of that increase will be in the subcompact segment. 

Table A1.3-7 Production Foot Print Mean 

Model Year Foot Print Mean 

Cars

Foot Print Mean for 

Trucks

Foot Print Mean for Cars & Trucks

Combined

2008 45.45 54.12 48.97

2017 44.94 53.93 48.19

2018 44.93 53.85 48.12

2019 44.92 53.76 48.03

2020 44.95 53.89 48.04

2021 44.93 53.81 47.96

2022 44.91 53.78 47.90

2023 44.93 53.66 47.84

2024 44.92 53.51 47.74

2025 44.92 53.47 47.69

Table A1.3-8 and Table A1.3-9 below show the changes in engine cylinders over the 

model years. The current assumptions show that engines will be downsized over the model 

years to which these rules apply. The biggest projected shift occurs between MY 2008 and 

2013. This shift is a projected consequence of the expected changes in class and segment mix 

as predicted by AEO and CSM, and does not represent engine downsizing attributable to the 

rules. 
Appendix A 

A-8 

Table A1.3-8 Truck Percentages of 4, 6, 8 Cylinder Engines by Model Year 

Model Year

Percentage of 4 

Cylinders

Percentage of 6 

Cylinders

Percentage of 8 

Cylinders

2008 10.33% 56.40% 33.27%

2017 10.94% 63.67% 25.39%

2018 10.65% 64.51% 24.84%

2019 10.42% 65.47% 24.12%

2020 10.29% 65.57% 24.14%

2021 10.28% 66.33% 23.39%

2022 10.26% 66.74% 23.00%

2023 10.26% 67.73% 22.01%

2024 10.47% 68.09% 21.44%

2025 10.52% 68.22% 21.26%

Table A1.3-9 Car Percentages of 4, 6, 8 Cylinder Engines by Model Year 

Model Year

Percentage of 4 

Cylinders

Percentage of 6 

Cylinders

Percentage of 8 

Cylinders

2008 56.99% 37.80% 5.20%

2017 60.63% 34.55% 4.82%

2018 60.70% 34.47% 4.83%

2019 60.72% 34.43% 4.85%

2020 60.39% 34.74% 4.87%

2021 60.75% 34.47% 4.78%

2022 61.19% 34.16% 4.65%

2023 61.05% 34.32% 4.63%

2024 61.12% 34.19% 4.68%

2025 61.20% 34.11% 4.69%

A1.3.4 How does manufacturer product plan data factor into the baseline? 

In the spring and fall of 2009, many manufacturers submitted product plans in 

response to NHTSA’s request. NHTSA and EPA both have access to these plans, and both 

agencies have reviewed them in detail. A small amount of product plan data was used in the 

development of the baseline. The specific pieces of data are: 

Wheelbase 

Track Width Front 

Track Width Rear 

Curb Weight 

GVWR (Gross Vehicle Weight Rating) 
2017-2025 Technical Assessment 

A-9 

The track widths, wheelbase, curb weight, and GVWR for vehicles could have been 

looked up on the internet (159 were), but were taken from the product plans when available 

for convenience. To ensure accuracy, a sample from each product plan was used as a check 

against the numbers available from Motortrend.com. These numbers will be published in the 

baseline file since they can be easily looked up on the internet. 
Appendix A 

A-10 

Appendix A References 

All references can be found in Docket EPA-HQ-OAR-2009-0472.

1

 WardsAuto.com: Used as a source for engine specifications. 

2

 Motortrend.com and Edmunds.com: Used as a source for foot print and vehicle weight data. 

3

 Energy Information Administration’s 2009 Annual Energy Outlook. 

4

 CSM World Wide, CSM World Wide is a paid service provider. 
2017-2025 Technical Assessment 

B-1 

Appendix B: Package Cost and Effectiveness 

B1 Explanation of Technology Packages 

As discussed briefly at the end of Chapter 3, EPA believes that manufacturers are 

likely to bundle technologies into ―packages‖ to capture synergistic aspects and reflect 

progressively larger CO2 reductions with additions or changes to any given package. In 

addition, manufacturers typically apply new technologies in packages during model 

redesigns—which occur once roughly every five years—rather than adding new technologies 

one at a time on an annual or biennial basis. This way, manufacturers can more efficiently 

make use of their redesign resources and more effectively plan for changes necessary to meet 

future standards. 

Therefore, the approach taken by EPA for purposes of this Technical Assessment 

Report is to group technologies into packages of increasing cost and effectiveness. While 

developing its analysis for the 2012-2016 rulemaking, EPA employed 19 different vehicle 

types for modeling the entire fleet. For the current assessment, we have used the same 19 

vehicle types, with the exception that vehicle type 15 was replaced with a different baseline 

engine to provide us with a more appropriate set of technologies and packages for large cars 

with baseline V8 overhead valve engines. Each of these 19 vehicle types is mapped into one 

of six classes of vehicles: Subcompact, Small car, Large car, Minivan, Small truck, and Large 

truck. Note that, for the current assessment, EPA has created a new vehicle class called 

―Subcompact‖ which allows for greater differentiation of costs for this growing class of 

vehicles (such as the Honda Fit, the Toyota Yaris, and the new Ford Fiesta). Note also that 

these 19 vehicle types span the range of vehicle footprints—smaller footprints for smaller 

vehicles and larger footprints for larger vehicles—which served as the basis for the 2012-2016 

GHG standards. The resultant 19 vehicle types, their baseline engines and their descriptions 

are shown in Table B1-1. 

Table B1-1: List of 19 Vehicle Types used to Model the Light-duty Fleet 

Vehicle 

Type #

Base Engine Base 

Trans Vehicle Class Description

1 1.5L 4V DOHC I4 4sp AT Subcompact Subcompact car I4

2 2.4L 4V DOHC I4 4sp AT Small car Compact car I4

3 2.4L 4V DOHC I4 4sp AT Small car Midsize car/Small MPV I4

4 3.0L 4V DOHC V6 4sp AT Minivan Compact car/Small MPV V6

5 3.3L 4V DOHC V6 4sp AT Large car Midsize/Large car V6

6 4.5L 4V DOHC V8 4sp AT Large car Midsize car/Large car V8

7 2.6L 4V DOHC I4 (I5) 4sp AT Minivan Midsize MPV/Small truck I4

8 3.7L 2V SOHC V6 4sp AT Small truck Midsize MPV/Small truck V6

9 4.0L 2V SOHC V6 4sp AT Minivan Large MPV V6

10 4.7L 2V SOHC V8 4sp AT Minivan Large MPV V8

11 4.2L 2V SOHC V6 4sp AT Large truck Large truck/van V6

12 3.8L 2V OHV V6 4sp AT Large truck Large truck/MPV V6

13 5.7L 2V OHV V8 4sp AT Large truck Large truck/van V8

14 5.4L 3V SOHC V8 4sp AT Large truck Large truck/van V8

15 5.7L 2V OHV V8 4sp AT Large car Large car V8

16 3.5L 4V DOHC V6 4sp AT Minivan Large MPV V6

17 4.6L 4V DOHC V8 4sp AT Minivan Large MPV V8
Appendix B 

B-2 

18 4.0L 4V DOHC V6 4sp AT Large truck Large truck/van V6

19 5.6L 4V DOHC V8 4sp AT Large truck Large truck/van V8

To prepare inputs for the OMEGA model, EPA builds a ―master-set‖ of technology 

packages. The master-set of packages for each vehicle type are meant to reflect the most 

likely technology packages manufacturers would consider when determining their plans for 

complying with future standards (as well as technology pathways described in Chapter 3 and 

6). In other words, they are meant to reflect the most cost effective groups of technologies—

those that provide the best trade-off of costs versus fuel consumption improvements. This is 

done by grouping reasonable technologies in all possible permutations and ranking those 

groupings based on the Technology Application Ranking Factor (TARF).A Grouping 

―reasonable technologies‖ simply means grouping those technologies that are complementary 

(e.g., turbocharging plus downsizing) and not grouping technologies that are not 

complementary (e.g., dual cam phasing and coupled cam phasing). 

To generate the master-set of packages for each of the vehicle types, EPA has built 

packages in a step-wise fashion looking first at conventional gasoline technologies, then 

advanced gasoline technologies and then hybrid and other electrified vehicle technologies. 

This was done by presuming that auto makers would first concentrate efforts on conventional 

gasoline engine and transmission technologies paired with varying levels of mass reduction to 

improve fuel consumption. This is essentially the impact that the 2012-2016 rule will have as 

that rule did not rely heavily on advanced gasoline technologies or 

hybridization/electrification of the fleet. The initial levels of mass reduction considered were 

up to 15%.

B Different pathways matched more intensive mass reductions with more 

advanced technologies. 

Once the conventional gasoline engine and transmission technologies have been fully 

considered, we expect that auto makers would apply more complex (and costly) technologies 

such as advanced gasoline engines (turbocharged and cooled EGR technology for example) 

and further mass reduction (beyond 15%) in both the conventional and advanced gasoline 

packages. 

From there, auto makers would most likely move to hybridization using one of two 

types of hybridization –P2 or 2-mode—depending on the vehicle type.C

 These hybrids could 

 

A

 The Technology Application Ranking Factor (TARF) is the factor used by the OMEGA model to rank 

packages and determine which are the most cost effective to apply. The TARF is calculated as the net 

incremental cost (or savings) of a package per kilogram of CO2 reduced by the package relative to the previous 

package. The net incremental cost is calculated as the incremental cost of the technology package less the 

incremental discounted fuel savings of the package over 5 years. The incremental CO2 reduction is calculated as 

the incremental CO2/mile emission level of the package relative to the prior package multiplied by the lifetime 

miles travelled. More detail on the TARF can be found in the OMEGA model supporting documentation (see 

EPA-420-B-09-035). 

B

 Importantly, the mass reduction associated for each of the 19 vehicle types was based on the vehicle-type sales 

weighted average curb weight. 

C

 For the current assessment, we have considered P2 hybrids and 2-mode hybrids and have not considered 

power-split or other hybrid technologies. The 2-mode hybrid has been considered because it provides for 

hybridization of a vehicle while also maintaining acceptable towing capability. The P2 hybrid has been chosen 
2017-2025 Technical Assessment 

B-3 

employ either conventional or advanced gasoline engines and would be paired with varying 

levels of mass reduction ranging from 15% up to 30%. 

Lastly, for some vehicle types, we anticipate that auto makers would move to more 

advanced electrification in the form of both range extended electric vehicles (REEV)Dand full 

electric vehicles (EV). These also would be paired with varying levels of mass reduction 

from 15% up to 30%. In general the packages are generated in order of increasing complexity 

or cost. 

Focusing first on the conventional gasoline packages, the first step in creating these 

packages was to consider the 8 primary categories of conventional gasoline engine 

technologies. These are: 

- Our ―anytime technologies‖ (ATT) which consist of low friction lubes, engine 

friction reduction, aggressive shift logic (automatic transmission only), early 

torque converter lock-up (automatic transmission only), and low rolling resistance 

tires. 

- Variable valve timing (VVT) consisting of coupled cam phasing (CCP, for OHV 

and SOHC engines) and dual cam phasing (DCP, for DOHC engines) 

- Variable valve lift (VVL) consisting of discrete variable valve lift (DVVL, for 

DOHC engines) 

- Cylinder deactivation (Deac, considered for OHV and SOHC V8 engines) 

- Gasoline direct injection (GDI) 

- Turbocharging and downsizing (TDS, which always includes a conversion to GDI) 

- Stop-start 

- Mass reduction consisting, in this step, of 3%, 5%, 10% and 15%. 

In this first step, we also considered the 3 primary transmission technologies. These 

are: 

- 6 speed automatic transmission (6sp AT) 

- 6 speed dual clutch transmission with wet clutch (6sp wet-DCT) 

- 6 speed dual clutch transmission with dry clutch (6sp dry-DCT) 

In considering the transmissions, we had to first determine how each transmission 

could reasonably be applied. DCTs, especially dry-DCTs, cannot be applied to every vehicle 

type due to low end torque demands at launch. In addition, wet-DCTs are more efficient than 

6sp ATs, and dry-DCTs are more efficient still. Further, each transmission has lower costs, 

respectively. Therefore, moving from 6sp AT to wet-DCT to dry-DCT as quickly as possible 

is preferable. Throughout this assessment, each of these transmissions were allowed on each 

 

because we believe that, in the timeframe of the current assessment, the P2 hybrid will provide the most cost 

effective approach to improving fuel consumption in vehicles that have no and/or comparatively low towing 

demands. 

D

 We are using the term REEV synonymously with PHEV (plug-in hybrid electric vehicle) for the purposes of 

this analysis. 
Appendix B 

B-4 

vehicle type giving consideration to the expected towing demands and curb weights as shown 

in Table B1-2 For example, vehicle type 5 is equipped with a 4 speed automatic transmission 

in the baseline. In a package consisting of a 3% to 20% mass reduction, we believe this 

vehicle type could convert to a wet-DCT because the lighter weight results in reduced low end 

torque demands thus making the wet-DCT feasible. Upon reaching 25% mass reduction, the 

vehicle type could employ a dry-DCT because the even lighter weight results in further 

reduction in low end torque demands. We note that we have estimated that all vehicle types 

will employ DCTs rather than 6 speed automatic transmissions, because we believe that the 

wet-DCT is capable of meeting the towing demands of the light-duty fleet while providing 

better efficiency and lower costs than the 6 speed automatic transmission, and it is thus 

reasonable to assume that all manufacturers will choose to employ wet-DCTs rather than 6 

speed automatics.

Table B1-2: Application of Transmission Technologies in Building Packages 

Vehicle 

Type #

Vehicle 

Class

Base 

Engine

Mass Reduction

0% 3% 5% 10% 15% 20% 25% 30%

1 Subcompact I4 4spAT 6sp dry-DCT

2 Small car I4 4spAT 6sp dry-DCT

3 Small car I4 4spAT 6sp dry-DCT

4 Minivan V6 4spAT 6sp wet-DCT 6sp dry-DCT

5 Large car V6 4spAT 6sp wet-DCT 6sp dryDCT

6 Large car V8 4spAT 6sp wet-DCT

7 Minivan I4 4spAT 6sp dry-DCT

8 Small truck V6 4spAT 6sp wet-DCT

9 Minivan V6 4spAT 6sp wet-DCT

10 Minivan V8 4spAT 6sp wet-DCT

11 Large truck V6 4spAT 6sp wet-DCT

12 Large truck V6 4spAT 6sp wet-DCT

13 Large truck V8 4spAT 6sp wet-DCT

14 Large truck V8 4spAT 6sp wet-DCT

15 Large car V8 4spAT 6sp wet-DCT

16 Minivan V6 4spAT 6sp wet-DCT

17 Minivan V8 4spAT 6sp wet-DCT

18 Large truck V6 4spAT 6sp wet-DCT

19 Large truck V8 4spAT 6sp wet-DCT

We start by first building a ―preliminary-set‖ of conventional gasoline packages for 

each vehicle type consisting of combinations of each of these 8 primary engine technologies. 

The initial packages represent what we expect a manufacturer will most likely implement on 

all vehicles, including low rolling resistance tires, changes to accommodate low friction 

lubricants, engine friction reduction, aggressive shift logic, early torque converter lock-up and

improved electrical accessories. Subsequent packages include more sophisticated gasoline 

engine and transmission technologies such as turbo/downsizing, GDI, increasing mass 

reduction and dual-clutch transmissions. This preliminary-set of conventional gasoline 
2017-2025 Technical Assessment 

B-5 

packages was ranked by its TARF for each vehicle type. The TARF ranking process 

eliminated some packages in favor of more cost effective packages. The packages that 

remained after the TARF ranking process were then included in the master-set of packages for 

each vehicle type. 

Once the preliminary-set of conventional gasoline packages had been pared down and 

moved into the master-set of packages, the most effective (i.e., not the most cost effective, but 

simply the most effective) of the conventional gasoline packages was paired with increasing 

levels of mass reduction up to 30%. Also, the advanced gasoline packages come in—note that 

all advanced gasoline packages are turbo/downsized GDI engines equipped with cooled EGR, 

dual cam phasing and discrete variable valve lift. We have built one advanced gasoline 

package without stop-start technology and one with. Each of these is then paired with 

increasing levels of mass reduction up to 30%. Even though these advanced technologies are 

paired with increased mass reduction, the model is able to isolate the effect of these 

individually in order to examine the separate technology pathways described in Chapter 3 and 

6 of the TAR. The master-set of packages now consists of the most cost effective 

conventional gasoline packages with mass reductions ranging from 0% to 15%, the most 

effective conventional gasoline package with increasing levels of mass reduction up to 30%, 

and advanced gasoline packages (both with stop-start and without) with mass reduction levels 

ranging from 15% to 30%. 

The next packages after the conventional and advanced gasoline packages are the 

HEVs. As noted, we have considered P2 and 2-mode HEVs for this assessment as discussed 

in section B4E

. The agencies assumed that, for some of the vehicles types ranging in size up 

to and including ―Large Car‖, ―Minivan‖ and ―Small Truck‖, towing capacity could be 

reduced to approximately 1,500 poundsF

on HEV models and that these vehicles would use a 

P2 HEV configuration. As described in Chapter 3, in some cases this reflects a loss in towing 

utility as compared to the baseline vehicle. For such vehicle types, consumers requiring 

greater towing capacity would select a non-HEV powertrain. The agencies assumed that the 

HEV versions of most of the larger vehicle types would require the same towing capacity as 

the baseline vehicle and a 2-mode HEV powertrain was selected for these vehicle types. The 

breakdown of HEV application is shown in Table B1-3. 

Table B1-3: Types of Hybridization Considered in this Assessment 

Vehicle 

Type #

Vehicle 

Class Base Engine HEV Type

1 Subcompact I4 P2

2 Small car I4 P2

3 Small car I4 P2

4 Minivan V6 P2

 

E

 P2 hybrids are defined and described in Chapter 3 (sction 3.2.3) 
Appendix B 

B-6 

5 Large car V6 P2

6 Large car V8 P2

7 Minivan I4 P2

8 Small truck V6 P2

9 Minivan V6 2-mode

10 Minivan V8 2-mode

11 Large truck V6 2-mode

12 Large truck V6 P2

13 Large truck V8 2-mode

14 Large truck V8 2-mode

15 Large car V8 P2

16 Minivan V6 P2

17 Minivan V8 2-mode

18 Large truck V6 P2

19 Large truck V8 2-mode

As done with conventional gasoline packages, we began with a preliminary-set of 

HEV packages that paired the HEV powertrain with increasing levels of engine technologies. 

For example, the preliminary-set of HEV packages would pair the HEV powertrain first with 

a very basic gasoline engine (e.g., anytime technologies (ATT) and variable valve timing 

(VVT), such as dual cam phasing (DCP)), then a slightly more sophisticated gasoline engine 

(e.g., ATT, DCP, GDI), then a more sophisticated gasoline engine (e.g., ATT, DCP, GDI, 

turbo/downsize), then an advanced gasoline engine (e.g., ATT, DCP, variable valve lift, GDI, 

turbo/downsize, cooled EGR), etc. We then ranked the preliminary-set of HEV packages 

according to TARF to generate the most cost effective set of HEV packages for each vehicle 

type that would then be included in the master-set of packages. 

In general, the result of the TARF ranking of the preliminary-set of packages resulted 

in a master-set of packages that included three versions of HEV for each vehicle type. The 

first version employs a simple conventional gasoline engine such as one equipped with 

anytime technologies and valve timing control. The second employs a 

downsized/turbocharged gasoline engine and gasoline direct injection. The third employs an 

advanced gasoline engine with turbo/downsizing, direct injection and cooled EGR. Each of 

these versions of HEV was then paired with mass reduction levels ranging from 15% to 30%. 

The last step was to build the REEVs and EVs for vehicle types 1 through 8 and 15. 

The other vehicle types were not considered for electrification beyond HEVs for purposes of 

the current analysis, either because of their expected towing demands or because of their high 

vehicle weight which would make the electrification of the vehicle prohibitively expensive. 

We have developed 2 primary types of REEV packages and 3 primary types of EV packages 

all of which are included in the master-set of packages. The REEVs consist of packages with 

battery packs capable of 20 miles of all electric operation (REEV20) and packages with 

battery packs capable of 40 miles of all electric operation (REEV40). For EVs, we have built 

packages capable of 75, 100 and 150 miles of all electric operation, EV75, EV100 and 

EV150, respectively. These ranges were selected to represent an increasing selection of 

ranges (and costs) that consumers will require and that we believe will be available in the 
2017-2025 Technical Assessment 

B-7 

2020 timeframe. For each of these packages, we have estimated specific battery-pack costs 

for systems placed in vehicles with 15% and 20% mass reduction to the ―glider‖ (i.e., the 

vehicle less any powertrain elements). We have then paired each REEV with 15%, 20%, 25% 

and 30% mass reduction and each EV with 15% and 20% mass reduction. Note that the 

REEVs with 25% and 30% mass reduction are not assumed to be constructed with the smaller 

battery packs and electric motors that would be possible with the 30%-lighter vehicle. This 

may make our estimates of cost effectiveness for REEVs with these higher mass reductions 

conservative since, while the higher mass reduction means lower fuel consumption and CO2

emissions, those benefits are balanced against the higher costs of further mass reduction 

without accounting for the lower cost of a smaller battery pack and motor. The end result is a 

master-set of over 40 packages for those vehicle types with REEVs and EVs and as many as 

30 packages for those vehicle types without REEVs and EVs. Because of the large number of 

total packages, Table B1-4 shows only the resultant master-set of packages for vehicle type 5, 

a large car with a V6 DOHC engine in the baseline. Note that a complete master-set of 

packages for each vehicle type along with their costs and effectiveness estimates is contained 

in a memorandum to the docket for this report.1

 Importantly, for each level of mass reduction, 

there is some level of expected engine downsizing made possible due to the lower vehicle 

weight. The analysis does not account for any cost credit for downsizing that consists only of 

minor displacement changes (i.e., less than 20%)—only because we have not yet developed 

estimated costs or savings of doing so—even though the engine itself would contain 

somewhat less material. However, when a downsize occurs that consists of cylinders being 

removed (in the case of V8 to V6 and V6 to I4 downsizing) or a large displacement change 

(in the case of an I4 to smaller I4), we do consider the cost implications of the downsizing 

because we have tear-down data upon which to base our cost estimates. 

Table B1-4: Technology Packages used in OMEGA for Vehicle Type 5, Large Car V6 

Tech 

Pkg #

Mass 

Rdxn Package Technologies Transmission Description

500 0% 3.3L 4V DOHC V6 4sp AT Baseline Package

501 3% 4V DOHC I4+ATT+DCP+GDI+TDS 6sp DCT-wet ATT=Anytime techs

502 5% 4V DOHC I4+ATT+DCP+GDI+TDS 6sp DCT-wet DCP=dual cam phasing

503 15% 4V DOHC I4+ATT+DCP+GDI+TDS 6sp DCT-wet

GDI=gasoline direct 

injection, 

TDS=turbo/downsize

504 15% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS 6sp DCT-wet DVVL=discrete variable 

valve lift

505 15% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS 6sp DCT-wet SS=stop-start

506 15% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR 6sp DCT-wet EGR=cooled EGR

507 15% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR 6sp DCT-wet

508 20% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS 6sp DCT-wet

509 25% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS 6sp DCT-dry

510 30% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS 6sp DCT-dry

511 20% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR 6sp DCT-wet

512 25% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR 6sp DCT-dry

513 30% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR 6sp DCT-dry

514 20% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR 6sp DCT-wet

515 25% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR 6sp DCT-dry

516 30% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR 6sp DCT-dry

517 15% 4V DOHC I4+ATT+DCP+DS+HEV 6sp DCT-wet HEV=P2 for this vehicle 

type

518 20% 4V DOHC I4+ATT+DCP+DS+HEV 6sp DCT-wet

519 25% 4V DOHC I4+ATT+DCP+DS+HEV 6sp DCT-dry
Appendix B 

B-8 

520 30% 4V DOHC I4+ATT+DCP+DS+HEV 6sp DCT-dry

521 15% 4V DOHC I4+ATT+DCP+GDI+TDS+HEV 6sp DCT-wet

522 20% 4V DOHC I4+ATT+DCP+GDI+TDS+HEV 6sp DCT-wet

523 25% 4V DOHC I4+ATT+DCP+GDI+TDS+HEV 6sp DCT-dry

524 30% 4V DOHC I4+ATT+DCP+GDI+TDS+HEV 6sp DCT-dry

525 15% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV 6sp DCT-wet

526 20% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV 6sp DCT-wet

527 25% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV 6sp DCT-dry

528 30% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV 6sp DCT-dry

529 15% 4V DOHC I4+ATT+GDI+DS+REEV20 6sp DCT-wet

530 20% 4V DOHC I4+ATT+GDI+DS+REEV20 6sp DCT-wet

531 30% 4V DOHC I4+ATT+GDI+DS+REEV20 6sp DCT-dry

532 15% 4V DOHC I4+ATT+GDI+DS+REEV40 6sp DCT-wet

533 20% 4V DOHC I4+ATT+GDI+DS+REEV40 6sp DCT-wet

534 30% 4V DOHC I4+ATT+GDI+DS+REEV40 6sp DCT-dry

535 15% EV75 (27kWh, 75 miles onroad @ 314 Wh/mi) N/A

536 20% EV75 (27kWh, 75 miles onroad @ 304 Wh/mi) N/A

537 15% EV100 (39kWh, 100 miles onroad @ 323 Wh/mi) N/A

538 20% EV100 (39kWh, 100 miles onroad @ 314 Wh/mi) N/A

539 15% EV150 (63kWh, 150 miles onroad @ 346 Wh/mi) N/A

540 20% EV150 (63kWh, 150 miles onroad @ 337 Wh/mi) N/A

To reiterate, some preliminary packages considered during the package creation 

process were determined to not be cost-effective when ranked with other packages for the 

given vehicle type. For example, the packages shown in Table B1-4 move immediately from 

the baseline package to a rather complex turbo/downsized package in package number 501. 

This does not mean that we did not consider packages consisting only of, for example, DCP 

or DCP+GDI when generating our preliminary-set of packages. Rather, it means that those 

packages simply were not as cost effective in this analysis, based on their Technology 

Application Ranking Factor (TARF), as was the package shown as #501. For that reason, the 

intermediate packages that were part of the preliminary-set of packages have simply been 

eliminated from consideration and have not been included in the master-set of packages since 

OMEGA will never pick them given the levels of potential standards considered in this 

Technical Assessment Report. 

Once the master-set of packages is complete, they are all ranked once again based on 

TARF to generate the ―ranked-set‖ of packages for each of the technology paths discussed in 

Section 3.3 of the main report. While the master-set of packages is considered unchanging (at 

least in the context of this current analysis), the ranked-set of packages is different for each 

technology pathway because each pathway has different levels of, for example, mass 

reduction caps. For a technology pathway with a mass reduction cap of 15%, those packages 

with mass reductions greater than 15% would be eliminated from consideration and would not 

be included in the ranked-set of packages. Likewise, those packages having mass reductions 

greater than 20% would be eliminated in a technology pathway having a mass reduction cap 

of 20%. The package ranking also changes for each given year since technology costs and, 

hence, package costs change year-to-year. As a result, a ranked-set of packages in 2020 may 

or may not include the same packages as a ranked-set of packages in 2025 even if using the 

same mass reduction cap, and they may or may not be ranked in the same order. 
2017-2025 Technical Assessment 

B-9 

B2 Engine Technologies 

B2.1 Updated Tear-down Costs from FEV 

As noted in Chapter 3, the agencies have reconsidered many of the costs used in the 

2012-2016 joint final rule where those costs were based on tear-down studies conducted by 

FEV under contract to EPA. We have reconsidered these costs because, in the 2012-2016 

light-duty final rule, the agencies relied on the FEV tear-down study findings in part for 

estimating the cost of several technologies. However, for some of the technologies, NHTSA 

and EPA modified FEV’s actual estimated costs. This was done because FEV based their 

costs on the assumption that these technologies would be mature when produced in large 

volumes (450,000 units or more). The agencies believed that there was some uncertainty 

regarding each manufacturer’s near-term ability to employ the technology at the volumes 

assumed in the FEV analysis with fully learned costs. There was also the potential for near 

term (earlier than 2016) supplier-level costs to be higher than those considered in the FEV 

analysis because existing equipment and facilities need to be converted to the production of 

new technologies and may lead to stranded capital if done too rapidly.G

 However, the 

agencies consider the FEV results to be valid for the 2017-2025 timeframe because the 

limitations considered in the 2012-2016 light-duty rule should no longer exist and sales 

volumes of 450,000 units are likely by then due to, at least in part, the new GHG and fuel 

economy requirements. 

We reiterate that the agencies believe that the best method to derive technology cost 

estimates is to conduct studies involving tear-down and analysis of actual vehicle 

components. A tear-down analysis involves breaking down a technology into its fundamental 

parts and manufacturing processes by completely disassembling vehicles and vehicle 

subsystems and precisely determining what would be required for its production. More 

details about tear-down studies can be found in the studies supporting the 2012-2016 lightduty final rule as well as the FEV and Munro Associates report for EPA.2

 This tear-down 

method of costing technologies is often used by manufacturers to benchmark their products 

against competitive products. Historically, vehicle and vehicle component tear-down has not 

been done in large scale by researchers and regulators due to the expense required for such 

studies. 

To date, such tear-down studies have been completed on the five technologies listed 

below. These completed tear-down studies provide a thorough evaluation of the component 

or system cost relative to their baseline (or replaced) technologies. A more detailed 

description of these technologies can be found in the Technical Support Document prepared 

for the 2012-2016 light-duty final rule.3For these technologies, the agencies have relied on 

the tear-down data available and scaling methodologies used in EPA’s ongoing study with 

FEV. 

 

G

 Stranded Capital is defined as manufacturing equipment and facilities that cannot be used in the production of 

a new technology. 
Appendix B 

B-10 

1. Stoichiometric gasoline direct injection and turbocharging with engine downsizing 

(TDS) for a large DOHC (dual overhead cam) 4 cylinder engine to a smaller 

DOHC 4 cylinder engine. 

2. Stoichiometric gasoline direct injection and turbo charging with engine 

downsizing for a SOHC (single overhead cam) 3 valve/cylinder V8 engine to a 

SOHC V6 engine. 

3. Stoichiometric gasoline direct injection and turbo charging with engine 

downsizing for a DOHC V6 engine to a DOHC 4 cylinder engine. 

4. 6-speed automatic transmission replacing a 5-speed automatic transmission. 

5. 6-speed wet dual clutch transmission (DCT) replacing a 6-speed automatic 

transmission. 

FEV’s costing methodology for these studies has been published and has been peer 

reviewed.4 Using this tear down costing methodology, FEV has developed costs for each of 

the above technologies. In addition, using the studies listed above, FEV and EPA were able 

to extrapolate the engine downsizing costs for the following scenarios to estimate costs 

presented in the 2012-2016 rule: 

1. Downsizing a SOHC 2 valve/cylinder V8 engine to a DOHC V6. 

2. Downsizing a DOHC V8 to a DOHC V6. 

3. Downsizing a SOHC V6 engine to a DOHC 4 cylinder engine. 

4. Downsizing a DOHC 4 cylinder engine to a DOHC 3 cylinder engine. 

The costs used in the 2012-2016 rule and the updated costs used in this assessment are 

shown in Table B2.1-1. 

Table B2.1-1: Comparison of Stoichiometric Gasoline Direct Injection, 

Turbo/Downsizing and Transmission Costs, Inclusive of Markups, used in the 2012-2016 

Rulemaking versus this Assessment 

2012-2016 

rulemaking; 

applicable to the 

2012MY

(2007 dollars)

2012-2016 

rulemaking; 

applicable to the 

2016MY

(2007 dollars)

Assessment 

Report; 

applicable to the 

2017MY

(2008 dollars)

Assessment 

Report; 

applicable to the 

2025MY

(2008 dollars)

Stoichiometric GDI (I3/I4)a$236 $209 $213 $181

Stoichiometric GDI (V6) a$341 $301 $370 $299

Stoichiometric GDI (V8) a$390 $346 $446 $360

Turbo/Downsize I4 DOHC 

to I3 DOHCb $395 $349 $287 $245

Turbo/Downsize I4 DOHC 

to smaller I4 DOHCb $441 $391 $365 $311

Turbo/Downsize V6 

DOHC to I4 DOHCb $168 $149 -$27 -$3

Turbo/Downsize V6 SOHC 

to I4 DOHCb $365 $323 $110 $107

Turbo/Downsize V6 OHV 

to I4 DOHCb $872 $771 $754 $628

Turbo/Downsize V8 

DOHC to V6 DOHCb $669 $592 $491 $428

Turbo/Downsize V8 SOHC $923 $816 $649 $555
2017-2025 Technical Assessment 

B-11 

2V/cyl to V6 DOHC

Turbo/Downsize V8 SOHC 

3V/cyl to V6 DOHCb $832 $736 $590 $507

Turbo/Downsize V8 OHV 

to V6 DOHCb $1,242 $1,099 $1,101 $920

6 speed automatic 

transmission (from a 4 

speed automatic 

transmission) a

$112 $99 -$13 -$10

6 speed dual wet-clutch 

transmission (from a 4 

speed automatic 

transmission) a

$104 $92 -$134 -$108

6 speed dual dry-clutch 

transmission (from a 4 

speed automatic 

transmission) a

$53 $47 -$190 -$153

a Low complexity ICMs applied: 2012MY=1.11; 2016MY=1.11; 2017MY=1.17; 2025MY=1.13. The 2012MY and 

2016MY ICMs differ from the 2017MY ICM—all considered near term—due to factors described in Section 3.2.5 of the 

main report. The 2025MY ICM is a long term ICM.

b Medium complexity ICMs applied: 2012MY=1.25; 2016MY=1.25; 2017MY=1.31; 2025MY=1.19. The 2012MY and 

2016MY ICMs differ from the 2017MY ICM—all considered near term—due to factors described in Section 3.2.5 of the 

main report. The 2025MY ICM is a long term ICM.

B2.2 Advanced Gasoline Cost and Effectiveness 

B2.2.1 Turbocharged/downsized Engines with Gasoline Direct Injection 

In the 2012-2016 final rule, the agencies estimated the combined effectiveness of 

turbocharging, engine downsizing and GDI in reducing GHG emission to be 7%. Recent data 

supports GHG effectiveness in the range of 12 to 30% depending on the extent of engine 

downsizing for a given engine torque requirement.5,6,7Taking into consideration the 

availability of more recent published data and confidential business information, the Agencies 

estimate the effectiveness of a Turbocharged GDI with single-stage turbocharging, dual camphasing and with downsizing consistent with a BMEP level of approximately 22-24 bar to be 

15%. 

B2.2.2 Cooled EGR 

A new technology considered for this assessment was cooled EGR with 

turbocharging. This technology was described briefly in the 2012-2016 GHG and CAFE final 

rule but the technology was not used in the cost and effectiveness analysis. Cooled EGR can 

prevent combustion knock and thus allows for an increase in engine compression ratio and/or 

more aggressive engine downsizing when combined with turbocharging and gasoline direct 

injection while maintaining torque output and vehicle performance. Cooled EGR with 

aggressive engine downsizing (approximately 24-bar BMEP), single-stage turbocharging, 

dual cam phasing and discrete variable valve lift has been estimated by Ricardo to reduce 

CO2 emissions over both the UDDS and highway fuel economy test by 23%.8 The 

incremental effectiveness of cooled EGR relative to a downsized, turbocharged GDI engines 
Appendix B 

B-12 

without EGR has been estimated to reduce BSFC by various sources to be approximately 5 to 

13%.5,9,10,11 Based on the cited publically available data and confidential business 

information, the Agencies estimate the incremental effectiveness of cooled EGR with singlestage variable geometry turbocharging and with downsizing consistent with approximately 

24-bar BMEP to be 6% relative to turbocharging, downsizing and GDI without cooled EGR 

as described in section B2.2.1; and 20% relative to a baseline 2008 PFI engine. We expect to 

update the effectiveness values of this technology for the NPRM based on vehicle simulation 

modeling currently being conducted under an EPA contract with Ricardo. 

The costs for the technology here build upon the costs presented in the 2012-2016 rule 

which showed costs of $75 for an EGR cooler, $20 for an EGR valve and $20 for associated 

piping for a total direct manufacturing cost of $115 (2007 dollars). We have updated each of 

those costs to 2008 dollars with the results being $77, $20 and $20, for a total of $117. To 

provide sufficient transient engine control, we have assumed that a dual-loop EGR system 

will be used with both high and low pressure EGR loops. We have doubled EGR component 

costs to $235 to reflect components in both EGR loops and have added a $5 venturi to provide 

for EGR flow from the low pressure exhaust system to the high pressure intake system, thus 

giving a total of $240 for the cooled EGR portion of the system. Because the system is 

expected to employ higher levels of boost over a broader range of flow conditions than the 

conventional gasoline turbocharged system, we have also included a 1.5x factor to the 

turbocharger costs to cover the incremental cost increase of a variable geometry turbocharger. 

In other words, the turbocharger system cost is 1.5x greater on engines with cooled EGR than 

on downsized, turbocharged engines without cooled EGR. This was estimated based on 

engineering judgment with input from suppliers. Therefore, to the $240 value, we have added 

$620 for I-configuration engines (1.5x the single turbocharger cost of $413 equals $620) and 

$1,043 (1.5x the twin turbocharger cost of $695 equals $1,043) for V-configuration engines 

(one turbocharger per cylinder bank, which is conservative as it is possible that not all Vconfiguration engines will use twin turbochargers). The results being $859 ($240+$620) for 

I-configuration engines and $1,283 ($240+$1,043) for V-configuration engines (direct 

manufacturing costs, 2008 dollars, 2012MY). All of the costs stated thus far represent direct 

manufacturing costs in 2008 dollars and are applicable to the 2012 model year. We consider 

time based learning to be applicable to this advanced gasoline technology. The resultant 

direct manufacturing cost and marked up costs are shown in Table B2.2-1 Importantly, these 

costs shown here do not represent package costs since they do not include the anytime 

technologies,H DCP, DVVL, GDI, or downsizing related costs or other technologies that 

might be included in an advanced gasoline package (such as stop-start or hybridization). 

Table B2.2-1: Cooled EGR System Costs (2008 dollars) 

Direct Mfg Costs Costs with ICM

Year 2012 2020 2025 2012 2020 2025

I-configuration engines $859 $701 $634 $1,125 $878 $754

V-configuration engines $1,283 $1,048 $947 $1,681 $1,304 $1,127

 

H

 Anytime technologies are simpler technologies that can be added outside the normal redesign cycle, thus they 

can be implemented anytime. An example is low rolling resistance tires.
2017-2025 Technical Assessment 

B-13 

ICM applied 1.31 1.31 1.19

B3 Transmission Technologies 

B3.1 6, 7, and 8 speed Automatic Transmissions 

As discussed in the 2012-2016 rule, manufacturers can choose to replace 4- and 5-

speed transmission with 6-, 7-, or 8-speed automatic transmissions. Additional ratios allow 

for further optimization of engine operation over a wider range of conditions, but this is 

subject to diminishing returns as the number of speeds increases. As additional planetary gear 

sets are added (which may be necessary in some cases to achieve the higher number of ratios), 

additional weight and friction are introduced. Also, the additional shifting of such a 

transmission can be perceived as bothersome to some consumers, so manufacturers need to 

develop strategies for smooth shifts. Some manufacturers are replacing 4- and 5-speed 

automatics with 6-speed automatics, and 7- and 8-speed automatics have also entered 

production, albeit in lower-volume applications in luxury and performance oriented cars. 

As discussed in the 2012-2016 rule, confidential manufacturer data projected that 6-

speed transmissions could incrementally reduce fuel consumption by 0 to 5 percent from a 

baseline 4-speed automatic transmission, while an 8-speed transmission could incrementally 

reduce fuel consumption by up to 6 percent from a baseline 4-speed automatic transmission. 

GM has publicly claimed a fuel economy improvement of up to 4 percent for its new 6-speed 

automatic transmissions.12

 The 2008 EPA Staff Technical Report found a 4.5 to 6.5 percent 

fuel consumption improvement for a 6-speed over a 4-speed automatic transmission.13 Based 

on this information, the agencies estimated that the conversion to a 6-,7- and 8-speed 

transmission from a 4 or 5-speed automatic transmission with IATC would have an 

incremental fuel consumption benefit of 1.4 percent to 3.4 percent, for all vehicle classes. 

From a baseline 4 or 5 speed transmission without IATC, the incremental fuel consumption 

benefit would be approximately 3 to 6 percent, which is consistent with the EPA Staff Report 

estimate. 

The agencies reviewed these effectiveness estimates and concluded that they remain 

accurate. The GHG model estimates the packaged effectiveness of 4.5 to 6.5 percent. 

The cost associated with 6 speed automatic transmissions has been updated for this 

assessment relative to the estimates presented in the 2012-2016 rule. These updated costs are 

presented above in Table B2.1-1 Dual Clutch Transmissions / Automated Manual 

Transmissions. 

An Automated Manual Transmission (AMT) is mechanically similar to a conventional 

manual transmission, but shifting and launch functions are automatically controlled by the 

electronics. There are two basic types of AMTs, single-clutch and dual-clutch (DCT). A 

single-clutch AMT is essentially a manual transmission with automated clutch and shifting. 

Because of shift quality issues with single-clutch designs, DCTs will likely be far more 

common in the U.S. and are the basis of the estimates that follow. A DCT uses separate 

clutches (and separate gear shafts) for the even-numbered gears and odd-numbered gears. In 

this way, the next expected gear is pre-selected, which allows for faster and smoother shifting. 
Appendix B 

B-14 

For example, if the vehicle is accelerating in third gear, the shaft with gears one, three and 

five has gear three engaged and is transmitting power. The shaft with gears two, four, and six 

is idle, but has gear four engaged. When a shift is required, the controller disengages the oddgear clutch while simultaneously engaging the even-gear clutch, thus making a smooth shift. 

If, on the other hand, the driver slows down instead of continuing to accelerate, the 

transmission will have to change to second gear on the idling shaft to anticipate a downshift. 

This shift can be made quickly on the idling shaft since there is no torque being transferred on 

it.

In addition to single-clutch and dual-clutch AMTs, there are also wet clutch and dry 

clutch designs which are used for different types of vehicle applications. Wet clutch AMTs 

offer a higher torque capacity that comes from the use of a hydraulic system that cools the 

clutches. Wet clutch systems are less efficient than the dry clutch systems due to the losses 

associated with hydraulic pumping. Additionally, wet AMTs have a higher cost due to the 

additional hydraulic hardware required. 

Overall, DCTs likely offer the greatest potential for effectiveness improvements 

among the various transmission options presented in this report because they offer the 

inherently lower losses of a manual transmission with the efficiency and shift quality 

advantages of electronic controls. The lower losses stem from the elimination of the 

conventional lock-up torque converter, and a greatly reduced need for high pressure hydraulic 

circuits to hold clutches or bands to maintain gear ratios in automatic transmissions. 

However, the lack of a torque converter will affect how the vehicle launches from rest, so a 

DCT will most likely be paired with an engine that offers sufficient torque at low engine 

speeds to allow for adequate launch performance. 

Referring to the 2012-2016 rule, these transmissions offer an effectiveness of 9.5 to 

14.5 percent over a 4-speed automatic transmission. The agencies conclude that 8 to 13 

percent effectiveness is still appropriate for this rule. The costs associated with 6 speed dual 

clutch transmissions have been updated for this assessment relative to the estimates presented 

in the 2012-2016 rule. These updated costs are presented above in Table B2.1-1. EPA had 

hoped to include in this assessment FEV-generated tear-down cost estimates for an 8 speed 

dual clutch transmission. Unfortunately, that work was not complete in time, but it is 

expected to be used in the upcoming federal NPRM. 

B4 Vehicle Technologies 

B4.1 Aerodynamic Improvement Cost and Effectiveness 

This can be achieved via two approaches, either reducing the drag coefficients or 

reducing vehicle frontal area. To reduce drag coefficients, skirts, air dams, underbody covers, 

and more aerodynamic side view mirrors can be applied, or the vehicle ride height can be 

lowered. In addition to the standard aerodynamic treatments, the agencies have included a 

second level of aerodynamic technologies (Aero 2) which could include active grille shutters, 

rear visors, and larger under body panels. The GHG and fuel economy effectiveness of 2% is 

unchanged from estimates used for 2016 model year vehicles in the 2012-2016 final rule, and 

is based on a 10% assumed reduction in aerodynamic drag coefficient . This second level of 
2017-2025 Technical Assessment 

B-15 

aerodynamic technologies was not considered in the 2012-2016 light-duty rule and, as such, 

the estimated costs are new and are presented in Table B4.1-1 along with the first level (Aero 

1) as used in the 2012-2016 rule. Effectiveness for Aero 2 is based on an additional 10% 

reduction in aerodynamic drag coefficient from the 2008 baseline and provides another 2% 

reduction in GHG. Note that we apply time based learning to aerodynamic improvements. 

Table B4.1-1: Costs Associated with Aerodynamic Improvements (2008 dollars) 

Direct Manufacturing Costs (applicable to the 2015MY)

Technology Quantity $/unit $/vehicle

Low

$/vehicle

High

Aero 1 (incremental to base vehicle)

Air dam 1 $15-20 $15 $20

Tire spats 4 $2.50 $10

Under body panels 1 $15-20 $15 $20

Total (Average=$40) $30 $50

Aero 2 (incremental to base vehicle)

Under body panels 3, 4 $10-20 $30 $80

Active grill shutters 1 $25-40 $25 $40

Rear visors – hood, liftgate, tailgate 1 $15-20 $15 $20

Low profile roof rack – stowable cross bows 1 $30 $30

Total (Average=$120) $70 $170

Marked up costs

Technology Year 2015 2020 2025

Aero 1 (ICM: Near term=1.17; Long term=1.13) $47 $40 $36

Aero 2 (ICM: Near term=1.31; Long term=1.19) $157 $128 $115

B4.2 Electrified Vehicles Costing – HEV, PHEV, and EV Vehicles 

While the overall methodology for costing electrified vehicles has not changed from 

the 2012~2016 rule the scaling and cost basis for both batteries and electric motors has been 

modified. Specifically, cost information developed by Oak Ridge National Laboratory 

(ORNL) on electric motors has been applied, as well as battery costing information from 

Argonne National Laboratory (ANL). Refer to the Technical Support Document (TSD)14 for 

the 2012-2016 rule for a full description of the electrified vehicle costing methodology. 

B4.2.1 Changes to the 2017-2025 Electrified Vehicle Costing 

Unless otherwise noted, the cost basis and scaling for electrified vehicles in the 2017-

2025 analysis is identical to that used in the 2012-2016 rule. There are, however, several 

changes to the cost basis due to various factors. The first was agreement within the agencies 

that the mass of electrified vehicles would continue to be reduced while energy densities of 

batteries are expected to increase. These trends made the current battery and motor sizing 

strategies inappropriate for this analysis. In addition, recent data from ANL, which has been 

corroborated with battery manufacturer data, indicates that battery costs will be dependent on 

not only the annual production volume, but also the ratio of the power to energy. The 

agencies, once again, determined that the application of a fixed $/kW-hr value was not 

appropriate going forward. One of the caveats in applying the ANL cost model was that it 
Appendix B 

B-16 

was highly dependent of production volumes, volumes at which batteries will on be produced 

until approximately MY 2025. As such, the electrified vehicle costing model was to apply 

time based learning to the non-battery costs, as those are based on the 2012 -2016 rule, and 

treat the ANL battery costs as 2025 values. With regard to motor costs, the agencies 

leveraged a cost study performed by ORNL on the Toyota Prius15 motor costs and applied the 

ORNL results directly. Further detail for each of these considerations is provided below. 

B4.2.1.1 P2 Hybrid Electric Vehicles 

A P2 hybrid is a vehicle with an electric drive motor coupled to the engine crankshaft 

via a clutch. The engine and the drive motor are mechanically independent of each other, 

allowing the engine or motor to power the vehicle separately or combined. This is similar to 

the Honda HEV architecture with the exception of the added clutch between the flywheel or 

flexplate and the electric motor, additional battery capacity, and increased electric motor 

power. Examples P2 hybrids include the 2011 Hyundai Sonata Hybrid, 2010 Hyundai Elantra 

LPI HEV (Korean market only), the 2011 Infinity G35 Hybrid and the 2011 Volkswagen 

Touareg Hybrid. The agencies believe that the P2 is an example of a ―strong‖ hybrid 

technology that is typical of what we will see in the timeframe of this rule. The agencies 

could have equally chosen the power-split architecture as the representative HEV architecture. 

These two HEV’s have comparable average GHG effectiveness values (combined city and 

highway fuel economy), though the P2 systems may have lower cost due to reduced number 

of parts and complexity. 

The Agencies estimated the effectiveness of the P2 hybrid system to be 30% within 

our analysis. The effectiveness when combined with a DCT transmission is approximately 

37%. The effectiveness used for vehicle packages with the P2 hybrid configuration within this 

analysis reflects a conservative estimate of system performance. Vehicle simulation modeling 

of technology packages using the P-2 hybrid configuration is currently underway under 

contract with Ricardo Engineering. The agencies plan to update the effectiveness of hybrid 

electric vehicle packages using the new Ricardo vehicle simulation modeling runs prior to the 

NPRM. 

Hybrid effectiveness was also applied differently across vehicle classes within this 

analysis when compared to the 2012-2016 rule. Previously, the Agencies assumed less engine 

downsizing and reduced effectiveness with increasing vehicle size to preserve some lighttowing capability for large cars, CUVs, minivans and small light trucks. For this analysis, P2 

hybrid packages were only applied to vehicles with reduced towing capability (SAE Class I or 

less) and the relative effectiveness due to engine downsizing with the P2 hybrid package was 

applied equally across all vehicle categories capable of receiving the P2 hybrid package in the 

Omega model. 
2017-2025 Technical Assessment 

B-17 

Figure B4.2-1: Functional schematic of P2 hybrid electric vehicle powertrain 

configuration (not to scale). 

B4.2.1.2 Battery and Motor Sizing 

Baseline vehicle effective power-to-weight ratioI was used to approximate equivalent 

performance for EVs, PHEVs and P2 hybrids. Electric motors were sized based on 

maintaining this ratio for EV, PHEV and hybridJvehicles. In addition, some level of mass 

reduction is expected to be realized for these types of vehicles, so the motor sizing was 

dependent on the final, mass reduced, vehicle. Motor size for PHEVs assumed full vehicle 

performance could be achieved on electric motor drive only. The Agencies scaled P2 hybrid 

motors to represent 20% of the vehicle’s (combined) effective power, as supported by 

manufacturer’s confidential information. 

The battery packs were sized to provide 75, 100 or 150 mile on-roadKranges in the 

case of EVs and 20 or 40 mile on-road ranges in the case of PHEVs. Battery sizing for EVs 

and PHEVs was based on a vehicle energy demand estimate (derived from EPA’s lumped 

parameter model) used to determine each vehicle’s electric energy consumption, in Wh/mile, 

for future EV, PHEV and hybrid packages (which considers road load and weight reductions). 

 

I

 To compare with conventional ICE-powered vehicles, we use ―effective‖ vehicle power -defined here as the 

peak combined power of the vehicle’s engine and electric motor. In the case of P2 hybrids it is assumed that the 

peak rated power values are additive, although this is not necessarily true for other architectures (such as powersplit hybrids, where the engine and motor power peaks do not occur at the same operating speed) 

J

 Vehicle weight reduction when applied to EVs and PHEVs was applied to the glider only (curb-weight less 

electric drive components). Weight reduction was applied to the entire vehicle in the case of HEVs. 

K

 EVs and PHEVs are assumed to experience an onroad range shortfall of 30%, whereas HEVs are assumed to 

see a shortfall of 25%. In terms of energy consumption (and thus battery size), this represents an increase of 

43% and 33% for EVs/PHEVs and HEVs, respectively. 

Engine

Clutch

Transmission /

Transaxle

Electric Motor
Appendix B 

B-18 

Additionally, battery usable state-of-charge (SOC) windowsL were assumed at 80% for future 

EVs, 70% for future PHEVs and 50% for future HEVs. 

B4.2.1.3 Battery Cost 

Battery costs were determined using a model developed by Argonne National 

Laboratory (ANL) which provides unique battery pack cost estimates for each of the three 

major types of electrified vehicles. Within the model, battery pack costs are estimated based 

on a bill of materials determined by battery pack design criteria. The costs include materials, 

manufacturing processes, cost of capital equipment, plant area and labor for each 

manufacturing step. A basic description of the ANL Li-ion battery cost model and initial 

modeling results for PHEV applications were published within a peer-reviewed technical 

paper presented at EVS-2416

. ANL has extended modeling inputs and pack design criteria 

within the cost model to include analysis of manufacturing costs for EV and HEV battery 

packs in addition to the original work on PHEV battery costs.17 A thorough peer-review of 

the ANL Li-ion battery cost model and its inputs and results is pending. The agencies expect 

to continue to work with DOE and ANL (as well as manufacturers) to obtain the most up to 

date information for the upcoming NPRM. 

Within the ANL battery cost model, a bill of materials for a battery pack is determined 

based on specific design criteria. The design criteria include a vehicle application’s power 

and energy storage capacity requirements, the battery’s cathode and anode chemistry, and the 

number of cells per module and modules per battery pack. The model assumes use of a 

laminated multi-layer prismatic cell and battery modules consisting of double-seamed rigid 

containers (Figure B4.2-2). The model also assumes that the battery modules are air-cooled. 

The model takes into consideration the cost of capital equipment, plant area and labor for each 

step in the manufacturing process for battery packs and places relevant limits on electrode 

coating thicknesses and other processes limited by existing and near-term manufacturing 

processes. Figure B4.2-3 shows a basic schematic of the plant layout and production steps 

assumed within the model The ANL model also takes into consideration annual pack 

production volume and economies of scale for high-volume production. 

 

L On-road range is defined as the percentage of a battery pack’s useful operating range. For durability and safety 

reasons, electric vehicle batteries are not discharged completely, nor are they typically operated at fully charged 

levels. Because of this limitation, . Thus the nominal battery size required always larger than that which is used, 

and is calculated as the actual required capacity divided by the SOC window. 
2017-2025 Technical Assessment 

B-19 

Figure B4.2-2: Prismatic Cell and Module Design for High Power-to Energy HEV 

Battery Packs (provided courtesy of Argonne National Laboratory). 

Terminal Seal

Polymer Seal of 

Cell Container 

to Terminal 

Ultrasonic Welds

of Terminal to 

Collector Foils

Cell Cross-Section Battery Module

Double-Seamed 

Module Closure

Heat Transfer Surfaces 

on Top and Bottom of 

Container in Contact 

with Cell Edge Seals

Cell Terminal 

Connections

Cell with Stiff, MultiLayer Container

Polymer 

Edge Seal 
Appendix B 

B-20 

Figure B4.2-3: Lithium-ion Battery Pack Manufacturing Plant Schematic Diagram 

(provided courtesy of Argonne National Laboratory). 

The cost outputs from the ANL model used by the Agencies to determine 2025 HEV, 

PHEV and EV battery costs assume 500,000 pack/year production volume. We also assumed 

the use of a common cathode and anode chemistry, LiMn2O4-spinel for the cathode and 

graphite for the anode. While it is expected that other Li-ion battery chemistries will likely be 

available in the 2017-2025 timeframe, the specific chemistry used for the cost analysis was 

chosen to be consistent with publicly available information on current and near term HEV, 

PHEV and EV product offerings from Hyundai, GM and Nissan.18,19,20,21 The battery designs 

used in the model also assumed full power delivery at 80% of the open circuit voltage. For 

EVs, battery power was assumed to be sufficient to provide peak motor power for an 

application with 15% added to account for HVAC and other non-motor electric loads. For 

HEVs and PHEVs, battery power was assumed to be sufficient to provide peak motor power 

for an application. The ANL battery cost model results for is compared to the costs used in 

the 2012-2016 final rule and to cost estimates compiled by EPA from OEM battery suppliers 

and auto OEMs in Figure B4.2-4. 

Shipping

Cell and 

Scrap 

Recycling

Receiving

Control 

Laboratory

Assembly Route

The areas in this diagram for each processing step are approximately proportional to 

the estimated plant areas in the baseline plant.

Battery Pack 

Assembly and 

Testing

Module 

Assembly

Formation 

Cycling

Current 

Collector

Welding

Enclosing 

Cell in 

Container

Electrolyte Filling

and Cell Closing

Cell Stacking

Solvent 

Evaporation

Positive

Negative

Electrode 

Coating

Positive

Negative

Electrode 

Slitting

Vacuum 

Drying

Electrode Materials 

Preparation

Positive

Negative Calendering

Solvent 

Recovery

Air 

Locks

ChargeRetention 

Testing 

Final 

Cell 

Sealing

Dry Room

Materials 

Handling

Outdoor dry-room air 

processing equipment
2017-2025 Technical Assessment 

B-21 

Figure B4.2-4: Comparison of direct manufacturing costs per unit of energy storage 

($/kW-hr) between the estimates used by EPA in the 2012-2016 GHG final rule, the 

ANL battery cost model results for PHEV20, PHEV40, EV100 and EV150 packages and 

OEM battery suppliers (2008 dollars, markups not included). Multiple points shown 

for the ANL cost model results for PHEV 20, PHEV40, EV100 and EV150 reflect the 

range of energy-specific costs for EPA’s subcompact through large-car package 

categories (see Table B4.2-1 for details). A range of OEM estimated battery costs is also 

shown for comparison (red bars) which may or may not reflect additional cost markups. 

A PHEV and EV battery cost sensitivity analysis is included in Chapter 6, section 6.5 

of the Technical Assessment. The analysis includes PHEV and EV battery pack costs 

approximately $100/kW-hr higher and $50/kW-hr lower than the costs estimates from the 

ANL battery cost model. The $100/kW-hr higher cost is comparable to commodity pricing 

for high-volume LiCoO2 cells for consumer applications. The $50/kW-hr lower cost assumes 

a breakthrough in battery design that would approximately triple cell energy density. 

B4.2.1.4 Motor Costing 

The agencies agreed that based on a review of the technical literature the cost-vspower relationship should not be a constant $15/kW across motor sizes. A linear relationship 

was chosen based on 2007 Camry/Prius motor and generator costs (based on ORNL/EEAestimated costs) and treated as near-term (2012-2016) results. The motor sizing, determined 

as described above was then applied to the linear cost model developed by ORNL: 

y (motor cost in USD) = 8.28 * (motor size in kW) + 181.43 

$-

$200 

$400 

$600 

$800 

$1,000 

$1,200 

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2030

Calendar Year

Cost ($U.S./kW-hr)

Total Range of OEM Supplier Estimates (>5sources) collected by EPA from 2008 -2010

2012-2016 EPA Cost Estimate

DOE/ANL (PHEV20) DOE/ANL (PHEV40)

DOE/ANL (EV150) DOE/ANL (EV100)

Estimated Battery Pack Costs

Range from the majority of OEM stakeholder meetings in June-August 2010
Appendix B 

B-22 

The final value is then learned down from 2012 to 2025 by applying time based 

learning. 

B4.2.1.5 Learning Applied to Battery and Non-Battery Costs 

As described above, the battery costs developed using the ANL model were 

considered the 2025 model year costs expressed in 2008 dollars. In contrast, the remaining 

parts of the hybrid or electrified vehicle system, termed the non-battery costs, were considered 

the 2012 model year costs expressed in 2008 dollars. While the non-battery systems are 

considered rather mature technologies for which time based learning is appropriate, the Li-ion 

battery system is a new technology for which volume based learning is more appropriate. In 

fact, the agencies believe it is likely that battery technology will undergo several levels of 

volume based learning between 2012 and 2025 given the newness of the technology and the 

rapid pace of development. For this reason, we have generated a unique learning curve for 

the battery system technology that attempts to estimate costs back in time from the 2025 

estimates discussed above. This allows us to estimate costs in the 2020 timeframe for 

OMEGA as well as estimate those costs in each year between today and 2025. The learning 

curve we have generated is shown in Figure B4.2-5. This learning curve consists of 5 full 

volume based learning steps each of which results in costs being reduced 20% relative to the 

prior step. These learning steps are shown occurring every two years beginning in 2012 until 

2020 at which time a 5 year gap is imposed until 2025 when the ANL costs are reached and 

the learning curve factor equals 1. Beyond 2025, time based learning is applied at 3% cost 

reductions per year. The smooth line shows a logarithmic curve fit applied to the learning 

curve as EPA’s cost model would apply learning. 

Figure B4.2-5: Battery Pack Learning Curve 

Using this learning curve, we can estimate the battery pack direct manufacturing costs 

for each year and for each type of battery pack. These details are shown in Table B4.2-1 

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

2012 2016 2020 2024 2028

Battery Pack Learning Curve

Learning curve Log. (Learning curve)
2017-2025 Technical Assessment 

B-23 

which shows, in the upper portion of the table, the estimated direct manufacturing costs for 

each type of battery pack considered (for a large car in this example) and in the lower portion 

the $/kWh estimated in each year based on the learning curve shown in Figure B4.2-5. 

Table B4.2-1: Direct Manufacturing Costs for Battery Packs and Associated $/kWh for 

Each, Costs for a Large Car (2008 dollars, markups not included) 

Cost Element 2012 2015 2018 2019 2020 2021 2022 2023 2024 2025

Battery Pack Costs

P2 battery pack $1,956 $1,565 $1,002 $1,002 $801 $801 $801 $801 $801 $641

REEV20 

battery pack $7,120 $5,696 $3,645 $3,645 $2,916 $2,916 $2,916 $2,916 $2,916 $2,333

REEV40 

battery pack $10,461 $8,368 $5,356 $5,356 $4,285 $4,285 $4,285 $4,285 $4,285 $3,428

EV75 battery 

pack $14,276 $11,421 $7,309 $7,309 $5,847 $5,847 $5,847 $5,847 $5,847 $4,678

EV100 battery 

pack $18,170 $14,536 $9,303 $9,303 $7,443 $7,443 $7,443 $7,443 $7,443 $5,954

EV150 battery 

pack $26,869 $21,495 $13,757 $13,757 $11,005 $11,005 $11,005 $11,005 $11,005 $8,804

Cost per Kilowatt-hour

$/kWh (P2) $2,964 $2,371 $1,518 $1,518 $1,214 $1,214 $1,214 $1,214 $1,214 $971

$/kWh 

(REEV20) $809 $647 $414 $414 $331 $331 $331 $331 $331 $265

$/kWh 

(REEV40) $581 $465 $298 $298 $238 $238 $238 $238 $238 $190

$/kWh (EV75) $501 $401 $256 $256 $205 $205 $205 $205 $205 $164

$/kWh

(EV100) $464 $371 $237 $237 $190 $190 $190 $190 $190 $152

$/kWh 

(EV150) $426 $341 $218 $218 $174 $174 $174 $174 $174 $140

B4.2.1.6 In-home Charger Costs 

We have also estimated cost associated with in-home chargers and installation of inhome chargers. Charger costs are covered in more detail in Section 4.2.3 of the main report. 

Here we summarize the actual costs used for developing EV and REEV package costs. We 

have estimated the cost of a level 1 charge cord at $30 (2008 dollars) based on typical costs of 

similar electrical equipment sold to consumers today and that for a level 2 charger at $200 

(2008 dollars). Labor associated with installing either of these chargers is estimated at $1,000 

(2008 dollars). Further, we have estimated that all REEV20 vehicles (REEVs with a 20 mile 

range) would be charged via a level 1 charger and that all EVs, regardless of range, would be 

charged via a level 2 charger. For the REEV40 vehicles (REEVs with a 40 mile range), we 

have estimated that: 25% of subcompacts would be charged with a level 1 charger with the 

remainder charged via a level 2 charger; 10% of small cars would be charged with a level 1 

charger with the remainder charged via a level 2 charger; and all remaining REEV 40 vehicles 

would be charged via a level 2 charger. All costs presented here are considered valid for the 

2025 model year. We have applied the learning curve presented above in Section B4.2.1.5 to 

the charger costs. We have also applied our High 2 ICMs to these costs (1.70 through the 

2021MY and 1.45 thereafter). Installation costs, being labor costs, have no learning impacts 
Appendix B 

B-24 

or ICM applied. The resultant costs for 2017, 2020 and 2025 are shown in Table B4.2-2. 

These costs are included in our package costs for all REEV and EV packages. 

Table B4.2-2: In-home Charger Related Costs for REEVs and EVs (2008 dollars) 

Technology Vehicle Class 2017 2020 2025

REEV20-Charger

Subcompact

Small car

Large car

Minivan

Small truck

$100 $64 $44

REEV40-Charger

Subcompact $523 $335 $228

Small car $608 $389 $265

Large car

Minivan

Small truck

$664 $425 $290

EV-Charger

Subcompact

Small car

Large car

Minivan

Small truck

$664 $425 $290

Labor

Subcompact

Small car

Large car

Minivan

Small truck

$1,000 $1,000 $1,000

B4.3 Mass Reduction Cost Model 

Application of mass reduction technologies for 2017-2025 vehicles has been discussed 

at length in meetings with vehicle manufacturers in preparation for this Technical Assessment 

Report. One of the challenges the manufacturers identified with respect to mass reduction 

was the feasibility of substituting some lower density materials for higher density materials. 

These issues included material availability, forming, joining, painting, corrosion, reparability, 

and impact performance. The agencies agree that these issues need further study in order to 

determine the feasibility of certain types of mass reduction and the appropriateness of 

assuming their applicability in the MYs 2017-2025 timeframe for purposes of the upcoming 

federal rulemaking. 

To begin to address these issues, the collaborative NHTSA, EPA, and DOE team 

described in Chapter 3 has focused on several tasks including a peer review of the Lotus 

Engineering report22 regarding holistic vehicle mass reduction opportunities, a 2nd phase of 

analysis by Lotus Engineering to assess the functional performance and safety of phase 1 

designs and to modify designs as appropriate through computer aided engineering (CAE), and 

two projects being conducted by DOE regarding, one regarding mass reduction feasibility and 
2017-2025 Technical Assessment 

B-25 

the other consisting of an actual vehicle build (Multi Material Vehicle – MMVM). NHTSA 

and EPA may also consider jointly funding a study to evaluate potentially feasible amounts of 

mass reduction and their accompanying cost for MY 2017-2025 separately from the study 

contracted to Lotus engineering by CARB. Computer Aided Engineering (CAE) tools would 

be used to analyze the structure of the vehicle. The proposed design should meet at least the 

same functional objectives as the baseline vehicle. If funded, this study would be designed to 

be finished in time for incorporation in the final rule analysis. 

For the 2012-2016 final rule, NHTSA and EPA relied on a 2015 cost of $1.32 (2007$) 

per pound of mass reduction, and the limit of mass reduction (penetration cap) was set to 10% 

based on our feasibility analysis.23 This cost was estimated by calculating an average of the 

costs estimated in three studies: 2002 NAS report (normalized estimated cost $1.50/lb)24

, 

Sierra Research (normalized estimated cost $1.01/lb for 10% mass reduction with 

compounding)25, and MIT (normalized estimated cost $1.36/lb for 14% mass reduction 

without mass compounding).26 The $1.32 per pound cost would be $1.35 per pound in 2008 

dollars. With a year of time-based learning at 3% per year the cost would be $1.31 (2008$) 

per pound in 2016 and with 4 years of time-based learning at 2% per year would be $1.20 

(2008$) per pound in 2020. 

However, in the 2017-2025 timeframe, many of the OEMs indicated in meetings with 

the agencies over the summer that they will be capable of higher levels of mass reduction than 

10 percent per vehicle. The OEMs also generally stated that there is some initial amount of 

mass reduction which can be accomplished with zero or very little cost (much lower than that 

estimated in the 2012-2016 rule of $1.32/lb), but emphasized that higher percentages of mass 

reduction may result in higher costs and that these costs are likely to increase non-linearly 

with increasing mass reduction levels. In response to this stakeholder feedback and based on 

our own preliminary analysis of the potential for vehicle mass reduction in the 2020 and 2025 

timeframe, the agencies have begun updating our mass reduction cost model to reflect this 

progressively increasing level of cost. A simple non-linear cost model is introduced below 

that has been employed for purposes of this Technical Assessment Report, but EPA and 

NHTSA intend to rely on additional studies for the upcoming federal rulemaking that are 

expected to be complete before the NPRM and final rule. The collaborative team has taken 

several actions to inform the cost model, including meeting with vehicle manufacturers, 

DOE’s update of their 2007 study on feasibility and cost, and EPA funding a 3rd party cost 

assessment of the Lotus Report. 

The agencies developed the non-linear cost model for mass reduction for purposes of 

this Technical Assessment Report by averaging the 2012-2016 linear cost for mass reduction 

in 2025 with the cost estimate for the High Development Case in the Lotus Engineering study, 

and then drawing a parabolic curve between $0 for 0 percent mass reduction and that average 

dollar value at 32 percent mass reduction. While the agencies recognize that there have been 

a number of vehicle mass reductions studies conducted in the literature in the past 10 years27

 

M

 DOE Notice of Intent to Issue Funding Opportunity Announcement N.:DE-FOA-000239.

http://www.netl.doe.gov/business/solicitations/NOTICE%20OF%20INTENT.pdf 
Appendix B 

B-26 

28 29 30 31, a complete literature review is beyond the scope of the report, and thus the agencies 

believe that the mass reduction feasibility and cost study conducted by Lotus Engineering in 

2010 is the most comprehensive vehicle mass reduction study conducted to date. 

Lotus Engineering purchased a 2009 Toyota Venza (a crossover SUV, or CUV) and 

tore the vehicle down, analyzing every subsystem of the vehicle. The study split the mass 

reduction into two phases: ―low‖ and ―high‖ development, to represent different potential 

levels of mass reduction. For the low development case, the majority of the body in white 

(BIW) weight reduction was accomplished by converting mild steel to high strength steel. In 

addition, all vehicle components and subsystems were compared to the best-in-class vehicle 

mass leaders and substituted (and scaled) to the Venza, which allowed significantly more 

weight reduction and the use of mass decompounding. This approach provided an extremely 

cost effective manner of reducing weight and cost compared to other studies in the literature 

that attempted to evaluate reducing similar amounts of mass. In the high development case, 

Lotus considered much more material substitution in the BIW, from steel to aluminum, 

magnesium, plastic and other materials, and relied extensively on completely novel (and 

smart) design of all possible components to reduce mass in all vehicle systems. Table B4.3-1 

summarizes the cost results from this study: 

Table B4.3-1: Costs for Mass Reduction Based on the Lotus Engineering Study* 

Low Development

(19% mass reduction)

High Development

(32% mass reduction)

Cost per 

vehicle

Lower 

bound

-$400

-$1600

$600

-$600

Upper 

bound $800 $1800

Cost per pound

Lower 

bound

-$0.55

-$2.20

$0.50

-$0.50

Upper 

bound $1.10 $1.49

* Estimates assume a total variable (or piece) cost of the Toyota Venza to be $20,000

The agencies note that some limitations exist for the Lotus study. First, Lotus 

analyzed these considerable levels of mass reduction based on a single vehicle. The agencies 

acknowledge that most of the improvements described in the report can be applied across all 

vehicles to varying degrees, but due to the expense and time of the study, it is impractical for 

our current purposes to conduct similar studies across many different vehicles. Second, 

Lotus’ cost estimates were based on manufacturer (OEM) piece costs due to the initial scope 

of the study, and only partially included the manufacturer tooling and assembly plant costs. 

As mentioned earlier, follow-up studies are being planned to improve these cost estimates. 

Third, the designs created by Lotus for the low and high development cases have not been 

shown to meet FMVSS safety regulations and voluntary NCAP and IIHS guidelines, or to 

achieve vehicle functional performance similar to the baseline vehicle. Each of these issues is 

being addressed in the Phase 2 Lotus study, but was not addressed in time for this Technical 

Assessment Report. 
2017-2025 Technical Assessment 

B-27 

The Lotus study also shows that it is possible to take up to 19% of the mass out of the 

vehicle at no cost (cost savings in fact) by using less costly piece costs for many components 

based on their benchmarking analysis. The agencies agree that it may be possible to remove 

mass at a cost savings on many vehicles – there are a number of other studies that have 

similar conclusions. However, the agencies are concerned about assigning a negative cost 

value at the higher ranges of what some of the manufacturers shared was the maximum 

feasible (approximately 20% mass reduction) within the 2017-2025 timeframe. Therefore, the 

agencies are pursuing further cost studies to confirm all of the costs (including manufacturing 

and tooling) before using the Lotus results directly. The agencies do acknowledge that the 

Lotus study included a high degree of uncertainty in the cost estimates, and that some degree 

of mass reduction may be possible at a cost savings. 

The agencies note that most manufacturers stated in stakeholder meetings over the 

summer that they anticipate that future safety and emission regulatory requirements will 

require increases in vehicle mass and, in addition, they intend to implement voluntary safety 

improvements that will increase vehicle mass. Net mass reduction for the 2017-2025 

timeframe will thus actually be the mass reduction achieved through methods similar to those 

identified in studies discussed above, but offset by mass increases for safety and emission 

regulations and voluntary safety improvements. Manufacturers also frequently stated that 

they already have incorporated varying levels of mass reduction in current production 

vehicles. The agencies have not considered these baseline factors explicitly in estimating the 

cost for mass reduction that is being used for this assessment. 

Thus, to model how mass reduction costs could increase at a non-linear rate for 

purposes of this Technical Assessment Report, the agencies have relied on a parabolic shape 

for the cost curve – where the cost per pound increases as the square of the percentage mass 

reduction. To determine the magnitude of the curvature, the parabola was calibrated to go 

through a designated ―high value‖ at 32% mass reduction. To determine this high value, the 

agencies averaged the $1.20/lb (2008$ in the 2020MY) value developed using the 2012-2016 

rule methodology, with the Lotus high development cost figure of $0.50/lb at 32% mass 

reduction (as described above). This averaging represents two factors. First, that the agencies 

believe that the cost used in the 2012-2016 rule appropriately captures the longer timeframe 

and improved design optimization methods that are likely to lower costs in the 2017-2025 

timeframe; but on the other hand, that the agencies believe that a constant value, independent 

of the complexities involved with greater levels of mass reduction, is not realistic. And 

second, as described above, the agencies believe that the Lotus costs on their own are too low, 

due to the missing manufacturing and tooling costs. The averaging of the two costs offsets 

the missing Lotus costs. A variety of non-linear curves could have been employed, however, 

the 2nd order polynomial defines the simplest model, which seemed reasonable for the current 

analysis. The curve has the shape shown in Figure B4.3-1. 
Appendix B 

B-28 

Figure B4.3-1: Mass Reduction Cost Model in Dollars per Pound in Model Year 2020 

Compared to the Lotus Results and 2012-2016 Final Rule Cost. 

Accounting for the indirect cost markup (ICM) on the mass reduction cost model, the 

agencies believe that it is appropriate to assign higher markups for the higher levels of mass 

reduction due to their increased complexity and lead time required. Descriptions of these 

different levels of ICM are in Chapter 3. Table B4.3-2 shows this increasing ICM with mass 

reduction levels. 

Table B4.3-2: Indirect Cost Markup Factors for Increasing Levels of Mass Reduction 

Mass 

Reduction Complexity

ICM

Near 

Term

ICM

Long 

Term

3% Low 1.17 1.13

5% Low 1.17 1.13

10% Low 1.17 1.13

15% Low 1.17 1.13

20% Medium 1.31 1.19

25% Medium 1.31 1.19

30% High 1 1.51 1.32

Accounting for the ICMs, the model with and without markups is shown in Figure B4.3-2. 

$(2.50)

$(2.00)

$(1.50)

$(1.00)

$(0.50)

$-

$0.50 

$1.00 

$1.50 

0 % 5 % 10% 15% 20% 25% 30% 35% 40%

$ per pound Cost (w/o ICM)

% Mass Reduction

Lotus Results

2012-2016 Cost Model

2017-2025 Cost Model
2017-2025 Technical Assessment 

B-29 

Figure B4.3-2: Mass Reduction Cost Model in 2008 Dollars per Pound in Model Year 

2020 With and Without Indirect Cost Markups 

As mentioned earlier, the agencies continue to explore avenues of increasing the 

fidelity of the mass reduction cost model, and believe that there are studies that are currently 

or anticipated being conducted which will improve the fidelity of the points used to calibrate 

this model and which may be employed for the upcoming federal rulemaking. 

B5 Fuel Cell Vehicle Technology Cost, Effectiveness and Leadtime Assessment 

B5.1 Technology Summary 

The state of fuel cell vehicle (FCV) technology has seen significant progress towards 

the U.S. Department of Energy (DOE) 2015 performance targets over the last few years. Fuel 

cell stack durability has more than doubled since 2006 and high volume production system 

cost has been reduced by over 80% since 2002 (additional details are provided below). 

Progress is still required in the areas of fuel cell costs, durability, and on-board hydrogen 

storage. However, the technology has matured sufficiently for commercialization, and 

production launch is feasible in the 2015-2017 time-frame. First generation vehicles will 

likely require financial incentives to initiate the market (as is currently planned for battery 

technologies). 

B5.2 Fuel Cell Costs 

Based on the most recent fuel cell system cost analysis by Directed Technologies, Inc 

(DTI32), contracted by DOE, today’s fuel cell technology when produced at high volumes 

would have a cost of $51/kW (system net power). Additionally, projected 2015 technology at 

high volume production would cost $39/kW. For a 100kW system in a large car (vehicle type 

5), this would equate to $3,945 (not including hydrogen storage). The analysis for this report 

$0.00

$0.20

$0.40

$0.60

$0.80

$1.00

$1.20

0% 5% 10% 15% 20% 25% 30%

$/pound

Mass Reduction Percentage

Direct Mfr Cost

Markedup Cost
Appendix B 

B-30 

bundled the fuel cell system costs with the electric drive component costs consistent with how 

the EV and PHEV technology packages were developed. For FCVs, this analysis assumed a 

system sized for the large car platform (vehicle type 5), and included the HEV battery pack 

and hydrogen storage costs in addition to the system noted above. 

The system costs noted above are the fully-learned, high volume production costs 

from DTI. However, these production volumes are not assumed to be achieved by 2025 for 

this analysis. FCV production levels of ~85,000 per year in the U.S. were assumed, 

representing approximately 0.5% of the U.S. LDV market in 2025. This is discussed further 

in Section B4.3.4. At these lower production levels, the incremental fuel cell system direct 

manufacturing cost is closer to +$4,800. 

As part of this analysis, fuel cell vehicle production costs were developed by relying 

on the 2015 technology costs from DTI along with the non-fuel cell electric drive component 

costs from the EPA OMEGA model. Figure B5.2-1 below shows the simulated production 

costs for a 100kW fuel cell system (average system size for larger vehicle platforms in this 

analysis). Note this is not the full FCV production cost which would include the full electric 

drive bill of material. Also not shown is the retail price markup (ICM); FCVs are assumed to 

have the same ICM as the EV and PHEV vehicle types, using the high complexity ICM 

values noted earlier in Appendix B. 

Figure B5.2-1: FC Production Cost Curve for a 100kW system (not including H2 

storage) 

(Sources: DTI (cost curve), extrapolation to 100kW) 

Figure B5.2-2 shows the summary breakdown of vehicle costs at the high volume 

production level. The fuel cell system cost at this level is based on the DTI $39/kW high 

volume data point. Compared to the 2010 DTI system estimate, this 2015 production cost 

$-

$5,000

$10,000

$15,000

$20,000

0 100,000 200,000 300,000 400,000 500,000

Annual Production Volume

Fuel Cell System Cost (100kW system, 2008 $)

National sales rate 

in 2025 assumed
2017-2025 Technical Assessment 

B-31 

assumes system improvements, including the elimination of external humidification 

components, elimination of an air expander, and slightly higher membrane operating 

temperatures that allow the reductions in the radiator and cooling loop size. For fuel cell 

stack costs, DTI assumes platinum loadings of 0.15 mg/cm2. In addition to the fuel cell 

system, the battery pack modeled was the lithium-ion battery assumed for HEVs in Table 

B4.2-1. Balance of EV drive components include drive motors, controllers, DC/DC 

converters, electric AC and heating, and a few other components. Finally, as noted above, the 

hydrogen storage system cost was assumed to be $10/kWh, notably higher than the DOE 2015 

target given the lower production volumes. 

Figure B5.2-2: Detailed fuel cell system costs at high volume production 

(Source: DTI, CARB) 

Table B5.2-1 shows the resulting direct manufacturing costs for the 2020 and 2025 

model years, highlighting the higher costs compared to the fully learned production levels at 

the far right of Figure B5.2-1.

Table B5.2-1: Fuel cell direct manufacturing costs at assumed production volumes 

1

2

3

4

5

Air Loop 

$700

Water & 

Thermal Mngt

$500

Fuel Loop 

$100

FC Stack 

$2,133

Controller & 

Sensors 

$512

1

2

3

4

5

Air Loop 

$700

Water & 

Thermal Mngt

$500

Fuel Loop 

$100

FC Stack 

$2,133

Controller & 

Sensors 

$512

2020MY 2025MY

U.S. FCV Sales 20,000 85,000

Fuel cell system cost

(100 kW)

$ 5,900 $ 4,800

Hydrogen storage cost

(4 kg @ $10/kWh)

$1,320 $1,320
Appendix B 

B-32 

Finally, as a reference, DOE’s analysis of various hydrogen storage systems was 

reviewed. The production costs for various on-board hydrogen storage technology 

alternatives were analyzed by TIAX under contract to DOE33. This analysis assumed high 

pressure gaseous storage remained the technology choice in 2025, although the cryocompressed alternative is receiving increased attention by major OEMs. The current DOE 

2010 target is $4/kWh and the 2015 target is $2/kWh, although DOE is planning to revise 

these targets soon. For the 2025 FCV simulated in this analysis, a storage cost of $10/kWh 

was assumed given production levels will not reach the fully mature point. 

B5.3 Performance Status 

Automakers are nearing DOE 2015 performance targets and continue to push the 

technology toward commercial readiness, as documented in the DOE 2009 Report to 

Congress34. A few of the key accomplishments are listed below and further information can 

be found at DOE’s Hydrogen Program Accomplishments webpage35.

Significantly reduced the cost of automotive fuel cells (from $275/kW in 2002 to 

$51/kW in 2010 (DTI), based on projections of high-volume manufacturing costs) 

Doubled the durability of fuel cell systems in vehicles operating under real-world 

conditions (data in 2006 showed 950-hour durability—today, this number is 2500 

hours, equivalent to approximately 75,000 miles of driving) 

Reduced the cost of producing hydrogen from both renewable resources and natural 

gas (hydrogen can now be produced by distributed reforming of natural gas at a 

projected high-volume cost of $3.00/gallon gasoline equivalent; this does not take into 

account FCV efficiency gains over an ICE which would improve these operating costs 

further) 

Independently validated a real-world driving range of 450 miles for an FCV from one 

of the major OEMs. 

The table below summarizes the cost, durability, and efficiency targets along with the 

status of today’s technology as assessed by DOE’s Technology Validation Program.36

Table B5.3-1: Current Status and U.S. DOE Targets for Automotive Fuel Cells 

Fuel cell system volume and weight have been largely reduced and are expected to 

achieve the targets, allowing for marketable vehicle integration. For example, the Honda FCX 

2009

(Current 

Status)

2010

(Cost 

Update)

2010

Target

2015

Target

System Efficiency 53-59% 60% 60%

System Cost $61 /kW $51 /kW 37 $45 /kW $30 /kW

Fuel Cell System 

Durability

2,500 hours

(~75,000 mi)

2,000 hours

(~60,000 mi)

5,000 hours

(~150,000 mi)

Vehicle Range 254 miles 38 250 miles 300 miles

H2 Storage Costs $20 /kWh 39 $4 /kWh $2 /kWh
2017-2025 Technical Assessment 

B-33 

Clarity’s fuel cell stack is 1/5 the weight and 1/4 the volume compared to the previous FCV 

model40. The weight and volume progress are a result of improvements in fuel cell materials 

(stamped metal flow plates, aromatic membrane structure, reductions in catalyst loading) and 

fuel cell simplification (part-count reduction, improved manufacturing). A detailed summary 

of the performance of the Generation 2 FCVs being evaluated in the DOE Technology 

Validation Program can be found in the NREL presentation to the 2010 DOE Merit Review41

.

FCVs have achieved the DOE 2015 efficiency targets already, which translates into 

large energy and greenhouse gas reductions compared to conventional vehicles. Although the 

full well-to-wheel (WTW) GHG reductions depend on the fuel source, hydrogen produced 

from natural gas and used in an FCV results in WTW GHG reductions of 50% compared to a 

projected internal combustion engine vehicle, and 20% compared to a projected hybrid 

vehicle42. Given that the vehicle powertrain is a zero emission technology, all emissions are 

generated from the fuel production and delivery stages. 

B5.4 Hydrogen Storage 

As noted above, the majority of FCV technology requirements necessary for a 

marketable vehicle have been addressed through continued R&D and demonstration. This 

includes rapid start-up, cold-start operation, stack power density, balance-of-plant (BOP) 

operation, and efficiency. On-board hydrogen storage is one of the remaining challenges that 

will require further development. This will not prevent the commercial launch of FCVs, 

however, as adequate storage systems are available for use in early commercial vehicles. The 

storage technology chosen by the majority of OEMs for existing FCVs is high pressure (700 

bar or 10,000 psi) gaseous storage. Although volumetric density, cost, and station dispensing 

complexity (a need for pre-cooling) are not ideal, the technology is ready today. 

Technologies under consideration by OEMs and energy companies for next generation 

vehicles include intermediate pressure gaseous storage (between 350 and 700 bar where precooling won’t be required) and cryo-compressed hydrogen storage. The latter has the promise 

of higher volumetric density, lower cost, and substantially reduced fuel boil-off (in engine-off 

mode) compared to liquid storage43

. 

Additional FCV and hydrogen storage information can be found from the following 

DOE resources. 

2010 U.S. DOE Merit Review Proceedings, June 2010. 

http://www.hydrogen.energy.gov/annual_review10_proceedings.html 

2009 U.S. DOE Hydrogen Program Annual Progress Report, November 2009. 

http://www.hydrogen.energy.gov/annual_progress09.html

B5.5 Commercialization Status 

Production announcements have been made by at least three major OEMs for a 2015 

launch. Production volumes will depend in part on the hydrogen infrastructure rollout in 

strategic locations where early customers are expected. In the U.S., this is likely to be in 
Appendix B 

B-34 

Southern California and New York where infrastructure is emerging. Based on two 

independent confidential surveys of OEMs and their FCV plans (conducted by the CaFCP44

and CARB/CEC), up to 50,000 FCVs could be deployed in California by 2018 (cumulative 

on-road). 

Hydrogen infrastructure continues to be a large challenge for FCVs in preparation for 

vehicle commercialization in 2015. Addressing this challenge requires stakeholder 

coordination and sustained commitments from both the public and private sectors. However, 

this activity is progressing in California, with actions coordinated by the CaFCP, CARB and 

CEC. The state is providing large cost-share incentives for hydrogen stations (led by CEC), 

and strategic planning is relying on concepts outlined in the CaFCP’s 2009 Action Plan45 and 

2010 Progress and Next Steps, as well as the UC Davis Roadmap.46

For the purposes of identifying production costs in this analysis, annual production 

volumes were estimated. Broadly based on California’s Zero Emission Vehicle Regulation as 

well as hydrogen infrastructure advancements in California and a few other states, it was 

assumed FCVs would comprise 0.5% of the U.S. LDV market in 2025. With a total assumed 

LDV market of 16.5 million vehicles, this equates to annual sales volumes of 85,000 

nationally. Although these levels are lower than previous FCV scenarios by the DOE 

(ORNL47) and the National Academies (NAS48), they represent full commercial scale 

production volumes and should result in the needed FCV cost reductions such that market 

share could grow significantly beyond 2025. 
2017-2025 Technical Assessment 

B-35 

Appendix B References 

1

 Memorandum to Docket EPA-HQ-OAR-2010-0799 from Todd Sherwood dated September 16, 2010. 

2

 U.S. Environmental Protection Agency, ―Light-Duty Technology Cost Analysis Pilot Study,‖ Contract No. EPC-07-069, Work Assignment 1-3, December 2009, EPA-420-R-09-020, Docket EPA-HQ-OAR-2009-0472- 

11282; peer review report dated November 6, 2009, is at EPA-HQ-OAR-2009-0472-11285; ―Light-duty 

Technology Cost Analysis – Report on Additional Case Studies,‖ EPA-HQ-OAR-2009-0472-11604 

3

 EPA-420-R-10-901

4

 U.S. Environmental Protection Agency, ―Light-Duty Technology Cost Analysis Pilot Study,‖ Contract No. EPC-07-069, Work Assignment 1-3, December 2009, EPA-420-R-09-020, Docket EPA-HQ-OAR-2009-0472- 

11282; peer review report dated November 6, 2009, is at EPA-HQ-OAR-2009-0472-11285; ―Light-duty 

Technology Cost Analysis – Report on Additional Case Studies,‖ EPA-HQ-OAR-2009-0472-11604. 

5

 Turner, J.W.G., Pearson, R.J., Curtis, R. Holland, B. ―Sabre: a cost effective engine technology combination 

for high efficiency, high performance and low CO2 emissions,‖ Low Carbon Vehicles 2009: Institution of 

Mechanical Engineers conference proceedings, May 2009. 

6

 Lumsden, G. OudeNijeweme, D., Fraser, N., Blaxill, H. ―Development of a Turbocharged Direct Injection 

Downsizing Demonstrator Engine,‖ SAE Technical Paper Series, No. 2009-01-1503.

7

 Yi., J., Wooldridge, S., Coulson, G., Hilditch, J., Iyer, C., Moilanen, P., Papaioannou, G., Reiche, D., Shelby, 

M. VanDerWege, B., Wearver, C., Xu, Z., Davis, D., Hinds, B., Schamel, A. ―Development and Optimization of 

the Ford 3.5L V6 EcoBoost Combustion System,‖ SAE Technical Paper Series, No. 2009-01-1494.

8

 Cruff, L., Kaiser, M., Krause, S., Harris, R., Krueger, U., Williams, M. ―EBDI - Application of a Fully Flexible 

High BMEP Downsized Spark Ignited Engine,‖ SAE Technical Paper Series, No. 2010-01-0587.

9

 Taylor, J., Fraser, N., Wieske, P. ―Water Cooled Exhaust Manifold and Full Load EGR Technology Applied to 

a Downsized Direct Injection Spark Ignition Engine,‖ SAE Technical Paper Series, No. 2010-01-0356. 

10 Kaiser, M., Krueger, U., Harris, R., Cruff, L. ―Doing More with Less - The Fuel Economy Benefits of Cooled 

EGR on a Direct Injected Spark Ignited Boosted Engine,‖ SAE Technical Paper Series, No. 2010-01-0589. 

11 Kapus, P.E., Fraidl, G.K., Prevedel, K., Fuerhapter, A. ―GDI Turbo – The Next Steps,‖ JSAE Technical Paper 

No. 20075355, 2007. 

12 General Motors, news release, ―From Hybrids to Six-Speeds, Direct Injection And More, GM’s 2008 Global 

Powertrain Lineup Provides More Miles with Less Fuel‖ (released Mar. 6, 2007). Available at 

http://www.gm.com/experience/fuel_economy/news/2007/adv_engines/2008-powertrain-lineup-082707.jsp (last 

accessed Sept. 18, 2008). 

13 ―EPA Staff Technical Report: Cost and Effectiveness Estimates of Technologies Used to Reduce Light-duty 

Vehicle Carbon Dioxide Emissions‖ Environmental Protection Agency, EPA420-R-08-008, March 2008, at page 

17, Docket EPA-HQ-OAR-2009-0472-0132. 

14 Joint Technical Support Document: Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission 

Standards and Corporate Average Fuel Economy Standardsfor EPA and NHTSA 2012-2016 GHG and CAFE 

Rule. EPA-420-R-10-901, April, 2010. 

15 Olszewski, M., 2008. Evaluation of the 2007 Toyota Camry Hybrid Synergy Drive System. Oak Ridge 

National Laboratory. ORNL/TM-2007/190. Oak Ridge, Tenesssee. April. 
Appendix B 

B-36 

16 Nelson, P.A., Santinit, D.J., Barnes, J. ―Factors Determining the Manufacturing Costs of Lithium-Ion Batteries 

for PHEVs,‖ 24th World Battery, Hybrid and Fuel Cell Electric Vehicle Symposium and Exposition EVS-24, 

Stavenger, Norway, May 13-16, 2009 (www.evs24.org). 

17 Santini, D.J., Gallagher, K.G., and Nelson, P.A. ―Modeling of Manufacturing Costs of Lithium-Ion Batteries 

for HEVs, PHEVs, and EVs,‖ Paper to be presented at the 25th World Battery, Hybrid and Fuel Cell Electric 

Vehicle Symposium and Exposition, EVS-25, Shenzhen, China, November 5-9, 2010 (www.evs25.org). 

Advance draft provided by D.J. Santini, Argonne National Laboratory, August 24, 2010. 

18 ―Hyundai ups tech ante with Sonata Hybrid,‖ Automotive News, August 2, 2010. 

19 ―Chevrolet Stands Behind Volt With Standard Eight-Year, 100,000-Mile Battery Warranty,‖ GM Press release 

(http://media.gm.com/content/media/us/en/news/news_detail.brand_gm.html/content/Pages/news/us/en/2010/Jul

y/0714_volt_battery) 

20 ―Nissan’s new 2012 hybrid system aims for 1.8-L efficiency with a 3.5-L V6,‖ SAE Automotive Engineering 

Online, February 15, 2010. 

21 ―Lithium-ion Battery,‖ Nissan Technological Development Activities (http://www.nissanglobal.com/EN/TECHNOLOGY/INTRODUCTION/DETAILS/LI-ION-EV/), 2009. 

22 Lotus Engineering, Inc. ―An Assessment of Mass Reduction Opportunities for a 2017 – 2020 Model Year 

Vehicle Program,‖ Published by the The International Council on Clean Transportation and available on the 

Internet at http://www.theicct.org/2010/03/lightweight-future/, March 30, 2010. 

23 Joint Technical Support Document: Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission 

Standards and Corporate Average Fuel Economy Standardsfor EPA and NHTSA 2012-2016 GHG and CAFE 

Rule. EPA-420-R-10-901, April, 2010. 

24 Effectiveness and Impact of Corporate Fuel Economy Standards, NAS, 2002. 

25 Basic Analysis of the Cost and Long-Term Impact of the Energy Independence and Security Act Fuel 

Economy Standard, Sierra Research, 2008. 

26 The Impact of Mass Decompounding on Assessing the Value of Vehicle Lightweighting, MIT 2008. 

27 Assessment of Fuel Economy Technologies for Light Duty Vehicles, NAS, 2010. 

28 Analysis of Light Duty Vehicle Weight Reduction Potential, Energy and Environmental Analysis Inc, 

prepared for DOE, July, 2007.

29 Cost-Effectiveness Of a 25% Body and Chassis Weight-Reduction Goal In Light-Duty Vehicles, Das, Sujit, 

prepared for DOE, 2008/ 

30 Cost-Effectiveness Of a 40% Body and Chassis Weight-Reduction Goal In Light-Duty Vehicles, Das, Sujit, 

prepared for DOE, 2009. 

31 Cost-Effectiveness Of a 50% Body and Chassis Weight-Reduction Goal In Light-Duty Vehicles, Das, Sujit, 

prepared for DOE, 2010. 

32 Directed Technologies Inc (DTI), ―Mass-Production Cost Estimation for Automotive Fuel Cell Systems,‖ 

2010 U.S. DOE Merit Review, FC018, June 7-11, 2010. 

http://www.hydrogen.energy.gov/pdfs/review10/fc018_james_2010_o_web.pdf
2017-2025 Technical Assessment 

B-37 

33 TIAX LLC, ―Analysis of Hydrogen Storage Materials and On-Board Systems,‖ 2010 U.S. DOE Merit 

Review, ST002, June 7-11, 2010. 

http://www.hydrogen.energy.gov/pdfs/review10/st002_lasher_2010_o_web.pdf

34 ―Hydrogen and Fuel Cell Activities, Progress, and Plans,‖ U.S. DOE Report to Congress, January 2009. 

http://www.hydrogen.energy.gov/program_records.html

35 http://www1.eere.energy.gov/hydrogenandfuelcells/accomplishments.html 

36 Refer to Table 3.1 in the U.S. DOE 2009 Report to Congress and a year-end summary by Dr. Sunita Satyapal, 

http://www1.eere.energy.gov/hydrogenandfuelcells/pdfs/ cng_h2_workshop_1_satyapal.pdf 

37 DTI. Projected 2015 system cost = $39/kW. System cost does not include H2 storage assembly or electric 

drive components 

38 Corresponds to vehicle fuel economy observations of 43-58 mi/kg-H2 as noted by the National Renewable 

Energy Laboratory (NREL) in ―Controlled Hydrogen Fleet and Infrastructure Analysis,‖ 2010 U.S. DOE Merit 

Review, TV001, June 10, 2010. www.hydrogen.energy.gov/pdfs/review10/tv001_wipke_2010_o_web.pdf

39 TIAX LLC, ―Analysis of Hydrogen Storage Materials and On-Board Systems,‖ 2010 U.S. DOE Merit 

Review, ST002, June 7-11, 2010. 

http://www.hydrogen.energy.gov/pdfs/review10/st002_lasher_2010_o_web.pdf . (Based on 700 bar gaseous 

pressure system at 5.6 kg H2 storage) 

40 Knight, Ben. Honda Motor Company. ―Fuel Cell Vehicle Technology Performance and Steps Ahead 

Presentation‖. CARB ZEV Symposium, September 21, 2009. 

http://www.arb.ca.gov/msprog/zevprog/2009symposium/2009program.htm

41 NREL, ―Controlled Hydrogen Fleet and Infrastructure Analysis,‖ 2010 US DOE Merit Review, TV001, June 

10, 2010 

42 ―Well-to-Wheels Greenhouse Gas Emissions and Petroleum Use,‖ U.S. DOE Hydrogen Program Record # 

9002, March 25, 2009. 

43 Argonne National Laboratory, ―System Level Analysis of Hydrogen Storage Options,‖ 2010 U.S. DOE Merit 

Review, ST001, June 7-11, 2010. 

44 California Fuel Cell Partnership (CaFCP), ―Hydrogen Fuel Cell Vehicle and Station Deployment Plan: A 

Strategy for Meeting the Challenge Ahead (Progress and Next Steps),‖ April 2010. 

http://www.fuelcellpartnership.org/resources/print-materials

45 CaFCP, ―Hydrogen Fuel Cell Vehicle and Station Deployment Plan: A Strategy for Meeting the Challenge 

Ahead (Action Plan),‖ February 2009. http://www.fuelcellpartnership.org/resources/print-materials

46 University of California, Davis, ―Roadmap for Hydrogen and Fuel Cell Vehicles in California: A Transition 

Strategy Through 2017,‖ a public-private collaborative report following a series of workshops, December 2009. 

47 Oak Ridge National Laboratory, ―Transition to Hydrogen Fuel Cell Vehicles & the Potential Hydrogen Energy 

Infrastructure Requirement,‖ ORNL/TM-2008/30, March 2008. 

48 National Academies of Science, ―Transitions to Alternative Transportation Technologies: A Focus on 

Hydrogen,‖ Committee on Assessment of Resource Needs for Fuel Cell and Hydrogen Technologies, 2009. 
2017-2025 Technical Assessment 

C-1 

Appendix C - Reserved 
2017-2025 Technical Assessment 

D-1 

D1 Appendix D: Air Conditioning 

D1.1 Overview 

Over 95% of the new cars and light trucks in the United States are equipped with 

mobile air conditioning (MAC or A/C) systems. In the 1970s and 1980s, A/C systems were 

an optional (luxury) feature, but these systems are now standard on almost all new vehicle 

models. The A/C system is a unique and distinct technology on the automobile. It is different 

from the other technologies described in Chapter 3 of the joint Technical Support Document 

(TSD) to the recent MY 2012-2016 Final Rule in several ways. First, most of the 

technologies described in the joint TSD directly affect the efficiency of the engine, 

transmission, and vehicle systems. As such, these systems are almost always active while the 

vehicle is moving down the road or being tested on a dynamometer for the fuel economy and 

emissions test drive cycles. A/C on the other hand, is a parasitic load on the engine that only 

burdens the engine when the vehicle occupants demand it. Since it is not tested as a normal 

part of the fuel economy and emissions test drive cycles for compliance purposes, it is 

referred to as an “off-cycle” effect. There are many other off-cycle loads that can be switched 

on by the occupant that affect the engine; these include lights, wipers, stereo systems, 

electrical defroster/defogger, heated seats, power windows, etc. However, these electrical 

loads individually amount to a very small effect on the engine (although together they can be 

significant). The A/C system (by itself) adds a significantly higher load on the engine as 

described later in this chapter. Secondly, present A/C systems are capable of leaking a 

powerful greenhouse gas (GHG) directly into the air - even when the vehicle is not in 

operation. No other vehicle system has associated GHG leakage. Because of these factors, a 

distinct approach to control of MAC systems is justified, and a separate technical discussion is 

also warranted. 

D1.2 Leakage 

D1.2.1 Overview 

This section describes a preliminary analysis of leakage emission reductions in the 

2025 timeframe. It is expected that this analysis will be reevaluated during the rulemaking 

process. The technological basis for the expected leakage reductions is discussed in detail in 

the EPA‟s model year (MY) 2012-2016 Light Duty Greenhouse Gas Final Rule (2016 FRM) 

RIA Chapter 2, and is summarized here. 

Mobile air conditioner (MAC) systems leak a powerful greenhouse gas directly into 

the air - even when the vehicle is not in operation. Because MAC emissions are not measured 

during certification testing for the GHG program, the 2016 final rule offered a compliance 

credit to encourage manufacturers to reduce the leakage from MAC systems. The analysis 

discussed herein serves as an update to that analysis. As in the 2016 FRM, a 2008 vehicle is 

considered an unimproved system, and is the basis of the discussion shown here. 

The hydrofluorocarbon (HFC) refrigerant compound used in most model year 2008 

vehicles is R134a (also known as 1,1,1,2-Tetrafluoroethane, or HFC-134a). Based on the 
Appendix D 

D-2 

higher global warming potential (GWP) of HFC-134a, a small leakage of this refrigerant has a 

greater global warming impact than a similar amount of emissions of some other mobile 

source GHGs. R134a has a global warming potential of 1430,A which means that 1 gram of 

R134a has a warming potential equivalent to 1,430 grams of CO2 (which has a GWP of 1).1 

The high pressure of an MAC system increases its propensity for leaks. In order for 

the A/C system to take advantage of the refrigerant‟s thermodynamic properties and to 

exchange heat properly, the system must be kept at high pressures even when not in operation. 

Typical static pressures can range from 50-80 psi depending on the temperature, and during 

operation, these pressures can get to several hundred psi. At these pressures leakage can 

occur through a variety of mechanisms. The refrigerant can leak slowly through seals, 

gaskets, and even small failures in the containment of the refrigerant. The rate of leakage 

may also increase over the course of normal wear and tear on the system. Leakage may also 

increase more quickly through rapid component deterioration such as during vehicle 

accidents, maintenance or end-of-life vehicle scrappage (especially when refrigerant capture 

and recycling programs are less efficient). Small amounts of leakage can also occur 

continuously even in extremely “leak-tight” systems by permeating through hose membranes. 

This last mechanism is not dissimilar to fuel permeation through porous fuel lines. 

Manufacturers may be able to reduce these leakage emissions through the implementation of 

technologies such as leak-tight, non-porous, durable components. The global warming impact 

of leakage emissions also can be addressed by using alternative refrigerants with lower global 

warming potential. 

 As MACs leak even when not being driven, it is most appropriate to determine their 

leakage based on a g/year or g/lifetime. However, for purposes of an estimation of 

reductions, it is possible to divide lifetime leakage losses by lifetime vehicle miles traveled 

(VMT) in order to determine the appropriate average g/mile leakage rate. 

D1.2.2 Description of Vintaging Model Inputs and Data Sources 

New data concerning HFC leakage has become available since the 2016 final rule 

analysis was completed. Most significantly, based on new data from the EPA Office of 

Atmospheric Programs (OAP), EPA has decreased the average charge size and leakage 

assumed in its analysis as compared to the 2016 final rule analysis. The inputs used to derive 

the HFC reductions are drawn from the OAP Vintaging model and are shown below in Table 

D1.2-1. These values are discussed in the following paragraphs, and are drawn from internal 

EPA documentation of the Vintaging model. 

Table D1.2-1: Inputs for HFC Potential Reduction Calculation from Vintaging Model 

 

A

 The global warming potentials (GWP) used in this analysis are consistent with Intergovernmental Panel on 

Climate Change (IPCC) Fourth Assessment Report (AR4). At this time, the IPCC Second Assessment Report 

(SAR) global warming potential values have been agreed upon as the official U.S. framework for addressing 

climate change. The IPCC SAR GWP values are used in the official U.S. greenhouse gas inventory submission 

to the United Nations climate change framework. 
2017-2025 Technical Assessment 

D-3 

Car Truck

2008 MY Vehicle MAC Charge (g HFC) 550 780

Lifetime of a MAC system (years) 12 12

Fraction of Vehicles w/AC 99% 99%

Recurring Annual Loss Rate (Service+Leaks) 18% 18%

End of Life Loss 43% 43%

D1.2.2.1 Charge Size 

The Vintaging model contains weighted average refrigerant charge sizes based on 

motor vehicle sales data and charge size data, by make, model, and year. 2008 Sales data is 

from Ward's US Light Vehicle Sales: 2005 through 2008 Calendar Years.

2

 Charge size data 

is from the Mobile Air Conditioning Society (MACS) Worldwide‟s A/C & Cooling System 

Specifications: 1996-2007.

3

 No assumptions are made regarding continued reductions in 

charge size beyond 2008. 

D1.2.2.2 AC System Lifetime 

The Vintaging Model assumes that all light duty passenger vehicle AC systems (in the 

U.S.) last exactly 12 years. This is in agreement with the IPCC report IPCC/TEAP 2005 

Safeguarding the Ozone Layer and the Global Climate System – Issues Related to 

Hydrofluorocarbons and Perfluorocarbons, which indicates lifetimes (worldwide) of 9 to 12 

years. 

D1.2.2.3 Fraction of Vehicles with AC 

Not all vehicles are sold with AC; Ward‟s vehicle sales data are adjusted based on the 

percentage of vehicles with AC, which increases over time before reaching a maximum of 

99% in 2002 (light trucks) and 2003 (cars). The Vintaging Model assumes that 1% of 

vehicles continue to be sold without air conditioning beyond 2003. 

D1.2.2.4 Emission Rates 

The Vintaging Model assumes that losses occur from three events: leak, service, and 

disposal. Although vehicle ACs are serviced during discrete events and not usually every 

year, emissions from those events are averaged over the lifetime of the AC system. Leak and 

service emissions are considered “annual losses” and are applied every year; disposal is 

considered an “end of life loss” and is applied only once for each vintage of vehicles. 

Emission rates in the Vintaging model do improve over time, with the 2008 vehicle emission 

rates attributable to vehicles manufactured from 1998 to present. 

Of note, the Vintaging model assumes that charge loss is replaced every year; ie, a 

vehicle with a charge of 100 grams would lose a constant rate of 18 grams/year. While other 

emissions, such as fugitive emissions at a production facility, leaks from cylinders in storage, 

etc., are not explicitly modeled, such emissions are accounted for within the annual loss rate. 
Appendix D 

D-4 

D1.2.3 Calculation of the Lifetime HFC loss per vehicle 

Several modifications were made to the Vintaging model outputs for the analysis of 

the potential HFC reductions. Most importantly, the charge size of the average car was 

increased as a result of the reclassification of a number of two wheel drive SUVs below 6,000 

pounds as cars starting in MY 2011, as discussed in Appendix A. It was assumed that 20% of 

the new cars were classic trucks. As a result, the charge sizes were weighted together, with a 

weighting of 80% car and 20% truck in order to calculate the car charge under the revised MY 

2011 and later definition. The charge size of trucks was not adjusted. We also assume that 

only vehicles which have AC systems are eligible for the AC credit, increasing the 99% value 

to 100% 

Using this data, the total average lifetime losses from an AC system can be calculated 

using Equation D1.2-1: 

Total Lifetime HFC Emissions = (Average Charge Size) * (Average Annual Loss) * (Average Lifetime) 

+ (End of Life Loss) 

Equation D1.2-1: Calculation of Total Lifetime HFC Loss 

Applying this equation results in an average per-vehicle HFC loss of approximately 

2.59 charges (18% loss of initial charge * 12 years + 43% loss at end of life.). This results in 

total lifetime losses of 1,543 g for cars and 2,020 grams for trucks. 

D1.2.4 Calculation of the HFC Credit Maximum 

The maximum HFC credit is set so that the reduction in HFC emissions can be 

replaced by an equivalent amount of tailpipe CO2 emissions. As CO2 emissions are regulated 

on a gram/mile basis, the HFC emissions must be converted into an equivalent metric using 

Equation D1.2-2. Based on the MY 2012-2016 final rule, the total lifetime VMT of cars and 

trucks is estimated at 195,264 and 225,865 respectively. These values are consistent with the 

MY 2012-2016 final rule, consistent with the early years of the time frame, and are slightly 

lower than the MY 2025 VMT estimated in this technical report. 

CO2eq g / mile = (Total lifetime HFC emissions) / (Total Lifetime VMT) * (GWP) 

Equation D1.2-2: Conversion of Lifetime HFC Emissions into CO2eq emissions 

 Finally, because a known 20% shortfall (the “on-road” gap) exists between 

certification test CO2 emissions and actual on-road emissions, the CO2 equivalent emissions 

calculated above were multiplied by 0.8 in order to appropriately offset the reduction in real 

emissions. 

The maximum possible credit, calculated through this methodology, is shown below. 

Assuming that alternative refrigerant with a GWP of zero is used, the maximum potential 

credit would be based on removing the full lifetime emissions. As discussed in the 2016 final 

rule, if conventional HFC 134a were used in an AC system, the maximum potential leakage 

reduction is 50% of the annual emission leakage. No improvements would be expected to end 
2017-2025 Technical Assessment 

D-5 

of life emissions, so the total possible credit is approximately 45% of the maximum credit 

with alternative refrigerant. 

Table D1.2-2: Maximum Credit (g/mile CO2 eq) 

Car Truck Fleet 

(MY 2025)

Maximum Credit (Alternative Refrigerant w/ 0 

GWP)

9.2 10.4 9.6

Maximum Credit (HFC 134a) 3.8 4.3 3.9

As the charges for the cars and light trucks differ, the mix of cars and trucks is significant to this analysis. 

MY 2025 is projected to have 67.5% cars and 2 wheel drive SUVs below 6,000 lbs. 

D1.2.5 System Leakage Standards 

In the timeframe considered in this Technical Assessment Report, EPA is considering 

a number of options to reduce A/C leakage emissions, including the setting of a refrigerant 

leakage standard for mobile A/C systems. The purpose of a leakage standard, as opposed to 

credits, is to assure that high-quality, low-leakage components are used in each air 

conditioning system design. EPA is considering a percent leakage per year standard curve, 

which is scaled to the refrigerant capacity of the system (i.e. small-capacity systems would 

have a larger allowable leakage standard than those with larger capacity). Since refrigerant 

leakage past the compressor shaft seal is the dominant source of leakage in belt-driven air 

conditioning systems, a single “percent refrigerant leakage per year” standard may not fairly 

addresses the range of system refrigerant capacities likely to be used in passenger cars, light 

duty trucks, and other vehicles. Since systems with less refrigerant may have a larger 

percentage of their annual leakage from the compressor shaft seal than systems with more 

refrigerant capacity, their relative percent refrigerant leakage per year could be higher, and a 

more extensive application of leakage reducing technologies could be needed to meet a 

standard. 

Manufacturers can choose to reduce A/C leakage emissions in two ways. First, they 

can utilize leak-tight components. Second, manufacturers can largely eliminate the global 

warming impact of leakage emissions by adopting systems that use an alternative, low-GWP 

refrigerant. EPA believes that reducing A/C system leakage is both highly cost-effective and 

technologically feasible. The availability of low leakage components is being driven by the 

air conditioning program in the light duty GHG rule which apply to 2012 model year and later 

vehicles. The cooperative industry and government Improved Mobile Air Conditioning 

(IMAC) program has demonstrated that new-vehicle leakage emissions can be reduced by 

50% by reducing the number and improving the quality of the components, fittings, seals, and 

hoses of the A/C system. All of these technologies are already in commercial use and exist 

on some of today‟s systems. 

In the MY 2012-2016 rule, EPA required that manufacturers demonstrate 

improvements in their A/C system designs and components through a design-based method. 

Thismethod for calculating A/C Leakage is based closely on an industry-consensus leakage 

scoring method, described below. This leakage scoring method is correlated to 

experimentally-measured leakage rates from a number of vehicles using the different 
Appendix D 

D-6 

available A/C components. Under this approach, manufacturers would choose from a menu of 

A/C equipment and components used in their vehicles in order to establish leakage scores, 

which would characterize their A/C system leakage performance and calculate the percent 

leakage per year as this score divided by the system refrigerant capacity. 

Consistent with the Light Duty Vehicle Greenhouse Gas Emissions rulemaking, EPA 

is considering that a manufacturer would compare the components of its A/C system with a 

set of leakage-reduction technologies and actions that is based closely on that being developed 

through IMAC and the Society of Automotive Engineers (as SAE Surface Vehicle Standard 

J2727, August 2008 version). See generally 75 FR at 25426. The J2727 approach was 

developed from laboratory testing of a variety of A/C related components, and EPA believes 

that the J2727 leakage scoring system generally represents a reasonable correlation with 

average real-world leakage in new vehicles. Like the IMAC approach, our proposed approach 

would associate each component with a specific leakage rate in grams per year identical to the 

values in J2727 and then sum together the component leakage values to develop the total A/C 

system leakage. However, in this “percent system leakage per year” approach, the total A/C 

leakage score and is then divided the value by the total refrigerant system capacity to develop 

a percent leakage per year. 

EPA believes that the design-based approach would result in estimates of likely 

leakage emissions reductions that would be comparable to those that would eventually result 

from performance-based testing (e.g. SAE J2763), and may consider allowing performance 

test results in lieu of design-based results, if a manufacturer can demonstrate that 100% of 

their vehicles systems are leak tested before they leave the assembly plant. At the same time, 

comments are encouraged on all developments that may lead to a robust, practical, 

performance-based test for measuring A/C refrigerant leakage emissions. 

D1.3 Air conditioning Efficiency 

D1.3.1 Overview 

EPA estimates that the CO2 emissions from A/C related load on the engine of a 

vehicle with an unimproved air conditioning system accounts for about 3.9% of total 

greenhouse gas emissions from passenger vehicles in the United States. This is equivalent to 

CO2 emissions of approximately 14.3 g/mi per vehicle. A complete discussion of this 

estimate is available in Chapter 2 of the EPA RIA to the MY 2012-2016 final rule. 

In brief, most of the excess load on the engine comes from the compressor, which 

pumps the refrigerant around the system loop. Significant additional load on the engine may 

also come from electrical or hydraulic fan units used for heat exchange across the condenser 

and radiator. EPA believes that the controls which manufacturers would use to achieve 

improved A/C efficiency would focus primarily, but not exclusively, on the compressor, 

electric motor controls, and system controls which reduce load on the A/C system (e.g. 

reduced „reheat‟ of the cooled air and increased use of recirculated cabin air). 

The program EPA finalized in the MY 2012-2016 final rule encourages the reduction 

of A/C CO2 emissions from cars and trucks by up to 40% from 2008 baseline levels through a 
2017-2025 Technical Assessment 

D-7 

credit system. A 40% reduction would be equivalent to a reduction of 5.7 grams of CO2 

emissions per mile. 

D1.3.2 A/C Efficiency Credits 

Similar to the 2012-to-2016 Light-Duty GHG Rule, a design-based approach to credits 

is being considered, although the number and type of items listed in the technology “menu” – 

as well as the amount of credit assigned to each item - may change as new methods of testing 

them in the vehicle develop. The design-based approach used in the GHG Rule was used 

because it was not possible to accurately assess their effectiveness of these technologies using 

the A/C Idle Test. 

D1.3.3 A/C Efficiency Test 

A new test to measure the impact of the A/C system operation on emissions is being 

evaluated with input from USCAR, CARB, and the European Union. The primary goal in 

developing this new test is to create a test cycle and test conditions which reflect 

environmental and driving experience found in typical customer usage (rather than the 

extreme, high ambient temperature condition of the SC03 or the idle-only condition of the 

A/C Idle Test). A secondary goal of this new test is to create a cycle which captures the 

effectiveness of advanced A/C technologies, and can demonstrate a fuel savings compared to 

a baseline technology. This new test may include a solar soak condition (to measure the 

effectiveness of solar load reducing technologies such as solar glass and cabin ventilation), a 

transient drive cycle (to measure the dynamic performance of the system during cabin cooldown), and steady-state cycles (to measure the effectiveness of the system under stabilized 

cabin temperature conditions). 

If this new test cycle is able to accurately assess the efficiency of the A/C system and 

its components, it could be used to determine the level of credits available. But if the 

effectiveness of certain technologies cannot be measured on the new test, a design menu 

approach may be utilized. 
Appendix D 

D-8 

Appendix D References 

1

 IPCC. Chapter 2. Changes in Atmospheric Constituents and in Radiative Forcing. September 2007. 

2

 Ward‟s Automotive. Ward's US Light Vehicle Sales: 2005 through 2008 Calendar Years. 

3

 Mobile Air Conditioning Society (MACS) Worldwide. A/C & Cooling System Specifications: 1996-2007. 
2017-2025 Technical Assessment 

E-1

E1 Appendix E: Key Inputs to the Analysis 

This section discusses the key inputs to the analysis which were jointly developed by 

the agencies for today’s Technical Assessment Report. These economic inputs incorporate a 

range of forecast information, economic estimates, and input parameters. This section 

describes the sources that the agencies relied upon for this information, the rationale 

underlying each assumption, and the agencies’ estimates of specific parameter values. These 

common values were then used as inputs to the analyses presented in this Technical 

Assessment Report.

Please note that there are additional economic and environmental impacts which were 

not considered in this assessment. A partial list includes: co-pollutant impacts, health 

impacts, the social cost of carbon emissions, and energy security. The exclusion of these 

impacts from this Technical Assessment Report does not suggest that these impacts should be 

disregarded. As in the MY 2012-2016 final rule, NHTSA and EPA will carefully consider 

other impacts of emission and fuel economy standards during the development of the 

upcoming Notice of Proposed Rulemaking (NPRM). 

Many of the inputs used in this technical assessment are carried forward from the 

analyses conducted for the MY 2012-2016 final rule. As part of developing the upcoming 

NPRM, EPA and NHTSA will consider updating these inputs. 

E1.1 Vehicle Sales 

As discussed in Chapter 6, the vehicle sales projection is based upon output from the 

National Energy Modeling System (NEMS) which is maintained by the Energy Information 

Administration (EIA). As in the MY 2012-2016 final rule, the car and truck split was drawn 

from NEMS, while market segmentation was drawn from CSM’s forecasting tool. Total 

market size is estimated in 2020 at 16.5 million vehicles (55.8 % cars) and in 2025 at 17.0 

million vehicles (57.9% cars). Cars, in the context of NEMS, are defined using the pre-MY 

2011 CAFE definition, as discussed above in Appendix A. 

For this analysis the DOT Volpe center produced a custom run of NEMS. This run 

generated the same overall vehicle sales as the reference case for AEOEIA Annual Energy 

Outlook 2010, but a different sales split between cars and light trucks. A detailed discussion 

on this topic is presented in Appendix A. 

E1.2 On-road Fuel Economy Shortfall 

Fuel economy levels achieved by vehicles in on-road driving fall significantly short of 

their levels measured by EPA under the laboratory test conditions used under the CAFE 

program to establish its published fuel economy ratings. In analyzing the impacts from 

passenger car and light truck GHG and fuel efficiency standards, the agencies adjust the test 

fuel economy performance of each passenger car and light truck model downward from its 

rated value to reflect the expected size of this on-road fuel economy differential. 
Appendix E 

E-2

The agencies note that in December 2006, EPA adopted changes to its regulations on 

fuel economy labeling, which were intended to bring vehicles’ rated fuel economy levels 

closer to their actual on-road fuel economy levels.1 Comparisons of on-road and CAFE fuel 

economy levels developed by EPA as part of that final rule indicate that actual on-road fuel 

economy for light-duty vehicles averages approximately 20 percent lower than published fuel 

economy levels.2

 While there is great heterogeneity among the population of drivers, as 

discussed in the referenced material, 20 percent represents the average for modeling a fleet. 

For example, if the overall EPA fuel economy rating of a light truck is 20 mpg, the on-road 

fuel economy actually achieved by a typical driver of that vehicle is expected to be 16 mpg 

(20*.80). EPA and NHTSA both applied this 20% differential in calculating the fuel savings 

of the MY 2012 – 2016 joint final rule. 

In this technical assessment report, the agencies assume that the overall energy 

shortfall for the electric drivetrain is 30%. Specifically, this refers to a larger shortfall relative 

to laboratory conditions while operating on electricity rather than liquid fuel. The 30% value 

is derived from engineering judgment based on several data points. Foremost among these, 

during the stakeholder meetings conducted prior to this technical assessment, confidential 

business information (CBI) was supplied by several manufacturers which indicated that 

electrically powered vehicles had greater variability in their on-road energy consumption than 

vehicles powered by internal combustion engines. Further, data from the 2006 analysis of the 

“five cycle” label potentially supported a larger on-road shortfall for vehicles with hybridelectric drivetrains.3

 Finally, heavy accessory load, extreme temperatures, and aggressive 

driving have deleterious impacts of unknown magnitudes on battery performance. As a 

counterpoint, CBI provided by several other manufacturers suggested that the onroad/laboratory differential attributable to electric operation should approach that of liquid 

fuel operation in the future. Consequently, 30% was judged a reasonable estimate for the 

current analysis. 

E1.3 Fuel Prices 

Federal government agencies generally use EIA’s projections in their assessments of 

future energy-related policies. The retail fuel price forecasts presented in AEO 2010 span the 

period from 2007 through 2035. Measured in constant 2008 dollars, the AEO 2010 Reference 

Case forecast of retail gasoline prices during calendar year 2020 is $3.34 per gallon, rising 

gradually to $3.91 by the year 2035 (these values include federal, state and local taxes). 

However, valuing fuel savings over the maximum lifetimes of passenger cars and light trucks 

used in this analysis requires fuel price forecasts that extend through 2060, approximately the 

last year during which a significant number of MY 2025 vehicles will remain in service.A To 

obtain fuel price forecasts for the years 2036 through 2060, the agency assumes that retail fuel 

prices will continue to increase after 2035 at the average annual rate (0.7%) projected for 

2008-2035 in the AEO 2010 Reference Case. This assumption results in a projected retail 

price of gasoline that reaches $4.34 in 2050. 

 

A

 The agency defines the maximum lifetime of vehicles as the highest age at which more than 2 percent of those 

originally produced during a model year remain in service. In the case of light-duty trucks, for example, this age 

has typically been 36 years for recent model years. 
2017-2025 Technical Assessment 

E-3

The value of fuel savings resulting from improved fuel economy and GHG emissions 

to buyers of light-duty vehicles is determined by the retail price of fuel, which includes 

federal, state, and any local taxes imposed on fuel sales. Total taxes on gasoline, including 

federal, state, and local levies averaged $0.42 per gallon during 2008, while those levied on 

diesel averaged $0.50. Because fuel taxes represent transfers of resources from fuel buyers to 

government agencies, however, rather than real resources that are consumed in the process of 

supplying or using fuel, their value must be deducted from retail fuel prices to determine the 

value of fuel savings resulting from more stringent fuel efficiency and GHG standards to the 

U.S. economy as a whole.4 When calculating the costs to any individual driver, the taxes are 

included as part of the realized fuel savings.B

E1.4 Vehicle Lifetimes and Survival Rates 

The agencies’ analysis of fuel savings and related benefits for this Technical 

Assessment Report begins by estimating the resulting changes in fuel use over the entire 

lifetimes of cars and light trucks. The change in total fuel consumption by vehicles produced 

during each of these model years is calculated as the difference in their lifetime fuel use under 

the reference and alternative assumptions. 

The first step in estimating lifetime fuel consumption by vehicles produced during a 

model year is to calculate the number of those vehicles expected to remain in service during 

each future calendar year after they are produced and sold.C This number is calculated by 

multiplying the number of vehicles originally produced during a model year by the proportion 

expected to remain in service at the age they will have reached during each subsequent 

calendar year, often referred to as a “survival rate.” 

The agencies used survival rate estimates from a NHTSA study5in calculating fuel 

savings and other impacts from the analyzed scenarios. The proportions of passenger cars and 

light trucks expected to remain in service at each age up to their maximum lifetimes are 

shown in Table E1.4-1.

D

 Note that that these survival rates were calculated against the preMY 2011 definitions of cars and light trucks, because the NHTSA study has not been updated 

 

B

 For society, the fuel taxes represent a transfer payment. By contrast, an individual realizes savings from not 

paying the additional money. 

C

 Vehicles are defined to be of age 1 during the calendar year corresponding to the model year in which they are 

produced; thus for example, model year 2000 vehicles are considered to be of age 1 during calendar year 2000, 

age 1 during calendar year 2001, and to reach their maximum age of 26 years during calendar year 2025. 

NHTSA considers the maximum lifetime of vehicles to be the age after which less than 2 percent of the vehicles 

originally produced during a model year remain in service. Applying these conventions to vehicle registration 

data indicates that passenger cars have a maximum age of 26 years, while light trucks have a maximum lifetime 

of 36 years. See Lu, S., NHTSA, Regulatory Analysis and Evaluation Division, “Vehicle Survivability and 

Travel Mileage Schedules,” DOT HS 809 952, 8-11 (January 2006). Available at http://wwwnrd.nhtsa.dot.gov/Pubs/809952.pdf (last accessed August 25, 2010).

D

 The maximum age of cars and light trucks was defined as the age when the number remaining in service has 

declined to approximately two percent of those originally produced. Based on an examination of recent 

registration data for previous model years, typical maximum ages appear to be 26 years for passenger cars and 

36 years for light trucks. 
Appendix E 

E-4

since 2006. Because the agencies are unaware of a better data source, these values were used 

unchanged. No improvements in survival rates were explicitly projected into the future. 

The survival and annual mileage estimates reported in this section’s tables reflect the 

convention that vehicles are defined to be of age 1 during the calendar year that coincides 

with their model year Thus for example, model year 2012 vehicles will be considered to be 

of age 1 during calendar year 2012. This convention is used in order to account for the fact 

that vehicles produced during a model year typically are first offered for sale in June through 

September of the preceding calendar year (for example, sales of a model year typically begin 

in June through September of the previous calendar year, depending on manufacturer). Thus 

virtually all of the vehicles produced during a model year will be in use for some or all of the 

calendar year coinciding with their model year, and they are considered to be of age 1 during 

that year.E

 

E

 As an illustration, virtually the entire production of model year 2012 cars and light trucks will have been sold 

by the end of calendar year 2012, so those vehicles are defined to be of age 1 during calendar year 2012. Model 

year 2012 vehicles are subsequently defined to be of age 2 during calendar year 2013, age 3 during calendar year 

2014, and so on. One complication arises because registration data are typically collected for July 1 of each 

calendar year, so not all vehicles produced during a model year will appear in registration data until the calendar 

year when they have reached age 2 (and sometimes age 3) under this convention. 
2017-2025 Technical Assessment 

E-5

Table E1.4-1 Survival Rates 

VEHICLE AGE

ESTIMATED 

SURVIVAL 

FRACTION

CARS

ESTIMATED

SURVIVAL 

FRACTION

LIGHT TRUCKS

1 0.9950 0.9950

2 0.9900 0.9741

3 0.9831 0.9603

4 0.9731 0.9420

5 0.9593 0.9190

6 0.9413 0.8913

7 0.9188 0.8590

8 0.8918 0.8226

9 0.8604 0.7827

10 0.8252 0.7401

11 0.7866 0.6956

12 0.7170 0.6501

13 0.6125 0.6042

14 0.5094 0.5517

15 0.4142 0.5009

16 0.3308 0.4522

17 0.2604 0.4062

18 0.2028 0.3633

19 0.1565 0.3236

20 0.1200 0.2873

21 0.0916 0.2542

22 0.0696 0.2244

23 0.0527 0.1975

24 0.0399 0.1735

25 0.0301 0.1522

26 0.0227 0.1332

27 0 0.1165

28 0 0.1017

29 0 0.0887

30 0 0.0773

31 0 0.0673

32 0 0.0586

33 0 0.0509

34 0 0.0443

35 0 0.0385

36 0 0.0334
Appendix E 

E-6

E1.5 VMT 

A critical element in estimating lifetime fuel use by the cars or light trucks produced 

during a future model year is to calculate the total number of miles that they will be driven 

during each year of their expected lifetimes. To estimate total miles driven, the number of 

cars and light trucks projected to remain in use during each future calendar year is multiplied 

by the average number of miles a surviving car or light truck is expected to be driven at each 

age. Estimates of average annual miles driven by MY 2001 cars and light trucks at each age 

were developed by NHTSA from the Federal Highway Administration’s 2001 National 

Household Transportation Survey (Table E1.5-1). These estimates represent the typical 

number of miles driven by a surviving light duty vehicle. To determine the miles driven by 

the average vehicle of a given vintage at a given age, one would multiply the mileage 

accumulation by the corresponding survival rate. 
2017-2025 Technical Assessment 

E-7

Table E1.5-1 MY 2001 Mileage Schedules based on NHTS Data 

VEHICLE AGE

ESTIMATED 

VEHICLE MILES 

TRAVELED

CARS

ESTIMATED

VEHICLE MILES 

TRAVELED 

LIGHT TRUCKS

1 14,231 16,085

2 13,961 15,782

3 13,669 15,442

4 13,357 15,069

5 13,028 14,667

6 12,683 14,239

7 12,325 13,790

8 11,956 13,323

9 11,578 12,844

10 11,193 12,356

11 10,804 11,863

12 10,413 11,369

13 10,022 10,879

14 9,633 10,396

15 9,249 9,924

16 8,871 9,468

17 8,502 9,032

18 8,144 8,619

19 7,799 8,234

20 7,469 7,881

21 7,157 7,565

22 6,866 7,288

23 6,596 7,055

24 6,350 6,871

25 6,131 6,739

26 5,940 6,663

27 0 6,648

28 0 6,648

29 0 6,648

30 0 6,648

31 0 6,648

32 0 6,648

33 0 6,648

34 0 6,648

35 0 6,648

36 0 6,648
Appendix E 

E-8

E1.5.1 Adjusting vehicle use for future fuel prices 

The estimates of average annual miles driven by passenger cars and light trucks 

reported in Table E1.5-1 reflect the historically low gasoline prices that prevailed at the time 

the 2001 NHTS was conducted. Under the assumption that people tend to drive more as the 

cost of driving decreases, the higher fuel prices in more recent projections leads to lower 

mileage schedules. For this report, the agencies updated the analysis with the forecasts of 

future gasoline prices reported in the AEO 2010 reference case. This adjustment accounts for 

the difference between the average retail price per gallon of fuel forecast during each calendar 

year over the expected lifetimes of future model year passenger cars and light trucks, and the 

average price that prevailed when the NHTS was conducted in 2001. The elasticity of annual 

vehicle use with respect to fuel cost per mile corresponding to the 10 percent fuel economy 

rebound effect used in this analysis (i.e., an elasticity of -0.10) was used in conjunction with 

the difference between each future year’s fuel prices and those prevailing in 2001 to adjust the 

estimates of vehicle use derived from the NHTS to reflect the effect of higher future fuel 

prices. This procedure was applied to the NHTS derived mileage figures to adjust annual 

mileage by age during each calendar year of the expected lifetimes of future model year cars 

and light trucks. 

E1.5.2 Ensuring consistency with growth in total vehicle use 

The estimates of annual miles driven by passenger cars and light trucks at each age 

were also adjusted to reflect projected future growth in average vehicle use. Increases in the 

average number of miles cars and trucks are driven each year have been an important source 

of historical growth in total car and light truck use, and are expected to represent an important 

source of future growth in total light-duty vehicle travel as well. As an illustration of the 

importance of growth in average vehicle use, the total number of miles driven by passenger 

cars increased 35 percent from 1985 through 2005, equivalent to a compound annual growth 

rate of 1.5 percent.6

 During that time, however, the total number of passenger cars registered 

for in the U.S. grew by only about 0.3 percent annually.F Thus growth in the average number 

of miles automobiles are driven each year accounted for the remaining 1.2 percent (= 1.5 

percent - 0.3 percent) annual growth in total automobile use.G Further, the AEO 2010 

Reference Case forecasts of total car and light truck use and of the number of cars and light 

trucks in use suggest that their average annual use will continue to increase gradually from 

2010 through 2035. 

In order to develop reasonable estimates of future growth in average car and light 

truck use, the agencies calculated the rate of growth in the mileage schedules necessary for 

 

F

 A slight increase in the fraction of new passenger cars remaining in service beyond age 10 has accounted for a 

small share of growth in the U.S. automobile fleet. The fraction of new automobiles remaining in service to 

various ages was computed from R.L. Polk vehicle registration data for 1977 through 2005 by the agency’s 

Center for Statistical Analysis. 

G

See supra note k below. 
2017-2025 Technical Assessment 

E-9

total car and light truck travel to increase at the rate forecast in the AEO 2010 Reference 

Case. The growth rate in average annual car and light truck use produced by this calculation 

is approximately 1.15 percent per year.H This rate was applied to the mileage figures reported 

in Table E1.5-1 to estimate annual mileage by age during each calendar year of the expected 

lifetimes of cars and light trucks during all model years. 

Separate adjustments for projected fuel prices and growth in vehicle use were made 

for each calendar year. Because the effects of both fuel prices and cumulative growth in 

average vehicle use vary by year, these adjustments result in different VMT schedules for 

each future year. While the adjustment for future fuel prices generally reduces average 

mileage at each age from the 2001 values, the adjustment for expected future growth in 

average vehicle use increases it. The net impact is growth over time. 

E1.5.3 Final VMT equation 

Below, we show the equations used to determine the VMT schedules used in this 

analysis. This particular form of the equation uses a negative form of the rebound rate. 

Where: 

V = CY 2001 VMT from NHTSA analysis of NHTS data 

SGR = Secular Growth Rate 

YS = Years since 2001 

RR= Rebound rate 

FCPM = Fuel Cost per mile 

Where: 

EC= Electrical consumption per mile 

EP = Electricity Price 

GC = Gasoline Consumption per mile 

GP = Gasoline Price 

 

H

 It was not possible to estimate separate growth rates in average annual use for cars and light trucks, because of 

the significant reclassification of light truck models as passenger cars discussed previously. 
Appendix E 

E-10

Table E1.5-2 MY 2020 and 2025 Reference Mileage SchedulesI

MY 2020 MY 2025

VEHICLE 

AGE

ESTIMATED 

VMT

CARS

ESTIMATED

VMT LIGHT 

TRUCKS

ESTIMATED 

VMT

CARS

ESTIMATED

VMT LIGHT 

TRUCKS

1 16,882 19,017 17,749 19,991

2 16,334 18,398 17,152 19,315

3 16,235 18,281 17,071 19,219

4 16,143 18,160 16,976 19,094

5 16,048 18,024 16,879 18,954

6 15,750 17,643 16,586 18,578

7 15,356 17,145 16,175 18,056

8 15,040 16,728 15,846 17,623

9 14,044 15,538 14,774 16,342

10 13,707 15,092 14,427 15,883

11 13,243 14,504 13,921 15,244

12 12,824 13,968 13,492 14,693

13 12,439 13,472 13,101 14,188

14 11,991 12,912 12,634 13,603

15 11,518 12,333 12,142 12,999

16 11,054 11,773 11,664 12,422

17 10,607 11,245 11,193 11,866

18 10,169 10,741 10,731 11,334

19 9,743 10,266 10,281 10,833

20 9,337 9,833 9,854 10,376

21 8,949 9,438 9,444 9,960

22 8,588 9,098 9,064 9,601

23 8,252 8,809 8,709 9,296

24 7,943 8,576 8,382 9,050

25 7,671 8,415 8,096 8,880

26 7,436 8,324 7,847 8,784

27 0 8,307 0 8,766

28 0 8,313 0 8,773

29 0 8,317 0 8,777

30 0 8,315 0 8,775

31 0 8,318 0 8,779

32 0 8,323 0 8,784

33 0 8,324 0 8,785

34 0 8,328 0 8,789

35 0 8,335 0 8,797

36 0 8,335 0 8,797

 

I

 VMT schedules differing by approximately 0.2% over the course of a vehicle lifetime were used in the 

estimation of costs and impacts. The VMT schedules used in cost estimation are shown here. 
2017-2025 Technical Assessment 

E-11

E1.5.4 Comparison to the VMT schedules in the MY 2012-2016 Final Rulemaking 

The VMT schedules used in the MY 2012-2016 final rulemaking and this assessment 

report are compared below. 

Table E1.5-3 Summary of Reference Expected Lifetime VMT 

2001 NHTS in 

NHTSA Report

MY 2012-2016 

Final Rule

MY 2020 MY 2025

Car 152,137 195,264 197,578 207,922

Trucks 179,954 225,865 231,856 244,026

E1.6 VMT Rebound 

The VMT rebound effect refers to the fraction of fuel savings expected to result from 

an increase in vehicle fuel economy that is offset by additional vehicle use. The increase in 

vehicle use that stems from improved fuel economy occurs because vehicle owners respond to 

the resulting reduction in vehicle fuel consumption and operating costs by driving more. 

The magnitude of the rebound effect is one of the determinants of the actual fuel 

savings that are likely to result from adopting stricter fuel economy or emissions standards, 

and thus is an important parameter affecting the evaluation of potential standards for future 

model years. It can be measured directly by estimating the elasticity of vehicle use with 

respect to fuel economy itself, or indirectly by the elasticity of vehicle use with respect to fuel 

cost per mile driven.J When expressed as a positive percentage, either of these parameters 

gives the fraction of fuel savings that would otherwise result from adopting stricter standards, 

but is offset by the increase in fuel consumption that results when vehicles with increased fuel 

economy are driven more. 

The fuel economy rebound effect for light-duty vehicles has been the subject of a large 

number of studies since the early 1980s. Although they have reported a wide range of 

estimates of its exact magnitude, these studies generally conclude that a significant rebound 

effect occurs when vehicle fuel efficiency improves.K

 The most common approach to 

 

J

 FuelFuel cost per mile is equal to the price of fuel in dollars per unit divided by fuel economy in miles per 

unitunit, so this figure declines when a vehicle’s fuel economy increases. 

K

 Some studies estimate that the long-run rebound effect is significantly larger than the immediate response to 

increased fuel efficiency. Although their estimates of the adjustment period required for the rebound effect to 
Appendix E 

E-12

estimating its magnitude has been to analyze household survey data on vehicle use, fuel 

consumption, fuel prices (often obtained from external sources), and other determinants of 

household travel demand to isolate the response of vehicle use to higher fuel economy. Other 

studies have relied on econometric analysis of annual U.S. data on vehicle use, fuel economy, 

fuel prices, and other variables to identify the response of total or average vehicle use to 

changes in fleet-wide average fuel economy and its effect of fuel cost per mile driven. Two 

recent studies analyzed yearly variation in vehicle ownership and use, fuel prices, and fuel 

economy among individual states over an extended time period in order to measure the 

response of vehicle use to changing fuel economy.L

Chapter Four of the Joint Technical Support Document to the recent MYs 2012-2016 

final rule surveys these previous studies, summarizes recent work on the rebound effect, and 

explains the basis for the 10 percent rebound effect EPA and NHTSA are using in the current 

technical analysis.7

 The use of a 10 percent rebound effect in this analysis reflects an 

assumption that the rebound effect applicable to the MYs 2012-2016 vehicles will remain 

applicable throughout future time periods. The agencies plan to conduct new analysis of the 

expected rebound effect in this time frame in a future rulemaking. 

E1.7 Estimating Emissions and Fuel Savings 

A vehicle emission standard would reduce GHG emissions emitted directly from vehicles 

due to reduced fuel use and decreased leakage from air conditioning systems. In addition to these 

“downstream” emissions, reducing CO2 emissions translates directly to reductions in the 

emissions associated with the processes involved in getting petroleum to the pump, including the 

extraction and transportation of crude oil, and the production and distribution of finished gasoline 

(termed “upstream” emissions). The agencies quantified these impacts using the inputs 

discussed in this section. 

Table E1.7-1 Processes Considered 

PROCESS UPSTREAM / DOWNSTREAM

Crude Oil Extraction Upstream

Crude Oil Transport Upstream

Oil Refining Upstream

Fuel Transport and Distribution Upstream

Fuel Tailpipe Emissions Downstream

Air Conditioning System Leakage Downstream

 

reach its long-run magnitude vary, this long-run effect is most appropriate for evaluating the fuel savings and 

emissions reductions resulting from stricter standards that would apply to future model years. 

L

 In effect, these studies treat U.S. states as a data “panel” by applying appropriate estimation procedures to data 

consisting of each year’s average values of these variables for the separate states. 
2017-2025 Technical Assessment 

E-13

1.7.1 Estimating reductions in GHG emissions from vehicle use (downstream) 

For the analysis documented in today’s Technical Assessment, the agencies used the 

OMEGA model to directly calculate CO2 emissions based on g/mile rates. These CO2

emissions were converted to gallons of fuel under the assumption that approximately the 

entire carbon content of liquid fuel is converted to CO2 emissions during the combustion 

process. The weighted average CO2 content of gasoline is estimated to be 8,887 grams per 

gallon, while that of diesel fuel is estimated to be approximately 10,200 grams per gallon. For 

details, please see EPA’s RIA and NHTSA’s RIA from the recent MY 2012-2016 Final Rule. 

EPA estimated the increases in emissions of methane (CH4) and nitrous oxide (N2O) 

due to increased vehicle use (“rebound driving”) by multiplying the increase in total miles 

driven by cars and light trucks of each model year and age by emission rates per vehicle-mile 

for these GHGs. These emission rates, which differ between cars and light trucks as well as 

between gasoline and diesel vehicles, were estimated by EPA using its Motor Vehicle 

Emission Simulator (MOVES 2010) model. The MOVES model assumes that the per-mile 

rates at which cars and light trucks emit these GHGs are determined by the efficiency of fuel 

combustion during engine operation and chemical reactions that occur during catalytic aftertreatment of engine exhaust, and are thus independent of vehicles’ fuel consumption rates. 

Thus MOVES emission factors for these GHGs are assumed to be unaffected by changes in 

energy consumption. TheCH4 and N2O emission factors are the same as those used in the MY 

2012-2016 Final Rule. The full derivation of these factors is available in Chapter 4 of the 

related Joint Technical Support Document. 

The emission factors used for HFC leakage emissions are discussed in Appendix D to 

this report. 

E1.8 Upstream Emissions 

In this analysis, we calculated upstream emission impacts for the greenhouse gases 

CH4, N2O, and CO2 from both gasoline and electricity production. The upstream gasoline 

emission factor, expressed in the form of gram/gallon produced, is taken directly from the 

analysis supporting the MYs 2012-2016 final rule. EPA derived the upstream gasoline 

emission factor from the Department of Energy’s GREET model, which provides separate 

estimates of air pollutant emissions that occur in four phases of fuel production and 

distribution: crude oil extraction, crude oil transportation and storage, fuel refining, and fuel 

distribution and storage. EPA modified the GREET model to change certain assumptions 

about emissions during crude petroleum extraction and transportation, as well as to update its 

emission rates to reflect adopted and pending EPA emission standards. The agency converted 

these emission rates from the mass per fuel energy content basis on which GREET reports 

them to mass per gallon of fuel supplied using the estimates of fuel energy content reported 

by GREET. Full details of this analysis are described in the MYs 2012-2016 rulemaking 

docket memo “Calculation of Upstream Emissions for the GHG Vehicle Rule.” The upstream 

gasoline emission factor does not change over time. 
Appendix E 

E-14

Table E1.8-1 Gasoline Upstream Emission Factors 

POLLUTANT GASOLINE (g/gallon)

CO2 2,161

CH4 12.25

N2O 0.03

CO2eq 2477

In the MY 2012-2016 Final Rule analysis, we noted that there are many issues 

involved with projecting the electricity upstream GHG emissions. Relevant issues associated 

with future EV and PHEV use include, but are not limited to, average versus marginal power 

generation, daytime versus nighttime vehicle charging, geographical differences, and changes 

in future electricity feedstocks. 

For the present report, we rely upon the reference case projections produced by the 

EPA Office of Atmospheric Programs for an analysis of the American Clean Energy and 

Security Act of 2009 (H.R. 2454).8

 This scenario assumes no new power sector regulations, 

but does assume construction of new plants to replace older retired plants. This results in a 

slight decrease (~10% compared to 2005) in the emission rate per kWh electricity produced, 

as newer plants tend to emit less than the plants which they have replaced. The H.R 2454 

base case analysis indicates that 4,395 MWh of net generation will be produced in 2025, with 

2462 million metric tons of CO2 emissions resulting. This results in an emission factor of 555 

grams CO2 per kWh. Based on eGrid20059, we estimate that approximately 0.01 grams of 

CH4 and 0.01 grams of N2O are emitted per kilowatt hour. We assume that electricity 

emission factors do not change after 2025. 

The upstream emission factor for electricity was adjusted upwards by six percent in 

order to properly capture the feedstock gathering that occurs upstream of the powerplant. M

Feedstock gathering includes the gathering, transporting, and preparing fuel for electricity 

generation. This adjustment factor is consistent with those discussed in the MY 2012-2016 

Final Rule.10

 

It is important to carefully outline the frame of reference for electricity emission 

factors. For calculations of GHG emissions from electricity generation, the total energy 

consumed from the battery is divided by 0.9 to account for charging losses, and by 0.93 to 

account for losses during transmission. The upstream emission factor is applied to total 

electricity production, rather than simply power consumed at the wheel. NO

 

M

 The factor of 1.06 to account for GHG emissions associated with feedstock extraction, transportation, and 

processing is based on Argonne National Laboratory’s The Greenhouse Gases, Regulated Emissions, and Energy 

Use in Transportation (GREET) Model, Version 1.8c.0, available at 

http://www.transportation.anl.gov/modeling_simulation/GREET/). EPA Docket EPA-HQ-OAR-2009-0472. 

N

 By contrast, consumer electricity costs would not include the power lost during transmission. While 

consumers indirectly pay for this lost power through higher rates, this power does not appear on their electric 

meter. 
2017-2025 Technical Assessment 

E-15

POLLUTANT CY 2025 

ELECTRICITY (g/kWh)

CO2 555

CH4 0.01

N2O 0.01

CO2eq 558

CO2eq adjusted for 

feedstock gathering 591

E1.9 Global Warming Potentials 

Increases in emissions of non-CO2 GHGs are converted to equivalent increases in CO2 

emissions using estimates of the Global Warming Potential (GWP) of hydrofluorocarbon 

134a (HFC134a), methane and nitrous oxide. These GWPs are one way of accounting for the 

higher radiative forcing capacity and differing lifetimes of methane and nitrous oxide when 

they are released into the earth’s atmosphere, measured relative to that of CO2. Because these 

gases differ in atmospheric lifetimes, their relative damages are not constant over time. 

Impacts other than temperature change also vary across gases in ways that are not captured by 

GWP. For instance, CO2 emissions, unlike methane and other greenhouse gases, contribute to 

ocean acidification. Methane contributes to health and ecosystem effects arising from 

increases in tropospheric ozone, while damages from methane emissions are not offset by the 

positive effect of CO2 fertilization. Noting these caveats, the CO2 equivalents of increases in 

emissions of these gases are then added to the increases in emissions of CO2 to summarize the 

effect of the total increase in CO2-equivalent GHG emissions from vehicle use. 

As in the final rule, the GWP values from the Intergovernmental Panel on Climate 

Change Annual Report 4 are used. These are 1430 for HFC134a, 298 for N2O, and 25 for 

CH4. 

11,P

 

O

 By contrast, consumer electricity costs would not include the power lost during transmission. While 

consumers indirectly pay for this lost power through higher rates, this power does not appear on their electric 

meter. 

P

 The global warming potentials (GWP) used in this rule are consistent with Intergovernmental Panel on Climate 

Change (IPCC) Fourth Assessment Report (AR4). Due to international agreement, the IPCC Second 

Assessment Report (SAR) GWP values are used in the official U.S. greenhouse gas inventory submission to the 

climate change framework. 
Appendix E 

E-16

Appendix E References 

1 EPA, Fuel Economy Labeling of Motor Vehicles: Revisions To Improve Calculation of Fuel Economy 

Estimates; Final Rule, 40 CFR Parts 86 and 600, Federal Register, December 27, 2006, pp. 77872-77969,

http://www.epa.gov/fedrgstr/EPA-AIR/2006/December/Day-27/a9749.pdf. 

2 EPA, Final Technical Support Document: Fuel Economy Labeling of Motor Vehicle Revisions to Improve 

Calculation of Fuel Economy Estimates, Office of Transportation and Air Quality EPA420-R-06-017 December 

2006, Chapter II, http://www.epa.gov/fueleconomy/420r06017.pdf. 

3

 EPA, Fuel Economy Labeling of Motor Vehicles: Revisions To Improve Calculation of Fuel Economy 

Estimates; Final Rule, 40 CFR Parts 86 and 600, Federal Register, December 27, 2006, pp. 77872-77969,

http://www.epa.gov/fedrgstr/EPA-AIR/2006/December/Day-27/a9749.pdf. 

4 OMB Circular A-4, September 17, 2003. http://www.whitehouse.gov/omb/assets/omb/circulars/a004/a-4.pdf 

5 Lu, S., NHTSA, Regulatory Analysis and Evaluation Division, “Vehicle Survivability and Travel Mileage 

Schedules,” DOT HS 809 952, 8-11 (January 2006). Available at http://www-nrd.nhtsa.dot.gov/pdf/nrd30/NCSA/Rpts/2006/809952.pdf (last accessed Feb. 15, 2010). 

6 FHWA, Highway Statistics, Summary to 1995, Table vm201at 

http://www.fhwa.dot.gov/ohim/summary95/vm201a.xlw , and annual editions 1996-2005, Table VM-1 at 

http://www.fhwa.dot.gov/policy/ohpi/hss/hsspubs.htm (last accessed Feb. 15, 2010). 

7 Sorrell, S. and J. Dimitropoulos, 2007. “UKERC Review of Evidence for the Rebound Effect, Technical 

Report 2: Econometric Studies”, UKERC/WP/TPA/2007/010, UK Energy Research Centre, London, October 

and Greening, L.A., D.L. Greene and C. Difiglio, 2000. “Energy Efficiency and Consumption – The Rebound 

Effect – A Survey”, Energy Policy, vol. 28, pp. 389-401. 

8

 EPA Office of Atmostpheric Programs. Analysis of HR2454. 

http://www.epa.gov/climatechange/economics/economicanalyses.html 

9 U.S. EPA. 2009. eGrid2007 dataset. http://www.epa.gov/cleanenergy/energyresources/ 

egrid/index.html. Accessed February 3, 2010. The Emissions & Generation Resource Integrated Database 

(eGRID) is a comprehensive inventory of environmental attributes of electric power systems. The preeminent 

source of air emissions data for the electric power sector, eGRID is based on available plant-specific data for all 

U.S. electricity generating plants that provide power to the electric grid and report data to the U.S. government. 

10 MY 2012-2016 Final Rule, Section III.2.C 

11 EPA. Final Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate 

Average Fuel Economy Standards. Joint Technical Support Document. Chapter 4. EPA-420-R-10-901 

http://www.epa.gov/otaq/climate/regulations/420r10901.pdf. Original data found in Intergovernmental Panel on 

Climate Change. Chapter 2. Changes in Atmospheric Constituents and in Radiative Forcing. September 2007. 

http://www.ipcc.ch/pdf/assessmentreport/ar4/wg1/ar4-wg1-chapter2.pdf. Docket ID: EPA-HQ-OAR-2009-0472-

0117
2017-2025 Technical Assessment 

F-1 

F1 Appendix F: EPA Documentation of OMEGA model 

Analysis 

F1.1 Overview of OMEGA 

This Appendix provides the methodology underlying the technical assessment of the 

future vehicle scenarios presented in Chapter 6. As in the analysis of the MY 2012-2016 

rulemaking, evaluating the feasibility of these scenarios included identifying potentially available 

technologies and assessing their effectiveness, cost, and impact on relevant aspects of vehicle 

performance and utility. The wide number of technologies which are available and likely to be 

used in combination required a method to account for their combined cost and effectiveness. As 

described in Chapter 6, this included developing three distinct technology pathways which 

emphasized one or the other of the more advanced technologies, such as hybrids, advanced 

gasoline engine, plug-ins and battery EVs. 

Applying these technologies efficiently to the wide range of vehicles produced by various 

manufacturers is a challenging task. In order to assist in this task, EPA has developed a 

computerized model called the Optimization Model for reducing Emissions of Greenhouse gases 

from Automobiles (OMEGA). Broadly, the model starts with a description of the future vehicle 

fleet, including manufacturer, sales, base CO2 emissions, footprint and the extent to which 

emission control technologies are already employed. For the purpose of this Technical 

Assessment Report analysis, 63 generic vehicle platforms—were used to capture important 

differences in engine design, vehicle design and vehicle utility. The model is then provided with a 

list of technologies which are applicable to various types of vehicles, along with their cost and 

effectiveness and the maximum percentage of vehicle sales which can receive each technology. 

This list varies slightly depending on whether model year 2020 or 2025 standards are being 

evaluated and on the specific technology pathway being evaluated. The model combines this 

information with economic parameters, such as fuel prices and a discount rate, to project how 

manufacturers could apply available technology in order to meet specified levels of emission 

control. For this Technical Assessment Report, as all vehicle sales have been combined into a 

single manufacturer, the model indicates how the industry when complying as a single 

manufacturer might use technology to reduce GHG emissions. The resulting output is a 

description of which technologies are added to each vehicle platform, along with the 

accompanying cost. 

OMEGA includes several components, including a number of pre-processors that assist 

users in preparing a baseline vehicle forecast,1

creating and ranking technology packages,2and 

calculating the degree to which technology is present on baseline vehicles. The OMEGA core 

model assembles this information and produces estimates of increases in vehicle cost and CO2

reduction. Based on the OMEGA core model output, the technology penetration of the new 

vehicle mix and the scenario impacts (fuel savings, emission impacts, and other monetized 

benefits) are calculated by post-processors. The pre- and post- processors are Microsoft Excel 

spreadsheets and visual basic programs, while the OMEGA core model is an executable program 

written in the C# language. The files used in this analysis, as well as the current version of 

OMEGA, are available in the TAR docket.
Appendix F 

F-2 

Figure F1.1-1: Information Flow in the OMEGA Model 

A detailed description of the OMEGA model, as well as the general modeling 

methodology is provided in the MY 2012-2016 rule preamble Section III.D. Consequently, 

the interested reader may find additional depth there,3

or in the OMEGA user guide on the 

EPA website.4

 The remainder of this appendix assumes a basic knowledge of OMEGA’s 

operation, and focuses on the particular data sources and methodologies used in the scenario 

analysis described in Chapter 6. 

F1.2 Summary of Inputs 

The inputs underlying the OMEGA analysis have significant impacts on the results, 

and are described in detail elsewhere in this Assessment Report, as follows. The fleet 

projection used for this analysis is described in Appendix A. The vehicle technology 

packages are described in Chapter 3 and Appendix B. The inputs relating to air conditioning 

controls are outlined in Appendix D. The other economic and environmental outputs are 

described in Appendix E. The detailed description of analytic scenarios, including the 

standards modeled and the reasoning behind a single fleet analysis, is available in Chapter 6. 

Generally, the table of contents to this technical assessment is a useful guide to additional 

detail. 

F1.3 Configuration of the Scenario File 

The scenario file in OMEGA contains a directory of data input files, a group of 

economic parameters, and a set of CO2 g/mile targets. For the Technical Assessment Report 

analysis, OMEGA was configured so that each technical pathway/model year combination 

was a single scenario file containing six runs. Four runs corresponding to each of the four 

emission control scenarios (i.e., 3% per year, 4% per year, etc.) were included. Also included 

were a diagnostic run requiring maximum application of technology, as well the reference 

case scenario of MY 2016 GHG standards from the recent MY 2012-2016 final rule. As a 
2017-2025 Technical Assessment 

F-3 

result, six scenario files were created (2 MYs x 3 technical pathways), and each scenario file 

contained parameters for six OMEGA runs. 

The emission control scenarios were each configured with a flat standard 

corresponding to the appropriate stringency. No limits were placed on credit transfers 

between the car and truck fleets. As in the MY 2012-2016 final rule analysis, EPA accounted 

for the emission reductions and technology costs due to air conditioning controls outside of 

the OMEGA model. In the MY 2025 timeframe, air conditioning remains a highly costeffective technology to control GHG emissions, and consequently, EPA projects that the 

entire market will convert to low leakage, high efficiency systems. In the time frame of MY 

2020 and later, these emission reductions were assigned a statutory value of 20.6 grams in the 

reference scenario5and 15.3 grams in the control scenarios.6 An example of the adjustments 

is shown in Table F1.3-1. The MY 2016 footprint curves and the flat standards were each 

adjusted by the maximum potential AC credits to produce the credit adjusted targets. The 

agencies note, as discussed in Chapter 6 above, that the upcoming federal rulemaking analysis 

will consider fuel economy and emission control scenarios defined in terms of attribute-based 

standards, but we believe the scenarios considered here are meaningful for purposes of this 

assessment. 

Table F1.3-1: Adjustment of Standards for Air Conditioning Credits 

Scenario Sales-Weighted 

MY 2025 Target

Projected AC 

Credits1

Sales-Weighted MY 

2025 Credit Adjusted

Target

Reference 248.1 20.6 268.7

3% 190.1 15.3 205.4

4% 173.1 15.3 188.4

5% 157.6 15.3 173.9

6% 143.2 15.3 158.5
Appendix F 

F-4 

A further adjustment was made with respect to the credit adjusted targets listed above. 

The scenarios described in this document are defined by a sales weighted average of car and 

truck CO2 emissions. When credit transfer is allowed between cars and trucks, OMEGA 

weights the CO2 average by both sales and vehicle miles traveled (VMT).A Light trucks 

generally are driven more than cars, so the sales and VMT weighted CO2 emission average 

tends to be slightly lower than the sales-weighted average. To account for this difference, the 

diagnostic run was used to produce VMT and sales weighted targets that corresponded to the 

sales weighted targets listed above. These calibrated targets can be seen in the scenario files 

available in the TAR docket. 

We also updated the VMT ratios used in car/truck credit transfer to the appropriate 

MY lifetime values discussed in Appendix E. 

F1.4 Configuration of the Technology File 

The technology input file defines the technology packages which the model can add to 

the vehicle fleet. A separate technology file was developed for each of the six technology 

pathway/model year combinations considered in this Technical Assessment Report. While 

the individual technology costs were the same between technology pathways, they differed 

between MY 2020 and MY 2025 due to the learning effects discussed in the Appendix 3 and 

the MY 2012-2016 Final Rule Section II.E. Due to the different limits on maximum 

penetrations of several key technologies (discussed in Chapter 6), each of the technology 

pathways also required a separate technology file and model run. The change in those 

maximum penetration rates also slightly affected the set of most cost effective technology 

packages selected for inclusion in the OMEGA model runs. The processes to build and rank 

technology packages for the technology file are described in the Chapter 3 and Appendix B of 

this report. This section describes the configuration of the OMEGA Technology input file 

which occurs after the ranked packages are developed. 

F1.4.1 Multiple Fuel Tracking 

OMEGA 1.0.2, which was used during the MY 2012-2016 rule analysis, tracked CO2

emissions at the vehicle platform level. For the present analysis, an upgrade was made to the 

OMEGA model to track CO2 emissions by fuel within each vehicle platform. As a result, a 

vehicle platform can be composed of sub-vehicles, each with its own fuel, CO2 emission rate 

and electricity consumption rate. To facilitate this tracking, every technology is encoded 

with its operating fuel, as well as the fuel of the vehicles to which it applies. In combination 

with technology specific caps,Bthis allows a vehicle platform to be split so that subsequent 

technologies can be applied to the specific subsets of the vehicle (Table F1.4-1). Thus, for 

example, a certain fraction of a vehicle’s sales can be equipped with a diesel engine. 

Subsequent diesel-based technologies can then be applied more simply and directly to this 

 

A

 This practice is consistent with EPA’s MY 2012-2016 regulations allowing VMT weighted credit transfer 

between car and truck fleets.

B

 ―Cap‖ is a shorthand term for the maximum penetration rates for certain technologies which define the various 

technology paths. 
2017-2025 Technical Assessment 

F-5 

subset of sales. The model keeps track of the sales and CO2 emission rates of both the 

gasoline and diesel versions of the vehicle. 

In the example below, Technology Package 3 is applied to the gasoline fuel vehicle 

created by the application of Technology Package 1. Technology Package 4 is applied to the 

diesel fuel vehicle created by the application of Technology Package 2. 

Table F1.4-1: Example of Multiple Fuel Technology File 

Tech 

Package

Name Cap1Fuel of the 

Technology

Fuel to which the 

Technology Applies

1 GDI Gasoline Engine 100% Gasoline Gasoline

2 Diesel Engine 15% Diesel Gasoline

3 Gasoline Hybrid 100% Gasoline Gasoline

4 Improved Diesel 100% Diesel Diesel

1Please note that OMEGA technology caps are relative to the population on that fuel, so a 100% cap on 

technology package four indicates that it applies to 100% of the 15% of vehicles which were converted to diesel 

in step 

In the current TAR analysis, this model feature simplified the ability to apply several 

types of electric vehicle and plug-in electric vehicle technology packages to the same baseline 

vehicle. In addition, we found it useful when applying certain advanced gasoline technology 

packages which had caps of less than 100%. For example, most of the technology paths limit 

the use of advanced (e.g., EGR-boosted) gasoline engine technologies to less than 100%. In 

most cases, further technology packages can be applied to both the vehicles which received 

this advanced gasoline technology and those that did not. By effectively treating ―advanced 

gasoline engines‖ as including a change in fuels, we were able to simplify the addition of 

subsequent technologies to both the subset of vehicle sales with this technology and that 

without it. This could have been accomplished without taking advantage of the OMEGA 

model’s new fuel tracking capability, but the estimation of the cost and effectiveness of the 

subsequent technology packages would have had to consider the fact that they were being 

applied to a subset of the vehicle’s sales which did not have the average attributes of that 

vehicle at that stage of technology addition. 

For example, if EGR boost technology is added to 50% of the sales of those vehicles 

operating on gasoline, it may be possible to hybridize both the vehicles with and without the 

EGR boost technology, with differing costs and effectiveness. It is possible to determine the 

overall impact of hybridizing the non-EGR vehicles first and then the EGR-boosted vehicles 

and developing the appropriate OMEGA model inputs which accomplish both of these steps 

of technology addition. However, since we were not using all of the fuel types currently 

tracked in the OMEGA model (e.g. E10), it was easier to separate the EGR-boosted vehicles 

from those without this technology by changing the former vehicles’ fuel to ―E10‖. We 

simply made the fuel properties of E10 exactly the same as those for gasoline. Then for 

example, the incremental effect of hybridizing the non-EGR boosted vehicles could be used 

directly in the model without the need to sales weight this impact by including the fact that the 

emissions of the non-EGR vehicles were not changing. 
Appendix F 

F-6 

To further illustrate this issue, consider the case of Vehicle A, a gasoline vehicle with 

CO2 emissions of 300 g/mile. In this example scenario, diesel packages are limited to 50% of 

the fleet because of concerns relative to production capacity.C In this case, two sequential 

diesel packages should be applied to the same 50% subset of the vehicle (Table F1.4-2). As 

can be seen in this table, OMEGA 1.3 now more accurately attributes the reductions to the 

appropriate subset within the vehicle platform. 

Table F1.4-2: Tracking CO2 

Step Package 

Fuel

Maximum 

Penetration 

Limit

Reduction OMEGA 1.0.2

Applied to average

vehicle.

OMEGA 1.3

Applied to a specific fuel 

within a platform.

CO2 Avg CO2 

Avg

CO2 

Gas

CO2 

Diesel

300 300 300 N/A

1 Diesel 50% 10% 285 285 300 270

2 Diesel 50%/100% 10% 270.75 271.5 300 243

1The maximum penetration limit in the second step applies to 50% of the total vehicles (OMEGA 1.0.2) or 100% 

of the diesel vehicles (OMEGA 1.3) 

In the analysis presented in this report, we encode limited technologies to different 

fuels so that the appropriate reductions are taken. As an example, plug-in hybrids are coded 

to diesel fuel. The fuels input file was modified so that the appropriate gasoline fuel 

properties are attributed to ―diesel‖ fuel. 

F1.4.2 Tracking of Electricity 

OMEGA 1.3 also tracks electrical consumption in kWh per mile. Each technology 

package is now associated with an ―electricity conversion percentage‖ which refers to the 

increase in the energy consumed by the electric drivetrain relative to reduction in the 

consumption of energy from liquid fuel. Electricity is a highly refined form of energy which 

can be used quite efficiently to create kinetic energy. Thus, electric motors are much more 

efficient than liquid fuel engines. Consequently, the electric consumption percentage input in 

in the Technology File for plug-in vehicles is generally well below than 100%. It may be 

possible that this percentage could exceed 100% under certain circumstances, for example 

when one type of plug-in vehicle is being converted into another plug-in vehicle and 

electricity consumption per mile is increasing due to larger and heavier batteries, etc. 

However, that was not the case for any of the technologies evaluated in this analysis. 

 

C

 Please note, this is just an example, and has no implications relative to actual maximum penetration rates for 

diesel vehicles. 
2017-2025 Technical Assessment 

F-7 

F1.5 Configuration of the Market File 

F1.5.1 Creating the Generic Vehicles 

As discussed in Section F1.4 above, vehicle manufacturers typically develop many 

different models by basing them on a smaller number of vehicle platforms. The platform 

typically consists of a common set of vehicle architecture and structural components. This 

allows for efficient use of design and manufacturing resources. In the MY 2012-2016 Final 

Rule, EPA created over 200 vehicle platforms which were used to capture the important 

differences in vehicle and engine design and utility of future vehicle sales of roughly 16 

million units in the 2016 timeframe. For the current analysis, we are not differentiating 

between manufacturers, and consequently require fewer vehicle platforms for the analysis. 

The approximately sixty vehicle platforms are a result of mapping the 1130 vehicle fleet into 

the 19 engine based vehicle types (Table F1.5-1) and the 10 body size and structure based 

utility classes (Table F1.5-2). As not all vehicle types match to all utility types, the number of 

generic vehicles is less than the multiplicative maximum of the two tables. 

Table F1.5-1 : Vehicle Types in the TAR Analysis 

Vehicle Type # Name Cam Engine

1 Subcompact Car DOHC I4

2 Compact Car I4 DOHC I4

3 Midsize Car/Small MPV (unibody) DOHC I4

4 Compact Car/Small MPV (unibody) DOHC V6

5 Midsize/Large Car DOHC V6

6 Midsize Car/Large Car DOHC V8

7 Mid-sized MPV (unibody)/Small Truck DOHC I4

8 Midsize MPV (unibody)/Small Truck SOHC V6

9 Large MPV (unibody) SOHC V8

10 Large MPV (unibody) SOHC V8

11 Large Truck (+ Van) SOHC V6

12 Large Truck + Large MPV OHV V6

13 Large Truck (+ Van) OHV V8

14 Large Truck (+Van) SOHC3V V8

15 Large Car OHV V8

16 Large MPV (unibody) DOHC V6

17 Large MPV (unibody) DOHC V8

18 Large Truck (+ Van) DOHC V6

19 Large Truck (+ Van) DOHC V8

Table F1.5-2 : Vehicle Types in the Technical Assessment Analysis 

Utility 

Class #

Utility Class Vehicle Use 1Footprint Criteria Structure Criteria

1 Subcompact Auto Car Footprint <43 --

2 Compact Auto Car 43<=Footprint<46 --

3 Mid Size Auto Car 46<=Footprint<53 --
Appendix F 

F-8 

4 Large Auto Car 56<=Footprint --

5 Small SUV SUV 43<=Footprint<46 --

6 Large SUV SUV 46<=Footprint --

7 Small Pickup Pickup Footprint < 50 --

8 Large Pickup Pickup 50<=Footprint --

9 Cargo Van Van -- Ladder Frame

10 Minivan Van -- Unibody

1. Vehicle use type is based upon analysis of EPA certification data. 

F1.5.2 Accounting for Technology already on the Vehicles 

The market data input file utilized by OMEGA, which characterizes the vehicle fleet, 

is designed to account for the fact that the 2008 model year vehicles which comprise our 

baseline fleet may already be equipped with one or more of the technologies available in 

general to reduce CO2 emissions. As described in Appendix B, EPA decided to apply 

technologies in packages, as opposed to one at a time. However, 2008 vehicles were 

equipped with a wide range of technology combinations, many of which cut across the 

packages. Thus, EPA developed a method to account for the presence of the combinations of 

applied technologies in terms of their proportion of the EPA packages described in Chapter 3. 

This analysis can be broken down into four steps 

The first step in the updated process is to breakdown the available GHG control 

technologies into five groups: 1) engine-related, 2) transmission-related, 3) hybridization, 4) 

weight reduction and 5) other. Within each group we gave each individual technology a 

ranking which generally followed the degree of complexity, cost and effectiveness of the 

technologies within each group. More specifically, the ranking is based on the premise that a 

technology on a 2008 baseline vehicle with a lower ranking would be replaced by one with a 

higher ranking which was contained in one of the technology packages which we included in 

our OMEGA modeling. The corollary of this premise is that a technology on a 2008 baseline 

vehicle with a higher ranking would be not be replaced by one with an equal or lower ranking 

which was contained in one of the technology packages which we chose to include in our 

OMEGA modeling. This ranking scheme can be seen in the TEB/CEB calculation macro, 

available in the docket. 

In the second step of the process, we used these rankings to estimate the complete list 

of technologies which would be present on each baseline vehicle after the application of each 

technology package. We then used the EPA lumped parameter model to estimate the total 

percentage CO2 emission reduction associated with the technology present on the baseline 

vehicle (termed package 0), as well as the total percentage reduction after application of each 

package. This process was repeated to determine the total cost of all of the technology 

present on the baseline vehicle and after the application of each applicable technology 

package. 

The third step in this process is to determine the degree of each technology package’s 

incremental effectiveness and incremental cost is affected by the technology already present 

on the baseline vehicle. The degree to which a technology package’s incremental 

effectiveness is reduced by technology already present on the baseline vehicle is termed the 
2017-2025 Technical Assessment 

F-9 

technology effectiveness basis, or TEB, in the OMEGA model. The value of each vehicle’s 

TEB for each applicable technology package is determined as follows: 

1,

,

1,

,

,

1,

1

1

1

1

1

1

1

ip

ip

ip

ip

iv

iv

i

tTotalEffec

tTotalEffec

tTotalEffec

tTotalEffec

tTotalEffec

tTotalEffec

TEB

Where 

TotalEffectv,i = Total effectiveness of all of the technologies present on the baseline vehicle after 

application of technology package i 

TotalEffectv,i-1 = Total effectiveness of all of the technologies present on the baseline vehicle after 

application of technology package i-1 

TotalEffectp,i = Total effectiveness of all of the technologies included in technology package i 

TotalEffectp,i-1 = Total effectiveness of all of the technologies included in technology package i-1 

Equation 1.5-1 – TEB calculation 

The degree to which a technology package’s incremental cost is reduced by 

technology already present on the baseline vehicle is termed the cost effectiveness basis, or 

CEB, in the OMEGA model. The value of each vehicle’s CEB for each applicable 

technology package is determined as follows: 

CEBi = 1 – (TotalCostv,i – TotalCostv,i-1) / (TotalCostp,i – TotalCostp,i-1) 

Where 

TotalCostv = total cost of all of the technology present on the vehicle after addition 

of package i or i-1 to baseline vehicle v 

TotalCostp = total cost of all of the technology included in package i or i-1 

i = the technology package being evaluated 

i-1 = the previous technology package 

Equation 1.5-2 – CEB calculation 

The values of CEB and TEB are capped at 1.0 or less, since a vehicle cannot have 

more than the entire package already present on it. In other words, the addition of a 

technology package cannot increase emissions nor reduce costs. (A value of 1.0 causes the 

OMEGA model to not change either the cost or CO2 emissions of a vehicle when that 

technology package is added.) The value of a specific TEB or CEB can be negative, however. 

This implies that the incremental effectiveness or the incremental cost of adding a package 

can be greater than that when adding the packages in sequence to a vehicle with no baseline 

technology. 

An example of this is a baseline vehicle with a 6 speed manual transmission. All of 

our technology package effectiveness and cost estimates are estimated for specified baseline 

vehicles, all of which have 4 speed automatic transmissions. Our technology packages 

improve this transmission, sometimes to a 6 speed automatic transmission and then a dual 

clutch transmission and sometimes directly to a dual clutch transmission. Subsequent 
Appendix F 

F-10 

packages may then strongly hybridize the vehicle. If a baseline vehicle has a 6 speed manual 

transmission, this transmission is unaffected by the technology packages which include either 

a 6 speed automatic transmission or a dual clutch transmission, since the manual transmission 

is both cheaper and/or more efficient than these other transmissions. However, when the 

vehicle is hybridized, this manual transmission is replaced. The incremental cost of changing 

this vehicle to a power-split hybrid design, for example, is greater than that for a vehicle with 

a dual clutch transmission, since the credit for removing the manual transmission is less than 

that for the dual clutch transmission. The negative CEB causes the OMEGA model to apply a 

cost for this power-split package which is slightly higher than that for the typical baseline 

vehicle. 

The fourth step is to combine the fractions of the cost and effectiveness of each 

technology package already present on the individual 2008 vehicles models for each vehicle 

type. For cost, percentages of each package already present are combined using a simple 

sales-weighting procedure, since the cost of each package is the same for each vehicle in a 

vehicle type. For effectiveness, the individual percentages are combined by weighting them 

by both sales and base CO2 emission level. This appropriately weights vehicle models with 

either higher sales or CO2 emissions within a vehicle type. Once again, this process prevents 

the model from adding technology which is already present on vehicles, and thus ensures that 

the model does not double count technology effectiveness and cost associated with complying 

with the reference standards or the CO2 control scenarios. 

For this analysis, we automated the process through a visual basic macro that both 

operates the lumped parameter model and calculates the TEBs and CEBs. This macroenabled excel file is available in the docket. 

F1.6 Post-processing OMEGA 

F1.6.1 A/C Credits 

As noted above, A/C credits were simply subtracted off the OMEGA results for both 

the reference and control cases. A/C system costs were added into both cases. As a result, the 

delta between reference and control cases, both in terms of costs and environmental impact, 

did not change. 

F1.6.2 Calculating Technology Penetrations 

Technology penetrations were calculated using the new ―techpacksales‖ output file of the 

OMEGA model. This output provides, for each of the approximately 60 vehicle platforms, 

the distribution of sales among the tech packs. In a post-processing step, this distribution is 

applied back to the 1130 individual vehicles of the disaggregate baseline fleet projection so 

that we have the tech pack distribution of each vehicle. As discussed in the description of 

TEB/CEB calculations, we have already produced a file which contains the specific 

technologies on each vehicles with every possible technology package. By applying the 

technology pack distributions from the 60 vehicle platforms back against the 1130 vehicles in 

dissagregated fleet, we are able to determine the specific technologies on each vehicle in each 

scenario and tech pathway. As an example, this file would show what technologies are 
2017-2025 Technical Assessment 

F-11 

actually on a Ford F150 with technology package 1, 2, 3 etc. This file is combined with 

OMEGA’s technology pack distribution output to determine the penetration of each tracked 

technology. 

F1.6.3 Impacts Calculations 

Liquid fuel consumption, electricity consumption and emission impacts were 

calculated in a modified version of the post-processor spreadsheet that was used in the MY 

2012-2016 final rule. This spreadsheet, available in the downloadable material accompanying 

this technical assessment report, is the repository for the inputs discussed in Appendix E. The 

impacts calculations sequentially calculate light duty vehicle stock, VMT, and impacts for 

each MY and CY from 2010 through 2050. Outputs are available on either calendar year or 

model year basis. For this Technical Assessment Report, the VMT algorithm was integrated 

into the benefits calculations, electricity calculations were added, and the inputs and outputs 

were restructured. Provided the same inputs, the current benefits spreadsheet would still 

provide the same outputs as the version used in the MY 2012-2016 Final Rule. 

A detailed discussion of the benefits calculations algorithms is available in the MY 

2012-2016 Final Rule RIA chapter 5 and in the OMEGA users guide. 

We note that the current analysis did not rely upon many of the outputs of the 

OMEGA benefits post-processor. These outputs, such as co-pollutant impacts, monetized 

emission impacts, the benefits of additional travel time, and damages due to noise, accidents, 

and congestion, may not produce accurate results in the context of the numerous input 

changes, and should not be used. 
Appendix F 

F-12 

Appendix F References 

1

 Appendix A 

2

 Appendix B 

3

 http://www.epa.gov/oms/climate/regulations.htm 

4

 http://www.epa.gov/oms/climate/models.htm 

5

 EPA. LD GHG MY 2012-2016 Rule, RIA Chapter 2 and 5. 

6

 Appendix D to this report. 
2017-2025 Technical Assessment 

G-1 

G1 Appendix G: Infrastructure 

Appendix G contains a compilation of additional information to support Chapter 4, 

Infrastructure Assessment. Appendix G contains additional information covering the 

following topic areas: 

DOE-funded grants for electric drive demonstration and evaluation programs

Estimates of costs of charging equipment

Battery end of life value 

Voluntary standards

Hydrogen Infrastructure

G1.1 American Recovery and Reinvestment Act: Transportation Electrification 

Initiative 

 Through the American Recovery and Reinvestment Act of 2009 (ARRA), DOE has 

awarded cost-shared grants to companies under the Transportation Electrification Initiative to 

establish development, demonstration, evaluation, and education projects to accelerate the 

market introduction and penetration of advanced electric drive vehicles. The component 

projects of the Transportation Electrification Initiative and other DOE electric-drive vehicle 

infrastructure activities are discussed below. 

ECOtality North America 

ECOtality North America has been awarded a cost-shared grant of nearly $115 million 

to support ―The EV Project,‖ to deploy electric-drive vehicles and charging infrastructure in 

sixteen major U.S. cities beginning in 2010. Upon full deployment of vehicles and 

infrastructure under this project in 2011, approximately 8,500 electric drive vehicles and 

14,850 Level 2 charging stations will be in service, providing a rich set of data regarding the 

operational and charging behavior of electric drive vehicle owners in a variety of markets. 

The ECOtality project will install grid-connected vehicle infrastructure in Phoenix, 

AZ; Tucson, AZ; San Diego, CA; Los Angeles, CA; Portland, OR; Eugene, OR; Salem, OR; 

Corvallis, OR; Seattle, WA; Dallas, TX; Fort Worth, TX; Houston, TX; Nashville, TN; 

Knoxville, TN; Chattanooga, TN; and Washington, DC. Residential Level 2 charging stations 

will be provided at no cost to purchasers of the Nissan LEAF EV and the Chevrolet Volt 

Extended Range Electric Vehicle (EREV) who subscribe to the program. Additionally, Level 

3 DC ―fast‖ chargers will be installed along routes connecting neighboring cities – such as 

Nashville/Knoxville/Chattanooga, Phoenix/Tucson, and Seattle/Portland/Eugene – 

establishing a network of electric vehicle corridors between electric transportation hubs. 

More information about The EV Project is available at http://www.theevproject.com. 

Coulomb Technologies 
Appendix G 

G-2 

Coulomb Technologies has been awarded a cost-shared grant of $15 million to support 

its ―ChargePoint America‖ project, to deploy electric-drive vehicles and charging 

infrastructure in nine major metropolitan areas beginning in 2010. The project will result in 

the deployment of approximately 5,000 Level 2 charging stations at residential and 

commercial locations in Bellevue/Redmond, WA; Sacramento, CA; San Jose/San Francisco 

Bay, CA; Los Angeles, CA; Austin, TX; Detroit, MI; New York, NY; Washington, DC; and 

Orlando, FL. Residential chargers will be provided to purchasers of the Chevrolet Volt 

EREV – in some cases, at no cost – and will also be deployed in conjunction with electric 

drive vehicles from Ford and Smart USA. More information about ChargePoint America is 

available at http://www.chargepointamerica.com. 

Navistar 

Navistar was awarded a cost-shared grant of over $39 million to develop and 

demonstrate a fleet of all-electric medium-duty delivery trucks, which the company has 

named the eStar. These vehicles will be manufactured in Wakarusa, IN, and deployed 

through various fleet partners nationwide. In total, 950 Class 2c-3 electric trucks will be 

deployed in conjunction with 950 Level 2 charging stations, at locations specified by the 

respective fleet owners. Data collected from these vehicles and charging stations will provide 

valuable information regarding the performance and suitability of medium-duty electric 

vehicles and the infrastructure required to support them. More information about eStar trucks 

is available at http://www.estar-ev.com. 

General Motors 

General Motors was awarded a cost-shared grant of over $30 million to develop and 

deploy a fleet of Chevrolet Volt EREVs, and to gather data on vehicle performance and 

infrastructure requirements. A fleet of 125 Chevy Volts will be deployed in combination with 

over 650 Level 2 charging stations, through electric utility partners in several diverse 

geographic locations throughout the U.S. The project will include the installation, 

demonstration, and testing of charging infrastructure in residential, commercial, and public 

locations. Additionally, a comprehensive set of data will be collected from the vehicles and 

charging stations from December 2010 through 2012, and will contribute to a more complete 

understanding of typical vehicle usage and operational needs, supporting the next generation 

of vehicle designs and infrastructure planning. The project will also include an analysis of 

fast charging requirements and the development and demonstration of smart charging 

capabilities using General Motors‘ OnStar telematics service. 

Smith Electric Vehicles 

Smith Electric Vehicles has been awarded a $32 million cost-shared grant to develop 

and demonstrate a fleet of all-electric medium-duty trucks. Approximately 500 vehicles will 

be built in Kansas City, MO, and deployed with 500 Level 2 charging stations through fleet 

partners representing a range of commercial and public-sector markets in diverse geographic 

and climatic areas by the end of 2011. In addition, the project will include the collection of 

real-world performance data using an automatic GPS-based telemetry system. The Smith 

Electric Vehicles project, combined with the Navistar project, will provide valuable insight 
2017-2025 Technical Assessment 

G-3 

into the applicability of electric-drive powertrains in medium-duty trucks in a variety of 

vocations. More information about Smith Electric Vehicles is available at 

http://www.smithelectric.com. 

South Coast Air Quality Management District 

SCAQMD was awarded a cost-shared grant of over $45 million to develop, 

demonstrate, and evaluate a fleet of medium-duty plug-in hybrid electric trucks and shuttle 

buses. A total of 378 vehicles will be demonstrated nationwide, in combination with 378 

Level 2 charging stations. The majority of the vehicles will be bucket trucks based on the 

Ford F-550 chassis, deployed through electric utility partners, while the shuttle buses, based 

on the Ford E-450, will be deployed via shuttle bus fleet operators. Data collected from the 

fleet will be analyzed in order to quantify the attributes of PHEV technologies for Class 4/5 

vehicles in terms of emissions, greenhouse gas reductions, and fossil fuel displacement. An 

additional goal of the project is to develop production ready smart charging capability for 

commercial applications. More information about the current status of this program is 

available at http://www.aqmd.gov/hb/2010/july/100710a.htm. 

Chrysler Group LLC 

Chrysler has been awarded a $48 million cost-shared grant to develop and demonstrate 

153 plug-in hybrid electric Dodge Ram pickup trucks combined with Level 2 charging 

infrastructure. The trucks and charging stations will be deployed through partner fleets in 

diverse geographies and climates, spanning from North Dakota to Arizona, and from Hawaii 

to Massachusetts. Full deployment of the vehicles will be achieved in early 2011, followed 

by data collection and vehicle monitoring activities through 2013 in order to prove real-world 

product viability and to quantify the benefits to consumers and to the nation. As part of this 

project Chrysler, with support from its project partners, will develop and demonstrate bidirectional charging capability. 

Education Grants 

Through the Transportation Electrification Initiative, ten grants totaling nearly $40 

million were awarded to educational institutions to establish programs to train engineers, 

technicians, and emergency first responders, as well as to inform the general public, in 

preparation for the transition to vehicles with advanced electric drive technologies. At the 

university level, graduate and undergraduate engineering degree programs will be created to 

educate students in technologies related to electric drive vehicles and charging infrastructure. 

Several community colleges received grants to establish technical training courses and 

certificate programs to train service personnel and automotive technicians to properly service 

and maintain vehicles with electric drive powertrains. Similarly, electric vehicle safety 

training programs will be created to train emergency personnel in proper safety protocols 

related to electric vehicles and infrastructure, which will differ from current vehicles and 

infrastructure with which first responders are already familiar. Furthermore, consumer 

outreach and K-12 educational materials will be created to familiarize the general public with 

electric-drive vehicle capabilities and infrastructure utilization. All of these activities will 

take place through projects supported by Transportation Electrification grants awarded to the 
Appendix G 

G-4 

University of Michigan, J. Sargeant Reynolds Community College, West Virginia 

University/National Alternative Fuels Training Consortium, Michigan Technological 

University, Missouri University of Science and Technology, Wayne State University, 

Colorado State University, Purdue University, City College of San Francisco, and the 

National Fire Protection Association. 

G1.2 Charger Cost Estimates 

The following list of charger cost estimates details the sources and the respective 

estimates pulled from each that were used in constructing the charger cost estimate Table 4.2-

2, ―Estimated Costs for Charging Stations‖. Here, the estimates are listed by source along 

with assumptions and context that are relevant to the cost estimate. 

Level 1 

1. Residential (Morrow, Karner and Francfort, 2008)1

a. Charge cord + circuit installation, 20A $878 

2. Public networked (May and Mattila, 2009)2

a. 12A stations (Coulomb Technologies) $2500 each + $1000 for ―gateway‖ station 

3. Public (May and Mattila, 2009)3

a. 20 amp/4 vehicle (Shorepower Technologies/SynkroMotive) $2500-$2900 

4. Apartment complex, not networked (5 stations) (Morrow, Karner and Francfort, 2008)4

a. 5 charge cords $1250 

b. 5 20 amp circuits $2221 

c. Installed $4165 

Level 2, Residential or Fleet Depot 

1. Residential, no service panel upgrade (ETEC, 2009)5

a. 40 amp EVSE $780 

b. Installed $2272 

2. Residential (Morrow, Karner and Francfort, 2008)6

a. EVSE 32 amp $650 

b. Charge cord $200 

c. 40 amp circuit $1080 

d. Installed $2146 

3. Residential, no upgrade (May and Mattila, 2009)7

a. 9-25 amp EVSE, output 3.3 kW (Brusa/Metric Mind) $3870 - $6353 

4. Residential (Electrification Coalition, 2009)8

a. No upgrade $500-$1500 

b. With upgrade, ―up to $2500‖) 

5. Commercial Fleet (10 stations) (ETEC, 2009)9

a. Distribution panel $650 

b. EVSE 40 amp $780 * 10 

c. EVSE Pedestal $450 * 10 

d. Installed $31,375 
2017-2025 Technical Assessment 

G-5 

e. $3138/station 

6. Apartment complex, not networked (5 stations) (Morrow, Karner and Francfort, 2008)10

a. 5 EVSEs $3250 

b. 5 charge cords $1000 

c. 5 circuits $2611 including labor costs for circuits and EVSEs 

d. Installed $7597 for 5 stations 

e. $1520/station 

Level 2, Public 

7. Public (2 chargers) (ETEC, 2009)11

a. Distribution sub-panel $250 

b. EVSE 40 amp $780 * 2 

c. EVSE Pedestal $450 * 2 

d. Installed $12,875 

e. $6438/station 

8. Public networked (May and Mattila, 2009)12

a. 32 amp stations (Coulomb Technologies) $3500 each + $1000 for ―gateway‖ station 

b. 120 amp stations, charges 4 vehicles (EV-Charge America) $1200-$1500 

c. 16.8 kW smart station (GoSmart Technologies) $2200-$3800 

d. Above apparently are hardware only 

9. Public stations (May and Mattila, 2009)13

a. Pre-assembled unit, $1400-$1800/single 24-30 amp, $2800/60 amp double (eTec) 

10. Public (Electrification Coalition, 2009)14: up to $5,000 

Level 3, Public Quick Charge 

1. Public Level 3 (2 stations) (ETEC, 2009)15

a. Distribution sub-panel $650 

b. Fast charger (30 kW) $25,000 * 2 

c. Point of sale system $2500 

d. Installed $64,158 

2. Unspecified (Electrification Coalition, 2009)16 $25,000-$50,000 

3. Nissan 50 kW Quick EV Charger, CHAdeMO standard, manufacturer‘s suggested retail price, 

not including installation $17,500 – 20,600A,17

4. Confidential submission, EVSE in high volume, direct manufacturing cost, not including 

installation $8,000B

The range in the costs for quick-charge EVSEs reflects a difference between current, 

relatively low volume public quick-charge EVSEs and a future EVSE incorporating multiple 

 

A

 Lower cost is base unit, higher cost reflects options for hot or cold climate operation. 

B

 Confidential information provided to EPA, ARB and NHTSA, August 2010. Manufacturing cost and general 

description of architecture cleared for release by the original source on September 10, 2010. 
Appendix G 

G-6 

chargers of the same type used for on-vehicle charging in order to share economies of scale 

between EVSEs and components sourced in much higher volume for automobile production. 

This would be expected to provide a significant cost reduction for some of the most expensive 

components within public quick-charge EVSEs. 

G1.3 Battery End-of-Life Value Potential 

Chapter 4.2.4 discusses issues surrounding the assessment of a secondary use value for 

EV/PHEV batteries. Work is underway to study this issue, including the extent of the market 

for secondary use batteries and the potential value to the original vehicle purchaser. This 

section summarizes one such study supported by DOE. 

Accelerated development and market penetration of PHEVs and EVs is presently 

restricted by the high cost of lithium-ion (Li-Ion) batteries. In fact, it has been estimated that a 

~50% reduction in battery costs is necessary to equalize the current economics of owning 

PHEVs and conventionally fueled vehicles.18

One way to address this problem is to recover a fraction of the battery cost via reuse in 

other applications after it is retired from service within the vehicle, where it may still have 

sufficient performance to meet the requirements of other energy storage applications. By 

extracting additional services and revenue from the battery in a post-vehicle application, the 

total lifetime value of the battery is increased. 

There are several current and emerging applications where the secondary use of PHEV 

and EV batteries may be beneficial. For example, the use of renewable solar and wind 

technologies to produce electricity is growing, and their increased market penetration requires 

energy storage to mitigate the intermittency of wind and solar energy. New trends in utility 

peak load reduction, energy efficiency, and load management also need energy storage. Smart 

grid, grid stabilization, low-energy buildings, and utility reliability require energy storage as 

well. It is reasonable to suggest that some utility applications are capable of supporting 

2010‘s new battery prices.19 20 21 Assuming that battery prices fall faster than the value of 

these utility applications (not improbable, given the anticipated decline in battery prices and 

that the increased presence of renewable generation should drive utility application values 

higher), the same will be true in the 2017-2025 time frame. 

Thus, substantial markets for used automotive batteries may exist, and given that the 

allowable battery costs for these applications will exceed new battery prices, battery salvage 

values must be determined relative to competing products rather than application values. 

Assuming that a primary competitor is new automotive Li-Ion batteries, salvage values can be 

computed based upon anticipated future Li-Ion prices. Additionally, the salvage value must be 

greater than the ―competing‖ application of leaving the battery in the aging vehicle and 

accepting its reduced range capability or selling it to someone with reduced range 

requirements. Under these assumptions, it is reasonable to assume that the future salvage 

value of a used PHEV/EV battery will be proportional to the cost of an equally capable new 

battery, taking into consideration the health of the used battery, the cost of collecting, 

refurbishing, and certifying the used battery, and a  ̳used‘ product discount factor. Given 

efforts to ramp up automotive battery production between 2010 and 2015, it is reasonable to 
2017-2025 Technical Assessment 

G-7 

assume that such batteries will be a relatively mature product and that the majority of the 

benefits owed to economies of scale will be achieved by 2017, leading to the following: 

· Battery life will be improved such that 10 years of in-vehicle life is common and 

significant health remains in the battery post automotive retirement 

· Battery price reduction across the battery life will be relatively small 

· Batteries will be treated as a commodity, thus used product discounts will be 

fairly low 

· Recognizing the value of secondary use and leveraging advances in battery 

health monitoring, automotive batteries will be designed to minimize reconditioning costs 

Based on the preceding conditions, one study estimates that net present salvage values 

for EV/PHEV batteries sold in the 2017-2025 time frame are approximately 20% of their 

initial purchase price.22

G1.4 List of Voluntary Standards 

This list of voluntary standards illustrates the complexity and interrelationships due to 

the addition of communication to the interface between the vehicle and each major element of 

the consumer-vehicle-grid system. These efforts are to enhance long-term success; however, 

they are not a prerequisite for a successful near-term market launch. It is worth noting that 

the SAE J1772 standard is complete, which is a significant development; many others are still 

under development. 

SAE – The following existing standards were identified in the Phase 1 NIST 

Framework and Roadmap for Smart Grid Interoperability StandardsCas standards that can be 

used now to support Smart Grid development: 

SAE J1772 Electrical Connector between PEVD/EV and EVSE 

o SAE J1772TM Electric Vehicle and Plug in Hybrid Electric Vehicle 

Conductive Charge Coupler 

SAE J2293 Communications between PEVs and EVSE for DC Energy [Part 1, 

Part 2] 

o SAE J2293/1 Energy Transfer System for Electric Vehicles: 

Functional Requirements and System Architectures 

 

C Available at http://www.nist.gov/public_affairs/releases/upload/smartgrid_interoperability_final.pdf (last 

accessed August 26, 2010). 

D

 ―PEV‖ (plug-in electric vehicle) is SAE‘s language of choice for what is called a PHEV elsewhere in this 

document. 
Appendix G 

G-8 

o SAE J2293/1 Energy Transfer System for Electric Vehicles: 

Communication Requirements and Network Architecture 

SAE J2836/1-3 Use Cases for PEV Interactions (in development) [Part 1, Part 2, 

Part 3] 

o J2836/1 Use Cases for Communication between Plug-in Vehicles 

and the Utility Grid 

o J2836/2 Use Cases for Communication between Plug-in Vehicles 

and the Supply Equipment (EVSE) 

o J2836/3 Use Cases for Communication between Plug-in Vehicles 

and the Utility Grid for Reverse Power Flow 

o J2836/4 Use Cases for Diagnostic Communication for Plug-in 

Vehicles 

o J2836/5 Use Cases for Communication between Plug-in Vehicles 

and their customers. 

SAE J2847/1-3 Communications for PEV Interactions (in development) [Part 1, 

Part 2, Part 3] 

o J2847/1 Communication between Plug-in Vehicles and the Utility 

Grid 

o J2847/2 Communication between Plug-in Vehicles and the Supply 

Equipment (EVSE) 

o J2847/3 Communication between Plug-in Vehicles and the Utility 

Grid for Reverse Power Flow 

o J2847/4 Diagnostic Communication for Plug-in Vehicles 

o J2847/5 Communication between Plug-in Vehicles and their 

customers 

J2894 Power Quality Requirements for Plug-in Vehicle Chargers – Part 1: 

Requirements 

J2894/2 Power Quality Requirements for Plug-in Vehicle Chargers – Part 2: Test 

Methods

J2931/1 Power Line Carrier Communications for Plug-in Electric Vehicles 
2017-2025 Technical Assessment 

G-9 

IEEE – Standards Coordinating Committee 21 (SCC21) sponsors the development of 

1547 interconnection standards and the P2030 smart grid interoperability standards project. 

IEEE 1547 Standard for Interconnecting Distributed Resources with Electric 

Power Systems 

IEEE P2030 Guide for Smart Grid Interoperability of Energy Technology and 

Information Technology and Information Technology Operation with the Electric 

Power System (EPS) and End-Use Applications and Loads 

UL – Underwriters Laboratories plays a critical role in the certification of hardware to 

be used in charging. UL offers certification for the many aspects of the EVSE, including the 

charge equipment (Levels 1-3), plugs, receptacles, cord sets and personal protection 

equipment. Of particular interest are specifications with respect to grounding/isolation. 

NFPA - NEC, part 625, specifically addresses the installation of charging equipment. 

It is updated every 3 years; currently NEC-2008 applies and inputs/petitions for the next 

version (NEC-2011) are closed. The draft national template project relies heavily on the NEC 

as it is the primary reference for permitting and installation in local municipalities. 

International - SAE and JARI agree on Level 2 charging standards (both countries 

use single-phase current); though, high-power Level 3 DC coupler standards for public 

charging differ substantially from those proposed in the U.S. (and Europe so far). The JARI 

Level 3 standards are promoted by CHAdeMO, an association formed in Japan to promote 

global adoption of JARI EV infrastructure standards, and are used on the TEPCO charge 

equipment that will be deployed by the ARRA-funded vehicle demonstration program (along 

with the Nissan Leaf EV); a U.S. Level 3 standard has yet to be developed. Though proposed 

charge coupler standards are constantly being refined, the following chart was recently 

developed to explain the differences at this time. 
Appendix G 

G-10 

Figure G1.4-1: International Charge Couple ComparisonE

G1.5 Hydrogen Infrastructure 

Section 4.3 in Chapter 4, Infrastructure Assessment, contains an overview of hydrogen 

refueling technology and availability. This section provides additional details about hydrogen 

infrastructure including costs, standards, and codes for hydrogen infrastructure installation. 

G1.5.1 Cost of Hydrogen 

This section summarizes slides taken from a presentation by Professor Joan Ogden of 

the Institute of Transportation Studies University of California, Davis. 23

The slides indicate projected cost of hydrogen in various U.S. cities from 2014 to 

2030, U.S. average delivered hydrogen cost through 2050 and hydrogen transition timing and 

costs. 

 

E

 Level 2 is up to 80 amp, but typically 16-32 amp 

Residential Charging

Overnight

AC Level 1: 120V 1 ф, 16A AC Level 2: 240V 1ф, 80A

AC Level 2: 240V 1ф, 80A

Public Opportunity Charging

~1 mile/minute of charge

Public Fast Charging

~ 3-10 miles/minute of charge

Combined SAE J1772TM and DC Level 3

(TBD)

AC Level 1: 100V 1ф, 16A AC Level 2: 200V 1ф, 80A

AC Level 2: 200V 1ф, 80A

AC Mode 1: 250V 1ф/480V 3ф, 16A AC Mode 2: 250V 1ф/480V 3ф, 32A

AC Mode 2: 250V 1ф/480V 3ф, 32A 

AC Level 3: <500V DC/<100kW

(TBD – CHAdeMO)

AC Mode 1: 220V 3ф, 16A AC Mode 2: 220V AC 3ф, 32A 

AC Mode 2: 220V 3ф, 32A (TBD)

DC Mode 3: 400V/750V DC/<240kW;

125A/250A/400A (TBD)

DC Mode 3: < 500V DC/<100kW

(TBD)

SAE J1772TM

SAE J1772TM

IEC 62196-2 Type 2

JEVS G105-1993

(Re-configured) IEC 62196-2 Type 2

BYD example

AC L1: 120V AC 1 ф, 12-16A/1.44-1.92kW

AC L2: 240V AC 1ф, 80A/19.2kW

AC L2: 240V AC 1ф, 80A/19.2kW AC L3: 240V AC 1ф, 400A (TBD 1ф or 3ф?)

DC L1: 200-450V DC, 80A/19.2kW DC L3: (TBD) 200-600V DC, ≤ 400A/≤ 240kW

DC L2: 200-450V DC, 200A/90kW

SAE J1772TM charging configurations and max ratings (ref: Kissel, June 2010)

Plugging in Internationally

[Standard/proposed charge couplers]

SAE J1772TM plus DC pins

KH_ANL
2017-2025 Technical Assessment 

G-11 

Figure 1.5-1: Cost of Hydrogen in Selected US Cities (UCD SSCHISM Model) 

J. Ogden and C. Yang, "Build-up of a hydrogen infrastructure in the US," Chapter 15, 

in The Hydrogen Economy: Opportunities and Challenges, edited by Dr Michael Ball and Dr 

Martin Wietschel, Cambridge University Press, 2009, pp.454-482. 

In certain regions, such as Los Angeles, hydrogen cost for infrastructure is projected to 

decrease rapidly between 2015 and 2018 as FCEVs are rolled out. 

Figure 1.5-2: US Average Delivered Hydrogen Cost (NRC 2008), Electricity and 

Gasoline Price (EIA 2008) 
Appendix G 

G-12 

National Research Council, National Academies of Engineering, Transitions to 

Alternative Transportation Technologies: A Focus on Hydrogen, Pre-publication version 

available from National Academies website 

http://www.nap.edu/catalog.php?record_id=12222 

Studies by UC Davis indicate that hydrogen costs can be competitive with gasoline in 

2020. Note that 1 kg of hydrogen has approximately the same energy content (lower heating 

value) as 1 gallon of gasoline (1kg hydrogen = 1 gallon gasoline equivalent (gge) 

National Research Council, National Academies of Engineering, Transitions to 

Alternative Transportation Technologies: A Focus on Hydrogen, Pre-publication version 

available from National Academies website 

http://www.nap.edu/catalog.php?record_id=12222

In 2008, the NRC‘s Committee on Assessment of Resource Needs for Fuel Cell and 

Hydrogen Technologies released the report, ―Transitions to Alternative Transportation 

Technologies—A Focus on Hydrogen,‖ which was required by the Energy Policy Act (2005) 

section 1825. One of the committee's conclusions was that to accelerate the penetration of 

FCEVs, strong government policies will be required. The NRC estimated that the 

government cost to support a transition to FCEVs for the period from 2008 to 2023 would 

be approximately $55 billion (this amounts to slightly more than $3.5 billion/year or about 

$10,000 per FCEV—the committee compared this value to ethanol subsidies, which were 

$2.6 billion in 2006 and are expected to grow to $15 billion/year by 2015). The table shows 

details on government costs required for infrastructure. 
2017-2025 Technical Assessment 

G-13 

G1.5.2 Codes and Standards to Support Hydrogen and Fuel Cell Infrastructure 

The United States and most countries in the world have established laws and 

regulations that require commercial products to meet all applicable codes and standards to 

demonstrate that they are safe, perform as designed and are compatible in the systems in 

which they are used. Hydrogen has an established history of industrial use as a chemical 

feedstock, but not as an energy carrier on a large-scale commercial basis. The development 

and promulgation of codes and standards are essential to establish a market-receptive 

environment for commercial, hydrogen-based products and systems for energy use. 

The key U.S. and international standards development organizations (SDOs) 

developing and publishing the majority of hydrogen codes and standards are shown in the 

table below. These organizations typically work with the public and private sectors to 

develop codes and standards. 

The U.S. Department of Energy (DOE) conducts underlying safety R&D and works 

with domestic and international SDOs to facilitate the development of applicable codes and 

standards. These standards are then referenced by building and other codes to expedite 

regulatory approval of hydrogen technologies. This approach ensures that U.S. consumers can 

purchase products that are safe and reliable, regardless of their country of origin, and that U.S. 

companies can compete internationally.24

Organizations Involved in Codes and Standards Development and Publication

Organization Responsibility

Domestic Codes and Standards

American Society for Testing and Materials Materials testing standards and protocols

(ASTM)

American National Standards Institute (ANSI)

Certifies consensus methodology of and serves as 

clearinghouse for codes and standards development

American Petroleum Institute (API) Equipment standards

American Society of Heating, Refrigeration Equipment design and performance standards

and Air Conditioning Engineers (ASHRAE)

American Society of Mechanical Engineers Equipment design and performance standards

(ASME)

Compressed Gas Association (CGA) Equipment design and performance standards

CSA America (CSA) Equipment standards
Appendix G 

G-14 

U.S. Department of Transportation Vehicle standards and regulations

International Association of Plumbing and Mechanical building code

Mechanical Officials (IAPMO)

Institute of Electrical and Electronic Engineers Electrical standards

(IEEE)

National Fire Protection Association (NFPA) Model building codes, standards

Natural Gas Institute (NGI) Natural gas vehicle standards

Society of Automotive Engineers (SAE)

Vehicle system and subsystem design and 

performance standards

Underwriters Laboratories (UL) Equipment and performance testing standards

International Electrotechnical Commission (IEC) International Performance Standards

International Organization for Standardization 

(ISO) International Performance Standards

In February 2010, the National Renewable Energy Laboratory (NREL) published the 

Vehicle Codes and Standards: Overview and Gap Analysis. The gap analysis includes a list 

of applicable codes and standards for alternative fuels including hydrogen infrastructure. The 

list of applicable codes and standards is below:25

ANNUAL INSPECTIONS 

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas 

Association 2005) 

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004) 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)

BALANCE OF PLANT 

Piping & Tubing 

ASME B31.12, Hydrogen Piping and Pipelines 

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas 

Association 2005) 

IFC (International Code Council 2006) 

International Fuel Gas Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

CGA H-3 Cryogenic Hydrogen Storage (Compressed Gas Association 2006) 

Pressure Relief 

CGA S-1.3, PRD Standards Part 3 - Stationary Storage Containers for Compressed Gases

(Compressed Gas Association 2005) 

IFC (International Code Council 2006) 
2017-2025 Technical Assessment 

G-15 

International Fuel Gas Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Valving and Fittings 

ASME B31.3, Process Piping (American Society of Mechanical Engineers 2006) 

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas 

Association 2005) 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Venting and Other Equipment 

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004) 

IFC (International Code Council 2006) 

International Fuel Gas Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

CANOPY TOPS 

International Building Code (International Code Council 2009) 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

COMPRESSED HYDROGEN GAS STORAGE 

Equipment Location 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

General Safety Requirements 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Storage Containers 

CGA PS-20, Direct Burial of Gaseous Hydrogen Storage Tanks (Compressed Gas Association 

2006) 

CGA PS-21, Adjacent Storage of Compressed Hydrogen and Other Flammable Gases 

(Compressed Gas Association 2005) 

IFC (International Code Council 2006) 
Appendix G 

G-16 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

COMPRESSION SYSTEMS AND EQUIPMENT 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

DESIGN 

Barrier Walls 

IFC (International Code Council 2006) 

Equipment 

International Fire Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Fuel Stations 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

Equipment 

International Fire Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Fuel Stations 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Weather Protection 

IFC (International Code Council 2006) 

DISPENSING 

Electrical Equipment 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection

Association 2003)

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Fuel Lines 

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas 

Association 2005) 

IFC (International Code Council 2006) 

International Fuel Gas Code (International Code Council 2006) 
2017-2025 Technical Assessment 

G-17 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Gaseous Dispensers 

IFC (International Code Council 2006) 

Facilities 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Hoses and Connectors 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Liquid Dispensers 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Vehicle Connectors 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

SAE J2600, Compressed Hydrogen Surface Vehicle Refueling Connection Devices (Society of 

Automotive Engineers 2002) 

DISPENSING, OPERATIONS, AND MAINTENANCE SAFETY 

Gaseous Hydrogen 

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004) 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Liquid Hydrogen 

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004) 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

FIRE SAFETY 

Construction 

IFC (International Code Council 2006) 

International Fuel Gas Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Equipment 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 
Appendix G 

G-18 

Signage 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

LIQUID HYDROGEN STORAGE 

Equipment Location 

IFC (International Code Council 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

General Safety Requirements 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Storage Containers 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

CGA H-3 Cryogenic Hydrogen Storage (Compressed Gas Association 2006) 

ON-SITE HYDROGEN PRODUCTION 

IFC (International Code Council 2006) 

International Fuel Gas Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

OPERATION APPROVALS 

Dispensing 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Fire And Emergency Planning 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 
2017-2025 Technical Assessment 

G-19 

Fuel Delivery 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Ignition Control 

IFC (International Code Council 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Personnel Issues and Training 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Signage 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Vehicle Access 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

SETBACKS AND FOOTPRINTS 

Liquid Systems 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic 

Fluids in Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection 

Association 2005) 

Outdoor Gaseous Systems 

IFC (International Code Council 2006) 
Appendix G 

G-20 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

TRANSPORTATION 

Compressed Hydrogen Gas 

CGA P-1, Safe Handling of Compressed Gases in Containers (Compressed Gas Association 2006) 

IFC (International Code Council 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Liquid Hydrogen 

CGA P-12, Safe Handling of Cryogenic Liquids (Compressed Gas Association 2005) 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Natural Gas 

ASME B31.8, Gas Transmission and Distribution Systems (American Society of Mechanical 

Engineers 2003) 

VAPORIZERS 

IFC (International Code Council 2006) 

IFC (International Code Council 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

The table below provides a summary of the identified Code and Standards Gaps for the 

expanded use of hydrogen as an alternative fuel. Also, the table presents the impacted document 

and proposed means to address the gap. It also illustrates the various areas of hydrogen codes and 

standards that require additional work in order to create a complete and standardized control 

strategy. 

One key area that may require additional work is operations and maintenance 

requirements for fuel dispensing systems. This area is of particular concern because relatively 

little data for the use of vehicular hydrogen dispensing systems exists. As data is accrued, it may 

become apparent that additional safety measures are needed to address operations and 

maintenance. A second area of concern is potential releases of hydrogen in confined spaces such 

as indoor fueling operations, tunnels, and parking garages. The release characteristics and 

prevention and mitigation measures vary for these different locations, but many of the same 

analytical tools can be used to characterize the hazards of these releases. A third area of concern is 

the potential energy contained in high-pressure storage and dispensing systems. The following 

table lists several other important gaps that require further work. 
2017-2025 Technical Assessment 

G-21 

Codes and Standards Gaps for Hydrogen 25

Codes or Standard Gap Documents Impacted Gap Resolution

No final fuel quality 

standard 

ISO Fuel Quality Draft 

International Standard, 

ASTM analysis standards, 

SAE Technical Information 

Report (TIR) J2719 

Provide data to ensure that 

draft standards become final 

standards 

Potentially incomplete 

requirements for indoor 

hydrogen vehicle dispensing 

NFPA 52, IFC Evaluate indoor release 

characteristics and accident 

scenarios for potential 

application to code 

development 

Off road vehicle storage 

tank standards are 

incomplete 

CSA America Heavy Goods 

Vehicle (HGV) 4.3, SAE 

J2601 

Support standards 

development work with 

direct committee 

involvement and data 

support 

Bulk liquefied hydrogen 

storage requirements lack 

technical basis 

documentation 

NFPA 55, NFPA 2, IFC Evaluate liquid release 

impacts and frequencies and 

provide this information to 

relevant technical 

committees to validate or 

revise bulk liquefied 

hydrogen storage 

requirements 

Requirements for tunnels, 

parking garages, and repair 

garages need review to 

determine whether 

additional requirements for 

hydrogen are needed 

[meeting with New York 

Port Authority January 

2009] 

NFPA 505, IFC, NFPA 88B, 

NFPA 30A, IBC, 

International Mechanical 

Code (IMC) 

Evaluate safety concerns in 

these environments and 

work with the technical 

committees to provide data 

required to address codes 

and standards requirements 
Appendix G 

G-22 

Operations and maintenance 

procedures lack supporting 

operational history data 

[conversation with Larry 

Fluer] 

NFPA 52, NFPA 30A, IFC Evaluate existing procedures 

to determine where they 

might be incomplete. 

Evaluate operations and 

maintenance history for 

similar fuels to determine 

whether useful information 

can be retrieved and applied 

to hydrogen 

Steam Methane Reformation 

(SMR) plants do not have a 

safety standard 

[conversation with Roger 

Smith] 

No current code specifically 

addresses SMR plants 

Develop a code or standard 

that addresses SMR plants 

New storage systems, such 

as metal hydrides, are 

minimally addressed in 

codes and standards 

NFPA 55, CGA H-1 and H2, IFC Determine whether new 

chemical storage systems are 

adequately addressed in 

codes and standards 

Limited familiarity with 

relevant hydrogen codes and 

standards among project 

developers and code 

officials [conversation with 

Larry Fluer] 

All hydrogen codes and 

standards 

Regional codes and 

standards workshops as well 

as web training and 

background information can 

help address this issue

Incomplete requirements for 

sensing technologies [Rivkin 

analysis of NFPA 52] 

NFPA 52, NFPA 55 Support the use of sensing 

technologies that replace 

odorants through evaluating 

sensing technologies and 

supporting code and 

standards development work 

in sensing technologies 

High-pressure storage, 

handling, and use of 

hydrogen [David Farese 

DOE Safety Panel meeting] 

NFPA 52, NFPA 55, CGA 

H series of documents 

Evaluate codes and 

standards that address highpressure storage to 

determine if requirements 

are adequate and if 
2017-2025 Technical Assessment 

G-23 

additional work is required 

Global Technical 

Regulations (GTR) 

Coordination with SAE and 

DOT regulations 

Continue to represent the 

United States in GTR 

development meetings and 

evaluate impacts of GTR in 

domestic regulations, codes, 

and standards 

Coordination of 

international (primarily ISO) 

standards and domestic 

codes and standards 

Multiple documents: SAE, 

CSA, UL, NFPA 

Evaluate component 

standards to ensure that 

there are not unnecessary 

conflicts 

The DOT guidance 

documents for incidents 

involving flammable gases 

are too general and 

prescriptive 

DOT Emergency Response 

Guide 

Add additional material to 

the DOT guide for hydrogen 

incidents 
Appendix G 

G-24 

Appendix G References 

1

 Morrow, Karner, Francfort (2008). ―Plug-in Hybrid Electric Vehicle Charging Infrastructure Review‖, Battelle 

Energy Alliance, U.S. Department of Energy Idaho National Laboratory. Nov 2008. 

2

 May, James W. and Matt Mattila (2009). ―Plugging In: A Stakeholder Investment Guide for Public ElectricVehicle Charging Infrastructure.‖ Rocky Mountain Institute. July 2009. 

3

 May and Mattila, 2009. 

4

 Morrow, Karner, Francfort, 2008. 

5

 Electric Transportation Engineering Corporation (ETEC), 2009. Electric Vehicle Charging Infrastructure 

Deployment Guidelines British Columbia, July. 

Also, Electric Transportation Engineering Corporation (2010), Electric Vehicle Charging Infrastructure 

Deployment Guidelines for the Central Puget Sound Area, May. 

6

 Morrow, Karner, Francfort, 2008. 

7

 May and Mattila, 2009.. 

8

 Electrification Coalition (2009). ―Electrification Roadmap‖, Electrification Coalition. Nov 2009. 

9

 ETEC, 2009. 

10 Morrow, Karner, Francfort, 2008. 

11 ETEC, 2009. 

12 May and Mattila, 2009. 

13 May and Mattila, 2009. 

14 Electrification Coalition, 2009. 

15 ETEC, 2009. 

16 Electrification Coalition, 2009. 

17 Press release from Nissan, May 2010, accessed on the Internet at: http://www.nissanglobal.com/EN/NEWS/2010/_STORY/100521-01-e.html. 

18 Brooker, et al (2010), ―Technology Improvement Pathways to Cost-Effective Vehicle Electrification,‖ to be 

presented at the SAE 2010 World Congress, Detroit, MI, April 2010. 

19 Energy Storage for the Electricity Grid: Benefits and Market Potential Assessment Guide, Sandia National 

Laboratories, Albuquerque, NM: 2010. 

20 Kamath (2010), ―Lithium Ion Batteries in Utility Applications‖, Proceedings of the 27th International Battery 

Seminar and Exhibit, Ft. Lauderdale, FL, March 2010. 

21 Market Feasibility for Nickel Metal Hydride and Other Advanced Electric Vehicle Batteries in Selected 

Stationary Applications, EPRI, Palo Alto, CA, and SMUD, Sacramento, CA: 2000. 
2017-2025 Technical Assessment 

G-25 

22 Neubauer, Jeremy and Ahmad Pesaran (2010), Preliminary EV/PHEV Battery Secondary Use Analysis in 

Support of EPA 2017-2025 Technical Assessment. 

23 Slides from a Presentation by Prof Joan Ogden. ―What is needed to initiate new fuel/vehicle pathways? 

Comparing Transition Costs for H2 FCVs, PHEVs and Biofuels.‖ Prof. Joan Ogden, Institute of Transportation 

Studies, University of California, Davis, June 14, 2010. 

24 MYPP (Multi-Year Research, Development, and Demonstration Plan) 2007. Hydrogen Codes and Standards. 

Washington, D.C.: U.S. Department of Energy, Energy Efficiency and Renewable Energy. 

http://www1.eere.energy.gov/hydrogenandfuelcells/mypp/pdfs/codes.pdf

25 NREL (National Renewable Energy Laboratory) 2010. Vehicle Codes and Standards: Overview and Gap 

Analysis. Washington, D.C.: U.S. Department of Energy, Energy Efficiency and Renewable Energy. 

www.nrel.gov/docs/fy10osti/47336.pdf