Technologies Considered in the Agencies’ Analysis 

3-1 

Table of Contents 

CHAPTER 3: TECHNOLOGIES CONSIDERED IN THE AGENCIES’ 

ANALYSIS 2

3.1 HOW DO THE AGENCIES DECIDE WHICH TECHNOLOGIES TO 

INCLUDE IN THE ANALYSIS? ........................................................................... 2

3.1.1 REPORTS AND PAPERS IN THE LITERATURE .............................. 2

3.1.2 FUEL ECONOMY CERTIFICATION DATA ...................................... 3

3.2 WHICH TECHNOLOGIES WILL BE APPLICABLE IN THE 

RULEMAKING TIME FRAME? .......................................................................... 4

3.3 WHAT TECHNOLOGY ASSUMPTIONS HAVE THE AGENCIES USED 

FOR THIS PROPOSAL? .................................................................................... 888

3.3.1 HOW ARE THE TECHNOLOGIES APPLIED IN THE AGENCIES’ 

RESPECTIVE MODELS? .................................................................................. 888

3.3.2 HOW DID THE AGENCIES DEVELOP TECHNOLOGY COST AND 

EFFECTIVENESS ESTIMATES FOR THE PROPOSAL? ....................... 101010

3.3.2.1 Considerations that affect technology effectiveness ............................ 101010

3.3.2.1.1 Technology synergies ....................................................................... 101010

3.3.2.2 Considerations that affect technology costs ........................................ 111111

3.3.2.2.1 Direct manufacturing costs .............................................................. 121212

3.3.2.2.2 Cost markups to account for indirect costs ..................................... 141414

3.3.2.2.3 Concept behind and development of indirect cost multipliers ....... 141414

3.4 SPECIFIC TECHNOLOGIES CONSIDERED AND ESTIMATES OF 

COSTS AND EFFECTIVENESS ................................................................. 212121

3.4.1 WHAT DATA SOURCES DID THE AGENCIES EVALUATE? 212121

3.4.2 INDIVIDUAL TECHNOLOGY DESCRIPTIONS AND 

COST/EFFECTIVENESS ESTIMATES ..................................................... 212121

3.5 COST AND EFFECTIVENESS TABLES .......................................... 852984

3.5.1 NHTSA cost and effectiveness tables ............................................... 852984

3.5.2 EPA cost and effectiveness tables .................................................. 1002998

Appendix 3.A ................................................................................................... 10529103

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Draft Joint Technical Support Document 

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* Due to the extremely high level of detail in this chapter, NHTSA and EPA 

engineers are continuing to review it, and further refinements should be expected in 

time for formal submission.

CHAPTER 3: Technologies Considered in the Agencies’ 

Analysis 

This Chapter of the joint TSD describes the technologies NHTSA and EPA 

evaluated as potential inputs in their respective models and provides estimates of the 

technologies’ costs, effectiveness and availability. This Chapter also describes, in general 

terms, how the agencies use these inputs in their respective models. For greater detail on 

this subject, please see Section V of NHTSA’s PRIA and Chapter 4 of EPA’s draft RIA. 

3.1 How do the agencies decide which technologies to include in the 

analysis? 

Technology assumptions, i.e., assumptions about their availability, cost, 

effectiveness, and the rate at which they can be incorporated into new vehicles, are often 

very controversial as they have a significant impact on the levels of the standards. 

Agencies must, therefore, take great care in developing and justifying these 

assumptions. In developing technology inputs for MY 2012-2016 standards the agencies 

reviewed the technology assumptions that NHTSA used in setting the 2011 standards and 

the comments that NHTSA received in response to its May 2008 Notice of Proposed 

Rulemaking. In addition, the agencies reviewed the technology input assumptions 

identified in EPA’s 2008 Staff Technical Report1

 and supplemented their review with 

information from the sources described in the following section. This analysis between 

the agencies continued until the publication of this notice and will continue until the final 

rule is published. 

3.1.1 Reports and papers in the literature 

NHTSA and EPA have done extensive research in identifying the most credible 

sources of information. These sources included: the 2002 NAS report on the effectiveness 

and impact of CAFE standards;2

 the 2004 study done by NESCCAF;3 the California Air 

Resources Board (CARB) Initial Statement of Reasons in support of their carbon 

rulemaking;4

 a 2006 study done by Energy and Environmental Analysis (EEA) for the 

Department of Energy;5 a study done by the Martec Group for the Alliance of 

Automobile Manufacturers, and an update by the Martec Group to that study;6 and 

vehicle fuel economy certification data. Both agencies also reviewed the published 

technical literature which addressed the issue of CO2 emission control and fuel economy, 

such as papers published by the Society of Automotive Engineers and the American 

Society of Mechanical Engineers. In addition, confidential data submitted by vehicle 

manufacturers in response to NHTSA’s request for product plans,7 and confidential 

information shared by automotive industry component suppliers in meetings with EPA 

and NHTSA staff held during the second half of the 2007 calendar year were used as a 
Technologies Considered in the Agencies’ Analysis 

3-3 

cross check of the public data mentioned above and not as a significant basis for this 

rulemaking. EPA also has a contracted study ongoing with FEV that consists of 

complete system tear-downs to evaluate technologies down to the nuts and bolts to arrive 

at very detailed estimates of the costs associated with manufacturing them (and, as noted, 

the agencies used this analysis to estimate costs of turbocharging with downsizing).8 

EPA and NHTSA reviewed all this information in order to develop the best estimates of 

availability, cost and effectiveness of these fuel-saving/CO2-reducing technologies. Note 

that tear-down cost estimates from FEV for additional engine and transmission 

technologies became available shortly before the release of this proposal, but were not 

incorporated into the agencies’ cost analysis. These preliminary results are available for 

review and the agencies will consider this information for use in the final rule analysis.9 

A detailed report will be submitted to the docket on these additional technologies during 

the public comment period for this proposal. In addition, additional technologies are 

expected to be completed from this study with FEV after the close of the comment period 

which the agencies will also docket. 

The agencies would also like to note that per the Energy Independence and 

Security Act (EISA), the National Academies of Sciences is conducting an updated study 

to update chapter 3 of their 2002 NAS Report, which presents technology effectiveness 

estimates. The update will take a fresh look at that list of technologies and their 

associated cost and effectiveness values. 

The updated NAS report is expected to be available on September 30, 2009. As 

the Report is received by the agencies, it will be placed in the respective dockets for this 

rulemaking for the public’s review and comment. Because this is expected to occur 

during the comment period, the public is encouraged to check the docket regularly and 

provide comments on the updated NAS Report by the closing of the public comment 

period. As requested by the President in the January 26, 2009 Executive Order, NHTSA 

and EPA will consider the updated NAS Report and any comments received on it, as 

appropriate, in developing the technology cost and effectiveness estimates for the final 

rule. 

3.1.2 Fuel economy certification data 

Where available, data from recent model years of EPA's Fuel Economy 

Certification Data was used. CO2 and fuel consumption reduction estimates were 

estimated from EPA's fuel economy database on the two-cycle (FTP city & highway) fuel 

economy test results. During the standard fuel economy test cycles, direct measurements 

of CO2 emissions are made. This data, along with other measurements, are then used to 

calculate the estimated fuel economy performance in gallons of fuel consumed per mile. 

Vehicle certification data are an obviously reliable source for determination of the CO2

and fuel consumption reduction potential when a directly comparable vehicle was offered 

both with and without the specific CO2 and fuel consumption reducing technology, 

because a comparison between the emissions data between the two vehicles directly 

reflect the application of the technologies on the vehicle test cycles. Where possible, 

technology-specific effectiveness numbers were extracted for vehicles where only the 
Draft Joint Technical Support Document 

3-4 

specific technology would be changed from a reference vehicle, in order to eliminate any 

confounding of values across several technologies. In some hybrid vehicle cases, the 

exact same vehicle may not be offered, and a similar vehicle was selected for 

comparison. 

3.2 Which technologies will be applicable in the rulemaking time 

frame? 

Fuel consumption and CO2 emissions reductions are possible from a variety of 

technologies whether they be engine-related (e.g., turbocharging), transmission-related 

(e.g., six forward gears in place of four), accessory-related (e.g., electric power steering), 

or vehicle-related (e.g., low rolling resistance tires). One of the key factors that NHTSA 

and EPA considered in developing the proposed standards for each model year is the 

availability and feasibility of fuel-saving/CO2-reducing technologies. In order to analyze 

the availability and feasibility of technologies in an objective way, the agencies reviewed 

NHTSA’s MY 2011 CAFE final rule and EPA’s 2008 Staff Report and updated the 

assumptions based on more current information. As a check on the new analysis, 

NHTSA and EPA also reviewed the product plans submitted by manufacturers to the 

agencies in response to NHTSA’s March 2009 request for product plans. 

Many technologies considered by the agencies are well known, readily available 

during the rulemaking time period, and could be incorporated into vehicles once 

production decisions are made. The agencies did not consider technologies in the 

research stage because their effectiveness and/or costs are presently only known with 

greater levels of uncertainty. 

The technologies considered by the NHTSA and EPA models are briefly 

described below. They fall under the five broad categories of engine, transmission, 

vehicle, electrification/accessory, and hybrid technologies. A more detailed description 

of each technology, and the technology’s costs and effectiveness, is described in greater 

detail in section 3.5 of this TSD. 

Types of engine technologies that improve fuel economy and reduce CO2 

emissions include the following:

• Low-friction lubricants – low viscosity and advanced low friction lubricants 

oils are now available with improved performance and better lubrication. 

• 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. 

• 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.
Technologies Considered in the Agencies’ Analysis 

3-5 

• 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 substantially 

reduces pumping losses 

• Variable valve timing – alters the timing or phase of the intake valve, exhaust 

valve, or both, primarily to reduce pumping losses, increase specific power, 

and control residual gases.

• 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. 

• Continuous variable valve lift – is an electromechanically controlled system in 

which cam period and phasing is changed as lift height is controlled. This 

yields a wide range of performance optimization and volumetric efficiency, 

including enabling the engine to be valve throttled. 

• 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. 

• Combustion restart – can be used in conjunction with gasoline direct-injection 

systems to enable idle-off or start-stop functionality. Similar to other startstop technologies, additional enablers, such as electric power steering, 

accessory drive components, and auxiliary oil pump, might be required. 

• Turbocharging and downsizing – increases the available airflow and specific 

power level, allowing a reduced engine size while maintaining performance. 

This reduces pumping losses at lighter loads in comparison to a larger engine.

• Exhaust-gas recirculation boost – increases the exhaust-gas recirculation used 

in the combustion process to increase thermal efficiency and reduce pumping 

losses. 

• 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, 

with a very lean air/fuel mixture, than an equivalent-performance gasoline 

engine. This technology requires additional enablers, such as NOx trap 

catalyst after-treatment or selective catalytic reduction NOx after-treatment.

Types of transmission technologies considered include: 
Draft Joint Technical Support Document 

3-6 

• 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. 

• Six-, seven-, and eight-speed automatic transmissions – the gear ratio spacing 

and transmission ratio are optimized for a broader range of engine operating 

conditions. 

• Dual clutch or automated shift manual transmissions – are similar to manual 

transmissions, but the vehicle controls shifting and launch functions. A dualclutch automated shift manual transmission uses separate clutches for evennumbered and odd-numbered gears, so the next expected gear is pre-selected, 

which allows for faster and smoother shifting.

• 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 transmission 

ratios with an infinite number of gears, enabling finer optimization of 

transmission torque multiplication under different operating conditions so that 

the powertrain can operate at its optimum efficiency.

• Manual 6-speed transmission – offers an additional gear ratio, often with a 

higher overdrive gear ratio, than a 5-speed manual transmission. 

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, therefore reducing the energy needed to move the vehicle. 

• 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. 

• 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. 

• Aerodynamic drag reduction – is achieved by changing vehicle shape or 

reducing frontal area, including skirts, air dams, underbody covers, and more 

aerodynamic side view mirrors. 

• Mass reduction and material substitution – Mass reduction encompasses a 

variety of techniques ranging from improved design and better component 

integration to application of lighter and higher-strength materials. Mass 
Technologies Considered in the Agencies’ Analysis 

3-7 

reduction is further compounded by reductions in engine power and ancillary 

systems (transmission, steering, brakes, suspension, etc.).

Types of electrification/accessory and hybrid technologies considered include: 

• Electric power steering (EPS) – 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.

• 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.

• 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 as a result 

of A/C use. These technologies are covered separately in the EPA RIA. 

• 12-volt micro-hybrid (MHEV) – also known as idle-stop or start stop and 

commonly implemented as a 12-volt belt-driven integrated starter-generator, 

this is the most basic hybrid system that facilitates idle-stop capability. Along 

with other enablers, this system replaces a common alternator with an 

enhanced power starter-alternator, both belt driven, and a revised accessory 

drive system.

• Higher Voltage Stop-Start/Belt Integrated Starter Generator (BISG) – 

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 motor, inverter, and battery wiring harnesses. 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).

• 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 motor, inverter, and battery wiring harnesses. 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).
Draft Joint Technical Support Document 

3-8 

• 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.

• 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.

• 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. They also use a 

control system that allows the battery pack to be substantially depleted under 

electric-only or blended mechanical/electric operation.

• Electric vehicles (EV) – are vehicles with all-electric drive and with vehicle 

systems powered by energy-optimized batteries charged primarily from grid 

electricity.

 

3.3 What technology assumptions have the agencies used for this 

proposal? 

3.3.1 How are the technologies applied in the agencies’ respective 

models? 

 While both NHTSA and EPA are basing their fuel economy and emission 

modeling on the same baseline vehicle fleet and cost and effectiveness estimates for 

control technologies, differences in the Volpe and OMEGA models require that this 

common information be processed prior to use in different ways. With respect to the 

vehicle fleet, the Volpe Model evaluates the addition of technology to individual vehicle 

configurations or models, while the OMEGA model does so for vehicle platforms broken 

down further by engine size. Thus, NHTSA used the vehicle sales estimates described 

above directly, while EPA combined the sales of certain vehicle models. The Volpe 
Technologies Considered in the Agencies’ Analysis 

3-9 

Model evaluates technologies individually. This, coupled with the modeling of 

individual vehicle models, means that only the presence or absence of any particular 

technology needs to be indicated, as described above. OMEGA applies technology in 

combinations or packages. This, plus the grouping of individual vehicle models, requires 

that the total effectiveness of the technology already applied in the baseline fleet must be 

calculated and must be reflected as a percentage of the various technology packages 

available to be added to those vehicles. 

 With respect to the cost and effectiveness of technology, as mentioned above, the 

Volpe Model applies technologies individually. It does this following certain specified 

pathways for several categories of technologies (e.g., engine, transmission, accessories, 

etc.). The Volpe Model applies technology incrementally, so the effectiveness of each 

subsequent technology needs to be determined relative to the previous one. The same is 

true for cost. In addition, because of overlap in the effectiveness of certain technologies, 

herein referred to as the dis-synergy, any such overlap between the next technology on a 

specified pathway with those which have already been potentially applied in other 

pathways must be determined. For example, the incremental effectiveness of switching 

from a six-speed automatic transmission to a dual clutch transmission will depend on the 

level of engine technology already applied (e.g., intake cam phasing on a port-fuel 

injected engine or a down-sized, turbocharged, direct injection engine). 

 EPA’s OMEGA model applies technologies in packages and according to a fixed 

sequence for any particular group of vehicles. This requires that the overall cost and 

effectiveness of each package be determined first, considering any and all dis-synergies 

which may exist. Then, the incremental cost and effectiveness of each subsequent 

package is determined relative to the prior one. 

 Thus, while the same baseline vehicle fleet and cost and effectiveness estimates 

for technologies are being used in both the Volpe and OMEGA models, the form of the 

actual inputs to the model will appear to be different. For more information on EPA’s and 

NHTSA’s unique approaches to modeling, please refer to each agency’s respective 

draft/proposed RIA. 

In order to estimate both technology costs and fuel consumption/CO2 reduction 

estimates, it is necessary for each agency to describe the baseline vehicle characteristics 

from which the estimates can be compared. This “baseline” is different from the usage in 

Chapter 1 of this joint TSD. In Chapter 1, the baseline fleet is the projected fleet in 2016 

before accounting for technologies needed to meet the 2011 MY CAFE standards and 

before accounting for changes in fleet composition attributable to that rule (those later 

steps accounted for independently by each agency in developing their separate reference 

fleets). In the present context, it indicates the vehicle types and technologies that will be 

used for comparison from a strictly cost and effectiveness point of view. These baselines 

may be slightly different for the two agencies. For EPA, unless noted elsewhere, the 

baseline vehicle is defined as a vehicle with a port-fuel injected, naturally aspirated 

gasoline engine with two intake and two exhaust valves and fixed valve timing and lift. 

The baseline transmission is a 4-speed automatic, and the vehicle has no hybrid systems. 
Draft Joint Technical Support Document 

3-10 

For NHTSA, unless noted elsewhere, the baseline vehicle is the actual vehicle as it exists 

in the baseline fleet (NHTSA models each unique vehicle separately). For details on how 

the technology cost and effectiveness estimates presented below are used in each 

agency’s model, refer to each agency’s respective draft/proposed RIA. 

3.3.2 How did the agencies develop technology cost and effectiveness estimates for 

the proposal? 

3.3.2.1 Considerations that affect technology effectiveness

Regarding estimates for technology effectiveness, NHTSA and EPA also 

reexamined the estimates from NHTSA’s MY 2011 CAFE final rule and EPA’s ANPRM 

and Staff Technical Report, which largely mirrored NHTSA’s NPRM estimates in the 

2008 proposed rule. The agencies also reconsidered other sources such as the 2002 NAS 

Report, the 2004 NESCCAF report, recent CAFE compliance data (comparing similar 

vehicles with different technologies against each other in fuel economy testing, such as a 

Honda Civic Hybrid versus a directly comparable Honda Civic conventional drive), and 

confidential manufacturer estimates of technology effectiveness. Using the BOM 

framework utilized in MY 2011 CAFE final rule, NHTSA and EPA engineers reviewed 

effectiveness information from the multiple sources for each technology. Together, they 

compared the multiple estimates and assessed their validity, taking care to ensure that 

common BOM definitions and other vehicle attributes such as performance, refinement, 

and drivability were taken into account. However, because the agencies’ respective 

models employ different numbers of vehicle subclasses and use different technology 

decision trees to arrive at the standards, direct comparison of BOMs was somewhat more 

complicated. To address this and to assure an apples-to-apple comparison, NHTSA and 

EPA developed mapping techniques, devising technology packages and corresponding 

incremental technology estimates. This approach helped compare incremental and 

packaged estimates and derive results that are consistent and could be translated into the 

respective models of the agencies. In general, most effectiveness estimates used in both 

the MY 2011 CAFE final rule and the 2008 EPA staff report were determined to be 

accurate and were carried forward without significant change into this rulemaking. When 

NHTSA and EPA’s estimates for effectiveness diverged slightly due differences in how 

agencies apply technologies to vehicles in their respective models, the agencies will 

report the ranges for the effectiveness values used in each model, as well as the reasons 

the range is reasonable. 

3.3.2.1.1 Technology synergies 

 The benefits of these technologies are generally but not always additive. That is, 

adding cylinder deactivation to dual cam phasing does not necessarily result in a 10 

percent improvement. This is true because some of the technologies address the same 
Technologies Considered in the Agencies’ Analysis 

3-11 

shortcomings of the internal combustion engine, although in different ways. Where that 

is the case, negative synergies are said to exist between two (or more) technologies. It is 

also true that combining some technologies provides more benefit than a simple additive 

effect. In those cases, positive synergies are said to exist. The analysis accounts for 

these positive and negative synergies wherever appropriate so as to ensure no double or 

insufficient counting of effects. Synergies are discussed in more detail in each agency’s 

respective draft/proposed RIA.

3.3.2.2 Considerations that affect technology costs 

As a general matter, the best way to derive technology cost estimates is to conduct 

real- world tear down studies. These studies break down each technology into its 

respective components, evaluate the costs of each component, and build up the costs of 

the entire technology based on the contribution of each component. As such, tear down 

studies require a significant amount of time and are very costly. EPA has begun 

conducting tear down studies to assess the costs of 4-5 technologies under a contract with 

FEV Inc., an independent engine and powertrain systems research, design and 

development company. To date, only one technology (downsizing and turbo charging) 

has been evaluated. Note that tear-down cost estimates from FEV for additional engine 

and transmission technologies became available shortly before the release of this 

proposal, but were not incorporated into the agencies’ cost analysis. These preliminary 

results are available for review and the agencies will consider this information for use in 

the final rule analysis.10 A detailed report will be submitted to the docket on these 

additional technologies during the public comment period for this proposal. In addition, 

additional technologies are expected to be completed from this study with FEV after the 

close of the comment period which the agencies will also docket. As tear down studies 

are concluded by FEV during the rulemaking process, the agencies will make them 

available in the joint rulemaking docket of this rulemaking. The agencies will consider 

these studies and any comments received on them, as practicable and appropriate, in 

developing technology cost assumptions for the final rule. As noted above, the agencies 

relied on some of the FEV findings of FEV for estimating the cost of this technologycosts

in this rulemaking. 

Regarding the other technologies, because tear down studies were not yet 

available, the agencies decided to pursue the Bill of Materials (BOM) approach as 

outlined in NHTSA’s 2011 final rule and EPA’s 2008 staff report. This approach was 

recommended to NHTSA by Ricardo, an international engineering consulting firm 

retained by NHTSA to aid in the analysis of public comments on its proposed standards 

for MYs 2011-2015 because of its expertise in the area of fuel economy technologies. A 

BOM approach is similar in concept to the approach used in tear down studies. The 

difference is that under a BOM approach, the build up of cost estimates is conducted 

based on a review of cost and effectiveness estimates for each component from available 

literature. To the extent that the agencies departed from the 2011 CAFE final rule and 

the 2008 staff report estimates, the agencies explained the reasons and provided 

supporting analyses. For example, while NHTSA and Ricardo engineers had relied 

considerably in the MY 2011 final rule on the 2008 Martec Report for costing contents of 
Draft Joint Technical Support Document 

3-12 

some technologies, upon further joint review and for purposes of the MY 2012-2016 

standards, the agencies decided that some of the costing information in that report was no 

longer accurate due to downward trends in commodity prices since the publication of that 

report. The agencies reviewed, revalidated or updated cost estimates for individual 

components based on new information. 

The subsequent sections describe the costs associated with the new vehicle 

technologies. The costs represent the piece costs for an individual piece of hardware or 

system, e.g., an intake cam phaser to provide variable valve timing. Costs are presented 

in terms of their hardware incremental compliance cost. This means that they include all 

potential costs associated with their application on vehicles, not just the cost of their 

physical parts. The basis for the piece costs presented here is NHTSA’s 2011 CAFE 

FRM and EPA’s 2008 Staff Technical Report.11,12 In those analyses, piece costs were 

estimated based on a number of sources for cost related information. The objective was 

to use those sources of information considered to be most credible for projecting the costs 

of individual vehicle technologies. As a result of meetings between EPA and NHTSA 

staff in the first half of 2009, where both piece costs and fuel consumption efficiencies 

were discussed in detail, cost estimates have been adjusted slightly. Where estimates 

differ between sources, engineering judgment was used to arrive at what is believed to be 

the best cost estimate available today, and explained the basis for that exercise of 

judgment. Thus while NHTSA and EPA found that much of the cost information used in 

NHTSA’s MY 2011 final rule and EPA’s 2008 staff report was consistent to a great 

extent, the agencies, in reconsidering information from many sources, revised several 

component costs of several major technologies information (turbocharging downsizing, 

mild and strong hybrids, diesels, SGDI, Valve Train Lift Technologies). 

 

Note that EPA’s 2008 staff report presented costs in terms of 2006 dollars. For 

this analysis, costs are expressed in terms of 2007 dollars. Any costs presented here that 

are based on costs expressed in 2006 dollars have been adjusted to reflect 2007 dollars 

using the Gross Domestic Product price deflator (see Appendix 3.A).13,a The following 

discussion summarizes the piece cost estimates and how these data sources were used to 

arrive at the best estimate of piece costs. The following sections describe individual 

technologies and their respective cost and effectiveness estimates. For purposes of this 

joint TSD, these estimates were developed jointly by NHTSA and EPA. Due to 

differences in the modeling and technology application methodologies employed by the 

two agencies, the estimates used by each agency may not match exactly but will be 

consistent given the different modeling tools used. Additional details are also provided in 

each agency’s respective proposed/draft RIAs. 

3.3.2.2.1 Direct manufacturing costs 

 Building on NHTSA’s estimates developed for the MY 2011 CAFE final rule 

and EPA’s Advanced Notice of Proposed Rulemaking, which relied on the 2008 Staff 

Technical Report, 14 the agencies took a fresh look at technology cost and effectiveness 

 

a

 The adjustment used to convert from 2006 dollars to 2007 dollars was 1.03. 
Technologies Considered in the Agencies’ Analysis 

3-13 

values for purposes of the joint proposal under the National Program. For costs, the 

agencies reconsidered both the direct or “piece” costs and indirect costs of individual 

components of technologies. For the direct costs, the agencies followed a bill of 

materials (BOM) approach as noted above. A bill of materials, in a general sense, is a list 

of components that make up a system—in this case, an item of fuel economy-improving 

technology. In order to determine what a system costs, one of the first steps is to 

determine its components and what they cost. 

NHTSA and EPA estimated these components and their costs based on a number 

of sources for cost-related information. The objective was to use those sources of 

information considered to be most credible for projecting the costs of individual vehicle 

technologies. For example, while NHTSA and Ricardo engineers had relied considerably 

in the MY 2011 CAFE final rule on the 2008 Martec Report for costing contents of some 

technologies, upon further joint review and for purposes of the MY 2012-2016 standards, 

the agencies decided that some of the costing information in that report was no longer 

accurate due to downward trends in commodity prices since the publication of that report. 

The agencies reviewed, revalidated or updated cost estimates for individual components 

based on new information. Thus though NHTSA and EPA found that much of the cost 

information used in NHTSA’s MY 2011 CAFE final rule and EPA’s staff report was 

consistent, the agencies, in reconsidering information from many sources, revised several 

component costs of several major technologies (turbocharging downsizing, mild and 

strong hybrids, diesels, SGDI, Valve Train Lift Technologies).b

 These are discussed at 

length below. For one technology (turbocharging/downsizing), the agencies relied, to the 

extent possible, on the tear down data available and scaling methodologies used in EPA’s 

ongoing study with FEV. This study consists of complete system tear-down to evaluate 

technologies down to the nuts and bolts to arrive at very detailed estimates of the costs 

associated with manufacturing them.15 The confidential information provided by 

manufacturers under their product plan submissions to the agencies or discussed in 

meetings between the agencies and the manufacturers and suppliers served largely as a 

check on publicly-available data. 

Once costs were determined, they were adjusted to ensure that they were all 

expressed in 2007 dollars using the GDP price deflator as described in Appendix 3.A. 

Indirect costs were accounted for using a new approach developed by EPA for this 

rulemaking and explained below rather than using the Retail Price Equivalent (RPE) 

multiplier of 1.5 as was done in NHTSA’s 2011 FRM and EPA’s 2008 staff report. 

NHTSA and EPA also considered how costs should be adjusted to reflect manufacturer 

learning as discussed below. Lastly, costs were adjusted by modifying or scaling content 

assumptions to account for differences across the range of vehicle sizes and functional 

requirements, and adjusted the associated material cost impacts to account for the revised 

 

b

 The 2002 NAS Report, the 2004 study done by NESCCAF, the California Air Resources Board (CARB) 

Initial Statement of Reasons in support of their carbon rulemaking, a 2006 study done by Energy and 

Environmental Analysis (EEA) for the Department of Energy, a study done by Martec for the Alliance of

Automobile Manufacturers and the 2008 Martec Report which updated that study, and vehicle fuel 

economy certification data. and confidential data submitted by manufacturers in response to the March 

2009 request for product plans. 
Draft Joint Technical Support Document 

3-14 

content, although these adjustments were different for each agency due to the different 

vehicle subclasses used in their respective models.

3.3.2.2.2 Cost markups to account for indirect costs 

 Indirect costs include production-related costs (research, development, and other 

engineering), business-related costs (corporate salaries, pensions), and retail-sales-related 

costs (dealer support, marketing). For this analysis, direct cost estimates were first 

developed for each technology or system at the auto manufacturer level, i.e., the price 

paid by the manufacturer to a Tier 1 component supplier. To these costs, an indirect cost 

markup factor was then applied that varied by the best estimate of the particular 

technology’s complexity. This section describes the approach to determining the indirect 

cost multipliers (ICM) used in this analysis and the specific multipliers used for each 

piece of technology. 

3.3.2.2.3 Concept behind and development of indirect cost 

multipliers 

If all desirable data were available, when a new technology is implemented, the 

costs of that technology would include the direct and indirect costs particular to that 

technology. For instance, some changes may involve new tooling, while others may not; 

some may affect the way the car is marketed, while others are of limited interest to 

consumers. In a world of full information, the indirect costs of a new technology would 

be calculated specifically for that technology. In practice, though, it is often difficult, if 

not impossible, to identify the indirect costs specific to a new technology. 

The automotive industry, EPA, and NHTSA have commonly used retail price 

equivalent (RPE) multipliers to approximate the indirect costs associated with a new 

technology. The RPE is a ratio of total revenues to direct manufacturing costs. Because, 

by definition, total revenues = direct costs + indirect costs + profit, the RPE is the factor 

that, when multiplied by direct manufacturing costs, recovers total revenue. This 

multiplication is accurate only in the aggregate; it does not in reality apply to any specific 

technology. The RPE is a way to estimate indirect costs on the assumption that indirect 

costs are constant across all technologies and processes in a company. In the MY 2011 

CAFE final rule NHTSA utilized a 1.5 RPE multiplier. 

 

In fact, however, the indirect costs of new technologies vary, both with the 

complexity of the technology and with the time frame. For instance, a hybrid-electric 

engine is likely to involve greater research and development and marketing costs per 

dollar of direct costs than low-rolling-resistance tires; the research and development costs 

of any technology are likely to decrease over time. In recognition of this concern, EPA 

contracted with RTI International to provide a current estimate of the RPE multiplier and 

to examine whether the indirect costs of new technologies are likely to vary across 

technologies. The report “Automobile Industry Retail Price Equivalent and Indirect Cost 

Multipliers,” by Alex Rogozhin, Michael Gallaher, and Walter McManus,16 calculates the 
Technologies Considered in the Agencies’ Analysis 

3-15 

RPE multiplier as 1.46 in 2007. The report then develops indirect cost (IC) multipliers 

that vary with the complexity of technology and the time frame. While any multiplier is 

only an approximation of the true indirect costs of a new technology, the IC multipliers in 

this report move away from the assumption that the proportion of indirect costs is 

constant across all technologies and take into account some of the variation in these costs. 

The multipliers developed in this report are presented in Table 3-1Table 3-1Table 3-1 . 

The indirect cost multipliers used adjustment factors, developed by a team of EPA 

engineers with expertise in the auto industry, which accounted for the differences in 

complexity of the specific technologies under study. To examine the sensitivity of the 

results to different technologies of the same complexity, and to provide more detailed 

documentation of the development of the adjustment factors, EPA convened a second 

panel,17 with NHTSA’s input, to develop adjustment factors for three different 

technologies. This latter process allowed for estimates of the variation in adjustment 

factors, and thus in the variation of indirect cost multipliers. These results are also 

presented in Table 3-1Table 3-1Table 3-1. 

 

Table 3-13-1 Indirect Cost Multipliers 

STUDY 

TECHNOLOGY COMPLEXITY 

Short Run Long Run 

Low Medium High Low Medium High 

RTI Report 1.05 1.20 1.45 1.02 1.05 1.26 

EPA Memo: Average 1.16 1.29 1.64 1.12 1.20 1.39 

Standard Deviation 0.14 0.15 0.21 0.14 0.13 0.15 

Median 1.12 1.26 1.66 1.06 1.20 1.40 

Max 1.43 1.53 2.15 1.42 1.45 1.69 

Min 1.00 1.02 1.37 1.00 1.01 1.12 

Multipliers Used in 

this Analysis 1.11 1.25 1.45 1.64 1.07 1.13 1.26 1.39 

The table shows minor differences in the multipliers for low- and mediumcomplexity technologies (roughly 0.1), but larger differences in the high-complexity 

technologies. The EPA and NHTSA engineers who reviewed the results believed that the 

differences reflected actual differences in the technologies under study. In particular, for 

low complexity, low-rolling-resistance tires (the application in the RTI Report) would 

involve lower indirect costs than aerodynamic improvements (the application in the EPA 

memo); and, for medium complexity, dual-clutch transmissions (the application in the 

RTI Report) should have a smaller multiplier than engine downsizing done in conjunction 

with turbocharging (the application in the EPA Memo). For these two cases, EPA and 

NHTSA considered these technologies to span the range of technologies assigned to 

those classes; the costs in this study, then, use the averages of the values of the two 

reports, as shown in the last line of Table 3-1Table 3-1Table 3-1. For high complexity 

technologies, the agencies felt the technologies assigned to these categories—hybridField Code Changed

Field Code Changed

Comment [TSh1]: Table updated 9/10/09 to 

include Std Deviations, Medians, Max and Min. 

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Draft Joint Technical Support Document 

3-16 

electric vehicles in the RTI Report; plug-in hybrid electric vehicles in the EPA Memo—

were sufficiently different that each deserved a different category. This is discussed in 

more detail in the next section which highlights the multipliers used for each specific 

technology. 

3.3.2.2.3.1 Application of specific indirect cost multipliers to each 

technology 

As noted in the previous section, a different ICM was applied to each 

technology’s direct cost to arrive at its compliance cost. These different ICMs were 

chosen based on the complexity of the technology in the opinions of staff engineers at 

EPA and NHTSA, most of whom have several years of experience in the auto industry. 

As shown in Table 3-1Table 3-1Table 3-1, ICMs were developed via two separate 

processes: that presented in the RTI report; and that presented in the EPA Memo. While 

all of the ICMs generated via these two processes were in general agreement, some 

differences did exist. In determining how to deal with these differences, EPA and 

NHTSA agreed that, for the low and medium complexity technologies, a simple average 

of the two values would be used. However, for the high complexity technologies, it was 

decided that two separate high-multipliers should be used. The lower multiplier, deemed 

high, would be applied to those technologies of high complexity but with some level of 

use in the marketplace today. Such technologies would be power-split and 2-mode 

hybrid electric vehicles. The higher multiplier, deemed high+, would be applied to those 

technologies of high complexity but with no, or essentially no, use in the current fleet. 

Such technologies would be plug-in hybrids and full electric vehicles. Table 3-2Table 

3-2Table 3-2 shows the complexity level for each technology considered in this analysis. 

Table 3-23-2 Complexity Levels of Technologies 

LOW COMPLEXITY MEDIUM COMPLEXITY HIGH COMPLEXTIY HIGH+ 

COMPLEXITY 

Low friction lubes VVLT-continuous (OHV) VVLT-continuous 

(OHC) 

Plug-in hybrid 

Engine friction reduction VVLT-discrete (OHV) Camless valve actuation Full electric vehicle 

VVT-intake (OHC) GDI-lean burn Homogeneous charge 

CI 

VVT-coupled (OHC & OHV) Turbocharge with downsize Weight reduction – 30% 

VVT-dual (OHC) Conversion to diesel Integrated motor assist 

hybrid

Cylinder deactivation (OHC & 

OHV) 

Dual clutch transmission 2-mode hybrid 

VVLT-discrete (OHC) Continually variable trans Power-split hybrid 

GDI-stoich 42 Volt conversion 

Turbocharge (with no downsize) Weight reduction – 20% 

Downsize (with no turbocharge) Integrated starter generator 

(stop-start) 

 

Cam configuration changes (with 

no downsize) 

Combustion restart 

Aggressive shift logic Cooled EGR/EGR boost

Early torque converter lockup 

5-speed auto transmission

6-speed auto transmission

6-speed manual transmission

Field Code Changed

Field Code Changed
Technologies Considered in the Agencies’ Analysis 

3-17 

Improved accessories 

Electric power steering 

Low rolling resistance tires 

Low drag brakes 

Secondary axle disconnect 

Improved aerodynamics 

Weight reduction – 3% 

Weight reduction – 5% 

Weight reduction – 10% 

A/C Leakage Reduction

A/C Efficiency Improvement 

The estimates of vehicle compliance costs cover the years of implementation of 

the program – 2012 through 2016. In EPA’s analysis, compliance costs have also been 

estimated for the years following implementation to shed light on the long term – 2022 

and later – cost impacts of the proposal. The year 2022 is used by EPA because the 

short-term and long-term markup factors described above are applied in five year 

increments with the 2012 through 2016 implementation span and the 2017 through 2021 

span both representing the short-term. 

3.3.2.2.4 Cost reduction through manufacturer learning 

For some of the technologies considered in this analysis, manufacturer learning 

effects would be expected to play a roll in the actual end costs. The “learning curve” or 

“experience curve” describes the reduction in unit production costs as a function of 

accumulated production volume. In theory, the cost behavior it describes applies to 

cumulative production volume measured at the level of an individual manufacturer, 

although it is often assumed—as both agencies have done in past regulatory analyses—to 

apply at the industry-wide level particularly in industries that utilize many common 

technologies and component supply sources.18 Both agencies believe there are indeed 

many factors that cause costs to decrease over time. Research in the costs of 

manufacturing has consistently shown that, as manufacturers gain experience in 

production, they are able to apply innovations to simplify machining and assembly 

operations, use lower cost materials, and reduce the number or complexity of component 

parts. All of these factors allow manufacturers to lower the per-unit cost of production 

(i.e., the manufacturing learning curve).19

NHTSA has a detailed description of the learning effect in the 2011 CAFE final 

rule, and EPA has a detailed description of the learning effect in the 2008 staff report and 

in several past rules.20 The description here is focused on how the learning effect has 

been used in the analyses support each agency’s rule. 

Most studies of the effect of experience or learning on production costs appear to 

assume that cost reductions begin only after some initial volume threshold has been 

reached, but not all of these studies specify this threshold volume. The rate at which 

costs decline beyond the initial threshold is usually expressed as the percent reduction in 
Draft Joint Technical Support Document 

3-18 

average unit cost that results from each successive doubling of cumulative production 

volume, sometimes referred to as the learning rate. Many estimates of experience curves 

do not specify a cumulative production volume beyond which cost reductions would no 

longer occur, instead depending on the asymptotic behavior of the effect for learning 

rates below 100 percent to establish a floor on costs. Table 3-3Table 3-3Table 3-3

summarizes estimates of learning rates derived from studies of production costs for 

various products. 

Table 3-33-3 Estimated Learning Rates and Associated Volumes for Various Products 

PRODUCT COSTS 

AFFECTED

THRESHOLD 

VOLUME

LEARNING 

RATE

Photovoltaic cells Total costs Not reported 20%

Wind turbines Total costs 100 MW 20%

Gas turbines Total costs 100 MW 10%

Semiconductors Total costs Not reported 13-24%

Automobile assembly Assembly labor Not reported 16%

Truck manufacturing Total costs Not reported 10%

Battery-electric LDV Total costs 10,000 units 10% 

Fuel cell hybrid LDV Total costs 10,000 units 16% 

Fuel cell LDV powertrain Total costs 10,000 units 19% 

In past rulemaking analyses, as noted above, both agencies have used a learning 

curve factor of 20 percent for each doubling of production volume. NHTSA has used 

this approach in analyses supporting recent CAFE rules. In its analysis, EPA has 

simplified the approach by using an “every two years” based learning progression rather 

than a pure production volume progression (i.e., after two years of production it was 

assumed that production volumes would have doubled and, therefore, costs would be 

reduced by 20 percent). This approach has served EPA well, especially considering that 

those rulemaking analyses have reflected programs in which every new engine or vehicle 

beginning in year one of implementation would be equipped with the newly required 

piece of technology. 

 

In the 2011 CAFE final rule, NHTSA considered not only this volume-based 

learning as described above, but also “time-based” learning. The time-based learning, 

estimated by NHTSA at three percent per year, occurs in years following the volumebased learning steps and represents the smaller scale learning that occurs as 

manufacturers continue to innovate. The time-based learning is, in effect, represented by 

the flattened out, asymptotic portion of the learning curve. 

For this analysis, each agency has employed both volume-based and time-based 

learning effects. In NHTSA’s analysis, volume-based learning is estimated to result in 20 

percent lower costs as production volumes of the given technology reach 300,000 units 

and again when they reach 600,000 units within the entire industry. The count of 

production units begins in the 2012 model year and/or with the first units produced, 

whichever is earlier. In EPA’s analysis, as noted above, volume-based learning is 

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Technologies Considered in the Agencies’ Analysis 

3-19 

estimated to result in 20 percent lower costs after two full years of implementation (i.e., 

the 2014 MY costs are 20 percent lower than the 2012 and 2013 model year costs). In 

each agency’s analysis, time-based learning is estimated to result in 3 percent lower costs 

in each year following first introduction of a given technology. Once two volume-based 

learning steps have occurred, or once the five year time-based learning period is 

completed, learning is assumed to be complete, at least for purposes of the analyses done 

to support each agency’s rule. 

 

Both agencies considered learning impacts on most but not all of the technologies 

expected to be used because some of the expected technologies are already used rather 

widely in the industry and, presumably, learning impacts have already occurred. 

Volume-based learning was considered for only a handful of technologies that are 

considered to be new or emerging technologies such as the hybrids and electric vehicles. 

Most technologies have been considered to be more established given their current use in 

the fleet and, hence, the lower time-based learning has been applied. The learning effects 

applied to each technology are summarized in Table 3-4Table 3-4Table 3-4. Volumebased learning has been applied to all of the hybrid and electric vehicle technologies with 

the exception of the power-split hybrid. For each analysis, the power-split hybrid (e.g., 

the Toyota Prius) was considered to have been in the market for enough years that the 

volume-based learning effects have already passed and all that remains are the smaller, 

time-based learning effects (this is consistent with NHTSA’s 2011 CAFE FRM). 

 

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Draft Joint Technical Support Document 

3-20 

Table 3-43-4 Learning Effects Applied to Each Technology 

TECHNOLOGY LEARNING EFFECT

Low friction lubricants None 

Engine friction reduction None 

VVT – intake cam phasing Time

VVT – coupled cam phasing Time 

VVT – dual cam phasing Time

Cylinder deactivation Time

Discrete VVLT Time

Continuous VVLT Time

GDI – stoichiometric Time

GDI – lean burn Time

Turbocharge (with no downsize) Time 

Downsize (with no turbocharge) Time 

Turbocharge with downsize Time 

Cam configuration changes (with no downsize) Time 

Homogeneous charge CI Time 

Conversion to diesel Time 

Aggressive shift logic Time 

Early torque converter lockup Time 

5-speed automatic Time 

6-speed automatic Time 

6-speed DCT – dry clutch Time 

6-speed DCT – wet clutch Time 

6-speed manual Time 

CVT Time 

Stop-Start Volume 

IMA/ISA/BSG (includes engine downsize) Volume 

2-Mode hybrid electric vehicle Volume

Power-split hybrid electric vehicle Time 

Plug-in hybrid electric vehicle Volume

Plug-in hybrid electric vehicle Volume 

Full electric vehicle Volume

Improved high efficiency alternator & electrification of accessories Time 

Upgrade to 42 volt electrical system Time

Electric power steering (12 or 42 volt) Time 

Aero drag reduction (20% on cars, 10% on trucks) Time 

Low rolling resistance tires None 

Low drag brakes (ladder frame only) None 

Secondary axle disconnect (unibody only) None 

Front axle disconnect (ladder frame only) Time 

A/C Leakage Reduction Time 

A/C Efficiency Improvements Time 

Table 3-20Table 3-20Table 3-20 through Table 3-25Table 324 show Volpe model 

costs and effectiveness values for each particular technology described throughout this 

chapter. The costs shown are applicable for the 2012 model year. The Volpe Model 

handles learning effects within the model itself so that individual technology costs in the 

2016 model year would be lower than those shown in the tables. 

Table 3-26Table 3-26Table 3-26 through Table 3-35Table 3-35Table 3-35 show 

OMEGA model costs and effectiveness values for each particular technology described 

throughout this chapter. The costs shown are applicable for the 2016 model year and, 

therefore, represent fully learned costs in the context of EPA’s analysis. For technologies 

Field Code Changed

Field Code Changed

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Technologies Considered in the Agencies’ Analysis 

3-21 

added in years prior to 2016, EPA has backed out the learning effects relative to the costs 

shown in the tables. For example, Table 3-28Table 3-28Table 3-28 shows the small car 

stop-start vehicle cost as $351 in 2016. In the 2012 model year, this cost would be higher 

since the volume-based learning reflected in the 2016 cost would not have occurred yet. 

Backing out two volume-based learning steps (i.e., dividing $351 by 80% twice) would 

result in a 2012 cost estimate of $548.

The different handling of learning effects across the two analyses (that done by 

EPA and that by NHTSA) would have little impact on the overall results of the analyses. 

NHTSA handles learning effects in the CAFE model. EPA handles learning effects 

outside of the OMEGA model since OMEGA is run for only one model year - 2016. 

Because the CAFE model adds technology on a year-by-year basis, it applies volumebased learning effects once the applicable production volume thresholds have been 

exceeded. In contrast, EPA would not apply volume-based learning until year 3 

(assumed to be the point at which initial production volumes have doubled). Most 

technologies in both analyses are subject to time-based learning which is applied on an 

annual basis in the same way by both agencies (with the exception that NHTSA applies 

time-based learning in the CAFE model while EPA applies it outside the OMEGA 

model). Importantly, by the 2016 model year, both agencies will have applied two 

volume-based learning steps to the appropriate technologies (hybrid and electric vehicles 

only) and four time-based learning steps to the appropriate technologies (most other 

technologies) to arrive at the same technology costs. 

3.4 Specific technologies considered and estimates of costs and 

effectiveness 

It is important to note that the cost and effectiveness values presented by NHTSA 

and EPA in this Draft TSD are used when creating input files for the agencies’ respective 

models but are not literally the inputs themselves. The Docket to this proposed 

rulemaking contains the specific input files EPA and NHTSA used when modeling the 

technology cost. 

 

3.4.1 What data sources did the agencies evaluate? 

Refer to section 3.1 for a discussion of the specific data sources and reference 

material used for the analysis of this rulemaking. 

3.4.2 Individual technology descriptions and cost/effectiveness estimates 

The sections that follow describe the technologies applied by both EPA and 

NHTSA. It is important to note that there are distinct differences between the agencies in 

how cost and effectiveness estimations are reported and applied. 

 

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Draft Joint Technical Support Document 

3-22 

EPA reports the total cost and effectiveness associated with a respective 

technology. The technologies are then applied to a vehicle type as a package. To 

calculate a cost for a vehicle package, the individual technologies are summed. To 

estimate the overall effectiveness, the lumped parameter method is applied. 

NHTSA applies cost and effectiveness through a series of decision trees. The 

progressive nature of this methodology results in conditions for which a portion of a 

technology has already been added. In this case, NHTSA would add an incremental 

value which is the difference between the total cost of a technology and the portion 

already existing. An example of this is cylinder deactivation. At the point in the decision 

tree that it is applied, valvetrain technologies which could enable this feature have 

already been added. NHTSA will add the delta in cost, which in this example accounts 

for the NVH attributes. 

3.4.2.1 Engine Technologies

 

NHTSA and EPA have reviewed the engine technology estimates used in 

NHTSA’s MY 2011 CAFE final rule and EPA’s 2008 staff report. In doing so NHTSA 

and EPA reconsidered all available sources and updated the estimates as appropriate. The 

section below describes each of the engine technologies considered for this rulemaking. 

3.4.2.1.1 Low Friction Lubricants (LUB)

One of the most basic methods of reducing fuel consumption in gasoline engines 

is the use of lower viscosity engine lubricants. More advanced multi-viscosity engine 

oils are available today with improved performance in a wider temperature band and with 

better lubricating properties. This can be accomplished by changes to the oil base stock 

(e.g., switching engine lubricants from a Group I base oils to lower-friction, lower 

viscosity Group III synthetic) and through changes to lubricant additive packages (e.g., 

friction modifiers and viscosity improvers). The use of 5W-30 motor oil is now 

widespread and auto manufacturers are introducing the use of even lower viscosity oils, 

such as 5W-20 and 0W-20, to improve cold-flow properties and reduce cold start friction. 

However, in some cases, changes to the crankshaft, rod and main bearings and changes to 

the mechanical tolerances of engine components may be required. In all cases, durability 

testing would be required to ensure that durability is not compromised. The shift to lower 

viscosity and lower friction lubricants will also improve the effectiveness of valvetrain 

technologies such as cylinder deactivation, which rely on a minimum oil temperature 

(viscosity) for operation. 

Several manufacturers have previously commented confidentially, that low 

friction lubricants could have an effectiveness value between 0 to 1 percent. For 

purposes of this NPRM, NHTSA and EPA are using effectiveness estimates within this 

range. Therefore 0.5 percent was used in both models. 
Technologies Considered in the Agencies’ Analysis 

3-23 

The 2002 NAS study estimated the low friction lubricant RPE at $8 to $11 using a 

1.4 markup factor. The NESCCAF study showed an RPE of $5 to $15 with a 1.4 

markup. The EEA report to DOE showed manufacturer costs of $10 to $20 with no 

markup. Confidential Business Information (CBI) data estimates an average incremental 

cost of $3 for the use of low friction lubricants. EPA’s 2008 Staff Report also confirms 

this $3 cost (2006$). Both NHTSA and EPA believe that manufacturer’s estimates are 

the most accurate, and thus continue to believe that the $3 cost estimate is appropriate 

and independent of vehicle class since the engineering work required should apply to any 

engine size. Applying an indirect cost multiplier (ICM) of 1.11, for a low complexity 

technology, results in a compliance cost of $3 per vehicle (2007$) for a MY 2012 through 

MY 2016 vehicle (learning effects are not applied to low friction lubes).c

3.4.2.1.2 Engine Friction Reduction (EFR)

In addition to low friction lubricants, manufacturers can also reduce friction and 

improve fuel consumption by improving the design of engine components and 

subsystems. Approximately 10 percent of the energy consumed by a vehicle is lost to 

friction, and just over half is due to frictional losses within the engine.21 Examples 

include improvements in low-tension piston rings, piston skirt design, roller cam 

followers, improved crankshaft design and bearings, material coatings, material 

substitution, more optimal thermal management, and piston and cylinder surface 

treatments. Additionally, as computer-aided modeling software continues to improve, 

more opportunities for evolutionary friction reductions may become available. 

All reciprocating and rotating components in the engine are potential candidates 

for friction reduction, and minute improvements in several components can add up to a 

measurable fuel economy improvement. The 2002 NAS, NESCCAF and EEA reports as 

well as confidential manufacturer data suggested a range of effectiveness for engine 

friction reduction to be between 1 to 3 percent. NHTSA and EPA continue to believe 

that this range is accurate. Because of the incremental nature of the CAFE model, 

NHTSA needed to continue to use the narrower range of 1-2, which was also used in the 

MY 2011 CAFE final rule. 

In the MY 2011 CAFE final rule, NHTSA estimated a range from $13 to $49 

using a 1.5 RPE on a per cylinder basis, or $9 to $33 without RPE (2007$). In the 2008 

NPRM engine friction reduction was estimated to cost up to $14 without RPE on a per 

cylinder basis (2006$). EPA’s 2008 staff report estimated this at $11 using a 1.5 RPE on 

a per cylinder basis, or $7 without RPE (2006$). After review, NHTSA and EPA believe 

that the cost estimate is closer to the lower end of the MY 2011 CAFE final rule range 

and thus for this rulemaking is $13 per cylinder compliance cost (2007$), including the 

low complexity ICM markup value of 1.11, for a MY 2012 through MY 2016 vehicle 

 

c

 Note that the costs developed for low friction lubes for this analysis reflect the costs associated with any 

engine changes that would be required as well as any durability testing that may be required.
Draft Joint Technical Support Document 

3-24 

(learning effects are not applied to engine friction reduction). This cost is multiplied by 

the number of engine cylinders. 

3.4.2.1.3 Variable Valve Timing (VVT)

Variable valve timing (VVT) classifies a family of valve-train designs that alter 

the timing of the intake valve, exhaust valve, or both, primarily to reduce pumping losses, 

increase specific power, and control the level of residual gases in the cylinder. VVT 

reduces pumping losses when the engine is lightly loaded by controlling valve timing 

closer to an optimum needed to sustain horsepower and torque. VVT can also improve 

volumetric efficiency at higher engine speeds and loads. Additionally, VVT can be used 

to alter (and optimize) the effective compression ratio where it is advantageous for 

certain engine operating modes (e.g., in the Atkinson Cycle). 

VVT has now become a widely adopted technology: in MY 2007, over half of all 

new cars and light trucks had engines with some method of variable valve timing.22

 

Manufacturers are currently using many different types of variable valve timing, which 

have a variety of different names and methods. The three major types of VVT are listed 

below. 

Each of the three implementations of VVT uses a cam phaser to adjust the 

camshaft angular position relative to the crankshaft position, referred to as “camshaft 

phasing.” The phase adjustment results in changes to the pumping work required by the 

engine to accomplish the gas exchange process. The majority of current cam phaser 

applications use hydraulically-actuated units, powered by engine oil pressure and 

managed by a solenoid that controls the oil pressure supplied to the phaser. 

3.4.2.1.3.1 Intake Cam Phasing (ICP) 

Valvetrains with ICP, which is the simplest of the cam phasing technologies, can 

modify the timing of the inlet valves by phasing the intake camshaft while the exhaust 

valve timing remains fixed. This requires the addition of a cam phaser on each bank of 

intake valves on the engine. An in-line 4-cylinder engine has one bank of intake valves, 

while V-configured engines have two banks of intake valves. 

NHTSA’s MY 2011 CAFE final rule and EPA 2008 Staff Report estimated an 

effectiveness of 1 to 2 percent for ICP, which was supported by the NESCCAF report and 

a majority of confidential manufacturer comments. The agencies have found no 

additional sources to suggest strongly that this estimate is inaccurate, and so have 

employed it for this NPRM. 

As for costs, NHTSA’s MY 2011 CAFE final rule estimated a $61 RPE ($41 nonRPE) cost per cam phaser, based on the 2008 Martec Report and confidential 

manufacturer data (2007$). In the 2008 staff report, EPA estimated this at $59 using a 

1.5 RPE or $40 without RPE (2006$). NHTSA and EPA believe that this estimate 

remains accurate. Using the new indirect cost multiplier of 1.11, for a low complexity 
Technologies Considered in the Agencies’ Analysis 

3-25 

technology, the compliance cost per cam phaser would be $45 per bank , yielding a $45 

cost for and in-line engine configurations and $90 for V-engine configurations for a MY 

2012 vehicle (2007$). Time-based learning is applied to ICP so the MY 2016 cost would 

be $40 for in in-line engine and $80 for the V-engine (2007$). 

 

3.4.2.1.3.2 Coupled Cam Phasing (CCPS and CCPO) 

Valvetrains with coupled (or coordinated) cam phasing can modify the timing of 

both the inlet valves and the exhaust valves an equal amount by phasing the camshaft of a 

single overhead cam (SOHC) engine or an overhead valve (OHV) engine.d For overhead 

cam engines, this requires the addition of a cam phaser on each bank of the engine. Thus, 

an in-line 4-cylinder engine has one cam phaser, while SOHC V-engines have two cam 

phasers. For overhead valve (OHV) engines, which have only one camshaft to actuate 

both inlet and exhaust valves, CCP is the only VVT implementation option available and 

requires only one cam phaser.e

Based on NHTSA’s MY 2011 CAFE final rule, previously-received confidential 

manufacturer data, and the NESCCAF report, NHTSA and EPA estimated the 

effectiveness of CCP to be between 1 to 4 percent. NHTSA and EPA reviewed this 

estimate for purposes of the NPRM, and continue to find it accurate. 

 The same cam phaser has been assumed for ICP and CCP applications, thus CCPs 

cost per cam phaser is identical to ICPs. This results in a cost of $45 for in-line SOHC 

and OHV engines and $90 for SOHC V-engine configurations for a MY 2012 vehicle 

(2007$). With time-based learning applied, these costs for a 2016 MY vehicle would be 

$40 and $80, respectively (2007$). 

 

3.4.2.1.3.3 Dual Cam Phasing (DCP) 

The most flexible VVT design is dual (independent) cam phasing, where the 

intake and exhaust valve opening and closing events are controlled independently. This 

option allows the option of controlling valve overlap, which can be used as an internal 

EGR strategy. At low engine loads, DCP creates a reduction in pumping losses, resulting 

in improved fuel consumption/reduced CO2 emissions. Increased internal EGR also 

results in lower engine-out NOX emissions. The amount by which fuel consumption is 

improved and CO2 emissions are reduced depends on the residual tolerance of the 

combustion system. Additional improvements are observed at idle, where low valve 

overlap could result in improved combustion stability, potentially reducing idle fuel 

consumption. 

 

d

 Although CCP appears only in the SOHC and OHV branches of the decision tree, it is noted that a single 

phaser with a secondary chain drive would allow CCP to be applied to DOHC engines. Since this would 

potentially be adopted on a limited number of DOHC engines NHTSA did not include it in that branch of 

the decision tree. 

e

 It is also noted that coaxial camshaft developments would allow other VVT options to be applied to OHV 

engines. However, since they would potentially be adopted on a limited number of OHV engines NHTSA 

did not include them in the decision tree. 
Draft Joint Technical Support Document 

3-26 

NHTSA MY 2011 CAFE final rule estimated the effectiveness of DCP to be 

between 3 to 5 percent relative to a base engine or 2 to 3 relative to an engine with ICP. 

NHTSA and EPA believe that this estimate remains applicable for the NPRM. 

As above, the same cam phaser has been assumed for ICP and DCP applications. 

Thus, DCP’s cost per cam phaser is identical to ICP’s. DCP requires two cam phasers 

per cylinder bank, one to control the intake valves and one to control the exhaust valves. 

This results in a cost of $90, relative to an engine without ICP, or $45 relative to an 

engine with ICP, minus $6 for the removal of the EGR valve, ultimately yielding costs of 

$84 and $39 respectively for in-line DOHC configurations (all in 2007$). For Vconfiguration engines, the cost is $180 relative to an engine without ICP, or $90 relative 

to an engine with ICP, minus $6 for the removal of the EGR valve, ultimately yielding 

costs of $174 and $84, respectively (all in 2007$). These costs are appropriate for a MY 

2012 vehicle. With time-based learning applied, these costs for a 2016 MY vehicle 

would be $157 and $73, respectively (2007$). 

3.4.2.1.4 Variable Valve Lift (VVL)

Controlling the lift of the valves provides a potential for further efficiency 

improvements. By optimizing the valve-lift profile for specific engine operating regions, 

the pumping losses can be reduced by reducing the amount of throttling required to 

produce the desired engine power output. By moving the throttling losses further 

downstream of the throttle valve, the heat transfer losses that occur from the throttling 

process are directed into the fresh charge-air mixture just prior to compression, delaying 

the onset of knock-limited combustion processes. Variable valve lift control can also be 

used to induce in-cylinder mixture motion, which improves fuel-air mixing and can result 

in improved thermodynamic efficiency. Variable valve lift control can also potentially 

reduce overall valvetrain friction. At the same time, such systems may also incur 

increased parasitic losses associated with their actuation mechanisms. A number of 

manufacturers have already implemented VVLT into their fleets (Toyota, Honda, and 

BMW), but overall this technology is still available for most of the fleet. There are two 

major classifications of variable valve lift, described below: 

1. Discrete Variable Valve Lift (DVVLS, DVVLD, DVVLO) 

DVVL systems allow the selection between two or three discrete cam profiles by 

means of a hydraulically-actuated mechanical system. By optimizing the cam profile for 

specific engine operating regions, the pumping losses can be reduced by reducing the 

amount of throttling required to produce the desired engine power output. This increases 

the efficiency of the engine. These cam profiles consist of a low and a high-lift lobe, and 

may include an inert or blank lobe to incorporate cylinder deactivation (in the case of a 3-

step DVVL system). DVVL is normally applied together with VVT control. DVVL is 

also known as Cam Profile Switching (CPS). DVVL is a mature technology with low 

technical risk. 

NHTSA’s MY 2011 CAFE final rule, previously-received confidential 

manufacturer data, and the NESCCAF report, all estimate the effectiveness of DVVL to 
Technologies Considered in the Agencies’ Analysis 

3-27 

be between 1 to 4 percent above that realized by VVT systems. NHTSA and EPA 

believe this estimate continues to be applicable for the NPRM. 

In the 2011 CAFE final rule, NHTSA estimated an RPE (1.5 markup factor) of 

$201 for an inline 4-cylinder engine, $306 for a V6 engine and $396 for a V8 engine or 

without the RPE markup $134, $204, $264, respectively (all in 2007$). In the 2008 staff 

report, EPA estimated this at $169, $246, and $322, respectively, using a 1.5 RPE factor 

(2006$) or $113, $164 and $215, respectively without markup (all in 2006$). For this 

analysis, the agencies have estimated the compliance costs, including $25 for controls 

and using a 1.11 ICM for a low complexity technology, at $141 for an inline 4-cylinder 

engine, $205 for a V6 engine and $293 for a V8 for a 2012 MY vehicle (2007$). With 

time-based learning applied, these costs would be $125, $181, and $259, respectively for 

a 2016 MY vehicle (2007$). 

 

2. Continuously Variable Valve Lift (CVVL) 

 

In CVVL systems, valve lift is varied by means of a mechanical linkage, driven 

by an actuator controlled by the engine control unit. The valve opening and phasing vary 

as the lift is changed and the relation depends on the geometry of the mechanical system. 

BMW has considerable production experience with CVVL systems and has sold portinjected “Valvetronic” engines since 2001. CVVL allows the airflow into the engine to 

be regulated by means of intake valve opening reduction, which improves engine 

efficiency by reducing pumping losses from throttling the intake system further upstream 

as with a conventionally throttled engine. 

 Variable valve lift gives a further reduction in pumping losses compared to that 

which can be obtained with cam phase control only, with CVVL providing greater 

effectiveness than DVVL, since it can be fully optimized for all engine speeds and loads, 

and is not limited to a two or three step compromise. There may also be a small 

reduction in valvetrain friction when operating at low valve lift, resulting in improved 

low load fuel consumption for cam phase control with variable valve lift as compared to 

cam phase control only. Most of the fuel economy effectiveness is achieved with 

variable valve lift on the intake valves only. CVVL is only applicable to double overhead 

cam (DOHC) engines. 

NHTSA’s MY 2011 CAFE final rule estimated the effectiveness for CVVL at 1.5 

to 3.5 percent over an engine with DCP, but also recognize that it could go up as high as 

5% above and beyond DCP to account for the implementation of more complex CVVL 

systems such as BMW’s “valvetronic” engines. This coincides with EPA Staff report 

estimates of the contribution of CVVL, which were based on the NESCCAF report, in 

which CVVL could improve effectiveness by 4 percent (minivans) and up to 6 percent 

(large cars) over dual cam phasing. Thus, the effectiveness range for CVVL in this joint 

TSD ranges from 1.5 to 6 percent depending on the complexity level of the application. 

However, due to the complexity and cost of this technology, the GHG model did not 

consider it and the CAFE models projected very limited application of less complex 
Draft Joint Technical Support Document 

3-28 

version of this technology respectively (i.e., 2 out of 1100 vehicles in the CAFE model). 

The most recent submission of manufacturers’ product plans confirmed that this 

technology will not be applied by most manufacturers. 

 

In the MY 2011 CAFE final rule, NHTSA estimated and RPE (1.5 factor) of 

continuously variable valve lift to be $306 for an inline 4-cylinder engine, $432 for a V6 

engine and $582 for a V8 engine or without RPE $204, $287, $388, respectively. In the 

2008 staff report, EPA estimated this at $254, $466, and $508, respectively, using a 1.5 

RPE factor (2006$) or $169, $311 and $339, respectively without markup (all in 2006$) 

For this analysis, the agencies have estimated the compliance costs, using a 1.45 ICM for 

a high complexity technology, at $277 for an inline 4-cylinder engine, $509 for a V6 

engine and $554 for a V8 engine for a MY 2012 vehicle (2007$). With time-based 

learning applied, these costs would become $245, $449, and $489, respectively for a MY 

2016 vehicle (2007$). 

3.4.2.1.5 Cylinder Deactivation (DEACS, DEACD, DEACO)

In conventional spark-ignited engines throttling the airflow controls engine torque 

output. At partial loads, efficiency can be improved by using cylinder deactivation 

instead of throttling. Cylinder deactivation (DEAC) can improve engine efficiency by 

disabling or deactivating (usually) half of the cylinders when the load is less than half of 

the engine’s total torque capability – the valves are kept closed, and no fuel is injected – 

as a result, the trapped air within the deactivated cylinders is simply compressed and 

expanded as an air spring, with reduced friction and heat losses. The active cylinders 

combust at almost double the load required if all of the cylinders were operating. 

Pumping losses are significantly reduced as long as the engine is operated in this “partcylinder” mode. 

 

Cylinder deactivation control strategy relies on setting maximum manifold 

absolute pressures or predicted torque within which it can deactivate the cylinders. Noise 

and vibration issues reduce the operating range to which cylinder deactivation is allowed, 

although manufacturers are exploring vehicle changes that enable increasing the amount 

of time that cylinder deactivation might be suitable. Some manufacturers may choose to 

adopt active engine mounts and/or active noise cancellations systems to address NVH 

concerns and to allow a greater operating range of activation. Manufacturers have stated 

that use of DEAC on 4 cylinder engines would cause unacceptable NVH; therefore 

cylinder deactivation has not been applied to 4-cylinder engines. 

Cylinder deactivation has seen a recent resurgence thanks to better valvetrain 

designs and engine controls. General Motors and Chrysler Group have incorporated 

cylinder deactivation across a substantial portion of their V8-powered lineups. Honda 

(Odyssey, Pilot) offers V6 models with cylinder deactivation. 
Technologies Considered in the Agencies’ Analysis 

3-29 

Effectiveness improvements scale roughly with engine displacement-to-vehicle 

weight ratio: the higher displacement-to-weight vehicles, operating at lower relative loads 

for normal driving, have the potential to operate in part-cylinder mode more frequently. 

NHTSA and EPA reviewed the MY 2011 CAFE estimate and confirmed a range 

of 0.5 to 6 percent depending on the valvetrain configuration and other existing 

technologies. The 6 percent was based on official fuel economy test data (i.e., 2005 V6 

Honda Odyssey with cylinder deactivation compared to the same vehicle (and engine 

displacement) without cylinder deactivation). The OMEGA model, which is based on 

packages, applies 6% reduction in CO2 emissions in all applications. The CAFE model, 

due to its incremental nature, uses a range depending on the engine valvetrain 

configuration. For example, for DOHC engines which are already equipped with DCP 

and DVVLD, there is little benefit that can be achieved from adding cylinder deactivation 

since the pumping work has already been minimized and internal Exhaust Gas 

Recirculation (EGR) rates are maximized, so the effectiveness is only up to 0.5 percent 

for DEACD. For Single Overhead Camshaft engines which have CCP and DVVLS 

applied, effectiveness ranged from 2.5 to 3 percent for DEACS. For OHV engines, 

without VVT or VVL technologies, the effectiveness for DEACO ranged from 3.9 to 5.5 

percent. 

NHTSA and EPA considered a range of $170 to $190 (or $28 to $190 depending 

on whether an engine already has lost motion devices, oil control valves and camshaft 

position sensors). This is a departure from NHTSA’s 2011 final rule, which used a range 

of $306 to $400. That range was primarily based on 2008 Martec Report and applied a 

higher RPE value. In reviewing these assumptions, NHTSA and EPA amended the MY 

2011 CAFE estimates and adjusted the estimates to include the new ICM low complexity 

markup of 1.11. The EPA staff report estimated this ranging from $203 to $229 (RPE 

using a 1.5 factor) or $135 to $153 without RPE (2006$). NHTSA’s NPRM showed 

estimates of a $170 for a 6-cylinder engine and $190 for an 8-cylinder engine—when 

adjusted for 2007 dollars and using the new ICM multipliers— for engines that do not 

have lost motion devices. These numbers were within the ranges described by the 2002 

NAS and NESCCAF reports. The $170 and $190 costs are appropriate of a MY 2012 

vehicle (2007$). With time-based learning applied, these would become $150 and $169, 

respectively, for a MY 2016 vehicle (2007$). 

If lost motion devices are on the engine, the cost of DEAC as applied to SOHC 

and DOHC engines could be as low as $28.f

 This $28g accounts for the potential 

additional application of active engine mounts on SOHC and DOHC engines and can 

only be applied on 50 percent of the vehicles. Further, this SOHC and DOHC engine 

 

f

 The $28 is an adjustment from the $75 estimate used in the MY 2011 final rule to account for the new 

ICM markup factor and the fact that it could only be applied on up to 50 percent of the vehicles. 
Draft Joint Technical Support Document 

3-30 

estimate is relevant to the CAFE model only because the OMEGA model does not apply 

technologies in the same incremental fashion as the CAFE model. 

3.4.2.1.6 Conversion to Double Overhead Camshaft Engine with 

Dual Cam Phasing (CDOHC)

Double overhead camshaft engines achieve increased airflow at high engine 

speeds, improve volumetric efficiency and reductions of the valvetrain’s moving mass. 

Such engines typically develop higher power at high engine speeds. Manufacturers may 

choose to replace OHV engines with DOHC engine designs with dual cam phasing 

(DCP). EPA and NHTSA estimate the effectiveness to be between 1 to 2.5 percent. 

 

As for costs, NHTSA’s MY 2011 CAFE final rule assumed that CDOHC would 

have an RPE of $746 ($497 non-RPE) for a V8 engine, $590 ($393 non-RPE) for a V6 

engine and $373 ($249 non-RPE) for inline 4-cylinder engine (2007$). In the 2008 staff 

report, EPA did not estimate a cost for this specific technology. For purposes of this 

NPRM, NHTSA revised the costs only by identifying this technology as a low 

complexity technology and applying an indirect cost multiplier of 1.11 resulting in a 

compliance cost of $552 for V8 engine, $436 for a V6 and $276 for an inline 4-cylinder 

engine. The above costs are for a MY 2012 vehicle and with the application of timebased learning will be slightly lower for MY 2016 vehicle 

3.4.2.1.7 Stoichiometric Gasoline Direct Injection (SGDI)

Gasoline direct injection (GDI), or Spark Ignition Direct injection (SIDI), engines 

inject fuel at high pressure directly into the combustion chamber (rather than the intake 

port in port fuel injection). GDI requires changes to the injector design, an additional 

high pressure fuel pump, new fuel rails to handle the higher fuel pressures and changes to 

the cylinder head and piston crown design. Direct injection of the fuel into the cylinder 

improves cooling of the air/fuel charge within the cylinder, which allows for higher 

compression ratios and increased thermodynamic efficiency without the onset of 

combustion knock. Recent injector design advances, improved electronic engine 

management systems and the introduction of multiple injection events per cylinder firing 

cycle promote better mixing of the air and fuel, enhance combustion rates, increase 

residual exhaust gas tolerance and improve cold start emissions. GDI engines achieve 

higher power density and match well with other technologies, such as boosting and 

variable valvetrain designs. 

Several manufacturers have recently introduced vehicles with GDI engines, 

including VW/Audi, BMW, Toyota (Lexus IS 350) and General Motors (Chevrolet 

Impala and Cadillac CTS 3.6L). BMW, GM, Ford and VW/Audi have announced their 

plans to increase dramatically the number of GDI engines in their portfolios. 
Technologies Considered in the Agencies’ Analysis 

3-31 

NHTSA’s MY 2011 CAFE final rule estimated the effectiveness of SGDI to be 

between 2 and 3 percent. NHTSA and EPA reviewed estimates from the Auto Alliance 

of American Manufacturers, which projects 3 percent gains in fuel efficiency and a 7 

percent improvement in torque. The torque increase provides the opportunity to 

downsize the engine allowing an increase in efficiency of up to a 5.8 percent. NHTSA 

and EPA also reviewed other published literature, reporting 3 percent effectiveness for 

SGDI.23 Another source reports a 5 percent improvement on the NEDC drive cycle.24 

Confidential manufacturer data reported an efficiency effectiveness range of 1 to 2 

percent. NHTSA and EPA determined that the range of 2 to 3 percent continues to be 

appropriate. Combined with other technologies (i.e., boosting, downsizing, and in some 

cases, cooled EGR), SGDI can achieve greater reductions in fuel consumption and CO2 

emissions compared to engines of similar power output. 

The NHTSA and EPA cost estimates for SGDI take into account the changes 

required to the engine hardware, engine electronic controls, ancillary and Noise Vibration 

and Harshness (NVH) mitigation systems. Through contacts with industry NVH 

suppliers, and manufacturer press releases, the agencies believe that the NVH treatments 

will be limited to the mitigation of fuel system noise, specifically from the injectors and 

the fuel lines. To that end, the agencies estimate SGDI costs at $251 for an inline 4-

cylinder and $326 for V6 and $353 for V8 including the low complexity ICM markup 

value of 1.11 (2007$). The preceding costs are for a MY 2012 vehicle. With time-based 

learning applied, these costs would be $222, $287, and $301 for a MY 2016 vehicle 

(2007$). 

 

3.4.2.1.8 Combustion Restart (CBRST)

Combustion restart allows “start-stop” functionality of DI engines through the 

implementation of an upgraded starter with bi-directional rotation to allow precise 

crankshaft positioning prior to subsequent fuel injection and spark ignition, allowing 

engine restart. This method of implementing engine stop/start functionality allows not 

only the fuel savings from not idling the engine, but also reduces fuel consumption as the 

engine speeds up to its operational speed. A Direct Injection (DI) fuel system is required 

for implementation of this technology. 

NHTSA reviewed the MY 2011 CAFE final rule assumptions and determined that 

due to technical risks with its implementation, this technology will be made available in 

the CAFÉ model in MY 2014 at the earliest. Some of the risks are associated with 

unresolved issues regarding the impact of very high or very low ambient air temperatures 

on the ability to start the engine in the described manner. Although the starter motor can 

provide fail-safe starting capability in these temperature limited areas, strategies must be 

developed to manage the transitions. Others relate to production readiness. 

Additional hardware is required to implement combustion restart, beyond SGDI. 

This includes a battery sensor, incremental wiring and high current switching, an 
Draft Joint Technical Support Document 

3-32 

incremental crank position sensor, and, in the case of an automatic transmission 

applications, a transmission oil pump to allow for torque converter continuity. 

BMW has published a 3.5 percent fuel consumption effectiveness over the NEDC 

drive cycle for combustion restart,25 and AVL a 4.8 percent effectiveness.26 However, 

these reported effectiveness levels could potentially be reduced significantly on the EPA 

combined drive cycle, as combustion restart does not save fuel on the highway drive 

cycle. Therefore, NHTSA estimates the fuel consumption effectiveness for CBRST to 

range from 2 to 2.5 percent. 

Regarding the cost estimate, NHTSA determined that the estimate of $118 from 

the 2008 Martec Report cost estimates for individual pieces was the best available. The 

total RPE cost (excluding transmission pump) is $141 at high volumes, which includes 

$70 for upgrading the starter, $10 for a battery sensor and wiring, $10 for high current 

switch and $4 for crank sensor a totaling $94 (non-RPE) cost. Applying an indirect cost 

multiplier of 1.25, for a medium complexity technology, results in a compliance cost of 

$118 for a MY 2012 vehicle and will be reduced in future years with the application of 

time-based learning. 

3.4.2.1.9 Turbocharging and Downsizing (TRBDS)

The specific power of a naturally aspirated engine is primarily limited by the rate 

at which the engine is able to draw air into the combustion chambers. Turbocharging and 

supercharging (grouped together here as boosting) are two methods to increase the intake 

manifold pressure and cylinder charge-air mass above naturally aspirated levels. 

Boosting increases the airflow into the engine, thus increasing the specific power level, 

and with it the ability to reduce engine displacement while maintaining performance. 

This effectively reduces the pumping losses at lighter loads in comparison to a larger, 

naturally aspirated engine. 

Almost every major manufacturer currently markets a vehicle with some form of 

boosting. While boosting has been a common practice for increasing performance for 

several decades, turbocharging has considerable potential to improve fuel economy and 

reduce CO2 emissions when the engine displacement is also reduced. Specific power 

levels for a boosted engine often exceed 100 hp/L, compared to average naturally 

aspirated engine power densities of roughly 70 hp/L. As a result, engines can 

conservatively be downsized roughly 30 percent to achieve similar peak output levels. In 

the last decade, improvements to turbocharger turbine and compressor design have 

improved their reliability and performance across the entire engine operating range. New 

variable geometry turbines and ball-bearing center cartridges allow faster turbocharger 

spool-up (virtually eliminating the once-common “turbo lag”) while maintaining high 

flow rates for increased boost at high engine speeds. However, even with turbocharger 

improvements, maximum engine torque at very low engine speed conditions, for example 

launch from standstill, is increased less than at mid and high engine speed conditions. 
Technologies Considered in the Agencies’ Analysis 

3-33 

The potential to downsize engines may be less on vehicles with low displacement to 

vehicle mass ratios in order to provide adequate acceleration from standstill, particularly 

up grades or at high altitudes. 

Use of GDI systems with turbocharged engines and air-to-air charge air cooling 

also reduces the fuel octane requirements for knock limited combustion and allows the 

use of higher compression ratios. Ford’s “Ecoboost” downsized, turbocharged GDI 

engines introduced on MY 2010 vehicles allow the replacement of V8 engines with V6 

engines with improved in 0-60 mph acceleration and with fuel economy improvements of 

up to 12 percent.27

NHTSA and EPA reviewed NHTSA’s MY 2011 CAFE final rule estimates that a 

turbocharged and downsized engine at equivalent performance levels would offer an 

effectiveness improvement of 2 to 5 percent over a naturally-aspirated SGDI engine of 

comparable performance. This would equate to a 12 to 14 effectiveness improvement 

over baseline fixed-valve engine, similar to the estimate for Ford’s Ecoboost. NHTSA 

and EPA kept these estimates for this NPRM. 

Recently published data with advanced spray-guided injection systems and more 

aggressive engine downsizing targeted towards reduced fuel consumption and CO2 

emissions reductions indicate that the potential for reducing CO2 emissions for 

turbocharged, downsized GDI engines may be as much as 15 to 30% relative to port-fuelinjected engines.14,15,16,17,18 EPA and NHTSA seek comment on how best to determine 

these values. Confidential manufacturer data suggests an incremental range of fuel 

consumption and CO2 emission reduction of 4.8 to 7.5 percent for turbocharging and 

downsizing. Other publicly-available sources suggest a fuel consumption and CO2 

emission reduction of 8 to 13 percent compared to current-production naturally-aspirated 

engines without friction reduction or other fuel economy technologies: a joint technical 

paper by Bosch and Ricardo suggesting fuel economy gain of 8 to 10 percent for 

downsizing from a 5.7 liter port injection V8 to a 3.6 liter V6 with direct injection using a 

wall-guided direct injection system;28 a Renault report suggesting a 11.9 percent NEDC 

fuel consumption gain for downsizing from a 1.4 liter port injection in-line 4-cylinder 

engine to a 1.0 liter in-line 4-cylinder engine, also with wall-guided direct injection;29 and 

a Robert Bosch paper suggesting a 13 percent NEDC gain for downsizing to a 

turbocharged DI engine, again with wall-guided injection.30 These reported fuel 

economy benefits show a wide range depending on the GDI technology employed. 

As noted above, the agencies relied on engine teardown analyses conducted by 

EPA, FEV and Munro to develop costs for turbocharged GDI engines.31 Teardown 

studies are one of the most effective ways to estimate technology costs. The study 

showed the cost of a turbocharger (variable geometry turbo, air-to-air charge air cooler, 

auxiliary cooling pump, lubes, upgrades to the exhaust manifold, and necessary controls) 

for the I4 DOHC engine studied to be $372 (2007$). The study also showed an engine 

downsizing savings for downsizing a 2.4L DOHC engine to a 1.6L DOHC engine of $60 
Draft Joint Technical Support Document 

3-34 

(2007$). These savings were the result of reduced bore spacing, a shorter camshaft and 

crankshaft, removal of two balance shafts and associated hardware, and a smaller intake 

manifold. These values ($372 and -$60) have been used for I4 engines adding boost and 

for I4 engines undergoing downsizing to a smaller I4, respectively. These costs are 

applicable for a MY 2012 vehicle. With time-based learning applied, these costs would 

be $329 and -$53 for a MY 2016 vehicle. 

Consistent with the 2008 staff report, the agencies estimate direct manufacturing 

costs associated with downsizing to be $50 per cylinder, $10 per valve, and $100 per cam 

shaft for the 2015 model year (2006$). Applying a 1 year of time-based learning to these 

costs, and adjusting them to 2007 dollars, results in 2016 direct manufacturing costs of 

$50 per cylinder, $10 per valve, and $100 per cam shaft. A summary of the final costs 

and how they were calculated is shown in Table 3-5Table 3-5Table 3-5 for a MY 2016 

vehicle in 2007$. For a MY 2012 vehicle, 4 years of time-based learning at 3% per year 

would be added back to the values shown in Table 3-5Table 3-5Table 3-5. 

Field Code Changed

Field Code Changed
Technologies Considered in the Agencies’ Analysis 

3-35 

Table 3-53-5 Turbocharging and Downsizing and Other Camshaft Configuration Costs in 2016 (2007 dollars) 

technology incremental to 

Direct manufacturing costs in 2016 

IC Mark 

up 

Compliance 

Cost* 

Turbo Engine downsize costs 

I3/I4 V6/V8 cylinder # 

change at 

$50/ 

valve # 

change at 

$10/ 

Cam # 

change at 

$100/ 

Resultant 

Downsize 

cost 

Turbo w/o downsize 

Downsize w/o turbo 

Turbocharge (single) Base engine $329 n/a n/a n/a n/a n/a 1.11 $366 Turbocharge (twin) Base engine n/a $598 n/a n/a n/a n/a 1.11 $663 Downsize to I4 DOHC V6 DOHC n/a n/a -2 -8 -2 -$379 1.11 -$337 Downsize to I4 DOHC V6 SOHC n/a n/a -2 +4 0 -$60 1.11 -$53 Downsize to I4 DOHC V6 OHV n/a n/a -2 +4 +3 $239 1.11 $265 Downsize to I4 DOHC I4 DOHC (larger) n/a n/a 0 0 0 -$53 1.11 -$47 Downsize to I3 DOHC I4 DOHC n/a n/a -1 -4 0 -$90 1.11 -$80 Downsize to V6 DOHC V8 DOHC n/a n/a -2 -8 0 -$179 1.11 -$160 Downsize to V6 DOHC V8 SOHC 2V n/a n/a -2 +8 +2 $179 1.11 $199 Downsize to V6 DOHC V8 SOHC 3V n/a n/a +2 0 +2 $299 1.11 $332 Downsize to V6 DOHC V8 OHV n/a n/a -2 +8 +3 $279 1.11 $310 

Turbo with downsize 

Downsize to I4 DOHC & add turbo 

V6 DOHC w/o turbo $398 n/a -2 -8 -2 -$379 1.25 $214 

Downsize to I4 DOHC & add turbo 

V6 SOHC w/o turbo $398 n/a -2 +4 0 -$60 1.25 $453 

Downsize to I4 DOHC & add turbo 

V6 OHV w/o turbo $398 n/a -2 +4 +3 $239 1.25 $797 

Downsize to I4 DOHC & add turbo 

I4 DOHC (larger) w/o turbo $329 n/a 0 0 0 -$53 1.25 $372 

Downsize to I3 DOHC & add turbo 

I4 DOHC w/o turbo $329 n/a -1 -4 0 -$90 1.25 $344 

Downsize to V6 DOHC & add twin turbo 

V8 DOHC w/o turbo n/a $598 -2 -8 0 -$179 1.25 $613 

Downsize to V6 DOHC & add twin turbo 

V8 SOHC 2V w/o turbo n/a $598 -2 +8 +2 $179 1.25 $971 

Downsize to V6 DOHC & add twin turbo 

V8 SOHC 3V w/o turbo n/a $598 -2 0 +2 $100 1.25 $872 

Downsize to V6 DOHC & add twin turbo 

V8 OHV w/o turbo n/a $598 -2 +8 +3 $279 1.25 $1,096 

Cam 

changes 

Convert to V6 DOHC V6 SOHC n/a n/a 0 +12 +2 $319 1.11 $354 Convert to V6 DOHC V6 OHV n/a n/a 0 +12 +3 $418 1.11 $464 Convert to V8 DOHC V8 SOHC 2V n/a n/a 0 +16 +2 $359 1.11 $398 Convert to V8 DOHC V8 SOHC 3V n/a n/a 0 +8 +2 $279 1.11 $310 Convert to V8 DOHC V8 OHV n/a n/a 0 +16 +3 $419 1.11 $509 

* Note that, where downsizing results in cost savings, the compliance cost is calculated as the IC markup less 1 which is then multiplied by the absolute value of the direct manufacturincost. The absolute value of the direct manufacturing cost is then subtracted from that to arrive at the end result. For example, for the V6 DOHC downsized to the I4 DOHC at a direct 

manufacturing cost of -$379, the compliance cost would be (1.11-1) x │-$379│ - │-$379│ = -$337. 
Draft Joint Technical Support Document 

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3.4.2.1.10 Cooled Exhaust Gas Recirculation/EGR Boost (EGRB)

Cooled exhaust gas recirculation (cooled EGR) or EGR Boost is a combustion 

concept that involves utilizing EGR as a charge dilutant for controlling combustion 

temperatures and cooling the EGR prior to its introduction to the combustion system. 

Higher exhaust gas residual levels at part load conditions reduce pumping losses for 

increased fuel economy. Cooled EGR reduces knock sensitivity which enables the use of 

more optimal spark advance or enables compression ratio to be increased for improved 

thermal efficiency, and increased fuel economy. Currently available turbo, charge air 

cooler, and EGR cooler technologies are sufficient to demonstrate the feasibility of this 

concept. 

 

However, this remains a technology with a number of issues that still need to be 

addressed and for which there is no production experience. EGR system fouling 

characteristics could be potentially worse than diesel EGR system fouling, due to the 

higher HC levels found in gasoline exhaust. Turbocharger compressor contamination 

may also be an issue for low pressure EGR systems. Additionally, transient controls of 

boost pressure, EGR rate, cam phasers and intake charge temperature to exploit the 

cooled EGR combustion concept will require development beyond what has already been 

accomplished by the automotive industry. These are all “implementation readiness” 

issues that must be resolved prior to putting EGR Boost into high volume production. 

 

NHTSA has concluded that these implementation issues could be resolved 

and this technology could be brought to production by MY 2013. Supporting this 

conclusion, MEMA has previously suggested a 5 to 7 percent effectiveness for 

cooled EGR systems, although without boosting.32

 Two public sources indicate a 10 to 20 percent fuel consumption 

effectiveness for a downsized DI engine with cooled EGR compared to a naturally 

aspirated baseline engine33 and a 4 percent fuel consumption effectiveness for

cooled EGR compared to a conventional downsized DI turbocharged engine.34 

Based on the data from these reports, NHTSA estimates the incremental reduction 

in fuel consumption for EGR Boost to be 4 percent over a turbocharged and 

downsized DI engine. Thus, if TRBDS precedes EGRB, adding the 12 percent gain 

from TRBDS to the 4 percent gain from EGRB results in total fuel consumption 

reduction of 16 percent. This is in agreement with the range suggested in the Lotus 

report.

Regarding costs, the addition of EGR cooler and EGR valve were estimated in 

NHTSA’s MY 2011 rule to have an incremental RPE cost impact of approximately $173 

based on confidential individual component cost data from 2008 Martec describing EGR 

cooler costs of $75, EGR valve costs of $20 and associated piping costs of $20, totaling 

$115 (non-RPE). For purposes of this NPRM, NHTSA found no information to indicate 

that these estimates were inaccurate. To that end, NHTSA applied an indirect cost 

Formatted: Left: 1.25", Right: 1.25"
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multiplier of 1.25, for a medium complexity technology, resulting in a compliance cost of 

$144 for MY 2012 vehicles with time-based learning applied. However, given the lack 

of public data on this technology, the agencies seek comment on these assumptions. 

 

3.4.2.1.11 Diesel Engine Technologies 

Diesel engines have several characteristics that give them superior fuel efficiency 

compared to conventional gasoline, spark-ignited engines. Pumping losses are much 

lower due to lack of (or greatly reduced) throttling. The diesel combustion cycle operates 

at a higher compression ratio, with a very lean air/fuel mixture, and turbocharged lightduty diesels typically achieve much higher torque levels at lower engine speeds than 

equivalent-displacement naturally-aspirated gasoline engines. Additionally, diesel fuel 

has a higher energy content per gallon.h However, diesel fuel also has a higher carbon to 

hydrogen ratio, which increases the amount of CO2 emitted per gallon of fuel used by 

approximately 15% over a gallon of gasoline. 

Diesel engines have emissions characteristics that present challenges to meeting 

federal Tier 2 NOx emissions standards. It is a significant systems-engineering 

challenge to maintain the fuel consumption advantage of the diesel engine while meeting 

U.S. emissions regulations. Fuel consumption can be negatively impacted by emissions 

reduction strategies depending on the combination of strategies employed. Emission 

compliance strategies for diesel vehicles sold in the U.S. are expected to include a 

combination of combustion improvements and aftertreatment. These emission control 

strategies are being introduced on Tier 2 light-duty diesel vehicles today 

To achieve U.S. Tier 2 emissions limits, roughly 45 to 65 percent more NOx

reduction is required compared to the Euro VI standards. Additionally, as discussed 

below, there may be a fuel consumption penalty associated with diesel aftertreatment 

since extra fuel is needed for the aftertreatment, and this extra fuel is not used in the 

combustion process of the engine that provides torque to propel the vehicle. 

Light-duty diesel emissions control systems capable of meeting Tier 2 Bin 5 

emission standards are already in production. Several key advances in diesel technology 

have made it possible to reduce emissions coming from the engine prior to aftertreatment. 

These technologies include improved fuel systems (higher injection pressure and 

multiple-injection capability), advanced controls and sensors to optimize combustion and 

emissions performance, higher EGR levels and EGR cooling to reduce NOx, and 

advanced turbocharging systems. 

 

On the aftertreatment side, the traditional 3-way catalyst aftertreatment found on 

gasoline-powered vehicles is ineffective due to the lean-burn combustion of a diesel. All 

diesels will require a diesel particulate filter (DPF) or catalyzed diesel particulate filter 

 

h

 Burning one gallon of diesel fuel produces about 15 percent more carbon dioxide than gasoline due to the 

higher density and carbon to hydrogen ratio. 
Draft Joint Technical Support Document 

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(CDPF), a diesel oxidation catalyst (DOC), and a NOx reduction strategy to comply with 

Tier 2 emissions standards. The most common NOx reduction strategies include the use 

of lean NOx traps (LNT) or selective catalytic reduction (SCR), which are outlined 

below. 

3. Diesel Engine with Lean NOx Trap (LNT) Catalyst AfterTreatment 

A lean NOx trap operates, in principle, by storing oxidizing NO to NO2 in the 

exhaust and storing NO2 on alkali sorbent material. When the control system 

determines (via mathematical model or a NOx sensor) that the trap is saturated with NOx, 

it switches the engine into a rich operating mode or may in some cases inject fuel directly 

into the exhaust stream to produce excess hydrocarbons that act as a reducing agent to 

convert the stored NOx to N2 and water, thereby “regenerating” the LNT and opening up 

more locations for NOx to be stored. LNTs preferentially store sulfate compounds from 

the fuel, which can reduce catalytic performance. The system must undergo periodic 

desulfurization by operating at a net-fuel-rich condition at high temperatures in order to 

retain NOx NOx trapping efficiency. 

NHTSA and EPA have concluded that the application of diesel engines on small 

vehicles is not a viable or cost effective option. The two agencies have also concluded 

that LNT-based diesel engines are best suited to smaller vehicle. Thus for purposes of 

this NPRM the application of LNT-based diesel engines has not been included and cost 

and effectiveness estimates were not generated. 

4. Diesel Engine with Selective Catalytic Reduction (SCR) AfterTreatment 

An SCR aftertreatment system uses a reductant (typically, ammonia derived from 

urea) that is injected into the exhaust stream ahead of the SCR catalyst. Ammonia 

combines with NOx in the SCR catalyst to form N2 and water. The hardware 

configuration for an SCR system is more complicated than that of an LNT, due to the 

onboard urea storage and delivery system (which requires a urea pump and injector to 

inject urea into the exhaust stream). While a rich engine-operating mode is not required 

for NOx reduction, the urea is typically injected at a rate of approximately 3 percent of 

the fuel consumed. Manufacturers designing SCR systems intend to align urea tank 

refills with standard maintenance practices such as oil changes. As is the case with LNTbased diesels, EPA and NHTSA project that SCR-based diesel engines will be available 

within the next couple of years. Mercedes-Benz recently introduced two 2009 model 

year vehicles R320 and GL320, both of which are certified to Tier 2, Bin 5 emission

standardss. Based on public announcements from several other companies, an increased 

number of product offerings from multiple companies are expected over the next few 

years. 

 

 In order to maintain equivalent performance to comparable gasoline-engine 

vehicles, an in-line 4-cylinder diesel engine, with displacement varying around 2.8 liters 

Formatted: Subscript
3-39 

was assumed to replace a V6 gasoline base engine for Performance Compact, 

Performance Midsize, Large Passenger Car, Minivan, and Midsize Truck for the CAFE 

model. A V-6 diesel engine, with displacement varying around 4.0 liters to meet vehicle 

performance requirements, was assumed to replace a V8 gasoline base engine for Large 

Truck and Performance Large Car vehicle classes for the CAFE model. It was also 

assumed that diesel engines for these classes would utilize SCR aftertreatment systems. 

Confidential manufacturer and non-confidential comment data submitted in response to 

NHTSA’s past rulemaking for diesel engines showed a fuel consumption reduction in the 

range of was in the range of 16.7 percent to 26.7 percent fuel consumption reduction or a 

15% to 23% CO2 emission reduction over a baseline gasoline engine. 

NHTSA’s MY 2011 CAFE final rule, which was supported by confidential 

manufacturer data, estimated the fuel consumption reductionbenefit of a SCR-based

diesel engine to be between 19 to 25 percent over a baseline gasoline engine. NHTSA 

and EPA have revisited these values and found them to be reasonable. EPA estimates a 

15 to 26% CO2 reduction for light-duty diesels equipped with SCR.

Diesel engines are more costly than port-injected spark-ignition gasoline engines. 

These higher costs result from: 

• Fuel systems (higher pressures and more responsive injectors); 

• Controls and sensors to optimize combustion and emissions performance; 

• Engine design (higher cylinder pressures require a more robust engine, but 

higher torque output means diesel engines can have reduced displacement); 

• Turbocharger(s); 

• Aftertreatment systems, which tend to be more costly for diesels; 

 

Due to a significant decrease in platinum group metal prices since NHTSA’s MY 

2011 CAFE final rule analysis, the agencies chose to re-analyze diesel costs. In EPA’s 

2008 Staff Report, costs were considered for two types of diesel systems: one using a 

lean-NOx NOX trap (LNT) along with a diesel particulate filter (DPF); and one using a 

selective catalytic reduction (SCR) system along with a DPF. In that report, EPA 

estimated direct manufacturing costs to range from $1,860 for the small car (LNT plus 

DPF) to $2,710 for the large truck (SCR plus DPF). For comparison, the NESCCAF 

study showed direct manufacturing costs of $1,500 to $1,950. More recently, NHTSA’s 

2011 CAFE final rule showed direct manufacturing costs of $2,670 for a 4-cylinder 

engine using a LNT plus DPF system, $3,735 for a 6-cylinder engine using a SCR plus 

DPF system, and $4,668 for an 8-cylinder engine using a SCR plus DPF system. 

NHTSA noted that estimates in the MY 2011 CAFE final rule were higher than those 

shown in the proposed rule due largely to the spike in platinum group metal prices that 

had occurred in the months just prior to issuing the final rule. 

Formatted: Subscript
Draft Joint Technical Support Document 

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The following diesel engine costs were developed by first taking a look back at 

EPA’s 2008 Staff Report, which reveals a couple of factors that resulted in somewhat 

misleading costs. First, the engine costs estimated there did not take into account the 

downsizing that would occur when moving from a gasoline engine to a diesel engine 

(provided equivalent performance was maintained). Second, the engine costs used in that 

analysis were actually stated in terms of 2002 dollars rather than 2006 dollars in which 

the report was meant to be stated. The agencies decided that an update to the enginerelated costs would provide a much better cost estimate of the costs offor converting to 

diesel. This was done by starting with the source for engine costs in the 2008 staff report 

which was an October 2005 EPA Interim Report35 which, in turn, sourced estimates to 

from a 2003 study done by FEV for EPA contained within a 2004 EPA Interim Technical 

Report.36 These direct manufacturing costs are reproduced in Table 3-6Table 3-6Table 

3-6. 

Table 3-63-6 Diesel Engine Direct Manufacturing Source Costs, Incremental to a Baseline Gasoline 

Engine (2002 dollars)

Component(s) Large SUV Midsize

Gasoline engine (baseline) 5L V8 2.4L I4 

Diesel engine 4L V8 2.2L I4 

Add high-pressure, common rail diesel fuel injection system $980 $630 

Delete gasoline fuel injection system -$245 -$165 

Add variable geometry turbocharger $175 $126 

Delete gasoline ignition system -$120 -$75 

Delete fuel pump and other changes to fuel system -$94 -$75 

Enhance powertrain mounting system $87 $107 

Other engine changes $80 $70 

Add air intercooler, ducts, and sensor $80 $55 

Larger battery and starter, add glow plugs $72 $50 

Delete exhaust gas oxygen sensor* -$60 -$30 

Add supplemental heater $50 $15 

Modify transmission $25 $25 

Enhance sound insulation package $25 $10 

Smaller radiator -$13 -$4 

Total $1,042 $739 

Note: Table reproduced from EPA420-R-05-012, October 2005

 

Building on the direct manufacturing costs shown in Table 3-6Table 3-6Table 

3-6, the agencies used appropriate scaling to estimate the costs for replacing a baseline 

gasoline engine with a diesel engine for the following four situations: a large car 

converted from a 4.5L V8 gasoline to a 3L V6 diesel; a medium/large MPV converted 

from a 3.2L V6 to a 2.8L I4 diesel; a small truck converted from a 3.2L V6 gasoline to a 

2.8L I4 diesel; and a large truck converted from a 5.6L V8 gasoline to a 4L V6 diesel. A 

small car conversion was not considered since the diesel conversion for the small car was 

not considered to be a viable or cost effective option. The results for the four base 

gasoline to diesel conversions are shown in Table 3-7Table 3-7Table 3-7. Values from 

Table 3-6Table 3-6Table 3-6 have been updated to 2007 dollars using the GDP price 

deflator factor of 1.15 (see Appendix 3.A). Since the source costs were developed in 

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2003, this analysis conservatively considers the costs shown in Table 3-7Table 3-7Table 

3-7 as being applicable to the 2012 model year. 

Table 3-73-7 Diesel Engine Direct Manufacturing Scaled-Costs in 2012, Incremental to Baseline 

Gasoline Engine (2007 dollars) 

Component(s) Large 

car 

Med/large 

MPV 

Small 

truck 

Large 

truck 

Notes 

(see text 

below) 

Gasoline engine (baseline) 4.5L V8 3.2L V6 3.2L V6 5.6L V8 

Diesel engine 3L V6 2.8L I4 2.8L I4 4L V6 

Add high-pressure, common rail diesel 

fuel injection system $1,026 $724 $724 $1,026 1 

Delete gasoline fuel injection system -$89 -$73 -$73 -$89 2 

Add variable geometry turbocharger $173 $145 $145 $201 3 

Delete gasoline ignition system -$138 -$112 -$112 -$138 4 

Delete fuel pump and other changes to 

fuel system -$108 -$86 -$86 -$108 5 

Enhance powertrain mounting system $100 $123 $123 $100 6 

Other engine changes $86 $80 $80 $86 7 

Add air intercooler, ducts, and sensor $78 $63 $63 $92 8 

Larger battery and starter, add glow 

plugs $70 $57 $57 $70 9 

Delete exhaust gas oxygen sensor* $0 $0 $0 $0 10 

Add supplemental heater $37 $17 $17 $57 11 

Modify transmission $29 $29 $29 $29 12 

Enhance sound insulation package $20 $11 $11 $29 13

Smaller radiator -$15 -$10 -$10 -$15 14 

Engine downsize credit -$185 -$390 -$390 -$185 15 

Total $1,085 $580 $580 $1,156 

* Note: Oxygen sensor removals are included in aftertreatment costs. 

The costs shown in Table 3-7Table 3-7Table 3-7 were scaled in the following ways: 

1. Large car and large truck calculated as 75% the cost of Table 3-6Table 3-6Table 3-6’s 

large SUV and 25% of midsize car; medium/large MPV and small truck calculated as 

equal to Table 3-6Table 3-6Table 3-6’s midsize car. Values converted to 2007 

dollars using GDP factor of 1.15. 

1.2. The estimates generated by FEV for eliminating the gasoline fuel injection 

systems were considerably larger than EPA & NHTSA believed was appropriate. 

Therefore, to remain conservative, these costs were estimated, in 2007 dollars as 

follows: large car and large truck were calculated using incremental costs of 

$8/injector, $20/fuel rail, and $5 for a pressure damper or $8x8+$20+$5=$89; 

medium/large MPV and small truck were calculated using incremental costs of 

$8/injector, $20/fuel rail, and $5 for a pressure damper or $8x6+$20+$5=$73. 

1.3. Large car calculated as the average of Table 3-6Table 3-6Table 3-6’s large SUV 

and midsize car; medium/large MPV and small truck calculated as equal to Table 

3-6Table 3-6Table 3-6’s midsize car, and large truck calculated as equal to Table 

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3-6Table 3-6Table 3-6’s large SUV. Values converted to 2007 dollars using GDP 

factor of 1.15. 

1.4. Medium/large MPV and small truck calculated as the average of Table 3-6Table 

3-6Table 3-6’s large SUV and midsize car; Large car and large truck calculated as 

equal to Table 3-6Table 3-6Table 3-6’s large SUV. Values converted to 2007 dollars 

using GDP factor of 1.15. 

1.5. Medium/large MPV and small truck calculated as equal to Table 3-6Table 

3-6Table 3-6’s midsize car; Large car and large truck calculated as equal to Table 

3-6Table 3-6Table 3-6’s large SUV. Values converted to 2007 dollars using GDP 

factor of 1.15. 

1.6. Medium/large MPV and small truck calculated as equal to Table 3-6Table 

3-6Table 3-6’s large SUV; Large car and large truck calculated as equal to Table 

3-6Table 3-6Table 3-6’s midsize car. Values converted to 2007 dollars using GDP 

factor of 1.15. 

1.7. Medium/large MPV and small truck calculated as equal to Table 3-6Table 

3-6Table 3-6’s midsize car; Large car and large truck calculated as the average of 

Table 3-6Table 3-6Table 3-6’s large SUV and midsize car. Values converted to 2007 

dollars using GDP factor of 1.15. 

1.8. Medium/large MPV and small truck calculated as equal to Table 3-6Table 

3-6Table 3-6’s midsize car; Large car calculated as the average of Table 3-6Table 

3-6Table 3-6’s large SUV and midsize car; Large truck calculated as equal to Table 

3-6Table 3-6Table 3-6’s large SUV. Values converted to 2007 dollars using GDP 

factor of 1.15. 

1.9. Medium/large MPV and small truck calculated as equal to Table 3-6Table 

3-6Table 3-6’s midsize car; Large car and large truck calculated as the average of 

Table 3-6Table 3-6Table 3-6’s large SUV and midsize car. Values converted to 2007 

dollars using GDP factor of 1.15. 

1.10. Medium/large MPV and small truck calculated as equal to Table 3-6Table 

3-6Table 3-6’s midsize car; Large car and large truck calculated as the average of 

Table 3-6Table 3-6Table 3-6’s large SUV and midsize car. Values converted to 2007 

dollars using GDP factor of 1.15. 

1.11. Medium/large MPV and small truck calculated as equal to Table 3-6Table 

3-6Table 3-6’s midsize car; Large car calculated as the average of Table 3-6Table 

3-6Table 3-6’s large SUV and midsize car; Large truck calculated as equal to Table 

3-6Table 3-6Table 3-6’s large SUV. Values converted to 2007 dollars using GDP 

factor of 1.15. 

1.12. Values from Table 3-6Table 3-6Table 3-6 converted to 2007 dollars using GDP 

factor of 1.15. 

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1.13. Medium/large MPV and small truck calculated as equal to Table 3-6Table 

3-6Table 3-6’s midsize car; Large car calculated as the average of Table 3-6Table 

3-6Table 3-6’s large SUV and midsize car; Large truck calculated as equal to Table 

3-6Table 3-6Table 3-6’s large SUV. Values converted to 2007 dollars using GDP 

factor of 1.15. 

1.14. Medium/large MPV and small truck calculated as the average of Table 3-6Table 

3-6Table 3-6’s large SUV and midsize car; Large car and large truck calculated as 

equal to Table 3-6Table 3-6Table 3-6’s large SUV. Values converted to 2007 dollars 

using GDP factor of 1.15. 

1.15. Based on the approach presented in the turbocharging/downsizing section (see 

section 3.5.2.1.11), the savings associated with downsizing the gasoline engine were 

calculated by estimating the cost in 2007 dollars of each cylinder at $51, each valve at 

$10, and each cam at $103.i

 Therefore, the large car and large truck, which each lose 

two cylinders (-$102), eight valves (-$82) and no cams realize a $185 savings. The 

medium/large MPV and small truck would each lose two cylinders (-$102) and eight 

valves (-$82) and two cams (-$205) for a savings of $390. 

 

For the diesel aftertreatment systems, the approach taken is consistent with the 

approach taken in EPA’s 2007/2010 Highway Diesel rule and EPA’s recent locomotive 

and marine rule.37 For platinum group metal costs, monthly average prices as of March 

2009 as reported by Johnson-Matthey were used.38 Those values were $1,085/troy ounce 

for platinum and $1,169/troy ounce for rhodium. Aftertreatment devices were sized 

according to the diesel engine displacement with a 1:1 ratio for both the SCR catalyst and 

the DPF, and a 0.5:1 ratio for the DOC (i.e., the DOC is half the displacement of the 

engine). The end result for aftertreatment devices, including a urea dosing unit, urea tank 

and necessary brackets and heaters, are shown in Table 3-8Table 3-8Table 3-8. Also 

shown in Table 3-8Table 3-8Table 3-8 are the savings associated with removal of the 

gasoline catalyst. Note that the gasoline catalyst was sized according to the gasoline 

engine that served as the baseline engine. 

Table 3-83-8 Diesel Aftertreatment Direct Manufacturing Costs in 2012 (2007 dollars)

 

i

 These are the correct costs for the 2015MY in 2007$. But, they are used here inappropriately as 2012MY 

values. Technically, 3 years of time-based learning should have been backed out to get 2012MY values. 

So, the 2012MY costs are slightly underestimated by roughly $10. 

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Component(s) Large car Med/large 

MPV Small truck Large truck 

Gasoline engine (baseline) 4.5L V8 3.2L V6 3.2L V6 5.6L V8 

Diesel engine 3L V6 2.8L I4 2.8L I4 4L V6 

DOC $277 $257 $257 $339 

DPF (includes a $20 pressure sensor for 

OBD & sensing) $534 $503 $503 $668 

SCR system (includes a $50 NOx sensor for 

OBD & sensing) $904 $904 $914 $996 

Removal of gasoline catalysts & sensors -$401 -$288 -$298 -$483 

Total $1,314 $1,376 $1,376 $1,520 

The incremental costs to convert from a gasoline to a diesel engine—Table 

3-7Table 3-7Table 3-7 and Table 3-8Table 3-8Table 3-8 combined—are shown in Table 

3-9Table 3-9Table 3-9. 

Table 3-93-9 Direct Manufacturing Costs to Convert from a Gasoline to Diesel System in 2012 (2007 

dollars)

Component(s) Large car Med/large 

MPV Small truck Large truck 

Gasoline engine (baseline) 4.5L V8 3.2L V6 3.2L V6 5.6L V8

Diesel engine 3L V6 2.8L I4 2.8L I4 4L V6 

Engine-related costs $1,085 $580 $580 $1,156 

Aftertreatment $1,314 $1,376 $1,376 $1,520 

Total $2,399 $1,956 $1,956 $2,676 

This analysis applies time-based learning to diesel systems and a 1.25 ICM for a 

medium complexity rating. Therefore, the MY 2016 compliance costs are as shown in 

Table 3-10Table 3-10Table 3-10. 

Table 3-103-10 Compliance Costs to Convert from a Gasoline to Diesel System in 2016 (2007 dollars)

Component(s) Large car Med/large 

MPV Small truck Large truck 

Gasoline engine (baseline) 4.5L V8 3.2L V6 3.2L V6 5.6L V8 

Diesel engine 3L V6 2.8L I4 2.8L I4 4L V6 

Total $2,655 $2,164 $2,164 $2,961 

In the NHTSA analysis, and consistent with the above analysis, SCR-based diesel 

costs for a 2.8L in-line 4-cylinder from a V-6 gasoline engine were estimated to be $2445 

in MY 2012. A MY 2012 cost of $3345 was estimated for a conversion to 4.0L V-6 

diesel from a V-8 gasoline engine. These MY 2012 estimates were obtained using the inline 4 cylinder cost of $1956 and V-6 cost of $2676, from Table 3-9Table 3-9Table 3-9, 

and multiplying them by the medium complexity ICM markup of 1.25 and are eligible for 

time-based learning cost reductions. 

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3.4.2.2 Transmission Technologies 

NHTSA and EPA have also reviewed the transmission technology estimates used 

in the MY 2011 CAFE final rule. In doing so NHTSA and EPA considered or 

reconsidered all available sources and updated the estimates as appropriate. The section 

below describes each of the transmission technologies considered for this rulemaking. 

3.4.2.2.1 Improved Automatic Transmission Control (IATC) 

(Aggressive Shift Logic and Early Torque Converter 

Lockup)

Calibrating the transmission shift schedule to upshift earlier and quicker, and to 

lock-up or partially lock-up the torque converter under a broader range of operating 

conditions can reduce fuel consumption and CO2 emissions. However, this operation can 

result in a perceptible degradation in noise, vibration, and harshness (NVH). The degree 

to which NVH can be degraded before it becomes noticeable to the driver is strongly 

influenced by characteristics of the vehicle, and although it is somewhat subjective, it 

always places a limit on how much fuel consumption can be improved by transmission 

control changes. Given that the Aggressive Shift Logic and Early Torque Converter 

Lockup are best optimized simultaneously due to the fact that adding both of them 

primarily requires only minor modifications to the transmission or calibration software, 

these two technologies are combined in the modeling. 

 

3.4.2.2.2 Aggressive Shift Logic

During operation, an automatic transmission’s controller manages the operation of 

the transmission by scheduling the upshift or downshift, and locking or allowing the 

torque converter to slip based on a preprogrammed shift schedule. The shift schedule 

contains a number of lookup table functions, which define the shift points and torque 

converter lockup based on vehicle speed and throttle position, and other parameters such 

as temperature. Aggressive shift logic (ASL) can be employed in such a way as to 

maximize fuel efficiency by modifying the shift schedule to upshift earlier and inhibit 

downshifts under some conditions, which reduces engine pumping losses and engine 

friction. The application of this technology does require a manufacturer to confirm that 

drivability, durability, and NVH are not significantly degraded. 

The agencies have estimated the effectiveness of aggressive shift logic at 1 to 2 

percent. The agencies have estimated the cost at $32 for a MY 2012 vehicle, regardless 

of size (2007$).j

 With time-based learning applied, this cost would be $28 for a MY 

2016 vehicle (2007$) 

 

 

j

 This reflects a revisiting of component costs for NHTSA since the 2011 CAFE FRM. 
Draft Joint Technical Support Document 

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3.4.2.2.3 Early Torque Converter Lockup

A torque converter is a fluid coupling located between the engine and 

transmission in vehicles with automatic transmissions and continuously-variable 

transmissions (CVT). This fluid coupling allows for slip so the engine can run while the 

vehicle is idling in gear (as at a stop light), provides for smoothness of the powertrain, 

and also provides for torque multiplication during acceleration, and especially launch. 

During light acceleration and cruising, the inherent slip in a torque converter causes 

increased fuel consumption, so modern automatic transmissions utilize a clutch in the 

torque converter to lock it and prevent this slippage. Fuel consumption can be further 

reduced by locking up the torque converter at lower vehicle speeds, provided there is 

sufficient power to propel the vehicle, and noise and vibration are not excessive.k

 If the 

torque converter cannot be fully locked up for maximum efficiency, a partial lockup 

strategy can be employed to reduce slippage. Early torque converter lockup is applicable 

to all vehicle types with automatic transmissions. Some torque converters will require 

upgraded clutch materials to withstand additional loading and the slipping conditions 

during partial lock-up. As with aggressive shift logic, confirmation of acceptable 

drivability, performance, durability and NVH characteristics is required to successfully 

implement this technology. 

Regarding the effectiveness of Improved Automatic Transmission Control, the 

MY2011 CAFE final rule, which was supported by the 2002 NAS and NESCCAF reports 

as well as confidential manufacturer data, estimated an effectiveness improvement of 1 to 

2 percent for aggressive shift logic and 0.5 percent for early torque converter lockup. 

These estimates are in agreement with the values stated in the NESCCAF report and 

confidential manufacturer data. For the purpose of this NPRM, NHTSA and EPA 

concluded that the combined estimated effectiveness is 1.5 to 2.5% reduction in CO2 

emissions and fuel consumption. 

Regarding cost estimates, the agencies estimate the cost at $29, regardless of 

vehicle size and including a low complexity ICM of 1.11 for a MY 2012 vehicle(2007$). 

With time-based learning, this cost would be $25 for a MY 2016 vehicle (2007$). For 

IATC (or the combination of aggressive shift logic and early torque converter lockup), 

the cost, including the 1.11 ICM, would be $60 for a MY 2012 vehicle and $53 for a MY 

2016 vehicle after time-based learning (2007$). 

 

3.4.2.2.4 Automatic 6-, 7- and 8-Speed Transmissions (NAUTO)

Manufacturers can also choose to replace 4- and 5-speed transmission with 6-, 7-, 

or 8-speed automatic transmissions. Additional ratios allow for further optimization of 

 

k

 Although only modifications to the transmission calibration software are considered as part of this 

technology, very aggressive early torque converter lock up may require an adjustment to damper stiffness 

and hysteresis inside the torque converter. 
3-47 

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 MY 2011 CAFE final 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. The 2008 Martec report estimated a cost of $323 (RPE adjusted) 

for converting a 4-speed to a 6-speed transmission and a cost of $638 (RPE adjusted) for 

converting a 4-speed to an 8-speed transmission. GM has publicly claimed a fuel 

economy improvement of up to 4 percent for its new 6-speed automatic transmissions.39 

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.40 Based on this 

information, NHTSA estimated in the MY 2011 rule, that the conversion to a 6-,7- and 8-

speed transmission (NAUTO) 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. 

NHTSA and EPA reviewed these effectiveness estimates and concluded that they 

remain accurate. While the CAFE model follows the incremental approach discussed 

above, the GHG model estimates the packaged effectiveness of 4.5 to 6.5 percent. 

NHTSA and EPA also reviewed the cost estimates from the MY 2011 CAFE final 

rule and the 2008 staff report (which assumed use of a Lepelletier gear set) and 

concluded that some but not all 6-speed automatic transmissions would be equipped with 

Lepelletier gear set, and as such, the estimates were revised to establish the cost for the 6-

speed transmission to be equally divided between application using Lepelletier, and 

application of a standard planetary gear set 6-speed automatic transmission as estimated 

in the 2008 Martec report (and the MY 211 CAFE final rule). As a result, the final 

incremental cost estimate was $170, independent of vehicle type and size and including a 

low complexity 1.11 ICM (2007$). In the CAFE model, due to the structure vehicle 

classes used, an additional $102 (2007$) is included to account for performance vehicle 

classes and for medium and large trucks. This is because for performance classes, 

additional gear ratios, such as 7 and 8 speed transmissions may be utilized, and for 

medium and large trucks heavier duty transmissions are required. These estimates 

represent MY 2012 vehicle costs. With time-based learning, the $170 cost would lower 

to $150 for a MY 2016 vehicle (2007$). 
Draft Joint Technical Support Document 

3-48 

3.4.2.2.5 Dual Clutch Transmissions / Automated Manual 

Transmissions (DCTAM)

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 dualclutch (DCT). A single-clutch AMT is essentially a manual transmission with automated 

clutch and shifting. Because of shift quality issues with single-clutch designs, DCT’s 

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 number gears and 

odd-numbered gears. In this way, the next expected gear is pre-selected which allows for 

faster and smoother shifting. 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 odd-gear 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 AMT’s have a higher 

cost due to the additional hydraulic hardware required. 

Overall, DCT’s 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) or hold pulleys in position to maintain gear ratio (in Continuously 

Variable 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. 

For the MY 2011 CAFE final rule, NHTSA estimated a 5.5 to 9.5 percent 

improvement in fuel consumption over a baseline 4/5-speed automatic transmission for a 

wet clutch DCT, which was assumed for all but the smallest of vehicle subclasses, 
3-49 

Subcompact and Compact cars and small LT. This results in an incremental effectiveness 

estimate of 2.7 to 4.1 percent over a 6-speed automatic transmission with IATC. For 

Subcompact and Compact Cars and small LT, which were assumed to use a dry clutch 

DCT, NHTSA estimated an 8 to 13 percent fuel consumption improvement over a 

baseline 4/5-speed automatic transmission, which equates to a 5.5 to 7.5 percent 

incremental improvement over the 6-speed transmission. This is consistent with the EPA 

staff report, which estimated that these transmissions offer an effectiveness of 9.5%-

14.5% over a 4-speed automatic transmission. EPA and NHTSA therefore conclude that 

8 to 13 percent effectiveness is appropriate for this proposal. 

In the MY 2011 CAFE final rule, the dry clutch DCT incremental cost was 

previously estimated to be $68 for Subcompact and Compact cars relative to the 6-speed 

automatic transmission. For larger vehicles such as Midsize and Large Car and Minivan 

the wet clutch DCT incremental cost over 6-speed transmission was estimated at $218, 

with both of these estimates assuming a 1.5 RPE. In the 2008 staff report, EPA estimated 

the RPE (1.5 RPE factor) of a wet clutch DCT (called an AMT in the report) at $141 

(2006$) 

The agencies revised these estimates to reflect updated sources and the ICM 

markup of a medium complexity technology of 1.26. For this NPRM, the agencies 

estimated MY 2012 costs of $74 for dry and $159 for wet DCT (2007$), which are only 

slightly different from MY 2011 CAFE final rule. With time-based learning these costs 

would be $65 and $139, respectively, for a MY 2016 vehicle (2007$). 

 

3.4.2.2.6 Continuously Variable Transmission (CVT)

A Continuously Variable Transmission (CVT) is unique in that it does not use 

gears to provide ratios for operation. Instead, the most common CVT design uses two Vshaped pulleys connected by a metal belt. Each pulley is split in half and a hydraulic 

actuator moves the pulley halves together or apart. This causes the belt to ride on either a 

larger or smaller diameter section of the pulley which changes the effective ratio of the 

input to the output shafts. Advantages of the CVT are that the engine can operate at its 

most efficient speed-load point more of the time, since there are no fixed ratios. 

However, CVT’s are limited by engine power and cannot be applied to high torque 

applications. Also, CVTs often have a wider range of ratios compared to conventional 

automatic transmissions which can provide for more options in engine optimization. 

While CVTs by definition are fully continuous, some automakers choose to emulate 

conventional stepped automatic operation because some drivers are not used to the 

sensation of the engine speed operating independently of vehicle speed. 

Considering the confidential data together with independent review, NHTSA has 

estimated the fuel consumption effectiveness for CVTs at 2.2 to 4.5 percent over a 4/5-
Draft Joint Technical Support Document 

3-50 

speed automatic transmission, which translates into a 0.7 to 2.0 incremental effectiveness 

improvement over an automatic transmission with the IATC technology. EPA and 

NHTSA reviewed these estimates and found them to be accurate. 

The agencies adjusted the original estimates used in MY 2011 CAFE final rule to 

account for medium complexity ICM of 1.25. This resulted in estimated incremental 

compliance cost of $250 for the MY 2012 vehicles. In the Volpe model, this technology 

was only applied to vehicles manufactured with unibody construction methods. CVTs 

are an established and readily available technology so time based learning is applied. 

3.4.2.2.7 6-Speed Manual Transmissions (6MAN)

Manual transmissions are entirely dependent upon driver input to shift gears: the 

driver selects when to perform the shift and which gear to select. This is the most 

efficient transfer of energy of all transmission layouts, because it has the lowest internal 

gear losses, with a minimal hydraulic system, and the driver provides the energy to 

actuate the clutch. From a systems viewpoint, however, vehicles with manual 

transmissions have the drawback that the driver may not always select the optimum gear 

ratio for fuel economy. Nonetheless, increasing the number of available ratios in a 

manual transmission can improve fuel economy by allowing the driver to select a ratio 

that optimizes engine operation more often. Typically, this is achieved through adding 

overdrive ratios to reduce engine speed at cruising velocities (which saves fuel through 

reduced engine pumping losses) and pushing the torque required of the engine towards 

the optimum level. However, if the gear ratio steps are not properly designed, this may 

require the driver to change gears more often in city driving resulting in customer 

dissatisfaction. Additionally, if gear ratios are selected to achieve improved launch 

performance instead of to improve fuel economy, then no fuel saving effectiveness is 

realized. 

NHTSA’s MY 2011 CAFE final rule estimated an effectiveness increase of 0.5 

percent for replacing a 5-speed manual with a 6-speed manual transmission, which was 

derived from confidential manufacturer data. NHTSA and EPA have found no evidence 

to dispute this estimate and chosen to use 0.5 percent reduction in CO2 emissions and 

fuel consumption for replacing a 5-speed manual with a 6-speed manual transmission for 

this proposal. 

NHTSA updated costs to reflect the ICM low complexity markup of 1.11 which 

resulted in a incremental compliance cost of $250 as compared to $338 for MY 2012, 

with lower costs later MYs due to the application of time based learning factors. In the 

2008 staff report, EPA estimated this RPE (1.5 RPE factor) at $107 (2006$) relative to a 

5-speed manual transmission and for a MY 2015 vehicle. EPA updated this value to 
3-51 

2007$ and used a 1.11 ICM to get costs of $89 for a MY 2012 vehicle and $69 for a MY 

2016 vehicle, both relative to a 5-speed manual transmission (2007$). 

3.4.2.3 Hybrid and Electrification/Accessory Technologies

A Hybrid is a vehicle that combines two or more sources of propulsion energy, 

where one uses a consumable fuel (like gasoline), and one is rechargeable (during 

operation, or by another energy source). Hybrid technology is established in the U.S. 

market and more manufacturers are adding hybrid models to their lineups. Hybrids 

reduce fuel consumption through three major mechanisms: 

• The internal combustion engine can be optimized (through downsizing, 

modifying the operating cycle, or other control techniques) to operate at or 

near its most efficient point more of the time. Power loss from engine 

downsizing can be mitigated by employing power assist from the secondary 

power source. 

• Some of the energy normally lost as heat while braking can be captured and 

stored in the energy storage system for later use. 

• The engine is turned off when it is not needed, such as when the vehicle is 

coasting or when stopped. 

Hybrid vehicles utilize some combination of the three above mechanisms to 

reduce fuel consumption and CO2 emissions. A fourth mechanism to reduce petroleum 

fuel consumption, available only to plug-in hybrids, is by substituting the petroleum fuel 

energy with energy from another source, such as the electric grid. The effectiveness of 

fuel consumption and CO2 reduction depends on the utilization of the above mechanisms 

and how aggressively they are pursued. One area where this variation is particularly 

prevalent is in the choice of engine size and its effect on balancing fuel economy and 

performance. Some manufacturers choose not to downsize the engine when applying 

hybrid technologies. In these cases, performance is vastly improved, while fuel 

efficiency improves significantly less than if the engine was downsized to maintain the 

same performance as the conventional version. While this approach has been used in 

cars such as the Honda Accord Hybrid (now discontinued), it is more likely to be used for 

vehicles like trucks where towing and/or hauling is an integral part of their performance 

requirements. In these cases, if the engine is downsized, the battery can be quickly 

drained during a long hill climb with a heavy load, leaving only a downsized engine to 

carry the entire load. Because towing capability is currently a heavily-marketed truck 

attribute, manufacturers are hesitant to offer a truck with downsized engine which can 

lead to a significantly diminished towing performance with a low battery, and therefore 

engines are traditionally not downsized for these vehicles..

Although hybrid vehicles using other energy storage concepts (flywheel, 

hydraulic) have been developed, the systems currently in production in the U.S. for 
Draft Joint Technical Support Document 

3-52 

passenger cars and light trucks use battery storage and electric drive systems. Hybrid 

electric vehicles (HEV) are part of a continuum of vehicles using systems with differing 

levels of electric drive and electric energy storage. This range of vehicles includes 

relatively basic engine start/stop systems, HEV systems with varying degrees of electric 

storage and electric drive system capability, plug-in hybrid electric vehicles (PHEV) with 

differing degrees of all electric range and battery electric vehicles (EV) that rely entirely 

on electric drive and battery electric energy storage. 

Different HEV, PHEV and EV concepts utilize these mechanisms differently, so 

they are treated separately for the purposes of this analysis. Below is a discussion of 

battery energy storage and the major hybrid concepts that were determined to be 

available in the near term. 

3.4.2.3.1 Batteries for MHEV, HEV, PHEV and EV Applications

The design of battery secondary cells can vary considerably between MHEV, 

HEV, PHEV and EV applications. 

MHEV batteries: Due to their lower voltage (12-42 VDC) and reduced power and 

energy requirements, MHEV systems will likely continue to use lead-acid batteries. 

MHEV battery designs differ from those of current starved-electrolyte (typical 

maintenance free batteries) or flooded-electrolyte (the older style lead-acid batteries 

requiring water “top-off”) batteries used for starting, lighting and ignition (SLI) in 

automotive applications. Standard SLI batteries are primarily designed to provide highcurrent for engine start-up and then recharge immediately after startup via the vehicle’s 

charging system. Deeply discharging a standard SLI battery will greatly shorten its life.

MHEV applications are expected to use: 

• Extended-cycle-life flooded (ELF) lead-acid batteries 

• Absorptive glass matt, valve-regulated lead-acid (AGM/VRLA) batteries –

or – 

• Asymmetric lead-acid battery/capacitor hybrids (e.g. flooded 

ultrabatteries) 

MHEV systems using electrolytic double-layer capacitors are also under development. 

HEV batteries: HEV applications operate in a narrow, short-cycling, chargesustaining state of charge (SOC). Energy capacity in HEV applications is somewhat 

limited by the ability of the battery and power electronics to accept charge and by space 

and weight constraints within the vehicle design. HEV battery designs tend to be 

optimized for high power density rather than high energy density, with thinner cathode 

and anode layers and more numerous current collectors and separators (Figure 3-1). Field Code Changed
3-53 

EV batteries: EV batteries tend to be optimized for high energy density and are 

considerably larger than HEV batteries. PHEV battery designs are intermediate between 

power-optimized HEV and energy-optimized EV battery cell designs. 

PHEV batteries: PHEV batteries must provide both charge depleting operation 

similar to an EV and charge sustaining operation similar to an HEV. Unlike HEV 

applications, charge sustaining operation with PHEVs occurs at a relatively low battery 

state of charge (SOC) which can pose a significant challenge with respect to attaining 

acceptable battery cycle life. In the case of the GM Volt, this limits charge depleting 

operation to a minimum SOC of approximately 30%.41 An alternative approach for 

PHEV applications that has potential to allow extension of charge depletion to a lower 

battery SOC is using energy-optimized lithium-ion batteries for charge depleting 

operation in combination with the use of supercapacitors for charge sustaining 

operation.42 

Figure 3-1: Schematic representation of power and energy optimized 

prismatic-layered battery cells 

Collector (-)

Cathode (-)

Separator

Anode (+)

Collector (+)

HEV Power-optimized Battery Cell

EV Energy-optimized Battery Cell

Power-split hybrid vehicles from Toyota, Ford and Nissan, integrated motor assist 

hybrid vehicles from Honda and the GM 2-mode hybrid vehicles currently use nickelmetal hydride (NiMH) batteries. Lithium-ion (Li-ion) batteries offer the potential to 

approximately double both the energy and power density relative to current NiMH 

batteries, enabling much more electrical-energy-intensive automotive applications such 

as PHEVs and EVs. Li-ion batteries for high-volume automotive applications differ 

substantially from those used in consumer electronics applications with respect to 

cathode chemistry, construction and cell size. Li-ion battery designs currently under 
Draft Joint Technical Support Document 

3-54 

development by CPI (LG-Chem) for the GM Volt PHEV and by AESC, GS-Yuasa and 

A123 Systems (respectively) for the upcoming Nissan, Mitsubishi and Chrysler EVs use 

large-format, layered-prismatic cells assembled into battery modules. The modules are 

then combined into battery packs. 

Cathodes for large-format, automotive Li-ion batteries are becoming increasingly 

focused on two chemistries – LiMn2O4-spinel (CPI, GS-Yuasa, AESC) and LiFePO4 

(A123 Systems). 

In addition to the purely hybrid technologies, which decrease the proportion of 

propulsion energy coming from the fuel by increasing the proportion of that energy 

coming from electricity, there are other steps that can be taken to improve the efficiency 

of auxiliary functions (e.g., power-assisted steering or air-conditioning) which also 

reduce CO2 emissions and fuel consumption. These steps, together with the hybrid 

technologies, are collectively referred to as “vehicle electrification” because they 

generally use electricity instead of engine power. In order to achieve consistency 

between the two modeling techniques, and to improve the number and range of 

technology offerings, the CAFE model was revised to include one additional mild hybrid 

technology. The high voltage or improved efficiency alternator (HVIA) technology, 

which was used in the 2011 rule, is no longer represented as a separate technology and 

has instead been incorporated into this new mild hybrid technology, as discussed further 

below. 

3.4.2.3.2 Hybrid System Sizing and Cost Estimating Methodology

NHTSA and EPA reviewed estimates of cost and effectiveness for hybrid and 

related electrical technologies and adjusted them as appropriate. Both agencies found the 

hybrid technology cost estimating methodology that Ricardo and NHTSA developed 

during the 2011 final rule to be reasonable and used it to estimate hybrid systems costs 

and account for variation in component sizing across both the hybrid types and vehicle 

subclasses. That method utilizes four pieces of data: (1) key component sizes for a 

midsize car by hybrid system type; (2) normalized costs for each key component; (3) 

component scaling factors that are applied to each vehicle class/subclass by hybrid 

system type; and (4) vehicle characteristics for the subclasses which are used as the basis 

for the scaling factors. During development of the methodology, NHTSA and Ricardo 

made several assumptions: 

1) Hybrid controls hardware varies with the level of functionality offered by the 

hybrid technology. Assumed hybrid controls complexity for a 12V micro 

hybrid (MHEV) and belt integrated starter generator (BISG) was 25 percent of 

a strong hybrid controls system and the complexity for a Crank Integrated 

Starter Generator (CISG) was 50 percent. These ratios were estimates based 

on the directional need for increased functionality as system complexity 

increases. 
3-55 

1)2) Li-Ion batteries for hybrid electric vehicles are currently entering 

production, including a 2010 MY Mercedes and Hyundai. One estimate from 

Anderman indicates that Li-ion market penetration will achieve 35 percent by 

2015.43 However, as was discussed above, significant development effort is 

underway by a number of battery producers which could impact cost and 

overcome other technical concerns. Therefore it was assumed that mild 

hybrids (MHEV, BISG, CISG) and strong hybrids (PSHEV, 2MHEV, PHEV) 

will use either Li-Ion or NiMH batteries, depending on cost considerations. 

However, plug-in hybrids will use Li-ion batteries only. Battery usage is 

discussed further below. 

1)3) The plug-in hybrid battery pack was sized for a mid-sized car by 

assuming: the vehicle has a 20 mile all electric range and consumes an 

average of 300 W-hr per mile; the battery pack can be discharged down to 30 

percent depth of discharge;l and the capacity of a new battery pack is 20 

percent greater than at end of life (i.e., range on a new battery pack is 24 

miles). 

1)4) All hybrid systems included a DC/DC converter which was sized to 

accommodate vehicle electrical loads appropriate for increased vehicle 

electrification in the time frame considered. 

1)5) High voltage wiring scaled with hybrid vehicle functionality and could be 

represented as a fraction of strong hybrid wiring. These ratios were estimates 

based on the directional need for increased functionality as system complexity 

increases. 

1)6) All hybrid systems included a supplemental heater to provide vehicle 

heating when the engine is stopped; however, in this proposal, it is assumed 

that only half of the vehicles will adapt this technology, as discussed further 

below. Only the strong hybrids included electric air conditioning to enable 

engine stop/start when vehicle air conditioning was requested by the operator. 

Furthermore, NHTSA and Ricardo recognized that some strong hybrid systems 

replaced a conventional transmission with a hybrid-specific transmission, resulting in a 

cost offset (i.e., a cost credit) for the removal of a portion of the clutches and gear sets 

within the transmission. In the MY 2011 rule, the transmission cost in Table 3-11Table 

3-11Table 3-11 below expressed hybrid transmission costs as a percentage of traditional 

automatic transmission cost, as described in the 2008 Martec Report, at $850 direct 

manufacturing costs (non-RPE/ICM). The method assumed that the mechanical aspect of

a power-split transmission with a reduced number of gear sets and clutches resulted in a 

cost savings of 50 percent ($425) over a conventional transmission with torque converter. 

For a 2-mode hybrid, the mechanical aspects of the transmission are similar in 

complexity to a conventional transmission, so no cost savings was appropriate. The plugin hybrid assumed a highly simplified transmission for electric motor drive, thus 25 

percent of the base vehicle transmission cost was applied (resulting in a $638 credit). 

 

l

 The GM Volt operates between 30% DOD and 85% DOD. So there is 55% useable DOD, but charge 

sustaining operation starts at 30% and cycles between 30 and 35% DOD. 

Formatted: Bullets and Numbering

Field Code Changed
Draft Joint Technical Support Document 

3-56 

The NHTSA MY 2011 CAFE final rule discusses in detail how the hybrid cost 

estimating methodology uses the information provided in the tables below to calculate 

costs for each of the strong hybrid systems used in this proposal. It also includes a stepby-step example for the midsize vehicle mild hybrid systems used in the MY 2011 CAFE 

final rule.44 As in that analysis, it is important to understand that the CISG technology 

replaces existing mild hybrid systems.m

NHTSA and EPA in reviewing the above made the following revisions. First, 

NHTSA and EPA revalidated the component sizes that were estimated for a midsize car 

for each type of hybrid system as shown in Table 3-11Table 3-11Table 3-11. However, 

NHTSA and EPA added an additional component-- front engine accessory drive (FEAD), 

because hybridization often involves revision to the FEAD design such that certain 

devices (belts, pulleys, idlers, etc) as well as other engine components (alternator, A/C 

compressor, and starter) may no longer be needed and can thus be eliminated, or may be 

de-specified to lower cost alternatives. This is applicable to CISG and the strong hybrid 

technologies, and is intended to account for cost savings associated with items that 

changed or are no longer required as a result of these technology applications. 

 

m

 For the incremental CAFE model, before CISG is applied, the costs for MHEV and BISG are subtracted 

if they were previously applied. 

Field Code Changed
3-57 

Table 3-113-11. Component Sizes by Hybrid Type for a Midsize Car 

Component MHEV 

BISG CISG PSHEV 2MHEV PHEV

Primary Motor power, continuous (kW) 3 11 45 45 45

Secondary Motor power, continuous (kW) na na 30 45 30

Primary Inverter power, continuous (kW) 3 11 45 45 45

Secondary Inverter power, continuous (kW) na na 30 45 30

Controls complexity (relative to strong hybrid) 25% 50% 100% 100% 100%

NiMH Battery Pack capacity (kW-hr)1

na 1 2 2 na

Li-Ion Battery Pack capacity (kW-hr)1

na 1 2 2 15

DC/DC Converter power (kW) 0.7 2 2 2 2

High Voltage Wiring (relative to strong hybrid) na 50% 100% 100% 100%

Supplemental heating2

50% 50% 50% 50% 50%

Mechanical Transmission (relative to baseline vehicle) 100% 100% 50% 100% 25%

Electric AC No No Yes Yes Yes

Blended Brakes No Yes Yes Yes Yes

FEAD Credit No Yes Yes Yes Yes

Charger power, continuous (kW) na na na na 3

 2 - Implemented through a reduction in component cost (50%)

 1 - Assumes the use of either NiMH or Li-Ion, and not both.

Hybrid Type

Second, the costs estimates of the key components were revised. The MY 2011 

CAFE final rule was developed at a time when economic conditions were significantly 

different than those that currently exist, a time when many of the commodity materials 

used in the hybrid systems were more expensive than today. These changes in economic 

conditions were one of the factors leading to some of the cost revisions EPA and NHTSA 

jointly discussed and made. Differences in estimates provided by confidential sources to 

either EPA or NHTSA also played a part in the revisions. In addition, the agencies 

applied the new ICM mark-up factors instead of the RPE that was used previously. An 

appropriate ICM factor (1.45 for most mild and strong hybrid technologies) replaces the 

previous RPE factor (1.5), as discussed in section 3.3.2.2.2. Specifically, the primary and 

secondary inverter cost per kilowatt were revised downward from $10 to $7, the controls 

cost was revised upward from $100 to $115, the DC/DC converter costs were revised 

from $100 to $88, the blended brake system that was revised from $400 to $310, and 

finally the fully learned, high volume production, cost per kilowatt hour (kW-hr) for 

Nickel Metal Hydride (NiMH) battery was revised from $350 to $320 to match the 

updated costs for Lithium Ion batteries discussed below.

n

The cost for Lithium Ion (Li-Ion) batteries was also revised. As previously stated, 

Li-Ion batteries are being implemented in series production in model year 2010. Battery 

technology is changing rapidly in the marketplace today, as discussed above, and is 

expected to continue along this path throughout the rulemaking period. OEMs are now 

forming relationships with battery manufacturers in an effort to research and develop not 

only new and improved battery technology, but also more efficient manufacturing 

 

n

 In the MY 2011 final rule NHTSA had misstated this $350 per kW-hr cost as $50 per kW-hr due to a 

typographical error. 

Field Code Changed
Draft Joint Technical Support Document 

3-58 

processes capable of supporting high volume production. Accordingly, as shown in 

Table 3-12Table 3-12Table 3-12, the $600 per kW-hr used in the 2011 rule was revised 

downward to $320 per kW-hr, matching that of the NiMH technology. The revision 

downward from $600/kW-hr in the 2011 CAFE final rule to $320/kW-hr in this analysis 

was done based a study by Deutsche Bank that estimated Li-Ion battery costs at 300-400 

€/kW-hr.45 This was converted to $500/kW-hr then learned twice using volume-based 

learning to arrive at the $320/kW-hr applicable in the 2015 timeframe.

Li-ion batteries were originally restricted to plug-in hybrids only. Recent vehicle 

introductions confirm either battery technology can be used in any mild or strong HEV 

application. However, manufacturers are likely to consider cost highly in their selection 

of battery technology. If Li-ion battery prices remain high, NiMH would be the default 

battery technology for all hybrid electric vehicles. For plug-in hybrids Li-ion would 

continue to be required because plug-in hybrids demand higher energy density than 

NiMH can provide. Neither the CAFE nor OMEGA model predicts a high penetration of 

plug-in technology in achieving the proposed standards. 

Finally, the agencies assessed the cost savings associated with the FEAD cCredit 

discussed above. This cost was not previously represented in the hybrid cost model. As 

shown in Table 3-12Table 3-12Table 3-12 below, a $100 credit is proposed which offsets 

directly the costs of the other components specified. This is the best approximation of the 

value of these items, based on NHTSA and EPA engineering assessment. 

Estimates of each key component are shown in Table 3-12Table 3-12Table 3-12

below along with the sources of those estimates. The cost basis estimates assume fully 

learned, high-volume (greater than 1.2 million units per annum) production, and the costs 

shown are direct manufacturing costs that are not RPE or ICM adjusted. This table does 

not show a cost applicable to the belt integrated starter generator system (BISG) since it 

is a fixed cost that, like the automatic transmission pump cost, is not scaled by subclass as 

described later. 

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Table 3-123-12. Component Cost Basis at High Volumes and Data Sources 

COMPONENT COST BASIS DATA SOURCE

Primary Motor ($/kW) $15 Martec 2008 Secondary Motor ($/kW) $15 

Primary Inverter ($/kW) $7 

Secondary Inverter ($/kW) $7 Confidential Business Information

Controls $115

NiMH Battery Pack ($/kW-hr.) $320 TBD EPA2011 CAFE FRM

(with revision)

Li-ion Battery Pack ($/kW-hr.) $320 TBD EPADeutsche Bank 2008

DC/DC Converter (Size: 2kW) $88 Confidential Business Information

High Voltage Wiring $200 Martec 2008 Supplemental Heating $42

Mechanical Transmission $850 Martec 2008 (to 4-spd auto) 

Electric Air Conditioning $450

Blended Brakes $310 Confidential Business Information

Charger $100

Automatic Transmission Pump $75 Martec 2008 

FEAD Credit $(100) Confidential Business Information

Third, NHTSA and EPA also revised component size/scaling assumptions for 

some vehicles (i.e., large trucks). NHTSA and EPA recognized that some manufacturers 

may choose not to use supplemental cabin heating opting instead to continue engine 

operation in the event heat demand occurs; therefore supplemental heating is specified for 

only half of the vehicles. Table 3-12Table 3-12Table 3-12 above indicates the 50 percent 

application rate implemented in the hybrid cost estimating methodology reducing the 

component cost from $84 to $42. 

EPA and NHTSA also reviewed the choice of a 3 kW DC/DC converter as a 

component size input for a midsize vehicle, which represented a 250 amp current 

capability. In retrospect this is a high specification for a midsize vehicle and revised the 

estimate to a 2 kW DC/DC converter, as shown in Table 3-12Table 3-12Table 3-12

above, which would represent a more reasonable 150 amp current capacity. 

The scaling factor used for the primary and secondary motors and invertors on the 

large truck and SUV vehicles was revised. As in the MY 2011 CAFE final rule, a linear 

extrapolation was used from the midsize vehicle and extended it out to the largest of 

vehicles, the large truck class. This resulted in projected component sizes that are larger 

than those used on a commercially realized truck in this vehicle class, the Chevrolet 

Tahoe two-mode HEV. Accordingly the scaling factors have been revised for this class 

(and the agencies have verified scaling factors for the other classes). This more closely 

approximates the motor and inverter sizes specified in the Tahoe application. For future 

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3-60 

analysis, the agencies are considering whether it may be more accurate to use one set of 

scaling for passenger cars and another different set for light trucks. 

Another revision involves the addition of a stand-alone higher voltage Start-Stop/ 

BISG mild hybrid system. NHTSA and EPA determined that by applying a cost increase 

to the MHEV technology to allow for a voltage increase (lead acid batteries) and 

efficiency improvements to the alternator, the system would then approximate the higher 

voltage Start-Stop /BISG applied by EPA. Based on confidential sources, the estimates 

provided were first converted to 2007 dollars and then reverse learned through two 

cycles, since volume learning is applicable, to arrive at a non-RPE/ICM incremental 

compliance cost to be $229. This cost is applicable to all classes that use higher voltage 

Start-Stop/BISG and is not scaled by any vehicle attribute. 

Component scaling factors for each type of hybrid system are as shown in Table 

3-13Table 3-13Table 3-13 below.

Table 3-133-13. Component Scaling Factors applied to Vehicle Class for each Hybrid System 

Component MHEV CISG PSHEV 2MHEV PHEV

Primary Motor Engine 

displacement

Curb 

weight Engine power

Secondary Motor na na Curb weight2

Primary Inverter

Secondary Inverter na na

Controls

NiMH Battery Pack na na

Li-Ion Battery Pack na Curb weight

DC/DC Converter

High Voltage Wiring na

Supplemental heating

Mechanical Transmission

Electric AC na na

Blended Brakes na

Charger na na na na Same for all 

vehicle classes

(1) For all vehicle classes except for performance classes which use Engine Torque

(2) Curb weight used as surrogate for vehicle road load

(3) Curb weight used as surrogate for vehicle electrical load

Same for all vehicle classes

Hybrid Type

Engine 

displacement

Curb weight1

Curb weight3

Vehicle footprint

Same for all vehicle classes

Vehicle footprint

Vehicle footprint

Primary motor power

Secondary motor power

Complexity

Curb weight

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Component MHEV CISG PSHEV 2MHEV PHEV

Primary Motor Engine 

displacement

Curb 

weight Engine power

Secondary Motor na na Vehicle mass2

Primary Inverter

Secondary Inverter na na

Controls

NiMH Battery Pack na na

Li-Ion Battery Pack na Vehicle mass

DC/DC Converter

High Voltage Wiring na

Supplemental heating

Mechanical Transmission

Electric AC na na

Blended Brakes na

Charger na na na na Same for all 

vehicle classes

(1) For all vehicle classes except for performance classes which use Engine Torque

(2) Vehicle mass used as surrogate for vehicle road load

(3) Vehicle mass used as surrogate for vehicle electrical load

Same for all vehicle classes

Hybrid Type

Engine 

displacement

Curb weight1

Vehicle mass3

Vehicle footprint

Primary motor power

Secondary motor power

Complexity

Vehicle mass

Same for all vehicle classes

Vehicle footprint

Vehicle footprint

Regarding the market data file from the MY 2011 CAFE final rule, NHTSA and 

EPA did not make any revisions to the average vehicle characteristics for each vehicle 

subclass as shown in Table 3-14Table 3-14Table 3-14, which defines the average vehicle 

characteristics for each vehicle subclass. These characteristics were used as the basis of 

the scaling factors in the CAFE and OMEGA models. EPA used these vehicle 

specifications solely for the purpose of scaling hybrid vehicle attributes in order to 

remain consistent with the NHTSA methodology. 

Table 3-143-14. Key Vehicle Characteristics For Each Vehicle Subclass for CAFE Model

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Vehicle Subclass

Curb 

Weight

(lbs)

Footprint

(ft2)

Engine 

Disp. (L)

Engine 

Power

(hp)

Torque

(ft-lb)

Subcompact Car 2795 41 1.9 134 133

Compact Car 3359 44 2.2 166 167

Midsize Car 3725 47 2.9 205 206

Large Car 4110 50 3.4 258 248

Performance Subcompact Car 3054 40 2.7 260 260

Performance Compact Car 3516 44 3.0 269 260

Performance Midsize Car 3822 47 3.9 337 318

Performance Large Car 4189 51 4.8 394 388

Minivan 4090 50 3.3 247 242

Small Truck 3413 45 2.6 178 185

Medium Truck 4260 50 3.6 250 256

Large Truck 5366 63 5.0 323 352

Vehicle Subclass

Curb 

Weight

(lbs)

Footprint

(ft2)

Engine 

Disp. (L)

Engine 

Power

(hp)

Torque

(ft-lb)

Subcompact Car 2795 41 1.9 134 133

Compact Car 3359 44 2.2 166 167

Midsize Car 3725 47 2.9 205 206

Large Car 4110 50 3.4 258 248

Performance Subcompact Car 3054 40 2.7 260 260

Performance Compact Car 3516 44 3.0 269 260

Performance Midsize Car 3822 47 3.9 337 318

Performance Large Car 4189 51 4.8 394 388

Minivan 4090 50 3.3 247 242

Small Truck 3413 45 2.6 178 185

Medium Truck 4260 50 3.6 250 256

Large Truck 5366 63 5.0 323 352

3.4.2.3.3 Electrical Power Steering (EPS)

Electric power steering (EPS) provides a potential reduction in CO2 emissions 

and fuel consumption over hydraulic power steering because of reduced overall accessory 

loads. This eliminates the parasitic losses associated with belt-driven power steering 

pumps which consistently draw load from the engine to pump hydraulic fluid through the 

steering actuation systems even when the wheels are not being turned. EPS is an enabler 

for all vehicle hybridization technologies since it provides power steering when the 
3-63 

engine is off. EPS may be implemented on most vehicles with a standard 12V system. 

Some heavier vehicles may require a higher voltage system which may add cost and 

complexity. 

In the 2011 final rule NHTSA estimated aNHTSA and EPA estimate 1.0 to 2 1 to 

2 percent effectiveness based on the 2002 NAS report, a Sierra Research report, and 

confidential manufacturer data. NHTSA and EPA reviewed these effectiveness and 

estimates and found them to be accurate, thus they have been retained for this proposal..

Regarding costs, in the MY 2011 CAFE final rule, NHTSA estimated EPS at 

$105-120 at 1.5 RPE mark-up factor. NHTSA and EPA adjusted these the EPS costs for 

the current proposal based on a review of the specification of the system. Adjustments 

were made to include potentially, which could accommodate higher voltage or heavier 

duty system operation, such as would be required on some hybrid trucks. Accordingly, 

higher costs were estimated for systems with higher capability. After accounting for the 

differences in system capability and applying the ICM markup of low complexity 

technology of 1.11, the estimated costs for this rulemaking are $106 for a MY 2012 

vehicle (2007$). With time-based learning, this cost would be $94 for a MY 2016 

vehicle (2007$). As EPS systems are in wide spread usage today, time based learning is 

deemed applicable. 

3.4.2.3.4 Improved Accessories (IACC)

The accessories on an engine, including the alternator, coolant and oil pumps are 

traditionally mechanically driven. A reduction in CO2 emissions and fuel consumption 

can be realized by driving them electrically, and only when needed (“on-demand”). 

Electric water pumps and electric fans can provide better control of engine 

cooling. For example, coolant flow from the an electric water pump can be restricted 

reduced and the radiator fan can be shut off during engine warm-upcold-start or cold 

ambient temperature conditions which will reduce warm-up time, reduce warm-up fuel 

enrichment, and reduce parasitic losses. 

Indirect benefit may be obtained by reducing the flow from the water pump 

electrically during the engine warm-up period, allowing the engine to heat more rapidly 

and thereby reducing the fuel enrichment needed during cold starting of the engine. 

Further benefit may be obtained when electrification is combined with an improved, 

higher efficiency engine alternator. Intelligent cooling can more easily be applied to 

vehicles that do not typically carry heavy payloads, so larger vehicles with towing 

capacity present a challenge, as these vehicles have high cooling fan loads.o

 

o

 In the CAFE model, IACC refers solely to improved engine cooling however EPA has included a high 

efficiency alternator in this category, as well as improvements to the cooling system. 
Draft Joint Technical Support Document 

3-64 

NHTSA and EPA jointly reviewed the estimates of 1 to 2 percent effectiveness 

estimates used in MY 2011 rule and found them to be accurate for Improved Electrical 

Accessories. NHTSA and EPA also reevaluated the assumptions from the MY 2011 

CAFE final rule. For its analysis, NHTSA simply adjusted the 2011 CAFE final rule 

costs to reflect the new ICM markup of low complexity value of 1.11, resulting in a cost 

estimate for this rulemaking of $128 at MY 2012 (2007$). Improved accessory systems 

are in production currently and thus timer based learning is applied. For its analysis, 

EPA considered both an accessory upgrade to a 12 Volt system and a combined 

accessory upgrade with conversion to a 42 Volt system. The accessory upgrade itself is 

estimated to cost $86 in MY 2012 and $76 in MY 2016 (with time-based learning; both 

in 2007$). The conversion to a 42 Volt electrical system is estimated to cost $97 for a 

MY 2012 vehicle and $86 for a MY 2016 vehicle (again with time-based learning; both 

in 2007$). 

 

3.4.2.3.5 12V Micro Hybrid (MHEV)

12V Micro-Hybrid (MHEV) systems are the most basic of hybrid systems and 

offer only the ability to turn the engine off when the vehicle is stopped or potentially 

during deceleration (i.e. idle stop). Their low cost and adaptability to existing 

powertrains and platforms can make them attractive for some applications. The 

conventional belt-driven alternator is replaced with a belt-driven, enhanced power 

starter-alternator and a redesigned front-end accessory drive system. A conventional 

12V gear-reduction starter is retained to ensure reliable cold-weather starting. Also, 

during idle-stop, some functions such as power steering and automatic transmission 

hydraulic pressure are lost; so electric power steering and an auxiliary transmission 

pump are needed. 

Although EPA doesn’t use the 12 V version of this stop-start technology, NHTSA 

and EPA jointly reviewed the assumptions. The effectiveness estimates for this 

technology ranged from 2.0 to 4.0 percent dependent on whether the vehicle is equipped 

with a 4, 6 or 8 cylinder engine, with the 4 cylinder engine having the lowest range and 

the 8 cylinder having the highest. The estimates reflect the limited capability of 12 volt 

systems; sources citing higher estimates typically involve higher voltage systems that 

have increased capability. 

For this proposal, the system specifications assumed in the 2011 CAFE final 

rule46 were applied (i.e., use of a 3 kW motor and a DC/DC converter) and the hybrid 

technology cost method produced costs like those in 2011 rule; however, the use of new 

ICM markups resulted in costs ranging from $288 for Subcompact subclass to $410 for 

the Large Performance subclass. This technology is not applied to the Large Truck and 

SUV subclass due to the heavy duty utility requirements of these vehicles. Time based 

learning is considered applicable, and a schematic of the MHEV system is shown in 

Figure 3-2. 

Figure 3-2 Schematic of MHEV type System [Husted, 2003] 

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3.4.2.3.6 Higher Voltage Stop-Start/Belt Integrated Starter 

Generator (BISG)

Higher Voltage Stop-Start and Belt Mounted Integrated Starter Generator 

(BISG) systems are similar to a micro-hybrid system, offering idle-stop functionality 

except that they utilize larger electric machine and a higher capacity battery, typically 

42 volts or above, thus enabling a limited level of regenerative braking which is 

generally not applicable to 12 volt systems. The larger electric machine and battery 

also enables a limited degree of power assist, which MHEV cannot provide. However, 

because of the limited torque capacity of the belt driven design, these systems have a 

smaller electric machine, and thus less capability than crank integrated or stronger 

hybrid systems. These systems replace the conventional alternator with a belt-driven 

starter/alternator and may add electric power steering and an auxiliary automatic 

transmission pump. The limited electrical requirements of these systems allow the use 

of lead-acid batteries or supercapacitors for energy storage. 

The effectiveness estimates used for these technologies range from 3.0 to 7.5 

percent dependent on vehicle subclass. The CAFE model, which applies this 

effectiveness incrementally to the prior 12 Volt technology, uses estimates of 4falls 

within the range of 3 to 6 percent. The estimates are is based on those found in the 2002 

NAS and 2004 NESCAFF reports, and confidential manufacturer data. 

EPA estimates an incremental compliance cost range of $549 (small car) to $682 

(large truck) for a MY 2012 vehicle and including a medium complexity ICM of 1.25 

(2007$). With volume-based learning applied, these become $351 (small car) and $437 

(large truck) for a MY 2016 vehicle (2007$). The cost estimate in the CAFE model is 

incremental to the 12 Volt micro hybrid systems as just noted and therefore is adjusted 

upwards to $286 to reflect the additional battery capacity, wiring upgrades, and a larger 

optimized electric machine only, as discussed above. The $286 reflects volume based 

learning factors and the ICM medium complexity markup of 1.25. 

Engine

Motor/ 

Generator

Trans.

Controller 

Inverter

Final Drive

Wheel

+ -

Battery
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3.4.2.3.7 Integrated Motor Assist (IMA)/Crank Integrated Starter 

Generator (CISG)

IMA is a system developed and marketed by Honda47 and is similar to CISG. 

They both utilize a thin axial electric motor bolted to the engine’s crankshaft and 

connected to the transmission through a torque converter or clutch. The axial motor is 

motor/generator that typically operates above 100 volts (but lower than the stronger 

hybrid systems discussed below, which typically operate at around 300 volts) and can 

provide sufficient torque for launch as well as generate sufficient current to provide 

significant levels of brake energy recovery. The motor/generator also acts as the starter 

for the engine and can replace a typical accessory-driven alternator. Current IMA/CISG

systems typically do not launch the vehicle on electric power alone, although some 

commercially available systems can cruise on electric power and dual-clutch 

IMA/CISG systems capable of all-electric drive are under development. IMA and 

CISG could be applied to all classes of vehicles. A schematic of the Honda IMA 

system is shown in Figure 3-3.

Figure 3-3 Schematic of Honda IMA System [Husted, 2003] 

NHTSA did not have an equivalent technology to CISG in the 2011 final rule (the 

ISG technology used in the 2011 rule was envisioned to be less capable than the CISG 

technology defined here). For the CISG technology NHTSA estimated a net

effectiveness range of 16 to 20 percent, relative to the baseline vehicle and across all 

vehicle subclasses in this analysis. The CAFE model therefore applies an incremental 

effectiveness of approximately 8.6 to 8.9 percent relative to the BISG technology and 

dependent on vehicle subclass except for large truck and SUV in which case BISG does 

not apply. Note that the net effectiveness assumptions used in this proposal do not 

include engine downsizing, or any other effectiveness gains from engine, transmission, or 

vehicle technologies added to the vehicle by the modeling process.

For the IMA/CISG technology NHTSA estimated a total effectiveness range of 16 

to 20 percent across the various subclasses. The CAFE model applies an incremental 

effectiveness of between 8.5 and 9 percent depending on the vehicle subclass. The net 

Final Drive

Engine Motor/ 

Generator 

Trans.

+ - 

Battery

Controller 

Inverter

Wheel
3-67 

effectiveness assumptions do not include or assume any form of engine downsizing, or 

the application of any additional engine, transmission, or vehicle technology to the 

vehicle being modeled.

EPA relied on a combination of certification data (comparing vehicles available 

with and without a hybrid system and backing out other components where appropriate) 

and manufacturer-supplied information to determine that the effectiveness of these 

systems in terms of CO2 reduction is 30% for small cars, 25% for large cars, and 20% for 

minivans and small trucks similar to the range estimated by NHTSA for the respective 

vehicle classes.. The effectiveness for small cars assumes engine downsizing to maintain 

approximately equivalent performance. The large car, minivan, and small truck 

effectiveness values assume less engine downsizing in order to improve vehicle 

performance and/or maintain towing and hauling performance. 

EPA has estimated these costs, relative to a base engine/transmission, as $4,459 

(small car) to $6,924 (large truck) for a MY 2012 vehicle and including a high 

complexity ICM of 1.45 (2007$). With volume-based learning, these costs become 

$2,854 and $4,431, respectively, for a MY 2016 vehicle (2007$). NHTSA has estimated

the MY 2012 compliance cost, relative to a BISG baseline, to range from $2,791 for 

Subcompact vehicles to $3,611 for Midsize Light Truck and Minivan vehicles. These 

include a high complexity ICM markup factor of 1.45 for this technology. As this 

technology is still in limited production use, volume based learning is applied, resulting 

in lower costs in later years.

NHTSA has estimated a compliance cost range of $2,791 to $4,431 in MY 2012 

based on the results provided by the hybrid costs estimating methodology. For the CAFE 

incremental approach, the costs were $2,791 for the Subcompact and $5,124 for the 

Large Truck and SUVs subclass when the high complexity ICM markup factor of 1.45 is 

used (all in 2007$). As this technology is still in limited production use, volume based 

learning is applied, resulting in lower costs in later years.

3.4.2.3.8 Power Split Hybrid

The Power Split hybrid (PSHEV) has the ability to move the vehicle on electric 

power only. It replaces the vehicle’s transmission with a single planetary gear and a 

motor/generator. A second, more powerful motor/generator is directly connected to the 

vehicle’s final drive. The planetary gear splits engine power between the first 

motor/generator and the final drive. The first motor/generator uses power from the 

engine to either charge the battery or supply power to the wheels. The speed of the first 

motor/generator determines the relative speed of the engine to the wheels. In this way, 

the planetary gear allows the engine to operate independently of vehicle speed, much like 

a CVT. The Toyota Prius and the Ford Hybrid Escape are two examples of power split 

hybrid vehicles. 

In addition to providing the functions of idle engine stop, subsequent restart and 

regenerative braking, this hybrid system allows for pure EV operation. The power split 
Draft Joint Technical Support Document 

3-68 

system provides very good fuel consumption in city driving. During highway cycles, the 

hybrid functions of regenerative braking, engine start/stop and optimal engine operation 

cannot be applied as often as in city driving, and so the effectiveness in fuel consumption 

is less. Additionally, it is less efficient at highway speeds due to the fact that the first 

motor/generator must be spinning at a relatively high speed and therefore incurs losses. 

Newer designs incorporate a gear-reduction motor to provide improved high speed 

efficiency and improved matching of motor torque to engine torque. 

The Power Split hybrid also reduces the cost of the transmission, replacing a 

conventional multi-speed unit with a single planetary gear. The electric components are 

bigger than those in mild hybrid and IMA/CISG configurations so the costs are 

correspondingly higher. 

EPA and NHTSA used a combination of manufacturer-supplied information and a 

comparison of vehicles available with and without a hybrid system from EPA’s fuel 

economy test data to determine that the effectiveness is 23-3519-36% for the classes to 

which it is applied. The estimate would depend on whether engine downsizing is also 

assumed. As an example, See Table 3-15Table 3-15Table 3-15 and Table 3-16Table 

3-16Table 3-16, which assume some level of engine downsizing. In the CAFE 

incremental model, the range of effectiveness used was 23 to 33 percent as engine 

downsizing is not assumed (and accounted for elsewhere). 

 Table 3-153-15 Large Car Power Split Certification Data 

 Tailpipe CO2

 City Hwy 55/45 comb. 

Nissan Altima 

3.5L CVT 444 306 386

 HEV 2.5L PS 317 254 286 

Net % difference -26%

 

Toyota Camry

 3.0L 5-auto 404 286 355 

HEV 2.4L PS 222 234 228

 Net % difference -36% 

 

Lexus GS 

 4.3L 6-auto 493 355 423 

 HEV 3.5L PS 355 317 341 

 Net % difference -19% 

 

Table 3-163-16 Small Truck Power Split Certification Data

 Tailpipe CO2

 City Hwy 55/45 comb. 

Ford Escape 4X4 

 3.0L 4-auto 467 386 423 

 HEV 2.3L PS 277 306 286 

Net % difference -32%

 

Ford Escape 4X2

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3-69 

 3.0L 4-auto 444 370 404 

 HEV 2.3L PS 247 286 261 

 Net % difference -35% 

 

Toyota Highlander 4X4 

 3.3L 5-auto 493 370 423 

 HEV 3.3L PS 286 329 306 

 Net % difference -28% 

 

Using the hybrid cost estimating methodology with updated component costs, 

EPA established a compliance cost range of $4,481 (small cars) to $8,145 (large trucks) 

relative to the base engine and transmission for a MY 2012 vehicle (all in 2007$). With 

time-based learning, these costs become $3,967 and $7,210, respectively, for a MY 2016 

vehicle (2007$). Using the same methodology, NHTSA established overall PSHEV 

system costs with electric power steering (PESEPS) and improved accessories (IACC) 

ranging from $5,509 to $11,534 for MY 2012, which leads to incremental costs in the 

CAFE model ranging from $1,600 to $6,723 depending on the subclass (all in 2007$). 

The estimates were determined with a 1.45 ICM for a high complexity technology. 

Time-based learning is applicable to the power split technology. 

3.4.2.3.9 2-Mode Hybrid

The 2-Mode Hybrid (2MHEV) uses an adaptation of a conventional stepped-ratio 

automatic transmission which replaces some of the transmission clutches with two 

electric motor/generators allowing the transmission to act like a CVT. The 

motor/generators control the ratio of engine speed to vehicle speed. The clutches allow 

the motors to be bypassed improving the transmission’s torque capacity and the 

efficiency for improved fuel economy at highway speeds. This type of system is used in 

the Chevrolet Tahoe Hybrid. 

In addition to providing the hybrid functions of engine stop and subsequent restart 

and regenerative braking, the 2MHEV allows for pure EV operation. The two 

motor/generators allow the engine to be run in efficient operating zones. The 2-mode 

system provides significantly reduced CO2 emissions and fuel consumption. The 

primary motor/generator is comparable in size to that in the PSHEV system, but the 

secondary motor/generator is larger. The 2-mode system cost is greater than that for the 

power split system due to the additional transmission complexity and secondary motor 

sizing. 

The battery pack for 2MHEV is assumed to be 300V NiMH as is used in current 

2MHEV systems today however GM recently announced an agreement with Hitachi to 

provide Li-ion battery packs for 2012 and later 2MHEVs. 

For this proposal the CAFE model considered a range of 23 to 33 percent with a 

midpoint of 28 percent, assuming no engine downsizing to preserve the utility nature of 

medium and large trucks (e.g., maintaining full towing capability even in situations with 
Draft Joint Technical Support Document 

3-70 

low battery charge) and EPA estimates CO2 emissions reduction effectiveness to be 25 

percent for large trucks (LDT3 and LDT4 categories) based on vehicle certification data. 

EPA estimates an effectiveness of 40 percent for smaller vehicles. 

EPA and NHTSA estimated MY 2012 costs using the updated component costs 

and scaling factors in the hybrid cost estimating methodology discussed above. EPA 

estimated the compliance cost to range from $5,469 for large car to $7,236 for large 

truck/SUV relative to the base engine/transmission (all in 2007$). NHTSA determined 

incremental cost estimates ranging from $3,521 to $5,779 for light-duty truck 

applications in the CAFE model. These include the 1.45 ICM markup value for high 

complexity technology. Given that the CAFE and OMEGA models classify vehicles 

differently, these numbers varied slightly in the modeling to reflect the different 

classification methods of the OMEGA and CAFE models, as described in the individual 

NHTSA and EPA PRIAs. Volume based learning is applicable to this technology. 

3.4.2.3.10 Plug-In Hybrid

Plug-In Hybrid Electric Vehicles (PHEVs) are very similar to Hybrid Electric 

Vehicles, but with three significant functional differences. The first is the addition of a 

means to charge the battery pack from an outside source of electricity (e.g. the electric 

grid). Second, a PHEV would have a larger battery pack with more energy storage, and a 

greater capability to be discharged. Finally, a PHEV would have a control system that 

allows the battery pack to be significantly depleted during normal operation. 

Table 3-17Table 3-17Table 3-17 below, illustrates how PHEVs compare 

functionally to both hybrid electric vehicles (HEV) and electric vehicles (EV). These 

characteristics can change significantly within each class/subclass, so this is simply 

meant as an illustration of the general characteristics. In reality, the design options are so 

varied that all these vehicles exist on a continuum with HEVs on one end and EVs on the 

other. 

Table 3-173-17 Conventional, HEVs, PHEVs, and EVs Compared 

 Increasing Electrification

Attribute Conventional HEV PHEV EV 

Drive Power Engine Blended 

Engine/Electric 

Blended 

Engine/Electric Electric 

Engine Size Full Size Full Size or Smaller Smaller or Much 

Smaller No Engine 

Electric Range None None to Very Short Short to Medium Medium to Long 

Battery Charging None On-Board Grid/On-Board Grid Only

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3-71 

Deriving some of their propulsion energy from the electric grid provides several 

advantages for PHEVs. PHEVs offer a significant opportunity to replace petroleum used 

for transportation energy with domestically-produced electricity. The reduction in 

petroleum usage does, of course, depend on the amount of electric drive the vehicle is 

capable of under its duty cycle.[1] PHEVs also provide electric utilities the possibility to 

increase electric generation during “off-peak” periods overnight when there is excess 

generation capacity and electricity prices are lower. Utilities like to increase this “base 

load” because it increases overall system efficiency and lowers average costs. Utilities 

are also investigating the use of PHEV and EV batteries as a source of grid storage 

capacity to provide ancillary services for grid stabilization purposes. PHEVs can lower 

localized emissions of criteria pollutants and air toxics especially in urban areas by 

operating on electric power. The emissions from the power generation occur outside the 

urban area at the power generation plant which provides health benefits for residents of 

the more densely populated urban areas by moving emissions of ozone precursors out of 

the urban air shed. Unlike most other alternative fuel technologies, PHEVs can initially 

use an existing infrastructure for refueling (charging and liquid refueling) so investments 

in infrastructure may be reduced. 

In analyzing the impacts of grid-connected vehicles like PHEVs and EVs, the 

emissions from the electrical generation can be accounted for if a full upstream and 

downstream analysis is desired. While this issue is being studied on an on-going basis, 

upstream CO2 emissions are not unique to grid-connected technologies and so are not 

included in this analysis. 

PHEVs will be considerably more costly than conventional vehicles and some 

other advanced technologies. To take advantage of their capability, consumers would 

have to be willing to charge the vehicles nightly, and would need access to electric power 

where they park their vehicles. For many urban dwellers who may park on the street, or 

in private or public lots or garages, charging may not be practical. Charging may be 

possible at an owner’s place of work, but that would increase grid loading during peak 

hours which would eliminate some of the benefits to utilities of off-peak charging vs. onpeak. Oil savings will still be the same in this case assuming the vehicle can be charged 

fully. 

The effectiveness potential of PHEVs depends on many factors, the most 

important being the energy storage capacity designed into the battery pack. To estimate 

the fuel consumption and tailpipe CO2 reduction potential of PHEVs, EPA has developed 

an in-house vehicle energy model (PEREGRIN) to estimate the fuel consumption/CO2

emissions reductions of PHEVs. This model is based on the PERE (Physical Emission 

Rate Estimator) physics-based model used as a fuel consumption input for EPA’s 

MOVES mobile source emissions model[2]. 

The PHEV small car, large car, minivan and small trucks were modeled using 

parameters from a midsize car similar to today’s hybrids and scaled to each vehicle’s 
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weight. The large truck PHEV was modeled separately assuming no engine downsizing. 

PHEVs can have a wide variation in the All Electric Range (AER) that they offer. Some 

PHEVs are of the “blended” type where the engine is on during most of the vehicle 

operation, but the proportion of electric energy that is used to propel the vehicle is 

significantly higher than that used in a PSHEV or 2MHEV. Each PHEV was modeled 

with enough battery capacity for a 20-mile-equivalent AER and a power requirement to 

provide similar performance to a hybrid vehicle. 20 miles was selected because it offers 

a good compromise for vehicle performance, weight, battery packaging and cost. Given 

expected near-term battery capability, a 20 mile range represents the likely capability that 

will be seen in PHEVs in the near-to-mid term.[3] 

To calculate the total energy use of a PHEV, the PHEV can be thought of as 

operating in two distinct modes, electric (EV) mode, and hybrid (HEV) mode. At the 

tailpipe, the CO2 emissions during EV operation are zero. The EV mode fuel economy 

can then be combined with the HEV mode fuel economy using the Utility Factor 

calculation in SAE J1711 to determine a total MPG value for the vehicle. (See Table 

3-18Table 3-18Table 3-18) 

Table 3-183-18 Sample Calculation of PHEV Gasoline-Equivalent CO2 Reduction 

 Midsize Car Large Truck 

EV energy comb (0.55 city / 0.45 hwy) 0.252 kwh/mi 0.429 kwh/mi

EV range (from PEREGRIN) 20 miles 20 miles 

SAE J1711 utility factor 0.30 0.30

HEV mode comb FE (0.55 city / 0.45 hwy) 49.1 mpg 25.6 mpg 

Total UF-adjusted FE (UF*FCEV + (1-UF)*FCHEV) 70.1 mpg 36.6 mpg

Baseline FE 29.3 mpg 19.2 mpg 

Percent FE gain 139% 90%

Percent CO2 reduction -58% -47% 

Calculating a total fuel consumption and tailpipe CO2 reduction based on model 

outputs and the Utility Factor calculations results in a 58% reduction for small cars, large 

cars, minivans, and small trucks. For large trucks, the result is a 47% reduction. The 

lower improvement is due to less engine downsizing in the large truck class. The CAFE 

model does not apply this technology to medium and large trucks and SUVs.

Using the hybrid cost estimating model and updated component costs, EPA and 

NHTSA determined MY 2012 incremental cost estimates for the CAFE model ranging 

from $11,527 for a subcompact car to $9,18719,265 for a midsize performance car. This 

includes the 1.64 ICM markup value for very high complexity technology. In the 

OMEGA model, and relative to a IMA/ISA/BSG, these values range from $6,922 for 

small car to $12,467 for a large truck, and relative to power-split hybrid, these values 

range from $5,423 for small car to $9,643 for large truck (all values for MY 2016 in 

2007$). Volume-based learning is applied to plug-in hybrid costs since this is a newly 

emerging technology. 

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3.4.2.4 Vehicle Technologies

3.4.2.4.1 Mass Reduction

Reducing a vehicle’s mass, or down weighting the vehicle, reduces decreases fuel 

consumption by reducing the energy demand that is needed to overcome forces resisting 

motion, and rolling resistance. Manufacturers employ a systematic approach to mass 

reduction were the net mass reduction is the addition of a direct component or system 

mass reduction plus the additional mass savings reduction taken from indirect ancillary 

systems and components, as a result of full vehicle optimization, effectively 

compounding the mass savingsreductions. Many manufacturers have already announced 

proposed future products plans reducing the weight of a vehicle body through the use of 

high strength steel body-in-white, composite body panels, magnesium alloy front and rear 

energy absorbing structures reducing vehicle weight sufficiently to allow a smaller, 

lighter and more efficient engine. 

Use of a smaller, lighter engine with lower torque-output subsequently allows the 

use of a smaller, lighter-weight transmission and drive line components. The 

compounded weight reductions of the body, engine and drivetrain reduce stresses on the 

suspension components, steering components, wheels, tires and brakes, allowing further 

reductions in the weight of these subsystems. The reductions in weight for unsprung 

masses such as brakes, control arms, wheels and tires further reduce stresses in the 

suspension mounting points allowing still furthering the compounding effect of mass 

reductions. 

Down-weighting through material substitution is broadly applicable across all 

vehicle subsystems including the engine, exhaust system, transmission, chassis, 

suspension, brakes, body, closure panels, glazing, seats and other interior components, 

engine cooling systems and HVAC systems. Weight reductions of 10 percent without the 

compounding effects account for a 2 to 4 percent fuel consumption and CO2 emissions 

reduction. When the mass reduction compounding techniques are used, this value is 

increased to a 6 to 7 percent fuel consumption and CO2 emissions reduction.48,49,50 It is 

estimated that up to 1.25 kilograms of secondary weight savings can be achieved for 

every kilogram of weight saved on a vehicle when all subsystems are redesigned to take 

into account the initial primary weight savings.51,52 

Down-weighting/material substitution can be accomplished by proven methods 

such as: 

• Smart Design: Computer aided engineering (CAE) tools can be used to better 

optimize load paths within structures by reducing stresses and bending moments 

applied to structures (Figure 3-4 through Figure 3-6). This allows better 

optimization of the sectional thicknesses of structural components to reduce mass 

while maintaining or improving the function of the component. Smart designs 

also integrate separate parts in a manner that reduces mass by combining 

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functions or the reduced use of separate fasteners. In addition, some “body on 

frame” vehicles are redesigned with a lighter “unibody” construction. 

• Material Substitution: Substitution of lower density and/or higher strength 

materials into a design in a manner that preserves or improves the function of the 

component. This includes substitution of high-strength steels, aluminum, 

magnesium or composite materials for components currently fabricated from mild 

steel. 

• Reduced Powertrain Requirements: Reducing vehicle weight sufficiently allows 

for the use of a smaller, lighter and more efficient engine while maintaining or 

increasing performance. Approximately half of the reduction is due to these 

reduced powertrain output requirements from reduced engine power output and/or 

displacement, changes to transmission and final drive gear ratios. The subsequent 

reduced rotating mass (e.g. transmission, driveshafts/halfshafts, wheels and tires) 

via weight and/or size reduction of components are made possible by reduced 

torque output requirements. 

Using smart design, material substitution and space efficient designs have already 

been integrated into vehicles as new platforms cycle into production although net vehicle 

weight and performance has continued to increase (Figure 3-4). 

Figure 3-4: Example of CAE optimization of the design and position of the roof rails and front seat 

cross-member for the “Future Generation Passenger Compartment.”53 The thin lines represent 

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relative positions for roof bows and front cross-members considered during iterations of the CAE 

analysis of the vehicle structure. The different colors given to the structural components represent 

differences in sectional material thickness within this particular CAE modeling run. 
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Figure 3-5: Example of CAE optimization of a roof-rail design for the “Future Generation Passenger 

Compartment” that reduces component mass by 41%.5353

Figure 3-6: Example of CAE optimization of a door-beam design for the “Future Generation 

Passenger Compartment” that reduces component mass by 57% and reduces part count and 

assemby.5353

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Figure 3-7: Lightweight, tubular front door intrusion beams (2007 Civic) 

• Automotive companies have largely used weight savings in some vehicle 

subsystems to offset or mitigate weight gains in other subsystems from increased 

feature content (sound insulation, entertainment systems, improved climate 

control, panoramic roof, etc.). 

• Lightweight designs have also been used to improve vehicle performance 

parameters by increased acceleration performance or superior vehicle handling 

and braking. 

Many manufacturers have already announced proposed future products plans 

reducing the weight of a vehicle body through the use of high strength steel body-inwhite, composite body panels, magnesium alloy front and rear energy absorbing 

structures reducing vehicle weight sufficiently to allow a smaller, lighter and more 

efficient engine. Use of a smaller, lighter engine with lower torque-output subsequently 

allows the use of a smaller, lighter-weight transmission and drive line components. The 

compounded weight reductions of the body, engine and drivetrain reduce stresses on the 

suspension components, steering components, wheels, tires and brakes, allowing further 

reductions in the weight of these subsystems. The reductions in weight for unsprung 

masses such as brakes, control arms, wheels and tires further reduce stresses in the 

suspension mounting points allowing still further reductions in weight. 

NHTSA in the CAFE model has used a tiered approach using material 

substitution to reduce mass without considering other means of vehicle mass reduction. 
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MS1, a 1.5 percent mass reduction, is applicable in any year at refresh or redesign. MS2, 

a 3.5 to 8.5 percent mass reduction is only available in MY 2014 and beyond in an 

attempt to mimic the product plans’ applications of down-weighting/material substitution 

in later years. For smaller vehicles MS2 was limited to a 3.5 percent mass reduction of 

down-weighting/material substitution on smaller vehicles and for larger cars and trucks 

up to 8.5 percent mass reduction. 

 In the CAFE model, MS2 is cumulative to MS1, as it is only applied after MS1; 

therefore the maximum weight reduction that can occur for smaller subclass vehicles is 

5%, while large cars, truck, and SUVs could experience up to a 10% weight reduction. 

Restricting weight reduction on smaller vehicles to lower limits, and vice versa for larger 

vehicles, is intended to mitigate or minimize the potential safety consequences from the 

modeled down-weighting/material substitution. Making the MS2 technology unavailable 

until MY 2014 is intended to recognize the lead time required to implement platform 

redesigns that would be necessary for these levels of weight reduction. 

NHTSA and EPA estimate that a 10 percent reduction in mass results in a 6.5 

percent reduction in fuel consumption while maintaining equivalent vehicle performance 

(i.e. 0-60 mph time, towing capacity, etc.) which is consistent with estimates in the 2002 

NAS report 

NHTSA and EPA have reviewed three studies of down-weighting/material 

substitution and the associated cost. The first, NAS, estimated that vehicle weight could 

be reduced for approximately $1.50 per pound. (3-4% reductions in fuel consumption, 

without engine downsizing, from a 5% reduction in vehicle weight at a cost of $210-

$350. This translates into $1.50 per pound, assuming a 3800 pound base vehicle and 

using the midpoint cost.) Additionally, Sierra Research estimates a 10% reduction, with 

compounding, could be accomplished for a cost of $1.01 per pound. Finally, MIT 

estimated that the weight of a vehicle could be reduced by 14%, with no compounding, 

for a cost of $1.36 per pound. The final cost estimate is $1.32 per pound and is based on 

the average of the three referenced studies. Applying an ICM factor of 1.11 for a low 

complexity technology results in a compliance cost of $1.48 per pound. For the vehicle 

mass reduction technologies, neither volume-based nor time-based cost reductions are 

applied since many of the materials under consideration are commodity based. 

 

3.4.2.4.2 Low Drag Brakes (LDB)

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 rotating disc 

either by mechanical or software designselectric methods. While most passenger cars 

have already adopted this technology with the standardization of electronic brake control, 

there are indications that this technology is still available for body-on-frame trucks. .

NHTSA’s MY 2011 CAFE final rule estimated the effectiveness of LDB to be up 

to 1 percent, based on confidential manufacturer data. NHTSA and EPA have reviewed 

this estimate and believe it to be applicable for the NPRM. 
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NHTSA and EPA have reviewed the cost estimates from the MY 2011 CAFE 

final rule and have not found any evidence to suggest that this cost is not a valid cost and 

have chosen to maintain this estimate. However, the agencies adjusted the costs to apply 

the ICM of 1.11, for a low complexity technology. The compliance cost for LDB is 

estimated to be $63 for MY 2012 through MY 2016 vehicles as no learning effects are 

applied to this technology.. 

 

3.4.2.4.3 Low Rolling Resistance Tires (ROLL)

Tire rolling resistance is the frictional loss associated mainly with the energy 

dissipated in the deformation of the tires under load and thus influences fuel economy 

and CO2 emissions. Other tire design characteristics (e.g., materials, construction, and 

tread design) influence durability, traction (both wet and dry grip), vehicle handling, and 

ride comfort in addition to rolling resistance. A typical low rolling resistance tires 

attributes would include: increased tire inflation pressure, material changes, and tire 

construction with less hysteresis, geometry changes (e.g., reduced aspect ratios), and 

reduction in sidewall and tread deflection. These changes would generally be 

accompanied with additional changes to suspension tuning and/or suspension design. 

EPA and NHTSA estimate a 1 to 2 percent increase in effectiveness with a 10 

percent reduction in rolling resistance, which was based on the 2002 NAS report findings 

and consistent with NHTSA’s MY 2011 CAFE final rule estimate. NHTSA and EPA 

still believe that this NAS effectiveness estimate to beis valid for this NPRM. Lower 

rolling resistance tires are widely available today. 

Based on NHTSA’ MY 2011 CAFE final rule and the 2006 NAS/NRC report, the 

agencies have estimated the cost for low rolling resistance tires to be $6 per vehicle.54 

This is based on a cost of $1 per tire as estimated by NAS/NRC 2006 report, which is $5 

per vehicle, including the spare tire. When applying the ICM low complexity markup 

factor, of 1.11, results in compliance cost of $6 per vehicle for MY 2012 through MY 

2016 vehicles (2007$).p Due to the commodity based nature of this technology cost 

learning is not applied. 

3.4.2.4.4 Front or Secondary Axle Disconnect for Four-Wheel 

Drive Systems (SAX)

Energy is required to continually drive the front, or secondary, axle in a four 

wheel drive system even when the system is not required during most operating 

conditions. This energy loss directly results in increased fuel consumption and CO2 

 

p

 Note that the costs developed for low rolling resistance tires for this analysis do not include the increase in 

lifetime costs that would be expected at each tire replacement. Instead, the analysis includes only the 

upfront increase in costs. The agencies intend to include the lifetime costs in the final analysis.
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emissions. Many part-time four-wheel drive systems use some type of front axle 

disconnect to provide shift-on-the-fly capabilities,. The front axle disconnect is normally 

part of the front differential assembly. As part of a shift-on-the-fly four-wheel drive 

system, the front axle disconnect serves two basic purposes. First, in two-wheel-drive 

mode, it disengages the front axle from the front driveline so the front wheels do not turn 

the front driveline at road speed, saving wear and tear. Second, when shifting from twoto four-wheel drive "on the fly" (while moving), the front axle disconnect couples the 

front axle to the front differential side gear only when the transfer case's synchronizing 

mechanism has spun the front driveshaft up to the same speed as the rear driveshaft. 

Four-wheel drive systems that have a front axle disconnect typically do not have either 

manual- or automatic-locking hubs. To isolate the front wheels from the rest of the front 

driveline, front axle disconnects use a sliding sleeve to connect or disconnect an axle 

shaft from the front differential side gear. NHTSA and EPA are not aware of any 

manufacturer offering this technology in the US today on unibody frame vehicles; 

however, it is possible this technology could be introduced by manufacturers within the 

rulemaking time period. there is no reason why this technology could not be introduced 

by manufacturers within the next one to two years

Based on confidential manufacturer data, NHTSA’s MY 2011 CAFE final rule 

estimated an effectiveness improvement of 1 to 1.5 percent for axle disconnect. NHTSA 

and EPA believe this to still be an accurate estimate for this rulemaking. 

Regarding costs, the agencies believe the incremental compliance cost from 

NHTSA’s MY 2011 final rule to be accurate. However, this was revised by applying the 

new ICM factor markup, for a low complexity technology, of 1.11. Thus, the compliance 

cost estimate for this NPRM, is $95 for a MY 2012 vehicle (2007$). With time-based 

learning this cost would be $84 for a MY 2016 vehicle (2007$). 

3.4.2.4.5 Aerodynamic Drag Reduction (AERO)

Many factors affect a vehicle’s aerodynamic drag and the resulting power 

required to move it through the air. While these factors change with air density and the 

square and cube of vehicle speed, respectively, the overall drag effect is determined by 

the product of its frontal area and drag coefficient. Reductions in these quantities can 

therefore reduce fuel consumption and CO2 emissions. Although frontal areas tend to be 

relatively similar within a vehicle class (mostly due to market-competitive size 

requirements), significant variations in drag coefficient can be observed. Significant 

changes to a vehicle’s aerodynamic performance may need to be implemented during a 

redesign (e.g. changes in vehicle shape). However, shorter-term aerodynamic reductions, 

with a somewhat lower effectiveness, may be achieved through the use of revised exterior 

components (typically at a model refresh in mid-cycle) and add-on devices that currently 

being applied. The latter list would include revised front and rear fascias, modified front 
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air dams and rear valances, addition of rear deck lips and underbody panels, and more 

efficient lower aerodynamic drag exterior mirrors. 

The MY 2011 CAFE final rule estimated that a fleet average of 10 to 20 percent 

total aerodynamic drag reduction is attainable (with a caveat for “high-performance” 

vehicles described below) which equates to incremental reductions in fuel consumption 

and CO2 emissions of 2 percent and 3 percent for cars and trucks. These numbers are 

generally supported by confidential manufacturer data and public technical literature and 

therefore NHTSA and EPA are retaining these estimates, as confirmed by joint review, 

for the purposes of this proposal. 

In the MY 2011 CAFE final rule, NHTSA estimated a range from $60 to $116 

(1.5 RPE); $40 to $75 (without RPE). .NHTSA and EPA reviewed these estimates and 

updated these estimates to reflect the new ICM markup factor of 1.11 for a low 

complexity technology. In addition, given its low complexity and the facility of its 

implementation during design and refresh cycles, NHTSA and EPA estimate closer to the 

lower end of the range is more appropriate. Thus, the cost estimate used in this 

rulemaking is $48, including the 1.11 ICM markup value, for a low complexity 

technology (2007$). This compliance cost is for a MY 2012 vehicle. With time-based 

learning, this cost would be $42 for a MY 2016 vehicle (2007$) 

3.4.2.5 Technologies considered but not included in the final rule 

analysis

NHTSA and EPA have identified six technologies that will not be available in the 

time frame considered under this rulemaking (though electric vehicles are available 

today). These technologies while considered were not made available in the CAFE and 

OMEGA models. They are: electric vehicles, camless valve actuation (CVA), lean burn 

gasoline direct injection (LBDI), homogeneous charge compression ignition (HCCI), and 

electric assist turbocharging and full series hydraulic hybrids (HHV). NHTSA and EPA 

will continue to monitor the industry and system suppliers for progress on these 

technologies, and should they become more available, consider them for use in future 

rulemaking activity. 

3.4.2.5.1 Electric Vehicles

The recent intense interest in Hybrid vehicles and the development of Hybrid 

vehicle battery and motor technology has helped make Electric Vehicle technology more 

viable than it has ever been. Electric Vehicles (EVs) require much larger batteries than 

either HEVs or PHEVs, but the batteries must be of a high-energy and lower-power 

design to deliver an appropriate amount of power over the useful charge of the battery. 

These high-energy batteries are generally less expensive per kilowatt-hour than high-
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power batteries required for hybrids, but the size of the battery pack still incurs a 

considerable cost. 

Electric motor and power electronics designs are very similar to HEV and PHEV 

designs, but they must be larger, more powerful, and more robust since they provide the 

only motive power for the vehicle. On the other hand, the internal combustion engine, 

fuel system, and possibly the transmission can all be removed for significant weight, 

complexity and cost savings. 

As for PHEVs, two electric vehicles were modeled, a small car and a large car, 

using the same model (PEREGRIN) and similar assumptions. EVs are only considered 

for these two classes because the larger, heavier vehicles would require too much battery 

capacity to be practical in the short-to-mid term and the agencies do not see any serious 

development activities for these vehicle types in the market. 

We chose to model the EVs with a range of 150 miles on the urban driving cycle 

because this range offers a good compromise in capability and battery cost, weight and 

size with expected technology in the near- to mid-term. Using the same methodology as 

used for PHEVs to calculate gasoline-equivalent fuel consumption, the results obtained 

are shown in Table 3-19Table 3-19Table 3-19, below. 

Table 3-193-19 Electric Vehicle Gasoline-Equivalent CO2 Reduction

Small Car Large Car 

EV energy comb (0.55 city / 0.45 hwy) 0.202 kwh/mi 0.244 kwh/mi 

City cycle EV range 150 miles 150 miles 

Highway cycle EV range 166 miles 162 miles

Baseline FE 35.5 25.3 mpg

Tailpipe CO2 reduction 100% 100% 

3.4.2.5.2 Camless Valve Actuation

Camless valve actuation relies on electromechanical actuators instead of 

camshafts to open and close the cylinder valves. When electromechanical actuators are 

used to replace cams and coupled with sensors and microprocessor controls, valve timing 

and lift can be optimized over all conditions. An engine valvetrain that operates 

independently of any mechanical means provides the increased flexibility for intake and 

exhaust timing and lift optimization. With it comes increased ability to vary valve 

overlap, the rapid response required to change between combustion operating modes 

(such as HCCI and GDI), intake valve throttling, cylinder deactivation, and elimination 

of the camshafts (reduced friction and rotating mass). This level of control can enable 

even further incremental reductions in fuel consumption and CO2 emissions. 

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This technology has been under research for many decades and although progress 

is being made, NHTSA and EPA have not found evidence to support that the technology 

can be successfully implemented within the 2012 through 2016 timeframe of these 

regulations. Thus NHTSA and EPA have not estimated cost or effectiveness at this time. 

3.4.2.5.3 Lean-Burn Gasoline Direct Injection Technology

Direct injection, especially with diesel-like “spray-guided” injection systems, 

enables operation with excess air in a stratified or partially-stratified fuel-air mixture, as a 

way of reducing the amount of intake throttling. Also, with higher-pressure fuel injection 

systems, the fuel may be added late enough during the compression stroke so as to delay 

the onset of autoignition, even with higher engine compression ratios or with boosted 

intake pressure. Taken together, an optimized “lean-burn” direct injection gasoline 

engine may achieve high engine thermal efficiency approaching which approaches that of 

a diesel engine. European gasoline direct-injection engines have implemented stratifiedcharge lean-burn GDI, although at higher NOx emissions levels than are allowed at under 

U.S. Federal Tier 2 emissions standards. Fuel system improvements, changes in 

combustion chamber design and repositioning of the injectors have allowed for better 

air/fuel mixing and combustion efficiency. There is currently a shift from wall-guided 

injection to spray guided injection, which improves injection precision and targeting 

towards the spark plug, increasing lean combustion stability. Combined with advances 

in NOx after-treatment, lean-burn GDI engines may eventually be a possibility in North 

America. 

EPA and NHTSA’s current assessment is that the availability of ultra-low sulfur 

(less than 15 ppm sulfur) gasoline is a key technical requirement for lean-burn GDI 

engines to meet EPA’s Tier 2 NOx emissions standards, therefore the technology was not 

applied in within EPA or NHTSA analyses. 

 

3.4.2.5.4 Homogeneous Charge Compression Ignition

Gasoline homogeneous charge compression ignition (HCCI), also referred to as 

controlled autoignition (CAI), is an alternate engine operating mode that does not rely on 

a spark event to initiate combustion. The principles are more closely aligned with a 

diesel combustion cycle, in which the compressed charge exceeds a temperature and 

pressure necessary for spontaneous autoignition although it differs form from diesel by 

having a homogenous fuel/air charge rather than being a diffusion controlled combustion 

event. The subsequent combustion event is much shorter in duration with higher thermal 

efficiency. 
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An HCCI engine has inherent advantages in its overall efficiency for two main 

reasons: 

• The engine is operated with a higher compression ratio, and with a shorter 

combustion duration, resulting in a higher thermodynamic efficiency, and 

• The engine can be operated virtually unthrottled, even at light loads, 

Combined, these effects have shown an increase in engine brake efficiency 

(typically 25-28%) to greater than 35% at the high end of the HCCI operating range.55

 

Criteria pollutant emissions are very favorable during HCCI operation. Lower peak incylinder temperatures (due to high dilution) keep engine-out NOx emissions to a 

minimum – realistically below Tier 2 levels without aftertreatment – and particulates are 

low due to the homogeneous nature of the premixed charge. 

Due to the inherent difficulty in maintaining combustion stability without 

encountering engine knock, HCCI is difficult to control, requiring feedback from incylinder pressure sensors and rapid engine control logic to optimize combustion timing, 

especially considering the transient nature of operating conditions seen in a vehicle. Due 

to the highly dilute conditions under which gasoline-HCCI combustion is stable, the 

range of engine loads achievable in a naturally-aspirated engine is somewhat limited. 

Because of this, it is likely that any commercial application would operate in a “dualmode” strategy between HCCI and spark ignition combustion modes, in which HCCI 

would be utilized for best efficiency at light engine loads and spark ignition would be 

used at higher loads and at idle. This type of dual-mode strategy has already been 

employed in diesel HCCI engines in Europe and Asia (notably the Toyota Avensis D-Cat 

and the Nissan light-duty “MK” combustion diesels).

Until recently, gasoline-HCCI technology was considered to still be in the 

research phase. However, most manufacturers have made public statements about the 

viability of incorporating HCCI into light-duty passenger vehicles, and have significant 

vehicle demonstration programs aimed at producing a viable product within the next 5-10 

years. 

There is widespread opinion as to the CO2 reduction potential for HCCI in the 

literature. Based on confidential manufacturer information, EPA and NHTSA believes

that a gasoline HCCI / GDI dual-mode engine might achieve 10-12% reduction in CO2, 

compared to a comparable SI engine. Despite its promise, application of HCCI in light 

duty vehicles is not yet ready for the market. It is not anticipated to be seen in volume for 

at least the next 5-10 years, which is concurrent with many manufacturers’ public 

estimates. NHTSA also noted in its MY 2011 CAFE final rule that the technology will 

not be available within the time frame considered based on a review of confidential 

product plan information. 
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3.4.2.5.5 Electric Assist Turbocharging

The Alliance commented in NHTSA’s previous rulemaking that global 

development of electric assist turbocharging has not demonstrated the fuel efficiency 

effectiveness of a 12V EAT up to 2kW power levels since the 2004 NESCCAF study, 

and stated that it saw remote probability of its application over the next decade.a While 

hybrid vehicles lower the incremental hardware requirements for higher-voltage, higherpower EAT systems, NHTSA and EPA agree that significant developmental work is 

required to demonstrate effective systems and that implementation in significant volumes 

will not occur in the 2012 to 2016 time frame considered in this rulemaking. Thus, this 

technology was not included in the NPRM. 

 

3.4.2.5.6 Full Series Hydraulic Hybrid

A Full Series Hydraulic Hybrid Vehicle (HHV) is somewhat similar in concept to 

a full series electric hybrid vehicle, except that the energy is stored in the form of 

compressed nitrogen gas and the power is transmitted in the form of hydraulic fluid. 

Series HHV technology currently under development by EPA is capable of a 40% 

decrease in tailpipe CO2 emissions in the small car, large car, minivan, and small truck 

classes. In the large truck class, a 30% CO2 reduction is possible. The large truck benefit 

is somewhat lower than the other classes because it is assumed that a large truck requires 

a larger engine to maintain towing and hauling performance after the energy in the high 

pressure hydraulic accumulator is exhausted. This technology is still under development 

and not yet commercialized however there are technology demonstration vehicles in 

service with UPS in daily package delivery service.

 

3.5 Cost and effectiveness tables

 

The tables representing the Volpe model input files for incremental technology 

costs by vehicle subclass are presented below. The tables have been divided into 

passenger cars, performance passenger cars, and light trucks to make them easier to read. 

3.5.1 NHTSA cost and effectiveness tables 

Table 3-203-20 Technology Incremental Cost Estimates for VolpeOLPE model, Performance 

Passenger Cars
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VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE (2007$) BY VEHICLE 

SUBCLASS - PASSENGER CARS

Subcompact Compact Midsize Large

Car Car Car Car

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6

Low Friction Lubricants 3 3 3 3

Engine Friction Reduction EFR 50 50 50 75

VVT - Coupled Cam Phasing (CCP) on SOHC CCPS 45 45 45 90

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 142 142 142 205

Cylinder Deactivation on SOHC DEACS n.a. n.a. n.a. 0 - 56

VVT - Intake Cam Phasing (ICP) ICP 45 45 45 90

VVT - Dual Cam Phasing (DCP) DCP 38 38 38 83

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 142 142 142 205

Continuously Variable Valve Lift (CVVL) CVVL 277 277 277 509

Cylinder Deactivation on DOHC DEACD n.a. n.a. n.a. 0 - 56

Cylinder Deactivation on OHV DEACO n.a. n.a. n.a. 170

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 45 45 45 45

Discrete Variable Valve Lift (DVVL) on OHV DVVLO 142 142 142 0 - 56

Conversion to DOHC with DCP CDOHC 276 276 276 436

Stoichiometric Gasoline Direct Injection (GDI) SGDI 251 251 251 326

Combustion Restart CBRST 118 118 118 118

Turbocharging and Downsizing TRBDS 644 644 644 512

Exhaust Gas Recirculation (EGR) Boost EGRB 144 144 144 144

Conversion to Diesel following CBRST

DSLC n.a. n.a. n.a.

1,572 -

1,627

Conversion to Diesel following TRBDS

DSLT n.a. n.a. n.a. 916 - 971

6-Speed Manual/Improved Internals 6MAN 250 250 250 250

Improved Auto. Trans. Controls/Externals IATC 60 60 60 60

Continuously Variable Transmission CVT 250 250 250 250

6/7/8-Speed Auto. Trans with Improved Internals NAUTO 170 170 170 170

Dual Clutch or Automated Manual Transmission DCTAM 73 73 158 158

Electric Power Steering EPS 106 106 106 106

Improved Accessories IACC 128 128 128 128

12V Micro-Hybrid MHEV 288 311 342 367

Belt mounted Integrated Starter Generator BISG 286 286 286 286

Crank mounted Integrated Starter Generator CISG 2,791 3,107 3,319 3,547

Power Split Hybrid PSHEV 1,600 2,133 2,742 3,261

2-Mode Hybrid 2MHEV n.a. n.a. n.a. n.a.

Plug-in Hybrid

PHEV

11,520 -

11,527

14,135 -

14,142

16,136 -

16,215 n.a.

Mass Reduction (1.5%) MS1 1.51 1.51 1.51 1.51

Mass Reduction (3.5 to 8.5%) MS2 1.51 1.51 1.51 1.51

Low Rolling Resistance Tires ROLL 6 6 6 6

Low Drag Brakes LDB n.a. n.a. n.a. 63

Secondary Axle Disconnect SAX 87 87 87 87
3-87 

Aero Drag Reduction AERO 48 48 48 48

Perform. Perform. Perform. Perform.

Subcomp. Compact Midsize Large

Car Car Car Car

Inline 4 V6 V6 V8

Low Friction Lubricants LUB 3 3 3 3

Engine Friction Reduction EFR 13 13 13 13

VVT - Coupled Cam Phasing (CCP) on SOHC CCPS 45 45 45 45

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 142 103 103 147

Cylinder Deactivation on SOHC DEACS n.a. 0 - 56 0 - 56 0 - 56

VVT - Intake Cam Phasing (ICP) ICP 45 45 45 45

VVT - Dual Cam Phasing (DCP) DCP 38 41 41 41

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 142 103 103 147

Continuously Variable Valve Lift (CVVL) CVVL 277 254 254 277

Cylinder Deactivation on DOHC DEACD n.a. 0 - 56 0 - 56 0 - 56

Cylinder Deactivation on OHV DEACO n.a. 28 28 24

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 45 23 23 23

Discrete Variable Valve Lift (DVVL) on OHV DVVLO 142 0 - 28 0 - 28 0 - 28

Conversion to DOHC with DCP CDOHC 276 218 218 276

Stoichiometric Gasoline Direct Injection (GDI) SGDI 63 54 54 44

Combustion Restart CBRST 118 118 118 118

Turbocharging and Downsizing TRBDS 644 512 512 1,098

Exhaust Gas Recirculation (EGR) Boost EGRB 144 144 144 144

Conversion to Diesel following CBRST

DSLC n.a.

1,792 - 

1,847

1,792 - 

1,847

2,675 - 

2,731

Conversion to Diesel following TRBDS

DSLT n.a.

1,135 - 

1,191

1,135 - 

1,191

1,434 - 

1,489

6-Speed Manual/Improved Internals 6MAN 250 250 250 250

Improved Auto. Trans. Controls/Externals IATC 60 60 60 60

Continuously Variable Transmission CVT 250 250 250 250

6/7/8-Speed Auto. Trans with Improved Internals NAUTO 170 - 272 170 - 272 170 - 272 170 - 272

Dual Clutch or Automated Manual Transmission DCTAM 73 158 158 158

Electric Power Steering EPS 106 106 106 106

Improved Accessories IACC 128 128 128 128

12V Micro-Hybrid MHEV 314 337 372 410

Belt mounted Integrated Starter Generator BISG 286 286 286 286

Crank mounted Integrated Starter Generator CISG 2,839 3,149 3,335 3,571

Power Split Hybrid PSHEV 3,661 4,018 5,287 6,723

2-Mode Hybrid 2MHEV n.a. n.a. n.a. n.a.

Plug-in Hybrid PHEV 14,987 16,792 19,265 n.a.

Material Substitution (1.5%) MS1 1 1 1 1

Material Substitution (3.5 to 8.5%) MS2 1 1 1 1

Low Rolling Resistance Tires ROLL n.a. n.a. n.a. n.a.

Low Drag Brakes LDB n.a. n.a. n.a. 63

Secondary Axle Disconnect SAX 87 87 87 87

Aero Drag Reduction AERO n.a. n.a. n.a. n.a.

VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE ($) BY VEHICLE 

TECHNICAL CLASS - PERFORMANCE PASSENGER CARS

Nominal Baseline Engine (For Cost Basis)
Draft Joint Technical Support Document 

3-88 

Table 3-213-21. Technology Incremental Cost Estimates for VolpeOLPE model, Performance 

Passenger carsLight Trucks

VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE (2007$) BY VEHICLE 

SUBCLASS - PERFORMANCE PASSENGER CARS

Perform. Perform. Perform. Perform.

Subcomp. Compact Midsize Large

Car Car Car Car

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8

Low Friction Lubricants LUB 3 3 3 3

Engine Friction Reduction EFR 50 75 75 101

VVT - Coupled Cam Phasing (CCP) on SOHC CCPS 45 90 90 90

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 142 205 205 293

Cylinder Deactivation on SOHC DEACS n.a. 0 - 56 0 - 56 0 - 56

VVT - Intake Cam Phasing (ICP) ICP 45 90 90 90

VVT - Dual Cam Phasing (DCP) DCP 38 83 83 82

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 142 205 205 293

Continuously Variable Valve Lift (CVVL) CVVL 277 509 509 555

Cylinder Deactivation on DOHC DEACD n.a. 0 - 56 0 - 56 0 - 56

Cylinder Deactivation on OHV DEACO n.a. 170 170 190

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 45 45 45 45

Discrete Variable Valve Lift (DVVL) on OHV DVVLO 142 0 - 56 0 - 56 0 - 56

Conversion to DOHC with DCP CDOHC 276 436 436 552

Stoichiometric Gasoline Direct Injection (GDI) SGDI 251 326 326 353

Combustion Restart CBRST 118 118 118 118

Turbocharging and Downsizing TRBDS 644 512 512 1,098

Exhaust Gas Recirculation (EGR) Boost EGRB 144 144 144 144

Conversion to Diesel following CBRST

DSLC n.a.

1,572 -

1,627

1,572 -

1,627

2,331 -

2,377

Conversion to Diesel following TRBDS

DSLT n.a. 916 - 971 916 - 971

1,090 -

1,145

6-Speed Manual/Improved Internals 6MAN 250 250 250 250

Improved Auto. Trans. Controls/Externals IATC 60 60 60 60

Continuously Variable Transmission CVT 250 250 250 250

6/7/8-Speed Auto. Trans with Improved Internals NAUTO 170 - 272 170 - 272 170 - 272 170 - 272

Dual Clutch or Automated Manual Transmission DCTAM 73 158 158 158

Electric Power Steering EPS 106 106 106 106

Improved Accessories IACC 128 128 128 128

12V Micro-Hybrid MHEV 314 372 372 410

Belt mounted Integrated Starter Generator BISG 286 286 286 286

Crank mounted Integrated Starter Generator CISG 2,839 3,335 3,149 3,571

Power Split Hybrid

PSHEV 3,661

5,106 -

5,287

3,838 -

4,018

6,543 -

6723

2-Mode Hybrid 2MHEV n.a. n.a. n.a. n.a.

Plug-in Hybrid

PHEV

14,891 -

14,993

19,085 -

19,265

16,612 -

16,714 n.a.
3-89 

Mass Reduction (1.5%) MS1 1.51 1.51 1.51 1.51

Mass Reduction (3.5 to 8.5%) MS2 1.51 1.51 1.51 1.51

Low Rolling Resistance Tires ROLL n.a. n.a. n.a. n.a.

Low Drag Brakes LDB n.a. n.a. n.a. 63

Secondary Axle Disconnect SAX 87 87 87 87

Aero Drag Reduction AERO n.a. n.a. n.a. n.a.
Draft Joint Technical Support Document 

3-90 

Small Midsize Large

LT LT LT LT

V6 Inline 4 V6 V8

Low Friction Lubricants LUB 3 3 3 3

Engine Friction Reduction EFR 13 13 13 13

VVT - Coupled Cam Phasing (CCP) on SOHC CCPS 45 45 45 45

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 103 142 103 147

Cylinder Deactivation on SOHC DEACS 0 - 56 n.a. 0 - 56 0 - 56

VVT - Intake Cam Phasing (ICP) ICP 45 45 45 45

VVT - Dual Cam Phasing (DCP) DCP 41 38 41 41

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 103 142 103 147

Continuously Variable Valve Lift (CVVL) CVVL 254 277 254 277

Cylinder Deactivation on DOHC DEACD 0 - 56 n.a. 0 - 56 0 - 56

Cylinder Deactivation on OHV DEACO 28 n.a. 28 24

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 23 45 23 23

Discrete Variable Valve Lift (DVVL) on OHV DVVLO 0 - 28 142 0 - 28 0 - 28

Conversion to DOHC with DCP CDOHC 218 276 218 276

Stoichiometric Gasoline Direct Injection (GDI) SGDI 54 63 54 44

Combustion Restart CBRST 118 118 118 118

Turbocharging and Downsizing TRBDS 512 644 512 1,098

Exhaust Gas Recirculation (EGR) Boost EGRB 144 144 144 144

Conversion to Diesel following CBRST

DSLC

1,792 - 

1,847 n.a.

1,792 - 

1,847

2,675 - 

2,731

Conversion to Diesel following TRBDS

DSLT

1,135 - 

1,191 n.a.

1,135 - 

1,191

1,434 - 

1,489

6-Speed Manual/Improved Internals 6MAN 250 250 250 250

Improved Auto. Trans. Controls/Externals IATC 60 60 60 60

Continuously Variable Transmission CVT 250 250 250 250

6/7/8-Speed Auto. Trans with Improved Internals NAUTO 170 170 170 - 272 170 - 272

Dual Clutch or Automated Manual Transmission DCTAM 158 73 158 158

Electric Power Steering EPS 106 106 106 106

Improved Accessories IACC 128 128 128 n.a.

12V Micro-Hybrid MHEV 367 325 376 n.a.

Belt mounted Integrated Starter Generator BISG 286 286 286 n.a.

Crank mounted Integrated Starter Generator CISG 3,547 3,141 3,611 4,386

Power Split Hybrid

PSHEV 3,261 2,377

3,462 - 

3,897 n.a.

2-Mode Hybrid

2MHEV n.a. 3,521

4,764 - 

5,098

5,678 - 

5,779

Plug-in Hybrid PHEV 18,648 14,662 n.a. n.a.

Material Substitution (1.5%) MS1 1 1 1 1

Material Substitution (3.5 to 8.5%) MS2 1 1 1 1

Low Rolling Resistance Tires ROLL 6 6 6 6

Low Drag Brakes LDB 63 n.a. 63 63

Secondary Axle Disconnect SAX 87 87 87 87

Aero Drag Reduction AERO 48 48 48 48

VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE ($) BY VEHICLE 

TECHNICAL CLASS - LIGHT TRUCKS

Nominal Baseline Engine (For Cost Basis)

The tables representing the Volpe model input files for incremental technology 

effectiveness values by vehicle subclass are presented below. The tables have been 
3-91 

divided into passenger cars, performance passenger cars, and light trucks to make them

easier to read.

Table 3-223-22 . Technology Incremental Cost Estimates for VolpeOLPE model, Light 

TrucksTechnology Incremental Effectiveness Estimates for VOLPE model, Passenger Cars

VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE (2007$) BY VEHICLE 

SUBCLASS - LIGHT TRUCKS

Minivan Small Midsize Large

LT LT LT LT

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8

Low Friction Lubricants LUB 3 3 3 3

Engine Friction Reduction EFR 75 50 75 101

VVT - Coupled Cam Phasing (CCP) on SOHC CCPS 90 45 90 90

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 205 142 205 293

Cylinder Deactivation on SOHC DEACS 0 - 56 n.a. 0 - 56 0 - 56

VVT - Intake Cam Phasing (ICP) ICP 90 45 90 90

VVT - Dual Cam Phasing (DCP) DCP 83 38 83 83

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 205 142 205 293

Continuously Variable Valve Lift (CVVL) CVVL 509 277 509 555

Cylinder Deactivation on DOHC DEACD 0 - 56 n.a. 0 - 56 0 - 56

Cylinder Deactivation on OHV DEACO 170 n.a. 170 190

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 45 45 45 45

Discrete Variable Valve Lift (DVVL) on OHV DVVLO 0 - 56 142 0 - 56 0 - 56

Conversion to DOHC with DCP CDOHC 436 276 436 552

Stoichiometric Gasoline Direct Injection (GDI) SGDI 326 251 326 353

Combustion Restart CBRST 118 118 118 118

Turbocharging and Downsizing TRBDS 512 644 512 1,098

Exhaust Gas Recirculation (EGR) Boost EGRB 144 144 144 144

Conversion to Diesel following CBRST

DSLC

1,572 -

1,627 n.a.

1,572 -

1,627

2,331 -

2,387

Conversion to Diesel following TRBDS

DSLT 916 - 971 n.a. 916 - 971

1,090 -

1,145

6-Speed Manual/Improved Internals 6MAN 250 250 250 250

Improved Auto. Trans. Controls/Externals IATC 60 60 60 60

Continuously Variable Transmission CVT 250 250 250 250

6/7/8-Speed Auto. Trans with Improved Internals NAUTO 170 170 170 - 272 170 - 272

Dual Clutch or Automated Manual Transmission DCTAM 158 73 158 158

Electric Power Steering EPS 106 106 106 106

Improved Accessories IACC 128 128 128 n.a.

12V Micro-Hybrid MHEV 367 325 376 n.a.

Belt mounted Integrated Starter Generator BISG 286 286 286 n.a.

Crank mounted Integrated Starter Generator CISG 3,547 3,141 3,611 5,124

Power Split Hybrid

PSHEV 3,261

2,377 -

2,384

3,282 -

3,462 n.a.
Draft Joint Technical Support Document 

3-92 

2-Mode Hybrid

2MHEV n.a. 3,521

4,663 -

4,764

5,678 -

5,779

Plug-in Hybrid PHEV n.a. 14,589 n.a. n.a.

Mass Reduction (1.5%) MS1 1.51 1.51 1.51 1.51

Mass Reduction (3.5 to 8.5%) MS2 1.51 1.51 1.51 1.51

Low Rolling Resistance Tires ROLL 6 6 6 6

Low Drag Brakes LDB 63 n.a. 63 63

Secondary Axle Disconnect SAX 87 87 87 87

Aero Drag Reduction AERO 48 48 48 48

Subcompact Compact Midsize Large

Car Car Car Car

Inline 4 Inline 4 Inline 4 V6

Low Friction Lubricants LUB 0.5 0.5 0.5 0.5

Engine Friction Reduction EFR 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Coupled Cam Phasing (CCP) on SOHC CCPS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Cylinder Deactivation on SOHC DEACS n.a. n.a. n.a. 2.5 - 3.0

VVT - Intake Cam Phasing (ICP) ICP 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Dual Cam Phasing (DCP) DCP 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Continuously Variable Valve Lift (CVVL) CVVL 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5

Cylinder Deactivation on DOHC DEACD n.a. n.a. n.a. 0 - 0.5

Cylinder Deactivation on OHV DEACO n.a. n.a. n.a. 3.9 - 5.5

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Discrete Variable Valve Lift (DVVL) on OHV DVVLO 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5

Conversion to DOHC with DCP CDOHC 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5

Stoichiometric Gasoline Direct Injection (GDI) SGDI 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Combustion Restart CBRST 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5

Turbocharging and Downsizing TRBDS 4.2 - 4.8 4.2 - 4.8 4.2 - 4.8 1.8 - 1.9

Exhaust Gas Recirculation (EGR) Boost EGRB 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0

Conversion to Diesel following CBRST DSLC n.a. n.a. n.a. 10.8 - 11.7

Conversion to Diesel following TRBDS DSLT n.a. n.a. n.a. 5.3 - 6.9

6-Speed Manual/Improved Internals 6MAN 0.5 0.5 0.5 0.5

Improved Auto. Trans. Controls/Externals IATC 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5

Continuously Variable Transmission CVT 0.7 - 2.0 0.7 - 2.0 0.7 - 2.0 0.7 - 2.0

6/7/8-Speed Auto. Trans with Improved Internals NAUTO 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4

Dual Clutch or Automated Manual Transmission DCTAM 5.5 - 7.5 5.5 - 7.5 2.7 - 4.1 2.7 - 4.1

Electric Power Steering EPS 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Improved Accessories IACC 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

12V Micro-Hybrid MHEV 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.5 - 3.5

Belt mounted Integrated Starter Generator BISG 4.0 - 6.0 4.0 - 6.0 4.0 - 6.0 3.5 - 5.5

Crank mounted Integrated Starter Generator CISG 8.6 - 8.9 8.6 - 8.9 8.6 - 8.9 8.6 - 8.9

Power Split Hybrid PSHEV 6.3 - 12.4 6.3 - 12.4 6.3 - 12.4 6.3 - 12.4

2-Mode Hybrid 2MHEV n.a. n.a. n.a. n.a.

Plug-in Hybrid PHEV 45.2 - 47.7 45.2 - 47.7 45.2 - 47.7 n.a.

Material Substitution (1.5%) MS1 1.0 1.0 1.0 1.0

Material Substitution (3.5 to 8.5%) MS2 2.3 2.3 3.9 5.6

Low Rolling Resistance Tires ROLL 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Low Drag Brakes LDB n.a. n.a. 0.5 - 1.0 0.5 - 1.0

Secondary Axle Disconnect SAX 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Aero Drag Reduction AERO 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

VEHICLE TECHNOLOGY INCREMENTAL FUEL CONSUMPTION REDUCTION (-%) 

BY VEHICLE TECHNOLOGY CLASS - PASSANGER CAR

Nominal Baseline Engine (For Cost Basis)
3-93 

Table 3-233-23. Technology Incremental Effectiveness Estimates for VolpeOLPE

model, Passenger CarsComponent Technology Incremental Effectiveness Estimates

for VOLPE model, Performance Cars

VEHICLE TECHNOLOGY INCREMENTAL FUEL CONSUMPTION REDUCTION 

(-%) BY VEHICLE SUBCLASS - PASSEANGER CAR

Subcompact Compact Midsize Large

Car Car Car Car

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4

Inline 

4 V6

Low Friction Lubricants LUB 0.5 0.5 0.5 0.5

Engine Friction Reduction EFR 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Coupled Cam Phasing (CCP) on 

SOHC CCPS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Discrete Variable Valve Lift (DVVL) on 

SOHC DVVLS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Cylinder Deactivation on SOHC DEACS n.a. n.a. n.a. 2.5 - 3.0

VVT - Intake Cam Phasing (ICP) ICP 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Dual Cam Phasing (DCP) DCP 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Discrete Variable Valve Lift (DVVL) on 

DOHC DVVLD 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Continuously Variable Valve Lift (CVVL) CVVL 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5

Cylinder Deactivation on DOHC DEACD n.a. n.a. n.a. 0 - 0.5

Cylinder Deactivation on OHV DEACO n.a. n.a. n.a. 3.9 - 5.5

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Discrete Variable Valve Lift (DVVL) on 

OHV DVVLO 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5

Conversion to DOHC with DCP CDOHC 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5

Stoichiometric Gasoline Direct Injection 

(GDI) SGDI 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Combustion Restart CBRST 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5

Turbocharging and Downsizing TRBDS 4.2 - 4.8 4.2 - 4.8 4.2 - 4.8 1.8 - 1.9

Exhaust Gas Recirculation (EGR) Boost EGRB 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0

Conversion to Diesel following CBRST

DSLC n.a. n.a. n.a.

10.8 -

11.7

Conversion to Diesel following TRBDS DSLT n.a. n.a. n.a. 5.3 - 6.9

6-Speed Manual/Improved Internals 6MAN 0.5 0.5 0.5 0.5

Improved Auto. Trans. Controls/Externals IATC 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5

Continuously Variable Transmission CVT 0.7 - 2.0 0.7 - 2.0 0.7 - 2.0 0.7 - 2.0

6/7/8-Speed Auto. Trans with Improved 

Internals NAUTO 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4

Dual Clutch or Automated Manual 

Transmission DCTAM 2.7 - 4.1 2.7 - 4.1 2.7 - 4.1 2.7 - 4.1

Electric Power Steering EPS 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Improved Accessories IACC 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

12V Micro-Hybrid MHEV 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.5 - 3.5

Belt mounted Integrated Starter Generator BISG 4.0 - 6.0 4.0 - 6.0 4.0 - 6.0 3.5 - 5.5

Crank mounted Integrated Starter Generator CISG 8.6 - 8.9 8.6 - 8.9 8.6 - 8.9 8.7 - 8.9

Power Split Hybrid

PSHEV 6.3 - 12.4 6.3 - 12.4

6.3 -

12.4

6.3 -

12.4
Draft Joint Technical Support Document 

3-94 

2-Mode Hybrid 2MHEV n.a. n.a. n.a. n.a.

Plug-in Hybrid

PHEV 45.2 - 47.7

45.2 -

47.7

45.2 -

47.7 n.a.

Mass Reduction (1.5%) MS1 1.0 1.0 1.0 1.0

Mass Reduction (3.5 to 8.5%) MS2 2.3 2.3 3.9 5.6

Low Rolling Resistance Tires ROLL 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Low Drag Brakes LDB n.a. n.a. n.a. 0.5 - 1.0

Secondary Axle Disconnect SAX 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Aero Drag Reduction AERO 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Perform. Perform. Perform. Perform.

Subcomp. Compact Midsize Large

Car Car Car Car

Inline 4 V6 V6 V8

Low Friction Lubricants LUB 0.5 0.5 0.5 0.5

Engine Friction Reduction EFR 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Coupled Cam Phasing (CCP) on SOHC CCPS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Cylinder Deactivation on SOHC DEACS n.a. 2.5 - 3.0 2.5 - 3.0 2.5 - 3.0

VVT - Intake Cam Phasing (ICP) ICP 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Dual Cam Phasing (DCP) DCP 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Continuously Variable Valve Lift (CVVL) CVVL 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5

Cylinder Deactivation on DOHC DEACD n.a. 0.0 - 0.5 0.0 - 0.5 0.0 - 0.5

Cylinder Deactivation on OHV DEACO n.a. 3.9 - 5.5 3.9 - 5.5 3.9 - 5.5

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Discrete Variable Valve Lift (DVVL) on OHV DVVLO 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5

Conversion to DOHC with DCP CDOHC 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5

Stoichiometric Gasoline Direct Injection (GDI) SGDI 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Combustion Restart CBRST 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5

Turbocharging and Downsizing TRBDS 4.2 - 4.8 1.8 - 1.9 1.8 - 1.9 1.8 - 1.9

Exhaust Gas Recirculation (EGR) Boost EGRB 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0

Conversion to Diesel following CBRST DSLC n.a. 10.8 - 11.7 10.8 - 11.7 10.8 - 11.7

Conversion to Diesel following TRBDS DSLT n.a. 5.3 - 6.9 5.3 - 6.9 5.3 - 6.9

6-Speed Manual/Improved Internals 6MAN 0.5 0.5 0.5 0.5

Improved Auto. Trans. Controls/Externals IATC 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5

Continuously Variable Transmission CVT 0.7 - 2.0 0.7 - 2.0 0.7 - 2.0 n.a.

6/7/8-Speed Auto. Trans with Improved Internals NAUTO 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4

Dual Clutch or Automated Manual Transmission DCTAM 5.5 - 7.5 2.7 - 4.1 2.7 - 4.1 2.7 - 4.1

Electric Power Steering EPS 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Improved Accessories IACC 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

12V Micro-Hybrid MHEV 2.0 - 3.0 2.5 - 3.5 2.5 - 3.5 3.0 - 4.0

Belt mounted Integrated Starter Generator BISG 4.0 - 6.0 3.5 - 5.5 3.5 - 5.5 3.5 - 5.5

Crank mounted Integrated Starter Generator CISG 8.6 - 8.9 8.7 - 8.9 8.7 - 8.9 8.6 - 8.9

Power Split Hybrid PSHEV 6.3 - 12.4 6.3 - 12.4 6.3 - 12.4 6.3 - 12.4

2-Mode Hybrid 2MHEV n.a. n.a. n.a. n.a.

Plug-in Hybrid PHEV 45.2 - 47.7 45.2 - 47.7 45.2 - 47.7 n.a.

Material Substitution (1.5%) MS1 1.0 1.0 1.0 1.0

Material Substitution (3.5 to 8.5%) MS2 2.3 2.3 3.9 5.6

Low Rolling Resistance Tires ROLL n.a. n.a. n.a. n.a.

Low Drag Brakes LDB n.a. n.a. n.a. 0.5 - 1.0

Secondary Axle Disconnect SAX 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Aero Drag Reduction AERO n.a. n.a. n.a. n.a.

Nominal Baseline Engine (For Cost Basis)

VEHICLE TECHNOLOGY INCREMENTAL FUEL CONSUMPTION REDUCTION (-%) BY 

VEHICLE TECHNOLOGY CLASS - PERFORMANCE PASSANGER CAR
3-95 

Table 3-243-24. Component Technology Incremental Effectiveness Estimates for 

VolpeOLPE model, Performance CarsComponent Technology Incremental Effectiveness 

Estimates for VOLPE model, Light Trucks

VEHICLE TECHNOLOGY INCREMENTAL FUEL CONSUMPTION REDUCTION 

(-%) BY VEHICLE SUBCLASS - PASSANGER CAR

Subcompact Compact Midsize Large

Car Car Car Car

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 

4

V6

Low Friction Lubricants LUB 0.5 0.5 0.5 0.5

Engine Friction Reduction EFR 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Coupled Cam Phasing (CCP) on 

SOHC

CCPS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Discrete Variable Valve Lift (DVVL) on 

SOHC

DVVLS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Cylinder Deactivation on SOHC DEACS n.a. n.a. n.a. 2.5 - 3.0

VVT - Intake Cam Phasing (ICP) ICP 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Dual Cam Phasing (DCP) DCP 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Discrete Variable Valve Lift (DVVL) on 

DOHC

DVVLD 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Continuously Variable Valve Lift (CVVL) CVVL 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5

Cylinder Deactivation on DOHC DEACD n.a. n.a. n.a. 0 - 0.5

Cylinder Deactivation on OHV DEACO n.a. n.a. n.a. 3.9 - 5.5

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Discrete Variable Valve Lift (DVVL) on 

OHV

DVVLO 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5

Conversion to DOHC with DCP CDOHC 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5

Stoichiometric Gasoline Direct Injection 

(GDI)

SGDI 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Combustion Restart CBRST 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5

Turbocharging and Downsizing TRBDS 4.2 - 4.8 4.2 - 4.8 4.2 - 4.8 1.8 - 1.9

Exhaust Gas Recirculation (EGR) Boost EGRB 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0

Conversion to Diesel following CBRST DSLC n.a. n.a. n.a. 10.8 -

11.7

Conversion to Diesel following TRBDS DSLT n.a. n.a. n.a. 5.3 - 6.9

6-Speed Manual/Improved Internals 6MAN 0.5 0.5 0.5 0.5

Improved Auto. Trans. Controls/Externals IATC 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5

Continuously Variable Transmission CVT 0.7 - 2.0 0.7 - 2.0 0.7 - 2.0 0.7 - 2.0

6/7/8-Speed Auto. Trans with Improved 

Internals

NAUTO 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4

Dual Clutch or Automated Manual 

Transmission

DCTAM 2.7 - 4.1 2.7 - 4.1 2.7 - 4.1 2.7 - 4.1

Electric Power Steering EPS 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Improved Accessories IACC 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

12V Micro-Hybrid MHEV 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.5 - 3.5

Formatted Table
Draft Joint Technical Support Document 

3-96 

Belt mounted Integrated Starter Generator BISG 4.0 - 6.0 4.0 - 6.0 4.0 - 6.0 3.5 - 5.5

Crank mounted Integrated Starter Generator CISG 8.6 - 8.9 8.6 - 8.9 8.6 - 8.9 8.7 - 8.9

Power Split Hybrid PSHEV 6.3 - 12.4 6.3 - 12.4 6.3 -

12.4

6.3 -

12.4

2-Mode Hybrid 2MHEV n.a. n.a. n.a. n.a.

Plug-in Hybrid PHEV 45.2 - 47.7 45.2 -

47.7

45.2 -

47.7

n.a.

Mass Reduction (1.5%) MS1 1.0 1.0 1.0 1.0

Mass Reduction (3.5 to 8.5%) MS2 2.3 2.3 3.9 5.6

Low Rolling Resistance Tires ROLL 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Low Drag Brakes LDB n.a. n.a. n.a. 0.5 - 1.0

Secondary Axle Disconnect SAX 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Aero Drag Reduction AERO 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

VEHICLE TECHNOLOGY INCREMENTAL FUEL CONSUMPTION REDUCTION 

(-%) BY VEHICLE SUBCLASS - PERFORMANCE PASSENGER CAR

Perform. Perform. Perform. Perform.

Subcomp. Compact Midsize Large

Car Car Car Car

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8

Low Friction Lubricants LUB 0.5 0.5 0.5 0.5

Engine Friction Reduction EFR 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Coupled Cam Phasing (CCP) on 

SOHC CCPS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Discrete Variable Valve Lift (DVVL) on 

SOHC DVVLS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Cylinder Deactivation on SOHC DEACS n.a. 2.5 - 3.0 2.5 - 3.0 2.5 - 3.0

VVT - Intake Cam Phasing (ICP) ICP 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Dual Cam Phasing (DCP) DCP 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Discrete Variable Valve Lift (DVVL) on 

DOHC DVVLD 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Continuously Variable Valve Lift (CVVL) CVVL 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5

Cylinder Deactivation on DOHC DEACD n.a. 0.0 - 0.5 0.0 - 0.5 0.0 - 0.5

Cylinder Deactivation on OHV DEACO n.a. 3.9 - 5.5 3.9 - 5.5 3.9 - 5.5

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Discrete Variable Valve Lift (DVVL) on 

OHV DVVLO 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5

Conversion to DOHC with DCP CDOHC 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5

Stoichiometric Gasoline Direct Injection 

(GDI) SGDI 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Combustion Restart CBRST 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5

Turbocharging and Downsizing TRBDS 4.2 - 4.8 1.8 - 1.9 1.8 - 1.9 1.8 - 1.9

Exhaust Gas Recirculation (EGR) Boost EGRB 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0

Conversion to Diesel following CBRST

DSLC n.a.

10.8 -

11.7

10.8 -

11.7

10.8 -

11.7

Conversion to Diesel following TRBDS DSLT n.a. 5.3 - 6.9 5.3 - 6.9 5.3 - 6.9

6-Speed Manual/Improved Internals 6MAN 0.5 0.5 0.5 0.5

Improved Auto. Trans. Controls/Externals IATC 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5

Continuously Variable Transmission CVT 0.7 - 2.0 0.7 - 2.0 0.7 - 2.0 n.a.

6/7/8-Speed Auto. Trans with Improved 

Internals NAUTO 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4
3-97 

Dual Clutch or Automated Manual 

Transmission DCTAM 2.7 - 4.1 2.7 - 4.1 2.7 - 4.1 2.7 - 4.1

Electric Power Steering EPS 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Improved Accessories IACC 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

12V Micro-Hybrid MHEV 2.0 - 3.0 2.5 - 3.5 2.5 - 3.5 3.0 - 4.0

Belt mounted Integrated Starter Generator BISG 4.0 - 6.0 3.5 - 5.5 3.5 - 5.5 3.0 - 5.0

Crank mounted Integrated Starter Generator CISG 8.6 - 8.9 8.7 - 8.9 8.7 - 8.9 8.7 - 8.9

Power Split Hybrid

PSHEV 6.3 - 12.4

6.3 -

12.4

6.3 -

12.4

6.3 -

12.4

2-Mode Hybrid 2MHEV n.a. n.a. n.a. n.a.

Plug-in Hybrid

PHEV

45.2 -

47.7

45.2 -

47.7

45.2 -

47.7 n.a.

Mass Reduction (1.5%) MS1 1.0 1.0 1.0 1.0

Mass Reduction (3.5 to 8.5%) MS2 2.3 2.3 3.9 5.6

Low Rolling Resistance Tires ROLL n.a. n.a. n.a. n.a.

Low Drag Brakes

LDB n.a. n.a. n.a.

0.5 -

1.0

Secondary Axle Disconnect SAX 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Aero Drag Reduction AERO n.a. n.a. n.a. n.a.
Draft Joint Technical Support Document 

3-98 

Minivan Small Midsize Large

LT LT LT LT

V6 Inline 4 V6 V8

Low Friction Lubricants LUB 0.5 0.5 0.5 0.5

Engine Friction Reduction EFR 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Coupled Cam Phasing (CCP) on SOHC CCPS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Cylinder Deactivation on SOHC DEACS 2.5 - 3.0 n.a. 2.5 - 3.0 2.5 - 3.0

VVT - Intake Cam Phasing (ICP) ICP 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Dual Cam Phasing (DCP) DCP 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Continuously Variable Valve Lift (CVVL) CVVL 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5

Cylinder Deactivation on DOHC DEACD 0.0 - 0.5 n.a. 0.0 - 0.5 0.0 - 0.5

Cylinder Deactivation on OHV DEACO 3.9 - 5.5 n.a. 3.9 - 5.5 3.9 - 5.5

VVT - Coupled Cam Phasing (CCP) on OHV CCPO 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Discrete Variable Valve Lift (DVVL) on OHV DVVLO 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5

Conversion to DOHC with DCP CDOHC 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5

Stoichiometric Gasoline Direct Injection (GDI) SGDI 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Combustion Restart CBRST 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5

Turbocharging and Downsizing TRBDS 1.8 - 1.9 4.2 - 4.8 1.8 - 1.9 1.8 - 1.9

Exhaust Gas Recirculation (EGR) Boost EGRB 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0

Conversion to Diesel following CBRST DSLC 10.8 - 11.7 n.a. 10.8 - 11.7 10.8 - 11.7

Conversion to Diesel following TRBDS DSLT 5.3 - 6.9 n.a. 5.3 - 6.9 5.3 - 6.9

6-Speed Manual/Improved Internals 6MAN 0.5 0.5 0.5 0.5

Improved Auto. Trans. Controls/Externals IATC 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5

Continuously Variable Transmission CVT 0.7 - 2.0 0.7 - 2.0 n.a. n.a.

6/7/8-Speed Auto. Trans with Improved Internals NAUTO 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4

Dual Clutch or Automated Manual Transmission DCTAM 2.7 - 4.1 5.5 - 7.5 2.7 - 4.1 2.7 - 4.1

Electric Power Steering EPS 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Improved Accessories IACC 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 n.a.

12V Micro-Hybrid MHEV 2.5 - 3.5 2.0 - 3.0 2.5 - 3.5 n.a.

Belt mounted Integrated Starter Generator BISG 3.5 - 5.5 4.0 - 6.0 3.5 - 5.5 n.a.

Crank mounted Integrated Starter Generator CISG 8.7 - 8.9 8.6 - 8.9 8.7 - 8.9 8.7 - 8.9

Power Split Hybrid PSHEV 6.3 - 12.4 6.3 - 12.4 6.3 - 12.4 n.a.

2-Mode Hybrid 2MHEV n.a. 0.1 - 3.9 3.0 - 7.2 3.0 - 7.3

Plug-in Hybrid PHEV 45.2 - 47.7 45.2 - 47.7 n.a. n.a.

Material Substitution (1.5%) MS1 1.0 1.0 1.0 1.0

Material Substitution (3.5 to 8.5%) MS2 3.9 3.9 3.9 5.6

Low Rolling Resistance Tires ROLL 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Low Drag Brakes LDB 0.5 - 1.0 n.a. 0.5 - 1.0 0.5 - 1.0

Secondary Axle Disconnect SAX 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Aero Drag Reduction AERO 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

VEHICLE TECHNOLOGY INCREMENTAL FUEL CONSUMPTION REDUCTION (-%) 

BY VEHICLE TECHNOLOGY CLASS - LIGHT TRUCKS

Nominal Baseline Engine (For Cost Basis)

Table 3-25. Component Technology Incremental Effectiveness Estimates for VolpeOLPE model, 

Light Trucks

VEHICLE TECHNOLOGY INCREMENTAL FUEL CONSUMPTION 

REDUCTION (-%) BY VEHICLE SUBCLASS - LIGHT TRUCKS

Minivan Small Midsize Large

LT LT LT LT

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8

Low Friction Lubricants LUB 0.5 0.5 0.5 0.5

Formatted Table
3-99 

Engine Friction Reduction EFR 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Coupled Cam Phasing (CCP) on 

SOHC

CCPS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Discrete Variable Valve Lift (DVVL) on 

SOHC

DVVLS 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Cylinder Deactivation on SOHC DEACS 2.5 - 3.0 n.a. 2.5 - 3.0 2.5 - 3.0

VVT - Intake Cam Phasing (ICP) ICP 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

VVT - Dual Cam Phasing (DCP) DCP 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Discrete Variable Valve Lift (DVVL) on 

DOHC

DVVLD 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0 1.0 - 3.0

Continuously Variable Valve Lift (CVVL) CVVL 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5 1.5 - 3.5

Cylinder Deactivation on DOHC DEACD 0 - 0.5 n.a. 0.0 - 0.5 0.0 - 0.5

Cylinder Deactivation on OHV DEACO 3.9 - 5.5 n.a. 3.9 - 5.5 3.9 - 5.5

VVT - Coupled Cam Phasing (CCP) on 

OHV

CCPO 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Discrete Variable Valve Lift (DVVL) on 

OHV

DVVLO 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5 0.5 - 2.5

Conversion to DOHC with DCP CDOHC 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5 1.0 - 2.5

Stoichiometric Gasoline Direct Injection 

(GDI)

SGDI 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0

Combustion Restart CBRST 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5 2.0 - 2.5

Turbocharging and Downsizing TRBDS 1.8 - 1.9 4.2 - 4.8 1.8 - 1.9 1.8 - 1.9

Exhaust Gas Recirculation (EGR) Boost EGRB 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0 3.5 - 4.0

Conversion to Diesel following CBRST DSLC 10.8 -

11.7

n.a. 10.8 -

11.7

10.8 -

11.7

Conversion to Diesel following TRBDS DSLT 5.3 - 6.9 n.a. 5.3 - 6.9 5.3 - 6.9

6-Speed Manual/Improved Internals 6MAN 0.5 0.5 0.5 0.5

Improved Auto. Trans. Controls/Externals IATC 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5 1.5 - 2.5

Continuously Variable Transmission CVT 0.7 - 2.0 0.7 - 2.0 0.7 - 2.0 n.a.

6/7/8-Speed Auto. Trans with Improved 

Internals

NAUTO 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4 1.4 - 3.4

Dual Clutch or Automated Manual 

Transmission

DCTAM 2.7 - 4.1 2.7 -4.1 2.7 - 4.1 2.7 - 4.1

Electric Power Steering EPS 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Improved Accessories IACC 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 n.a.

12V Micro-Hybrid MHEV 2.5 - 3.5 2.0 - 3.0 2.5 - 3.5 n.a.

Belt mounted Integrated Starter Generator BISG 3.5 - 5.5 4.0 - 6.0 3.5 - 5.5 n.a.

Crank mounted Integrated Starter Generator CISG 8.7 - 8.9 8.6 - 8.9 8.7 - 8.9 14.1 -

16.3

Power Split Hybrid PSHEV 6.3 -

12.4

6.3 -

12.4

6.3 -

12.4

n.a.

2-Mode Hybrid 2MHEV n.a. 3.0 - 7.3 3.0 - 7.2 4.1 - 9.5

Plug-in Hybrid PHEV n.a. 45.2 -

47.7

n.a. n.a.

Mass Reduction (1.5%) MS1 1.0 1.0 1.0 1.0

Mass Reduction (3.5 to 8.5%) MS2 5.6 3.9 3.9 5.6

Low Rolling Resistance Tires ROLL 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0 1.0 - 2.0

Low Drag Brakes LDB 0.5 - 1.0 n.a. 0.5 - 1.0 0.5 - 1.0

Secondary Axle Disconnect SAX 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5 1.0 - 1.5

Aero Drag Reduction AERO 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0 2.0 - 3.0
Draft Joint Technical Support Document 

3-100 

3.5.2 EPA cost and effectiveness tables

 The tables below show costs and effectiveness values for each particular 

technology described throughout this chapter (those considered by EPA in its model). 

The costs are shown as incremental to a particular baseline as noted in the tables. In 

general, the costs are meant to reflect the cost of a given technology relative to a baseline 

vehicle or engine with fixed timing 4 valves per cylinder, port fuel injection and a 4 

speed automatic transmission. Where this is not the case is made clear in the tables. The 

same is true of the effectiveness tables below. As such, the costs and effectiveness values 

shown in the tables below will differ from the values contained in the NHTSA tables due 

to the different ways that the agency’s models handles them. However, the underlying 

cost and effectiveness values used by each agency in their respective analyses are 

consistent. 

 

Table 3-263-25 EPA’s Incremental Piece Costs for Engine Technologies Marked up to include both Direct and 

Indirect Costs in 2016 (2007 Dollars per Vehicle) 

TECHNOLOGY INCREMENTAL TO VEHICLE CLASS 

Small Car Large Car Minivan Small Truck Large Truck

 Low friction lubricants Base engine $3 $3 $3 $3 $3

 Engine friction reduction Base engine $50 $75 $75 $75 $100 OHC Engines 

VVT – intake cam 

phasing Base engine $40 $80 $80 $80 $80 

VVT – coupled cam 

phasing Base engine $40 $80 $80 $80 $80 

VVT – dual cam phasing Base engine $73 $157 $157 $157 $157 

Cylinder deactivation Base engine n/a $150 $150 $150 $169 

Discrete VVLT Base engine $125 $181 $181 $181 $259 

Continuous VVLT Base engine $245 $449 $449 $449 $489 

OHV Engines 

Cylinder deactivation Base engine n/a $150 $150 $150 $169 

VVT – coupled cam 

phasing Base engine $40 $40 $40 $40 $40 

Discrete VVLT Base engine $141 $204 $204 $204 $291 

Continuous VVLT 

(includes conversion to 

Overhead Cam)

Base engine w/ VVTcoupled $497 $1,048 $1,048 $1,048 $1,146 

 Camless valvetrain 

(electromagnetic) Base engine $501 $501 $501 $501 $501 

 GDI – stoichiometric Base engine $222 $287 $287 $287 $312 

 GDI – lean burn GDI - stoich $623 $623 $623 $623 $623 Turbo w/o downsize Downsize w/o turbo 

Turbocharge (single) Base engine $366 $366 $366 $366 $366 

Turbocharge (twin) Base engine $663 $663 $663 $663 $663 

Downsize to I4 DOHC V6 DOHC -$337 -$337 -$337 -$337 -$337 

Downsize to I4 DOHC V6 SOHC -$53 -$53 -$53 -$53 -$53 

Downsize to I4 DOHC V6 OHV $265 $265 $265 $265 $265

Downsize to I4 DOHC I4 DOHC (larger) -$47 -$47 -$47 -$47 -$47 

Downsize to I3 DOHC I4 DOHC -$80 n/a n/a n/a n/a 

Downsize to V6 DOHC V8 DOHC n/a -$160 -$160 -$160 -$160 

Downsize to V6 DOHC V8 SOHC 2V n/a $199 $199 $199 $199 

Downsize to V6 DOHC V8 SOHC 3V n/a $111 $111 $111 $111 

Downsize to V6 DOHC V8 OHV n/a $310 $310 $310 $310

Turbo 

with 

downsiz

e Downsize to I4 DOHC 

& add turbo V6 DOHC w/o turbo $214 $214 $214 $214 $214 

Downsize to I4 DOHC 

& add turbo V6 SOHC w/o turbo $453 $453 $453 $453 $453 
3-101 

Downsize to I4 DOHC 

& add turbo V6 OHV w/o turbo $797 $797 $797 $797 $797 

Downsize to I4 DOHC 

& add turbo 

I4 DOHC (larger) 

w/o turbo $372 $372 $372 $372 $372 

Downsize to I3 DOHC 

& add turbo I4 DOHC w/o turbo $344 n/a n/a n/a n/a 

Downsize to V6 DOHC 

& add twin turbo V8 DOHC w/o turbo n/a $613 $613 $613 $613 

Downsize to V6 DOHC 

& add twin turbo 

V8 SOHC 2V w/o 

turbo n/a $971 $971 $971 $971 

Downsize to V6 DOHC 

& add twin turbo 

V8 SOHC 3V w/o 

turbo n/a $872 $872 $872 $872 

Downsize to V6 DOHC 

& add twin turbo V8 OHV w/o turbo n/a $1,096 $1,096 $1,096 $1,096 

Convert to V6 DOHC V6 SOHC n/a $354 $354 $354 $354

 Convert to V6 DOHC V6 OHV n/a $464 $464 $464 $464 

Convert to V8 DOHC V8 SOHC 2V n/a $398 $398 $398 $398

 Convert to V8 DOHC V8 SOHC 3V n/a $310 $310 $310 $310 

 Convert to V8 DOHC V8 OHV n/a $509 $509 $509 $509 

 Gasoline HCCI dualmode GDI - stoich $253 $375 $375 $375 $659 

 Diesel – Lean NOx trap Base gasoline engine 

 Diesel – urea SCR Base gasoline engine $2,655 $2,164 $2,164 $2,961 

Table 3-273-26 EPA’s Incremental Piece Costs for Transmission Technologies Marked up to include both Direct 

and Indirect Costs in 2016 (2007 Dollars per Vehicle) 

TECHNOLOGY INCREMENTAL TO 

VEHICLE CLASS 

Small 

Car 

Large 

Car Minivan Small Truck 

Large 

Truck 

Aggressive shift logic Base trans $28 $28 $28 $28 $28 

Early torque converter lockup Base trans $25 $25 $25 $25 $25 

5-speed automatic 4-speed auto trans $90 $90 $90 $90 $90 

6-speed automatic 4-speed auto trans $150 $150 $150 $150 $150 

6-speed DCT – dry clutch 6-speed auto trans $65 $65 $65 $65 $65 

6-speed DCT – wet clutch 6-speed auto trans $139 $139 $139 $139 $139 

6-speed manual 5-speed manual trans $79 $79 $79 $79 $79

CVT 4-speed auto trans $192 $224 $224 n/a n/a

Table 3-283-27 EPA’s Incremental Piece Costs for Hybrid Technologies Marked up to include both Direct and 

Indirect Costs in 2016 (2007 Dollars per Vehicle) 

TECHNOLOGY INCREMENTAL 

TO 

VEHICLE CLASS 

Small Car Large Car Minivan Small Truck Large Truck

Stop-Start Base engine & 

trans $351 $398 $398 $398 $437 

IMA/ISA/BSG 

(includes engine 

downsize)

Base engine & 

trans $2,854 $3,612 $3,627 $3,423 $4,431 

2-Mode hybrid 

electric vehicle 

Base engine & 

trans $4,232 $5,469 $5,451 $4,943 $7,236 

Power-split 

hybrid electric 

vehicle 

Base engine & 

trans $3,967 $5,377 $5,378 $4,856 $7,210 

Plug-in hybrid IMA/ISA/BSG $6,922 $9,519 $9,598 $9,083 $12,467 

Formatted: Font: 9 pt, Italian (Italy)

Formatted: Italian (Italy)
Draft Joint Technical Support Document 

3-102 

electric vehicle hybrid 

Plug-in hybrid 

electric vehicle 

Power-split 

hybrid $5,423 $7,431 $7,351 $7,128 $9,643 

Full electric 

vehicle

Base engine & 

trans

$27,628 n/a n/a n/a n/a 

Table 3-293-28 EPA’s Incremental Piece Costs for Accessory Technologies Marked up to include both Direct and 

Indirect Costs in 2016 (2007 Dollars per Vehicle) 

TECHNOLOGY INCREMENTAL 

TO 

VEHICLE CLASS 

Small Car Large Car Minivan Small Truck Large Truck

Improved high efficiency 

alternator & 

electrification of 

accessories 

Base accessories $76 $76 $76 $76 $76 

Upgrade to 42 volt 

electrical system 

12 volt electrical 

system $86 $86 $86 $86 $86 

Electric power steering 

(12 or 42 volt) 

Base power 

steering $94 $94 $94 $94 $94 

Table 3-303-29 EPA’s Incremental Piece Costs for Vehicle Technologies Marked up to include both Direct and 

Indirect Costs in 2016 (2007 Dollars per Vehicle) 

TECHNOLOGY INCREMENTAL 

TO 

VEHICLE CLASS 

Small Car Large Car Minivan Small Truck Large Truck

Aero drag reduction (20% 

on cars, 10% on trucks) Base vehicle $42 $42 $42 $42 $42 

Low rolling resistance 

tires Base tires $6 $6 $6 $6 $6 

Low drag brakes (ladder 

frame only) Base brakes n/a n/a n/a $63 $63 

Secondary axle disconnect 

(unibody only) Base vehicle $514 $514 $514 $514 n/a 

Front axle disconnect 

(ladder frame only) Base vehicle n/a n/a n/a $84 $84 

Table 3-31Table 3-31Table 3-31 through Table 3-35Table 3-35Table 3-35

summarize the estimates for the CO2 reduction estimates of various technologies which 

can be applied to cars and light-duty trucks. 

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Table 3-313-30 Engine Technology Effectiveness 

Technology 

Absolute CO2

 Reduction (% from baseline vehicle) 

Small Car Large 

Car Minivan Small Truck 

Large 

Truck 

Low friction lubricants – incremental to base engine 0.5 0.5 0.5 0.5 0.5 

Engine friction reduction – incremental to base engine 1-3 1-3 1-3 1-3 1-3 

Overhead Cam Branch 

VVT – intake cam phasing 2 1 1 1 2 

VVT – coupled cam phasing 3 4 2 3 4

VVT – dual cam phasing 3 4 2 2 4

Cylinder deactivation (includes imp. oil pump, 

if applicable) n.a. 6 6 6 6 

Discrete VVLT 4 3 3 4 4 

Continuous VVLT 5 6 4 5 5 

Overhead Valve Branch 

Cylinder deactivation (includes imp. oil 

pump, if applicable) n.a. 6 6 6 6 

VVT – coupled cam phasing 3 4 2 3 4 

Discrete VVLT 4 4 3 4 4 

Continuous VVLT (includes conversion to 

Overhead Cam) 5 6 4 5 5 

Camless valvetrain (electromagnetic) 5-15 5-15 5-15 5-15 5-15

Gasoline Direct Injection–stoichiometric (GDI-S) 1-2 1-2 1-2 1-2 1-2 

Gasoline Direct Injection–lean burn (incremental to

GDI-S) 8-10 9-12 9-12 9-12 10-14 

Gasoline HCCI dual-mode (incremental to GDI-S) 10-12 10-12 10-12 10-12 10-12 

Turbo+downsize (incremental to GDI-S) 5-7 5-7 5-7 5-7 5-7 

Diesel – Lean NOx trap[]* 15-26 15-26 15-26 15-26 15-26 

Diesel – urea SCR []* 15-26 15-26 15-26 15-26 15-26 

Table 3-323-31 Transmission Technology Effectiveness 

Technology 

Absolute CO2 Reduction (% from baseline vehicle) 

Small 

Car 

Large 

Car Minivan Small Truck 

Large 

Truck 

 5-speed automatic (from 4-speed auto) 2.5 2.5 2.5 2.5 2.5

 Aggressive shift logic 1-2 1-2 1-2 1-2 1-2 

 Early torque converter lockup 0.5 0.5 0.5 0.5 0.5

 6-speed automatic (from 4-speed auto) 4.5-6.5 4.5-6.5 4.5-6.5 4.5-6.5 4.5-6.5 

 6-speed AMT (from 4-speed auto) 9.5-14.5 9.5-14.5 9.5-14.5 9.5-14.5 9.5-14.5

 6-speed manual (from 5-speed manual) 0.5 0.5 0.5 0.5 0.5 

 CVT (from 4-speed auto) 6 6 6 n.a. n.a. 

Table 3-333-32 Hybrid Technology Effectiveness 

Technology 

Absolute CO2 Reduction (% from baseline vehicle) 

Small 

Car

Large 

Car Minivan Small Truck

Large 

Truck

 Stop-Start with 42 volt system 7.5 7.5 7.5 7.5 7.5 

 IMA/ISA/BSG (includes engine downsize) 30 25 20 20 20

 2-Mode hybrid electric vehicle n.a. 40 40 40 25

 Power-split hybrid electric vehicle 35 35 35 35 n.a.

 Full-Series hydraulic hybrid 40 40 40 40 30
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3-104 

 Plug-in hybrid electric vehicle 58 58 58 58 47 

 Full electric vehicle (EV) 100 100 n.a. n.a. n.a. 

Table 3-343-33 Accessory Technology Effectiveness 

Technology 

Absolute CO2 Reduction (% from baseline vehicle) 

Small 

Car

Large 

Car Minivan Small Truck

Large 

Truck

Improved high efficiency alternator & electrification of 

accessories (12 volt) 1-2 1-2 1-2 1-2 1-2 

Electric power steering (12 or 42 volt) 1.5 1.5-2 2 2 2 

Improved high efficiency alternator & electrification of 

accessories (42 volt) 2-4 2-4 2-4 2-4 2-4 

Table 3-353-34 Other Vehicle Technology Effectiveness 

Technology 

Absolute CO2 Reduction (% from baseline vehicle) 

Small 

Car

Large 

Car Minivan Small Truck

Large 

Truck

 Aero drag reduction (20% on cars, 10% on trucks) 3 3 3 2 2 

 Low rolling resistance tires (10%) 1-2 1-2 1-2 1-2 n.a.

 Low drag brakes (ladder frame only) n.a. n.a. n.a. 1 1 

 Secondary axle disconnect (unibody only) 1 1 1 1 n.a. 

 Front axle disconnect (ladder frame only) n.a. n.a. n.a. 1.5 1.5 
3-105 

Appendix 3.A 

Gross Domestic Product Adjustments Used to Adjust 2002-2006 Dollars 

to 2007 Dollars 

Throughout this analysis, the incremental cost estimates have been presented in 

terms of 2007 dollars. However, most of the data sources relied upon as the basis for the 

estimates have presented costs in terms of 2006 dollars. To convert the 2006 dollars to 

2007 dollars, the “chain-type” Gross Domestic Product (GDP) deflator was used. Table 

3.A-1 shows the GDP deflator data used for this analysis. 

Table 3.A-1 Price Indexes for Gross Domestic Product 

LINE 2002 2003 2004 2005 2006 2007 2008 

1 Gross domestic product 104.193 106.409 109.462 113.039 116.676 119.819 122.5

2 Personal consumption 

expenditures 103.542 105.597 108.392 111.581 114.675 117.659 121.596

3 Durable goods 95.766 92.366 90.696 89.984 88.772 87.154 86.071

4 Nondurable goods 102.089 104.145 107.626 111.606 114.984 118.407 124.666

5 Services 106.018 109.379 112.929 116.7 120.752 124.712 128.752

6 Gross private domestic 

investment 101.64 103.191 106.686 111.381 116.102 117.735 118.509

7 Fixed investment 101.66 103.313 106.845 111.638 116.38 117.995 118.727

8 Nonresidential 99.513 99.591 100.896 103.829 107.277 108.739 110.513

9 Structures 110.03 113.872 120.912 135.177 151.822 157.662 163.298

10 Equipment and software 95.956 94.912 94.6 94.534 94.594 94.87 95.485

11 Residential 107.24 112.372 120.587 129.268 136.897 138.884 135.587

12 Change in private inventories

13 Net exports of goods and 

services 

14 Exports 99.273 101.429 104.997 108.814 112.618 116.586 122.788

15 Goods 98.661 100.64 104.323 107.536 111.131 115.062 121.147

16 Services 100.762 103.333 106.632 111.855 116.156 120.211 126.684

17 Imports 96.341 99.685 104.526 111.154 115.932 120.168 132.698

18 Goods 95.288 98.063 102.915 109.568 114.171 118.326 131.408

19 Services 101.878 108.291 113.049 119.496 125.257 129.928 139.217

20 

Government consumption 

expenditures and gross 

investment 

105.507 109.849 114.754 121.47 127.239 132.941 139.234

21 Federal 105.631 110.094 115.322 120.834 125.806 130.076 134.289

22 National defense 105.792 110.751 115.932 121.944 127.381 131.874 136.574

23 Nondefense 105.345 108.898 114.218 118.744 122.803 126.636 129.869

24 State and local 105.435 109.712 114.431 121.862 128.109 134.671 142.219

Source: Bureau of Economic Analysis, U.S. Department of Commerce, 

http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=4 

Using Line 1 in the table, 2006 dollars can be adjusted to 2007 dollars by 

multiplying the ratio 119.8/116.7, or 1.027, by any value expressed in 2006 dollars. For 

example, $1 in 2006 dollars would be $1 x 1.027, or $1.03 in 2007 dollars.
Draft Joint Technical Support Document 

3-106 

References 

CHAPTER 3: TECHNOLOGIES CONSIDERED IN THE AGENCIES’ 

ANALYSIS 22

3.1 HOW DO THE AGENCIES DECIDE WHICH TECHNOLOGIES TO 

INCLUDE IN THE ANALYSIS? ......................................................................... 22

3.1.1 REPORTS AND PAPERS IN THE LITERATURE ............................ 22

3.1.2 FUEL ECONOMY CERTIFICATION DATA .................................... 33

3.2 WHICH TECHNOLOGIES WILL BE APPLICABLE IN THE 

RULEMAKING TIME FRAME? ........................................................................ 44

3.3 WHAT TECHNOLOGY ASSUMPTIONS HAVE THE AGENCIES USED 

FOR THIS PROPOSAL? ...................................................................................... 88

3.3.1 HOW ARE THE TECHNOLOGIES APPLIED IN THE AGENCIES’ 

RESPECTIVE MODELS? .................................................................................... 88

3.3.2 HOW DID THE AGENCIES DEVELOP TECHNOLOGY COST AND 

EFFECTIVENESS ESTIMATES FOR THE PROPOSAL? ........................... 1010

3.3.2.1 Considerations that affect technology effectiveness ................................ 1010

3.3.2.1.1 Technology synergies ........................................................................... 1010

3.3.2.2 Considerations that affect technology costs ............................................ 1111

3.3.2.2.1 Direct manufacturing costs .................................................................. 1212

3.3.2.2.2 Cost markups to account for indirect costs ......................................... 1414

3.3.2.2.3 Concept behind and development of indirect cost multipliers ........... 1414

3.4 SPECIFIC TECHNOLOGIES CONSIDERED AND ESTIMATES OF 

COSTS AND EFFECTIVENESS ..................................................................... 2121

3.4.1 WHAT DATA SOURCES DID THE AGENCIES EVALUATE? ... 2121

3.4.2 INDIVIDUAL TECHNOLOGY DESCRIPTIONS AND 

COST/EFFECTIVENESS ESTIMATES ......................................................... 2121

3.5 COST AND EFFECTIVENESS TABLES .............................................. 8583

3.5.1 NHTSA cost and effectiveness tables ................................................... 8583

3.5.2 EPA cost and effectiveness tables ...................................................... 10096

Appendix 3.A ....................................................................................................... 105101

 

1

 “EPA Staff Technical Report: Cost and Effectiveness Estimates of Technologies Used to Reduce Lightduty Vehicle Carbon Dioxide Emissions,” EPA420-R-08-008, March 2008. 

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3-107 

 

2

 “Effectiveness and Impact of Corporate Average Fuel Economy (CAFE) Standards,” National Research 

Council, National Academy of Sciences, 2002. 

3

 “Reducing Greenhouse Gas Emissions from Light-Duty Motor Vehicles,” Northeast States Center for a 

Clean Air Future, September 2004. 

4

 “Staff Report: Initial Statement of Reasons for Proposed Rulemaking,” California Environmental 

Protection Agency, Air Resources Board, Regulations to Control Greenhouse Gas Emissions from Motor 

Vehicles, August 6, 2004. 

5

 “Technology to Improve the Fuel Economy of Light Duty Trucks to 2015,” Energy and Environmental 

Analysis, Inc., May 2006. 

6

 “Variable Costs of Fuel Economy Technologies,” prepared for The Alliance of Automobile 

Manufacturers, June 1, 2008; and, “Variable Costs of Fuel Economy Technologies,” prepared for The 

Alliance of Automobile Manufacturers, June 1, 2008, Amended December 10, 2008. 

7

 National Highway Traffic Safety Administration, Request for Product Plan Information, 70 FR 51466, 

August 30, 2005. 

8 U.S. Environmental Protection Agency, “Draft Report – Light-Duty Technology Cost Analysis Pilot 

Study,” Contract No. EP-C-07-069, Work Assignment 1-3, September 3, 2009Reference report/draft report 

of FEV work. 

9

 Memorandum from Don Kopinski, U.S. EPA, to the docket, dated September xx, 2009 (EPA-HQ-OAR2009-0472-xxx), dated September 11, 2009.

10 Memorandum from Don Kopinski, U.S. EPA, to the docket, dated September xx, 2009 (EPA-HQ-OAR2009-0472-xxx), dated September 11, 2009.

11 Reference NHTSA’s 2011 CAFE FRM final rule at(FR cite) 74 FR 14196. 

12 “EPA Staff Technical Report: Cost and Effectiveness Estimates of Technologies Used to Reduce Lightduty Vehicle Carbon Dioxide Emissions,” EPA420-R-08-008, March 2008. 

13 National Income and Product Accounts Table 1.1.4: Price Indexes for Gross Domestic Product; 

downloaded on 6/25/2009 At 12:00:25 PM, Last Revised June 25, 2009; Bureau of Economic Analysis, 

U.S. Department of Commerce, www.bea.gov. 

14 “EPA Staff Technical Report: Cost and Effectiveness Estimates of Technologies Used to Reduce LightDuty Vehicle Carbon Dioxide Emissions,” EPA420-R-08-008, March 2008. 

15 U.S. Environmental Protection Agency, “Draft Report – Light-Duty Technology Cost Analysis Pilot 

Study,” Contract No. EP-C-07-069, Work Assignment 1-3, September 3, 2009Reference report/draft report 

of FEV work. 

16 Rogozhin, Alex, Michael Gallaher, and Walter McManus, “Automobile Industry Retail Price Equivalent 

and Indirect Cost Multipliers,” EPA 420-R-09-003, February 2009, http://epa.gov/otaq/ldhwy/420r09003.pdf. 

17 “Memorandum: Documentation of the Development of Indirect Cost Multipliers for Three Automotive 

Technologies,” Gloria Helfand and Todd Sherwood, Office of Transportation and Air Quality, U.S. 

Environmental Protection Agency, DATEAugust 2009. 
Draft Joint Technical Support Document 

3-108 

 

18 “Regulatory Impact Analysis: Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel 

Sulfur Control Requirements,” EPA420-R-00-026, December 2000; “Final Regulatory Analysis: Control 

of Emissions from Nonroad Diesel Engines,” EPA420-R-04-007, May 2004; “Draft Regulatory Impact 

Analysis: Control of Emissions of Air Pollution from Locomotive Engines and Marine CompressionIgnition Engines Less than 30 Liters per Cylinder,” EPA420-D-0708-001a, March 2007May 2008; NHTSA 

2011 CAFE final rule at 74 FR 14196. 

19 “Learning Curves in Manufacturing,” Linda Argote and Dennis Epple, Science, February 23, 1990, Vol. 

247, pp. 920-924. 

20 NHTSA 2011 CAFE final rule at 74 FR 14196;Reference NHTSA 2011 (or 2008, or both) FRM, “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; “Final Regulatory Analysis: 

Control of Emissions from Nonroad Diesel Engines,” EPA420-R-04-007, May 2004; “Regulatory Impact 

Analysis: Control of Emissions of Air Pollution from Locomotive Engines and Marine CompressionIgnition Engines Less than 30 Liters per Cylinder,” EPA420-D-08-001a, May 20082008 staff report, 

2007/2010 Hwy Rule RIA, NRT4 rule RIA. 

21 “Impact of Friction Reduction Technologies on Fuel Economy,” Fenske, G. Presented at the March 2009 

Chicago Chapter Meeting of the ‘Society of Tribologists and Lubricated Engineers’ Meeting, March 18th,

2009. Available at: http://www.chicagostle.org/program/2008-

2009/Impact%20of%20Friction%20Reduction%20Technologies%20on%20Fuel%20Economy%20-

%20with%20VGs%20removed.pdf (last accessed July 9, 2009). 

22 “Light-Duty Automotive Technology and Fuel Economy Trends: 1975 Through 2007”, EPA420-S-07-

001, September 2007. Available at http://www.epa.gov/oms/cert/mpg/fetrends/fetrends-archive.htm (last

accessed July 9, 2009). 

23 Paul Whitaker, Ricardo, Inc., “Gasoline Engine Performance And Emissions – Future Technologies and 

Optimization,” ERC Symposium, Low Emission Combustion Technologies for Future IC Engines, 

Madison, WI, June 8-9, 2005. Available at 

http://www.erc.wisc.edu/symposiums/2005_Symposium/June%208%20PM/Whitaker_Ricardo.pdf (last 

accessed Nov. 9, 2008). 

24 Stefan Trampert, FEV Motorentechnik GmbH, “Engine and Transmission Development Trends - Rising 

Fuel Cost Pushes Technology,” Symposium on International Automotive Technology, Pune, India, January 

2007. 

25 Stefan Wolff, Dirk Abendroth, Werner Weigl, Claus-Peter Linner, Rupert Neudecker, Michael 

Schneider, Wolfgang Huber, and Andreas Rau, BMW, “Introducing The Automatic Start-Stop (ASS) 

Function In Series Models,” 7th Stuttgart Automotive Vehicle and Engine Symposium, Organised by 

FKFS, Mar 2007, Vol. 1. 

26 G.K. Fraidl, P.E. Kapus, and H. Friedl, AVL List GmbH, “Future Gasoline Engine Technologies for 130 

g/Km CO2,” VKM-THD 11th Symposium on the Working Process of Combustion Engines, TU Graz, 

Sept. 2007. 

27 “Development and Optimization of the Ford 3.5L V6 EcoBoost Combustion System,” Yi,J., Wooldridge, 

S., Coulson, G., Hilditch, J. Iyer, C.O., Moilanen, P., Papaioannou, G., Reiche, D. Shelby, M., 

VanDerWege, B., Weaver, C. Xu, Z., Davis, G., Hinds, B. Schamel, A. SAE Technical Paper No. 2009-01-

1494, 2009. 
3-109 

 

28 David Woldring and Tilo Landenfeld of Bosch, and Mark J. Christie of Ricardo, “DI Boost: Application

of a High Performance Gasoline Direct Injection Concept,” SAE 2007-01-1410. Available at 

http://www.sae.org/technical/papers/2007-01-1410 (last accessed Nov. 9, 2008) 

29 Yves Boccadoro, Loïc Kermanac’h, Laurent Siauve, and Jean-Michel Vincent, Renault Powertrain 

Division, “The New Renault TCE 1.2L Turbocharged Gasoline Engine,” 28th Vienna Motor Symposium, 

April 2007. 

30 Tobias Heiter, Matthias Philipp, Robert Bosch, “Gasoline Direct Injection: Is There a Simplified, CostOptimal System Approach for an Attractive Future of Gasoline Engines?” AVL Engine & Environment 

Conference, September 2005. 

31 U.S. Environmental Protection Agency, “Draft Report – Light-Duty Technology Cost Analysis Pilot 

Study,” Contract No. EP-C-07-069, Work Assignment 1-3, September 3, 2009Reference FEV/Munro 

report that provides details of turbo/downsize tear-down and costs. 

32 Docket No. NHTSA-2008-0089-0193.1 

33 Cairns et al., Lotus, “Low Cost Solutions for Improved Fuel Economy in Gasoline Engines,” Global 

Powertrain Congress September 27-29, 2005, vol. 33. Available at http://www.gpcicpem.org/pages/publications.html (last accessed Nov. 9, 2008).

34 Tim Lake, John Stokes, Richard Murphy, and Richard Osborne of Ricardo and Andreas Schamel of 

Ford-Werke, “Turbocharging Concepts for Downsized DI Gasoline Engines,” VKA/ika Aachen 

Colloquium 2003. Available at http://cat.inist.fr/?aModele=afficheN&cpsidt=16973598 (last accessed 

Nov. 9, 2008). 

35 “Interim Report: New Powertrain Technologies and Their Projected Costs,” October 2005, EPA420-R05-012. 

36 “Cost and Fuel Economy Comparison of Diesel and Gasoline Powertrains in Passenger Cars and Light 

Trucks,” submitted by FEV Engine Technology, Inc., April 23, 2003, contained as Appendix I within EPA 

Interim Technical Report EPA420-R-04-002. 

37 cite EPA’s 2007/2010 diesel heavy-duty highway final rule atFRM66 FR 5002; EPA’s Locomotive and 

Marine final rule at 73 FR 37096. and L-M rule FRM

38 http://www.platinum.matthey.com/Cite J-M website. 

39 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). 

40 Page 17, “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.

41 “Latest Chevrolet Volt Battery Pack and Generator Details and Clarifications.” Lyle Dennis interview 

of Rob Peterson (GM) regarding the all-electric drive range of the GM Volt, August 29, 2007. Accessed on 

the Internet on June 30, 2009 at: http://gm-volt.com/2007/08/29/latest-Chevrolet-volt-battery-pack-andgenerator-details-and-clarifications/ 
Draft Joint Technical Support Document 

3-110 

 

42 “Active Combination of Ultracapacitorsand Batteries for PHEV ESS.” Bohn, T. U.S. Department of 

Energy 2009 Vehicle Technologies Merit Review, May 20, 2009 

43 Anderman, Advanced Automotive Battery Conference, May 2008. Proceedings available for purchase at 

http://www.advancedautobat.com/Proceedings/index.html (last accessed October 17, 2008). 

44 74 FR 14291 (Mar. 30, 2009) 

45 “Electric Cars: Plugged In, Batteries must be included,” Deutsche Bank Global Markets Research 

Company, June 9, 2008.

46 74 FR 14293 (Mar. 30, 2009) 

47

 http://automobiles.honda.com/insight-hybrid/features.aspx?Feature=ima (last accessed on September 10, 

2009).Insert reference for Honda hybrid system.

48 “Factor of Two: Halving the Fuel Consumption of New U.S. Automobiles by 2035,” Cheah, L., Evans, 

C., Bandivadekar, A., Heywood, J., Massachusetts Institute of Technology, Publication No. LFEE 2007-04

RP, October 2007. 

49 “FY 2007 Progress Report for Lightweighting Materials”, Davis, P., Sullivan, R., Carpenter, J., U.S. 

Department of Energy Office of Vehicle Technologies, December 2008. Accessed on the Internet on April

30, 2009 at: http://www1.eere.energy.gov/vehiclesandfuels/resources/vt_lm_fy07.html 

50 “Benefit Analysis: Use of Aluminum Structures in Conjunction with Alternative Powertrain 

Technologies in Automobiles,” Bull, M. Chavali, R., Mascarin, A., Aluminum Association Research 

Report, May 2008. Accessed on the Internet on April 30, 2009 at: 

http://www.autoaluminum.org/downloads/IBIS-Powertrain-Study.pdf

51 “Future Generation Passenger Compartment-Validation,” in “Lightweighting Materials – FY 2008 

Progress Report,” U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Vehicle

Technologies Program, May 2009. 

52 “Preliminary Vehicle Mass Estimation Using Empirical Subsystem Influence Coefficients,” Malen, D.E., 

Reddy, K. Auto-Steel Partnership Report, May 2007. Accessed on the Internet on May 30, 2009 at: 

http://www.a-sp.org/database/custom/Mass%20Compounding%20-%20Final%20Report.pdf 

53 “Future Generation Passenger Compartment – Final Report,” Auto-Steel Partnership Report, June 2007. 

Accessed on the Internet on May 30, 2009 at: http://www.a-sp.org/database/custom/FGPC%20Phase 

%201%20Final%20Report.pdf 

54 “Tires and Passenger Vehicle Fuel Economy,” Transportation Research Board Special Report 286, 

National Research Council of the National Academies, 2006. 

55 “An HCCI Engine Power Plant for a Hybrid Vehicle,” Sun, R., R. Thomas and C. Gray, Jr., SAE 

Technical Paper No. 2004-01-0933, 2004.