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## EPA and NHTSA Response to **June 17**  **, 2015 Interagency Comments on**  **Preamble Section IX Rebound -** 

**HDV Phase 2 NPRM** Agencies	Responses : The	agencies	accept	the	E.O.	12866	suggested	edits shown	as	blue type,	below.		We	will	make	one	edit	that	replaces	“calculation”	with	“value,”	shown	in purple	type
. **(3) How the Agencies**  **Estimated the HDV Rebound Effect for this Proposal**  (a ) Values Used in the Phase 1 Analysis At the time the agencies conducted th eir anal ys is of the Phase 1 fuel efficiency and GHG emissions standards, the only evidence on the HDV rebound effect were the previousl y described studies from CSIand the Volpe Center. 1 The agencies determined that this evidence did not lend itself to a specific quantitative value calculation for use in the anal ys is. On the basis Rather, based on a qualitative assessment of this evidence informed b y and the agencies’ best professional judgement , the agencies chose rebound effects of 15 percent for vocatio nal vehicles and 5 percent for combination tractors, both of which were toward the lower end of the range of values from these studies. The agencies found no evidence on the rebound effect for HD pickup trucks and vans, but concluded it would be inappropriate to use the values selected for vocational vehicles or combination tractors for those vehicles. Because the usage patterns of HD pickup trucks and vans can more closely resemble those of large light
- duty vehicles, the agencies used our judgement to se lect the 10 percent rebound effect we had employed in our most recent light
duty rulemaking to anal yze the Phase 1 standards for 2b/3 vehicles.

1 The Gately study was also available, however, the agencies were not aware of the work at the time.*** E.O. 12866 Review

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(b ) How the Agencies Analyzed VMT Rebound in this Proposal After considering the new evidence that has become availa ble since the HD Phase 1 final rule, the agencies elected to continue using the rebound effect estimates we used previousl y in the HD Phase 1 rule in our anal ys is of Phase 2 proposed standards. In arriving at this decision, the agencies considered the sho rtcomings and limitations of the newl y- available studies described previously , particularly the limited applicability

of the two published studies using data from European nations to the U.S. context. After weighing these attributes of the more recent stu dies, the agencies concluded that we had insufficient evidence to justify revising the rebound effect values that were used in the Phase 1 anal ys is. In our assessment, we do not differentiate between short
- run and long
- run rebound effects, although these effects may differ. The vocational and combination truck estimates are based on the Volpe Center anal ys is presented in the HD Phase 1 rule and the case study from CSI . As with the HD Phase 1 rule, we did not find any literature specifically

examining the HD pickup and truck sector. Since these vehicles are used for very different purposes than combination tractors and vocational vehicles, and they are more similar in use to large light
- duty vehicles, we have chosen the light
- dut y rebound effect of 10 percent used in the final rule establishing fuel economy and GHG standards for MYs 2017
- 2025 light
- duty vehicles in our anal ys is of HD pickup trucks and vans. While for this proposal, the agenci es have selected to use these rebound effect values of 5% for combination tractors, 10% for heav y duty pickup trucks and vans and 15% for vocational vehicles , we acknowledge the literature shows a wide range of rebound effect estimates. Therefore, we will review and consider revising these estimates in the final rule, taking into*** E.O. 12866 Review

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consideration all available data and anal ys is, including submissions from public commenters and new research on the rebound effect.

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