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A1 Appendix A: The Baseline and Reference Vehicle Fleet

The passenger cars and light trucks sold currently in the United States, and those 

which are anticipated to be sold in the MYs 2017-2025 time frame, are highly varied and 

satisfy a wide range of consumer needs. From two-seater miniature cars to 11-seater 

passenger vans to large extended cab pickup trucks, American consumers have a great 

number of vehicle options to accommodate their utility needs and preferences. Recent 

volatility in oil prices and the state of the economy have demonstrated that consumer demand 

and choice of vehicles within this wide range can be sensitive to these factors. Although it is 

impossible for anyone or any organization to precisely predict the future, a characterization 

and quantification of the future fleet are required to assess the impacts of rules which would 

affect that future fleet. In order to do this, the various leading publicly-available sources are 

examined, and a series of models are relied upon that help us to project the composition of a 

reference fleet. This appendix gives a high level over view of the process to accomplish this 

and a simple analysis of the fleet’s characteristics, drawing extensively from the joint final 

TSD for the MYs 2012-2016 final rule.

A1.1 Why do the agencies establish a baseline and reference vehicle fleet?

In order to calculate the impacts of potential future EPA and NHTSA standards, it is 

necessary to estimate the composition of the future vehicle fleet absent those CAFE/GHG 

standards in order to conduct comparisons. EPA in consultation with NHTSA has developed 

a comparison fleet in two parts. The first step was to develop a baseline fleet based on model 

year 2008 data. EPA and NHTSA create a baseline fleet in order to track the volumes and 

types of fuel economy-improving and CO2-reducing technologies which are already present in 

today’s fleet. Creating a baseline fleet helps to keep, to some extent, the agencies’ models 

from adding technologies to vehicles that already have these technologies, which would result 

in “double counting” of technologies’ costs and benefits. The second step was to project the 

baseline fleet sales into MYs 2017-2025. This is called the reference fleet, and it represents 

the fleet that would exist in MYs 2017-2025 absent any change from current regulations. The 

third step was to add technologies to that MY 2008 fleet such that each manufacturer’s 

average car and truck CO2 levels are in compliance with their MY 2016 CAFE standards. 

This final “reference fleet” is the light duty fleet estimated to exist in MYs 2017-2025 without 

new CAFE/GHG standards. All of the agencies’ estimates of emission reductions/fuel 

economy improvements, costs, and societal impacts for purposes of this Technical 

Assessment Report are developed in relation to this reference fleet for MY 2016. This 

Appendix describes the first two steps of the development of the baseline and reference fleets. 

The third step of technology addition is developed separately by each agency as the outputs of 

the OMEGA and Volpe models; for purposes of this Technical Assessment Report, as 

discussed above, only the OMEGA model was employed for the main analysis, although both 

models will be run for the forthcoming federal rulemaking. The overall process for 

developing baseline and reference fleets for the agencies’ modeling is described in the MYs 

2012-2016 final rule in section II of the preamble and in each agency’s respective RIA. 
Appendix A 

A-2

A1.2 The 2008 baseline vehicle fleet

A1.2.1 Why did the agencies choose 2008 as the baseline model year?

A baseline vehicle fleet was developed by EPA in consultation with NHTSA for the 

2012-2016 final rule. The baseline for the 2012-2016 final rule is comprised of model year 

2008 individual vehicle attribute data volumes along with projected volumes out to 2016. 

Model year 2008 vehicle data was again chosen to be the basis of the baseline fleet, but for 

different reasons than the final rule. Model year 2008 is now the most recent model year for 

which the industry had normal sales. Model year 2009 data was available, but the agencies 

believe that the model year was disrupted by the economic downturn and the bankruptcies of 

both General Motors and Chrysler. There was a significant reduction in the number of 

vehicles sold by both companies and the industry as a whole. These abnormalities made the 

agencies conclude that 2009 data was unsuitable for projecting the future fleet. Therefore, the 

agencies chose to use model year 2008 as the baseline since it was the latest representative

transparent data set available. 

A1.2.1.1 On what data is the baseline vehicle fleet based?

As part of the CAFE program, EPA measures vehicle CO2 emissions and converts 

them to mpg and generates and maintains the federal fuel economy database. Most of the 

information about the 2008 vehicle fleet was gathered from EPA’s emission certification and 

fuel economy database, most of which is available to the public. The data obtained from this 

source included vehicle production volume, fuel economy, carbon dioxide emissions, fuel 

type, number of engine cylinders, displacement, valves per cylinder, engine cycle, 

transmission type, drive, hybrid type, and aspiration. However, EPA’s certification database 

does not include a detailed description of the types of fuel economy-improving/CO2-reducing 

technologies considered in this final rule, because this level of information is not necessary 

for emission certification or fuel economy testing. Thus, EPA augmented this description 

with publicly-available data which includes more complete technology descriptions from 

Ward’s Automotive Group.

1,A

 In a few instances when required vehicle information was not 

available from these two sources (such as vehicle footprint), this information was obtained 

from publicly-accessible internet sites such as Motortrend.com, Edmunds.com and other 

sources to a lesser extent (such as articles about specific vehicles revealed from internet 

search engine research.2,B

For details on how the 2008 baseline fleet was constructed for the 2012-2016 final 

rule, please see the Chapter 1 of the Joint Technical Support Document for that rule.

 

A Note that WardsAuto.com is a fee-based service, but all information is public to subscribers.

B Motortrend.com and Edmunds.com are free, no-fee internet sites.
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A1.3 The MY 2017-2025 Reference Fleet

The reference fleet aims to reflect the current market conditions and expectations 

about conditions of the vehicle fleet during the model years to which the agencies’ rules 

apply. Fundamentally, constructing this fleet involved projecting the MY 2008 baseline fleet 

into the 2017-2025 model years. It also included the assumption that none of the models had 

changes during this period, in terms of both the technology present in the vehicles themselves, 

and the vehicles present in the fleet. Projecting what the fleet will look like in the future is a 

process that is inherently uncertain. NHTSA and EPA therefore relied on many sources of 

reputable information to make these projections. 

A1.3.1 On what data is the reference vehicle fleet based?

EPA and NHTSA have based the projection of total car and light truck sales on recent 

projections made by the Energy Information Administration (EIA). EIA publishes a 

projection of national energy use annually called the Annual Energy Outlook (AEO).

3

 EIA 

published its Annual Energy Outlook for 2010 in May 2010. Similar to the analyses 

supporting the MYs 2012-2016 rulemaking, the agencies have used the Energy Information 

Administration’s (EIA’s) National Energy Modeling System (NEMS) to estimate the future 

relative market shares of passenger cars and light trucks. However, the version of NEMS 

supporting EIA’s Annual Energy Outlook 2010 (AEO2010) contains a “dummy variable” that 

forces the passenger car market share to increase after 2007, to facilitate projected compliance 

with EISA’s requirement that the overall fleet achieve 35 mpg by 2020 (the car and truck 

volumes based on this analysis are shown in Table A1.3-1. Because we use our market 

projection as a baseline relative to which we measure the effects of new standards, and we 

attempt to estimate the industry’s ability to comply with new standards without changing 

product mix, the AEO2010 projected shift in passenger car market share as a result of 

legislatively required fuel economy improvements creates a circular logic. Therefore, for the 

current analysis, a new projection of passenger car and light truck sales shares was developed 

by running scenarios from the AEO2010 reference case that first deactivate the abovementioned dummy variable and holds post-2017 CAFE standards constant at MY 2016 levels. 

Incorporating these changes reduced the projected passenger car share of the light vehicle 

market by an average of about 5% during 2017-2025. This case is referred to as the Unforced 

Reference Case, and the values are shown below in Table A1.3-2.

Table A1.3-1 AEO Original Reference Case Values

Model Year Cars Trucks Total Vehicles

2017 9,329,656 6,855,287 16,184,943

2018 9,375,428 6,595,148 15,970,576

2019 9,640,245 6,482,139 16,122,384

2020 10,105,479 6,436,088 16,541,566

2021 10,156,471 6,303,343 16,459,813

2022 10,178,345 6,166,611 16,344,956

2023 10,293,661 6,118,791 16,412,452

2024 10,516,662 6,166,036 16,682,698
Appendix A 

A-4

2025 10,761,857 6,204,297 16,966,155

Table A1.3-2 AEO Unforced Reference Case Values

Model Year Cars Trucks Total Vehicles

2017 8,783,816 7,401,127 16,184,943

2018 8,728,990 7,241,586 15,970,576

2019 8,899,836 7,222,548 16,122,384

2020 9,230,279 7,311,287 16,541,566

2021 9,265,881 7,193,932 16,459,813

2022 9,282,884 7,062,072 16,344,956

2023 9,382,100 7,030,352 16,412,452

2024 9,588,366 7,094,332 16,682,698

2025 9,817,211 7,148,944 16,966,155

Using the unforced reference case, EIA projects that total light-duty vehicle sales 

gradually recover from their currently depressed levels by roughly 2013. In 2017, car and 

light truck sales are projected to be 8.8 and 7.4 million units, respectively. While the total 

level of sales of 16.1 million units is similar to pre-2008 levels, the fraction of car sales is 

projected to be higher than that existing in the 2000-2007 timeframe. Note that EIA’s 

definition of cars and trucks follows that used by NHTSA prior to the MY 2011 CAFE final

rule. The MY 2011 CAFE final rule reclassified a number of 2-wheel drive sport utility 

vehicles from the truck fleet to the car fleet. EIA’s sales projections of cars and trucks for the 

2017-2025 model years under both the old NHTSA truck definition are shown above in Table 

A1.3-1 and Table A1.3-2.

In addition to a shift towards more car sales, sales of segments within both the car and 

truck markets have also been changing and are expected to continue to change in the future. 

Manufacturers are continuing to introduce more crossover models which offer much of the 

utility of SUVs but use more car-like designs and unibody structures. In order to reflect these 

changes in fleet makeup, EPA and NHTSA used a custom long range forecast purchased from

CSM Worldwide (CSM). CSM Worldwide (CSM) 4is a well-known industry analyst, that 

provided the forecast used for the 2012-2016 final rule. NHTSA and EPA decided to use the 

forecast from CSM for several reasons. One, CSM agreed to allow us to publish their high 

level data, on which the forecast is based, in the public domain. Two, it covered all the 

timeframe of greatest relevance to this analysis (2017-2025 model years). Three, it provided 

projections of vehicle sales both by manufacturer and by market segment. Four, it utilized 

market segments similar to those used in the EPA emission certification program and fuel 

economy guide. As discussed further below, the CSM forecast is combined with other data 

obtained by NHTSA and EPA.
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A1.3.2 How do the agencies develop the reference vehicle fleet?

The process of producing the 2017-2025 reference fleet involved combining the 

baseline fleet with the projection data described above. This was a complex multistep 

procedure, which is described in detail in the Joint Technical Support Document from the 

2012-2016 final rule with an abbreviated discussion in this section. 

A1.3.2.1 How was the 2008 baseline data merged with the CSM data?

Merging the 2008 baseline data with the 2017-2025 CSM data required a thorough 

mapping of certification vehicles to CSM vehicles by individual make and model. One 

challenge the agencies faced when determining a reference case fleet was that the sales data 

projected by CSM had different market segmentation than the data contained in EPA’s 

internal database. In order to create a common segmentation between the two databases, sideby-side comparison of the specific vehicle models in both datasets was performed, and an 

additional “CSM segment” modifier in the spreadsheet was created, thus mapping the two 

datasets. The reference fleet sales based on the “CSM segmentation” was then projected.

In the combined EPA certification and CSM database, all of the 2008 vehicle models 

were assumed to continue out to 2025, though their volumes changed in proportion to CSM 

projections. Also, any new models expected to be introduced within the 2011-2025

timeframe are not included in the data. These volumes are reassigned to the existing models. 

All MY 2017-2025 vehicles are mapped to the existing vehicles by a process of mapping to 

manufacturer market share and overall segment distribution. 

A1.3.2.2 How were the CSM forecasts normalized to the AEO forecasts?

The projected CSM forecasts for relative sales of cars and trucks by manufacturer and 

by market segment were normalized (set equal) to the total sales estimates of the AEO 2010 

reference case. NHTSA and EPA used projected car and truck volumes for this period from 

AEO 2010. However, the AEO projects sales only at the car and truck level, not at the 

manufacturer and model-specific level, which are needed for the analysis. The CSM data 

provided year-by-year percentages of cars and trucks sold by each manufacturer as well as the 

percentages of each vehicle segment. Using these percentages normalized to the AEOprojected volumes then provided the manufacturer-specific market share and model-specific 

sales for model years 2017-2025 (it is worth clarifying that the agencies are not using the 

model-specific sales volumes from CSM, only the volumes by manufacturer and segment). 

This process is described in greater detail in Chapter 1 of the Joint Technical Support 

Document for the 2012-2016 final rule.

A1.3.3 What are the sales volumes and characteristics of the reference fleet?

Table A1.3-3 and Table A1.3-6 below contain the sales volumes that result from the 

process above for MY 2008 and 2017-2020. Table A1.3-4 and Table A1.3-5 below contain 

the sales volumes that result from the process above for MY 2021-2025.
Appendix A 

A-6

Table A1.3-3 Vehicle Segment Volumesa

Reference Class 

Segment

Actual and Projected Sales Volume

2008 2017 2018 2019 2020

LargeAuto 557,693 381,148 361,437 361,164 406,604 

MidSizeAuto 3,097,859 3,472,360 3,456,168 3,501,241 3,603,571

CompactAuto 1,976,424 2,452,469 2,432,700 2,500,944 2,598,610

SubCmpctAuto 1,364,434 2,530,789 2,529,308 2,588,403 2,674,638

All Cars 6,971,256 8,783,816 8,728,990 8,899,836 9,230,279

LargePickup 1,581,880 1,521,906 1,452,047 1,404,242 1,413,451

SmallPickup 177,497 156,992 158,850 163,210 148,911 

LargeSUV 2,783,949 3,210,047 3,168,335 3,226,391 3,266,435

MidSizeSUV 1,263,360 1,365,334 1,316,762 1,286,724 1,311,146

SmallSUV 285,355 148,962 150,791 157,027 165,874 

MiniVan 642,055 758,207 743,808 727,994 728,384 

CargoVan 110,858 186,730 200,370 205,042 223,940 

All Trucks 6,870,108 7,401,127 7,241,586 7,222,548 7,311,287

a Volumes in this table are based on the pre-2011 NHTSA definition of Cars and Trucks.

Table A1.3-4 Vehicle Segment Volumesa

Reference Class 

Segment

Actual and Projected Sales Volume

2021 2022 2023 2024 2025

LargeAuto 384,191 353,301 352,705 345,006 356,435 

MidSizeAuto 3,604,960 3,635,168 3,732,222 3,781,545 3,835,289

CompactAuto 2,629,933 2,645,629 2,651,598 2,756,463 2,847,781

SubCmpctAuto 2,704,376 2,708,913 2,708,098 2,770,523 2,843,941

All Cars 9,265,881 9,282,884 9,382,100 9,588,366 11,461,493

LargePickup 1,352,502 1,302,512 1,251,253 1,226,935 1,215,296

SmallPickup 148,400 142,033 145,507 149,188 149,308 

LargeSUV 3,274,899 3,245,920 3,281,687 3,353,515 3,395,154

MidSizeSUV 1,266,485 1,238,672 1,219,552 1,247,145 1,258,695

SmallSUV 165,290 163,744 163,691 167,086 169,425 

MiniVan 720,675 713,307 712,312 695,336 700,287 

CargoVan 208,102 195,757 193,828 189,957 194,544 

All Trucks 7,193,932 7,062,072 7,030,352 7,094,332 5,504,662

a Volumes in this table are based on the pre-2011 NHTSA definition of Cars and Trucks.

Table A1.3-5 2011+ NHTSA Car and Truck Definition Based Volumes

Vehicle Type Actual and Projected Sales Volume

2008 2017 2018 2019 2020

Trucks 5,620,847 5,846,663 5,703,588 5,667,948 5,714,586
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Cars 8,220,517 10,338,280 10,266,989 10,454,435 10,826,981

Cars and Trucks 13,841,364 16,184,943 15,970,576 16,122,384 16,541,566

Table A1.3-6 2011+ NHTSA Car and Truck Definition Based Volumes

Vehicle Type Actual and Projected Sales Volume

2021 2022 2023 2024 2025

Trucks 5,618,286 5,505,720 5,468,789 5,475,941 5,504,662

Cars 10,841,528 10,839,236 10,943,663 11,206,758 11,461,493

Cars and Trucks 16,459,813 16,344,956 16,412,452 16,682,698 16,966,155

Table A1.3-7 also shows how the change in fleet make-up may affect the footprint 

distributions over time. The resulting data indicate that footprint will not change significantly 

between 2008 and 2025. There will be an increase in the number of cars sold (as compared to 

trucks), which will cause the average footprints for cars and trucks combined to be slightly 

smaller (about 2%). This is the result of AEO projecting an increased number of cars, and 

CSM predicting that most of that increase will be in the subcompact segment. 

Table A1.3-7 Production Foot Print Mean

Model Year Foot Print Mean 

Cars

Foot Print Mean for 

Trucks

Foot Print Mean for Cars & Trucks

Combined

2008 45.45 54.12 48.97

2017 44.94 53.93 48.19

2018 44.93 53.85 48.12

2019 44.92 53.76 48.03

2020 44.95 53.89 48.04

2021 44.93 53.81 47.96

2022 44.91 53.78 47.90

2023 44.93 53.66 47.84

2024 44.92 53.51 47.74

2025 44.92 53.47 47.69

Table A1.3-8 and Table A1.3-9 below show the changes in engine cylinders over the 

model years. The current assumptions show that engines will be downsized over the model 

years to which these rules apply. The biggest projected shift occurs between MY 2008 and 

2013. This shift is a projected consequence of the expected changes in class and segment mix 

as predicted by AEO and CSM, and does not represent engine downsizing attributable to the 

rules.
Appendix A 

A-8

Table A1.3-8 Truck Percentages of 4, 6, 8 Cylinder Engines by Model Year

Model Year

Percentage of 4 

Cylinders

Percentage of 6 

Cylinders

Percentage of 8 

Cylinders

2008 10.33% 56.40% 33.27%

2017 10.94% 63.67% 25.39%

2018 10.65% 64.51% 24.84%

2019 10.42% 65.47% 24.12%

2020 10.29% 65.57% 24.14%

2021 10.28% 66.33% 23.39%

2022 10.26% 66.74% 23.00%

2023 10.26% 67.73% 22.01%

2024 10.47% 68.09% 21.44%

2025 10.52% 68.22% 21.26%

Table A1.3-9 Car Percentages of 4, 6, 8 Cylinder Engines by Model Year

Model Year

Percentage of 4 

Cylinders

Percentage of 6 

Cylinders

Percentage of 8 

Cylinders

2008 56.99% 37.80% 5.20%

2017 60.63% 34.55% 4.82%

2018 60.70% 34.47% 4.83%

2019 60.72% 34.43% 4.85%

2020 60.39% 34.74% 4.87%

2021 60.75% 34.47% 4.78%

2022 61.19% 34.16% 4.65%

2023 61.05% 34.32% 4.63%

2024 61.12% 34.19% 4.68%

2025 61.20% 34.11% 4.69%

A1.3.4 How does manufacturer product plan data factor into the baseline?

In the spring and fall of 2009, many manufacturers submitted product plans in 

response to NHTSA’s request. NHTSA and EPA both have access to these plans, and both 

agencies have reviewed them in detail. A small amount of product plan data was used in the 

development of the baseline. The specific pieces of data are:

Wheelbase

Track Width Front

Track Width Rear

Curb Weight

GVWR (Gross Vehicle Weight Rating)
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The track widths, wheelbase, curb weight, and GVWR for vehicles could have been 

looked up on the internet (159 were), but were taken from the product plans when available 

for convenience. To ensure accuracy, a sample from each product plan was used as a check 

against the numbers available from Motortrend.com. These numbers will be published in the 

baseline file since they can be easily looked up on the internet.
Appendix A 

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Appendix A References 

All references can be found in Docket EPA-HQ-OAR-2009-0472.

1 WardsAuto.com: Used as a source for engine specifications. 

2 Motortrend.com and Edmunds.com: Used as a source for foot print and vehicle weight data.

3 Energy Information Administration’s 2009 Annual Energy Outlook. 

4 CSM World Wide, CSM World Wide is a paid service provider.
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Appendix B: Package Cost and Effectiveness

B1 Explanation of Technology Packages

As discussed briefly at the end of Chapter 3, EPA believes that manufacturers are 

likely to bundle technologies into ―packages‖ to capture synergistic aspects and reflect 

progressively larger CO2 reductions with additions or changes to any given package. In 

addition, manufacturers typically apply new technologies in packages during model 

redesigns—which occur once roughly every five years—rather than adding new technologies 

one at a time on an annual or biennial basis. This way, manufacturers can more efficiently 

make use of their redesign resources and more effectively plan for changes necessary to meet 

future standards.

Therefore, the approach taken by EPA for purposes of this Technical Assessment 

Report is to group technologies into packages of increasing cost and effectiveness. While 

developing its analysis for the 2012-2016 rulemaking, EPA employed 19 different vehicle 

types for modeling the entire fleet. For the current assessment, we have used the same 19 

vehicle types, with the exception that vehicle type 15 was replaced with a different baseline 

engine to provide us with a more appropriate set of technologies and packages for large cars 

with baseline V8 overhead valve engines. Each of these 19 vehicle types is mapped into one 

of six classes of vehicles: Subcompact, Small car, Large car, Minivan, Small truck, and Large 

truck. Note that, for the current assessment, EPA has created a new vehicle class called 

―Subcompact‖ which allows for greater differentiation of costs for this growing class of 

vehicles (such as the Honda Fit, the Toyota Yaris, and the new Ford Fiesta). Note also that 

these 19 vehicle types span the range of vehicle footprints—smaller footprints for smaller 

vehicles and larger footprints for larger vehicles—which served as the basis for the 2012-2016 

GHG standards. The resultant 19 vehicle types, their baseline engines and their descriptions 

are shown in Table B1-1.

Table B1-1: List of 19 Vehicle Types used to Model the Light-duty Fleet

Vehicle 

Type #

Base Engine Base 

Trans Vehicle Class Description

1 1.5L 4V DOHC I4 4sp AT Subcompact Subcompact car I4

2 2.4L 4V DOHC I4 4sp AT Small car Compact car I4

3 2.4L 4V DOHC I4 4sp AT Small car Midsize car/Small MPV I4

4 3.0L 4V DOHC V6 4sp AT Minivan Compact car/Small MPV V6

5 3.3L 4V DOHC V6 4sp AT Large car Midsize/Large car V6

6 4.5L 4V DOHC V8 4sp AT Large car Midsize car/Large car V8

7 2.6L 4V DOHC I4 (I5) 4sp AT Minivan Midsize MPV/Small truck I4

8 3.7L 2V SOHC V6 4sp AT Small truck Midsize MPV/Small truck V6

9 4.0L 2V SOHC V6 4sp AT Minivan Large MPV V6

10 4.7L 2V SOHC V8 4sp AT Minivan Large MPV V8

11 4.2L 2V SOHC V6 4sp AT Large truck Large truck/van V6

12 3.8L 2V OHV V6 4sp AT Large truck Large truck/MPV V6

13 5.7L 2V OHV V8 4sp AT Large truck Large truck/van V8

14 5.4L 3V SOHC V8 4sp AT Large truck Large truck/van V8

15 5.7L 2V OHV V8 4sp AT Large car Large car V8

16 3.5L 4V DOHC V6 4sp AT Minivan Large MPV V6

17 4.6L 4V DOHC V8 4sp AT Minivan Large MPV V8
Appendix B

B-2

18 4.0L 4V DOHC V6 4sp AT Large truck Large truck/van V6

19 5.6L 4V DOHC V8 4sp AT Large truck Large truck/van V8

To prepare inputs for the OMEGA model, EPA builds a ―master-set‖ of technology 

packages. The master-set of packages for each vehicle type are meant to reflect the most 

likely technology packages manufacturers would consider when determining their plans for 

complying with future standards (as well as technology pathways described in Chapter 3 and 

6). In other words, they are meant to reflect the most cost effective groups of technologies—

those that provide the best trade-off of costs versus fuel consumption improvements. This is 

done by grouping reasonable technologies in all possible permutations and ranking those 

groupings based on the Technology Application Ranking Factor (TARF).A Grouping 

―reasonable technologies‖ simply means grouping those technologies that are complementary 

(e.g., turbocharging plus downsizing) and not grouping technologies that are not 

complementary (e.g., dual cam phasing and coupled cam phasing). 

To generate the master-set of packages for each of the vehicle types, EPA has built 

packages in a step-wise fashion looking first at conventional gasoline technologies, then 

advanced gasoline technologies and then hybrid and other electrified vehicle technologies. 

This was done by presuming that auto makers would first concentrate efforts on conventional 

gasoline engine and transmission technologies paired with varying levels of mass reduction to 

improve fuel consumption. This is essentially the impact that the 2012-2016 rule will have as 

that rule did not rely heavily on advanced gasoline technologies or 

hybridization/electrification of the fleet. The initial levels of mass reduction considered were 

up to 15%.

B Different pathways matched more intensive mass reductions with more 

advanced technologies. 

Once the conventional gasoline engine and transmission technologies have been fully 

considered, we expect that auto makers would apply more complex (and costly) technologies 

such as advanced gasoline engines (turbocharged and cooled EGR technology for example)

and further mass reduction (beyond 15%) in both the conventional and advanced gasoline 

packages. 

From there, auto makers would most likely move to hybridization using one of two 

types of hybridization –P2 or 2-mode—depending on the vehicle type.C These hybrids could 

 

A The Technology Application Ranking Factor (TARF) is the factor used by the OMEGA model to rank 

packages and determine which are the most cost effective to apply. The TARF is calculated as the net 

incremental cost (or savings) of a package per kilogram of CO2 reduced by the package relative to the previous

package. The net incremental cost is calculated as the incremental cost of the technology package less the 

incremental discounted fuel savings of the package over 5 years. The incremental CO2 reduction is calculated as 

the incremental CO2/mile emission level of the package relative to the prior package multiplied by the lifetime 

miles travelled. More detail on the TARF can be found in the OMEGA model supporting documentation (see 

EPA-420-B-09-035).

B

Importantly, the mass reduction associated for each of the 19 vehicle types was based on the vehicle-type sales 

weighted average curb weight.

C

For the current assessment, we have considered P2 hybrids and 2-mode hybrids and have not considered 

power-split or other hybrid technologies. The 2-mode hybrid has been considered because it provides for 

hybridization of a vehicle while also maintaining acceptable towing capability. The P2 hybrid has been chosen 
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employ either conventional or advanced gasoline engines and would be paired with varying 

levels of mass reduction ranging from 15% up to 30%.

Lastly, for some vehicle types, we anticipate that auto makers would move to more 

advanced electrification in the form of both range extended electric vehicles (REEV)Dand full 

electric vehicles (EV). These also would be paired with varying levels of mass reduction 

from 15% up to 30%. In general the packages are generated in order of increasing complexity 

or cost. 

Focusing first on the conventional gasoline packages, the first step in creating these 

packages was to consider the 8 primary categories of conventional gasoline engine 

technologies. These are:

- Our ―anytime technologies‖ (ATT) which consist of low friction lubes, engine 

friction reduction, aggressive shift logic (automatic transmission only), early 

torque converter lock-up (automatic transmission only), and low rolling resistance 

tires.

- Variable valve timing (VVT) consisting of coupled cam phasing (CCP, for OHV 

and SOHC engines) and dual cam phasing (DCP, for DOHC engines)

- Variable valve lift (VVL) consisting of discrete variable valve lift (DVVL, for 

DOHC engines)

- Cylinder deactivation (Deac, considered for OHV and SOHC V8 engines)

- Gasoline direct injection (GDI)

- Turbocharging and downsizing (TDS, which always includes a conversion to GDI)

- Stop-start

- Mass reduction consisting, in this step, of 3%, 5%, 10% and 15%.

In this first step, we also considered the 3 primary transmission technologies. These 

are:

- 6 speed automatic transmission (6sp AT)

- 6 speed dual clutch transmission with wet clutch (6sp wet-DCT)

- 6 speed dual clutch transmission with dry clutch (6sp dry-DCT)

In considering the transmissions, we had to first determine how each transmission 

could reasonably be applied. DCTs, especially dry-DCTs, cannot be applied to every vehicle 

type due to low end torque demands at launch. In addition, wet-DCTs are more efficient than 

6sp ATs, and dry-DCTs are more efficient still. Further, each transmission has lower costs, 

respectively. Therefore, moving from 6sp AT to wet-DCT to dry-DCT as quickly as possible 

is preferable. Throughout this assessment, each of these transmissions were allowed on each 

 

because we believe that, in the timeframe of the current assessment, the P2 hybrid will provide the most cost 

effective approach to improving fuel consumption in vehicles that have no and/or comparatively low towing 

demands.

D We are using the term REEV synonymously with PHEV (plug-in hybrid electric vehicle) for the purposes of 

this analysis. 
Appendix B

B-4

vehicle type giving consideration to the expected towing demands and curb weights as shown 

in Table B1-2 For example, vehicle type 5 is equipped with a 4 speed automatic transmission 

in the baseline. In a package consisting of a 3% to 20% mass reduction, we believe this 

vehicle type could convert to a wet-DCT because the lighter weight results in reduced low end 

torque demands thus making the wet-DCT feasible. Upon reaching 25% mass reduction, the 

vehicle type could employ a dry-DCT because the even lighter weight results in further 

reduction in low end torque demands. We note that we have estimated that all vehicle types 

will employ DCTs rather than 6 speed automatic transmissions, because we believe that the 

wet-DCT is capable of meeting the towing demands of the light-duty fleet while providing 

better efficiency and lower costs than the 6 speed automatic transmission, and it is thus 

reasonable to assume that all manufacturers will choose to employ wet-DCTs rather than 6 

speed automatics.

Table B1-2: Application of Transmission Technologies in Building Packages

Vehicle 

Type #

Vehicle 

Class

Base 

Engine

Mass Reduction

0% 3% 5% 10% 15% 20% 25% 30%

1 Subcompact I4 4spAT 6sp dry-DCT

2 Small car I4 4spAT 6sp dry-DCT

3 Small car I4 4spAT 6sp dry-DCT

4 Minivan V6 4spAT 6sp wet-DCT 6sp dry-DCT

5 Large car V6 4spAT 6sp wet-DCT 6sp dryDCT

6 Large car V8 4spAT 6sp wet-DCT

7 Minivan I4 4spAT 6sp dry-DCT

8 Small truck V6 4spAT 6sp wet-DCT

9 Minivan V6 4spAT 6sp wet-DCT

10 Minivan V8 4spAT 6sp wet-DCT

11 Large truck V6 4spAT 6sp wet-DCT

12 Large truck V6 4spAT 6sp wet-DCT

13 Large truck V8 4spAT 6sp wet-DCT

14 Large truck V8 4spAT 6sp wet-DCT

15 Large car V8 4spAT 6sp wet-DCT

16 Minivan V6 4spAT 6sp wet-DCT

17 Minivan V8 4spAT 6sp wet-DCT

18 Large truck V6 4spAT 6sp wet-DCT

19 Large truck V8 4spAT 6sp wet-DCT

We start by first building a ―preliminary-set‖ of conventional gasoline packages for 

each vehicle type consisting of combinations of each of these 8 primary engine technologies. 

The initial packages represent what we expect a manufacturer will most likely implement on 

all vehicles, including low rolling resistance tires, changes to accommodate low friction 

lubricants, engine friction reduction, aggressive shift logic, early torque converter lock-up and

improved electrical accessories. Subsequent packages include more sophisticated gasoline 

engine and transmission technologies such as turbo/downsizing, GDI, increasing mass 

reduction and dual-clutch transmissions. This preliminary-set of conventional gasoline 
2017-2025 Technical Assessment

B-5

packages was ranked by its TARF for each vehicle type. The TARF ranking process 

eliminated some packages in favor of more cost effective packages. The packages that 

remained after the TARF ranking process were then included in the master-set of packages for 

each vehicle type.

Once the preliminary-set of conventional gasoline packages had been pared down and 

moved into the master-set of packages, the most effective (i.e., not the most cost effective, but 

simply the most effective) of the conventional gasoline packages was paired with increasing 

levels of mass reduction up to 30%. Also, the advanced gasoline packages come in—note that 

all advanced gasoline packages are turbo/downsized GDI engines equipped with cooled EGR, 

dual cam phasing and discrete variable valve lift. We have built one advanced gasoline 

package without stop-start technology and one with. Each of these is then paired with 

increasing levels of mass reduction up to 30%. Even though these advanced technologies are 

paired with increased mass reduction, the model is able to isolate the effect of these 

individually in order to examine the separate technology pathways described in Chapter 3 and 

6 of the TAR. The master-set of packages now consists of the most cost effective 

conventional gasoline packages with mass reductions ranging from 0% to 15%, the most 

effective conventional gasoline package with increasing levels of mass reduction up to 30%, 

and advanced gasoline packages (both with stop-start and without) with mass reduction levels 

ranging from 15% to 30%.

The next packages after the conventional and advanced gasoline packages are the 

HEVs. As noted, we have considered P2 and 2-mode HEVs for this assessment as discussed 

in section B4E. The agencies assumed that, for some of the vehicles types ranging in size up 

to and including ―Large Car‖, ―Minivan‖ and ―Small Truck‖, towing capacity could be 

reduced to approximately 1,500 poundsFon HEV models and that these vehicles would use a 

P2 HEV configuration. As described in Chapter 3, in some cases this reflects a loss in towing 

utility as compared to the baseline vehicle. For such vehicle types, consumers requiring 

greater towing capacity would select a non-HEV powertrain. The agencies assumed that the 

HEV versions of most of the larger vehicle types would require the same towing capacity as 

the baseline vehicle and a 2-mode HEV powertrain was selected for these vehicle types. The 

breakdown of HEV application is shown in Table B1-3.

Table B1-3: Types of Hybridization Considered in this Assessment

Vehicle 

Type #

Vehicle 

Class Base Engine HEV Type

1 Subcompact I4 P2

2 Small car I4 P2

3 Small car I4 P2

4 Minivan V6 P2

 

E

P2 hybrids are defined and described in Chapter 3 (sction 3.2.3)
Appendix B

B-6

5 Large car V6 P2

6 Large car V8 P2

7 Minivan I4 P2

8 Small truck V6 P2

9 Minivan V6 2-mode

10 Minivan V8 2-mode

11 Large truck V6 2-mode

12 Large truck V6 P2

13 Large truck V8 2-mode

14 Large truck V8 2-mode

15 Large car V8 P2

16 Minivan V6 P2

17 Minivan V8 2-mode

18 Large truck V6 P2

19 Large truck V8 2-mode

As done with conventional gasoline packages, we began with a preliminary-set of 

HEV packages that paired the HEV powertrain with increasing levels of engine technologies. 

For example, the preliminary-set of HEV packages would pair the HEV powertrain first with 

a very basic gasoline engine (e.g., anytime technologies (ATT) and variable valve timing 

(VVT), such as dual cam phasing (DCP)), then a slightly more sophisticated gasoline engine 

(e.g., ATT, DCP, GDI), then a more sophisticated gasoline engine (e.g., ATT, DCP, GDI, 

turbo/downsize), then an advanced gasoline engine (e.g., ATT, DCP, variable valve lift, GDI, 

turbo/downsize, cooled EGR), etc. We then ranked the preliminary-set of HEV packages 

according to TARF to generate the most cost effective set of HEV packages for each vehicle 

type that would then be included in the master-set of packages.

In general, the result of the TARF ranking of the preliminary-set of packages resulted 

in a master-set of packages that included three versions of HEV for each vehicle type. The 

first version employs a simple conventional gasoline engine such as one equipped with 

anytime technologies and valve timing control. The second employs a 

downsized/turbocharged gasoline engine and gasoline direct injection. The third employs an 

advanced gasoline engine with turbo/downsizing, direct injection and cooled EGR. Each of 

these versions of HEV was then paired with mass reduction levels ranging from 15% to 30%.

The last step was to build the REEVs and EVs for vehicle types 1 through 8 and 15. 

The other vehicle types were not considered for electrification beyond HEVs for purposes of 

the current analysis, either because of their expected towing demands or because of their high 

vehicle weight which would make the electrification of the vehicle prohibitively expensive. 

We have developed 2 primary types of REEV packages and 3 primary types of EV packages

all of which are included in the master-set of packages. The REEVs consist of packages with 

battery packs capable of 20 miles of all electric operation (REEV20) and packages with 

battery packs capable of 40 miles of all electric operation (REEV40). For EVs, we have built 

packages capable of 75, 100 and 150 miles of all electric operation, EV75, EV100 and 

EV150, respectively. These ranges were selected to represent an increasing selection of 

ranges (and costs) that consumers will require and that we believe will be available in the 
2017-2025 Technical Assessment

B-7

2020 timeframe. For each of these packages, we have estimated specific battery-pack costs 

for systems placed in vehicles with 15% and 20% mass reduction to the ―glider‖ (i.e., the 

vehicle less any powertrain elements). We have then paired each REEV with 15%, 20%, 25%

and 30% mass reduction and each EV with 15% and 20% mass reduction. Note that the 

REEVs with 25% and 30% mass reduction are not assumed to be constructed with the smaller 

battery packs and electric motors that would be possible with the 30%-lighter vehicle. This 

may make our estimates of cost effectiveness for REEVs with these higher mass reductions

conservative since, while the higher mass reduction means lower fuel consumption and CO2

emissions, those benefits are balanced against the higher costs of further mass reduction 

without accounting for the lower cost of a smaller battery pack and motor. The end result is a 

master-set of over 40 packages for those vehicle types with REEVs and EVs and as many as 

30 packages for those vehicle types without REEVs and EVs. Because of the large number of 

total packages, Table B1-4 shows only the resultant master-set of packages for vehicle type 5, 

a large car with a V6 DOHC engine in the baseline. Note that a complete master-set of 

packages for each vehicle type along with their costs and effectiveness estimates is contained 

in a memorandum to the docket for this report.1 Importantly, for each level of mass reduction, 

there is some level of expected engine downsizing made possible due to the lower vehicle 

weight. The analysis does not account for any cost credit for downsizing that consists only of 

minor displacement changes (i.e., less than 20%)—only because we have not yet developed 

estimated costs or savings of doing so—even though the engine itself would contain 

somewhat less material. However, when a downsize occurs that consists of cylinders being 

removed (in the case of V8 to V6 and V6 to I4 downsizing) or a large displacement change 

(in the case of an I4 to smaller I4), we do consider the cost implications of the downsizing 

because we have tear-down data upon which to base our cost estimates.

Table B1-4: Technology Packages used in OMEGA for Vehicle Type 5, Large Car V6

Tech 

Pkg #

Mass 

Rdxn Package Technologies Transmission Description

500 0% 3.3L 4V DOHC V6 4sp AT Baseline Package

501 3% 4V DOHC I4+ATT+DCP+GDI+TDS 6sp DCT-wet ATT=Anytime techs

502 5% 4V DOHC I4+ATT+DCP+GDI+TDS 6sp DCT-wet DCP=dual cam phasing

503 15% 4V DOHC I4+ATT+DCP+GDI+TDS 6sp DCT-wet

GDI=gasoline direct 

injection, 

TDS=turbo/downsize

504 15% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS 6sp DCT-wet DVVL=discrete variable 

valve lift

505 15% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS 6sp DCT-wet SS=stop-start

506 15% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR 6sp DCT-wet EGR=cooled EGR

507 15% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR 6sp DCT-wet

508 20% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS 6sp DCT-wet

509 25% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS 6sp DCT-dry

510 30% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS 6sp DCT-dry

511 20% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR 6sp DCT-wet

512 25% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR 6sp DCT-dry

513 30% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR 6sp DCT-dry

514 20% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR 6sp DCT-wet

515 25% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR 6sp DCT-dry

516 30% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR 6sp DCT-dry

517 15% 4V DOHC I4+ATT+DCP+DS+HEV 6sp DCT-wet HEV=P2 for this vehicle 

type

518 20% 4V DOHC I4+ATT+DCP+DS+HEV 6sp DCT-wet

519 25% 4V DOHC I4+ATT+DCP+DS+HEV 6sp DCT-dry
Appendix B

B-8

520 30% 4V DOHC I4+ATT+DCP+DS+HEV 6sp DCT-dry

521 15% 4V DOHC I4+ATT+DCP+GDI+TDS+HEV 6sp DCT-wet

522 20% 4V DOHC I4+ATT+DCP+GDI+TDS+HEV 6sp DCT-wet

523 25% 4V DOHC I4+ATT+DCP+GDI+TDS+HEV 6sp DCT-dry

524 30% 4V DOHC I4+ATT+DCP+GDI+TDS+HEV 6sp DCT-dry

525 15% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV 6sp DCT-wet

526 20% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV 6sp DCT-wet

527 25% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV 6sp DCT-dry

528 30% 4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV 6sp DCT-dry

529 15% 4V DOHC I4+ATT+GDI+DS+REEV20 6sp DCT-wet

530 20% 4V DOHC I4+ATT+GDI+DS+REEV20 6sp DCT-wet

531 30% 4V DOHC I4+ATT+GDI+DS+REEV20 6sp DCT-dry

532 15% 4V DOHC I4+ATT+GDI+DS+REEV40 6sp DCT-wet

533 20% 4V DOHC I4+ATT+GDI+DS+REEV40 6sp DCT-wet

534 30% 4V DOHC I4+ATT+GDI+DS+REEV40 6sp DCT-dry

535 15% EV75 (27kWh, 75 miles onroad @ 314 Wh/mi) N/A

536 20% EV75 (27kWh, 75 miles onroad @ 304 Wh/mi) N/A

537 15% EV100 (39kWh, 100 miles onroad @ 323 Wh/mi) N/A

538 20% EV100 (39kWh, 100 miles onroad @ 314 Wh/mi) N/A

539 15% EV150 (63kWh, 150 miles onroad @ 346 Wh/mi) N/A

540 20% EV150 (63kWh, 150 miles onroad @ 337 Wh/mi) N/A

To reiterate, some preliminary packages considered during the package creation

process were determined to not be cost-effective when ranked with other packages for the 

given vehicle type. For example, the packages shown in Table B1-4 move immediately from 

the baseline package to a rather complex turbo/downsized package in package number 501. 

This does not mean that we did not consider packages consisting only of, for example, DCP 

or DCP+GDI when generating our preliminary-set of packages. Rather, it means that those 

packages simply were not as cost effective in this analysis, based on their Technology 

Application Ranking Factor (TARF), as was the package shown as #501. For that reason, the 

intermediate packages that were part of the preliminary-set of packages have simply been 

eliminated from consideration and have not been included in the master-set of packages since 

OMEGA will never pick them given the levels of potential standards considered in this 

Technical Assessment Report. 

Once the master-set of packages is complete, they are all ranked once again based on 

TARF to generate the ―ranked-set‖ of packages for each of the technology paths discussed in 

Section 3.3 of the main report. While the master-set of packages is considered unchanging (at 

least in the context of this current analysis), the ranked-set of packages is different for each 

technology pathway because each pathway has different levels of, for example, mass 

reduction caps. For a technology pathway with a mass reduction cap of 15%, those packages 

with mass reductions greater than 15% would be eliminated from consideration and would not 

be included in the ranked-set of packages. Likewise, those packages having mass reductions 

greater than 20% would be eliminated in a technology pathway having a mass reduction cap 

of 20%. The package ranking also changes for each given year since technology costs and, 

hence, package costs change year-to-year. As a result, a ranked-set of packages in 2020 may 

or may not include the same packages as a ranked-set of packages in 2025 even if using the 

same mass reduction cap, and they may or may not be ranked in the same order.
2017-2025 Technical Assessment

B-9

B2 Engine Technologies

B2.1 Updated Tear-down Costs from FEV

As noted in Chapter 3, the agencies have reconsidered many of the costs used in the 

2012-2016 joint final rule where those costs were based on tear-down studies conducted by 

FEV under contract to EPA. We have reconsidered these costs because, in the 2012-2016 

light-duty final rule, the agencies relied on the FEV tear-down study findings in part for 

estimating the cost of several technologies. However, for some of the technologies, NHTSA 

and EPA modified FEV’s actual estimated costs. This was done because FEV based their 

costs on the assumption that these technologies would be mature when produced in large 

volumes (450,000 units or more). The agencies believed that there was some uncertainty 

regarding each manufacturer’s near-term ability to employ the technology at the volumes 

assumed in the FEV analysis with fully learned costs. There was also the potential for near 

term (earlier than 2016) supplier-level costs to be higher than those considered in the FEV 

analysis because existing equipment and facilities need to be converted to the production of 

new technologies and may lead to stranded capital if done too rapidly.G However, the 

agencies consider the FEV results to be valid for the 2017-2025 timeframe because the 

limitations considered in the 2012-2016 light-duty rule should no longer exist and sales 

volumes of 450,000 units are likely by then due to, at least in part, the new GHG and fuel 

economy requirements.

We reiterate that the agencies believe that the best method to derive technology cost 

estimates is to conduct studies involving tear-down and analysis of actual vehicle 

components. A tear-down analysis involves breaking down a technology into its fundamental 

parts and manufacturing processes by completely disassembling vehicles and vehicle 

subsystems and precisely determining what would be required for its production. More 

details about tear-down studies can be found in the studies supporting the 2012-2016 lightduty final rule as well as the FEV and Munro Associates report for EPA.2

 This tear-down 

method of costing technologies is often used by manufacturers to benchmark their products 

against competitive products. Historically, vehicle and vehicle component tear-down has not 

been done in large scale by researchers and regulators due to the expense required for such 

studies. 

To date, such tear-down studies have been completed on the five technologies listed 

below. These completed tear-down studies provide a thorough evaluation of the component 

or system cost relative to their baseline (or replaced) technologies. A more detailed 

description of these technologies can be found in the Technical Support Document prepared 

for the 2012-2016 light-duty final rule.3For these technologies, the agencies have relied on 

the tear-down data available and scaling methodologies used in EPA’s ongoing study with 

FEV. 

 

G

Stranded Capital is defined as manufacturing equipment and facilities that cannot be used in the production of 

a new technology.
Appendix B

B-10

1. Stoichiometric gasoline direct injection and turbocharging with engine downsizing 

(TDS) for a large DOHC (dual overhead cam) 4 cylinder engine to a smaller 

DOHC 4 cylinder engine.

2. Stoichiometric gasoline direct injection and turbo charging with engine 

downsizing for a SOHC (single overhead cam) 3 valve/cylinder V8 engine to a 

SOHC V6 engine. 

3. Stoichiometric gasoline direct injection and turbo charging with engine 

downsizing for a DOHC V6 engine to a DOHC 4 cylinder engine. 

4. 6-speed automatic transmission replacing a 5-speed automatic transmission.

5. 6-speed wet dual clutch transmission (DCT) replacing a 6-speed automatic 

transmission.

FEV’s costing methodology for these studies has been published and has been peer 

reviewed.4 Using this tear down costing methodology, FEV has developed costs for each of 

the above technologies. In addition, using the studies listed above, FEV and EPA were able 

to extrapolate the engine downsizing costs for the following scenarios to estimate costs 

presented in the 2012-2016 rule: 

1. Downsizing a SOHC 2 valve/cylinder V8 engine to a DOHC V6.

2. Downsizing a DOHC V8 to a DOHC V6.

3. Downsizing a SOHC V6 engine to a DOHC 4 cylinder engine.

4. Downsizing a DOHC 4 cylinder engine to a DOHC 3 cylinder engine.

The costs used in the 2012-2016 rule and the updated costs used in this assessment are 

shown in Table B2.1-1.

Table B2.1-1: Comparison of Stoichiometric Gasoline Direct Injection, 

Turbo/Downsizing and Transmission Costs, Inclusive of Markups, used in the 2012-2016 

Rulemaking versus this Assessment

2012-2016 

rulemaking; 

applicable to the 

2012MY

(2007 dollars)

2012-2016 

rulemaking; 

applicable to the 

2016MY

(2007 dollars)

Assessment 

Report; 

applicable to the 

2017MY

(2008 dollars)

Assessment 

Report; 

applicable to the 

2025MY

(2008 dollars)

Stoichiometric GDI (I3/I4)a$236 $209 $213 $181

Stoichiometric GDI (V6) a$341 $301 $370 $299

Stoichiometric GDI (V8) a$390 $346 $446 $360

Turbo/Downsize I4 DOHC 

to I3 DOHCb $395 $349 $287 $245

Turbo/Downsize I4 DOHC 

to smaller I4 DOHCb $441 $391 $365 $311

Turbo/Downsize V6 

DOHC to I4 DOHCb $168 $149 -$27 -$3

Turbo/Downsize V6 SOHC 

to I4 DOHCb $365 $323 $110 $107

Turbo/Downsize V6 OHV 

to I4 DOHCb $872 $771 $754 $628

Turbo/Downsize V8 

DOHC to V6 DOHCb $669 $592 $491 $428

Turbo/Downsize V8 SOHC $923 $816 $649 $555
2017-2025 Technical Assessment

B-11

2V/cyl to V6 DOHC

Turbo/Downsize V8 SOHC 

3V/cyl to V6 DOHCb $832 $736 $590 $507

Turbo/Downsize V8 OHV 

to V6 DOHCb $1,242 $1,099 $1,101 $920

6 speed automatic 

transmission (from a 4 

speed automatic 

transmission) a

$112 $99 -$13 -$10

6 speed dual wet-clutch 

transmission (from a 4 

speed automatic 

transmission) a

$104 $92 -$134 -$108

6 speed dual dry-clutch 

transmission (from a 4 

speed automatic 

transmission) a

$53 $47 -$190 -$153

a Low complexity ICMs applied: 2012MY=1.11; 2016MY=1.11; 2017MY=1.17; 2025MY=1.13. The 2012MY and 

2016MY ICMs differ from the 2017MY ICM—all considered near term—due to factors described in Section 3.2.5 of the 

main report. The 2025MY ICM is a long term ICM.

b Medium complexity ICMs applied: 2012MY=1.25; 2016MY=1.25; 2017MY=1.31; 2025MY=1.19. The 2012MY and 

2016MY ICMs differ from the 2017MY ICM—all considered near term—due to factors described in Section 3.2.5 of the 

main report. The 2025MY ICM is a long term ICM.

B2.2 Advanced Gasoline Cost and Effectiveness

B2.2.1 Turbocharged/downsized Engines with Gasoline Direct Injection

In the 2012-2016 final rule, the agencies estimated the combined effectiveness of 

turbocharging, engine downsizing and GDI in reducing GHG emission to be 7%. Recent data 

supports GHG effectiveness in the range of 12 to 30% depending on the extent of engine 

downsizing for a given engine torque requirement.5,6,7Taking into consideration the 

availability of more recent published data and confidential business information, the Agencies 

estimate the effectiveness of a Turbocharged GDI with single-stage turbocharging, dual camphasing and with downsizing consistent with a BMEP level of approximately 22-24 bar to be 

15%. 

B2.2.2 Cooled EGR

A new technology considered for this assessment was cooled EGR with 

turbocharging. This technology was described briefly in the 2012-2016 GHG and CAFE final 

rule but the technology was not used in the cost and effectiveness analysis. Cooled EGR can 

prevent combustion knock and thus allows for an increase in engine compression ratio and/or 

more aggressive engine downsizing when combined with turbocharging and gasoline direct 

injection while maintaining torque output and vehicle performance. Cooled EGR with 

aggressive engine downsizing (approximately 24-bar BMEP), single-stage turbocharging, 

dual cam phasing and discrete variable valve lift has been estimated by Ricardo to reduce 

CO2 emissions over both the UDDS and highway fuel economy test by 23%.8 The 

incremental effectiveness of cooled EGR relative to a downsized, turbocharged GDI engines 
Appendix B

B-12

without EGR has been estimated to reduce BSFC by various sources to be approximately 5 to 

13%.5,9,10,11 Based on the cited publically available data and confidential business 

information, the Agencies estimate the incremental effectiveness of cooled EGR with singlestage variable geometry turbocharging and with downsizing consistent with approximately 

24-bar BMEP to be 6% relative to turbocharging, downsizing and GDI without cooled EGR

as described in section B2.2.1; and 20% relative to a baseline 2008 PFI engine. We expect to 

update the effectiveness values of this technology for the NPRM based on vehicle simulation 

modeling currently being conducted under an EPA contract with Ricardo. 

The costs for the technology here build upon the costs presented in the 2012-2016 rule 

which showed costs of $75 for an EGR cooler, $20 for an EGR valve and $20 for associated 

piping for a total direct manufacturing cost of $115 (2007 dollars). We have updated each of 

those costs to 2008 dollars with the results being $77, $20 and $20, for a total of $117. To 

provide sufficient transient engine control, we have assumed that a dual-loop EGR system 

will be used with both high and low pressure EGR loops. We have doubled EGR component

costs to $235 to reflect components in both EGR loops and have added a $5 venturi to provide 

for EGR flow from the low pressure exhaust system to the high pressure intake system, thus 

giving a total of $240 for the cooled EGR portion of the system. Because the system is 

expected to employ higher levels of boost over a broader range of flow conditions than the 

conventional gasoline turbocharged system, we have also included a 1.5x factor to the 

turbocharger costs to cover the incremental cost increase of a variable geometry turbocharger. 

In other words, the turbocharger system cost is 1.5x greater on engines with cooled EGR than 

on downsized, turbocharged engines without cooled EGR. This was estimated based on 

engineering judgment with input from suppliers. Therefore, to the $240 value, we have added 

$620 for I-configuration engines (1.5x the single turbocharger cost of $413 equals $620) and 

$1,043 (1.5x the twin turbocharger cost of $695 equals $1,043) for V-configuration engines

(one turbocharger per cylinder bank, which is conservative as it is possible that not all Vconfiguration engines will use twin turbochargers). The results being $859 ($240+$620) for 

I-configuration engines and $1,283 ($240+$1,043) for V-configuration engines (direct 

manufacturing costs, 2008 dollars, 2012MY). All of the costs stated thus far represent direct 

manufacturing costs in 2008 dollars and are applicable to the 2012 model year. We consider 

time based learning to be applicable to this advanced gasoline technology. The resultant 

direct manufacturing cost and marked up costs are shown in Table B2.2-1 Importantly, these 

costs shown here do not represent package costs since they do not include the anytime 

technologies,H DCP, DVVL, GDI, or downsizing related costs or other technologies that 

might be included in an advanced gasoline package (such as stop-start or hybridization).

Table B2.2-1: Cooled EGR System Costs (2008 dollars)

Direct Mfg Costs Costs with ICM

Year 2012 2020 2025 2012 2020 2025

I-configuration engines $859 $701 $634 $1,125 $878 $754

V-configuration engines $1,283 $1,048 $947 $1,681 $1,304 $1,127

 

H Anytime technologies are simpler technologies that can be added outside the normal redesign cycle, thus they 

can be implemented anytime. An example is low rolling resistance tires.
2017-2025 Technical Assessment

B-13

ICM applied 1.31 1.31 1.19

B3 Transmission Technologies

B3.1 6, 7, and 8 speed Automatic Transmissions

As discussed in the 2012-2016 rule, manufacturers can choose to replace 4- and 5-

speed transmission with 6-, 7-, or 8-speed automatic transmissions. Additional ratios allow 

for further optimization of engine operation over a wider range of conditions, but this is 

subject to diminishing returns as the number of speeds increases. As additional planetary gear 

sets are added (which may be necessary in some cases to achieve the higher number of ratios), 

additional weight and friction are introduced. Also, the additional shifting of such a 

transmission can be perceived as bothersome to some consumers, so manufacturers need to 

develop strategies for smooth shifts. Some manufacturers are replacing 4- and 5-speed 

automatics with 6-speed automatics, and 7- and 8-speed automatics have also entered 

production, albeit in lower-volume applications in luxury and performance oriented cars.

As discussed in the 2012-2016 rule, confidential manufacturer data projected that 6-

speed transmissions could incrementally reduce fuel consumption by 0 to 5 percent from a 

baseline 4-speed automatic transmission, while an 8-speed transmission could incrementally 

reduce fuel consumption by up to 6 percent from a baseline 4-speed automatic transmission. 

GM has publicly claimed a fuel economy improvement of up to 4 percent for its new 6-speed 

automatic transmissions.12 The 2008 EPA Staff Technical Report found a 4.5 to 6.5 percent 

fuel consumption improvement for a 6-speed over a 4-speed automatic transmission.13 Based 

on this information, the agencies estimated that the conversion to a 6-,7- and 8-speed 

transmission from a 4 or 5-speed automatic transmission with IATC would have an 

incremental fuel consumption benefit of 1.4 percent to 3.4 percent, for all vehicle classes. 

From a baseline 4 or 5 speed transmission without IATC, the incremental fuel consumption 

benefit would be approximately 3 to 6 percent, which is consistent with the EPA Staff Report 

estimate.

The agencies reviewed these effectiveness estimates and concluded that they remain 

accurate. The GHG model estimates the packaged effectiveness of 4.5 to 6.5 percent.

The cost associated with 6 speed automatic transmissions has been updated for this 

assessment relative to the estimates presented in the 2012-2016 rule. These updated costs are 

presented above in Table B2.1-1 Dual Clutch Transmissions / Automated Manual 

Transmissions.

An Automated Manual Transmission (AMT) is mechanically similar to a conventional 

manual transmission, but shifting and launch functions are automatically controlled by the 

electronics. There are two basic types of AMTs, single-clutch and dual-clutch (DCT). A 

single-clutch AMT is essentially a manual transmission with automated clutch and shifting. 

Because of shift quality issues with single-clutch designs, DCTs will likely be far more 

common in the U.S. and are the basis of the estimates that follow. A DCT uses separate 

clutches (and separate gear shafts) for the even-numbered gears and odd-numbered gears. In 

this way, the next expected gear is pre-selected, which allows for faster and smoother shifting. 
Appendix B

B-14

For example, if the vehicle is accelerating in third gear, the shaft with gears one, three and 

five has gear three engaged and is transmitting power. The shaft with gears two, four, and six 

is idle, but has gear four engaged. When a shift is required, the controller disengages the oddgear clutch while simultaneously engaging the even-gear clutch, thus making a smooth shift. 

If, on the other hand, the driver slows down instead of continuing to accelerate, the 

transmission will have to change to second gear on the idling shaft to anticipate a downshift. 

This shift can be made quickly on the idling shaft since there is no torque being transferred on 

it.

In addition to single-clutch and dual-clutch AMTs, there are also wet clutch and dry 

clutch designs which are used for different types of vehicle applications. Wet clutch AMTs 

offer a higher torque capacity that comes from the use of a hydraulic system that cools the 

clutches. Wet clutch systems are less efficient than the dry clutch systems due to the losses 

associated with hydraulic pumping. Additionally, wet AMTs have a higher cost due to the 

additional hydraulic hardware required.

Overall, DCTs likely offer the greatest potential for effectiveness improvements 

among the various transmission options presented in this report because they offer the 

inherently lower losses of a manual transmission with the efficiency and shift quality 

advantages of electronic controls. The lower losses stem from the elimination of the 

conventional lock-up torque converter, and a greatly reduced need for high pressure hydraulic 

circuits to hold clutches or bands to maintain gear ratios in automatic transmissions. 

However, the lack of a torque converter will affect how the vehicle launches from rest, so a 

DCT will most likely be paired with an engine that offers sufficient torque at low engine 

speeds to allow for adequate launch performance.

Referring to the 2012-2016 rule, these transmissions offer an effectiveness of 9.5 to 

14.5 percent over a 4-speed automatic transmission. The agencies conclude that 8 to 13 

percent effectiveness is still appropriate for this rule. The costs associated with 6 speed dual 

clutch transmissions have been updated for this assessment relative to the estimates presented 

in the 2012-2016 rule. These updated costs are presented above in Table B2.1-1. EPA had 

hoped to include in this assessment FEV-generated tear-down cost estimates for an 8 speed 

dual clutch transmission. Unfortunately, that work was not complete in time, but it is 

expected to be used in the upcoming federal NPRM. 

B4 Vehicle Technologies

B4.1 Aerodynamic Improvement Cost and Effectiveness

This can be achieved via two approaches, either reducing the drag coefficients or 

reducing vehicle frontal area. To reduce drag coefficients, skirts, air dams, underbody covers, 

and more aerodynamic side view mirrors can be applied, or the vehicle ride height can be 

lowered. In addition to the standard aerodynamic treatments, the agencies have included a 

second level of aerodynamic technologies (Aero 2) which could include active grille shutters, 

rear visors, and larger under body panels. The GHG and fuel economy effectiveness of 2% is 

unchanged from estimates used for 2016 model year vehicles in the 2012-2016 final rule, and 

is based on a 10% assumed reduction in aerodynamic drag coefficient . This second level of 
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B-15

aerodynamic technologies was not considered in the 2012-2016 light-duty rule and, as such, 

the estimated costs are new and are presented in Table B4.1-1 along with the first level (Aero 

1) as used in the 2012-2016 rule. Effectiveness for Aero 2 is based on an additional 10% 

reduction in aerodynamic drag coefficient from the 2008 baseline and provides another 2% 

reduction in GHG. Note that we apply time based learning to aerodynamic improvements.

Table B4.1-1: Costs Associated with Aerodynamic Improvements (2008 dollars)

Direct Manufacturing Costs (applicable to the 2015MY)

Technology Quantity $/unit $/vehicle

Low

$/vehicle

High

Aero 1 (incremental to base vehicle)

Air dam 1 $15-20 $15 $20

Tire spats 4 $2.50 $10

Under body panels 1 $15-20 $15 $20

Total (Average=$40) $30 $50

Aero 2 (incremental to base vehicle)

Under body panels 3, 4 $10-20 $30 $80

Active grill shutters 1 $25-40 $25 $40

Rear visors – hood, liftgate, tailgate 1 $15-20 $15 $20

Low profile roof rack – stowable cross bows 1 $30 $30

Total (Average=$120) $70 $170

Marked up costs

Technology Year 2015 2020 2025

Aero 1 (ICM: Near term=1.17; Long term=1.13) $47 $40 $36

Aero 2 (ICM: Near term=1.31; Long term=1.19) $157 $128 $115

B4.2 Electrified Vehicles Costing – HEV, PHEV, and EV Vehicles

While the overall methodology for costing electrified vehicles has not changed from 

the 2012~2016 rule the scaling and cost basis for both batteries and electric motors has been 

modified. Specifically, cost information developed by Oak Ridge National Laboratory 

(ORNL) on electric motors has been applied, as well as battery costing information from 

Argonne National Laboratory (ANL). Refer to the Technical Support Document (TSD)14 for 

the 2012-2016 rule for a full description of the electrified vehicle costing methodology.

B4.2.1 Changes to the 2017-2025 Electrified Vehicle Costing

Unless otherwise noted, the cost basis and scaling for electrified vehicles in the 2017-

2025 analysis is identical to that used in the 2012-2016 rule. There are, however, several 

changes to the cost basis due to various factors. The first was agreement within the agencies 

that the mass of electrified vehicles would continue to be reduced while energy densities of 

batteries are expected to increase. These trends made the current battery and motor sizing 

strategies inappropriate for this analysis. In addition, recent data from ANL, which has been 

corroborated with battery manufacturer data, indicates that battery costs will be dependent on 

not only the annual production volume, but also the ratio of the power to energy. The 

agencies, once again, determined that the application of a fixed $/kW-hr value was not 

appropriate going forward. One of the caveats in applying the ANL cost model was that it 
Appendix B

B-16

was highly dependent of production volumes, volumes at which batteries will on be produced 

until approximately MY 2025. As such, the electrified vehicle costing model was to apply 

time based learning to the non-battery costs, as those are based on the 2012 -2016 rule, and 

treat the ANL battery costs as 2025 values. With regard to motor costs, the agencies 

leveraged a cost study performed by ORNL on the Toyota Prius15 motor costs and applied the 

ORNL results directly. Further detail for each of these considerations is provided below.

B4.2.1.1 P2 Hybrid Electric Vehicles

A P2 hybrid is a vehicle with an electric drive motor coupled to the engine crankshaft 

via a clutch. The engine and the drive motor are mechanically independent of each other, 

allowing the engine or motor to power the vehicle separately or combined. This is similar to 

the Honda HEV architecture with the exception of the added clutch between the flywheel or 

flexplate and the electric motor, additional battery capacity, and increased electric motor 

power. Examples P2 hybrids include the 2011 Hyundai Sonata Hybrid, 2010 Hyundai Elantra 

LPI HEV (Korean market only), the 2011 Infinity G35 Hybrid and the 2011 Volkswagen 

Touareg Hybrid. The agencies believe that the P2 is an example of a ―strong‖ hybrid 

technology that is typical of what we will see in the timeframe of this rule. The agencies 

could have equally chosen the power-split architecture as the representative HEV architecture. 

These two HEV’s have comparable average GHG effectiveness values (combined city and 

highway fuel economy), though the P2 systems may have lower cost due to reduced number 

of parts and complexity. 

The Agencies estimated the effectiveness of the P2 hybrid system to be 30% within 

our analysis. The effectiveness when combined with a DCT transmission is approximately 

37%. The effectiveness used for vehicle packages with the P2 hybrid configuration within this 

analysis reflects a conservative estimate of system performance. Vehicle simulation modeling 

of technology packages using the P-2 hybrid configuration is currently underway under 

contract with Ricardo Engineering. The agencies plan to update the effectiveness of hybrid 

electric vehicle packages using the new Ricardo vehicle simulation modeling runs prior to the 

NPRM.

Hybrid effectiveness was also applied differently across vehicle classes within this 

analysis when compared to the 2012-2016 rule. Previously, the Agencies assumed less engine 

downsizing and reduced effectiveness with increasing vehicle size to preserve some lighttowing capability for large cars, CUVs, minivans and small light trucks. For this analysis, P2 

hybrid packages were only applied to vehicles with reduced towing capability (SAE Class I or 

less) and the relative effectiveness due to engine downsizing with the P2 hybrid package was 

applied equally across all vehicle categories capable of receiving the P2 hybrid package in the 

Omega model. 
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Figure B4.2-1: Functional schematic of P2 hybrid electric vehicle powertrain 

configuration (not to scale).

B4.2.1.2 Battery and Motor Sizing

Baseline vehicle effective power-to-weight ratioI was used to approximate equivalent 

performance for EVs, PHEVs and P2 hybrids. Electric motors were sized based on 

maintaining this ratio for EV, PHEV and hybridJvehicles. In addition, some level of mass 

reduction is expected to be realized for these types of vehicles, so the motor sizing was 

dependent on the final, mass reduced, vehicle. Motor size for PHEVs assumed full vehicle 

performance could be achieved on electric motor drive only. The Agencies scaled P2 hybrid 

motors to represent 20% of the vehicle’s (combined) effective power, as supported by 

manufacturer’s confidential information.

The battery packs were sized to provide 75, 100 or 150 mile on-roadKranges in the 

case of EVs and 20 or 40 mile on-road ranges in the case of PHEVs. Battery sizing for EVs 

and PHEVs was based on a vehicle energy demand estimate (derived from EPA’s lumped 

parameter model) used to determine each vehicle’s electric energy consumption, in Wh/mile, 

for future EV, PHEV and hybrid packages (which considers road load and weight reductions). 

 

I To compare with conventional ICE-powered vehicles, we use ―effective‖ vehicle power -defined here as the 

peak combined power of the vehicle’s engine and electric motor. In the case of P2 hybrids it is assumed that the 

peak rated power values are additive, although this is not necessarily true for other architectures (such as powersplit hybrids, where the engine and motor power peaks do not occur at the same operating speed)

J Vehicle weight reduction when applied to EVs and PHEVs was applied to the glider only (curb-weight less 

electric drive components). Weight reduction was applied to the entire vehicle in the case of HEVs.

K EVs and PHEVs are assumed to experience an onroad range shortfall of 30%, whereas HEVs are assumed to 

see a shortfall of 25%. In terms of energy consumption (and thus battery size), this represents an increase of 

43% and 33% for EVs/PHEVs and HEVs, respectively.

Engine

Clutch

Transmission /

Transaxle

Electric Motor
Appendix B

B-18

Additionally, battery usable state-of-charge (SOC) windowsL were assumed at 80% for future 

EVs, 70% for future PHEVs and 50% for future HEVs. 

B4.2.1.3 Battery Cost

Battery costs were determined using a model developed by Argonne National 

Laboratory (ANL) which provides unique battery pack cost estimates for each of the three 

major types of electrified vehicles. Within the model, battery pack costs are estimated based 

on a bill of materials determined by battery pack design criteria. The costs include materials, 

manufacturing processes, cost of capital equipment, plant area and labor for each 

manufacturing step. A basic description of the ANL Li-ion battery cost model and initial 

modeling results for PHEV applications were published within a peer-reviewed technical 

paper presented at EVS-2416. ANL has extended modeling inputs and pack design criteria 

within the cost model to include analysis of manufacturing costs for EV and HEV battery 

packs in addition to the original work on PHEV battery costs.

17

 A thorough peer-review of 

the ANL Li-ion battery cost model and its inputs and results is pending. The agencies expect 

to continue to work with DOE and ANL (as well as manufacturers) to obtain the most up to 

date information for the upcoming NPRM. 

Within the ANL battery cost model, a bill of materials for a battery pack is determined 

based on specific design criteria. The design criteria include a vehicle application’s power 

and energy storage capacity requirements, the battery’s cathode and anode chemistry, and the 

number of cells per module and modules per battery pack. The model assumes use of a 

laminated multi-layer prismatic cell and battery modules consisting of double-seamed rigid 

containers (Figure B4.2-2). The model also assumes that the battery modules are air-cooled. 

The model takes into consideration the cost of capital equipment, plant area and labor for each 

step in the manufacturing process for battery packs and places relevant limits on electrode 

coating thicknesses and other processes limited by existing and near-term manufacturing 

processes. Figure B4.2-3 shows a basic schematic of the plant layout and production steps 

assumed within the model The ANL model also takes into consideration annual pack 

production volume and economies of scale for high-volume production.

 

L On-road range is defined as the percentage of a battery pack’s useful operating range. For durability and safety 

reasons, electric vehicle batteries are not discharged completely, nor are they typically operated at fully charged 

levels. Because of this limitation, . Thus the nominal battery size required always larger than that which is used, 

and is calculated as the actual required capacity divided by the SOC window.
2017-2025 Technical Assessment

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Figure B4.2-2: Prismatic Cell and Module Design for High Power-to Energy HEV 

Battery Packs (provided courtesy of Argonne National Laboratory).

Terminal Seal

Polymer Seal of 

Cell Container 

to Terminal 

Ultrasonic Welds

of Terminal to 

Collector Foils

Cell Cross-Section Battery Module

Double-Seamed 

Module Closure

Heat Transfer Surfaces 

on Top and Bottom of 

Container in Contact 

with Cell Edge Seals

Cell Terminal 

Connections

Cell with Stiff, MultiLayer Container

Polymer 

Edge Seal 
Appendix B

B-20

Figure B4.2-3: Lithium-ion Battery Pack Manufacturing Plant Schematic Diagram 

(provided courtesy of Argonne National Laboratory).

The cost outputs from the ANL model used by the Agencies to determine 2025 HEV, 

PHEV and EV battery costs assume 500,000 pack/year production volume. We also assumed

the use of a common cathode and anode chemistry, LiMn2O4-spinel for the cathode and 

graphite for the anode. While it is expected that other Li-ion battery chemistries will likely be 

available in the 2017-2025 timeframe, the specific chemistry used for the cost analysis was 

chosen to be consistent with publicly available information on current and near term HEV, 

PHEV and EV product offerings from Hyundai, GM and Nissan.18,19,20,21 The battery designs 

used in the model also assumed full power delivery at 80% of the open circuit voltage. For 

EVs, battery power was assumed to be sufficient to provide peak motor power for an 

application with 15% added to account for HVAC and other non-motor electric loads. For 

HEVs and PHEVs, battery power was assumed to be sufficient to provide peak motor power 

for an application. The ANL battery cost model results for is compared to the costs used in 

the 2012-2016 final rule and to cost estimates compiled by EPA from OEM battery suppliers

and auto OEMs in Figure B4.2-4.

Shipping

Cell and 

Scrap 

Recycling

Receiving

Control 

Laboratory

Assembly Route

The areas in this diagram for each processing step are approximately proportional to 

the estimated plant areas in the baseline plant.

Battery Pack 

Assembly and 

Testing

Module 

Assembly

Formation 

Cycling

Current 

Collector

Welding

Enclosing 

Cell in 

Container

Electrolyte Filling

and Cell Closing

Cell Stacking

Solvent 

Evaporation

Positive

Negative

Electrode 

Coating

Positive

Negative

Electrode 

Slitting

Vacuum 

Drying

Electrode Materials 

Preparation

Positive

Negative Calendering

Solvent 

Recovery

Air 

Locks

ChargeRetention 

Testing 

Final 

Cell 

Sealing

Dry Room

Materials 

Handling

Outdoor dry-room air 

processing equipment
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Figure B4.2-4: Comparison of direct manufacturing costs per unit of energy storage

($/kW-hr) between the estimates used by EPA in the 2012-2016 GHG final rule, the 

ANL battery cost model results for PHEV20, PHEV40, EV100 and EV150 packages and 

OEM battery suppliers (2008 dollars, markups not included). Multiple points shown 

for the ANL cost model results for PHEV 20, PHEV40, EV100 and EV150 reflect the 

range of energy-specific costs for EPA’s subcompact through large-car package 

categories (see Table B4.2-1 for details). A range of OEM estimated battery costs is also 

shown for comparison (red bars) which may or may not reflect additional cost markups. 

A PHEV and EV battery cost sensitivity analysis is included in Chapter 6, section 6.5 

of the Technical Assessment. The analysis includes PHEV and EV battery pack costs 

approximately $100/kW-hr higher and $50/kW-hr lower than the costs estimates from the 

ANL battery cost model. The $100/kW-hr higher cost is comparable to commodity pricing 

for high-volume LiCoO2 cells for consumer applications. The $50/kW-hr lower cost assumes 

a breakthrough in battery design that would approximately triple cell energy density.

B4.2.1.4 Motor Costing

The agencies agreed that based on a review of the technical literature the cost-vspower relationship should not be a constant $15/kW across motor sizes. A linear relationship 

was chosen based on 2007 Camry/Prius motor and generator costs (based on ORNL/EEAestimated costs) and treated as near-term (2012-2016) results. The motor sizing, determined 

as described above was then applied to the linear cost model developed by ORNL:

y (motor cost in USD) = 8.28 * (motor size in kW) + 181.43

$-

$200 

$400 

$600 

$800 

$1,000 

$1,200 

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2030

Calendar Year

Cost ($U.S./kW-hr)

Total Range of OEM Supplier Estimates (>5sources) collected by EPA from 2008 -2010

2012-2016 EPA Cost Estimate

DOE/ANL (PHEV20) DOE/ANL (PHEV40)

DOE/ANL (EV150) DOE/ANL (EV100)

Estimated Battery Pack Costs

Range from the majority of OEM stakeholder meetings in June-August 2010
Appendix B

B-22

The final value is then learned down from 2012 to 2025 by applying time based 

learning.

B4.2.1.5 Learning Applied to Battery and Non-Battery Costs

As described above, the battery costs developed using the ANL model were 

considered the 2025 model year costs expressed in 2008 dollars. In contrast, the remaining 

parts of the hybrid or electrified vehicle system, termed the non-battery costs, were considered 

the 2012 model year costs expressed in 2008 dollars. While the non-battery systems are 

considered rather mature technologies for which time based learning is appropriate, the Li-ion

battery system is a new technology for which volume based learning is more appropriate. In 

fact, the agencies believe it is likely that battery technology will undergo several levels of 

volume based learning between 2012 and 2025 given the newness of the technology and the 

rapid pace of development. For this reason, we have generated a unique learning curve for 

the battery system technology that attempts to estimate costs back in time from the 2025 

estimates discussed above. This allows us to estimate costs in the 2020 timeframe for 

OMEGA as well as estimate those costs in each year between today and 2025. The learning 

curve we have generated is shown in Figure B4.2-5. This learning curve consists of 5 full 

volume based learning steps each of which results in costs being reduced 20% relative to the 

prior step. These learning steps are shown occurring every two years beginning in 2012 until 

2020 at which time a 5 year gap is imposed until 2025 when the ANL costs are reached and 

the learning curve factor equals 1. Beyond 2025, time based learning is applied at 3% cost 

reductions per year. The smooth line shows a logarithmic curve fit applied to the learning 

curve as EPA’s cost model would apply learning. 

Figure B4.2-5: Battery Pack Learning Curve

Using this learning curve, we can estimate the battery pack direct manufacturing costs 

for each year and for each type of battery pack. These details are shown in Table B4.2-1

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

2012 2016 2020 2024 2028

Battery Pack Learning Curve

Learning curve Log. (Learning curve)
2017-2025 Technical Assessment

B-23

which shows, in the upper portion of the table, the estimated direct manufacturing costs for 

each type of battery pack considered (for a large car in this example) and in the lower portion 

the $/kWh estimated in each year based on the learning curve shown in Figure B4.2-5. 

Table B4.2-1: Direct Manufacturing Costs for Battery Packs and Associated $/kWh for 

Each, Costs for a Large Car (2008 dollars, markups not included)

Cost Element 2012 2015 2018 2019 2020 2021 2022 2023 2024 2025

Battery Pack Costs

P2 battery pack $1,956 $1,565 $1,002 $1,002 $801 $801 $801 $801 $801 $641

REEV20 

battery pack $7,120 $5,696 $3,645 $3,645 $2,916 $2,916 $2,916 $2,916 $2,916 $2,333

REEV40 

battery pack $10,461 $8,368 $5,356 $5,356 $4,285 $4,285 $4,285 $4,285 $4,285 $3,428

EV75 battery 

pack $14,276 $11,421 $7,309 $7,309 $5,847 $5,847 $5,847 $5,847 $5,847 $4,678

EV100 battery 

pack $18,170 $14,536 $9,303 $9,303 $7,443 $7,443 $7,443 $7,443 $7,443 $5,954

EV150 battery 

pack $26,869 $21,495 $13,757 $13,757 $11,005 $11,005 $11,005 $11,005 $11,005 $8,804

Cost per Kilowatt-hour

$/kWh (P2) $2,964 $2,371 $1,518 $1,518 $1,214 $1,214 $1,214 $1,214 $1,214 $971

$/kWh 

(REEV20) $809 $647 $414 $414 $331 $331 $331 $331 $331 $265

$/kWh 

(REEV40) $581 $465 $298 $298 $238 $238 $238 $238 $238 $190

$/kWh (EV75) $501 $401 $256 $256 $205 $205 $205 $205 $205 $164

$/kWh

(EV100) $464 $371 $237 $237 $190 $190 $190 $190 $190 $152

$/kWh 

(EV150) $426 $341 $218 $218 $174 $174 $174 $174 $174 $140

B4.2.1.6 In-home Charger Costs

We have also estimated cost associated with in-home chargers and installation of inhome chargers. Charger costs are covered in more detail in Section 4.2.3 of the main report. 

Here we summarize the actual costs used for developing EV and REEV package costs. We 

have estimated the cost of a level 1 charge cord at $30 (2008 dollars) based on typical costs of 

similar electrical equipment sold to consumers today and that for a level 2 charger at $200

(2008 dollars). Labor associated with installing either of these chargers is estimated at $1,000

(2008 dollars). Further, we have estimated that all REEV20 vehicles (REEVs with a 20 mile 

range) would be charged via a level 1 charger and that all EVs, regardless of range, would be 

charged via a level 2 charger. For the REEV40 vehicles (REEVs with a 40 mile range), we 

have estimated that: 25% of subcompacts would be charged with a level 1 charger with the 

remainder charged via a level 2 charger; 10% of small cars would be charged with a level 1 

charger with the remainder charged via a level 2 charger; and all remaining REEV 40 vehicles 

would be charged via a level 2 charger. All costs presented here are considered valid for the 

2025 model year. We have applied the learning curve presented above in Section B4.2.1.5 to 

the charger costs. We have also applied our High 2 ICMs to these costs (1.70 through the 

2021MY and 1.45 thereafter). Installation costs, being labor costs, have no learning impacts 
Appendix B

B-24

or ICM applied. The resultant costs for 2017, 2020 and 2025 are shown in Table B4.2-2. 

These costs are included in our package costs for all REEV and EV packages.

Table B4.2-2: In-home Charger Related Costs for REEVs and EVs (2008 dollars)

Technology Vehicle Class 2017 2020 2025

REEV20-Charger

Subcompact

Small car

Large car

Minivan

Small truck

$100 $64 $44

REEV40-Charger

Subcompact $523 $335 $228

Small car $608 $389 $265

Large car

Minivan

Small truck

$664 $425 $290

EV-Charger

Subcompact

Small car

Large car

Minivan

Small truck

$664 $425 $290

Labor

Subcompact

Small car

Large car

Minivan

Small truck

$1,000 $1,000 $1,000

B4.3 Mass Reduction Cost Model

Application of mass reduction technologies for 2017-2025 vehicles has been discussed 

at length in meetings with vehicle manufacturers in preparation for this Technical Assessment 

Report. One of the challenges the manufacturers identified with respect to mass reduction 

was the feasibility of substituting some lower density materials for higher density materials. 

These issues included material availability, forming, joining, painting, corrosion, reparability, 

and impact performance. The agencies agree that these issues need further study in order to 

determine the feasibility of certain types of mass reduction and the appropriateness of 

assuming their applicability in the MYs 2017-2025 timeframe for purposes of the upcoming 

federal rulemaking. 

To begin to address these issues, the collaborative NHTSA, EPA, and DOE team

described in Chapter 3 has focused on several tasks including a peer review of the Lotus 

Engineering report22 regarding holistic vehicle mass reduction opportunities, a 2nd phase of 

analysis by Lotus Engineering to assess the functional performance and safety of phase 1 

designs and to modify designs as appropriate through computer aided engineering (CAE), and 

two projects being conducted by DOE regarding, one regarding mass reduction feasibility and 
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B-25

the other consisting of an actual vehicle build (Multi Material Vehicle – MMVM). NHTSA 

and EPA may also consider jointly funding a study to evaluate potentially feasible amounts of 

mass reduction and their accompanying cost for MY 2017-2025 separately from the study 

contracted to Lotus engineering by CARB. Computer Aided Engineering (CAE) tools would 

be used to analyze the structure of the vehicle. The proposed design should meet at least the 

same functional objectives as the baseline vehicle. If funded, this study would be designed to 

be finished in time for incorporation in the final rule analysis. 

For the 2012-2016 final rule, NHTSA and EPA relied on a 2015 cost of $1.32 (2007$) 

per pound of mass reduction, and the limit of mass reduction (penetration cap) was set to 10%

based on our feasibility analysis.

23

 This cost was estimated by calculating an average of the 

costs estimated in three studies: 2002 NAS report (normalized estimated cost $1.50/lb)24, 

Sierra Research (normalized estimated cost $1.01/lb for 10% mass reduction with 

compounding)25, and MIT (normalized estimated cost $1.36/lb for 14% mass reduction 

without mass compounding).26 The $1.32 per pound cost would be $1.35 per pound in 2008 

dollars. With a year of time-based learning at 3% per year the cost would be $1.31 (2008$) 

per pound in 2016 and with 4 years of time-based learning at 2% per year would be $1.20 

(2008$) per pound in 2020.

However, in the 2017-2025 timeframe, many of the OEMs indicated in meetings with 

the agencies over the summer that they will be capable of higher levels of mass reduction than 

10 percent per vehicle. The OEMs also generally stated that there is some initial amount of 

mass reduction which can be accomplished with zero or very little cost (much lower than that 

estimated in the 2012-2016 rule of $1.32/lb), but emphasized that higher percentages of mass 

reduction may result in higher costs and that these costs are likely to increase non-linearly 

with increasing mass reduction levels. In response to this stakeholder feedback and based on 

our own preliminary analysis of the potential for vehicle mass reduction in the 2020 and 2025 

timeframe, the agencies have begun updating our mass reduction cost model to reflect this 

progressively increasing level of cost. A simple non-linear cost model is introduced below 

that has been employed for purposes of this Technical Assessment Report, but EPA and 

NHTSA intend to rely on additional studies for the upcoming federal rulemaking that are 

expected to be complete before the NPRM and final rule. The collaborative team has taken 

several actions to inform the cost model, including meeting with vehicle manufacturers, 

DOE’s update of their 2007 study on feasibility and cost, and EPA funding a 3rd party cost 

assessment of the Lotus Report. 

The agencies developed the non-linear cost model for mass reduction for purposes of 

this Technical Assessment Report by averaging the 2012-2016 linear cost for mass reduction 

in 2025 with the cost estimate for the High Development Case in the Lotus Engineering study, 

and then drawing a parabolic curve between $0 for 0 percent mass reduction and that average 

dollar value at 32 percent mass reduction. While the agencies recognize that there have been 

a number of vehicle mass reductions studies conducted in the literature in the past 10 years27

 

M DOE Notice of Intent to Issue Funding Opportunity Announcement N.:DE-FOA-000239.

http://www.netl.doe.gov/business/solicitations/NOTICE%20OF%20INTENT.pdf
Appendix B

B-26

28 29 30 31, a complete literature review is beyond the scope of the report, and thus the agencies 

believe that the mass reduction feasibility and cost study conducted by Lotus Engineering in 

2010 is the most comprehensive vehicle mass reduction study conducted to date. 

Lotus Engineering purchased a 2009 Toyota Venza (a crossover SUV, or CUV) and 

tore the vehicle down, analyzing every subsystem of the vehicle. The study split the mass 

reduction into two phases: ―low‖ and ―high‖ development, to represent different potential 

levels of mass reduction. For the low development case, the majority of the body in white 

(BIW) weight reduction was accomplished by converting mild steel to high strength steel. In 

addition, all vehicle components and subsystems were compared to the best-in-class vehicle 

mass leaders and substituted (and scaled) to the Venza, which allowed significantly more 

weight reduction and the use of mass decompounding. This approach provided an extremely 

cost effective manner of reducing weight and cost compared to other studies in the literature 

that attempted to evaluate reducing similar amounts of mass. In the high development case, 

Lotus considered much more material substitution in the BIW, from steel to aluminum, 

magnesium, plastic and other materials, and relied extensively on completely novel (and 

smart) design of all possible components to reduce mass in all vehicle systems. Table B4.3-1

summarizes the cost results from this study:

Table B4.3-1: Costs for Mass Reduction Based on the Lotus Engineering Study*

Low Development

(19% mass reduction)

High Development

(32% mass reduction)

Cost per 

vehicle

Lower 

bound

-$400

-$1600

$600

-$600

Upper 

bound $800 $1800

Cost per pound

Lower 

bound

-$0.55

-$2.20

$0.50

-$0.50

Upper 

bound $1.10 $1.49

* Estimates assume a total variable (or piece) cost of the Toyota Venza to be $20,000

The agencies note that some limitations exist for the Lotus study. First, Lotus 

analyzed these considerable levels of mass reduction based on a single vehicle. The agencies 

acknowledge that most of the improvements described in the report can be applied across all 

vehicles to varying degrees, but due to the expense and time of the study, it is impractical for 

our current purposes to conduct similar studies across many different vehicles. Second, 

Lotus’ cost estimates were based on manufacturer (OEM) piece costs due to the initial scope 

of the study, and only partially included the manufacturer tooling and assembly plant costs. 

As mentioned earlier, follow-up studies are being planned to improve these cost estimates. 

Third, the designs created by Lotus for the low and high development cases have not been 

shown to meet FMVSS safety regulations and voluntary NCAP and IIHS guidelines, or to 

achieve vehicle functional performance similar to the baseline vehicle. Each of these issues is 

being addressed in the Phase 2 Lotus study, but was not addressed in time for this Technical 

Assessment Report.
2017-2025 Technical Assessment

B-27

The Lotus study also shows that it is possible to take up to 19% of the mass out of the 

vehicle at no cost (cost savings in fact) by using less costly piece costs for many components 

based on their benchmarking analysis. The agencies agree that it may be possible to remove 

mass at a cost savings on many vehicles – there are a number of other studies that have 

similar conclusions. However, the agencies are concerned about assigning a negative cost 

value at the higher ranges of what some of the manufacturers shared was the maximum 

feasible (approximately 20% mass reduction) within the 2017-2025 timeframe. Therefore, the 

agencies are pursuing further cost studies to confirm all of the costs (including manufacturing 

and tooling) before using the Lotus results directly. The agencies do acknowledge that the 

Lotus study included a high degree of uncertainty in the cost estimates, and that some degree 

of mass reduction may be possible at a cost savings. 

The agencies note that most manufacturers stated in stakeholder meetings over the 

summer that they anticipate that future safety and emission regulatory requirements will 

require increases in vehicle mass and, in addition, they intend to implement voluntary safety 

improvements that will increase vehicle mass. Net mass reduction for the 2017-2025 

timeframe will thus actually be the mass reduction achieved through methods similar to those 

identified in studies discussed above, but offset by mass increases for safety and emission 

regulations and voluntary safety improvements. Manufacturers also frequently stated that 

they already have incorporated varying levels of mass reduction in current production 

vehicles. The agencies have not considered these baseline factors explicitly in estimating the 

cost for mass reduction that is being used for this assessment.

Thus, to model how mass reduction costs could increase at a non-linear rate for 

purposes of this Technical Assessment Report, the agencies have relied on a parabolic shape 

for the cost curve – where the cost per pound increases as the square of the percentage mass 

reduction. To determine the magnitude of the curvature, the parabola was calibrated to go 

through a designated ―high value‖ at 32% mass reduction. To determine this high value, the 

agencies averaged the $1.20/lb (2008$ in the 2020MY) value developed using the 2012-2016 

rule methodology, with the Lotus high development cost figure of $0.50/lb at 32% mass 

reduction (as described above). This averaging represents two factors. First, that the agencies 

believe that the cost used in the 2012-2016 rule appropriately captures the longer timeframe 

and improved design optimization methods that are likely to lower costs in the 2017-2025 

timeframe; but on the other hand, that the agencies believe that a constant value, independent 

of the complexities involved with greater levels of mass reduction, is not realistic. And 

second, as described above, the agencies believe that the Lotus costs on their own are too low, 

due to the missing manufacturing and tooling costs. The averaging of the two costs offsets 

the missing Lotus costs. A variety of non-linear curves could have been employed, however, 

the 2nd order polynomial defines the simplest model, which seemed reasonable for the current 

analysis. The curve has the shape shown in Figure B4.3-1. 
Appendix B

B-28

Figure B4.3-1: Mass Reduction Cost Model in Dollars per Pound in Model Year 2020 

Compared to the Lotus Results and 2012-2016 Final Rule Cost.

Accounting for the indirect cost markup (ICM) on the mass reduction cost model, the 

agencies believe that it is appropriate to assign higher markups for the higher levels of mass 

reduction due to their increased complexity and lead time required. Descriptions of these 

different levels of ICM are in Chapter 3. Table B4.3-2 shows this increasing ICM with mass 

reduction levels. 

Table B4.3-2: Indirect Cost Markup Factors for Increasing Levels of Mass Reduction

Mass 

Reduction Complexity

ICM

Near 

Term

ICM

Long 

Term

3% Low 1.17 1.13

5% Low 1.17 1.13

10% Low 1.17 1.13

15% Low 1.17 1.13

20% Medium 1.31 1.19

25% Medium 1.31 1.19

30% High 1 1.51 1.32

Accounting for the ICMs, the model with and without markups is shown in Figure B4.3-2.

$(2.50)

$(2.00)

$(1.50)

$(1.00)

$(0.50)

$-

$0.50 

$1.00 

$1.50 

0 % 5 % 10% 15% 20% 25% 30% 35% 40%

$ per pound Cost (w/o ICM)

% Mass Reduction

Lotus Results

2012-2016 Cost Model

2017-2025 Cost Model
2017-2025 Technical Assessment

B-29

Figure B4.3-2: Mass Reduction Cost Model in 2008 Dollars per Pound in Model Year 

2020 With and Without Indirect Cost Markups

As mentioned earlier, the agencies continue to explore avenues of increasing the 

fidelity of the mass reduction cost model, and believe that there are studies that are currently 

or anticipated being conducted which will improve the fidelity of the points used to calibrate 

this model and which may be employed for the upcoming federal rulemaking. 

B5 Fuel Cell Vehicle Technology Cost, Effectiveness and Leadtime Assessment

B5.1 Technology Summary

The state of fuel cell vehicle (FCV) technology has seen significant progress towards 

the U.S. Department of Energy (DOE) 2015 performance targets over the last few years. Fuel 

cell stack durability has more than doubled since 2006 and high volume production system 

cost has been reduced by over 80% since 2002 (additional details are provided below). 

Progress is still required in the areas of fuel cell costs, durability, and on-board hydrogen 

storage. However, the technology has matured sufficiently for commercialization, and 

production launch is feasible in the 2015-2017 time-frame. First generation vehicles will 

likely require financial incentives to initiate the market (as is currently planned for battery 

technologies). 

B5.2 Fuel Cell Costs

Based on the most recent fuel cell system cost analysis by Directed Technologies, Inc 

(DTI32), contracted by DOE, today’s fuel cell technology when produced at high volumes 

would have a cost of $51/kW (system net power). Additionally, projected 2015 technology at 

high volume production would cost $39/kW. For a 100kW system in a large car (vehicle type 

5), this would equate to $3,945 (not including hydrogen storage). The analysis for this report 

$0.00

$0.20

$0.40

$0.60

$0.80

$1.00

$1.20

0% 5% 10% 15% 20% 25% 30%

$/pound

Mass Reduction Percentage

Direct Mfr Cost

Markedup Cost
Appendix B

B-30

bundled the fuel cell system costs with the electric drive component costs consistent with how 

the EV and PHEV technology packages were developed. For FCVs, this analysis assumed a 

system sized for the large car platform (vehicle type 5), and included the HEV battery pack 

and hydrogen storage costs in addition to the system noted above.

The system costs noted above are the fully-learned, high volume production costs 

from DTI. However, these production volumes are not assumed to be achieved by 2025 for 

this analysis. FCV production levels of ~85,000 per year in the U.S. were assumed, 

representing approximately 0.5% of the U.S. LDV market in 2025. This is discussed further 

in Section B4.3.4. At these lower production levels, the incremental fuel cell system direct 

manufacturing cost is closer to +$4,800.

As part of this analysis, fuel cell vehicle production costs were developed by relying 

on the 2015 technology costs from DTI along with the non-fuel cell electric drive component 

costs from the EPA OMEGA model. Figure B5.2-1 below shows the simulated production 

costs for a 100kW fuel cell system (average system size for larger vehicle platforms in this 

analysis). Note this is not the full FCV production cost which would include the full electric 

drive bill of material. Also not shown is the retail price markup (ICM); FCVs are assumed to 

have the same ICM as the EV and PHEV vehicle types, using the high complexity ICM 

values noted earlier in Appendix B.

Figure B5.2-1: FC Production Cost Curve for a 100kW system (not including H2 

storage)

(Sources: DTI (cost curve), extrapolation to 100kW)

Figure B5.2-2 shows the summary breakdown of vehicle costs at the high volume 

production level. The fuel cell system cost at this level is based on the DTI $39/kW high 

volume data point. Compared to the 2010 DTI system estimate, this 2015 production cost 

$-

$5,000

$10,000

$15,000

$20,000

0 100,000 200,000 300,000 400,000 500,000

Annual Production Volume

Fuel Cell System Cost (100kW system, 2008 $)

National sales rate 

in 2025 assumed
2017-2025 Technical Assessment

B-31

assumes system improvements, including the elimination of external humidification 

components, elimination of an air expander, and slightly higher membrane operating 

temperatures that allow the reductions in the radiator and cooling loop size. For fuel cell 

stack costs, DTI assumes platinum loadings of 0.15 mg/cm2. In addition to the fuel cell 

system, the battery pack modeled was the lithium-ion battery assumed for HEVs in Table 

B4.2-1. Balance of EV drive components include drive motors, controllers, DC/DC 

converters, electric AC and heating, and a few other components. Finally, as noted above, the 

hydrogen storage system cost was assumed to be $10/kWh, notably higher than the DOE 2015 

target given the lower production volumes. 

Figure B5.2-2: Detailed fuel cell system costs at high volume production

(Source: DTI, CARB)

Table B5.2-1 shows the resulting direct manufacturing costs for the 2020 and 2025 

model years, highlighting the higher costs compared to the fully learned production levels at 

the far right of Figure B5.2-1.

Table B5.2-1: Fuel cell direct manufacturing costs at assumed production volumes

1

2

3

4

5

Air Loop 

$700

Water & 

Thermal Mngt

$500

Fuel Loop 

$100

FC Stack 

$2,133

Controller & 

Sensors 

$512

1

2

3

4

5

Air Loop 

$700

Water & 

Thermal Mngt

$500

Fuel Loop 

$100

FC Stack 

$2,133

Controller & 

Sensors 

$512

2020MY 2025MY

U.S. FCV Sales 20,000 85,000

Fuel cell system cost

(100 kW)

$ 5,900 $ 4,800

Hydrogen storage cost

(4 kg @ $10/kWh)

$1,320 $1,320
Appendix B

B-32

Finally, as a reference, DOE’s analysis of various hydrogen storage systems was 

reviewed. The production costs for various on-board hydrogen storage technology 

alternatives were analyzed by TIAX under contract to DOE33. This analysis assumed high 

pressure gaseous storage remained the technology choice in 2025, although the cryocompressed alternative is receiving increased attention by major OEMs. The current DOE 

2010 target is $4/kWh and the 2015 target is $2/kWh, although DOE is planning to revise 

these targets soon. For the 2025 FCV simulated in this analysis, a storage cost of $10/kWh 

was assumed given production levels will not reach the fully mature point. 

B5.3 Performance Status

Automakers are nearing DOE 2015 performance targets and continue to push the 

technology toward commercial readiness, as documented in the DOE 2009 Report to 

Congress34. A few of the key accomplishments are listed below and further information can 

be found at DOE’s Hydrogen Program Accomplishments webpage35.

Significantly reduced the cost of automotive fuel cells (from $275/kW in 2002 to 

$51/kW in 2010 (DTI), based on projections of high-volume manufacturing costs)

Doubled the durability of fuel cell systems in vehicles operating under real-world 

conditions (data in 2006 showed 950-hour durability—today, this number is 2500 

hours, equivalent to approximately 75,000 miles of driving)

Reduced the cost of producing hydrogen from both renewable resources and natural 

gas (hydrogen can now be produced by distributed reforming of natural gas at a 

projected high-volume cost of $3.00/gallon gasoline equivalent; this does not take into 

account FCV efficiency gains over an ICE which would improve these operating costs 

further)

Independently validated a real-world driving range of 450 miles for an FCV from one 

of the major OEMs.

The table below summarizes the cost, durability, and efficiency targets along with the 

status of today’s technology as assessed by DOE’s Technology Validation Program.36

Table B5.3-1: Current Status and U.S. DOE Targets for Automotive Fuel Cells

Fuel cell system volume and weight have been largely reduced and are expected to 

achieve the targets, allowing for marketable vehicle integration. For example, the Honda FCX 

2009

(Current 

Status)

2010

(Cost 

Update)

2010

Target

2015

Target

System Efficiency 53-59% 60% 60%

System Cost $61 /kW $51 /kW 37 $45 /kW $30 /kW

Fuel Cell System 

Durability

2,500 hours

(~75,000 mi)

2,000 hours

(~60,000 mi)

5,000 hours

(~150,000 mi)

Vehicle Range 254 miles 38 250 miles 300 miles

H2 Storage Costs $20 /kWh 39 $4 /kWh $2 /kWh
2017-2025 Technical Assessment

B-33

Clarity’s fuel cell stack is 1/5 the weight and 1/4 the volume compared to the previous FCV 

model40. The weight and volume progress are a result of improvements in fuel cell materials 

(stamped metal flow plates, aromatic membrane structure, reductions in catalyst loading) and 

fuel cell simplification (part-count reduction, improved manufacturing). A detailed summary 

of the performance of the Generation 2 FCVs being evaluated in the DOE Technology 

Validation Program can be found in the NREL presentation to the 2010 DOE Merit Review41.

FCVs have achieved the DOE 2015 efficiency targets already, which translates into 

large energy and greenhouse gas reductions compared to conventional vehicles. Although the 

full well-to-wheel (WTW) GHG reductions depend on the fuel source, hydrogen produced 

from natural gas and used in an FCV results in WTW GHG reductions of 50% compared to a 

projected internal combustion engine vehicle, and 20% compared to a projected hybrid 

vehicle42. Given that the vehicle powertrain is a zero emission technology, all emissions are 

generated from the fuel production and delivery stages. 

B5.4 Hydrogen Storage

As noted above, the majority of FCV technology requirements necessary for a 

marketable vehicle have been addressed through continued R&D and demonstration. This 

includes rapid start-up, cold-start operation, stack power density, balance-of-plant (BOP) 

operation, and efficiency. On-board hydrogen storage is one of the remaining challenges that 

will require further development. This will not prevent the commercial launch of FCVs, 

however, as adequate storage systems are available for use in early commercial vehicles. The 

storage technology chosen by the majority of OEMs for existing FCVs is high pressure (700 

bar or 10,000 psi) gaseous storage. Although volumetric density, cost, and station dispensing 

complexity (a need for pre-cooling) are not ideal, the technology is ready today.

Technologies under consideration by OEMs and energy companies for next generation 

vehicles include intermediate pressure gaseous storage (between 350 and 700 bar where precooling won’t be required) and cryo-compressed hydrogen storage. The latter has the promise 

of higher volumetric density, lower cost, and substantially reduced fuel boil-off (in engine-off 

mode) compared to liquid storage43. 

Additional FCV and hydrogen storage information can be found from the following 

DOE resources.

2010 U.S. DOE Merit Review Proceedings, June 2010.

http://www.hydrogen.energy.gov/annual_review10_proceedings.html

2009 U.S. DOE Hydrogen Program Annual Progress Report, November 2009.

http://www.hydrogen.energy.gov/annual_progress09.html

B5.5 Commercialization Status

Production announcements have been made by at least three major OEMs for a 2015 

launch. Production volumes will depend in part on the hydrogen infrastructure rollout in 

strategic locations where early customers are expected. In the U.S., this is likely to be in 
Appendix B

B-34

Southern California and New York where infrastructure is emerging. Based on two 

independent confidential surveys of OEMs and their FCV plans (conducted by the CaFCP44

and CARB/CEC), up to 50,000 FCVs could be deployed in California by 2018 (cumulative 

on-road).

Hydrogen infrastructure continues to be a large challenge for FCVs in preparation for 

vehicle commercialization in 2015. Addressing this challenge requires stakeholder 

coordination and sustained commitments from both the public and private sectors. However, 

this activity is progressing in California, with actions coordinated by the CaFCP, CARB and 

CEC. The state is providing large cost-share incentives for hydrogen stations (led by CEC), 

and strategic planning is relying on concepts outlined in the CaFCP’s 2009 Action Plan45 and 

2010 Progress and Next Steps, as well as the UC Davis Roadmap.

46

For the purposes of identifying production costs in this analysis, annual production 

volumes were estimated. Broadly based on California’s Zero Emission Vehicle Regulation as 

well as hydrogen infrastructure advancements in California and a few other states, it was 

assumed FCVs would comprise 0.5% of the U.S. LDV market in 2025. With a total assumed 

LDV market of 16.5 million vehicles, this equates to annual sales volumes of 85,000 

nationally. Although these levels are lower than previous FCV scenarios by the DOE 

(ORNL47) and the National Academies (NAS48), they represent full commercial scale 

production volumes and should result in the needed FCV cost reductions such that market 

share could grow significantly beyond 2025.
2017-2025 Technical Assessment

B-35

Appendix B References

1 Memorandum to Docket EPA-HQ-OAR-2010-0799 from Todd Sherwood dated September 16, 2010.

2 U.S. Environmental Protection Agency, ―Light-Duty Technology Cost Analysis Pilot Study,‖ Contract No. EPC-07-069, Work Assignment 1-3, December 2009, EPA-420-R-09-020, Docket EPA-HQ-OAR-2009-0472-

11282; peer review report dated November 6, 2009, is at EPA-HQ-OAR-2009-0472-11285; ―Light-duty 

Technology Cost Analysis – Report on Additional Case Studies,‖ EPA-HQ-OAR-2009-0472-11604

3 EPA-420-R-10-901

4 U.S. Environmental Protection Agency, ―Light-Duty Technology Cost Analysis Pilot Study,‖ Contract No. EPC-07-069, Work Assignment 1-3, December 2009, EPA-420-R-09-020, Docket EPA-HQ-OAR-2009-0472-

11282; peer review report dated November 6, 2009, is at EPA-HQ-OAR-2009-0472-11285; ―Light-duty 

Technology Cost Analysis – Report on Additional Case Studies,‖ EPA-HQ-OAR-2009-0472-11604.

5 Turner, J.W.G., Pearson, R.J., Curtis, R. Holland, B. ―Sabre: a cost effective engine technology combination 

for high efficiency, high performance and low CO2 emissions,‖ Low Carbon Vehicles 2009: Institution of 

Mechanical Engineers conference proceedings, May 2009.

6 Lumsden, G. OudeNijeweme, D., Fraser, N., Blaxill, H. ―Development of a Turbocharged Direct Injection 

Downsizing Demonstrator Engine,‖ SAE Technical Paper Series, No. 2009-01-1503.

7 Yi., J., Wooldridge, S., Coulson, G., Hilditch, J., Iyer, C., Moilanen, P., Papaioannou, G., Reiche, D., Shelby, 

M. VanDerWege, B., Wearver, C., Xu, Z., Davis, D., Hinds, B., Schamel, A. ―Development and Optimization of 

the Ford 3.5L V6 EcoBoost Combustion System,‖ SAE Technical Paper Series, No. 2009-01-1494.

8 Cruff, L., Kaiser, M., Krause, S., Harris, R., Krueger, U., Williams, M. ―EBDI - Application of a Fully Flexible 

High BMEP Downsized Spark Ignited Engine,‖ SAE Technical Paper Series, No. 2010-01-0587.

9 Taylor, J., Fraser, N., Wieske, P. ―Water Cooled Exhaust Manifold and Full Load EGR Technology Applied to 

a Downsized Direct Injection Spark Ignition Engine,‖ SAE Technical Paper Series, No. 2010-01-0356.

10 Kaiser, M., Krueger, U., Harris, R., Cruff, L. ―Doing More with Less - The Fuel Economy Benefits of Cooled 

EGR on a Direct Injected Spark Ignited Boosted Engine,‖ SAE Technical Paper Series, No. 2010-01-0589.

11 Kapus, P.E., Fraidl, G.K., Prevedel, K., Fuerhapter, A. ―GDI Turbo – The Next Steps,‖ JSAE Technical Paper 

No. 20075355, 2007.

12 General Motors, news release, ―From Hybrids to Six-Speeds, Direct Injection And More, GM’s 2008 Global 

Powertrain Lineup Provides More Miles with Less Fuel‖ (released Mar. 6, 2007). Available at 

http://www.gm.com/experience/fuel_economy/news/2007/adv_engines/2008-powertrain-lineup-082707.jsp (last 

accessed Sept. 18, 2008).

13 ―EPA Staff Technical Report: Cost and Effectiveness Estimates of Technologies Used to Reduce Light-duty 

Vehicle Carbon Dioxide Emissions‖ Environmental Protection Agency, EPA420-R-08-008, March 2008, at page 

17, Docket EPA-HQ-OAR-2009-0472-0132.

14 Joint Technical Support Document: Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission 

Standards and Corporate Average Fuel Economy Standardsfor EPA and NHTSA 2012-2016 GHG and CAFE 

Rule. EPA-420-R-10-901, April, 2010.

15 Olszewski, M., 2008. Evaluation of the 2007 Toyota Camry Hybrid Synergy Drive System. Oak Ridge 

National Laboratory. ORNL/TM-2007/190. Oak Ridge, Tenesssee. April.
Appendix B

B-36

16 Nelson, P.A., Santinit, D.J., Barnes, J. ―Factors Determining the Manufacturing Costs of Lithium-Ion Batteries 

for PHEVs,‖ 24th World Battery, Hybrid and Fuel Cell Electric Vehicle Symposium and Exposition EVS-24, 

Stavenger, Norway, May 13-16, 2009 (www.evs24.org).

17 Santini, D.J., Gallagher, K.G., and Nelson, P.A. ―Modeling of Manufacturing Costs of Lithium-Ion Batteries 

for HEVs, PHEVs, and EVs,‖ Paper to be presented at the 25th World Battery, Hybrid and Fuel Cell Electric 

Vehicle Symposium and Exposition, EVS-25, Shenzhen, China, November 5-9, 2010 (www.evs25.org). 

Advance draft provided by D.J. Santini, Argonne National Laboratory, August 24, 2010.

18 ―Hyundai ups tech ante with Sonata Hybrid,‖ Automotive News, August 2, 2010.

19 ―Chevrolet Stands Behind Volt With Standard Eight-Year, 100,000-Mile Battery Warranty,‖ GM Press release 

(http://media.gm.com/content/media/us/en/news/news_detail.brand_gm.html/content/Pages/news/us/en/2010/Jul

y/0714_volt_battery)

20 ―Nissan’s new 2012 hybrid system aims for 1.8-L efficiency with a 3.5-L V6,‖ SAE Automotive Engineering 

Online, February 15, 2010.

21 ―Lithium-ion Battery,‖ Nissan Technological Development Activities (http://www.nissanglobal.com/EN/TECHNOLOGY/INTRODUCTION/DETAILS/LI-ION-EV/), 2009. 

22 Lotus Engineering, Inc. ―An Assessment of Mass Reduction Opportunities for a 2017 – 2020 Model Year 

Vehicle Program,‖ Published by the The International Council on Clean Transportation and available on the 

Internet at http://www.theicct.org/2010/03/lightweight-future/, March 30, 2010.

23 Joint Technical Support Document: Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission 

Standards and Corporate Average Fuel Economy Standardsfor EPA and NHTSA 2012-2016 GHG and CAFE 

Rule. EPA-420-R-10-901, April, 2010.

24 Effectiveness and Impact of Corporate Fuel Economy Standards, NAS, 2002.

25 Basic Analysis of the Cost and Long-Term Impact of the Energy Independence and Security Act Fuel 

Economy Standard, Sierra Research, 2008.

26 The Impact of Mass Decompounding on Assessing the Value of Vehicle Lightweighting, MIT 2008.

27 Assessment of Fuel Economy Technologies for Light Duty Vehicles, NAS, 2010.

28 Analysis of Light Duty Vehicle Weight Reduction Potential, Energy and Environmental Analysis Inc, 

prepared for DOE, July, 2007.

29 Cost-Effectiveness Of a 25% Body and Chassis Weight-Reduction Goal In Light-Duty Vehicles, Das, Sujit, 

prepared for DOE, 2008/

30 Cost-Effectiveness Of a 40% Body and Chassis Weight-Reduction Goal In Light-Duty Vehicles, Das, Sujit, 

prepared for DOE, 2009.

31 Cost-Effectiveness Of a 50% Body and Chassis Weight-Reduction Goal In Light-Duty Vehicles, Das, Sujit, 

prepared for DOE, 2010.

32 Directed Technologies Inc (DTI), ―Mass-Production Cost Estimation for Automotive Fuel Cell Systems,‖ 

2010 U.S. DOE Merit Review, FC018, June 7-11, 2010. 

http://www.hydrogen.energy.gov/pdfs/review10/fc018_james_2010_o_web.pdf
2017-2025 Technical Assessment

B-37

33 TIAX LLC, ―Analysis of Hydrogen Storage Materials and On-Board Systems,‖ 2010 U.S. DOE Merit 

Review, ST002, June 7-11, 2010. 

http://www.hydrogen.energy.gov/pdfs/review10/st002_lasher_2010_o_web.pdf

34 ―Hydrogen and Fuel Cell Activities, Progress, and Plans,‖ U.S. DOE Report to Congress, January 2009. 

http://www.hydrogen.energy.gov/program_records.html

35 http://www1.eere.energy.gov/hydrogenandfuelcells/accomplishments.html

36 Refer to Table 3.1 in the U.S. DOE 2009 Report to Congress and a year-end summary by Dr. Sunita Satyapal, 

http://www1.eere.energy.gov/hydrogenandfuelcells/pdfs/ cng_h2_workshop_1_satyapal.pdf

37 DTI. Projected 2015 system cost = $39/kW. System cost does not include H2 storage assembly or electric 

drive components

38 Corresponds to vehicle fuel economy observations of 43-58 mi/kg-H2 as noted by the National Renewable 

Energy Laboratory (NREL) in ―Controlled Hydrogen Fleet and Infrastructure Analysis,‖ 2010 U.S. DOE Merit 

Review, TV001, June 10, 2010. www.hydrogen.energy.gov/pdfs/review10/tv001_wipke_2010_o_web.pdf

39 TIAX LLC, ―Analysis of Hydrogen Storage Materials and On-Board Systems,‖ 2010 U.S. DOE Merit 

Review, ST002, June 7-11, 2010. 

http://www.hydrogen.energy.gov/pdfs/review10/st002_lasher_2010_o_web.pdf . (Based on 700 bar gaseous 

pressure system at 5.6 kg H2 storage)

40 Knight, Ben. Honda Motor Company. ―Fuel Cell Vehicle Technology Performance and Steps Ahead 

Presentation‖. CARB ZEV Symposium, September 21, 2009. 

http://www.arb.ca.gov/msprog/zevprog/2009symposium/2009program.htm

41 NREL, ―Controlled Hydrogen Fleet and Infrastructure Analysis,‖ 2010 US DOE Merit Review, TV001, June 

10, 2010

42 ―Well-to-Wheels Greenhouse Gas Emissions and Petroleum Use,‖ U.S. DOE Hydrogen Program Record # 

9002, March 25, 2009.

43 Argonne National Laboratory, ―System Level Analysis of Hydrogen Storage Options,‖ 2010 U.S. DOE Merit 

Review, ST001, June 7-11, 2010.

44 California Fuel Cell Partnership (CaFCP), ―Hydrogen Fuel Cell Vehicle and Station Deployment Plan: A 

Strategy for Meeting the Challenge Ahead (Progress and Next Steps),‖ April 2010. 

http://www.fuelcellpartnership.org/resources/print-materials

45 CaFCP, ―Hydrogen Fuel Cell Vehicle and Station Deployment Plan: A Strategy for Meeting the Challenge 

Ahead (Action Plan),‖ February 2009. http://www.fuelcellpartnership.org/resources/print-materials

46 University of California, Davis, ―Roadmap for Hydrogen and Fuel Cell Vehicles in California: A Transition 

Strategy Through 2017,‖ a public-private collaborative report following a series of workshops, December 2009.

47 Oak Ridge National Laboratory, ―Transition to Hydrogen Fuel Cell Vehicles & the Potential Hydrogen Energy 

Infrastructure Requirement,‖ ORNL/TM-2008/30, March 2008.

48 National Academies of Science, ―Transitions to Alternative Transportation Technologies: A Focus on 

Hydrogen,‖ Committee on Assessment of Resource Needs for Fuel Cell and Hydrogen Technologies, 2009.
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Appendix C - Reserved
2017-2025 Technical Assessment

D-1

D1 Appendix D: Air Conditioning

D1.1 Overview

Over 95% of the new cars and light trucks in the United States are equipped with 

mobile air conditioning (MAC or A/C) systems. In the 1970s and 1980s, A/C systems were 

an optional (luxury) feature, but these systems are now standard on almost all new vehicle 

models. The A/C system is a unique and distinct technology on the automobile. It is different 

from the other technologies described in Chapter 3 of the joint Technical Support Document 

(TSD) to the recent MY 2012-2016 Final Rule in several ways. First, most of the 

technologies described in the joint TSD directly affect the efficiency of the engine, 

transmission, and vehicle systems. As such, these systems are almost always active while the 

vehicle is moving down the road or being tested on a dynamometer for the fuel economy and 

emissions test drive cycles. A/C on the other hand, is a parasitic load on the engine that only 

burdens the engine when the vehicle occupants demand it. Since it is not tested as a normal 

part of the fuel economy and emissions test drive cycles for compliance purposes, it is 

referred to as an “off-cycle” effect. There are many other off-cycle loads that can be switched 

on by the occupant that affect the engine; these include lights, wipers, stereo systems, 

electrical defroster/defogger, heated seats, power windows, etc. However, these electrical 

loads individually amount to a very small effect on the engine (although together they can be 

significant). The A/C system (by itself) adds a significantly higher load on the engine as 

described later in this chapter. Secondly, present A/C systems are capable of leaking a 

powerful greenhouse gas (GHG) directly into the air - even when the vehicle is not in 

operation. No other vehicle system has associated GHG leakage. Because of these factors, a 

distinct approach to control of MAC systems is justified, and a separate technical discussion is 

also warranted. 

D1.2 Leakage

D1.2.1 Overview

This section describes a preliminary analysis of leakage emission reductions in the 

2025 timeframe. It is expected that this analysis will be reevaluated during the rulemaking 

process. The technological basis for the expected leakage reductions is discussed in detail in 

the EPA‟s model year (MY) 2012-2016 Light Duty Greenhouse Gas Final Rule (2016 FRM) 

RIA Chapter 2, and is summarized here. 

Mobile air conditioner (MAC) systems leak a powerful greenhouse gas directly into 

the air - even when the vehicle is not in operation. Because MAC emissions are not measured 

during certification testing for the GHG program, the 2016 final rule offered a compliance 

credit to encourage manufacturers to reduce the leakage from MAC systems. The analysis 

discussed herein serves as an update to that analysis. As in the 2016 FRM, a 2008 vehicle is 

considered an unimproved system, and is the basis of the discussion shown here. 

The hydrofluorocarbon (HFC) refrigerant compound used in most model year 2008 

vehicles is R134a (also known as 1,1,1,2-Tetrafluoroethane, or HFC-134a). Based on the 
Appendix D

D-2

higher global warming potential (GWP) of HFC-134a, a small leakage of this refrigerant has a 

greater global warming impact than a similar amount of emissions of some other mobile 

source GHGs. R134a has a global warming potential of 1430,A which means that 1 gram of 

R134a has a warming potential equivalent to 1,430 grams of CO2 (which has a GWP of 1).1 

The high pressure of an MAC system increases its propensity for leaks. In order for 

the A/C system to take advantage of the refrigerant‟s thermodynamic properties and to 

exchange heat properly, the system must be kept at high pressures even when not in operation. 

Typical static pressures can range from 50-80 psi depending on the temperature, and during 

operation, these pressures can get to several hundred psi. At these pressures leakage can 

occur through a variety of mechanisms. The refrigerant can leak slowly through seals, 

gaskets, and even small failures in the containment of the refrigerant. The rate of leakage 

may also increase over the course of normal wear and tear on the system. Leakage may also 

increase more quickly through rapid component deterioration such as during vehicle 

accidents, maintenance or end-of-life vehicle scrappage (especially when refrigerant capture 

and recycling programs are less efficient). Small amounts of leakage can also occur 

continuously even in extremely “leak-tight” systems by permeating through hose membranes. 

This last mechanism is not dissimilar to fuel permeation through porous fuel lines. 

Manufacturers may be able to reduce these leakage emissions through the implementation of 

technologies such as leak-tight, non-porous, durable components. The global warming impact 

of leakage emissions also can be addressed by using alternative refrigerants with lower global 

warming potential. 

As MACs leak even when not being driven, it is most appropriate to determine their 

leakage based on a g/year or g/lifetime. However, for purposes of an estimation of 

reductions, it is possible to divide lifetime leakage losses by lifetime vehicle miles traveled 

(VMT) in order to determine the appropriate average g/mile leakage rate.

D1.2.2 Description of Vintaging Model Inputs and Data Sources

New data concerning HFC leakage has become available since the 2016 final rule

analysis was completed. Most significantly, based on new data from the EPA Office of 

Atmospheric Programs (OAP), EPA has decreased the average charge size and leakage 

assumed in its analysis as compared to the 2016 final rule analysis. The inputs used to derive 

the HFC reductions are drawn from the OAP Vintaging model and are shown below in Table 

D1.2-1. These values are discussed in the following paragraphs, and are drawn from internal 

EPA documentation of the Vintaging model.

Table D1.2-1: Inputs for HFC Potential Reduction Calculation from Vintaging Model

 

A The global warming potentials (GWP) used in this analysis are consistent with Intergovernmental Panel on 

Climate Change (IPCC) Fourth Assessment Report (AR4). At this time, the IPCC Second Assessment Report 

(SAR) global warming potential values have been agreed upon as the official U.S. framework for addressing 

climate change. The IPCC SAR GWP values are used in the official U.S. greenhouse gas inventory submission 

to the United Nations climate change framework. 
2017-2025 Technical Assessment

D-3

Car Truck

2008 MY Vehicle MAC Charge (g HFC) 550 780

Lifetime of a MAC system (years) 12 12

Fraction of Vehicles w/AC 99% 99%

Recurring Annual Loss Rate (Service+Leaks) 18% 18%

End of Life Loss 43% 43%

D1.2.2.1 Charge Size

The Vintaging model contains weighted average refrigerant charge sizes based on 

motor vehicle sales data and charge size data, by make, model, and year. 2008 Sales data is 

from Ward's US Light Vehicle Sales: 2005 through 2008 Calendar Years.

2

 Charge size data 

is from the Mobile Air Conditioning Society (MACS) Worldwide‟s A/C & Cooling System 

Specifications: 1996-2007.

3

 No assumptions are made regarding continued reductions in 

charge size beyond 2008.

D1.2.2.2 AC System Lifetime

The Vintaging Model assumes that all light duty passenger vehicle AC systems (in the 

U.S.) last exactly 12 years. This is in agreement with the IPCC report IPCC/TEAP 2005 

Safeguarding the Ozone Layer and the Global Climate System – Issues Related to 

Hydrofluorocarbons and Perfluorocarbons, which indicates lifetimes (worldwide) of 9 to 12 

years. 

D1.2.2.3 Fraction of Vehicles with AC

Not all vehicles are sold with AC; Ward‟s vehicle sales data are adjusted based on the 

percentage of vehicles with AC, which increases over time before reaching a maximum of 

99% in 2002 (light trucks) and 2003 (cars). The Vintaging Model assumes that 1% of 

vehicles continue to be sold without air conditioning beyond 2003.

D1.2.2.4 Emission Rates

The Vintaging Model assumes that losses occur from three events: leak, service, and 

disposal. Although vehicle ACs are serviced during discrete events and not usually every 

year, emissions from those events are averaged over the lifetime of the AC system. Leak and 

service emissions are considered “annual losses” and are applied every year; disposal is 

considered an “end of life loss” and is applied only once for each vintage of vehicles. 

Emission rates in the Vintaging model do improve over time, with the 2008 vehicle emission 

rates attributable to vehicles manufactured from 1998 to present. 

Of note, the Vintaging model assumes that charge loss is replaced every year; ie, a 

vehicle with a charge of 100 grams would lose a constant rate of 18 grams/year. While other 

emissions, such as fugitive emissions at a production facility, leaks from cylinders in storage, 

etc., are not explicitly modeled, such emissions are accounted for within the annual loss rate.
Appendix D

D-4

D1.2.3 Calculation of the Lifetime HFC loss per vehicle

Several modifications were made to the Vintaging model outputs for the analysis of 

the potential HFC reductions. Most importantly, the charge size of the average car was 

increased as a result of the reclassification of a number of two wheel drive SUVs below 6,000 

pounds as cars starting in MY 2011, as discussed in Appendix A. It was assumed that 20% of 

the new cars were classic trucks. As a result, the charge sizes were weighted together, with a 

weighting of 80% car and 20% truck in order to calculate the car charge under the revised MY 

2011 and later definition. The charge size of trucks was not adjusted. We also assume that 

only vehicles which have AC systems are eligible for the AC credit, increasing the 99% value 

to 100%

Using this data, the total average lifetime losses from an AC system can be calculated 

using Equation D1.2-1:

Total Lifetime HFC Emissions = (Average Charge Size) * (Average Annual Loss) * (Average Lifetime) 

+ (End of Life Loss)

Equation D1.2-1: Calculation of Total Lifetime HFC Loss

Applying this equation results in an average per-vehicle HFC loss of approximately 

2.59 charges (18% loss of initial charge * 12 years + 43% loss at end of life.). This results in 

total lifetime losses of 1,543 g for cars and 2,020 grams for trucks. 

D1.2.4 Calculation of the HFC Credit Maximum

The maximum HFC credit is set so that the reduction in HFC emissions can be 

replaced by an equivalent amount of tailpipe CO2 emissions. As CO2 emissions are regulated 

on a gram/mile basis, the HFC emissions must be converted into an equivalent metric using 

Equation D1.2-2. Based on the MY 2012-2016 final rule, the total lifetime VMT of cars and 

trucks is estimated at 195,264 and 225,865 respectively. These values are consistent with the 

MY 2012-2016 final rule, consistent with the early years of the time frame, and are slightly 

lower than the MY 2025 VMT estimated in this technical report. 

CO2eq g / mile = (Total lifetime HFC emissions) / (Total Lifetime VMT) * (GWP)

Equation D1.2-2: Conversion of Lifetime HFC Emissions into CO2eq emissions

 Finally, because a known 20% shortfall (the “on-road” gap) exists between 

certification test CO2 emissions and actual on-road emissions, the CO2 equivalent emissions 

calculated above were multiplied by 0.8 in order to appropriately offset the reduction in real 

emissions. 

The maximum possible credit, calculated through this methodology, is shown below. 

Assuming that alternative refrigerant with a GWP of zero is used, the maximum potential 

credit would be based on removing the full lifetime emissions. As discussed in the 2016 final 

rule, if conventional HFC 134a were used in an AC system, the maximum potential leakage 

reduction is 50% of the annual emission leakage. No improvements would be expected to end 
2017-2025 Technical Assessment

D-5

of life emissions, so the total possible credit is approximately 45% of the maximum credit 

with alternative refrigerant. 

Table D1.2-2: Maximum Credit (g/mile CO2 eq)

Car Truck Fleet 

(MY 2025)

Maximum Credit (Alternative Refrigerant w/ 0 

GWP)

9.2 10.4 9.6

Maximum Credit (HFC 134a) 3.8 4.3 3.9

As the charges for the cars and light trucks differ, the mix of cars and trucks is significant to this analysis. 

MY 2025 is projected to have 67.5% cars and 2 wheel drive SUVs below 6,000 lbs. 

D1.2.5 System Leakage Standards

In the timeframe considered in this Technical Assessment Report, EPA is considering

a number of options to reduce A/C leakage emissions, including the setting of a refrigerant 

leakage standard for mobile A/C systems. The purpose of a leakage standard, as opposed to 

credits, is to assure that high-quality, low-leakage components are used in each air 

conditioning system design. EPA is considering a percent leakage per year standard curve, 

which is scaled to the refrigerant capacity of the system (i.e. small-capacity systems would

have a larger allowable leakage standard than those with larger capacity). Since refrigerant 

leakage past the compressor shaft seal is the dominant source of leakage in belt-driven air 

conditioning systems, a single “percent refrigerant leakage per year” standard may not fairly 

addresses the range of system refrigerant capacities likely to be used in passenger cars, light 

duty trucks, and other vehicles. Since systems with less refrigerant may have a larger 

percentage of their annual leakage from the compressor shaft seal than systems with more 

refrigerant capacity, their relative percent refrigerant leakage per year could be higher, and a 

more extensive application of leakage reducing technologies could be needed to meet a 

standard. 

Manufacturers can choose to reduce A/C leakage emissions in two ways. First, they 

can utilize leak-tight components. Second, manufacturers can largely eliminate the global 

warming impact of leakage emissions by adopting systems that use an alternative, low-GWP 

refrigerant. EPA believes that reducing A/C system leakage is both highly cost-effective and 

technologically feasible. The availability of low leakage components is being driven by the 

air conditioning program in the light duty GHG rule which apply to 2012 model year and later 

vehicles. The cooperative industry and government Improved Mobile Air Conditioning 

(IMAC) program has demonstrated that new-vehicle leakage emissions can be reduced by 

50% by reducing the number and improving the quality of the components, fittings, seals, and 

hoses of the A/C system. All of these technologies are already in commercial use and exist 

on some of today‟s systems. 

In the MY 2012-2016 rule, EPA required that manufacturers demonstrate 

improvements in their A/C system designs and components through a design-based method. 

Thismethod for calculating A/C Leakage is based closely on an industry-consensus leakage 

scoring method, described below. This leakage scoring method is correlated to 

experimentally-measured leakage rates from a number of vehicles using the different 
Appendix D

D-6

available A/C components. Under this approach, manufacturers would choose from a menu of 

A/C equipment and components used in their vehicles in order to establish leakage scores, 

which would characterize their A/C system leakage performance and calculate the percent 

leakage per year as this score divided by the system refrigerant capacity. 

Consistent with the Light Duty Vehicle Greenhouse Gas Emissions rulemaking, EPA 

is considering that a manufacturer would compare the components of its A/C system with a 

set of leakage-reduction technologies and actions that is based closely on that being developed 

through IMAC and the Society of Automotive Engineers (as SAE Surface Vehicle Standard 

J2727, August 2008 version). See generally 75 FR at 25426. The J2727 approach was 

developed from laboratory testing of a variety of A/C related components, and EPA believes 

that the J2727 leakage scoring system generally represents a reasonable correlation with 

average real-world leakage in new vehicles. Like the IMAC approach, our proposed approach 

would associate each component with a specific leakage rate in grams per year identical to the 

values in J2727 and then sum together the component leakage values to develop the total A/C 

system leakage. However, in this “percent system leakage per year” approach, the total A/C 

leakage score and is then divided the value by the total refrigerant system capacity to develop 

a percent leakage per year.

EPA believes that the design-based approach would result in estimates of likely 

leakage emissions reductions that would be comparable to those that would eventually result 

from performance-based testing (e.g. SAE J2763), and may consider allowing performance 

test results in lieu of design-based results, if a manufacturer can demonstrate that 100% of 

their vehicles systems are leak tested before they leave the assembly plant. At the same time, 

comments are encouraged on all developments that may lead to a robust, practical, 

performance-based test for measuring A/C refrigerant leakage emissions.

D1.3 Air conditioning Efficiency

D1.3.1 Overview

EPA estimates that the CO2 emissions from A/C related load on the engine of a 

vehicle with an unimproved air conditioning system accounts for about 3.9% of total 

greenhouse gas emissions from passenger vehicles in the United States. This is equivalent to 

CO2 emissions of approximately 14.3 g/mi per vehicle. A complete discussion of this 

estimate is available in Chapter 2 of the EPA RIA to the MY 2012-2016 final rule.

In brief, most of the excess load on the engine comes from the compressor, which 

pumps the refrigerant around the system loop. Significant additional load on the engine may 

also come from electrical or hydraulic fan units used for heat exchange across the condenser 

and radiator. EPA believes that the controls which manufacturers would use to achieve 

improved A/C efficiency would focus primarily, but not exclusively, on the compressor, 

electric motor controls, and system controls which reduce load on the A/C system (e.g. 

reduced „reheat‟ of the cooled air and increased use of recirculated cabin air). 

The program EPA finalized in the MY 2012-2016 final rule encourages the reduction 

of A/C CO2 emissions from cars and trucks by up to 40% from 2008 baseline levels through a 
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D-7

credit system. A 40% reduction would be equivalent to a reduction of 5.7 grams of CO2 

emissions per mile. 

D1.3.2 A/C Efficiency Credits

Similar to the 2012-to-2016 Light-Duty GHG Rule, a design-based approach to credits 

is being considered, although the number and type of items listed in the technology “menu” –

as well as the amount of credit assigned to each item - may change as new methods of testing 

them in the vehicle develop. The design-based approach used in the GHG Rule was used 

because it was not possible to accurately assess their effectiveness of these technologies using 

the A/C Idle Test. 

D1.3.3 A/C Efficiency Test

A new test to measure the impact of the A/C system operation on emissions is being 

evaluated with input from USCAR, CARB, and the European Union. The primary goal in 

developing this new test is to create a test cycle and test conditions which reflect 

environmental and driving experience found in typical customer usage (rather than the 

extreme, high ambient temperature condition of the SC03 or the idle-only condition of the 

A/C Idle Test). A secondary goal of this new test is to create a cycle which captures the 

effectiveness of advanced A/C technologies, and can demonstrate a fuel savings compared to 

a baseline technology. This new test may include a solar soak condition (to measure the 

effectiveness of solar load reducing technologies such as solar glass and cabin ventilation), a 

transient drive cycle (to measure the dynamic performance of the system during cabin cooldown), and steady-state cycles (to measure the effectiveness of the system under stabilized 

cabin temperature conditions).

If this new test cycle is able to accurately assess the efficiency of the A/C system and 

its components, it could be used to determine the level of credits available. But if the 

effectiveness of certain technologies cannot be measured on the new test, a design menu 

approach may be utilized. 
Appendix D

D-8

Appendix D References

1

IPCC. Chapter 2. Changes in Atmospheric Constituents and in Radiative Forcing. September 2007.

2

 Ward‟s Automotive. Ward's US Light Vehicle Sales: 2005 through 2008 Calendar Years. 

3

 Mobile Air Conditioning Society (MACS) Worldwide. A/C & Cooling System Specifications: 1996-2007.
2017-2025 Technical Assessment

E-1

E1 Appendix E: Key Inputs to the Analysis

This section discusses the key inputs to the analysis which were jointly developed by 

the agencies for today’s Technical Assessment Report. These economic inputs incorporate a 

range of forecast information, economic estimates, and input parameters. This section 

describes the sources that the agencies relied upon for this information, the rationale 

underlying each assumption, and the agencies’ estimates of specific parameter values. These 

common values were then used as inputs to the analyses presented in this Technical 

Assessment Report.

Please note that there are additional economic and environmental impacts which were 

not considered in this assessment. A partial list includes: co-pollutant impacts, health 

impacts, the social cost of carbon emissions, and energy security. The exclusion of these 

impacts from this Technical Assessment Report does not suggest that these impacts should be

disregarded. As in the MY 2012-2016 final rule, NHTSA and EPA will carefully consider 

other impacts of emission and fuel economy standards during the development of the

upcoming Notice of Proposed Rulemaking (NPRM).

Many of the inputs used in this technical assessment are carried forward from the

analyses conducted for the MY 2012-2016 final rule. As part of developing the upcoming

NPRM, EPA and NHTSA will consider updating these inputs. 

E1.1 Vehicle Sales

As discussed in Chapter 6, the vehicle sales projection is based upon output from the 

National Energy Modeling System (NEMS) which is maintained by the Energy Information 

Administration (EIA). As in the MY 2012-2016 final rule, the car and truck split was drawn 

from NEMS, while market segmentation was drawn from CSM’s forecasting tool. Total 

market size is estimated in 2020 at 16.5 million vehicles (55.8 % cars) and in 2025 at 17.0 

million vehicles (57.9% cars). Cars, in the context of NEMS, are defined using the pre-MY 

2011 CAFE definition, as discussed above in Appendix A. 

For this analysis the DOT Volpe center produced a custom run of NEMS. This run 

generated the same overall vehicle sales as the reference case for AEOEIA Annual Energy 

Outlook 2010, but a different sales split between cars and light trucks. A detailed discussion 

on this topic is presented in Appendix A.

E1.2 On-road Fuel Economy Shortfall

Fuel economy levels achieved by vehicles in on-road driving fall significantly short of 

their levels measured by EPA under the laboratory test conditions used under the CAFE 

program to establish its published fuel economy ratings. In analyzing the impacts from 

passenger car and light truck GHG and fuel efficiency standards, the agencies adjust the test

fuel economy performance of each passenger car and light truck model downward from its 

rated value to reflect the expected size of this on-road fuel economy differential. 
Appendix E

E-2

The agencies note that in December 2006, EPA adopted changes to its regulations on 

fuel economy labeling, which were intended to bring vehicles’ rated fuel economy levels 

closer to their actual on-road fuel economy levels.1 Comparisons of on-road and CAFE fuel 

economy levels developed by EPA as part of that final rule indicate that actual on-road fuel 

economy for light-duty vehicles averages approximately 20 percent lower than published fuel 

economy levels.2 While there is great heterogeneity among the population of drivers, as 

discussed in the referenced material, 20 percent represents the average for modeling a fleet. 

For example, if the overall EPA fuel economy rating of a light truck is 20 mpg, the on-road 

fuel economy actually achieved by a typical driver of that vehicle is expected to be 16 mpg 

(20*.80). EPA and NHTSA both applied this 20% differential in calculating the fuel savings 

of the MY 2012 – 2016 joint final rule.

In this technical assessment report, the agencies assume that the overall energy 

shortfall for the electric drivetrain is 30%. Specifically, this refers to a larger shortfall relative 

to laboratory conditions while operating on electricity rather than liquid fuel. The 30% value 

is derived from engineering judgment based on several data points. Foremost among these, 

during the stakeholder meetings conducted prior to this technical assessment, confidential 

business information (CBI) was supplied by several manufacturers which indicated that 

electrically powered vehicles had greater variability in their on-road energy consumption than 

vehicles powered by internal combustion engines. Further, data from the 2006 analysis of the 

“five cycle” label potentially supported a larger on-road shortfall for vehicles with hybridelectric drivetrains.3

 Finally, heavy accessory load, extreme temperatures, and aggressive 

driving have deleterious impacts of unknown magnitudes on battery performance. As a 

counterpoint, CBI provided by several other manufacturers suggested that the onroad/laboratory differential attributable to electric operation should approach that of liquid 

fuel operation in the future. Consequently, 30% was judged a reasonable estimate for the 

current analysis.

E1.3 Fuel Prices

Federal government agencies generally use EIA’s projections in their assessments of 

future energy-related policies. The retail fuel price forecasts presented in AEO 2010 span the 

period from 2007 through 2035. Measured in constant 2008 dollars, the AEO 2010 Reference 

Case forecast of retail gasoline prices during calendar year 2020 is $3.34 per gallon, rising 

gradually to $3.91 by the year 2035 (these values include federal, state and local taxes). 

However, valuing fuel savings over the maximum lifetimes of passenger cars and light trucks 

used in this analysis requires fuel price forecasts that extend through 2060, approximately the 

last year during which a significant number of MY 2025 vehicles will remain in service.A To 

obtain fuel price forecasts for the years 2036 through 2060, the agency assumes that retail fuel 

prices will continue to increase after 2035 at the average annual rate (0.7%) projected for 

2008-2035 in the AEO 2010 Reference Case. This assumption results in a projected retail 

price of gasoline that reaches $4.34 in 2050. 

 

A The agency defines the maximum lifetime of vehicles as the highest age at which more than 2 percent of those 

originally produced during a model year remain in service. In the case of light-duty trucks, for example, this age 

has typically been 36 years for recent model years.
2017-2025 Technical Assessment

E-3

The value of fuel savings resulting from improved fuel economy and GHG emissions 

to buyers of light-duty vehicles is determined by the retail price of fuel, which includes 

federal, state, and any local taxes imposed on fuel sales. Total taxes on gasoline, including 

federal, state, and local levies averaged $0.42 per gallon during 2008, while those levied on 

diesel averaged $0.50. Because fuel taxes represent transfers of resources from fuel buyers to 

government agencies, however, rather than real resources that are consumed in the process of 

supplying or using fuel, their value must be deducted from retail fuel prices to determine the 

value of fuel savings resulting from more stringent fuel efficiency and GHG standards to the 

U.S. economy as a whole.4 When calculating the costs to any individual driver, the taxes are 

included as part of the realized fuel savings.B

E1.4 Vehicle Lifetimes and Survival Rates

The agencies’ analysis of fuel savings and related benefits for this Technical 

Assessment Report begins by estimating the resulting changes in fuel use over the entire 

lifetimes of cars and light trucks. The change in total fuel consumption by vehicles produced 

during each of these model years is calculated as the difference in their lifetime fuel use under 

the reference and alternative assumptions. 

The first step in estimating lifetime fuel consumption by vehicles produced during a 

model year is to calculate the number of those vehicles expected to remain in service during 

each future calendar year after they are produced and sold.C This number is calculated by 

multiplying the number of vehicles originally produced during a model year by the proportion 

expected to remain in service at the age they will have reached during each subsequent 

calendar year, often referred to as a “survival rate.” 

The agencies used survival rate estimates from a NHTSA study5in calculating fuel 

savings and other impacts from the analyzed scenarios. The proportions of passenger cars and 

light trucks expected to remain in service at each age up to their maximum lifetimes are 

shown in Table E1.4-1.

D Note that that these survival rates were calculated against the preMY 2011 definitions of cars and light trucks, because the NHTSA study has not been updated 

 

B

For society, the fuel taxes represent a transfer payment. By contrast, an individual realizes savings from not 

paying the additional money.

C Vehicles are defined to be of age 1 during the calendar year corresponding to the model year in which they are 

produced; thus for example, model year 2000 vehicles are considered to be of age 1 during calendar year 2000, 

age 1 during calendar year 2001, and to reach their maximum age of 26 years during calendar year 2025. 

NHTSA considers the maximum lifetime of vehicles to be the age after which less than 2 percent of the vehicles 

originally produced during a model year remain in service. Applying these conventions to vehicle registration 

data indicates that passenger cars have a maximum age of 26 years, while light trucks have a maximum lifetime 

of 36 years. See Lu, S., NHTSA, Regulatory Analysis and Evaluation Division, “Vehicle Survivability and 

Travel Mileage Schedules,” DOT HS 809 952, 8-11 (January 2006). Available at http://wwwnrd.nhtsa.dot.gov/Pubs/809952.pdf (last accessed August 25, 2010).

D The maximum age of cars and light trucks was defined as the age when the number remaining in service has 

declined to approximately two percent of those originally produced. Based on an examination of recent 

registration data for previous model years, typical maximum ages appear to be 26 years for passenger cars and 

36 years for light trucks. 
Appendix E

E-4

since 2006. Because the agencies are unaware of a better data source, these values were used 

unchanged. No improvements in survival rates were explicitly projected into the future. 

The survival and annual mileage estimates reported in this section’s tables reflect the 

convention that vehicles are defined to be of age 1 during the calendar year that coincides 

with their model year Thus for example, model year 2012 vehicles will be considered to be 

of age 1 during calendar year 2012. This convention is used in order to account for the fact 

that vehicles produced during a model year typically are first offered for sale in June through 

September of the preceding calendar year (for example, sales of a model year typically begin 

in June through September of the previous calendar year, depending on manufacturer). Thus 

virtually all of the vehicles produced during a model year will be in use for some or all of the 

calendar year coinciding with their model year, and they are considered to be of age 1 during 

that year.E

 

E As an illustration, virtually the entire production of model year 2012 cars and light trucks will have been sold 

by the end of calendar year 2012, so those vehicles are defined to be of age 1 during calendar year 2012. Model 

year 2012 vehicles are subsequently defined to be of age 2 during calendar year 2013, age 3 during calendar year 

2014, and so on. One complication arises because registration data are typically collected for July 1 of each 

calendar year, so not all vehicles produced during a model year will appear in registration data until the calendar 

year when they have reached age 2 (and sometimes age 3) under this convention. 
2017-2025 Technical Assessment

E-5

Table E1.4-1 Survival Rates

VEHICLE AGE

ESTIMATED 

SURVIVAL 

FRACTION

CARS

ESTIMATED

SURVIVAL 

FRACTION

LIGHT TRUCKS

1 0.9950 0.9950

2 0.9900 0.9741

3 0.9831 0.9603

4 0.9731 0.9420

5 0.9593 0.9190

6 0.9413 0.8913

7 0.9188 0.8590

8 0.8918 0.8226

9 0.8604 0.7827

10 0.8252 0.7401

11 0.7866 0.6956

12 0.7170 0.6501

13 0.6125 0.6042

14 0.5094 0.5517

15 0.4142 0.5009

16 0.3308 0.4522

17 0.2604 0.4062

18 0.2028 0.3633

19 0.1565 0.3236

20 0.1200 0.2873

21 0.0916 0.2542

22 0.0696 0.2244

23 0.0527 0.1975

24 0.0399 0.1735

25 0.0301 0.1522

26 0.0227 0.1332

27 0 0.1165

28 0 0.1017

29 0 0.0887

30 0 0.0773

31 0 0.0673

32 0 0.0586

33 0 0.0509

34 0 0.0443

35 0 0.0385

36 0 0.0334
Appendix E

E-6

E1.5 VMT

A critical element in estimating lifetime fuel use by the cars or light trucks produced 

during a future model year is to calculate the total number of miles that they will be driven 

during each year of their expected lifetimes. To estimate total miles driven, the number of 

cars and light trucks projected to remain in use during each future calendar year is multiplied 

by the average number of miles a surviving car or light truck is expected to be driven at each 

age. Estimates of average annual miles driven by MY 2001 cars and light trucks at each age 

were developed by NHTSA from the Federal Highway Administration’s 2001 National

Household Transportation Survey (Table E1.5-1). These estimates represent the typical 

number of miles driven by a surviving light duty vehicle. To determine the miles driven by 

the average vehicle of a given vintage at a given age, one would multiply the mileage 

accumulation by the corresponding survival rate.
2017-2025 Technical Assessment

E-7

Table E1.5-1 MY 2001 Mileage Schedules based on NHTS Data

VEHICLE AGE

ESTIMATED 

VEHICLE MILES 

TRAVELED

CARS

ESTIMATED

VEHICLE MILES 

TRAVELED 

LIGHT TRUCKS

1 14,231 16,085

2 13,961 15,782

3 13,669 15,442

4 13,357 15,069

5 13,028 14,667

6 12,683 14,239

7 12,325 13,790

8 11,956 13,323

9 11,578 12,844

10 11,193 12,356

11 10,804 11,863

12 10,413 11,369

13 10,022 10,879

14 9,633 10,396

15 9,249 9,924

16 8,871 9,468

17 8,502 9,032

18 8,144 8,619

19 7,799 8,234

20 7,469 7,881

21 7,157 7,565

22 6,866 7,288

23 6,596 7,055

24 6,350 6,871

25 6,131 6,739

26 5,940 6,663

27 0 6,648

28 0 6,648

29 0 6,648

30 0 6,648

31 0 6,648

32 0 6,648

33 0 6,648

34 0 6,648

35 0 6,648

36 0 6,648
Appendix E

E-8

E1.5.1 Adjusting vehicle use for future fuel prices

The estimates of average annual miles driven by passenger cars and light trucks 

reported in Table E1.5-1 reflect the historically low gasoline prices that prevailed at the time 

the 2001 NHTS was conducted. Under the assumption that people tend to drive more as the 

cost of driving decreases, the higher fuel prices in more recent projections leads to lower 

mileage schedules. For this report, the agencies updated the analysis with the forecasts of 

future gasoline prices reported in the AEO 2010 reference case. This adjustment accounts for 

the difference between the average retail price per gallon of fuel forecast during each calendar 

year over the expected lifetimes of future model year passenger cars and light trucks, and the 

average price that prevailed when the NHTS was conducted in 2001. The elasticity of annual 

vehicle use with respect to fuel cost per mile corresponding to the 10 percent fuel economy 

rebound effect used in this analysis (i.e., an elasticity of -0.10) was used in conjunction with 

the difference between each future year’s fuel prices and those prevailing in 2001 to adjust the 

estimates of vehicle use derived from the NHTS to reflect the effect of higher future fuel 

prices. This procedure was applied to the NHTS derived mileage figures to adjust annual 

mileage by age during each calendar year of the expected lifetimes of future model year cars 

and light trucks. 

E1.5.2 Ensuring consistency with growth in total vehicle use

The estimates of annual miles driven by passenger cars and light trucks at each age 

were also adjusted to reflect projected future growth in average vehicle use. Increases in the 

average number of miles cars and trucks are driven each year have been an important source 

of historical growth in total car and light truck use, and are expected to represent an important 

source of future growth in total light-duty vehicle travel as well. As an illustration of the 

importance of growth in average vehicle use, the total number of miles driven by passenger 

cars increased 35 percent from 1985 through 2005, equivalent to a compound annual growth 

rate of 1.5 percent.6 During that time, however, the total number of passenger cars registered 

for in the U.S. grew by only about 0.3 percent annually.F Thus growth in the average number 

of miles automobiles are driven each year accounted for the remaining 1.2 percent (= 1.5 

percent - 0.3 percent) annual growth in total automobile use.G Further, the AEO 2010

Reference Case forecasts of total car and light truck use and of the number of cars and light 

trucks in use suggest that their average annual use will continue to increase gradually from 

2010 through 2035. 

In order to develop reasonable estimates of future growth in average car and light 

truck use, the agencies calculated the rate of growth in the mileage schedules necessary for 

 

F A slight increase in the fraction of new passenger cars remaining in service beyond age 10 has accounted for a 

small share of growth in the U.S. automobile fleet. The fraction of new automobiles remaining in service to 

various ages was computed from R.L. Polk vehicle registration data for 1977 through 2005 by the agency’s 

Center for Statistical Analysis. 

G

See supra note k below.
2017-2025 Technical Assessment

E-9

total car and light truck travel to increase at the rate forecast in the AEO 2010 Reference 

Case. The growth rate in average annual car and light truck use produced by this calculation 

is approximately 1.15 percent per year.H This rate was applied to the mileage figures reported 

in Table E1.5-1 to estimate annual mileage by age during each calendar year of the expected 

lifetimes of cars and light trucks during all model years.

Separate adjustments for projected fuel prices and growth in vehicle use were made 

for each calendar year. Because the effects of both fuel prices and cumulative growth in 

average vehicle use vary by year, these adjustments result in different VMT schedules for 

each future year. While the adjustment for future fuel prices generally reduces average 

mileage at each age from the 2001 values, the adjustment for expected future growth in 

average vehicle use increases it. The net impact is growth over time. 

E1.5.3 Final VMT equation

Below, we show the equations used to determine the VMT schedules used in this 

analysis. This particular form of the equation uses a negative form of the rebound rate.

Where: 

V = CY 2001 VMT from NHTSA analysis of NHTS data

SGR = Secular Growth Rate

YS = Years since 2001

RR= Rebound rate

FCPM = Fuel Cost per mile 

Where: 

EC= Electrical consumption per mile

EP = Electricity Price

GC = Gasoline Consumption per mile

GP = Gasoline Price

 

H

It was not possible to estimate separate growth rates in average annual use for cars and light trucks, because of 

the significant reclassification of light truck models as passenger cars discussed previously.
Appendix E

E-10

Table E1.5-2 MY 2020 and 2025 Reference Mileage SchedulesI

MY 2020 MY 2025

VEHICLE 

AGE

ESTIMATED 

VMT

CARS

ESTIMATED

VMT LIGHT 

TRUCKS

ESTIMATED 

VMT

CARS

ESTIMATED

VMT LIGHT 

TRUCKS

1 16,882 19,017 17,749 19,991

2 16,334 18,398 17,152 19,315

3 16,235 18,281 17,071 19,219

4 16,143 18,160 16,976 19,094

5 16,048 18,024 16,879 18,954

6 15,750 17,643 16,586 18,578

7 15,356 17,145 16,175 18,056

8 15,040 16,728 15,846 17,623

9 14,044 15,538 14,774 16,342

10 13,707 15,092 14,427 15,883

11 13,243 14,504 13,921 15,244

12 12,824 13,968 13,492 14,693

13 12,439 13,472 13,101 14,188

14 11,991 12,912 12,634 13,603

15 11,518 12,333 12,142 12,999

16 11,054 11,773 11,664 12,422

17 10,607 11,245 11,193 11,866

18 10,169 10,741 10,731 11,334

19 9,743 10,266 10,281 10,833

20 9,337 9,833 9,854 10,376

21 8,949 9,438 9,444 9,960

22 8,588 9,098 9,064 9,601

23 8,252 8,809 8,709 9,296

24 7,943 8,576 8,382 9,050

25 7,671 8,415 8,096 8,880

26 7,436 8,324 7,847 8,784

27 0 8,307 0 8,766

28 0 8,313 0 8,773

29 0 8,317 0 8,777

30 0 8,315 0 8,775

31 0 8,318 0 8,779

32 0 8,323 0 8,784

33 0 8,324 0 8,785

34 0 8,328 0 8,789

35 0 8,335 0 8,797

36 0 8,335 0 8,797

 

I VMT schedules differing by approximately 0.2% over the course of a vehicle lifetime were used in the 

estimation of costs and impacts. The VMT schedules used in cost estimation are shown here.
2017-2025 Technical Assessment

E-11

E1.5.4 Comparison to the VMT schedules in the MY 2012-2016 Final Rulemaking 

The VMT schedules used in the MY 2012-2016 final rulemaking and this assessment 

report are compared below. 

Table E1.5-3 Summary of Reference Expected Lifetime VMT

2001 NHTS in 

NHTSA Report

MY 2012-2016 

Final Rule

MY 2020 MY 2025

Car 152,137 195,264 197,578 207,922

Trucks 179,954 225,865 231,856 244,026

E1.6 VMT Rebound

The VMT rebound effect refers to the fraction of fuel savings expected to result from 

an increase in vehicle fuel economy that is offset by additional vehicle use. The increase in 

vehicle use that stems from improved fuel economy occurs because vehicle owners respond to 

the resulting reduction in vehicle fuel consumption and operating costs by driving more. 

The magnitude of the rebound effect is one of the determinants of the actual fuel 

savings that are likely to result from adopting stricter fuel economy or emissions standards, 

and thus is an important parameter affecting the evaluation of potential standards for future 

model years. It can be measured directly by estimating the elasticity of vehicle use with 

respect to fuel economy itself, or indirectly by the elasticity of vehicle use with respect to fuel 

cost per mile driven.J When expressed as a positive percentage, either of these parameters 

gives the fraction of fuel savings that would otherwise result from adopting stricter standards, 

but is offset by the increase in fuel consumption that results when vehicles with increased fuel 

economy are driven more. 

The fuel economy rebound effect for light-duty vehicles has been the subject of a large 

number of studies since the early 1980s. Although they have reported a wide range of 

estimates of its exact magnitude, these studies generally conclude that a significant rebound 

effect occurs when vehicle fuel efficiency improves.K The most common approach to 

 

J

FuelFuel cost per mile is equal to the price of fuel in dollars per unit divided by fuel economy in miles per 

unitunit, so this figure declines when a vehicle’s fuel economy increases.

K

Some studies estimate that the long-run rebound effect is significantly larger than the immediate response to 

increased fuel efficiency. Although their estimates of the adjustment period required for the rebound effect to 
Appendix E

E-12

estimating its magnitude has been to analyze household survey data on vehicle use, fuel 

consumption, fuel prices (often obtained from external sources), and other determinants of 

household travel demand to isolate the response of vehicle use to higher fuel economy. Other 

studies have relied on econometric analysis of annual U.S. data on vehicle use, fuel economy, 

fuel prices, and other variables to identify the response of total or average vehicle use to 

changes in fleet-wide average fuel economy and its effect of fuel cost per mile driven. Two 

recent studies analyzed yearly variation in vehicle ownership and use, fuel prices, and fuel 

economy among individual states over an extended time period in order to measure the 

response of vehicle use to changing fuel economy.L

Chapter Four of the Joint Technical Support Document to the recent MYs 2012-2016 

final rule surveys these previous studies, summarizes recent work on the rebound effect, and 

explains the basis for the 10 percent rebound effect EPA and NHTSA are using in the current 

technical analysis.7 The use of a 10 percent rebound effect in this analysis reflects an 

assumption that the rebound effect applicable to the MYs 2012-2016 vehicles will remain 

applicable throughout future time periods. The agencies plan to conduct new analysis of the 

expected rebound effect in this time frame in a future rulemaking.

E1.7 Estimating Emissions and Fuel Savings

A vehicle emission standard would reduce GHG emissions emitted directly from vehicles 

due to reduced fuel use and decreased leakage from air conditioning systems. In addition to these 

“downstream” emissions, reducing CO2 emissions translates directly to reductions in the 

emissions associated with the processes involved in getting petroleum to the pump, including the 

extraction and transportation of crude oil, and the production and distribution of finished gasoline 

(termed “upstream” emissions). The agencies quantified these impacts using the inputs 

discussed in this section.

Table E1.7-1 Processes Considered

PROCESS UPSTREAM / DOWNSTREAM

Crude Oil Extraction Upstream

Crude Oil Transport Upstream

Oil Refining Upstream

Fuel Transport and Distribution Upstream

Fuel Tailpipe Emissions Downstream

Air Conditioning System Leakage Downstream

 

reach its long-run magnitude vary, this long-run effect is most appropriate for evaluating the fuel savings and 

emissions reductions resulting from stricter standards that would apply to future model years. 

L

In effect, these studies treat U.S. states as a data “panel” by applying appropriate estimation procedures to data 

consisting of each year’s average values of these variables for the separate states. 
2017-2025 Technical Assessment

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1.7.1 Estimating reductions in GHG emissions from vehicle use (downstream)

For the analysis documented in today’s Technical Assessment, the agencies used the 

OMEGA model to directly calculate CO2 emissions based on g/mile rates. These CO2

emissions were converted to gallons of fuel under the assumption that approximately the 

entire carbon content of liquid fuel is converted to CO2 emissions during the combustion 

process. The weighted average CO2 content of gasoline is estimated to be 8,887 grams per 

gallon, while that of diesel fuel is estimated to be approximately 10,200 grams per gallon. For 

details, please see EPA’s RIA and NHTSA’s RIA from the recent MY 2012-2016 Final Rule.

EPA estimated the increases in emissions of methane (CH4) and nitrous oxide (N2O) 

due to increased vehicle use (“rebound driving”) by multiplying the increase in total miles 

driven by cars and light trucks of each model year and age by emission rates per vehicle-mile 

for these GHGs. These emission rates, which differ between cars and light trucks as well as 

between gasoline and diesel vehicles, were estimated by EPA using its Motor Vehicle 

Emission Simulator (MOVES 2010) model. The MOVES model assumes that the per-mile 

rates at which cars and light trucks emit these GHGs are determined by the efficiency of fuel 

combustion during engine operation and chemical reactions that occur during catalytic aftertreatment of engine exhaust, and are thus independent of vehicles’ fuel consumption rates. 

Thus MOVES emission factors for these GHGs are assumed to be unaffected by changes in 

energy consumption. TheCH4 and N2O emission factors are the same as those used in the MY 

2012-2016 Final Rule. The full derivation of these factors is available in Chapter 4 of the 

related Joint Technical Support Document.

The emission factors used for HFC leakage emissions are discussed in Appendix D to 

this report.

E1.8 Upstream Emissions

In this analysis, we calculated upstream emission impacts for the greenhouse gases

CH4, N2O, and CO2 from both gasoline and electricity production. The upstream gasoline 

emission factor, expressed in the form of gram/gallon produced, is taken directly from the 

analysis supporting the MYs 2012-2016 final rule. EPA derived the upstream gasoline

emission factor from the Department of Energy’s GREET model, which provides separate 

estimates of air pollutant emissions that occur in four phases of fuel production and 

distribution: crude oil extraction, crude oil transportation and storage, fuel refining, and fuel 

distribution and storage. EPA modified the GREET model to change certain assumptions 

about emissions during crude petroleum extraction and transportation, as well as to update its 

emission rates to reflect adopted and pending EPA emission standards. The agency converted 

these emission rates from the mass per fuel energy content basis on which GREET reports 

them to mass per gallon of fuel supplied using the estimates of fuel energy content reported 

by GREET. Full details of this analysis are described in the MYs 2012-2016 rulemaking 

docket memo “Calculation of Upstream Emissions for the GHG Vehicle Rule.” The upstream 

gasoline emission factor does not change over time.
Appendix E

E-14

Table E1.8-1 Gasoline Upstream Emission Factors

POLLUTANT GASOLINE (g/gallon)

CO2 2,161

CH4 12.25

N2O 0.03

CO2eq 2477

In the MY 2012-2016 Final Rule analysis, we noted that there are many issues 

involved with projecting the electricity upstream GHG emissions. Relevant issues associated 

with future EV and PHEV use include, but are not limited to, average versus marginal power 

generation, daytime versus nighttime vehicle charging, geographical differences, and changes 

in future electricity feedstocks. 

For the present report, we rely upon the reference case projections produced by the 

EPA Office of Atmospheric Programs for an analysis of the American Clean Energy and 

Security Act of 2009 (H.R. 2454).

8

 This scenario assumes no new power sector regulations, 

but does assume construction of new plants to replace older retired plants. This results in a 

slight decrease (~10% compared to 2005) in the emission rate per kWh electricity produced, 

as newer plants tend to emit less than the plants which they have replaced. The H.R 2454 

base case analysis indicates that 4,395 MWh of net generation will be produced in 2025, with 

2462 million metric tons of CO2 emissions resulting. This results in an emission factor of 555 

grams CO2 per kWh. Based on eGrid20059, we estimate that approximately 0.01 grams of 

CH4 and 0.01 grams of N2O are emitted per kilowatt hour. We assume that electricity 

emission factors do not change after 2025. 

The upstream emission factor for electricity was adjusted upwards by six percent in 

order to properly capture the feedstock gathering that occurs upstream of the powerplant. M

Feedstock gathering includes the gathering, transporting, and preparing fuel for electricity 

generation. This adjustment factor is consistent with those discussed in the MY 2012-2016 

Final Rule.10 

It is important to carefully outline the frame of reference for electricity emission 

factors. For calculations of GHG emissions from electricity generation, the total energy 

consumed from the battery is divided by 0.9 to account for charging losses, and by 0.93 to 

account for losses during transmission. The upstream emission factor is applied to total 

electricity production, rather than simply power consumed at the wheel. NO

 

M The factor of 1.06 to account for GHG emissions associated with feedstock extraction, transportation, and 

processing is based on Argonne National Laboratory’s The Greenhouse Gases, Regulated Emissions, and Energy 

Use in Transportation (GREET) Model, Version 1.8c.0, available at 

http://www.transportation.anl.gov/modeling_simulation/GREET/). EPA Docket EPA-HQ-OAR-2009-0472. 

N By contrast, consumer electricity costs would not include the power lost during transmission. While 

consumers indirectly pay for this lost power through higher rates, this power does not appear on their electric 

meter. 
2017-2025 Technical Assessment

E-15

POLLUTANT CY 2025 

ELECTRICITY (g/kWh)

CO2 555

CH4 0.01

N2O 0.01

CO2eq 558

CO2eq adjusted for 

feedstock gathering 591

E1.9 Global Warming Potentials

Increases in emissions of non-CO2 GHGs are converted to equivalent increases in CO2

emissions using estimates of the Global Warming Potential (GWP) of hydrofluorocarbon 

134a (HFC134a), methane and nitrous oxide. These GWPs are one way of accounting for the 

higher radiative forcing capacity and differing lifetimes of methane and nitrous oxide when 

they are released into the earth’s atmosphere, measured relative to that of CO2. Because these 

gases differ in atmospheric lifetimes, their relative damages are not constant over time.

Impacts other than temperature change also vary across gases in ways that are not captured by 

GWP. For instance, CO2 emissions, unlike methane and other greenhouse gases, contribute to 

ocean acidification. Methane contributes to health and ecosystem effects arising from 

increases in tropospheric ozone, while damages from methane emissions are not offset by the 

positive effect of CO2 fertilization. Noting these caveats, the CO2 equivalents of increases in 

emissions of these gases are then added to the increases in emissions of CO2 to summarize the 

effect of the total increase in CO2-equivalent GHG emissions from vehicle use. 

As in the final rule, the GWP values from the Intergovernmental Panel on Climate 

Change Annual Report 4 are used. These are 1430 for HFC134a, 298 for N2O, and 25 for 

CH4. 

11,P

 

O By contrast, consumer electricity costs would not include the power lost during transmission. While 

consumers indirectly pay for this lost power through higher rates, this power does not appear on their electric 

meter. 

P The global warming potentials (GWP) used in this rule are consistent with Intergovernmental Panel on Climate 

Change (IPCC) Fourth Assessment Report (AR4). Due to international agreement, the IPCC Second 

Assessment Report (SAR) GWP values are used in the official U.S. greenhouse gas inventory submission to the 

climate change framework. 
Appendix E

E-16

Appendix E References

1 EPA, Fuel Economy Labeling of Motor Vehicles: Revisions To Improve Calculation of Fuel Economy 

Estimates; Final Rule, 40 CFR Parts 86 and 600, Federal Register, December 27, 2006, pp. 77872-77969,

http://www.epa.gov/fedrgstr/EPA-AIR/2006/December/Day-27/a9749.pdf. 

2 EPA, Final Technical Support Document: Fuel Economy Labeling of Motor Vehicle Revisions to Improve 

Calculation of Fuel Economy Estimates, Office of Transportation and Air Quality EPA420-R-06-017 December 

2006, Chapter II, http://www.epa.gov/fueleconomy/420r06017.pdf. 

3 EPA, Fuel Economy Labeling of Motor Vehicles: Revisions To Improve Calculation of Fuel Economy 

Estimates; Final Rule, 40 CFR Parts 86 and 600, Federal Register, December 27, 2006, pp. 77872-77969,

http://www.epa.gov/fedrgstr/EPA-AIR/2006/December/Day-27/a9749.pdf. 

4 OMB Circular A-4, September 17, 2003. http://www.whitehouse.gov/omb/assets/omb/circulars/a004/a-4.pdf

5 Lu, S., NHTSA, Regulatory Analysis and Evaluation Division, “Vehicle Survivability and Travel Mileage 

Schedules,” DOT HS 809 952, 8-11 (January 2006). Available at http://www-nrd.nhtsa.dot.gov/pdf/nrd30/NCSA/Rpts/2006/809952.pdf (last accessed Feb. 15, 2010). 

6 FHWA, Highway Statistics, Summary to 1995, Table vm201at 

http://www.fhwa.dot.gov/ohim/summary95/vm201a.xlw , and annual editions 1996-2005, Table VM-1 at 

http://www.fhwa.dot.gov/policy/ohpi/hss/hsspubs.htm (last accessed Feb. 15, 2010).

7 Sorrell, S. and J. Dimitropoulos, 2007. “UKERC Review of Evidence for the Rebound Effect, Technical 

Report 2: Econometric Studies”, UKERC/WP/TPA/2007/010, UK Energy Research Centre, London, October 

and Greening, L.A., D.L. Greene and C. Difiglio, 2000. “Energy Efficiency and Consumption – The Rebound 

Effect – A Survey”, Energy Policy, vol. 28, pp. 389-401.

8

EPA Office of Atmostpheric Programs. Analysis of HR2454. 

http://www.epa.gov/climatechange/economics/economicanalyses.html

9 U.S. EPA. 2009. eGrid2007 dataset. http://www.epa.gov/cleanenergy/energyresources/

egrid/index.html. Accessed February 3, 2010. The Emissions & Generation Resource Integrated Database 

(eGRID) is a comprehensive inventory of environmental attributes of electric power systems. The preeminent 

source of air emissions data for the electric power sector, eGRID is based on available plant-specific data for all 

U.S. electricity generating plants that provide power to the electric grid and report data to the U.S. government.

10 MY 2012-2016 Final Rule, Section III.2.C

11 EPA. Final Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate 

Average Fuel Economy Standards. Joint Technical Support Document. Chapter 4. EPA-420-R-10-901 

http://www.epa.gov/otaq/climate/regulations/420r10901.pdf. Original data found in Intergovernmental Panel on 

Climate Change. Chapter 2. Changes in Atmospheric Constituents and in Radiative Forcing. September 2007. 

http://www.ipcc.ch/pdf/assessmentreport/ar4/wg1/ar4-wg1-chapter2.pdf. Docket ID: EPA-HQ-OAR-2009-0472-

0117
2017-2025 Technical Assessment

F-1

F1 Appendix F: EPA Documentation of OMEGA model 

Analysis

F1.1 Overview of OMEGA

This Appendix provides the methodology underlying the technical assessment of the 

future vehicle scenarios presented in Chapter 6. As in the analysis of the MY 2012-2016 

rulemaking, evaluating the feasibility of these scenarios included identifying potentially available 

technologies and assessing their effectiveness, cost, and impact on relevant aspects of vehicle 

performance and utility. The wide number of technologies which are available and likely to be

used in combination required a method to account for their combined cost and effectiveness. As 

described in Chapter 6, this included developing three distinct technology pathways which 

emphasized one or the other of the more advanced technologies, such as hybrids, advanced 

gasoline engine, plug-ins and battery EVs. 

Applying these technologies efficiently to the wide range of vehicles produced by various 

manufacturers is a challenging task. In order to assist in this task, EPA has developed a 

computerized model called the Optimization Model for reducing Emissions of Greenhouse gases 

from Automobiles (OMEGA). Broadly, the model starts with a description of the future vehicle 

fleet, including manufacturer, sales, base CO2 emissions, footprint and the extent to which 

emission control technologies are already employed. For the purpose of this Technical 

Assessment Report analysis, 63 generic vehicle platforms—were used to capture important 

differences in engine design, vehicle design and vehicle utility. The model is then provided with a 

list of technologies which are applicable to various types of vehicles, along with their cost and 

effectiveness and the maximum percentage of vehicle sales which can receive each technology. 

This list varies slightly depending on whether model year 2020 or 2025 standards are being 

evaluated and on the specific technology pathway being evaluated. The model combines this 

information with economic parameters, such as fuel prices and a discount rate, to project how 

manufacturers could apply available technology in order to meet specified levels of emission 

control. For this Technical Assessment Report, as all vehicle sales have been combined into a 

single manufacturer, the model indicates how the industry when complying as a single 

manufacturer might use technology to reduce GHG emissions. The resulting output is a 

description of which technologies are added to each vehicle platform, along with the 

accompanying cost.

OMEGA includes several components, including a number of pre-processors that assist 

users in preparing a baseline vehicle forecast,1creating and ranking technology packages,2and 

calculating the degree to which technology is present on baseline vehicles. The OMEGA core 

model assembles this information and produces estimates of increases in vehicle cost and CO2

reduction. Based on the OMEGA core model output, the technology penetration of the new 

vehicle mix and the scenario impacts (fuel savings, emission impacts, and other monetized 

benefits) are calculated by post-processors. The pre- and post- processors are Microsoft Excel 

spreadsheets and visual basic programs, while the OMEGA core model is an executable program 

written in the C# language. The files used in this analysis, as well as the current version of 

OMEGA, are available in the TAR docket.
Appendix F

F-2

Figure F1.1-1: Information Flow in the OMEGA Model

A detailed description of the OMEGA model, as well as the general modeling 

methodology is provided in the MY 2012-2016 rule preamble Section III.D. Consequently, 

the interested reader may find additional depth there,3or in the OMEGA user guide on the 

EPA website.4 The remainder of this appendix assumes a basic knowledge of OMEGA’s 

operation, and focuses on the particular data sources and methodologies used in the scenario 

analysis described in Chapter 6.

F1.2 Summary of Inputs

The inputs underlying the OMEGA analysis have significant impacts on the results, 

and are described in detail elsewhere in this Assessment Report, as follows. The fleet 

projection used for this analysis is described in Appendix A. The vehicle technology 

packages are described in Chapter 3 and Appendix B. The inputs relating to air conditioning

controls are outlined in Appendix D. The other economic and environmental outputs are 

described in Appendix E. The detailed description of analytic scenarios, including the 

standards modeled and the reasoning behind a single fleet analysis, is available in Chapter 6. 

Generally, the table of contents to this technical assessment is a useful guide to additional 

detail. 

F1.3 Configuration of the Scenario File 

The scenario file in OMEGA contains a directory of data input files, a group of

economic parameters, and a set of CO2 g/mile targets. For the Technical Assessment Report

analysis, OMEGA was configured so that each technical pathway/model year combination

was a single scenario file containing six runs. Four runs corresponding to each of the four 

emission control scenarios (i.e., 3% per year, 4% per year, etc.) were included. Also included 

were a diagnostic run requiring maximum application of technology, as well the reference 

case scenario of MY 2016 GHG standards from the recent MY 2012-2016 final rule. As a 
2017-2025 Technical Assessment

F-3

result, six scenario files were created (2 MYs x 3 technical pathways), and each scenario file 

contained parameters for six OMEGA runs. 

The emission control scenarios were each configured with a flat standard 

corresponding to the appropriate stringency. No limits were placed on credit transfers

between the car and truck fleets. As in the MY 2012-2016 final rule analysis, EPA accounted 

for the emission reductions and technology costs due to air conditioning controls outside of 

the OMEGA model. In the MY 2025 timeframe, air conditioning remains a highly costeffective technology to control GHG emissions, and consequently, EPA projects that the 

entire market will convert to low leakage, high efficiency systems. In the time frame of MY 

2020 and later, these emission reductions were assigned a statutory value of 20.6 grams in the 

reference scenario5and 15.3 grams in the control scenarios.6 An example of the adjustments 

is shown in Table F1.3-1. The MY 2016 footprint curves and the flat standards were each

adjusted by the maximum potential AC credits to produce the credit adjusted targets. The 

agencies note, as discussed in Chapter 6 above, that the upcoming federal rulemaking analysis 

will consider fuel economy and emission control scenarios defined in terms of attribute-based 

standards, but we believe the scenarios considered here are meaningful for purposes of this 

assessment.

Table F1.3-1: Adjustment of Standards for Air Conditioning Credits

Scenario Sales-Weighted 

MY 2025 Target

Projected AC 

Credits1

Sales-Weighted MY 

2025 Credit Adjusted

Target

Reference 248.1 20.6 268.7

3% 190.1 15.3 205.4

4% 173.1 15.3 188.4

5% 157.6 15.3 173.9

6% 143.2 15.3 158.5
Appendix F

F-4

A further adjustment was made with respect to the credit adjusted targets listed above. 

The scenarios described in this document are defined by a sales weighted average of car and 

truck CO2 emissions. When credit transfer is allowed between cars and trucks, OMEGA 

weights the CO2 average by both sales and vehicle miles traveled (VMT).

A

 Light trucks 

generally are driven more than cars, so the sales and VMT weighted CO2 emission average 

tends to be slightly lower than the sales-weighted average. To account for this difference, the 

diagnostic run was used to produce VMT and sales weighted targets that corresponded to the 

sales weighted targets listed above. These calibrated targets can be seen in the scenario files 

available in the TAR docket.

We also updated the VMT ratios used in car/truck credit transfer to the appropriate 

MY lifetime values discussed in Appendix E. 

F1.4 Configuration of the Technology File 

The technology input file defines the technology packages which the model can add to 

the vehicle fleet. A separate technology file was developed for each of the six technology 

pathway/model year combinations considered in this Technical Assessment Report. While 

the individual technology costs were the same between technology pathways, they differed 

between MY 2020 and MY 2025 due to the learning effects discussed in the Appendix 3 and 

the MY 2012-2016 Final Rule Section II.E. Due to the different limits on maximum 

penetrations of several key technologies (discussed in Chapter 6), each of the technology 

pathways also required a separate technology file and model run. The change in those 

maximum penetration rates also slightly affected the set of most cost effective technology 

packages selected for inclusion in the OMEGA model runs. The processes to build and rank 

technology packages for the technology file are described in the Chapter 3 and Appendix B of 

this report. This section describes the configuration of the OMEGA Technology input file

which occurs after the ranked packages are developed. 

F1.4.1 Multiple Fuel Tracking

OMEGA 1.0.2, which was used during the MY 2012-2016 rule analysis, tracked CO2

emissions at the vehicle platform level. For the present analysis, an upgrade was made to the 

OMEGA model to track CO2 emissions by fuel within each vehicle platform. As a result, a 

vehicle platform can be composed of sub-vehicles, each with its own fuel, CO2 emission rate

and electricity consumption rate. To facilitate this tracking, every technology is encoded 

with its operating fuel, as well as the fuel of the vehicles to which it applies. In combination

with technology specific caps,Bthis allows a vehicle platform to be split so that subsequent 

technologies can be applied to the specific subsets of the vehicle (Table F1.4-1). Thus, for 

example, a certain fraction of a vehicle’s sales can be equipped with a diesel engine. 

Subsequent diesel-based technologies can then be applied more simply and directly to this 

 

A This practice is consistent with EPA’s MY 2012-2016 regulations allowing VMT weighted credit transfer 

between car and truck fleets.

B

―Cap‖ is a shorthand term for the maximum penetration rates for certain technologies which define the various 

technology paths.
2017-2025 Technical Assessment

F-5

subset of sales. The model keeps track of the sales and CO2 emission rates of both the 

gasoline and diesel versions of the vehicle. 

In the example below, Technology Package 3 is applied to the gasoline fuel vehicle 

created by the application of Technology Package 1. Technology Package 4 is applied to the 

diesel fuel vehicle created by the application of Technology Package 2. 

Table F1.4-1: Example of Multiple Fuel Technology File

Tech 

Package

Name Cap1Fuel of the 

Technology

Fuel to which the 

Technology Applies

1 GDI Gasoline Engine 100% Gasoline Gasoline

2 Diesel Engine 15% Diesel Gasoline

3 Gasoline Hybrid 100% Gasoline Gasoline

4 Improved Diesel 100% Diesel Diesel

1Please note that OMEGA technology caps are relative to the population on that fuel, so a 100% cap on 

technology package four indicates that it applies to 100% of the 15% of vehicles which were converted to diesel 

in step 

In the current TAR analysis, this model feature simplified the ability to apply several 

types of electric vehicle and plug-in electric vehicle technology packages to the same baseline 

vehicle. In addition, we found it useful when applying certain advanced gasoline technology 

packages which had caps of less than 100%. For example, most of the technology paths limit 

the use of advanced (e.g., EGR-boosted) gasoline engine technologies to less than 100%. In 

most cases, further technology packages can be applied to both the vehicles which received 

this advanced gasoline technology and those that did not. By effectively treating ―advanced 

gasoline engines‖ as including a change in fuels, we were able to simplify the addition of 

subsequent technologies to both the subset of vehicle sales with this technology and that 

without it. This could have been accomplished without taking advantage of the OMEGA 

model’s new fuel tracking capability, but the estimation of the cost and effectiveness of the 

subsequent technology packages would have had to consider the fact that they were being 

applied to a subset of the vehicle’s sales which did not have the average attributes of that 

vehicle at that stage of technology addition. 

For example, if EGR boost technology is added to 50% of the sales of those vehicles 

operating on gasoline, it may be possible to hybridize both the vehicles with and without the 

EGR boost technology, with differing costs and effectiveness. It is possible to determine the 

overall impact of hybridizing the non-EGR vehicles first and then the EGR-boosted vehicles 

and developing the appropriate OMEGA model inputs which accomplish both of these steps 

of technology addition. However, since we were not using all of the fuel types currently 

tracked in the OMEGA model (e.g. E10), it was easier to separate the EGR-boosted vehicles 

from those without this technology by changing the former vehicles’ fuel to ―E10‖. We 

simply made the fuel properties of E10 exactly the same as those for gasoline. Then for 

example, the incremental effect of hybridizing the non-EGR boosted vehicles could be used 

directly in the model without the need to sales weight this impact by including the fact that the 

emissions of the non-EGR vehicles were not changing. 
Appendix F

F-6

To further illustrate this issue, consider the case of Vehicle A, a gasoline vehicle with 

CO2 emissions of 300 g/mile. In this example scenario, diesel packages are limited to 50% of 

the fleet because of concerns relative to production capacity.

C

 In this case, two sequential 

diesel packages should be applied to the same 50% subset of the vehicle (Table F1.4-2). As 

can be seen in this table, OMEGA 1.3 now more accurately attributes the reductions to the 

appropriate subset within the vehicle platform. 

Table F1.4-2: Tracking CO2

Step Package 

Fuel

Maximum 

Penetration 

Limit

Reduction OMEGA 1.0.2

Applied to average

vehicle.

OMEGA 1.3

Applied to a specific fuel 

within a platform.

CO2 Avg CO2 

Avg

CO2 

Gas

CO2 

Diesel

300 300 300 N/A

1 Diesel 50% 10% 285 285 300 270

2 Diesel 50%/100% 10% 270.75 271.5 300 243

1The maximum penetration limit in the second step applies to 50% of the total vehicles (OMEGA 1.0.2) or 100% 

of the diesel vehicles (OMEGA 1.3)

In the analysis presented in this report, we encode limited technologies to different 

fuels so that the appropriate reductions are taken. As an example, plug-in hybrids are coded 

to diesel fuel. The fuels input file was modified so that the appropriate gasoline fuel 

properties are attributed to ―diesel‖ fuel.

F1.4.2 Tracking of Electricity

OMEGA 1.3 also tracks electrical consumption in kWh per mile. Each technology 

package is now associated with an ―electricity conversion percentage‖ which refers to the 

increase in the energy consumed by the electric drivetrain relative to reduction in the 

consumption of energy from liquid fuel. Electricity is a highly refined form of energy which 

can be used quite efficiently to create kinetic energy. Thus, electric motors are much more 

efficient than liquid fuel engines. Consequently, the electric consumption percentage input in 

in the Technology File for plug-in vehicles is generally well below than 100%. It may be 

possible that this percentage could exceed 100% under certain circumstances, for example 

when one type of plug-in vehicle is being converted into another plug-in vehicle and 

electricity consumption per mile is increasing due to larger and heavier batteries, etc. 

However, that was not the case for any of the technologies evaluated in this analysis.

 

C

Please note, this is just an example, and has no implications relative to actual maximum penetration rates for 

diesel vehicles.
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F-7

F1.5 Configuration of the Market File

F1.5.1 Creating the Generic Vehicles

As discussed in Section F1.4 above, vehicle manufacturers typically develop many 

different models by basing them on a smaller number of vehicle platforms. The platform 

typically consists of a common set of vehicle architecture and structural components. This 

allows for efficient use of design and manufacturing resources. In the MY 2012-2016 Final 

Rule, EPA created over 200 vehicle platforms which were used to capture the important 

differences in vehicle and engine design and utility of future vehicle sales of roughly 16 

million units in the 2016 timeframe. For the current analysis, we are not differentiating 

between manufacturers, and consequently require fewer vehicle platforms for the analysis. 

The approximately sixty vehicle platforms are a result of mapping the 1130 vehicle fleet into 

the 19 engine based vehicle types (Table F1.5-1) and the 10 body size and structure based 

utility classes (Table F1.5-2). As not all vehicle types match to all utility types, the number of 

generic vehicles is less than the multiplicative maximum of the two tables.

Table F1.5-1 : Vehicle Types in the TAR Analysis

Vehicle Type # Name Cam Engine

1 Subcompact Car DOHC I4

2 Compact Car I4 DOHC I4

3 Midsize Car/Small MPV (unibody) DOHC I4

4 Compact Car/Small MPV (unibody) DOHC V6

5 Midsize/Large Car DOHC V6

6 Midsize Car/Large Car DOHC V8

7 Mid-sized MPV (unibody)/Small Truck DOHC I4

8 Midsize MPV (unibody)/Small Truck SOHC V6

9 Large MPV (unibody) SOHC V8

10 Large MPV (unibody) SOHC V8

11 Large Truck (+ Van) SOHC V6

12 Large Truck + Large MPV OHV V6

13 Large Truck (+ Van) OHV V8

14 Large Truck (+Van) SOHC3V V8

15 Large Car OHV V8

16 Large MPV (unibody) DOHC V6

17 Large MPV (unibody) DOHC V8

18 Large Truck (+ Van) DOHC V6

19 Large Truck (+ Van) DOHC V8

Table F1.5-2 : Vehicle Types in the Technical Assessment Analysis

Utility 

Class #

Utility Class Vehicle Use 1Footprint Criteria Structure Criteria

1 Subcompact Auto Car Footprint <43 --

2 Compact Auto Car 43<=Footprint<46 --

3 Mid Size Auto Car 46<=Footprint<53 --
Appendix F

F-8

4 Large Auto Car 56<=Footprint --

5 Small SUV SUV 43<=Footprint<46 --

6 Large SUV SUV 46<=Footprint --

7 Small Pickup Pickup Footprint < 50 --

8 Large Pickup Pickup 50<=Footprint --

9 Cargo Van Van -- Ladder Frame

10 Minivan Van -- Unibody

1. Vehicle use type is based upon analysis of EPA certification data.

F1.5.2 Accounting for Technology already on the Vehicles

The market data input file utilized by OMEGA, which characterizes the vehicle fleet, 

is designed to account for the fact that the 2008 model year vehicles which comprise our 

baseline fleet may already be equipped with one or more of the technologies available in 

general to reduce CO2 emissions. As described in Appendix B, EPA decided to apply 

technologies in packages, as opposed to one at a time. However, 2008 vehicles were 

equipped with a wide range of technology combinations, many of which cut across the

packages. Thus, EPA developed a method to account for the presence of the combinations of 

applied technologies in terms of their proportion of the EPA packages described in Chapter 3. 

This analysis can be broken down into four steps 

The first step in the updated process is to breakdown the available GHG control 

technologies into five groups: 1) engine-related, 2) transmission-related, 3) hybridization, 4) 

weight reduction and 5) other. Within each group we gave each individual technology a 

ranking which generally followed the degree of complexity, cost and effectiveness of the 

technologies within each group. More specifically, the ranking is based on the premise that a 

technology on a 2008 baseline vehicle with a lower ranking would be replaced by one with a 

higher ranking which was contained in one of the technology packages which we included in 

our OMEGA modeling. The corollary of this premise is that a technology on a 2008 baseline 

vehicle with a higher ranking would be not be replaced by one with an equal or lower ranking 

which was contained in one of the technology packages which we chose to include in our 

OMEGA modeling. This ranking scheme can be seen in the TEB/CEB calculation macro, 

available in the docket.

In the second step of the process, we used these rankings to estimate the complete list 

of technologies which would be present on each baseline vehicle after the application of each 

technology package. We then used the EPA lumped parameter model to estimate the total 

percentage CO2 emission reduction associated with the technology present on the baseline 

vehicle (termed package 0), as well as the total percentage reduction after application of each 

package. This process was repeated to determine the total cost of all of the technology 

present on the baseline vehicle and after the application of each applicable technology 

package. 

The third step in this process is to determine the degree of each technology package’s 

incremental effectiveness and incremental cost is affected by the technology already present 

on the baseline vehicle. The degree to which a technology package’s incremental 

effectiveness is reduced by technology already present on the baseline vehicle is termed the 
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F-9

technology effectiveness basis, or TEB, in the OMEGA model. The value of each vehicle’s 

TEB for each applicable technology package is determined as follows:

, 1

,

, 1

,

,

, 1

1

1

1

1

1

1

1

p i

p i

p i

p i

v i

v i

i

TotalEffec t

TotalEffec t

TotalEffec t

TotalEffec t

TotalEffec t

TotalEffec t

TEB

Where

TotalEffectv,i = Total effectiveness of all of the technologies present on the baseline vehicle after 

application of technology package i

TotalEffectv,i-1 = Total effectiveness of all of the technologies present on the baseline vehicle after 

application of technology package i-1

TotalEffectp,i = Total effectiveness of all of the technologies included in technology package i

TotalEffectp,i-1 = Total effectiveness of all of the technologies included in technology package i-1

Equation 1.5-1 – TEB calculation

The degree to which a technology package’s incremental cost is reduced by 

technology already present on the baseline vehicle is termed the cost effectiveness basis, or 

CEB, in the OMEGA model. The value of each vehicle’s CEB for each applicable 

technology package is determined as follows:

CEBi = 1 – (TotalCostv,i – TotalCostv,i-1) / (TotalCostp,i – TotalCostp,i-1)

Where 

TotalCostv = total cost of all of the technology present on the vehicle after addition 

of package i or i-1 to baseline vehicle v

TotalCostp = total cost of all of the technology included in package i or i-1

i = the technology package being evaluated

i-1 = the previous technology package 

Equation 1.5-2 – CEB calculation

The values of CEB and TEB are capped at 1.0 or less, since a vehicle cannot have 

more than the entire package already present on it. In other words, the addition of a 

technology package cannot increase emissions nor reduce costs. (A value of 1.0 causes the 

OMEGA model to not change either the cost or CO2 emissions of a vehicle when that 

technology package is added.) The value of a specific TEB or CEB can be negative, however. 

This implies that the incremental effectiveness or the incremental cost of adding a package 

can be greater than that when adding the packages in sequence to a vehicle with no baseline 

technology. 

An example of this is a baseline vehicle with a 6 speed manual transmission. All of 

our technology package effectiveness and cost estimates are estimated for specified baseline 

vehicles, all of which have 4 speed automatic transmissions. Our technology packages 

improve this transmission, sometimes to a 6 speed automatic transmission and then a dual 

clutch transmission and sometimes directly to a dual clutch transmission. Subsequent 
Appendix F

F-10

packages may then strongly hybridize the vehicle. If a baseline vehicle has a 6 speed manual 

transmission, this transmission is unaffected by the technology packages which include either 

a 6 speed automatic transmission or a dual clutch transmission, since the manual transmission 

is both cheaper and/or more efficient than these other transmissions. However, when the 

vehicle is hybridized, this manual transmission is replaced. The incremental cost of changing 

this vehicle to a power-split hybrid design, for example, is greater than that for a vehicle with 

a dual clutch transmission, since the credit for removing the manual transmission is less than 

that for the dual clutch transmission. The negative CEB causes the OMEGA model to apply a 

cost for this power-split package which is slightly higher than that for the typical baseline 

vehicle. 

The fourth step is to combine the fractions of the cost and effectiveness of each 

technology package already present on the individual 2008 vehicles models for each vehicle 

type. For cost, percentages of each package already present are combined using a simple 

sales-weighting procedure, since the cost of each package is the same for each vehicle in a 

vehicle type. For effectiveness, the individual percentages are combined by weighting them 

by both sales and base CO2 emission level. This appropriately weights vehicle models with 

either higher sales or CO2 emissions within a vehicle type. Once again, this process prevents 

the model from adding technology which is already present on vehicles, and thus ensures that 

the model does not double count technology effectiveness and cost associated with complying 

with the reference standards or the CO2 control scenarios. 

For this analysis, we automated the process through a visual basic macro that both 

operates the lumped parameter model and calculates the TEBs and CEBs. This macroenabled excel file is available in the docket.

F1.6 Post-processing OMEGA

F1.6.1 A/C Credits

As noted above, A/C credits were simply subtracted off the OMEGA results for both 

the reference and control cases. A/C system costs were added into both cases. As a result, the 

delta between reference and control cases, both in terms of costs and environmental impact, 

did not change. 

F1.6.2 Calculating Technology Penetrations 

Technology penetrations were calculated using the new ―techpacksales‖ output file of the 

OMEGA model. This output provides, for each of the approximately 60 vehicle platforms, 

the distribution of sales among the tech packs. In a post-processing step, this distribution is 

applied back to the 1130 individual vehicles of the disaggregate baseline fleet projection so 

that we have the tech pack distribution of each vehicle. As discussed in the description of 

TEB/CEB calculations, we have already produced a file which contains the specific 

technologies on each vehicles with every possible technology package. By applying the 

technology pack distributions from the 60 vehicle platforms back against the 1130 vehicles in 

dissagregated fleet, we are able to determine the specific technologies on each vehicle in each 

scenario and tech pathway. As an example, this file would show what technologies are 
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F-11

actually on a Ford F150 with technology package 1, 2, 3 etc. This file is combined with 

OMEGA’s technology pack distribution output to determine the penetration of each tracked 

technology. 

F1.6.3 Impacts Calculations

Liquid fuel consumption, electricity consumption and emission impacts were 

calculated in a modified version of the post-processor spreadsheet that was used in the MY 

2012-2016 final rule. This spreadsheet, available in the downloadable material accompanying 

this technical assessment report, is the repository for the inputs discussed in Appendix E. The 

impacts calculations sequentially calculate light duty vehicle stock, VMT, and impacts for 

each MY and CY from 2010 through 2050. Outputs are available on either calendar year or 

model year basis. For this Technical Assessment Report, the VMT algorithm was integrated 

into the benefits calculations, electricity calculations were added, and the inputs and outputs 

were restructured. Provided the same inputs, the current benefits spreadsheet would still 

provide the same outputs as the version used in the MY 2012-2016 Final Rule.

A detailed discussion of the benefits calculations algorithms is available in the MY 

2012-2016 Final Rule RIA chapter 5 and in the OMEGA users guide.

We note that the current analysis did not rely upon many of the outputs of the 

OMEGA benefits post-processor. These outputs, such as co-pollutant impacts, monetized 

emission impacts, the benefits of additional travel time, and damages due to noise, accidents, 

and congestion, may not produce accurate results in the context of the numerous input 

changes, and should not be used.
Appendix F

F-12

Appendix F References

1 Appendix A

2 Appendix B

3

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

4

http://www.epa.gov/oms/climate/models.htm

5 EPA. LD GHG MY 2012-2016 Rule, RIA Chapter 2 and 5.

6 Appendix D to this report.
2017-2025 Technical Assessment

G-1

G1 Appendix G: Infrastructure

Appendix G contains a compilation of additional information to support Chapter 4, 

Infrastructure Assessment. Appendix G contains additional information covering the 

following topic areas:

DOE-funded grants for electric drive demonstration and evaluation programs

Estimates of costs of charging equipment

Battery end of life value 

Voluntary standards

Hydrogen Infrastructure

G1.1 American Recovery and Reinvestment Act: Transportation Electrification 

Initiative

 Through the American Recovery and Reinvestment Act of 2009 (ARRA), DOE has 

awarded cost-shared grants to companies under the Transportation Electrification Initiative to 

establish development, demonstration, evaluation, and education projects to accelerate the 

market introduction and penetration of advanced electric drive vehicles. The component 

projects of the Transportation Electrification Initiative and other DOE electric-drive vehicle 

infrastructure activities are discussed below. 

ECOtality North America

ECOtality North America has been awarded a cost-shared grant of nearly $115 million 

to support ―The EV Project,‖ to deploy electric-drive vehicles and charging infrastructure in 

sixteen major U.S. cities beginning in 2010. Upon full deployment of vehicles and 

infrastructure under this project in 2011, approximately 8,500 electric drive vehicles and 

14,850 Level 2 charging stations will be in service, providing a rich set of data regarding the 

operational and charging behavior of electric drive vehicle owners in a variety of markets.

The ECOtality project will install grid-connected vehicle infrastructure in Phoenix, 

AZ; Tucson, AZ; San Diego, CA; Los Angeles, CA; Portland, OR; Eugene, OR; Salem, OR; 

Corvallis, OR; Seattle, WA; Dallas, TX; Fort Worth, TX; Houston, TX; Nashville, TN; 

Knoxville, TN; Chattanooga, TN; and Washington, DC. Residential Level 2 charging stations 

will be provided at no cost to purchasers of the Nissan LEAF EV and the Chevrolet Volt 

Extended Range Electric Vehicle (EREV) who subscribe to the program. Additionally, Level 

3 DC ―fast‖ chargers will be installed along routes connecting neighboring cities – such as 

Nashville/Knoxville/Chattanooga, Phoenix/Tucson, and Seattle/Portland/Eugene –

establishing a network of electric vehicle corridors between electric transportation hubs. 

More information about The EV Project is available at http://www.theevproject.com.

Coulomb Technologies
Appendix G

G-2

Coulomb Technologies has been awarded a cost-shared grant of $15 million to support 

its ―ChargePoint America‖ project, to deploy electric-drive vehicles and charging 

infrastructure in nine major metropolitan areas beginning in 2010. The project will result in 

the deployment of approximately 5,000 Level 2 charging stations at residential and 

commercial locations in Bellevue/Redmond, WA; Sacramento, CA; San Jose/San Francisco 

Bay, CA; Los Angeles, CA; Austin, TX; Detroit, MI; New York, NY; Washington, DC; and 

Orlando, FL. Residential chargers will be provided to purchasers of the Chevrolet Volt 

EREV – in some cases, at no cost – and will also be deployed in conjunction with electric 

drive vehicles from Ford and Smart USA. More information about ChargePoint America is 

available at http://www.chargepointamerica.com.

Navistar

Navistar was awarded a cost-shared grant of over $39 million to develop and 

demonstrate a fleet of all-electric medium-duty delivery trucks, which the company has 

named the eStar. These vehicles will be manufactured in Wakarusa, IN, and deployed 

through various fleet partners nationwide. In total, 950 Class 2c-3 electric trucks will be 

deployed in conjunction with 950 Level 2 charging stations, at locations specified by the 

respective fleet owners. Data collected from these vehicles and charging stations will provide 

valuable information regarding the performance and suitability of medium-duty electric 

vehicles and the infrastructure required to support them. More information about eStar trucks 

is available at http://www.estar-ev.com.

General Motors

General Motors was awarded a cost-shared grant of over $30 million to develop and 

deploy a fleet of Chevrolet Volt EREVs, and to gather data on vehicle performance and 

infrastructure requirements. A fleet of 125 Chevy Volts will be deployed in combination with 

over 650 Level 2 charging stations, through electric utility partners in several diverse 

geographic locations throughout the U.S. The project will include the installation, 

demonstration, and testing of charging infrastructure in residential, commercial, and public 

locations. Additionally, a comprehensive set of data will be collected from the vehicles and 

charging stations from December 2010 through 2012, and will contribute to a more complete 

understanding of typical vehicle usage and operational needs, supporting the next generation 

of vehicle designs and infrastructure planning. The project will also include an analysis of 

fast charging requirements and the development and demonstration of smart charging 

capabilities using General Motors‘ OnStar telematics service.

Smith Electric Vehicles

Smith Electric Vehicles has been awarded a $32 million cost-shared grant to develop 

and demonstrate a fleet of all-electric medium-duty trucks. Approximately 500 vehicles will 

be built in Kansas City, MO, and deployed with 500 Level 2 charging stations through fleet 

partners representing a range of commercial and public-sector markets in diverse geographic 

and climatic areas by the end of 2011. In addition, the project will include the collection of 

real-world performance data using an automatic GPS-based telemetry system. The Smith 

Electric Vehicles project, combined with the Navistar project, will provide valuable insight 
2017-2025 Technical Assessment

G-3

into the applicability of electric-drive powertrains in medium-duty trucks in a variety of 

vocations. More information about Smith Electric Vehicles is available at 

http://www.smithelectric.com.

South Coast Air Quality Management District

SCAQMD was awarded a cost-shared grant of over $45 million to develop, 

demonstrate, and evaluate a fleet of medium-duty plug-in hybrid electric trucks and shuttle 

buses. A total of 378 vehicles will be demonstrated nationwide, in combination with 378 

Level 2 charging stations. The majority of the vehicles will be bucket trucks based on the 

Ford F-550 chassis, deployed through electric utility partners, while the shuttle buses, based 

on the Ford E-450, will be deployed via shuttle bus fleet operators. Data collected from the 

fleet will be analyzed in order to quantify the attributes of PHEV technologies for Class 4/5 

vehicles in terms of emissions, greenhouse gas reductions, and fossil fuel displacement. An 

additional goal of the project is to develop production ready smart charging capability for 

commercial applications. More information about the current status of this program is 

available at http://www.aqmd.gov/hb/2010/july/100710a.htm.

Chrysler Group LLC

Chrysler has been awarded a $48 million cost-shared grant to develop and demonstrate 

153 plug-in hybrid electric Dodge Ram pickup trucks combined with Level 2 charging 

infrastructure. The trucks and charging stations will be deployed through partner fleets in 

diverse geographies and climates, spanning from North Dakota to Arizona, and from Hawaii 

to Massachusetts. Full deployment of the vehicles will be achieved in early 2011, followed 

by data collection and vehicle monitoring activities through 2013 in order to prove real-world 

product viability and to quantify the benefits to consumers and to the nation. As part of this 

project Chrysler, with support from its project partners, will develop and demonstrate bidirectional charging capability.

Education Grants

Through the Transportation Electrification Initiative, ten grants totaling nearly $40 

million were awarded to educational institutions to establish programs to train engineers, 

technicians, and emergency first responders, as well as to inform the general public, in 

preparation for the transition to vehicles with advanced electric drive technologies. At the 

university level, graduate and undergraduate engineering degree programs will be created to 

educate students in technologies related to electric drive vehicles and charging infrastructure. 

Several community colleges received grants to establish technical training courses and 

certificate programs to train service personnel and automotive technicians to properly service 

and maintain vehicles with electric drive powertrains. Similarly, electric vehicle safety 

training programs will be created to train emergency personnel in proper safety protocols 

related to electric vehicles and infrastructure, which will differ from current vehicles and 

infrastructure with which first responders are already familiar. Furthermore, consumer 

outreach and K-12 educational materials will be created to familiarize the general public with 

electric-drive vehicle capabilities and infrastructure utilization. All of these activities will 

take place through projects supported by Transportation Electrification grants awarded to the 
Appendix G

G-4

University of Michigan, J. Sargeant Reynolds Community College, West Virginia 

University/National Alternative Fuels Training Consortium, Michigan Technological 

University, Missouri University of Science and Technology, Wayne State University, 

Colorado State University, Purdue University, City College of San Francisco, and the 

National Fire Protection Association.

G1.2 Charger Cost Estimates

The following list of charger cost estimates details the sources and the respective 

estimates pulled from each that were used in constructing the charger cost estimate Table 4.2-

2, ―Estimated Costs for Charging Stations‖. Here, the estimates are listed by source along 

with assumptions and context that are relevant to the cost estimate.

Level 1

1. Residential (Morrow, Karner and Francfort, 2008)1

a. Charge cord + circuit installation, 20A $878

2. Public networked (May and Mattila, 2009)2

a. 12A stations (Coulomb Technologies) $2500 each + $1000 for ―gateway‖ station

3. Public (May and Mattila, 2009)3

a. 20 amp/4 vehicle (Shorepower Technologies/SynkroMotive) $2500-$2900

4. Apartment complex, not networked (5 stations) (Morrow, Karner and Francfort, 2008)4

a. 5 charge cords $1250

b. 5 20 amp circuits $2221

c. Installed $4165

Level 2, Residential or Fleet Depot

1. Residential, no service panel upgrade (ETEC, 2009)5

a. 40 amp EVSE $780

b. Installed $2272

2. Residential (Morrow, Karner and Francfort, 2008)6

a. EVSE 32 amp $650

b. Charge cord $200

c. 40 amp circuit $1080

d. Installed $2146

3. Residential, no upgrade (May and Mattila, 2009)7

a. 9-25 amp EVSE, output 3.3 kW (Brusa/Metric Mind) $3870 - $6353

4. Residential (Electrification Coalition, 2009)8

a. No upgrade $500-$1500

b. With upgrade, ―up to $2500‖) 

5. Commercial Fleet (10 stations) (ETEC, 2009)9

a. Distribution panel $650

b. EVSE 40 amp $780 * 10

c. EVSE Pedestal $450 * 10

d. Installed $31,375
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e. $3138/station

6. Apartment complex, not networked (5 stations) (Morrow, Karner and Francfort, 2008)10

a. 5 EVSEs $3250

b. 5 charge cords $1000

c. 5 circuits $2611 including labor costs for circuits and EVSEs

d. Installed $7597 for 5 stations

e. $1520/station

Level 2, Public

7. Public (2 chargers) (ETEC, 2009)11

a. Distribution sub-panel $250

b. EVSE 40 amp $780 * 2

c. EVSE Pedestal $450 * 2

d. Installed $12,875

e. $6438/station

8. Public networked (May and Mattila, 2009)12

a. 32 amp stations (Coulomb Technologies) $3500 each + $1000 for ―gateway‖ station

b. 120 amp stations, charges 4 vehicles (EV-Charge America) $1200-$1500

c. 16.8 kW smart station (GoSmart Technologies) $2200-$3800

d. Above apparently are hardware only 

9. Public stations (May and Mattila, 2009)13

a. Pre-assembled unit, $1400-$1800/single 24-30 amp, $2800/60 amp double (eTec)

10. Public (Electrification Coalition, 2009)14: up to $5,000

Level 3, Public Quick Charge

1. Public Level 3 (2 stations) (ETEC, 2009)15

a. Distribution sub-panel $650

b. Fast charger (30 kW) $25,000 * 2

c. Point of sale system $2500

d. Installed $64,158

2. Unspecified (Electrification Coalition, 2009)16 $25,000-$50,000

3. Nissan 50 kW Quick EV Charger, CHAdeMO standard, manufacturer‘s suggested retail price, 

not including installation $17,500 – 20,600A,17

4. Confidential submission, EVSE in high volume, direct manufacturing cost, not including 

installation $8,000B

The range in the costs for quick-charge EVSEs reflects a difference between current, 

relatively low volume public quick-charge EVSEs and a future EVSE incorporating multiple 

 

A Lower cost is base unit, higher cost reflects options for hot or cold climate operation.

B Confidential information provided to EPA, ARB and NHTSA, August 2010. Manufacturing cost and general 

description of architecture cleared for release by the original source on September 10, 2010.
Appendix G

G-6

chargers of the same type used for on-vehicle charging in order to share economies of scale 

between EVSEs and components sourced in much higher volume for automobile production. 

This would be expected to provide a significant cost reduction for some of the most expensive 

components within public quick-charge EVSEs.

G1.3 Battery End-of-Life Value Potential

Chapter 4.2.4 discusses issues surrounding the assessment of a secondary use value for 

EV/PHEV batteries. Work is underway to study this issue, including the extent of the market 

for secondary use batteries and the potential value to the original vehicle purchaser. This 

section summarizes one such study supported by DOE. 

Accelerated development and market penetration of PHEVs and EVs is presently 

restricted by the high cost of lithium-ion (Li-Ion) batteries. In fact, it has been estimated that a 

~50% reduction in battery costs is necessary to equalize the current economics of owning 

PHEVs and conventionally fueled vehicles.18

One way to address this problem is to recover a fraction of the battery cost via reuse in 

other applications after it is retired from service within the vehicle, where it may still have 

sufficient performance to meet the requirements of other energy storage applications. By 

extracting additional services and revenue from the battery in a post-vehicle application, the 

total lifetime value of the battery is increased. 

There are several current and emerging applications where the secondary use of PHEV 

and EV batteries may be beneficial. For example, the use of renewable solar and wind 

technologies to produce electricity is growing, and their increased market penetration requires 

energy storage to mitigate the intermittency of wind and solar energy. New trends in utility 

peak load reduction, energy efficiency, and load management also need energy storage. Smart 

grid, grid stabilization, low-energy buildings, and utility reliability require energy storage as 

well. It is reasonable to suggest that some utility applications are capable of supporting 

2010‘s new battery prices.19 20 21 Assuming that battery prices fall faster than the value of 

these utility applications (not improbable, given the anticipated decline in battery prices and 

that the increased presence of renewable generation should drive utility application values 

higher), the same will be true in the 2017-2025 time frame. 

Thus, substantial markets for used automotive batteries may exist, and given that the 

allowable battery costs for these applications will exceed new battery prices, battery salvage 

values must be determined relative to competing products rather than application values. 

Assuming that a primary competitor is new automotive Li-Ion batteries, salvage values can be 

computed based upon anticipated future Li-Ion prices. Additionally, the salvage value must be 

greater than the ―competing‖ application of leaving the battery in the aging vehicle and 

accepting its reduced range capability or selling it to someone with reduced range 

requirements. Under these assumptions, it is reasonable to assume that the future salvage 

value of a used PHEV/EV battery will be proportional to the cost of an equally capable new 

battery, taking into consideration the health of the used battery, the cost of collecting, 

refurbishing, and certifying the used battery, and a  ̳used‘ product discount factor. Given 

efforts to ramp up automotive battery production between 2010 and 2015, it is reasonable to 
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G-7

assume that such batteries will be a relatively mature product and that the majority of the 

benefits owed to economies of scale will be achieved by 2017, leading to the following: 

· Battery life will be improved such that 10 years of in-vehicle life is common and 

significant health remains in the battery post automotive retirement 

· Battery price reduction across the battery life will be relatively small 

· Batteries will be treated as a commodity, thus used product discounts will be 

fairly low 

· Recognizing the value of secondary use and leveraging advances in battery 

health monitoring, automotive batteries will be designed to minimize reconditioning costs 

Based on the preceding conditions, one study estimates that net present salvage values 

for EV/PHEV batteries sold in the 2017-2025 time frame are approximately 20% of their 

initial purchase price.22

G1.4 List of Voluntary Standards

This list of voluntary standards illustrates the complexity and interrelationships due to 

the addition of communication to the interface between the vehicle and each major element of 

the consumer-vehicle-grid system. These efforts are to enhance long-term success; however, 

they are not a prerequisite for a successful near-term market launch. It is worth noting that 

the SAE J1772 standard is complete, which is a significant development; many others are still 

under development.

SAE – The following existing standards were identified in the Phase 1 NIST 

Framework and Roadmap for Smart Grid Interoperability StandardsCas standards that can be 

used now to support Smart Grid development: 

SAE J1772 Electrical Connector between PEVD/EV and EVSE 

o SAE J1772TM Electric Vehicle and Plug in Hybrid Electric Vehicle 

Conductive Charge Coupler

SAE J2293 Communications between PEVs and EVSE for DC Energy [Part 1, 

Part 2] 

o SAE J2293/1 Energy Transfer System for Electric Vehicles: 

Functional Requirements and System Architectures

 

C Available at http://www.nist.gov/public_affairs/releases/upload/smartgrid_interoperability_final.pdf (last 

accessed August 26, 2010).

D

―PEV‖ (plug-in electric vehicle) is SAE‘s language of choice for what is called a PHEV elsewhere in this 

document.
Appendix G

G-8

o SAE J2293/1 Energy Transfer System for Electric Vehicles: 

Communication Requirements and Network Architecture

SAE J2836/1-3 Use Cases for PEV Interactions (in development) [Part 1, Part 2, 

Part 3] 

o J2836/1 Use Cases for Communication between Plug-in Vehicles 

and the Utility Grid

o J2836/2 Use Cases for Communication between Plug-in Vehicles 

and the Supply Equipment (EVSE)

o J2836/3 Use Cases for Communication between Plug-in Vehicles 

and the Utility Grid for Reverse Power Flow

o J2836/4 Use Cases for Diagnostic Communication for Plug-in 

Vehicles

o J2836/5 Use Cases for Communication between Plug-in Vehicles 

and their customers.

SAE J2847/1-3 Communications for PEV Interactions (in development) [Part 1, 

Part 2, Part 3] 

o J2847/1 Communication between Plug-in Vehicles and the Utility 

Grid

o J2847/2 Communication between Plug-in Vehicles and the Supply 

Equipment (EVSE)

o J2847/3 Communication between Plug-in Vehicles and the Utility 

Grid for Reverse Power Flow

o J2847/4 Diagnostic Communication for Plug-in Vehicles

o J2847/5 Communication between Plug-in Vehicles and their 

customers

J2894 Power Quality Requirements for Plug-in Vehicle Chargers – Part 1: 

Requirements

J2894/2 Power Quality Requirements for Plug-in Vehicle Chargers – Part 2: Test 

Methods

J2931/1 Power Line Carrier Communications for Plug-in Electric Vehicles
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IEEE – Standards Coordinating Committee 21 (SCC21) sponsors the development of 

1547 interconnection standards and the P2030 smart grid interoperability standards project.

IEEE 1547 Standard for Interconnecting Distributed Resources with Electric 

Power Systems

IEEE P2030 Guide for Smart Grid Interoperability of Energy Technology and 

Information Technology and Information Technology Operation with the Electric 

Power System (EPS) and End-Use Applications and Loads

UL – Underwriters Laboratories plays a critical role in the certification of hardware to 

be used in charging. UL offers certification for the many aspects of the EVSE, including the 

charge equipment (Levels 1-3), plugs, receptacles, cord sets and personal protection 

equipment. Of particular interest are specifications with respect to grounding/isolation.

NFPA - NEC, part 625, specifically addresses the installation of charging equipment. 

It is updated every 3 years; currently NEC-2008 applies and inputs/petitions for the next 

version (NEC-2011) are closed. The draft national template project relies heavily on the NEC 

as it is the primary reference for permitting and installation in local municipalities.

International - SAE and JARI agree on Level 2 charging standards (both countries 

use single-phase current); though, high-power Level 3 DC coupler standards for public 

charging differ substantially from those proposed in the U.S. (and Europe so far). The JARI 

Level 3 standards are promoted by CHAdeMO, an association formed in Japan to promote 

global adoption of JARI EV infrastructure standards, and are used on the TEPCO charge 

equipment that will be deployed by the ARRA-funded vehicle demonstration program (along 

with the Nissan Leaf EV); a U.S. Level 3 standard has yet to be developed. Though proposed 

charge coupler standards are constantly being refined, the following chart was recently 

developed to explain the differences at this time. 
Appendix G

G-10

Figure G1.4-1: International Charge Couple ComparisonE

G1.5 Hydrogen Infrastructure

Section 4.3 in Chapter 4, Infrastructure Assessment, contains an overview of hydrogen 

refueling technology and availability. This section provides additional details about hydrogen 

infrastructure including costs, standards, and codes for hydrogen infrastructure installation.

G1.5.1 Cost of Hydrogen

This section summarizes slides taken from a presentation by Professor Joan Ogden of 

the Institute of Transportation Studies University of California, Davis.

23

The slides indicate projected cost of hydrogen in various U.S. cities from 2014 to 

2030, U.S. average delivered hydrogen cost through 2050 and hydrogen transition timing and 

costs.

 

E Level 2 is up to 80 amp, but typically 16-32 amp

Residential Charging

Overnight

AC Level 1: 120V 1 ф, 16A AC Level 2: 240V 1ф, 80A

AC Level 2: 240V 1ф, 80A

Public Opportunity Charging

~1 mile/minute of charge

Public Fast Charging

~ 3-10 miles/minute of charge

Combined SAE J1772TM and DC Level 3

(TBD)

AC Level 1: 100V 1ф, 16A AC Level 2: 200V 1ф, 80A

AC Level 2: 200V 1ф, 80A

AC Mode 1: 250V 1ф/480V 3ф, 16A AC Mode 2: 250V 1ф/480V 3ф, 32A

AC Mode 2: 250V 1ф/480V 3ф, 32A 

AC Level 3: <500V DC/<100kW

(TBD – CHAdeMO)

AC Mode 1: 220V 3ф, 16A AC Mode 2: 220V AC 3ф, 32A 

AC Mode 2: 220V 3ф, 32A (TBD)

DC Mode 3: 400V/750V DC/<240kW;

125A/250A/400A (TBD)

DC Mode 3: < 500V DC/<100kW

(TBD)

SAE J1772TM

SAE J1772TM

IEC 62196-2 Type 2

JEVS G105-1993

(Re-configured) IEC 62196-2 Type 2

BYD example

AC L1: 120V AC 1 ф, 12-16A/1.44-1.92kW

AC L2: 240V AC 1ф, 80A/19.2kW

AC L2: 240V AC 1ф, 80A/19.2kW AC L3: 240V AC 1ф, 400A (TBD 1ф or 3ф?)

DC L1: 200-450V DC, 80A/19.2kW DC L3: (TBD) 200-600V DC, ≤ 400A/≤ 240kW

DC L2: 200-450V DC, 200A/90kW

SAE J1772TM charging configurations and max ratings (ref: Kissel, June 2010)

Plugging in Internationally

[Standard/proposed charge couplers]

SAE J1772TM plus DC pins

KH_ANL
2017-2025 Technical Assessment

G-11

Figure 1.5-1: Cost of Hydrogen in Selected US Cities (UCD SSCHISM Model)

J. Ogden and C. Yang, "Build-up of a hydrogen infrastructure in the US," Chapter 15, 

in The Hydrogen Economy: Opportunities and Challenges, edited by Dr Michael Ball and Dr 

Martin Wietschel, Cambridge University Press, 2009, pp.454-482.

In certain regions, such as Los Angeles, hydrogen cost for infrastructure is projected to 

decrease rapidly between 2015 and 2018 as FCEVs are rolled out.

Figure 1.5-2: US Average Delivered Hydrogen Cost (NRC 2008), Electricity and 

Gasoline Price (EIA 2008)
Appendix G

G-12

National Research Council, National Academies of Engineering, Transitions to 

Alternative Transportation Technologies: A Focus on Hydrogen, Pre-publication version 

available from National Academies website 

http://www.nap.edu/catalog.php?record_id=12222 

Studies by UC Davis indicate that hydrogen costs can be competitive with gasoline in 

2020. Note that 1 kg of hydrogen has approximately the same energy content (lower heating 

value) as 1 gallon of gasoline (1kg hydrogen = 1 gallon gasoline equivalent (gge)

National Research Council, National Academies of Engineering, Transitions to 

Alternative Transportation Technologies: A Focus on Hydrogen, Pre-publication version 

available from National Academies website 

http://www.nap.edu/catalog.php?record_id=12222

In 2008, the NRC‘s Committee on Assessment of Resource Needs for Fuel Cell and 

Hydrogen Technologies released the report, ―Transitions to Alternative Transportation 

Technologies—A Focus on Hydrogen,‖ which was required by the Energy Policy Act (2005) 

section 1825. One of the committee's conclusions was that to accelerate the penetration of 

FCEVs, strong government policies will be required. The NRC estimated that the 

government cost to support a transition to FCEVs for the period from 2008 to 2023 would 

be approximately $55 billion (this amounts to slightly more than $3.5 billion/year or about 

$10,000 per FCEV—the committee compared this value to ethanol subsidies, which were 

$2.6 billion in 2006 and are expected to grow to $15 billion/year by 2015). The table shows 

details on government costs required for infrastructure.
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G-13

G1.5.2 Codes and Standards to Support Hydrogen and Fuel Cell Infrastructure

The United States and most countries in the world have established laws and 

regulations that require commercial products to meet all applicable codes and standards to 

demonstrate that they are safe, perform as designed and are compatible in the systems in 

which they are used. Hydrogen has an established history of industrial use as a chemical 

feedstock, but not as an energy carrier on a large-scale commercial basis. The development 

and promulgation of codes and standards are essential to establish a market-receptive 

environment for commercial, hydrogen-based products and systems for energy use.

The key U.S. and international standards development organizations (SDOs)

developing and publishing the majority of hydrogen codes and standards are shown in the 

table below. These organizations typically work with the public and private sectors to 

develop codes and standards.

The U.S. Department of Energy (DOE) conducts underlying safety R&D and works 

with domestic and international SDOs to facilitate the development of applicable codes and

standards. These standards are then referenced by building and other codes to expedite 

regulatory approval of hydrogen technologies. This approach ensures that U.S. consumers can 

purchase products that are safe and reliable, regardless of their country of origin, and that U.S. 

companies can compete internationally.24

Organizations Involved in Codes and Standards Development and Publication

Organization Responsibility

Domestic Codes and Standards

American Society for Testing and Materials Materials testing standards and protocols

(ASTM)

American National Standards Institute (ANSI)

Certifies consensus methodology of and serves as 

clearinghouse for codes and standards development

American Petroleum Institute (API) Equipment standards

American Society of Heating, Refrigeration Equipment design and performance standards

and Air Conditioning Engineers (ASHRAE)

American Society of Mechanical Engineers Equipment design and performance standards

(ASME)

Compressed Gas Association (CGA) Equipment design and performance standards

CSA America (CSA) Equipment standards
Appendix G

G-14

U.S. Department of Transportation Vehicle standards and regulations

International Association of Plumbing and Mechanical building code

Mechanical Officials (IAPMO)

Institute of Electrical and Electronic Engineers Electrical standards

(IEEE)

National Fire Protection Association (NFPA) Model building codes, standards

Natural Gas Institute (NGI) Natural gas vehicle standards

Society of Automotive Engineers (SAE)

Vehicle system and subsystem design and 

performance standards

Underwriters Laboratories (UL) Equipment and performance testing standards

International Electrotechnical Commission (IEC) International Performance Standards

International Organization for Standardization 

(ISO) International Performance Standards

In February 2010, the National Renewable Energy Laboratory (NREL) published the 

Vehicle Codes and Standards: Overview and Gap Analysis. The gap analysis includes a list 

of applicable codes and standards for alternative fuels including hydrogen infrastructure. The 

list of applicable codes and standards is below:25

ANNUAL INSPECTIONS 

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas 

Association 2005) 

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004) 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)

BALANCE OF PLANT 

Piping & Tubing 

ASME B31.12, Hydrogen Piping and Pipelines 

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas 

Association 2005) 

IFC (International Code Council 2006) 

International Fuel Gas Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

CGA H-3 Cryogenic Hydrogen Storage (Compressed Gas Association 2006)

Pressure Relief 

CGA S-1.3, PRD Standards Part 3 - Stationary Storage Containers for Compressed Gases

(Compressed Gas Association 2005)

IFC (International Code Council 2006) 
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G-15

International Fuel Gas Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Valving and Fittings 

ASME B31.3, Process Piping (American Society of Mechanical Engineers 2006) 

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas 

Association 2005) 

IFC (International Code Council 2006)

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Venting and Other Equipment 

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004) 

IFC (International Code Council 2006) 

International Fuel Gas Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

CANOPY TOPS 

International Building Code (International Code Council 2009) 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

COMPRESSED HYDROGEN GAS STORAGE 

Equipment Location 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

General Safety Requirements 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Storage Containers 

CGA PS-20, Direct Burial of Gaseous Hydrogen Storage Tanks (Compressed Gas Association 

2006) 

CGA PS-21, Adjacent Storage of Compressed Hydrogen and Other Flammable Gases 

(Compressed Gas Association 2005) 

IFC (International Code Council 2006) 
Appendix G

G-16

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

COMPRESSION SYSTEMS AND EQUIPMENT 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

DESIGN 

Barrier Walls 

IFC (International Code Council 2006) 

Equipment 

International Fire Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Fuel Stations 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

Equipment 

International Fire Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Fuel Stations 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Weather Protection 

IFC (International Code Council 2006) 

DISPENSING 

Electrical Equipment 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection

Association 2003)

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Fuel Lines 

CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas 

Association 2005) 

IFC (International Code Council 2006) 

International Fuel Gas Code (International Code Council 2006) 
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G-17

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Gaseous Dispensers 

IFC (International Code Council 2006) 

Facilities 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Hoses and Connectors 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Liquid Dispensers 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Vehicle Connectors 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

SAE J2600, Compressed Hydrogen Surface Vehicle Refueling Connection Devices (Society of 

Automotive Engineers 2002)

DISPENSING, OPERATIONS, AND MAINTENANCE SAFETY 

Gaseous Hydrogen 

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004) 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Liquid Hydrogen 

CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004) 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

FIRE SAFETY 

Construction 

IFC (International Code Council 2006) 

International Fuel Gas Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Equipment 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 
Appendix G

G-18

Signage 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

LIQUID HYDROGEN STORAGE 

Equipment Location 

IFC (International Code Council 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

General Safety Requirements 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Storage Containers 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

CGA H-3 Cryogenic Hydrogen Storage (Compressed Gas Association 2006) 

ON-SITE HYDROGEN PRODUCTION 

IFC (International Code Council 2006) 

International Fuel Gas Code (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

OPERATION APPROVALS 

Dispensing 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

Fire And Emergency Planning 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 
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Fuel Delivery 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Ignition Control 

IFC (International Code Council 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Personnel Issues and Training 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Signage 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Vehicle Access 

IFC (International Code Council 2006) 

NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire 

Protection Association 2003) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

SETBACKS AND FOOTPRINTS 

Liquid Systems 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic 

Fluids in Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection 

Association 2005) 

Outdoor Gaseous Systems 

IFC (International Code Council 2006) 
Appendix G

G-20

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

TRANSPORTATION 

Compressed Hydrogen Gas 

CGA P-1, Safe Handling of Compressed Gases in Containers (Compressed Gas Association 2006) 

IFC (International Code Council 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Liquid Hydrogen 

CGA P-12, Safe Handling of Cryogenic Liquids (Compressed Gas Association 2005) 

IFC (International Code Council 2006) 

NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

Natural Gas 

ASME B31.8, Gas Transmission and Distribution Systems (American Society of Mechanical 

Engineers 2003) 

VAPORIZERS 

IFC (International Code Council 2006) 

IFC (International Code Council 2006) 

NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in 

Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association 

2005) 

The table below provides a summary of the identified Code and Standards Gaps for the 

expanded use of hydrogen as an alternative fuel. Also, the table presents the impacted document 

and proposed means to address the gap. It also illustrates the various areas of hydrogen codes and

standards that require additional work in order to create a complete and standardized control 

strategy. 

One key area that may require additional work is operations and maintenance 

requirements for fuel dispensing systems. This area is of particular concern because relatively 

little data for the use of vehicular hydrogen dispensing systems exists. As data is accrued, it may 

become apparent that additional safety measures are needed to address operations and 

maintenance. A second area of concern is potential releases of hydrogen in confined spaces such 

as indoor fueling operations, tunnels, and parking garages. The release characteristics and 

prevention and mitigation measures vary for these different locations, but many of the same 

analytical tools can be used to characterize the hazards of these releases. A third area of concern is

the potential energy contained in high-pressure storage and dispensing systems. The following 

table lists several other important gaps that require further work.
2017-2025 Technical Assessment

G-21

Codes and Standards Gaps for Hydrogen 25

Codes or Standard Gap Documents Impacted Gap Resolution

No final fuel quality 

standard 

ISO Fuel Quality Draft 

International Standard, 

ASTM analysis standards, 

SAE Technical Information 

Report (TIR) J2719 

Provide data to ensure that 

draft standards become final 

standards 

Potentially incomplete 

requirements for indoor 

hydrogen vehicle dispensing 

NFPA 52, IFC Evaluate indoor release 

characteristics and accident 

scenarios for potential 

application to code 

development 

Off road vehicle storage 

tank standards are 

incomplete 

CSA America Heavy Goods 

Vehicle (HGV) 4.3, SAE 

J2601 

Support standards 

development work with 

direct committee 

involvement and data 

support 

Bulk liquefied hydrogen 

storage requirements lack 

technical basis 

documentation 

NFPA 55, NFPA 2, IFC Evaluate liquid release 

impacts and frequencies and 

provide this information to 

relevant technical 

committees to validate or 

revise bulk liquefied 

hydrogen storage 

requirements 

Requirements for tunnels, 

parking garages, and repair 

garages need review to 

determine whether 

additional requirements for 

hydrogen are needed 

[meeting with New York 

Port Authority January 

2009] 

NFPA 505, IFC, NFPA 88B, 

NFPA 30A, IBC, 

International Mechanical 

Code (IMC) 

Evaluate safety concerns in 

these environments and 

work with the technical 

committees to provide data 

required to address codes 

and standards requirements 
Appendix G

G-22

Operations and maintenance 

procedures lack supporting 

operational history data 

[conversation with Larry 

Fluer] 

NFPA 52, NFPA 30A, IFC Evaluate existing procedures 

to determine where they 

might be incomplete. 

Evaluate operations and 

maintenance history for 

similar fuels to determine 

whether useful information 

can be retrieved and applied 

to hydrogen 

Steam Methane Reformation 

(SMR) plants do not have a 

safety standard 

[conversation with Roger 

Smith] 

No current code specifically 

addresses SMR plants 

Develop a code or standard 

that addresses SMR plants 

New storage systems, such 

as metal hydrides, are 

minimally addressed in 

codes and standards 

NFPA 55, CGA H-1 and H2, IFC Determine whether new 

chemical storage systems are 

adequately addressed in 

codes and standards 

Limited familiarity with 

relevant hydrogen codes and 

standards among project 

developers and code 

officials [conversation with 

Larry Fluer] 

All hydrogen codes and 

standards 

Regional codes and 

standards workshops as well 

as web training and 

background information can 

help address this issue

Incomplete requirements for 

sensing technologies [Rivkin 

analysis of NFPA 52] 

NFPA 52, NFPA 55 Support the use of sensing 

technologies that replace 

odorants through evaluating 

sensing technologies and 

supporting code and 

standards development work 

in sensing technologies 

High-pressure storage, 

handling, and use of 

hydrogen [David Farese 

DOE Safety Panel meeting] 

NFPA 52, NFPA 55, CGA 

H series of documents 

Evaluate codes and 

standards that address highpressure storage to 

determine if requirements 

are adequate and if 
2017-2025 Technical Assessment

G-23

additional work is required 

Global Technical 

Regulations (GTR) 

Coordination with SAE and 

DOT regulations 

Continue to represent the 

United States in GTR 

development meetings and 

evaluate impacts of GTR in 

domestic regulations, codes, 

and standards 

Coordination of 

international (primarily ISO) 

standards and domestic 

codes and standards 

Multiple documents: SAE, 

CSA, UL, NFPA 

Evaluate component 

standards to ensure that 

there are not unnecessary 

conflicts 

The DOT guidance 

documents for incidents 

involving flammable gases 

are too general and 

prescriptive 

DOT Emergency Response 

Guide 

Add additional material to 

the DOT guide for hydrogen 

incidents 
Appendix G

G-24

Appendix G References

1 Morrow, Karner, Francfort (2008). ―Plug-in Hybrid Electric Vehicle Charging Infrastructure Review‖, Battelle 

Energy Alliance, U.S. Department of Energy Idaho National Laboratory. Nov 2008.

2 May, James W. and Matt Mattila (2009). ―Plugging In: A Stakeholder Investment Guide for Public ElectricVehicle Charging Infrastructure.‖ Rocky Mountain Institute. July 2009.

3 May and Mattila, 2009.

4 Morrow, Karner, Francfort, 2008.

5 Electric Transportation Engineering Corporation (ETEC), 2009. Electric Vehicle Charging Infrastructure 

Deployment Guidelines British Columbia, July.

Also, Electric Transportation Engineering Corporation (2010), Electric Vehicle Charging Infrastructure 

Deployment Guidelines for the Central Puget Sound Area, May.

6 Morrow, Karner, Francfort, 2008.

7 May and Mattila, 2009..

8 Electrification Coalition (2009). ―Electrification Roadmap‖, Electrification Coalition. Nov 2009.

9 ETEC, 2009.

10 Morrow, Karner, Francfort, 2008.

11 ETEC, 2009.

12 May and Mattila, 2009.

13 May and Mattila, 2009.

14 Electrification Coalition, 2009.

15 ETEC, 2009.

16 Electrification Coalition, 2009.

17 Press release from Nissan, May 2010, accessed on the Internet at: http://www.nissanglobal.com/EN/NEWS/2010/_STORY/100521-01-e.html.

18 Brooker, et al (2010), ―Technology Improvement Pathways to Cost-Effective Vehicle Electrification,‖ to be 

presented at the SAE 2010 World Congress, Detroit, MI, April 2010. 

19 Energy Storage for the Electricity Grid: Benefits and Market Potential Assessment Guide, Sandia National 

Laboratories, Albuquerque, NM: 2010.

20 Kamath (2010), ―Lithium Ion Batteries in Utility Applications‖, Proceedings of the 27th International Battery 

Seminar and Exhibit, Ft. Lauderdale, FL, March 2010.

21 Market Feasibility for Nickel Metal Hydride and Other Advanced Electric Vehicle Batteries in Selected 

Stationary Applications, EPRI, Palo Alto, CA, and SMUD, Sacramento, CA: 2000.
2017-2025 Technical Assessment

G-25

22 Neubauer, Jeremy and Ahmad Pesaran (2010), Preliminary EV/PHEV Battery Secondary Use Analysis in 

Support of EPA 2017-2025 Technical Assessment.

23 Slides from a Presentation by Prof Joan Ogden. ―What is needed to initiate new fuel/vehicle pathways? 

Comparing Transition Costs for H2 FCVs, PHEVs and Biofuels.‖ Prof. Joan Ogden, Institute of Transportation 

Studies, University of California, Davis, June 14, 2010. 

24 MYPP (Multi-Year Research, Development, and Demonstration Plan) 2007. Hydrogen Codes and Standards. 

Washington, D.C.: U.S. Department of Energy, Energy Efficiency and Renewable Energy.

http://www1.eere.energy.gov/hydrogenandfuelcells/mypp/pdfs/codes.pdf

25 NREL (National Renewable Energy Laboratory) 2010. Vehicle Codes and Standards: Overview and Gap 

Analysis. Washington, D.C.: U.S. Department of Energy, Energy Efficiency and Renewable Energy. 

www.nrel.gov/docs/fy10osti/47336.pdf