Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

1 of 54 1 ENVIRONMENTAL PROTECTION AGENCY 40 CFR Parts 1036, 1037, 1066, and 1068 DEPARTMENT OF TRANSP ORTATION National Highway Traffic Safety Administration 49 CFR Parts 5 23 and 5 35 [EPA

–HQ

– OAR

–2010

– 0162; NHTSA - 2010 - 0096; FRL - xxxx - x] RIN 2060 - AP61; RIN XXXX - XXXX Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Heavy Duty Engines and Vehicles AGENCIES: Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration (NHTSA). ACTION: Proposed Rules

________________

__________________________________________________ SUMMARY: The Environmental Protection Agency (EPA) and the National Highway Traffic Safet y Administration (NHTSA) on behalf of the Department of Transportation, are each proposing rules to establish a c omprehensive heavy

- dut y national program (the “HD National Program”) that will reduce greenhouse gas (GHG) emissions and increase fuel efficiency for on

- road heavy

- duty

vehicles , responding to the President’s directive on May 21, 2010, to take coordinated steps to produce a new generation of clean vehicles

. NHTSA’s proposed fuel consumption standards and EPA’s proposed carbon dioxide ( CO 2 ) emissions standards would be tailored to each of three regulatory categories of heav y - dut y vehicles: ( 1 ) Combination Tractors ; (2 ) Heav y - duty Pick

- up Trucks and Vans; and (3) Vocational Trucks , as well as gasoline and diesel heavy

- dut y engines

. EPA ’ s p ropos ed hydrofluorocarbons emissions (from air conditioning) standards would apply to tractors, pickup trucks , and vans , and EPA’s proposed nitrous oxide (N 2 O) and methane (CH 4 ) emissions standards would appl y to all heavy

- dut y engines, pickup truck s , and vans. EPA’s proposed GHG emission standards under the Clean Air Act (CAA) would begin with model y ear 2014. NHTSA’s proposed fuel consumption standards under the Energy Independence and Security Act of 2007 (EISA) would be optional in model years 2014 and 2015, becoming mandatory with model y ear 201 6 for most regulatory categories

. Commercial trailers would not be regu lated in this phase of the HD National Program, although there is a discussion of the possibility of future action for trailers.2 of 54 1

DATES: Comments : Comments on all aspects of the heav y - duty greenhouse gas proposed rule must be received on or before XX [ in sert date ], XX [ insert # ] day s after publication in the Federal Register. Under the Paperwork Reduction Act, comments on the information collection provisions must be received b y the Office of Management and Budget (OMB) on or before [ Insert date 30 days after publication in the Federal Register ], thirty day s after date of publication in the Federal Register . See the SUPPLEMENTARY INFORMATION section on “Public Participation” for more information about written comments. Public Hearings : NHTSA and EPA will jointly hold two public hearings on the following dates: [date], 2010 in [location]; and [date], 2010 in [location]. The hearings will start at 9 a.m. local time and continue until everyone has had a chance to speak. See the SUPPLEMENTARY INFORMATION sect ion on “Public Participation” for more information about the public hearings. [NOTE: NHTSA and EPA are continuing to finalize details of the h earing s a nd will update this section to ensure the clearest instructions to the public.] ADDRESSES: Submit your comments, identified by Docket ID No. NHTSA - 2010 - 0096 and/or EPA - HQ - OAR- 2010 - 0162 , by one of the following methods:

• www.regulations.gov : Follow the on

- line instructions for submitting comments.

• Email: a - and

- r - docket@epa.gov

• Fax: NHTSA: (202) 493

- 2251; EPA: (202) 566

- 9744

• Mail: NHTSA: Docket Management Facility , M
- 30, U.S. Department of Transportation, West Building, Ground Floor, Rm. W12

- 140, 1200 New Jersey Avenue, SE, Washington, DC 20590. EPA : Air Docket, Environmental Protection Agency , E PA Docket Center, Mailcode: 6102T , 1200 Pennsylvania Ave., NW., Washington, DC 20460. In addition, please mail a copy of your comments on the information collection provisions to the Office of Information and Regulatory Affairs, Office of Management and B udget (OMB), Attn: Desk Officer for EPA, 725 17th St. NW., Washington, DC 20503.

• Hand Delivery : NHTSA: West Building, Ground Floor, Rm. W12

- 140, 1200 New Jersey Avenue, SE, Washington, DC 20590, between 9 a.m. and 5 p.m. Eastern Time, Monday through Friday , except Federal Holiday s. EPA: EPA Docket Center, (Air Docket), U.S. Environmental Protection Agency , EPA West Building, 1301 Constitution Ave., N.W., Room: 3334, Mail Code 2822T, Washington DC. Such deliveries are onl y accepted during the Docket’sDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

3 of 54 1 normal hours of operation, and special arrangements should be made for deliveries of boxed information. Instructions : Direct your comments to Docket ID No. NHTSA - 2010 - 0096 and/or EPA HQ - OAR- 2010 - 0162 . See the SUPPLEMENTARY INFORMATION section on “Public Participation” for additional instructions on submitting written comments. Docket : All documents in the docket are listed in the www.regulations.gov index. Although listed in the index, some information is not publicly available, e.g. , confidential busin ess information (CBI) or other information whose disclosure is restricted b y statute. Certain other material, such as cop yri ghted material, will be publicly available only

in hard cop y in EPA’s docket, but may be available electronicall y in NHTSA’s docket at regulations.gov . Publicly available docket materials are available either electronicall y in www.regulations.gov or in hard cop y at the following locations: NHTSA: Docket Management Facility , M
- 30, U.S. Department of Transportation, West Building, Ground Floor, Rm. W12

- 140, 1200 New Jersey Avenue, SE, Washington, DC 20590. The Docket Management Facility is open between 9 a.m. and 5 p.m. Eastern Time, Monday through Friday , except Federal holiday s. EPA: EPA Docket Center, EPA/DC, EPA West, Room 33 34, 1301 Constitution Ave., NW, Washington, DC. The Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday , excluding legal holiday s. The telephone number for the Air Docket is (202) 566

- 174 2

. FOR FURTHER INFORMATION CONTACT: NH TSA: Rebecca Yoon, Office of Chief Counsel, National Highway Traffic Safet y Administration, 1200 New Jersey Avenue, SE, Washington, DC 20590. Telephone: (202) 366

- 2992. EP A: [ insert name] , Office of Transportation and Air Qualit y, Assessment and Standards Division (ASD), Environmental Protection Agency , 2000 Traverwood Drive, Ann Arbor, MI48105; telephone number: (734) 214

- [XXXX] ; fax number: (734) 214

- [XXXX] ; email address: [insert appropriate email address, e.g., [lastname.firstname]@epa.gov] , or Asse ssment and Standards Division Hotline; telephone number; (734) 214

- 4636; email asdinfo@epa.gov. SUPPLEMENTARY INFORMATION: 

### A. Does this Action Apply to Me This action would affect companies that manufacture, sell, or import into the United States new heav y - duty

engines and new Class 2b through 8 trucks, including combination tractors, school and transit buses, vocational vehicles such as utility service trucks, as4 of 54 1

well as 3⁄4

- ton and 1

- ton pickup trucks and vans. 1 The heav y - dut y category incorporates all mo tor vehicles rated at a gross vehicle weight of 8,500 pounds, and the engines that power them, except for medium

- duty passenger vehicles already covered by the GHG and CAFE standards issued for model ye ars 2012

- 2016. This action also includes a discussion of the possible future regulation of commercial trailers. Potentially affected categories and entities include the following: Category NAI CS Code a Examples of Potentially Affected Entities Industry 336111 Motor Vehicle Manufacturers, Engine and Truck M anufacturers 336112 336120 Industry 541514 Commercial Importers of Vehicles and Vehicle Components 811112 811198 Industry 336111 Alternative Fuel Vehicle Converters 336112 422720 454312 541514 541690 811198 Industry 336212 Truck Trailer Manufacturers b Note: a North American Industry Classification System (NAICS) b This category is included for purposes of advance notice of possible future rulemaking action This table is not intended to be exhaustive, but rather provides a guide for readers regarding entities likely

to be regulated b y this proposal . This table lists the ty pes of entities that the agencies are now aware could potentially be regulated b y this action. Other ty pes of entities not listed in the table could a lso be regulated. To determine whether your activities may be regulated b y this action, you should carefully examine the applicability

criteria in 40 CFR parts 1036, 1037 , 49 CFR parts 523 and 535, and the proposed regulations. You may direct questions r egarding the applicability of this action to the persons listed in the preceding FOR FURTHER INFORMATION CONTACT section. 

### B. Public Participation NHTSA and EPA request comment on all aspects of th e s e joint proposed rule s . This section describes how yo u can participate in this process.

1 For purposes of NHTSA’s fuel consumption regulations, non

- commercial recreational vehicles will not be covered, even if they would otherwise fall under these categories. See 49 U.S.C. § 32901(a)(7).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

5 of 54 1 (1) How Do I Prepare and Submit Comments? In this joint rulemaking , there are man y issues common to both EPA’s and NHTSA’s proposals. For the convenience of all parties, comments submitted to the EPA docket (whether hard cop y or ele ctronic) will be considered comments submitted to the NHTSA docket, and vice versa. An exception is that comments submitted to the NHTSA docket on the Draft Environmental Impact Statement will not be considered submitted to the EPA docket. Therefore, the public only needs to submit comments to either one of the two agency

dockets. Comments that are submitted for consideration by one agency should be identified as such, and comments that are submitted for consideration by both agencies should be identifie d as such. Absent such identification, each agency will exercise its best judgment to determine whether a comment is submitted on its proposal. Further instructions for submitting comments to either the EPA or NHTSA docket are described below. NHTSA : Your comments must be written and in English. To ensure that your comments are correctl y filed in the Docket, please include the Docket I.D No. NHTSA 2010 - 0096 in your comments. By regulation, your comments must not be more than 15 pages long. 2 NHTSA established this limit to encourage you to write your primary comments in a concise fashion. However, you may attach necessary additional documents to your comments. There is no limit on the length of the attachments. I f you are submitting comments elec tronically as a PDF (Adobe) file, we ask that the documents submitted be scanned using the Optical Character Recognition (OCR) process, thus allowing the agencies to search and cop y certain portions of your submissions. 3 Please note that pursuant to the D ata Qualit y Act, in order for the substantive data to be relied upon and used b y the agencies, it must meet the information quality standards set forth in the OMB and Department of Transportation (DOT) Data Quality Act guidelines. Accordingl y, we encourag e you to consult the guidelines in preparing your comments. OMB’s guidelines may

be accessed at http://www.whitehouse.gov/omb/fedreg/reproducible.html. DOT’s guidelines may be accessed at http://regs.dot.gov

. EPA: Di rect your comments to Docket ID No EPA - HQ - OAR- 2010 - 0162 . EPA’s policy is that all comments received will be included in the public docket without change and may be made available online at www.regulations.gov , including an y personal information provided, unless the comment includes information claimed to be Confidential Business Information (CBI) or other information whose disclosure is restricted b y statute. Do not submit information that you consider to be CBI or otherwise protected through www.regulation s.gov or e - mail. The www.regulations.gov website is an “anon ym ous access” sy stem, which means EPA will not know your identity or contact information unless you provide it in the body of your comment. If you send an e

- mail

2 See 49 CFR § 553.21 3 Optical character recogni tion (OCR) is the process of converting an image of text, such as a scanned paper document or electronic fax file, into computer

- editable text.6 of 54 1

comment directl y to EPA without going through www.regulations.gov your e - mail address will be automatically captured and included as part of the comment that is placed in the public docket and made available on the Internet. If you submit an electronic comment, EPA recommends that you i nclude your name and other contact information in the body of your comment and with any disk or CD

- ROM you submit. If EPA cannot read your comment due to technical difficulties and cannot contact you for clarification, EPA may not be able to consider your comment. Electronic files should avoid the use of special characters, an y form of encry ption, and be free of any

defects or viruses. For additional information about EPA’s public docket visit the EPA Docket Center homepage at http://www.epa.gov/epahome/d ockets.htm

. (2) Tips for Preparing Your Comments. When submitting comments, remember to :

 Id entify

the rulemaking by

docket number and other identifying information (subject heading, Federal Register date and page number).  Follow directions

- The agency may ask you to respond to specific questions or organize comments by

referencing a Code of Federal Regulations (CFR) part or section number.  Explain why

you agree or disagree, suggest alternatives, and substitute language for yo ur requested changes.  Describe an y assumptions and provide an y technical information and/or data that you used.  If you estimate potential costs or burdens, explain how you arrived at your estimate in sufficient detail to allow for it to be reproduced.  Provide specific examples to illustrate your concerns, and suggest alternatives.  Explain your views as clearl y as possible, avoiding the use of profanity or personal threats.  Make sure to submit your comments by the comment period deadline identified in the DATES section above. (3) How Can I B e Sure That My Comments Were Received? NHTSA: If you submit your comments by mail and wish Docket Management to notify yo u upon its receipt of your comments, enclose a self

- addressed, stamped postcard in the envelope containing your comments. Upon receiv ing your comments, Docket Management will return the postcard b y mail. (4) How D o I Submit Confidential Business Information? Any confidential business information (CBI) submitted to one of the agencies will also be available to the other agency

. 4 However, as with all public comments, any CBI

4 This statement constitutes notice to commenters pursuant to 40 CFR § 2.209(c) that EPA will share confidential business information received with NHTSA unless commenters expressly specify that they wish to submit their CBI only to EPA and not to both agencies.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

7 of 54 1 information only

needs to be submitted to either one of the agencies’ dockets and it will be available to the other. Following are specific instructions for submitting CBI to either agency . NHTSA: If you wish to submit any information under a claim of confidentiality , you should submit three copies of your complete submission, including the information you claim to be CBI , to the Chief Counsel, NHTSA, at the address given above under FOR FURTHER INFORMATION CONTACT . Wh en you send a comment containing CBI , you should include a cover letter setting forth the information specified in our CBI regulation. In addition, you should submit a copy from which you have deleted the claimed CBI to the Docket by one of the methods se t forth above. EPA: Do not submit CBI to EPA through www.regulations.gov or e - mail. Clearly mark the part or all of the information that you claim to be CBI. For CBI information in a disk or CD ROM that you mail to EPA, mark the outside of the disk or C D ROM as CBI and then identify

electronically

within the disk or CD ROM the specific information that is claimed as CBI. In addition to one complete version of the comment that includes information claimed as CBI, a cop y of the comment that does not contain the information claimed as CBI must be submitted for inclusion in the public docket. Information so marked will not be disclosed except in accordance with procedures set forth in 40 CFR Part 2. (5) Will the Agencies Consider Late Comments? N HTSA and EPA wi ll consider all comments received before the close of business on the comment closing date indicated above under DATES . To the extent practicable, we will also consider comments received after that date. If interested persons believe that any new information the agency places in the docket affects their comments, they may submit comments after the closing date concerning how the agency should consider that information for the final rule. However, the agencies’ ability to consider any

such late comments i n this rulemaking will be limited due to the time frame for issuing a final rule. If a comment is received too late for us to practicably consider in developing a final rule, we will consider that comment as an informal suggestion for future rulemaking ac tion. (6) How Can I Read the Comments Submitted by Other People? You may read the materials placed in the docket s for this document ( e.g ., the comments submitted in response to this document by other interested persons) at an y time by going to http://www.regulations.gov . Follow the online instructions for accessing the dockets. You may also read the materials at the NHTSA Docket Management Facility or the EPA Docket Center b y going to the street addresses given above under ADDRESSES

. (7) How Do I Participate in the Public Hearings? EPA and NHTSA will jointly host two public hearings on the dates and locations described in the DATES section above. If you would like to present testimony at a public hearing, we ask that you notify both the NHTSA and EPA contact person s listed under FOR FURTHER INFORMATION CONTACT at least ten day s before the hearing. Once the agencies learn how man y people have registered to speak at the public8 of 54 1

hearing, we will allocate an appropriate amount of time to each participant, allowing time for lunch and necessary

breaks throughout the day . For planning purposes, each speaker should anticipate speaking for approximately ten minutes, although we may need to adjust the time for each speaker if there i s a large turnout. We request that you bring two copies of your statement or other material for the agencies’ panels. To accommodate as many speakers as possible, we prefer that speakers not use technological aids ( e.g ., audio

visuals, computer slideshows) . In addition, we will reserve a block of time for an yone else in the audience who wants to give testimon y. Each hearing will be held at a site accessible to individuals with disabilities. Individuals who require accommodations such as sign language inter preters should contact the persons listed under FO R FURTHER INFORMATION CONTACT section above no later than ten day s before the date of the hearing. EPA and NHTSA will conduct the hearing informally , and technical rules of evidence will not apply . We will arrange for a written transcript of each hearing and keep the official record s of the hearing s open for 30 day s to allow you to submit supplementary information. You may

make arrangements for copies of a transcript directl y with the court reporter. 

### C. Additi onal Information about this Rulemaking EPA’s Advance Notice of Proposed Rulemaking (ANPR) for regulating greenhouse gases under the Clean Air Act (see 73 Fed Reg 44353, July 30, 2008) included a discussion of possible rulemaking paths for the heavy

- duty tr ansportation sector. This notice of proposed rulemaking relies in part on information that was obtained from that notice, which can be found in Public Docket EPA

- HQ

- OAR

- 2008

- 0318. That docket is incorporated into the docket for this action, EPA - HQ - OAR- 20 10 - 0162

. Table of Contents I. Overview A. Introduction B. Building Blocks of the Heavy

- duty National Program C. Summary of the Proposed EPA and NHTSA HD National Program D. Summary of Costs and Benefits of the HD National Program E. Program Flexibilities F. EPA and NHTSA Statutory Authorities G. Future HD GHG and Fuel Consumption Rulemakings II. Proposed GHG and Fuel Consumption Standards for Heavy Duty Engines and Vehicle s A. What vehicles would be affected? B. Class 7/8 Combination Tractors C. Heavy

-Duty Pickup Trucks and Vans D. Class 2b

- 8 Vocational Trucks E. EPA’s Proposed N 2 0 and CH

4 Standards III. Feasibility Assessments and Conclusions A. Class 7

- 8 Combination Tractors B. Class 2b and 3 Complete Pickup Trucks and Vans C. Class 2b

- 8 Vocational Vehicles IV. Proposed Regulatory Flexibility Provisions A. Averaging, Banking, and Trading (ABT) ProgramDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

9 of 54 1 B. Class 2b/3 Heavy

- duty Pickup Trucks and Vans Flexibility Provisions C. Additional Proposed Flexibility Provisions V. NHTSA and EPA Proposed Compliance, Certification, and Enforcement Provisions A. Overview B. Heavy

- duty Pickup Trucks and Vans C. Heavy

-Duty Engines D. Class 7/8 Combination Trucks E. Class 2b

- 8 Vocational Trucks F. Statutory Prohibited Acts G. NHTSA Enforcement Penalties VI. How Would This Proposed ProgramIm pact Fuel Consumption, GHG Emissions, and Climate Change? A. What methodologies did the agencies use to project GHG emissions and fuel consu mption impacts? B. MOVES Analysis C. What are the projected reductions in fuel consumption and GHG emissions? D. Overview of Climate Change Impacts from G HG Emissions E. Changes in Atmospheric CO2 Concentrations, Global Mean Temperature, Sea Level Rise, and Ocean pH Associated with the Proposal’s GHG Emissions Reductions VII. How Would This Proposal Impact Non - GHG Emissions and Their Associated Effects? A. Emissions Inventory Impacts B. Health Effects of Non

- GHG Pollutants C. Environmental E

ffects of Non

- GHG Pollutants D. Air Quality Impacts of Non

- GHG Pollutants VIII. What are the Agencies' Estimated Cost, Economic, and Other Impacts of the Proposed Program ? A. Conceptual Framework for Evaluating Impacts B. Costs Associated with the proposed program C. Indirect Cost Multipliers D. Cost per To n of Emissions Reductions E. Impacts of Reduction in Fuel Consumption F. Class Shifting and Fleet Turnover Impacts G. Benefits of Reducing CO2 Emissions H. Non

- GHG Health and Environmental Impacts I. Energy Security Impacts J. Other Impacts K. Summary of Costs and Benefits L. Economy

- Wide Impacts of the Rule IX. Analysis of Alternatives A. What are the alternatives that the agencies considered? B. How do these alternatives compare in overall GHG emissions reductions and fuel efficiency and cost? C. How would the agencies include commercial trailers, as described in Alternative 7? X. Recommendations from the March 2010 NAS Report A. Overview B. What were the major findings and recommendations of the March 2010 NAS Report, and how is the proposed HD National Program consistent with them? XI. Statutory and Executive Order Reviews XII. Statutory Provisions and Legal Authority A. EPA B. NHTSA10 of 54 1



## I. Overview A. Introduction The Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) (“the agencies”) are announcing a first

- ever program to reduce greenhouse gas (GHG) emissions and improve fuel effi ciency in the heavy

- dut y highway vehicle sector. This broad sector

– ranging from large pickups to sleeper

- cab tractor s
– together represent the second largest contributor to oil consumption and GHG emission s, after light

- duty passenger cars and trucks. In a recent memorandum to the Administrators of EPA and NHTSA (and the Secretaries of Transportation and Energy) , the President stated that “America has the opportunity

to lead the world in the development of a new generation of clean cars and trucks throu gh innovative technologies and manufacturing that will spur economic growth and create high

- quality domestic jobs, enhance our energy security , and improve our environment.” 5 Earlier this year, EPA and NHTSA established for the first time a national prog ram to sharply reduce GHG emissions and fuel consumption from passenger cars and light trucks. Now, each agency is proposing rules that together would create a strong and comprehensive program (the “Heav y - Duty (HD) National Program”) designed to address the urgent and closely intertwined challenges of dependence on oil, energy securit y, and global climate change. At the same time, the proposed program would enhance American competitiveness and job creation, benefit consumers and businesses by reducing co sts for transporting goods, and spur growth in the clean energy sector. A number of major HD truck and engine manufacturers representing the vast majority of this industry , and the California Air Resources Board, sent letters to EPA and NHTSA supporting a HD National Program based on a common set of principles. In the letters, the stakeholders commit to working with the agencies and with other stakeholders toward a program consistent with common principles, including:

 In creased use of existing technolog ies to achieve significant GHG emissions and fuel consumption reductions;

 A program that starts in 2014 and is fully phased in by 2018;

 A program that w orks towards harmonization of methods for determining a vehicle’s GHG and fuel efficiency , recognizing the global nature of the issues and the industry ;

 Standards that recognize the commercial needs of the trucking industry ; and

5 Improving Energy Security, American Competitiveness and Job Creation, and Environmental Protection Thro ugh a Transformation of Our Nation’s Fleet of Cars And Trucks , ” Issued May 21, 2010, published at 75 FR 29399 ( May 26, 2010 ).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

11 of 54 1  In centives leading to the earl y introduction of advanced technologies. The proposed HD National Program builds on many years of heavy - dut y engine and vehicle technology

development to achieve what the agencies believe would be the greatest degree of GHG emission and fuel consumption reduction appropriate , feasible, and cost

- effective for the model y ears in question . Still, by proposi ng to take aggressive steps that are reasonabl y possible now, based on the technological opportunities and pathway s that present themselves during these model years , the agencies and industry will also continue learning about emerging opportunities for thi s complex sector to further reduce GHG emissions and fuel consumption. For example, NHTSA and EPA have stopped short of proposing fuel consumption and GHG standards for trucks based on use of hy

brid powertrain technology

. Similarly , we expect that the ag encies will parti cipate in efforts to improve our ability to accuratel y characterize the actual in

- use fuel consumption and emissions of this complex sector. As such opportunities emerge in the coming ye ars, we expect that we will propose a second phase o f provisions in the future to reinforce these developments and maximize the achieved reductions in GHG emissions and fuel consumption reduction for the mid

- and longer

- term time frame

. In the May

21 memorandum, the President request ed the Administrators of EPA and NHTSA to “immediately begin work on a joint rulemaking under the Clean Air Act (CAA) and the Energy

Independence and Securit y Act of 2007 (EISA) to establish fuel efficiency and greenhouse gas emissions standards for commercial medium

- and heav y d uty vehicles beginning with model year 2014, with the aim of issuing a final rule by July 30, 2011.” This proposed rulemaking is consistent with this Presidential Memorandum, with each agency

proposing rules under its respective authority that together co mprise a coordinated and comprehensive HD National Program. Heav y - dut y vehicles move much of the nation ’ s freight and carry out numerous other tasks, including utility work, concrete delivery , fire response, refuse collection, and many more. Heavy
- dut y ve hicles are primaril y powered b y diesel engines, although about 37 percent of these vehicles are powered b y gasoline engines. Heavy
- duty trucks 6 have alway s been an important part of the goods movement infrastructure in this country and have experienced si gnificant growth over the last decase related to increased imports and exports of finished goods and increased shipping of finished goods to homes through internet purchases. The heav y - duty

sector is extremely

diverse in several respects, including t ypes o f manufacturing companies involved, the range of sizes of trucks and engines they produce, the t ypes of work the trucks are designed to perform, and the regulatory history of different subcategories of vehicles and engines. The current heav y - dut y fleet en compasses vehicles from the “ 18

- wheeler ” combination trucks one sees on the

6 In this rulemaking, EPA and NHTSA use the term “truck” in a general way, referring to all categories of regulated heavy

- duty hi ghway vehicles (including buses). As such, the term is generally interchangeable with “heavy

- duty vehicle.”12 of 54 1

highway to school and transit buses, to vocational vehicles such as utility service trucks, as well as the largest pickup trucks and vans. For purposes of this preamble, the term “ heavy

- duty” or “ HD ” is used to apply to all highway

vehicles and engines that are not within the range of light

- dut y vehicles, light

- duty trucks, and medium

- duty passenger vehicles (MDPV) covered by the GHG and Corporate Average Fuel Economy (CAFE) standards issued for model ye ars (MY) 2012

- 2016. 7 Italso does not include motorcycles. Thus, in this notice, unless specified otherwise, the heav y - duty category incorporates all vehicles rated at a gross vehicle weight above 8,500 pounds, and the engines that power them, except for MDPVs. 8 We note that the Energy

Independence and Security Act of 2007 requires NHTSA to set standards for “ commercial medium

- and heav y - duty on - highway

vehicles and work trucks. ” 9 NHTSA interprets this to include all segments of the heav y - dut y category described above, except for recreational vehicles, such as motor homes, since recreational vehicles are not commercial. Setting GHG emissions standards for the heav y - duty sector will help to address c limate change , which is widely viewed as a significant long

- term threat to the global environment. As summarized in the Technical Support Document for EPA ’ s Endangerment and Cause or Contribute Findings under Section 202(a) of the Clean Air Act, anthropogenic emissions of GHGs are very likely ( a 90 to 99 percent probability) the c ause of most of the observed global warming over the last 50 y ears. 10 The primary GHGs of concern are carbon dioxide (CO 2 ), methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. Mobile sources emitted 31 percent of all U.S. GHGs in 2007 (transportation sources, which do not include certain off

- highway sources, account for 28 percent) and have been the fastest

- growing source of U.S. GHGs since 1990. 11 Mobile sources addressed in the recent endangerment and contribution findings under CAA section 202(a)

-- light

- dut y vehicles, heav y - dut y trucks, buses, and motorcycles

-- accounted for 23 percent of all U.S. GHG emissions in 2007. 12 Heav y -

7 Light

- Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards; Final Rule 75 FR 25323 (May 7, 2010). 8 The CAA defines heavy

- duty as a truck , bus or other motor vehicles with a gross vehicle w eight rating exceeding 6 , 000 pounds ( CAA section 202(b)(3) ) . The term HD as used in this action refers to a subset of these vehicles and engines. 9 49 U.S.C. 32902( k)(2). “Commercial medium

- and heavy

- duty on

- highway vehicles” are defined as on

highway vehicles with a gross vehicle weight rating of 10,000 pounds or more, while “work trucks” are defined as vehicles rated between 8,500 and 10,000 pounds gross vehic le weight that are not MDPVs. See 49 U.S.C. 32901(a)(7) and (a)(19). 10 “ Technical Support Document for Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act” available at Docket: EPA

- HQ

- OAR

- 2009

- 0472

- 11292, and athttp://epa.gov/climatechange/endangerment.html. 11 U.S. Environmental Protection Agency. 2009. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990

- 2007. EPA 430

- R
- 09

- 004. Available at http://epa.gov/climatechange/emissions/downloads09/GH G2007entire_report

- 508.pdf 12 U.S. EPA. 2009 Technical Support Document for Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act. Washington, DC. pp. 180

- 194. Available at http://epa.gov/climatechange/endangerment/downloads/Endangerment%20TSD.pdfDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

13 of 54 1 duty vehicles emit CO 2 , methane, nitrous ox ide, and hydrofluorocarbons and are responsible for nearl y 19 percent of all mobile source GHGs (nearl y 6% of all U.S. GHGs) and about 25 p ercent of s ection 202(a) mobile source GHGs . For heav y - dut y vehicles in 2007 , CO 2 emissions represent ed more than 99 percent of all GHG emissions (including HFCs )

. 13 Setting fuel consumption standards for the heav y - duty sector, pursuant to NHTSA’s EISA authority , will also improve our energy securit y b y reducing our dependence on foreign oil , which has been a national o bjective since the first oil price shocks in the 1970s. Net petroleum imports now account for approximately 60 percent of U.S. petroleum consumption. World crude oil production is highly concentrated, exacerbating the risks of supply disruptions and pric e shocks. Tight global oil markets led to prices over $100 per barrel in 2008, with gasoline reaching as high as $4 per gallon in many parts of the U.S., causing financial hardship for many families and businesses

. The export of U.S. assets for oil impor ts continues to be an important component of the historically

unprecedented U.S. trade deficits. Transportation accounts for about 72 percent of U.S. petroleum consumption. Heavy

- duty vehicles account for about 17 percent of transportation oil use, which means that they alone account for about 12 percent of all U.S. oil consumption

. 14 In developing this joint proposal, the a gencies have worked with a large and diverse group of stakeholders representing truck and engine manufacturers, trucking fleets, envi ronmental organizations , and states including the State of California. 15 While our discussions covered a wide range of issues and viewpoints, one widespread recommendation was that the two agencies should develop a common federal program with consistent st andards of performance regarding fuel consumption and GHG emissions. The HD National Program we are proposing today is consistent with that goal. Further it is our expectation based on our ongoing work with the State of California that the California Air Resources Board (CARB) will be able to adopt regulations equivalent in practice to those of this National Program , just as it has done for past EPA regulation of heav y - dut y trucks and engines. NHTSA and EPA are committed to continuing to work with CARB through out this rulemaking process to help ensure our final rule s can lead to that outcome. In light of the industry ’ s diversity , and consistent with the recommendations of the National Academ y of Sciences as discussed further below, the agencies are propos ing a HD National Program that recognizes the different sizes and work requirements of this

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

- 2007. EPA 430

- R
- 09

- 004. Available at http://epa.gov/climatechange/emissions/downloads09 /GHG2007entir e_report
- 508.pdf 14 In 2009 Source: EIA Annual Energy Outlook 2010 released May 11, 2010 15 Pursuant to DOT Order 2100.2, NHTSA will place a memorandum recording those meetings that it attended and documents submitted by stakeholders which formed a basis for this proposal and which can be made publicly available in its docket for this rulemaking. DOT Order 2100.2 is available at http://regs.dot.gov.14 of 54 1

wide range of heav y - duty vehicles and their engines. NHTSA ’ s proposed fuel consumption standards and EPA ’ s proposed GHG standards would appl y t o manufacturers of the following t ypes of heav y - duty vehicles and their engines; the proposed provisions for each of these are described in more detail below in this section:

 Heav y - dut y Pickup Trucks and Vans  Combination Tractors  Vocational Trucks As in the recent light

- duty vehicle rule establishing CAFE and GHG standards for MYs 2012

- 2016 light

- duty vehicles, EPA ’ s and NHTSA ’ s proposed standards for the heav y - dut y sector are largel y harmonized with one another due to the close and direct relationship between improving the fuel efficiency of these vehicles and reducing their carbon dioxide (CO 2 ) tailpipe emissions. For all vehicles that consume carbon

- based fuels, the amount of CO 2 emissions is essentially constant per gallon for a given ty pe of fuel that is consumed. T he more efficient a heav y - duty truck is in completing its work, the lower its environmental impact will be , because the less fuel consume d to move cargo a given distance, the less CO 2 emitted into the air. T he technologies available for improving fuel effici ency, and therefore for reducing both CO 2 emissions and fuel consumption, are one and the same. 16 Because of this close technical relationship, NHTSA and EPA have been able to rel y on jointly

- developed assumptions, anal ys es, and anal yt ical conclusions to s upport the standards and other provisions that NHTSA and EPA are proposing under our separate legal authorities. The timelines for the implementation of the proposed NHTSA and EPA standards are also closely

coordinated. EPA ’ s proposed GHG emission standards would begin in model year 2014. In order to provide for the four full model y ears of regulatory lead time required b y E IS A, as discussed in Section B.5 below, NHTSA ’ s proposed fuel consumption standards would be optional in model years 2014 and 2015, becoming mandatory

in model year 2016, except for diesel engine standards which would be optional in model years 2014, 2015 and 2016, becoming mandatory in model year 2017. A detailed discussion of how the proposed standards are consistent with each agenc y ’ s respective statutory

requirements and authorities is found later in this notice. Neither EPA nor NHTSA is proposing standards at this time for GHG emissions or fuel consumption, respectivel y, for heav y - dut y commercial trailers. However, the agencies are considering proposing such standards in a future rulemaking, and request comment on such an action later in this preamble.

16 How ever, as discussed below , in addition to addressing CO 2 , the EPA ’ s proposed standards also include pr ovisions to address other GHGs (nitrous oxide, methane, and air conditioning refrigerant emissions).), as required by the Endangerment Finding under the Clean Air Act. See Section II
.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

15 of 54 1 

### B. Building Blocks of the Heavy - duty National Progra m The standards that are being proposed in this notice represent the first time that EPA and NHTSA would regulate the heav y - dut y s ector for fuel consumption and GHG emissions. NHTSA and EPA are proposing standards for heav y - dut y vehicles and their engines that are rooted in EPA’s prior regulatory history , the SmartWay

Partnership pro gram, and extensive technical and engineering anal ys es done at the federal level. This section summarizes some of the most important of these precursors and foundations for this HD National Program.

(1) EPA ’ s Traditional Heavy - duty Regulatory Program Since the 1980s, EPA has acted several times to address tailpipe emissions of criteria pollutants and air toxics from heavy

- dut y vehicles and engines. During the last 18 years, these programs have primaril y addressed emissions of ozone precursors (hydrocarbons and nitrogen oxides (NO X )) and particulate matter (PM). These programs have successfull y achieved significant and cost

- effective reductions in emissions and associated health and welfare benefits to the nation. They have been structured in way s that acco unt for the varying circumstances of the engine and truck industries. As required b y the CAA, the emission standards implemented b y these programs include standards that appl y at the time that the vehicle or engine is sold as well as standards that apply in actual use. As a result of these programs, new vehicles meeting current emission standards will emit 98% less NO X and 99% less PM than new trucks 20 ye ars ago. The resulting emission reductions provide significant public health and welfare benefits. The most recent EPA regulations which were full y phased

- in in 2010 are projected to provide greater than $70 billion in health and welfare benefits annuall y in 2030 alone. 17 EPA ’ s overall program goal has alway s been to achieve emissions reductions from the complete vehicles that operate on our highway s. The agency has often accomplished this goal for many heavy

- duty

truck categories through the regulation of heav y - dut y engine emissions. A key part of this success has been the development over many years of a well

- established, representative, and robust set of engine test procedures that industry

and EPA now routinely

use to measure emissions and determine compliance with emission standards. These test procedures in turn serve the overall compliance prog ram that EPA implements to help ensure that emissions reductions are being achieved. By

isolating the engine from the many variables involved when the engine is installed and operated in a HD vehicle, EPA has been able to accuratel y address the contributi on of the engine alone to overall emissions. The agencies discuss below how the proposed program incorporates the existing engine

- based approach used for criteria emissions regulations, as well as new vehicle

- based approaches.

17 66 FR 5002, January 18, 2001.16 of 54 1 (2) NHTSA ’ s Responsibilities to Regulate Heavy - Duty Fuel Efficiency under EISA With the passage of the EI SA in December 2007, Congress laid out a framework developing the first fuel efficiency regulations for HD vehicles. As codified at 49 U.S.C. § 32902(k), EISA requires NHTSA to deve lop a regulatory s ys tem for the fuel econom y of commercial medium

- duty and heav y - dut y on - highway vehicles and work trucks in three steps: a study b y the National Academ y of Sciences (NAS), a study by NHTSA, and a rulemaking to develop the regulations them selves. 18 Specificall y, section 102 of EI SA, codified at 49 U.S.C. 32902(k)(2), states that not later than two years after completion of the NHTSA study, DOT (b y delegation, NHTSA), in consultation with the Department of Energy and EPA, shall develop a regu lation to implement a “ commercial medium

- duty and heav y - dut y on - highway vehicle and work truck fuel efficiency improvement program designed to achieve the maximum feasible improvement. ” NHTSA interprets the timing requirements as permitting a regulation t o be developed earlier, rather than as requiring the agency to wait a specified period of time. Congress specified that as part of the “ HD fuel efficiency improvement program designed to achieve the maximum feasible improvement, ” NHTSA must adopt and imple ment:

 Appropriate test methods;

 Measurement metrics;  Fuel economy

standards; 19 and  Compliance and enforcement protocols. Congress emphasized that the test methods, measurement metrics, standards, and compliance and enforcement protocols must all be appropri ate , cost
- effective , and technologically feasible for commercial medium

- duty and heav y - dut y on - highway vehicles and work trucks. NHTSA notes that these criteria are different from the “ four factors ” of § 32902(f) 20 that have long governed NHTSA ’ s setting o f fuel economy standards for passenger cars and light trucks, although man y of the same factors are considered under each of these provisions.

18 The NAS study is described below , and the NHTSA study accompanies this NPRM. 19 In the context of section 32902(k), NHTSA interprets “fuel economy standards” as referring not specifically to miles per gallon, as in the light

- duty vehicle context, but instead more broadly to account as accurate ly

as possible for MD/HD fuel efficiency . While it is a metric that NHTSA considered for setting MD/HD fuel efficiency standards, the agency recognizes that miles per gallon may not be an appropriate metric given the work that MD/HD vehicles are manufactured to do . NHTSA is thus proposing alternative metrics . as discussed further below

. 20 49 U.S.C. 32902(f) states that “When deciding maximum feasible average fuel economy under this section, [NHTSA] shall consider technological feasibility, economic practi cability, the effect of other motor vehicle standards of the Government on fuel economy, and the need of the United States to conserve energy.”Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

17 of 54 1 Congress also stated that NHTSA may set separate standards for different classes of HD vehicles, which the agency interprets broadly to allow regulation of HD engines in addition to HD vehicles, and provided requirements new to section 32902 in terms of timing of regulations, stating that the standards adopted as a result of the agency ’ s rulemaking shall provide not less than four full model y ears of regulatory lead time, and three full model ye ars of regulatory stability

. (3) National Academy of Sciences Report on Heavy - duty Technology As mandated b y Congress in EI SA, the National Research Council (NRC) of the National Academ y of Sciences (NAS) recentl y issued a report to NHTSA and to Congress evaluating medium

- duty and heav y - dut y truck fuel efficiency improvement opportunities , titled “ Technologies and Approaches to Reducing the Fuel Consumption of Medium

- and Heav y - duty Vehicles. ” 21 This study covers the same universe of heav y duty vehicles that is the focus of this proposed rulemaking

– all highway vehicles that are not light

- duty , MDPVs, or motorcycles. The agencies have carefull y evaluated the research supporting this report and its conclusions and have incorporated them to the extent practicable in the development of this rulemaking. NHTSA ’ s and EPA ’ s detailed assessments of each of the relevant elements of the NAS report are discussed in section X of this preambl e and in the NHTSA HD study accompanying this NPRM

. (4) The Recent NHTSA and EPA Light - duty National GHG Program On April 1, 2010, EPA and NHTSA finalized the first

- ever National Program for light

- duty cars and trucks, which set GHG and fuel econom y standards for model years 2012

- 2016. The agencies have used the light

- duty National Program as a model for this proposed HD National Program in many respects. This is most apparent in the case of heav y - dut y pickups and vans, which are very similar to the light

- duty trucks addressed in the light

- dut y National Program both technologically as well as in terms of how they are manufactured (i.e., the same compan y often makes both the vehicle and the engine). For these vehicles, there are close parallels to the light

- d uty program in how the agencies have developed our respective proposed standards and compliance structures, although in this proposal each agency proposes standards based on attributes other than vehicle footprint, as discussed below. Due to the diversit y of the remaining HD vehicles, there are fewer parallels with the structure of the light

- duty program. However, the agencies have maintained the same collaboration and coordination that characterized the development of the light

- dut y program. Most notab ly , as with the light

- dut y program, manufacturers will be able to

21 National Academy of Science, Committee to Assess Fuel Economy Technologies for Medium

- and Heavy
- Duty Vehicles , “Technologies and Approaches to Reducing the Fuel Consumption of Medium

- and Heavy
- Duty Vehicles,” March 2010 (hereafter, “March 2010 NAS Report” or “NAS Report”). Available at http://www.nap.edu/catalog.php?record_id=12845 (last accessed August 5, 2010 ).18 of 54 1

design and build to meet a closel y coordinated federal program, and avoid unnecessarily duplicative testing and compliance burdens.

(5) EPA ’ s SmartWay Program EPA ’ s voluntary

SmartWay

Partners hip program encourages shipping and trucking companies to take actions that reduce fuel consumption and CO 2 by working with the shipping community and the freight sector to identify low carbon strategies and technologies, and b y providing technical information, financial incentives, and partner recognition to accelerate the adoption of theses strategies. Through the SmartWay program, EPA has worked closely with truck manufacturers and truck fleets to develop test procedures to evaluate vehicle and component performance in reducing fuel consumption and has conducted testing and has established test programs to verify technologies that can achieve these reductions. Over the last six years, EPA has developed hands

- on experience testing the largest heav y - dut y trucks and evaluating improvements in tire and vehicle aerodynamic performance. In 2010, according to vehicle manufacturers, approximately 5 percent of new combination heavy

- duty trucks will meet the SmartWay

performance criteria demonstrating that they r epresent the pinnacle of current heav y - duty truck reductions in fuel consumption. In developing this HD National Program, the agencies have drawn from the SmartWay

experience, as discussed in detail both in Sections II and III below (e.g., developing test procedures to evaluate trucks and truck components) but also in the Draft RIA (estimating performance levels from the application of the best available technologies identified in the SmartWay program). These technologies provide part of the basis for the GHG emission and fuel consumption standards proposed in this rulemaking for certain t ypes of new heav y - dut y C lass 7 and 8 combination tractors. In addition to identifying technologies, the SmartWay program includes operational approaches that truck fleet owners as well as individual drivers and their freight customers can incorporate that the NHTSA and EPA believe will complement the proposed standards. These include such approaches as improved logistics and driver training, as discussed in the DRIA. Th is approach is consistent with the one of the three alternative approaches that the NAS recommended be considered. The three approaches were raising fuel taxes, liberalizing truck size and weight restrictions, and encouraging incentives to disseminate inf ormation to inform truck drivers about the relationship between driving behavior and fuel savings. Taxes and truck size and weight limits are mandated b y public law; as such, are outside EPA's and NHTSA's authority to implement. However, complementary op erational measures like driver training, which SmartWay

does promote, can complement the proposed standards and also provide benefits for the existing truck fleet, furthering the public policy objectives of addressing energy securit y and climate change. (6) Ca nada ’ s Department of the Environment The Government of Canada ’ s Department of the Environment (Environment Canada) assisted EPA ’ s development of this Proposed Rulemaking, b y conductingDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

19 of 54 1 emissions testing of heavy

- dut y vehicles at Environment Canada test fac ilities to gather data on a range of possible test cycles. We expect the technical collaboration with Environment Canada to continue as we address issues raised by stakeholders in response to this NPRM, and as we continue to develop details of certain test ing and compliance verification procedures. We may also be able to begin to develop a knowledge base enabling improvement upon this regulatory framework for model y ears beyond 2018 (for example, improvements to the means of demonstrating compliance). We also expect to continue our collaboration with Environment Canada on compliance issues. 

### C. Summary of the Proposed EPA and NHTSA HD National Program When EPA first addressed emissions from heav y - duty trucks in the 1980s, it established standards for engines, based on the amount of work performed (grams of pollutant per unit of work (brake horsepower

- hour), or g/bhp

- hr). This approach recognized the fact that engine characteristics are the dominant determinant of the ty pes of emissions generated, and engine

- b ased technologies (including exhaust aftertreatment sy stems) need to be the focus for addressing those emissions. Vehicle

- based technologies, in contrast, have less influence on overall truck emissions of the pollutants that EPA has regulated in the past. The engine testing approach also recognized the relativel y small number of distinct heav y - dut y engine designs, as compared to the extremely wide range of truck designs. EPA concluded at that time that any incremental gain in conventional emission contro l that could be achieved through regulation of the complete vehicle would be small in comparison to the cost of addressing the many variants of complete trucks that make up the heavy

- dut y sector

– smaller and larger vocational trucks for dozens of purposes , various designs of combination tractors, and many others. Addressing GHG emissions and fuel consumption from heav y - duty trucks, however, requires a different approach. Reducing GHG emissions and fuel consumption requires increasing the inherent efficien cy of the engine as well as making changes to the vehicles to reduce the amount of work that the engine needs to do per mile traveled. This thus requires a focus on the entire vehicle. For example, in addition to the basic emissions and fuel consumption levels of the engine, the aerodynamics of the vehicle can have a major impact on the amount of work that must be performed to transport freight at common highway

speeds. The March 2010 NAS Report recognized this need and recommended a complete

- vehicle app roach to regulation. As described elsewhere in this preamble, the proposed standards that make up the HD National Program aim to address the complete vehicle, to the extent practicable and appropriate under the agencies’ respective statutory

authorities, through complementary engine and vehicle standards, in order to reduce the complexity of the regulatory

sy stem and achieve the greatest gains as soon as possible.20 of 54 1 (1) Brief Overview of the Heavy - duty Truck Industry The heav y - duty

truck sector spans a wide range of vehicles with often unique form and function. A primary indicator of the extreme diversit y among heavy

- dut y trucks is the range of load

- carrying capability across the industry

. The heavy

- dut y truck sector is often subdivided by vehicle weight clas sifications , as defined b y the vehicle ’ s gross vehicle weight rating, or GVWR , which is a measure of the combined curb (empt y) weight and cargo carrying capacity of the truck

. Table I
- 1 below outlines the vehicle weight classific ations commonly used for man y years for a variet y of purposes by several federal agencies, including the Department of Transportation, the Department of Commerce, and the Internal Revenue Service. Table I - 1 Ve hicle Weight Classification Class 2b 3 4 5 6 7 8 GVWR (lb.) 8,501

-

10,000 10,001

-

14,000 14,001

-

16,000 16,001

-

19,500 19,501

-

26,000 26,001

-

33,000 >

33,001 In the framework of these vehicle weight classifications, the heav y - dut y truck sector refers to Clas s 2b through Class 8 vehicles and the engines that power those vehicles. 22 Unlike light

- duty vehicles, which are primarily used for transporting passengers for personal travel, heavy

- dut y vehicles fill much more di verse operator needs

. Heavy
- dut y pickup trucks and vans (Classes 2b and 3) are used chiefly as work truck and vans, and as shuttle vans, as well as for personal transportation , with an average annual mileage in the range of 15,000 miles. The rest of the heavy

- dut y sector is used for carryi ng car go and/or performing specialized tasks. Commercial “ vocational ” trucks, which may

span Classes 2b through 8, vary widely in size, including smaller and larger van trucks, utility “ bucket ” trucks, tank trucks, refuse trucks, urban and over

- the

- road buses, fire trucks, flat

- bed trucks, and dump trucks, among others. The annual mileage of these trucks is as varied as their uses, but for the most part tends to fall in between heavy

duty pickups/vans and the large combination trucks, ty picall y from 15,000 to 1 50,000 miles per y ear, although some travel more and some less. Class 7 and 8 combination tractor
- trailers

– some equipped with sleeper cabs and some not

-- are primarily used for freight transportation. They are sold as tractors and sometimes run without a trailer in between loads , but most of the time they run with one or more trailers that can carry up to 50,000 pounds or more of payload , consuming significant quantities of fuel and producing significant amounts of GHG emissions

. The combination trac tor/trailers used in combination applications can travel more than 150,000 miles per y ear. EPA and NHTSA have designed our respective proposed standards in careful consideration of the diversity and complexity

of the heav y - dut y truck industry , as discussed next.

22 Class 2b vehicles designed as passenger vehicles (Medium Duty Passenger Vehicles, MDPVs) are covered by the light

- duty GHG and fuel economy standards and not addressed in this rulemaking.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

21 of 54 1 (2) Summary of Proposed EPA GHG Emission Standards and NHTSA Fuel Consumption Standards As described above, NHTSA and EPA recognize the importance of addressing the entire vehicle in reducing fuel consumption and GHG emissions. At the same time, the a gencies understand that the complexity of the industry

means that we will need to use different approaches to achieve this goal, depending on the characteristics of each general ty pe of truck. We are therefore proposing to divide the industry into three d iscrete regulatory

categories for purposes of setting our respective standards

– combination tractors, heav y - dut y pickups and vans, and vocational trucks

-- based on the relative degree of homogeneit y among trucks within each category. For each regulatory category , the agencies are proposing related but distinct program approaches reflecting the specific challenges that we see for manufacturers in these segments. In the following paragraphs, we discuss EPA ’ s proposed GHG emission standards and NHTSA ’ s pro posed fuel consumption standards for the three regulatory categories of heavy

- dut y vehicles and their engines. The agencies are proposing test metrics that express fuel consumption and GHG emissions relative to the most important measures of heav y - dut y tr uck utility

for each segment , consistent with the recommendation of the March 2010 NAS Report that metrics should reflect and account for the work performed b y various t ypes of HD vehicles . Specifically , for heavy

- dut y pickup trucks and vans, EPA and NHTS A are proposing standards on a per

- mile basis (g/mile for the EPA standards, gallons/100 miles for the NHTSA standards), as explained in Section I .C(2)(a) below. For heavy

- dut y trucks, both combination and vocational, the agencies are proposing standards expressed in terms of the key

measure of freight movement tons of payload miles or, more simply , ton
- miles. Hence, for EPA the proposed standards are in the form of the mass of emissions from carrying a ton of cargo over a distance of one mile (g/ton

- mi)) . Similarly , the proposed NHTSA standards are in terms of fuel consumed over a set distance (one thousand miles), or gal/1000 ton

- mile. Finally , for engines, EPA is proposing standards in the form of grams of emissions per unit of work (grams per brake

- h orsepower - hour, or g/bhp

- hr), the same metric used for non

- GHG heavy

- dut y engine standards today. Similarly , NHTSA is proposing standards for heavy

- dut y engines in the form of fuel consumption (in gallons) per 100 units of work (gal/100 bhp

- hr). Section I I below discusses the proposed EPA and NHTSA standards in greater detail. (a ) Class 7 and 8 Combination Tractors Class 7 and 8 combination tractors and their engines contribute the largest portion of the total GHG emissions and fuel consumption of the heav y duty sector , approximately 65 %, of today ’ s GHG emissions and XX% of today’s fuel consumption, due to their large payload s, their high annual miles traveled , and their major role in national freight22 of 54 1

transport. 23 These vehicles consist of a cab and engine (tr actor or combination tractor) and a detachable trailer. In general, reducing GHGs and fuel consumption for these vehicles would involve improvements such as aerody namics and tires and reduction in idle operation, as well as engine

- based efficiency improve ments. In general, the heavy

- duty combination tractor industry consists of tractor manufacturers (which manufacture the tractor and purchase and install the engine) and trailer manufacturers . These manufacturers are usually separate from each other

. Thus, we are not aware of an y manufacturer that t ypically assembles both the finished truck and the trailer and introduces the combination into commerce for sale to a buyer, as the owners of trucks and trailers are often distinct. A ty pical truck buyer w ill purchase onl y the tractor. The trailers are usuall y purchased and owned b y fleets and shippers. This occurs in part because trucking fleets on average maintain 3 trailers per tractor and in come cases as man y as 6 or more trailers per tractor. There are also large differences in the kinds of manufacturers involved with producing tractors and trailers. For HD highway tractors and their engines, a relativel y limited number of manufacturers produce the vast majority

of them. The trailer manufacturing industry is quite different, and includes a large number of companies, man y of which are relativel y small in size and production volume. Setting standards for the products involved

-- tractors and trailers

-- requires recognition of the large differences between these manufacturing industries, which can then warrant consideration of different regulatory approaches. Based on these industry

characteristics , EPA and NHTSA believe that the most straightforward regulatory approach for combination tractors and trailers is to establish standards for tractors separatel y from trailers

. As discussed below in Section IX , the agencies are proposing standards for the tractors and their engines in this rulemaking, but are not proposing standards for trailers in this r ulemaking . The agencies are requesting comment on potential standards for trailers, but will address standards for trailers in a separate rulemaking

. As with the other regulatory categories of heavy

- duty vehicles, EPA and NHTS A have concluded that achiev ing reductions in GHG emissions and fuel consumption from combination tractors requires addressing both the cab and the engine, and EPA and NHTSA each are proposing standards that reflect this conclusion. The importance of the cab is that its design deter mines the amount of power that the engine must produce in moving the truck down the road. As illustrated in Figure I
- 1 , the loads that require additional power from the engine include air resistance ( aerod ynamic s) , tire rolling r esistance, and parasitic losses (including accessory loads and friction in the drivetrain)

. The importance of the engine design is that it determines the basic GHG emissions and fuel consumption performance of the engine for the variety of demands placed on the engine, regardless of the characteristics of the cab in which it is installed. The agencies

23 The vast majority of combination tractor

- trailers is used in highway applications, and these vehicles are the focus of this proposed program. A small fraction of combination trucks are used in off

- road applications and are treated differently, as describe in Section II.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

23 of 54 1 intend for the proposed standards to result in the application of improved technologies for lower GHG emissions and fuel consumption for both the cab and th e engine.

Figure I - 1 : Combination Tractor and Trailer Loads 24 Accordingl y, for Class 7 and 8 combination tractors, the agencies are each proposing two sets of standards. For vehicle

- related emissions and f uel consumption, the agencies are proposing that tractor manufacturers meet respective vehicle

- based standards. Compliance with the vehicle standard would ty picall y be determined based on a vehicle simulation model, called [TEST] , which is consistent with the NAS Report recommendations to require compliance testing for combination tractors using vehicle simulation rather than chassis dy namometer testing. This compliance model was developed b y EPA specifically for this rulemaking. It is an accurate and co st
- effective alternative to measuring emissions and fuel consumption while operating the vehicle on a chassis dy

namometer. Instead of using a chassis dy namometer as an indirect way to evaluate real

- world operation and performance, various characteristics of the vehicle are measured and these measurements are used as inputs to the model. These characteristics relate to key

technologies appropriate for this subcategory of truck

– including aerod ynamic features, weight reductions, tire rolling resistance, th e presence of idle

reducing technology , and vehicle speed limiters. The model would also assume the use of a representative ty

pical engine, rather than a vehicle

- specific engine, because engines are regulated separately

and include an averaging, banking, and trading program separate from the vehicle program. The model and appropriate inputs would be used to quantify the overall performance of the vehicle in terms of CO 2 emissions and fuel consumption. The model ’ s development and design, as well as the so urces for inputs and the evaluation of the model ’ s accuracy , are discussed in detail in Section II below and in the draft RIA.

24 Adapted from Figure 4.1 Class 8 Truck E nergy Audit, Technology Roadmap for the 21st Century Truck Program: A Government

- Industry Research Partnership, 21CT

- 001, December, 200024 of 54 1 EPA and NHTSA also considered developing respective alternative standards based on the direct testing of the emissions and fuel consumption of the entire vehicle for this subcategory

of vehicles, as measured using a chassis test procedure. This would be similar to the proposed approach for standards for HD pickups and vans discussed below. The agencies believe that such an appro ach warrants continued consideration. However, the agencies are not prepared to propose chassis

- test
- based standards at this time, primarily because of the very

small number of chassis

- test facilities that currently exist, but rather are proposing only th e tractor standards and the engine

- based standards discussed above. The agencies seek comment on the potential benefits and trade

- offs of chassis

- test
- based standards for combination tractors. (i ) Proposed Standards for Class 7 and 8 Combination Tractors Th e vehicle standards that EPA and NHTSA are proposing for Class 7 and 8 combination tractor manufacturers are based on several key attributes related to GHG emissions and fuel consumption that we believe reasonably represent the many differences in utility among these vehicles. The proposed standards differ depending on GVWR ( i.e ., whether the truck is Class 7 or Class 8), the height of the roof of the cab, and whether it is a “ day

cab ” or a “ sleeper cab.” These later two attributes are important because the height of the roof, designed to correspond to the height of the trailer, significantl y affects air resistance, and a sleeper cab generally corresponds to the opportunity

for idle emission and fuel consumption improvements. Thus, the agencies have created nine subcategories within the Cl ass 7 and 8 combination tractor category based on the differences in expected emissions and fuel consumption associated with the key attributes of GVWR, cab ty pe, and roof height. Table I
- 2 presents the agencies’ respective proposed standards for combination tractor manufacturers for the 2017 model year for illustration

. Table I - 2 : Heavy - duty Co mbination Tr actor EPA Emissions Standar ds (g CO 2 /ton - mi le) and

NHTSA Fuel Consumption Standards (gal/ 1000 ton - mi le) 2017 Model Year CO 2 Grams per Ton

- Mile Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 106 80 65 Mid Roof 106 80 65 High Roof 120 88 72 2017 Model Year Gallons of Fue l per 1000 Ton

- Mile Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 10.4 7.9 6.4 Mid Roof 10.4 7.9 6.4 High Roof 11.8 8.6 7.1 In addition, the agencies are proposing separate performance standards for the engines manufactured for use in these trucks. EPA ’ s proposed engine

- based CO 2Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

25 of 54 1 standards and NHTSA ’ s proposed engine

- based fuel consumption standards would vary based on the expected weight class and usage of the truck into which the engine would be installed. EPA is also proposing engine

- bas ed N 2 O and CH 4 standards for manufacturers of the engines used in combination tractors. EPA is proposing separate engine

- based standards for these GHGs because the agency believes that N 2 O and CH 4 emissions are technologicall y related solely to the engine , fuel, and emissions aftertreatment sy stems, and the agency

is not aware of any

influence of vehicle

- based technologies on these emissions. EPA expects that manufacturers of current engine technologies would be able to comply

with the proposed “cap” stan dards with little or no technological improvements; the value of the standards would be to prevent significant increases in these emissions as alternative technologies are developed and introduced in the future. Compliance with the proposed EPA engine

- bas ed CO 2 standards and the proposed NHTSA fuel consumption standards, as well as the proposed EPA N 2 O and CH 4 standards, would be determined using the appropriate EPA engine test procedure, as discussed in Section II below. As with the other subcategories o f heav y - dut y vehicles, EPA and NHTSA are proposing respective standards that would appl y to Class 7 and 8 trucks both at the time of production (as in Table I
- 2 , above). In addition, EPA is proposing separate standards that would apply

for a specified period of time in use. All of the proposed standards for these trucks, as well as details about the proposed provisions for certification and implementation of these standards, are discussed in more detail in Sections II, III, IV, a nd V below and in the draft RIA. (ii) EPA Proposed Air Conditioning Leakage Standard for Class 7 and 8 Combination Tractors In addition to the proposed EPA tractor

- and engine

- based standards for CO 2 and engine

- based standards for N 2 O, and CH 4 emissions, EPA is also proposing a separate standard to reduce leakage of HFC refrigerant from cabin air conditioning (A/C) sy stems from combination tractors, to apply to the tractor manufacturer. This standard would be independent of the CO 2 tractor standard, as discus sed below. Because the current refrigerant used widely

in all these sy stems has a very high global warming potential (GWP), EPA is concerned about leakage of refrigerant over time. 25 Because the interior volume to be cooled of most of these truck cabins is similar to that of light

- dut y trucks, the size and design of current truck A/C systems is also very similar. The proposed compliance approach for Class 7 and 8 trucks is therefore similar to that in the light

- duty

rule in that these proposed standards are design

- based. Manufacturers would choose technologies from a menu of leak

- reducing technologies sufficient to comply

with the standard, as opposed to using a test to measure performance.

25 The global warming potential (GWP) for HFC

- 134a refrigerant of 1430 used in this proposal is consistent with the Inte rgovernmental Panel on Climate Change (IPCC) Fourth Assessment Report (AR4).26 of 54 1 However, the proposed heav y - dut y A/C provisions differ in two important way s from those established in the light

- dut y rule. First, the light

- dut y provisions were established as voluntary

way s to generate credits towards the CO 2 g/mi standard, and EPA took into account the expected use of such credits in establishing the CO 2 emissions standards. In this rule, EPA is proposing that manufacturers actually meet a standard

– as opposed to having the opportunity to earn a credit

-- for A/C refrigerant leakage. Thus, for this rule, refrigerant leakage is not accounted for in the development of the proposed CO 2 standards. We are taking this approach here recognizing that while the per A/C sy stem benefits of leakage control are almost identical between light

- dut y and heav y - dut y vehicles, the credits based on per mile benefi ts are much smaller for heav y - duty vehicles due to their much higher CO2 emissions rates and higher annual mileage when compared to light duty

vehicles. Hence a credit based approach as done for light

- duty would provide almost no motivation for manufactur ers to install low leakage s ys tems even though such s ys tems represent a highly cost effective means to control GHG emissions. The second difference relates the expression of the leakage rate. The light

- duty A/C leakage standard is expressed in terms of grams per year. For this heavy

- duty rule, however, because of the wide variet y of s ys tem designs and arrangements, a one

- size

fits

- all gram per ye ar standard would likely be much less relevant, so EPA believes it is more appropriate to propose a standard i n terms of percent of total refrigerant leakage per ye ar, This requires the total refrigerant capacit y of the A/C system to be taken into account in determining compliance. EPA believes that this proposed approach

-- a standard instead of a credit, and b asing the standard on percent leakage over time

– is more appropriate for heavy

- dut y tractors than the light

- duty approach and that it will achieve the desired reductions in refrigerant leakage. Compliance with the standard would be determined through a s howing by the tractor manufacturer that it s A/C sy stem incorporated a combination of low

- leak technologies sufficient to meet the percent leakage of the standard. This proposed “ menu ” of technologies is very similar to that established in the light

- duty G HG rule. 26 Finally , EPA is not proposing an A/C s ys tem efficiency standard in this heavy

duty rulemaking, although an efficiency credit was a part of the light

- dut y rule. The much larger emissions of CO 2 from a heav y - dut y tractor as compared to those fro m a light duty vehicle mean that the relative amount of CO 2 that could be reduced through A/C efficiency

improvements is very

small. We request comment on this decision and whether EPA should reflect A/C sy stem efficiency in the final program either as a credit or a stand alone standard based on the same technologies and performance levels as the light

- duty program. A more detailed discussion of A/C related issues is found in Section II of this preamble.

26 At this time, EPA is considering approval of an alternative refrigerant, HFO

- 1234yf, which has a very low GWP. The proposed A/C leakage standard is designed to account for use of an alternative, low

- GWP refrigerant. If in the future this refrigerant is approved and if it becomes widespread as a substitute for HFC

- 134a in mobile A/C systems, EPA may propose to revise or eliminate the leakage standard.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

27 of 54 1 (b ) Heavy

-Duty Pickup Trucks and Vans (Class 2b and 3 ) Heav y - dut y vehicles with GVWR between 8,501 and 10,000 lb are classified in the industry

as Class 2b motor vehicles per the FMCSA definition. As discussed above, Class 2b includes medium

- duty passenger vehicles (MDPVs) that are regulated by the agencies under the light

- duty vehicle program, and the agencies are not considering additional requirements for MDPVs in this rulemaking. Heav y - dut y vehicles with GVWR between 10,001 and 14,000 lb are classified as Class 3 motor vehicles. Class 2b and Class 3 heav y - dut y vehicles (referred to in this proposal as “ HD pickups and vans”) together emit about 20% of today ’s GHG emissions from the heavy

- duty vehicle sector. About 90 percent of HD pickups and vans are 3⁄4

- ton and 1

- ton pick

- up trucks, 12

- and 15

- passenger vans, and large work vans that are sold by the original equipment manufacturers (OEMs) as complete vehicles, with no secondary manufacturer making substantial modifications prior to registration and use. These OEMs are companies with major light

- dut y mar

kets in the U.S., primarily Ford, General Motors, and Chry sler. Furthermore, the technologies available to reduce fuel consumption and GHG emissions from this segment are similar to the technologies used on light

- dut y pickup trucks , including both engine efficiency improvements (for gasoline and diesel engines) and vehicle efficiency improvements. For these reasons, EPA believes it is appropriate to propose GHG standards for HD pickups and vans based on the whole vehicle, including the engine, expressed as grams per mile, consistent with the way these vehicles are regulated by EPA today

for criteria pollutants. NHTSA believes it is appropriate to propose corresponding gallons per 100 mile fuel consumption standards that are likewise base on the whole ve hicle. This complete vehicle approach being proposed by both agencies for HD pickups and vans is consistent with the recommendations of the NAS Committee in their March 2010 Report. EPA and NHTSA also believe that the structure and man y of the detailed p rovisions of the recently finalized light

- duty GHG and fuel econom y program, which also involves vehicle

- based standards, are appropriate for the HD pickup and van GHG and fuel consumption standards as well, and this is reflected in the standards each agen cy is proposing, as detailed in section II. These proposed commonalities include a new vehicle fleet average standard for each manufacturer in each model year and the determination of these fleet average standards based on production volume

- weighted targe ts for each model, with the targets varying based on a defined vehicle attribute. Vehicle testing would be conducted on chassis dy namo meters using the drive cycles from the EPA Federal Test Procedure (FTP or ‘‘ cit y ’’ test) and Highway Fuel Economy

Test (H FET or ‘‘ highway ’’ tes t). For the light

- dut y GHG and fuel econom y standards, the agencies factored in vehicle size by

basing the emissions and fuel economy targets on vehicle footprint (the wheelbase times the average track width). 27 For those standards, p assenger cars and light

27 EISA requires CAFE stand ards for passenger cars and light trucks to be attribute

- based; see 49 U.S.C. 32902(b)(3)(A).28 of 54 1

trucks with larger footprints are assigned higher GHG and lower fuel economy target levels in acknowledgement of their inherent tendency to consume more fuel and emit more GHGs per mile. For HD pickups and vans, the agencies believ e that setting standards based on vehicle attributes is appropriate, but feel that a weight

- based metric provides a better attribute than the footprint attribute utilized in the light

- duty vehicle rulemaking. Weight

- based measures such as payload and towi ng capability are key among the things that characterize differences in the design of these vehicles, as well as differences in how the vehicles will be utilized. Buyers consider these utility

- based attributes when purchasing a heav y - dut y pick

- up or van. EPA and NHTSA are therefore proposing standards for HD pickups and vans based on a “work factor” that combines their payload and towing capabilities, with an added adjustment for 4

- wheel drive vehicles. The agencies are proposing that each manufacturer’s fleet average standard would be based on production volume

- weighting of target standards for each vehicle that in turn are based on the vehicle’s work factor. These target standards would be taken from a set of curves (mathematical functions), presented in Section II.C. EPA is also proposing that the CO 2 standards be phased in graduall y starting in the 2014 model year, at 15

- 20

- 40

- 60

- 100 percent in model years 2014

- 2015

- 2016

- 2017

- 2018, respectively . The phase

- in would take the form of a set of target st andard curves, with increasing stringency in each model year, as detailed in Section II.C. The EPA standards proposed for 2018 (including a separate standard to control air conditioning s ys tem leakage) represent an average per

vehicle reduction in GHGs of 17 percent for diesel vehicles and 12 percent for gasoline vehicles, compared to a common baseline, as described in Sections II and III of this preamble. Section II also discusses the rationale behind the proposal of separate targets for diesel and gasol ine vehicle standards. EPA is also proposing a manufacturer’s alternative implementation schedule for model years 2016

- 2018 that parallels and is equivalent to NHTSA’s first alternative described below. NHTSA is proposing to allow manufacturers to select one of two fuel consumption standard alternatives for model years 2016

- 2018 . To meet the EI SA statutory requirement for three year regulatory stability , the first alternative would define individual gasoline vehicle and diesel vehicle fuel consumption target curves that would not change over model years 2016 to 2018. The proposed target curves for this alternative are presented in Section II. The second alternative would use target curves that are equivalent to the EPA program in each model year 2016 to 2 018. Stringency for the alternatives has been selected to allow a manufacturer, through the use of the credit and deficit carry

- forward provisions that the agencies are also proposing, to rely on the same product plans to satisfy

either alternative, and a lso EPA requirements. NHTSA is also proposing that manufacturers may voluntaril y opt into the NHTSA HD pickup and van program in model years 2014 or 2015. For these model years, NHTSA’s fuel consumption target curves are equivalent to EPA’s target curves

.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

29 of 54 1 The proposed EPA and NHTSA standard curves are based on a set of vehicle, engine, and transmission technologies expected to be used to meet the recently established GHG and fuel economy standards f

or model year 2012

- 2016 light

- dut y vehicles, with full co nsideration of how these technologies would perform in heav y - dut y vehicle testing and use. All of these technologies are already in use or have been announced for upcoming model years in some light

- duty vehicle models , and some are in use in a portion of HD pickups and vans as well

. The technologies include:

 advanced 8

- speed automatic transmissions
 aerod ynamic improvements
 electro

- hydraulic power steering
 engine friction reductions
 improved accessories
 low friction lubricants in powertrain components
 lowe r rolling resistance tires
 lightweighting
 gasoline direct injection
 gasoline engine coupled cam phasing
 diesel aftertreatment optimization
 air conditioning s ys tem leakage reduction (for EPA program onl y) See Section III. xx for a detailed anal ys is of these and other potential technologies, including their feasibility, costs, and effectiveness when emplo yed for reducing fuel consumption and CO2 emissions in HD pickups and vans

. A relativel y small number of HD pickups and vans are sold b y OEMs as incomplete v ehicles, without the primary load

- carrying device or container attached. We are proposing that these vehicles generall y be regulated as Class 2b through 8 vocational trucks, as described in Section I .C(2)(c), because, like other vocational trucks, we hav e little information on baseline aerodynamic performance and expectations for improvement. However, a sizeable subset of these incomplete vehicles, often called cab

chassis vehicles, are sold by the OEMs in configurations with many of the components that affect GHGs and fuel consumption identical to those on complete pickup truck or van counterparts

— including engines, cabs, frames, transmissions, axles, and wheels. We are proposing that these vehicles be included in the chassis

- based HD pickup and van p rogram. Similarly , some Class 4 complete vehicles are very similar to complete Class 3 vehicle models, including overall vehicle architecture and use of the same basic engines, and we are proposing that these Class 4 vehicles be included in the chassis

- ba sed HD pickup and van program as well. These proposed provisions are described in Section V.E. In addition to proposed EPA CO 2 emission standards and the proposed NHTSA fuel consumption standards for HD pickups and vans, EPA is also proposing standards for two additional GHGs, N 2 O and CH 4 , as well as standards for air conditioning

- related HFC emissions. These standards are discussed in more detail in Sections II.xx and II.xx.30 of 54 1

Finally , EPA is proposing standards that would apply to HD pickups and vans in use. All of the proposed standards for these HD pickups and vans, as well as details about the proposed provisions for certification and implementation of these standards, are discussed in Sections II.C. (c) Class 2b

- 8 Vocational Trucks Class 2b

- 8 vocational trucks consist of a wide variety of truck t ypes. Some of the primary applications for trucks in this segment include delivery , refuse, utility , dump, and cement trucks; transit, shuttle, and school buses; emergency vehicles, motor homes, 28 tow trucks, amon g others . These trucks and their engines contribute approximately 15 % of today ’ s heavy

- duty

truck sector GHG emissions

. Manufacturing of trucks in this segment of the industry is organized in a more complex way

than that of the other heav y - dut y subcatego ries

. Class 2b

- 8 vocational trucks are often built as a chassis with an installed engine and an installed transmission. Both the engine and transmissions are ty pically manufactured by

other manufacturers and the chassis manufacturer purchases and install s them. Many of the same companies that build Class 7 and 8 tractors are also in the Class 2b

- 8 chassis manufacturing market. The chassis is ty

picall y then sent to a body manufacturer , which completes the vehicle by installing the appropriate feature

-- s uch as dump bed, delivery box, or utility bucket

-- onto the chassis. Truck b ody manufacturers tend to be small businesses that specialize in specific t ypes of bodies or specialized features

. EPA and NHTSA are proposing that in this vocational truck sub category the chassis manufacturers be the focus of the proposed GHG and fuel consumption standards. They play a central role in the manufacturing process, and the product they produce

– the chassis with engine and transmissions

– includes the primary technologies that affect emissions and fuel consumption. They also constitute a much more limited group of manufacturers for purposes of developing a regulatory program. In contrast, a focus on the body manufacturers would be much less practical, since they represent a much more diverse set of manufacturers, and the part of the vehicle that they add has a very

limited impact on opportunities to reduce GHG emissions and fuel consumption (given the limited role that aerodyn amics play s in the t yp es of lower spee d operation ty picall y found with vocational trucks.) Therefore, the proposed standards in this vocational truck category would apply

to the chassis manufacturers of all heavy

- dut y vehicles not otherwise covered b y the HD pickup and van standards or Class 7 and 8 combination tractor standards discussed above. The agencies request comment on our proposed focus on chassis manufacturers. As discussed above, EPA and NHTS A have concluded that reductions in GHG emissions and fuel consumption require addressing b oth the vehicle and the engine. As discussed above for Class 7 and 8 combination tractors, the agencies are each proposing

28 Again, we note that NHTSA’s proposed fuel consumption standards would not apply to non

- commercial vehicles like motor homes.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

31 of 54 1 two sets of standards for Class 2b

- 8 vocational trucks. For vehicle

- related emissions, the agencies are proposing standards for cha ssis manufacturers: EPA CO 2 (g/ton

- mile) standards and NHTSA fuel consumption (gal/1000 ton

- mile) standards). Also as in the case of Class 7 and 8 tractors, we propose to use the [TEST] vehicle simulation model to determine compliance with the vocational truck standards. The primary manufacturer

generated input into the proposed compliance model for this category of trucks would be a measure of tire rolling resistance, as discussed further below, because tire improvements are the primary means of vehicle improvement available at this time.. The model would also assume the use of a ty pical representative engine in the simulation, resulting in an overall value for CO 2 emissions and one for fuel consumption. As is the case for combination tractors, the manufacturers of the engines intended for vocational trucks would be subject to separate engine

- based standards. (i ) Proposed Standards for Class 2b

- 8 Vocational Trucks Based on our analy sis and research, the agencies believe that the primary opportunity for redu ctions in vocational truck GHG emissions and fuel consumption will be through improved engine technologies and improved tire rolling resistance. For engines, as proposed for combination tractors, EPA and NHTSA are proposing separate standards for the manu facturers of engines used in Class 2b

- 8 vocational trucks. EPA ’ s proposed engine

- based CO 2 standards and NHTSA ’ s proposed engine

- based fuel consumption standards would vary based on the expected weight class and usage of the truck into which the engine wo uld be installed. The agencies propose to use the groupings EPA currentl y uses for other heav y - duty engine standards

-- light heav y - dut y, medium heav y - dut y, and heav y heav y - dut y, as discussed in Section II below. Tire rolling resistance is closely related to the weight of the vehicle. Therefore, we propose that the vehicle

- based standards for these trucks vary according to one key attribute, GVWR. For this initial HD rulemaking, we propose that these standards be based on the same groupings of truck weight classes used for the engine standards

-- light heav y - dut y, medium heavy

- dut y, and heav y heavy

- dut y. These groupings are appropriate for the proposed vehicle

- based standards because they parallel the general divisions among key

engine characteristics, a s discussed in Section II. The agencies intend to monitor the development of and production feasibility of new vehicle

- related GHG and fuel consumption reduction improving technologies and consider including these technologies in future rulemakings. As di scussed below, we are including provisions to account for and credit the use of h ybrid technology as a technology

that can reduce emissions and fuel consumption. Hy brid technology

can currentl y be a cost

- effective technology in certain specific vocational applications, and the agencies want to recognize and promote the use of this technology . We also are proposing a mechanism whereb y credits can be generated b y use of other technologies not included in the compliance model. (See sections I .E and IV below .) Table I
- 3 presents EPA ’ s proposed CO 2 standards and NHTSA ’ s proposed fuel consumption standards for chassis manufacturers of Class 2b through Class 8 vocational trucks for the 2017 model year for illustrative purposes.32 of 54 1 Table I - 3 : Proposed 2017 Class 2b - 8 Vocational Truck EPA CO 2 Standards and NHTSA Fuel Consumption Standards EPA CO 2 (gram/ton

- mile) Standard Effective 2017 Model Year

Li ght Heav y Class 3

- 5 Medium Heav y

Class 6

- 7 Heav y Heav y

Class 8 CO 2 Emissions 404 240 100 NHTSA Fuel Consumption (gallon per 1000 ton

- mile) Standard Effective 2017 Model Year Li ght Heav y

Class 3

- 5 Medium Heav y

Class 6

- 7 Heav y Heav y

Class 8 Fuel Consumption 39.7 23.6 9.8 At this time, NHTSA and EPA are not prepared to propose alternative standards based on a whole

- vehicle chassis test for vocational trucks in this initial heavy

- duty rulemaking. As discussed above for combination tractors, the primary reason is the very small number of chassis

- test facilities that currently exist. Thus, the agencies are proposing onl y the compliance

- model based standards and engine standards discussed above, and seek comment on the appropriateness of chassis

- test
- based standards for the vocational truck subcat egory . For vocational trucks using h ybrid technology, the agencies are proposing two specialized approaches to allow manufacturers to gain credit for the emissions and fuel consumption reductions associated with h ybrid technology. Hybrid applications in vocational trucks use the secondary hy brid power source as a power take

- off (PTO) to operate secondary

equipment such as a utility bucket or dump bed that would otherwise require the use of the truck ’ s engine. One option to account for the reductions ass ociated with vocational trucks using h ybrid technology would compare vehicle

- based chassis tests with and without the hy brid technology . The other option would allow a manufacturer to simulate the operation of the h yb rid sy stem in an engine

- based test. T he options are further discussed in section IV. T he proposed program also provides for opportunities to generate credits for technologies not measured by the [TEST] model, again described more fully in s ection IV
. As mentioned above for Class 7 and 8 combi nation trucks, EPA believes that N 2 O and CH 4 emissions are technologically related solely to the engine, fuel, and emissions aftertreatment s ys tems, and the agency is not aware of any

influence of vehicle

- based technologies on these emissions. Therefore, for Class 2b

- 8 vocational trucks, EPA is not proposing separate vehicle

- based standards for these GHGs, but is proposing engine

based N 2 O and CH 4 standards for manufacturers of the engines to be used in vocational trucks. EPA expects that manufacturers of current engine technologies would be able to comply with the proposed “cap” standards with little or no technological improvements; the value of the standards would be in that they would prevent significant increases in these emissions as alternative technologies are developed and introduced in the future. Compliance with the proposed EPA engine

- based CO 2 standards and the proposedDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

33 of 54 1 NHTSA fuel consumption standards, as well as the proposed EPA N 2 O and CH 4 standards, would be determined using the appropriat e EPA engine test procedure, as discussed in Section II below. As with the other regulatory categories of heavy

- duty vehicles, EPA and NHTSA are proposing standards that would apply to Class 2b

- 8 vocational trucks at the time of production, and EPA is proposing standards for a specified period of time in use. All of the proposed standards for these trucks, as well as details about the proposed provisions for certification and implementation of these standards, are discussed in more detail later in this notice and in the Draft RIA. EPA is not proposing A/C refrigerant leakage standards for Class 2b

- 8 vocational trucks at this time, primarily because of the number of entities involved in their manufacture and thus the potential for different entities besi des the chassis manufacturer to be involved in the A/C sy stem production and installation. EPA requests comment on how A/C standards might practicall y be applied to manufacturers of vocational trucks. (d ) What Manufacturers Are Not Covered by the Proposed Standards? EPA and NHTSA are proposing to temporaril y defer the proposed greenhouse gas emissions and fuel consumption standards for an y manufacturers of heav y - duty engines, manufacturers of combination tractors, and manufacturers of vocational trucks that meet the “small business” size criteria set b y the Small Business Administration (SBA). We are not aware of an y manufacturers of HD pickups and vans that meet these criteria. For each of the other subcategories and for engines, we have identified a smal l number of manufacturers that would appear to meet the SBA criteria. The production of these companies is small, and we believe that deferring the standards for these companies at this time would have a negligible impact on the GHG emission reductions an d fuel consumption reductions that the program would otherwise achieve. We request comment on our assumption that the impact of these exemptions for small businesses will be small and further whether it will be possible to circumvent the regulations by cr eating new small businesses to displace existing manufacturers. We discuss the specific deferral provisions in more detail in Section II. The agencies will consider appropriate GHG emissions and fuel consumption standards for these entities as part of a f uture regulatory

action. 

### D. Summary of Costs and Benefits of the HD National Program This section summarizes the projected costs and benefits of the proposed NHTSA fuel consumption and EPA GHG emissions standards. These projections help to inform the agenci es’ choices among the alternatives considered and provide further confirmation that the proposed standards are an appropriate choice within the spectrum of choices allowable under the agencies’ respective statutory criteria. NHTSA and EPA have used common projected cost s and benefits as the bases for our respective standards.34 of 54 1 The agencies have anal yzed in detail the projected costs and benefits of the proposed GHG and fuel consumption standards. Table I
- 4 shows estimated lifetime discounted cost s , benefits and net benefits for all heavy

- dut y vehicles projected to be sold in model y ears 2014

- 2018. Table I - 4 : Estimated Lifetime Discounted Costs, Benefits, and Net Benefits for 2014 - 201 8 Model

Year HD Vehicles assuming the $22/ton SCC Value a,b (2008 dollars) 3% Discount Rate $billions Costs $ 8.2 Benefits $4 9 Net Benefits $ 41 7% Discount Rate Costs $ 8.2 Benefits $3 4 Net Benefits $ 26 Note s: a Although the agencies estimated the benefits associated with four different values of a one ton CO 2 reduction (SCC: $5, $22, $36, $66), for the purposes of this overvie w presentation of estimated costs and benefits we are showing the benefits associated with the marginal value deemed to be central by the interagency working group on this topic: $22 per ton of CO 2 , in 2008 dollars and 2010 emissions and fuel consumption. As noted in Section VIII.F, SCC increases over time. b Note that net present value of reduced GHG emissions is calculated differently from other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, and 2.5 percent) is used to calculate net present value of SCC for internal consistency. Refer to Section VIII.F for more d etail.

Table I
- 5 shows the estimated lifetime reductions in CO 2 emissions and fuel consumption for all heavy

- dut y vehicles sold in the model years 2014

- 2018. The values in Table I
- 5 are projected lifeti me totals for each model year and are not discounted. The two agencies’ standards together comprise the HD National Program, and the agencies’ respective GHG emissions and fuel consumption standards, jointly , are the source of the benefits and costs of th e HD National Program. Table I - 5 : Estimated Lifetime Reductions in Fuel Consumption and CO 2 Em issions f or 2014 - 2018 Model Year HD Vehicles 2014 2015 2016 2017 2018 Total All Heav y Duty Vehicles Fuel (bil lion gallons) 3.0 3.1 3.5 5.2 5.7 20.4

Fuel (billion barrels) 0.07 0.07 0.08 0.12 0.14 0.5 CO 2 (mmt) a 37.2 38.7 42.7 63.2 70.0 252

a Includes upstream and downstream CO 2 reductions. Ta ble I
- 6 shows the estimated lifetime di scounted benefits for all heav y - duty vehicles sold in model y ears 2014

- 2018. Although the agencies estimated the benefits associated with four different values of a one ton CO 2 reduction ($5, $22, $36, $66), forDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

35 of 54 1 the purposes of this overview presentation of estimated benefits the agencies are showing the benefits associated with one of these marginal values, $22 per ton of CO 2 , in 2008 dollars and 2010 emissions. Ta ble I
- 6 presents benefits based on the $22 value. Section VIII.F presents the four marginal values used to estimate monetized benefits of CO 2 reductions and Section VIII presents the program benefits using each of the four marginal values, which represent only a partial accounting of total benefits due to omitted climate change impacts and other factors that are not readily monetized. The values in the table are discounted values for each model ye ar of vehicles throughout their projected lifetimes. The anal ys is include s other economic impacts such as fuel savings, ene rgy securit y , and other externalities such as reduced accidents, congestion and noise. However, the anal ys is supporting the proposal omits other impacts such as benefits related to non

- GHG emission reductions. The lifetime discounted benefits are shown f or one of four different social cost of carbon (SCC) values considered b y EPA and NHTSA. The values in Ta

ble I
- 6 do not include costs associated with new technology required to meet the GHG and fuel consumption standard s .

Ta ble I - 6 : Estimated Lifetime Discounted Benefits for 2014 - 2018 Model Year HD Vehicles Assuming the $22/ton SCC Value a,b (billions of 2008 dollars) Discount Rate Model Year

2014 2015 2016 2017 2018 Total 3% $ 7. 2 $ 7. 4 $ 8.2 $ 12.3 $ 13.6 $4 9 7% $5. 4 $5. 5 $5. 9 $ 8.5 $ 9.0 $3 4 Notes: a The analysis includes impacts such as the economic value of reduced fuel consumption and accompanying climate

- related economic benefits from reducing emissions of CO 2 (but not other G HGs), and reductions in energy security externalities caused by U.S. petroleum consumption and imports. The analysis also includes economic impacts stemming from additional heavy

- duty vehicle use, such as the economic damages caused by accidents, congesti on and noise. b Note that net present value of reduced CO 2 emissions is calculated differently from other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, and 2.5 percent) is used to calculate net present value of SCC for internal consistency. Refer to Section VIII.F for more detail. c

Table I
- 7 shows the agencies’ estimated lifetime fuel savings, lifetime CO 2 emission reductions, and the monetized net present values of those fuel savings and CO 2 emission reductions. The gallons of fuel and CO 2 emission reductions are projected lifetime values for all vehicles sold in the model years 2014

- 2018. The estimated fuel savings in billions of barrels and the GHG reductions in million metric tons of CO 2 shown in Table I
- 7 are totals for the five model ye ars throughout their projected lifetime and are not discounted. The monetized values shown in Table I
- 7 are the summed val ues of the discounted monetized

- fuel consumption and monetized

- CO 2 reductions for the five36 of 54 1

model years 2014

- 2018 throughout their lifetimes. The monetized values in Table I
- 7 reflect both a 3 percent and a 7 percent discount rate as noted.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

37 of 54 1 Table I - 7 : Estimated Lifetime Reductions and Associated Discounted Monetized Benefits for 2014 -

2018 Model Year HD Vehicles (m onetized values in 2008 dollars) Amount $ value (billions)
Fuel Cons umption Reductions 0.5 billion barrels $42 , 3% discount rate $28 , 7% discount rate CO 2 Emission Reductions a V alued assuming $22/ton CO 2 in 2010) 252 MMT CO 2 $4.3 b
Notes: a Includes both upstream and downstream CO 2 e emission reductions. b Note that net present value of reduced CO 2 emissions is calculated differently form other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, and 2.5 percent) is used to calculate net present value of SCC for internal consistency. Refer to Section VIII.F for more detail. Table I
- 8 shows the estimated incremental and total technology outlay s for all heav y - dut y vehicles for each of the model ye ars 2014

- 2018. The technology outla ys shown in Table I
- 8 are for the industry as a whole and do not account for fuel saving s associated with the program. Table I - 8 : Estimated Incremental Technology Outlays for 2014 - 201 8 Model Year HD Vehicles (billions of 200 8 dollars) 2014 2015 2016 2017 2018 Total All Heav y Duty Vehicles $ 1.4 $ 1.4 $ 1.6 $ 1.7 $2.1 $ 8.2
Table I
- 9 shows EPA’s estimated incremental cost increase of the average new heav y - dut y ve hicle for each model year 2014

- 201 8

. The values shown are incremental to a baseline vehicle and are not cumulative. Table I - 9 : Estimated Incremental Increase in Average Cost for 2014 - 2018 Model Year HD Vehi cles (200 8 dollars per unit) 2014 2015 2016 2017 2018 Combination Tractors $6,828 $6,638 $6,358 $6,668 $6,403 HD Pickups &Vans $ 233 $ 302 $ 587 $ 887 $1,458 Vocational Trucks $362 $356 $38 9 $ 382 $ 349



### E. Program Flexibilities For each of the heav y - duty veh icle subcategories and heavy

- dut y engines for which we are proposing respective standards, EPA and NHTSA are also proposing38 of 54 1

provisions designed to give manufacturers a degree of flexibility in compl ying with the standards. These proposed provisions have e nabled the agencies to consider overall standards that are more stringent and that would become effective sooner than we could consider with a more rigid program, one in which all of a manufacturer’s similar vehicles or engines would be required to achieve the same emissions or fuel consumption levels, and at the same time. 29 We believe that incorporating carefully structured regulatory flexibility provisions into the overall program is an important way to achieve each agency ’s goals for the program. NHT SA’s and EPA’s proposed flexibility provisions are essentially identical to each other in structure and function. For combination tractor and vocational truck categories and for heav y - duty engines, we are proposing four primary t ypes of flexibility

– aver aging, banking, and trading (ABT) provisions, earl y credits, advanced technology credits, and innovative technology credit provisions. In addition, we are proposing special provisions to apply to vocational trucks that incorporate h ybrid powertrain techno logies. The proposed ABT provisions are patterned on existing EPA ABT programs and would allow a vehicle manufacturer to reduce CO 2 emission and fuel consumption levels further than the level of the standard for one or more vehicles to generate ABT credit s. The manufacturer could then use those credits to offset higher emission or fuel consumption levels in other similar vehicles, “bank” the credits for later use, or “trade” the credits to another manufacturer. We are proposing similar ABT provisions for manufacturers of heav y - dut y engines. For HD pickups and vans, we are proposing a fleet averaging s ys tem very similar to the light

- dut y GHG and CAFE fleet averaging s ys tem. To best ensure that the overall emission and fuel consumption reductions of the pr ogram would be achieved and to minimize any effect on the ability

of the market to respond to consumer needs, the agencies propose to restrict the use of averaging to limited sets of vehicles and engines expected to have similar emission or fuel consumptio n characteristics. For example, averaging would be allowed among Class 7 low

- roof day

cab vehicles, but not among those vehicles and Class 8 sleeper cabs or vocational vehicles. Also, we propose that credits generated b y vehicles not be applicable to eng ine compliance, and vice versa. For HD pickups and vans, we propose that fleet averaging be allowed with minimum restriction within the HD pickup and van subcategory

. In addition to ABT, the agencies are proposing that a manufacturer that reduces CO 2 emis sions and fuel consumption below required levels prior to the beginning of the program be allowed to generate the same number of credits (“early credits”) that they would after the program begins.

29 NHTSA notes that it has greater flexibility in the HD program to include consideration of credits and other flexibilities in determining appropriate and feasible levels of stringency than it does in the light

- duty CAFE program. Cf. 49 U.S.C. 32902(h), which applies to light

- duty CAFE but not heavy

- duty fuel efficiency under 32902(k).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

39 of 54 1 The agencies are also proposing that vocational truck manufacturers that show improvements in CO 2 emissions and fuel consumptions and incorporate certain technologies (including hy brid powertrains, Rankine engines, or electric vehicles) be eligible for special “advanced technology” credits. Unlike other credits in this proposal, the advanced technology

credits could be applied to any heavy dut y vehicle or engine, and not be limited to the vehicle category generating the credit. The technologies eligible for advanced technology credits above lend themselves to straightforward methodologies for quantifying the emission or fuel consumption reductions. For other technologies which can reduce CO 2 and fuel consumption, but for which there do not yet exist established methods for quantifying reductions, the agencies still seek to encourage the development of such innovative technologies, and are therefore proposing special “innovative technology” credits. These innovative technology

credits would apply

to technologies that are shown to produce emission and fuel cons umption reductions that are not adequately recognized on the current test procedures and that are not y et in widespread use. Manufacturers would need to quantify the reductions in fuel consumption and CO 2 emissions that the technology could achieve, above and beyond those achieved on the existing test procedures. As with ABT, we propose that the use of innovative technology credits be only

allowed among vehicles and engines expected to have similar emissions and fuel consumption characteristics ( e.g ., within each of the nine Class 7 & 8 combination tractor classifications, or within each of the three Class 2b

- 8 vocational truck classifications). A detailed discussion of each agency ’s ABT and innovative technology provisions for each regulatory category o f heav y - duty

vehicles and engines is found in Section IV below. 

### F. EPA and NHTSA Statutory Authorities

(1) EPA Authority Title II of the Clean Air Act (CAA) provides for comprehensive regulation of mobile sources, authorizing EPA to regulate emissions of air pollutants from all mobile source categories. When acting under Title II of the CAA, EPA considers such issues as technology

effectiveness, its cost (both per vehicle, per manufacturer, and per consumer), the lead time necessary

to implement the technology , and based on this the feasibility and practicabilit y of potential standards; the impacts of potential standards on emissions reductions of both GHGs and non

- GHGs; the impacts of standards on oil conservation and energy

securit y; the impacts of standards on fuel savings b y customers ; the impacts of standards on the truck industry ; other energy impacts; as well as other relevant factors such as impacts on safety

. This proposal implements a specific provision from Title II, section 202(a). 30 Section 202(a)(1) of the CAA states that “ the Administrator shall by regulation prescribe

30 42 U.S.C. 7521 (a)40 of 54 1

(and from time to time revise)...standards applicable to the emission of any air pollutant from an y class or classes of new motor vehicles ..., which in his judgment cause, or contribute t o, air pollution which may reasonabl y be anticipated to endanger public health or welfare. ” With EPA ’ s December 2009 final findings for greenhouse gases , section 202(a) authorizes EPA to issue standards applicable to emissions of those pollutants from new motor vehicles. Any standards under CAA section 202(a)(1) “ shall be applicable to such vehicles ... for their useful life. ” Emission standards set by the EPA under CAA section 202(a)(1) are technology

- based, as the levels chosen must be premised on a findi ng of technological feasibility . Thus, standards promulgated under CAA section 202(a) are to take effect onl y “ after providing such period as the Administrator finds necessary to permit the development and application of the requisite technology , giving a ppropriate consideration to the cost of compliance within such period ” (section 202(a)(2); see also NRDC v. EPA , 655 F. 2d 318, 322 (D.C. Cir. 1981)). EPA is afforded considerable discretion under section 202(a) when assessing issues of technical feasibil ity and availability

of lead time to implement new technology . Such determinations are “ subject to the restraints of reasonableness ” , which “ does not open the door to ‘ crys tal ball ’ inquiry

. ” NRDC , 655 F. 2d at 328, quoting International Harvester Co. v. Ruckelshaus , 478 F. 2d 615, 629 (D.C. Cir. 1973). However, “ EPA is not obliged to provide detailed solutions to every

engineering problem posed in the perfection of the trap

- oxidizer. In the absence of theoretical objections to the technology , the agenc y need only identify the major steps necessary

for development of the device, and give plausible reasons for its belief that the industry

will be able to solve those problems in the time remaining. The EPA is not required to rebut all speculation that uns pecified factors may hinder ‘ real world ’ emission control. ” NRDC , 655 F. 2d at 333

- 34. In developing such technology

based standards, EPA has the discretion to consider different standards for appropriate groupings of vehicles ( “ class or classes of new m otor vehicles ” ), or a single standard for a larger grouping of motor vehicles (NRDC , 655 F. 2d at 338). Although standards under CAA section 202(a)(1) are technology

- based, they are not based exclusively

on technological capability . EPA has the discretion to consider and weigh various factors along with technological feasibility , such as the cost of compliance (see section 202(a) (2)), lead time necessary for compliance (section 202(a)(2)), safet y (see NRDC , 655 F. 2d at 336 n. 31) and other impacts on con sumers, and energy impacts associated with use of the technology . See George E. Warren Corp. v. EPA , 159 F.3d 616, 623

- 624 (D.C. Cir. 1998) (ordinaril y permissible for EPA to consider factors not specificall y enumerated in the Act). See also Entergy Corp . v. Riverkeeper, Inc. , 129 S.Ct. 1498, 1508

- 09 (2009) (congressional silence did not bar EPA from employing cost

benefit anal ys is under Clean Water Act absent some other clear indication that such anal ys is was prohibited; rather, silence indicated discret ion to use or not use such an approach as the agency

deems appropriate). In addition, EPA has clear authority to set standards under CAA section 202(a) that are technology

forcing when EPA considers that to be appropriate, but is not required to do so (as compared to standards set under provisions such as section 202(a)(3) andDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

41 of 54 1 section 213(a)(3)). EPA has interpreted a similar statutory provision, CAA section 231, as follows: While the statutory

language of section 231 is not identical to other provisions in title II of the CAA that direct EPA to establish technology

- based standards for various ty pes of engines, EPA interprets its authorit y under section 231 to be somewhat similar to those provisions that require us to identify a reasonable balance of speci fied emissions reduction, cost, safet y, noise, and other factors. See, e.g., Husqvarna AB v. EPA, 254 F.3d 195 (DC Cir. 2001) (upholding EPA ’ s promulgation of technology

- based standards for small non

- road engines under section 213(a)(3) of the CAA). Howeve r, EPA is not compelled under section 231 to obtain the ‘‘ greatest degree of emission reduction achievable ’’ as per sections 213 and 202 of the CAA, and so EPA does not interpret the Act as requiring the agency to give subordinate status to factors such as cost, safet y, and noise in determining what standards are reasonable for aircraft engines. Rather, EPA has greater flexibility

under section 231 in determining what standard is most reasonable for aircraft engines, and is not required to achieve a ‘‘ techn ology forcing ’’ result. 31 This interpretation was upheld as reasonable in NACAA v. EPA , 489 F.3d 1221, 1230 (D.C. Cir. 2007). CAA section 202(a) does not specify the degree of weight to apply to each factor, and EPA accordingl y has discretion in choosing an appropriate balance among factors. See Sierra Club v. EPA , 325 F.3d 374, 378 (D.C. Cir. 2003) (even where a provision is technology

- forcing, the provision “ does not resolve how the Administrator should weigh all [the statutory] factors in the process o f finding the
‘ greatest emission reduction achievable ’ ” ). Also see Husqvarna AB v. EPA , 254 F. 3d 195, 200 (D.C. Cir. 2001) (great discretion to balance statutory factors in considering level of technology

- based standard, and statutory requirement “ to [g ive appropriate] consideration to the cost of applying ... technology” does not mandate a specific method of cost anal ys is); see also Hercules Inc. v. EPA , 598 F. 2d 91, 106 (D.C. Cir. 1978) ( “ In reviewing a numerical standard the agencies must ask whether the agency ’ s numbers are within a zone of reasonableness, not whether its numbers are precisely right ” ); Permian Basin Area Rate Cases , 390 U.S. 747, 797 (1968) (same); Federal Power Commission v. Conway Corp. , 426 U.S. 271, 278 (1976) (same); Exxon Mobil G as Marketing Co. v. FERC , 297 F. 3d 1071, 1084 (D.C. Cir. 2002) (same). (a ) EPA Testing Authority Under section 203 of the CAA, sales of vehicles are prohibited unless the vehicle is covered b y a certificate of conformity . EPA issues certificates of conformity pursuant to section 206 of the Act, based on (necessarily) pre

- sale testing conducted either by EPA or by the manufacturer. The Heav y Dut y Federal Test Procedure (FTP) and the Supplemental Engine Test (SET) cycle are used for this purpose. Compliance w ith standards is required not only at certification but throughout a vehicle ’ s useful life, so that testing requirements may continue post

- certification. Useful life standards may

31 70 FR 69664, 69676, November 17, 2005.42 of 54 1

apply an adjustment factor to account for vehicle emission control deterior ation or variability

in use (section 206(a)). EPA established the FTP for emissions measurement in the earl y 1970s. In 1976, in response to the Energy Policy and Conservation Act (EPCA) statute, EPA extended the use of the FTP to fuel economy measurement. 32 EPA can determine fuel efficiency of a vehicle by

measuring the amount of CO 2 and all other carbon compounds (e.g. total hydrocarbons (THC) and carbon monoxide (CO)), and then, by mass balance, calculating the amount of fuel consumed. (b ) EPA Enforcement Authority Section 207 of the CAA grants EPA broad authority to require manufacturers to remed y vehicles if EPA determines there are a substantial number of noncomplying vehicles. In addition, section 205 of the CAA authorizes EPA to assess penalties of up to $37,500 per vehicle for violations of various prohibited acts specified in the CAA. In determining the appropriate penalty, EPA must consider a variety of factors such as the gravity of the violation, the economic impact of the violation, the violator ’ s history of compliance, and “ such other matters as justice may require. ” (2) NHTSA Authority 49 U.S.C. 32902(k)(2), established by Congress in EI SA, authorizes NHTSA to create a fuel efficiency

improvement program for “ commercial medium

- and heav y - dut y on - highway

vehicles and work trucks ” 33 by rulemaking, to include standards, testing, and enforcement. Congress directed that the standards, test methods, measurement metrics, and compliance and enforcement protocols be “ appropriate, cost

- effective, and technolog icall y feasible ” for the vehicles to be regulated, while achieving the “ maximum feasible improvement ” in fuel efficiency . Since this is the first rulemaking that NHTSA has conducted under 32902(k)(2), this is the first opportunity the agency

has had to interpret these factors in the context of setting standards, choosing metrics, and determining test methods and compliance/enforcement sy stems. Congress also gave NHTSA the authorit y to set separate standards for different classes of these vehicles, but required that all standards adopted provide not less than four full model years of regulatory

lead

- time and three full model years of regulatory stability

. (a ) NHTSA Testing Authority 49 U.S.C. 32902(k)(2) states that NHTSA must adopt and implement appropriate, c ost
- effective, and technologicall y feasible test methods and measurement metrics as part of the fuel efficiency

improvement program.

32 See 49 U.S.C. 32904(c). 33 “Co mmercial medium

- and heavy

- duty on - highway vehicles” are defined at 49 U.S.C. § 32901(a)(7), and “work trucks” ar e defined at (a)(19).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

43 of 54 1 (b ) NHTSA Enforcement Authority 49 U.S.C. 32902(k)(2) also states that NHTSA must adopt and implement appropriate, cost

- effec tive, and technologically feasible compliance and enforcement protocols for the fuel efficiency improvement program. 

### G. Future HD GHG and Fuel Consumption Rulemakings Today ’s proposal represents a first regulatory step by NHTSA and EPA to address the multi

- faceted challenges of reducing fuel use and greenhouse gas emissions from these vehicles. By

focusing on existing technologies and well

- developed regulatory tools, the agencies are able to propose rules that we believe will produce real and important redu ctions in GHG emissions and fuel consumption within only a few ye ars. Within the context of this regulatory timeframe, our proposal is very aggressive

- with limited leadtime compared to historic heav y - dut y regulations

- but pragmatic in the context of te chnologies that are available. While we are now onl y proposing this first step, it is worthwhile to consider how future regulations that may follow this step may

be constructed. Technologies such as hy brid drivetrains, advanced bottoming cycle engines, and full electric vehicles are promoted in this first step through incentive concepts as discussed in section IV, but we believe that these advanced technologies would not be necessary to meet the proposed standards, which are premised on the use of existin g technologies. When we begin our future work to develop a possible next set of regulatory standards, the agencies expect these advanced technologies to be an important part of the regulatory program and will consider them in setting the stringency of any standards beyond the 2018 model y ear. We will not only

consider the progress of technology in our future regulatory efforts, but the agencies are also committed to fully considering a range of regulatory approaches. To more completely capture the complex interactions of the total vehicle and the potential to reduce fuel consumption and GHG emissions through the optimization of those interactions may require a more sophisticated approach to vehicle testing than we are proposing today for the largest heav y - dut y vehicles. In future regulations, the agencies expect to fully evaluate the potential to expand the use of vehicle compliance models to reflect engine and drivetrain performance. Similarly , we intend to consider the potential for complete vehicle tes ting using a chassis dy namometer, not only as a means for compliance, but also as a complementary tool for the development of more complex vehicle modeling approaches. In considering these more comprehensive regulatory approaches, the agencies will also r eevaluate whether separate regulation of trucks and engines remains necessary. In addition to technology and test procedures, vehicle and engine drive cycles are an important part of the overall approach to evaluating and improving vehicle performance. EP A working through the WP.29 Global Technical Regulation (GTR) process has activel y participated in the development of a new world harmonized Heav y Duty Certification procedure (WHDC) for heavy

- duty engines. EPA is committed to bringing forward these new p rocedures as part of our overall comprehensive approach for44 of 54 1

controlling criteria and GHG emissions. However, we believe the important issues and technical work related to setting new criteria emissions standards appropriate for the WHDC are significant an d beyond the scope of this rulemaking. Therefore, the agencies are not proposing to adopt these test procedures in today ’s proposal, but we are ready to work with interested stakeholders to adopt these procedures in a future action. As with today ’s propos al, our future efforts will be based on collaborative outreach with the stakeholder community and will be focused on a program that delivers on our energy

securit y and environmental goals without restricting the industry’s ability to produce a very

diverse range of vehicles serving a wide range of needs. 

## II. Proposed GHG

and Fuel Consumption Standards for Heavy Duty Engines and Ve hicles This section describes the standards and implementation dates that the agencies are proposing for the three categories of heav y duty vehicles. The agencies have performed a technology

anal ys is to determine the level of standards that we believe would be appropriate, cost

- effective, and feasible during the rulemaking timeframe. This anal ys is, described in Section III and in more detail in Draft RIA Chapter 2, considered:

 the level of technology that is incorporated in current new trucks,  the available data on corresponding CO 2 emissions and fuel consumption for these vehicles,  technologies that would reduce CO 2 emissions and fu el consumption and that are judged to be feasible and appropriate for these vehicles through 2018 model y ear,  the effectiveness and cost of these technologies,  projections of future U.S. sales for trucks, and  forecasts of manufacturers’ product redesign schedules. 

### A. What vehicles would be affected? EPA and NHTSA are proposing standards for heavy dut y engines and also for what we refer to generally as “heavy

duty trucks.” As noted in Section I , for purposes of this preamble, the term “heav y - dut y: or “HD” is used to apply to all highway

vehicles and engines that are not regulated b y the light

- duty vehicle, light

- dut y truck and medium duty passenger vehicle greenhouse gas and CAFE standards issued for MYs 2012

- 2016. Thus, in this notice, unless specified o therwise, the heav y - dut y category incorporates all vehicles rated at a gross vehicle weight greater than 8,500 pounds, and the engines that power these vehicles, except for MDPVs. The CAA defines heav y - dut y vehicles as trucks, buses or other motor vehicl es with a gross vehicle weight rating exceeding 6000 pounds. CAA section 202(b)(3). In the context of the CAA, the term HD as used in these proposed rules thus refers to a subset of these vehicles and engines. EISA Section 103(a)(3) defines a ‘commercial medium

- and heavy

- dut y on - highway vehicle’ as an on

-Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

45 of 54 1 highway vehicle with a gross vehicle weight rating (GVWR) of 10,000 pounds or more. 34 EI SA Section 103(a)(6) defines a ‘work truck’ as a vehicle that is rated at between 8,500 and 10,000 pounds gross veh icle weight and is not a medium duty passenger vehicle. 35 Therefore, the term "heavy dut y trucks" in this proposal refers to both work trucks and commercial medium and heav y dut y on - highway vehicles as defined by

EISA. Heav y duty engines affected b y the p roposed standards are those that are installed in commercial medium and heav y dut y trucks, except for the engines installed in vehicles certified to a complete vehicle emissions standard based on a chassis test, which would be addressed as a part of those complete vehicles, and except for engines used exclusively for stationary power when the vehicle is parked. The agencies’ scope is the same with the exception of recreational vehicles (or motor homes), as discussed above. EPA is proposing to include recr eational on

- highway

vehicles within their rulemaking, while NHTSA is limiting their scope to commercial trucks which would not include these vehicles. EPA and NHTSA are proposing standards for each of the following categories, which together comprise all h eav y dut y vehicles and all engines used in such vehicles. 36 In order to most appropriately regulate the broad range of heavy dut y vehicles, the agencies are proposing to set separate engine and vehicle standards for the combination tractors and the Class 2b through 8 vocational trucks and the engines installed in them. The engine standards and test procedures for engines installed in the tractors and vocational trucks are discussed within the applicable vehicle sections.

 Class 7 and 8 Combination Tractors  Heav y - Duty

Pickup Trucks and Vans  Class 2b through 8 Vocational Trucks As discussed in Section IX, the agencies are not proposing GHG emission and fuel consumption standards for trailers at this time. In addition, the agencies are proposing to not set st andards at this time for engine, chassis, and vehicle manufacturers which meet the small business definitions. More detailed discussion of each regulatory category is included in the subsequent sections below.

34 Codified at 49 U.S.C. § 32901(a)(7). 35 EISA Section 103(a)(6) is codified at 49 U.S.C. 32901(a)(19). EPA defines medium

- duty passenger vehicles as any complete vehicle between 8,500 and 10,000 pounds GVWR designed primarily for th e transportation of persons which meet the criteria outlined in 40 C.F.R. 86.1803

- 01. The definition specifically excludes any vehicle that (1) has a capacity of more than 12 persons total or, (2) is designed to accommodate more than 9 persons in seating r earward of the driver’s seat or, (3) has a cargo box ( e.g., pick

- up box or bed) of six feet or more in interior length. (See the Tier 2 final rulemaking, 65 FR 6698, February 10, 2000.) 36 Both agencies have authority to develop separate standards for vehic le and engine categories, as appropriate. See CAA section 202 (a) (1) (authority to establish standards for “any class or classes of new mo tor vehicles or engines” and 49 USC 32902 (k) (2) (authority to establish standards for HD vehicles that are “app ropriate, cost

- effective, and technologically feasible” that are designed to achive the “maximum feasible improvement” in fuel efficiency; authority to establish “separate standards for different classes of vehicles under this subsection.” NHTSA interprets 329029k)(2) to include a grant of authority to establish engines standards pursuant to the broader statement of authority to establish standards that achieve the maximum feasible improvement in fuel efficiency.)46 of 54 1



### B. Class 7/8 Combination Tractors EPA is proposi ng CO 2 standards and NHTSA is proposing fuel consumption standards for new Class 7/8 combination tractors. The standards are for the tractor cab, with a separate standard for the engines that are installed in the tractor. Together these standards would a chieve reductions up to 20 percent from tractor cabs. As discussed below, EPA is proposing to adopt the existing useful life definitions for heavy dut y engines for the Class 7/8 tractors. NHTSA is proposing fuel consumption standards for tractors , and en gine standards for heav y dut y engines for Class 7/8 tractors

. The agencies' anal ys es, as discussed briefl y below and in more detail later in this preamble and in the Draft RIA Chapter 2, show that these standards are appropriate and feasible under each ag ency ’s respective statutory authorities. EPA is also proposing standards to control N 2 O, CH 4 , and HFC emissions from Class 7/8 combination tractors. The proposed heavy dut y engine standards for both N 2 O and CH 4 and details of the standard are included i n the discussion in II. E. The proposed air conditioning leakage standards appl yi ng to tractor manufacturers to address HFC emissions are included in Section II. E. The agencies are proposing CO 2 emi ssions and fuel consumption standards for the combination tractors that will focus on reductions that can be achieved through improvements in the tractor (such as aerodyn amics), tires, and other vehicle sy stems. The agencies are also proposing heav y duty engine standards for CO 2 emissions and fuel consumption that would focus on potential technological improvements in fuel combustion and overall engine efficiency

. The agencies have anal yzed the feasibility of achieving the CO 2 and fuel consumption standards, based on projections of what actions manufacturers are expected to take to reduce emissions and fuel consumption. EPA and NHTSA also present the estimated costs and benefits of the standards in Section III. In developing the proposed rules, the age ncies have evaluated the kinds of technologies that could be utilized by engine and tractor manufacturers, as well as the associated costs for the industry and fuel savings for the consumer and the magnitude of the CO 2 and fuel econom y s avings that may be achieved. EPA and NHTSA are proposing attribute

- based standards for the Class 7/8 combination tractors, or, put another way , we are proposing to set different standards for different subcategories of these tractors with the basis for subcategorization bein g particular tractor attributes. Attribute

- based standards in general recognize the variet y of functions performed b y vehicles and engines, which in turn can affect the kind of technology

that is available to control emissions and red uce fuel consumption, or its effectiveness. Attributes that characterize differences in the design of vehicles, as well as differences in how the vehicles will be emplo ye d in

- use, can be key factors in evaluating technological improvements for reducing C O 2 emissions and fuel consumption. Developing an appropriate attribute

- based standard can also avoid interfering with the ability of the market to offer a variet y of products to meet consumer demand. There are several examples of where the agencies hav e utilized an attribute

-Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

47 of 54 1 based standard. In addition to the example of the recent light

- dut y vehicle fuel econom y and GHG rule, in which the standards are based on the attribute of vehicle "footprint," the existing non

- GHG heav y duty engine criteria pollut ant emission standards for man y ye ars have been based on a vehicle weight attribute (Light Heav y, Medium Heavy, Heav y Heav y) with different useful life periods, which is the same approach proposed for the engine GHG and fuel consumption standards discussed below. Heav y dut y combination trucks are built to move freight. The abilit y of a truck to meet a customer's freight transportation requirements depends on three major characteristics of the tractor: the gross vehicle weight rating (which along with gross combined weight rating (GCWR) establishes the maximum carrying capacity of the tractor and trailer), cab t ype (sleeper cabs provide overnight accommodations for drivers), and the tractor roof height (to mate tractors to trailers for the most fuel

- effi cient configuration). Each of these attributes impacts the baseline fuel consumption and GHG emissions, as well as the effectiveness of possible technologies, like aerodynamics, and is discussed in more detail below. The first tractor characteristic to consider is payload which is determined by a tractor’s gross vehicle weight rating (GVWR) and gross combined weight rating (GCWR) relative to the weight of the tractor, trailer, fuel, driver, and equipment. Class 7 trucks, which have a GVWR of 26,000

- 33,0 00 pounds and a t ypical GCWR of 65,000 pounds, have a lesser payload capacity than Class 8 trucks. Class 8 trucks have a GVWR of greater than 33,000 pounds and a t ypical 80,000 pound GCWR. Consistent with the recommendation in the National Academy of Sci ences March 2010 Report to NHTSA, 37 the agencies are proposing a load specific fuel consumption metric (g/ton

- mile and gal/1000 ton

- mile) where the “ton” represents the amount of payload. Generall y, higher payload capacit y trucks have better specific fuel consumption and GHG emissions than lower payload capacity

trucks. Therefore, since the amount of payload that a Class 7 truck can carry

is less than the Class 8 truck’s payload capacit y, the baseline fuel consumption and GHG emissions performance per ton

- mile differs between the categories. Itis consequently reasonable to distinguish between these two vehicle categories, so that the agencies are proposing separate standards for Class 7 and Class 8 tractors. The agencies are not proposing to set a singl e standard for both Class 7 and 8 tractors based on the payload carrying capabilities and assumed t ypical payload levels of Class 8 tractors alone, as that would quite likely have the perverse impact of increasing fuel consumption and greenhouse gas emissi ons. Such a single standard would penalize Class 7 vehicles in favor of Class 8 vehicles, however the greater capabilities of Class 8 tractors and their related greater efficiency when measured on a per ton

- mile basis is only relevant in the context of op erations where that greater capacity is needed. For many applications such as regional distribution, the trailer payloads dictated by the goods being carried are lower than the average Class 8 tractor payload. In those situations, Class 7

37 March 2010 NAS Report, Recommendation 2

- 1.48 of 54 1

tractors are mo re efficient than Class 8 tractors when measured on a per ton

- mile of actual freight carried. This is because the extra capabilities of Class 8 tractors add additional weight to vehicle that is only beneficial in the context of its higher capabilities. T he existing market already selects for vehicle performance based on the projected payloads. By

setting separate standards the agencies do not advantage or disadvantage class 7 or 8 tractors relative to one another and continue to allow trucking fleets to purchase the vehicle most appropriate to their business practices. The second characteristic that affects fuel consumption and GHG emissions is the relationship between the tractor cab roof height and the ty pe of trailer used to carry the freight. The pri mary

trailer ty pes are box, flat bed, tanker, bulk carrier, chassis, and low boy s. Tractor manufacturers sell tractors in three roof heights

– low, mid, and high. The manufacturers do this to obtain the best aerodyn amic performance of a tractor

- trailer c ombination, resulting in reductions of GHG emissions and fuel consumption, because it allows the frontal area of the tractor to be similar in size to the frontal area of the trailer. In other words, high roof tractors are designed to be paired with a (rel atively tall) box trailer while a low roof tractor is designed to pull a (relatively low) flat bed trailer. The baseline performance of a high roof, mid roof, and low roof tractor differs due to the variation in frontal area which determines the aerody nam ic drag. For example, the frontal area of a low roof tractor is approximately 6 square meters, while a high roof tractor has a frontal area of approximately 9.8 square meters. Therefore, as explained below, the agencies are proposing that the roof height of the tractor determine the trailer ty pe required to be used to demonstrate compliance of a truck with the fuel consumption and CO 2 emissions standards. As with vehicle weight classes, setting separate standards for each tractor roof height helps ensure that all tractors are regulated to achieve appropriate improvements, without inadvertently leading to increased emissions and fuel consumption by

shifting the mix of vehicle roof heights offered in the market away from a level customaril y tied to the actu al trailers vehicles will haul in

- use. Tractor cabs t ypicall y can be divided into two configurations

– day cabs and sleeper cabs. Line haul operations ty picall y require overnight accommodations due to Federal Motor Carrier Safety Administration hours of o peration requirements. 38 Therefore, some truck buy ers purchase tractor cabs with sleeping accommodations, also known as sleeper cabs, because they do not return to their home base nightly . Sleeper cabs tend to have a greater empt y curb weight than day cab s due to the larger cab volume and accommodations, which lead to a higher baseline fuel consumption for sleeper cabs when compared to day

cabs. In addition, there are specific technologies, such as extended idle reduction technologies, which are appropriate onl y for tractors which hotel

-- such as sleeper cabs. To respect these differences, the agencies are proposing to create separate standards for sleeper cabs and day cabs.

38 FMCSA’s Hours

- of

- Service regulations put limits in place for when and how long commercial motor vehicle (CMV) drivers may drive. They are based on an exhaustive scientific review and are designed to ensure truck drivers get the necessary rest to per form safe operations. See 49 CFR Part 395, and see also http://www.fmcsa.dot.gov/rules

- regulations/topics/hos/index.htm (last accessed August 8, 2010).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

49 of 54 1 To account for the relevant combinations of these attributes, the agencies the refore propose to segment combination tractors into the following nine regulatory subcategories:

 Class 7 Day

Cab with L ow Roof  Class 7 Day

Cab with Mid Roof  Class 7 Day

Cab with High Roof  Class 8 Day

Cab with L ow Roof  Class 8 Day

Cab with Mid Roof  Class 8 Day

Cab with High Roof  Class 8 Sleeper Cab with L ow Roof  Class 8 Sleeper Cab with Mid Roof  Class 8 Sleeper Cab with High Roof The agencies have not identified an y Class 7 or Class 8 day cabs with mid roof heights in the market today but welcome comments wi th regard to this market characterization. In addition, the agencies are proposing to classify all vehicles with sleeper cabs as tractors. The proposed rule s would not allow vehicles with sleeper cabs to be classified as vocational vehicles. This provisi on is intended prevent the initial manufacture of straight truck vocational vehicles with sleeper cabs that, soon after introduction into commerce , would be converted to line haul tractors, as a means to circumvent the Class 8 sleeper cab regulat ions

. The agencies welcome comments on the likelihood of manufacturers using such an approach to circumvent the regulations and the appropriate regulatory

provisions the agencies should consider to prevent such actions. (1) What are the Proposed Class 7/8 Tractor and E ngine CO 2 Emissions and Fuel Consumption standards and their timing? In developing the proposed tractor and engine standards, the agencies have evaluated the current levels of emissions and fuel consumption, the kinds of technologies that could be utilized by

truck and engine manufacturers to reduce emissions and fuel consumption from tractors and engines, the associated lead time, the associated costs for the industry , fuel savings for the consumer, and the magnitude of the CO 2 and fuel econom y savings that may be achieved. The technologies that the agencies considered while setting the proposed tractor standards include improvements in aerody namic design, lower rolling resistance tires, extended idle reduction technologies, and vehicle empty weight reduct ion. The technologies that the agencies considered while setting the engine standards include engine friction reduction, aftertreatment optimization, and turbocompounding, among others. The agencies’ evaluation indicates that these technologies are avail able today , but have very low application rates in the market. The agencies have anal yz ed the technical feasibility of achieving the proposed CO 2 and fuel consumption standards for tractors and engines, based on projections of what actions manufacturers w ould be expected to take to reduce emissions and fuel consumption to achieve the standards. EPA and NHTSA also present the estimated costs and benefits of50 of 54 1

the class 7 and 8 combination tractor and engine standards in Section III and in DRIA Chapter 2. (a ) T ractor Standards The agencies are proposing the following standards for Class 7/8 combination tractors in Table II
- 1 , using the subcategorization approach just explained. As noted, the agencies are not aware of any mid roof day

c ab tractors at this time, but are proposing that any Class 7 and 8 day

cabs with a mid roof would meet the respective low roof standards, based on the similarity in baseline performance and similarity in expected improvement of mid roof sleeper cabs relati ve to low roof sleeper cabs. The agencies are aware of low roof tractor cabs which have an adjustable roof fairing allowing the operator to adjust the roof height to most appropriatel y match the trailer. The agencies welcome comment on the best approach to handle this t ype of technology. As explained below in Section III, EPA has determined that there is sufficient leadtime to introduce the tractor and engine technologies into the fleet starting in the 2014 model year, and is proposing standards starting for that model y ear. EPA is proposing more stringent tractor standards for the 2017 model year which reflect the CO 2 emissions reductions required through the 2017 model y ear engine standards. (As explained in Section II.B.2.o below, engine performance is one of the inputs into the compliance model, and that input will change in 2017 to reflect the 2017 MY engine standards.) The 2017 MY vehicle standards are not premised on manufacturers installing additional vehicle technologies. EPA’s proposed standards appl y throughout the useful life period as described in Section V. Similar to EPA’s non

- GHG standards approach, manufacturers may

generate and use credits from Class7/8 combination tractors to show compliance with the standards. NHTSA is proposing C lass 7/8 tractor fuel consumption standards that are voluntary opt
- in standards in the 2014 and 2015 model y ears and become mandatory beginning in the 2016 model y ear, as required by the lead time and stability requirement within EI SA. NHTSA is also propo sing new standards for the 2017 model y ear which reflect additional improvements in the heav y dut y engines only. NHTSA proposes to use useful life considerations for establishing fuel consumption performance for initial compliance and for ABT, NHTSA does n ot intend to implement an in

- use compliance program for fuel consumption because it is not currentl y anticipated there will be notable deterioration of fuel consumption over the useful life. NHTSA believes that the vehicle and engine standards proposed fo r combination tractors are appropriate, cost

- effective, and technologicall y feasible in the rulemaking timeframe based on our analysis detailed below in Section III and in the draft RIA. EPA and NHTSA are not proposing to make the 2017 vehicle standards more stringent based on the application of additional truck technologies because projected application rates of truck technologies used in setting the 2014 truck standard already reflect the maximum application rates we believe appropriate for these vehicl es given their specific use patterns as described in Section III. We considered setting more stringent standards for Class 7/8 tractors based on the application of more advancedDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

51 of 54 1 aerod ynamic s ys tems, such as self

- compensating side extenders or other advanc ed aerod ynamic technologies, but concluded that those technologies would not be fully developed in the timeframe of this regulation. We request comment on this decision, supported by

data as appropriate. Table II - 1 : Heavy Duty Combination Tractor Emissions and Fuel Consumption Standards 2014 Model Year CO 2 Grams per Ton

- Mile

Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 108 81 65 Mid Roof 108 81 65 High Roof 123 89 73 2014

- 2016 Model Year Gal lons of Fuel per 1000 Ton

- Mile 39

Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 10.6 8.0 6.4 Mid Roof 10.6 8.0 6.4 High Roof 12.1 8.7 7.2 2017 Model Year CO 2 Grams per Ton

- Mile

Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 106 80 6 5 Mid Roof 106 80 65 High Roof 120 88 72 2017

- 2018 Model Year Gallons of Fuel per 1000 Ton

- Mile

Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 10.4 7.9 6.4 Mid Roof 10.4 7.9 6.4 High Roof 11.8 8.6 7.1 Based on our analy sis, the 2017 model ye ar standards represent up to a 20 percent reduction in CO 2 emissions and fuel consumption over a 2010 model ye ar baseline, as detailed in Section III.A.2. (i ) Off

-Road Tractor Standards In developing the proposal EPA and NHTSA received comment from manufacturers and owners that trucks sometimes have very limited on

- road usage. These trucks by definition of Title 40, Part 85.1703 are motor vehicles, but will spend the

39 Manufacturers may voluntarily opt

- in to the NHTSA fuel consumption program in 2014 or 2015. If a manufacturer opts

- in, the program becomes mandatory. See Section [add cross reference] below for more information about NHTSA’s voluntary opt

- in program for MYs 2014 and 2015.52 of 54 1

majority of their operations off

- road. Trucks, such as those used in oil fields, will experi ence little benefit from improved aerodyn amics and low rolling resistance tires. The agencies are therefore proposing to allow a narrow range of these de facto off

- road trucks to be excluded from the proposed tractor standards because the trucks do not travel at speeds high enough to realize aerodynamic improvements and require special off

- road tires such as lug tires. The trucks must still use a certified engine, which will provide fuel consumption and CO 2 emission reductions to the truck in all applicati ons. To ensure the limited use of these trucks, the agencies are proposing requirements that the vehicles have off

- road tires, have limited high speed operation, and are designed for specific off

- road applications. 40 The agencies are proposing that a truck must meet the following requirements to qualify

for an exemption from the vehicle standards for Class 7/8 tractors:

 Installed tires which are lug tires or contain a speed rating of less than or

equal to 60 mph; and

 In clude a vehicle speed limiter gover ned to 55 mph, and

 Contain PTO controls, or have axle configurations other than 4x2, 6x2, or 6x4 and have GVWR greater than 57,000 pounds; and

 Has a frame Resisting Bending Moment (RBM) greater than 2,000,000 lb. in. 41 EPA and NHTSA have concluded that the onroad performance losses and additional costs to develop a truck which meets these specifications will limit the exemption to trucks built for the desired purposes. 42 The agencies welcome comment on the proposed requirements and exemptions.
(b ) Engine Standa rds EPA is proposing GHG standards and NHTSA is proposing fuel consumption standards for new heav y duty engines. The standards will vary depending on the ty

pe of vehicle in which they

are used, as well as whether the engines are diesel or gasoline powered . This section discusses the standards for engines used in Class7/8 combination

40 For purposes of compliance with NHTSA’s safety regulations, such as FMVSS Nos. 1 19 and 121, a manufacturer wishing for their vehicle to classify as “off

- road” would still need to work with the relevant NHTSA office to declare its vehicle as “off

- road” if it uses public roads at any point in its service. 41 The agencies have found base d on standard truck specifications, that vehicles designed for significant off

- road applications, such as concrete pumper and logging trucks have RRM greater than 2,100,000 lb.in. (ranging up to 3,580,000 lb. in.). The typical on highway tractors have RBM of 1,390,000 lb. in. 42 The estimated cost for a lift axle is approximately $10,000. Axles with weight ratings greater than a ty pical on

- road axle cost an additional $3000.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

53 of 54 1 tractors, and also provides some overall background information. More information is also provided in the discussion of the standards for engines used in vocational trucks. EPA’s existing non

- GHG emissions regulations for heav y dut y on highway engines establish four regulatory classes that represent the engine’s intended and primary truck application. 43 The L ight Heavy Dut y Diesel (LHDD) engines are intended for application in Class 2b through Class 5 trucks (8,501 through 19,500 pounds GVWR). The Medium Heav y Duty Diesel (MHDD) engines are intended for Class 6 and Class 7 trucks (19,501 through 33,000 pounds GVWR). The Heav y Heav y Dut y Diesel (HHDD) engines are primaril y u sed in Class 8 trucks (33,001 pounds and greater GVWR). Lastly , spark ignition engines (primarily gasoline

- powered engines) installed in incomplete vehicles less than 14,000 pounds GVWR and spark ignition engines that are installed in all vehicles (comple te or incomplete) greater than 14,000 pounds GVWR are grouped into a single engine regulatory class. The engines in these four regulatory classes range in size between approximately five liters and sixteen liters. For the purposes of the GHG engine emissi ons and engine fuel consumption standards that EPA and NHTSA are proposing today , the agencies intend to maintain these same four regulatory classes for both sets of standards. This class structure would enable the agencies to set standards that appropriately reflect the technology available for engines for use in each t ype of vehicle, and that are therefore technologically feasible for these engines. This section discusses the MHDD and HHDD engines used in Class 7 and 8 combination tractors. EPA's propos ed heav y duty CO 2 emission standards for diesel engines installed in combination tractors are presented in Table II
- 2 . We should note that this does not cover gasoline or LHDD engines as they are not used in 7/8 combination tract ors. Similar to EPA’s non

- GHG standards approach, manufacturers may generate and use credits to show compliance with the standards. EPA is proposing to adopt the existing useful life definitions for heav y duty engines. The EPA standards would become effe ctive in the 2014 model year, with more stringent standards becoming effective in model year 2017. Recently , EPA’s non

- GHG heav y dut y engine program provided new emissions standards for the industry in three year increments. L argel y, the heav y dut y engin e and truck manufacturer product plans have fallen into three ye ar cycles to reflect this regulatory

environment. The proposed two

- step CO 2 emission standards recognize the opportunity

for technology

improvements over this timeframe while reflecting the t ypical diesel truck manufacturers’ product plan cycles. With respect to the lead time and cost of incorporating technology improvements that reduce GHG emissions and fuel consumption, EPA and NHTSA place important weight on the fact that during MYs 2014

- 2017 engine manufacturers are expected to redesign and upgrade their products. Over these four model years there will be an opportunity

for manufacturers to evaluate almost every one of their engine models and

43 Insert cite for LHDD, MHDD, HHDD intended classes54 of 54 1

add technology

in a cost

- effective way , consi stent with existing redesign schedules, to control GHG emissions and reduce fuel consumption. The time

- frame and levels for the standards, as well as the ability to average, bank and trade credits and carry a deficit forward for a limited time, are expecte d to provide manufacturers the time needed to incorporate technology

that will achieve the proposed GHG and fuel consumption reductions, and to do this as part of the normal engine redesign process. This is an important aspect of the proposed rules, as it will avoid the much higher costs that would occur if manufacturers needed to add or change technology at times other than these scheduled redesigns. This time period will also provide manufacturers the opportunity to plan for compliance using a multi

- ye ar time frame, again in accord with their normal business practice. Further details on lead time, redesigns and technical feasibility can be found in Section III NHTSA’s fuel consumption standards, also presented in Table II
- 2 , would contain a voluntary

opt
- in to the engine program starting in 2014 model year, with mandatory engine standards starting in 2017 model year, harmonized with EPA’s 2017 model year standards. A manufacturer may opt
- in to NHTSA’s voluntary standards in 2014, 2015 or 2016. Once a manufacturer opts

- in the standards become mandatory for the opt

- in and subsequent model y ears, and the manufacturer may not reverse its decision. To opt into the program, a manufacture must declare its intent to opt in to the program at the same time it submits the Pre

- Certification Compliance Report. See Section 49 CFR Part 535.8 for information related to the Pre

- Certification Compliance Report. A manufacturer opting into the program would begin tracking credits and debits beginnin g in the model ye ar in which they

opt into the program. Table II - 2 : Proposed Heavy Duty Diesel Engine Standards for Engines Installed in Tractors Effective 2014 Model Year MHDD Engine HHDD Engine CO 2 Stand ard (g/bhp

- hr) 502 475 Optional Fuel Consumption Standard (gallon/100 bhp

- hr) 4.93 4.67 Effective 2017 Model Year MHDD Engine HHDD Engine CO 2 Standard (g/bhp

- hr) 487 460 Fuel Consumption (gallon/100 bhp

- hr) 4.78 4.52 Combination tractors spend the m ajority of their operation at steady state conditions, and will obtain in

- use benefit of technologies such as turbocompounding and other waste heat recovery technologies during this kind of ty pical engine operation. Therefore, the engines installed in tra ctors would be required to meet the standard based on the Supplemental Engine Test (SET), which is a steady state test cycle. The baseline HHDD engine performance in 2010 model year on the SET is 490 g CO 2 /bhp

- hr (4.81 gal/100 bhp

- hr), as determined from c onfidential data provided by manufacturers and the non

- GHG emissions certification process. Similarly , the baselineDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

55 of 54 1 MHDD engine performance on the SET cycle is 518 g CO 2 /bhp

- hr (5.09 gallon/100

- bhp

hr) in the 2010 model ye ar. Further discussion of the d erivation of the baseline can be found in Section III The diesel engine standards that EPA is proposing and the voluntary opt
- in standards being proposed by NHTSA for the 2014 model y ear would require diesel engine manufacturers to achieve on average a three percent reduction in fuel consumption and CO 2 emissions over the baseline 2010 model year performance for the engines. The agencies’ assessment of the findings of the March 2010 NAS Report and other literature sources indicates that there are technol ogies available to reduce fuel consumption by this level in the proposed timeframe. These technologies include improved turbochargers, aftertreatment optimization, low temperature exhaust gas recirculation, and engine friction reductions. Additional disc ussion on technical feasibility is included in Section III below and in DRIA Chapter 2. Furthermore, the agencies are proposing that diesel engines further reduce fuel consumption and CO 2 emissions from the 2010 model y ear baseline in 2017 model year. The proposed reductions represent on average a six percent reduction for MHDD and HHDD engines required to use the SET

- based standard. The additional reductions could likely be achieved through the increased refinement of the technologies projected to be implemented for 2014, plus the addition of turbocompounding or other waste heat recovery s ys tems. The agencies’ anal ys is indicates that this ty pe of advanced engine technology

would require a longer development time than the 2014 model y ear, and we therefor e are proposing to provide additional lead time to allow for its introduction. The agencies are aware that some truck and engine manufacturers would prefer to align their product development plans for these engine standards with their current plans to me et OnBoard Diagnostic (OBD) regulations for EPA and California in 2013 and 2016. We believe our proposed averaging, banking and trading provisions already provide these manufacturers with considerable flexibility to manage their GHG compliance plans consi stent with the 2013 model y ear. Nevertheless, we are requesting comment on whether EPA and NHTSA should provide additional defined phase

- in schedules that would more explicitly accommodate this request. For example, we request comment on a phase

- in sched ule with a standard of 485 g/bhp

- hr for the y ears 2013

- 2015 followed b y a standard of 460 g/bhp

- hr for 2016

- 18 with the associated fuel consumption values for the NHTSA program. This phase

- in schedule is just one of many potential schedules that would pro vide identical fuel savings and emissions reductions for the period from 2013

- 2018. If commenters wish to discuss a different phase

- in schedule than the one proposed b y the agencies, we request that commenters include a description of thei preferred phase

- in schedule, including an analy sis showing that it would be at least as effective (or more) as the primary program for the period through the 2018 model y ear. We also request comment on whether similar provisions should be made for the vocational engine standards discussed later in this section. In proposing this standard for heav y - dut y diesel engines used in class7/8 combination trucks , the agencies have examined the current performance levels of the engines across the fleet. EPA and NHTSA found that a large majorit y of the engines were generally

relativel y close to the average baseline, with some above and some below. We recognize , however , that when regulating a category of engines for the first time,56 of 54 1

there will be individual products that may deviate significantl y from this baseline level of performance. For the current fleet there is a relatively small group of engines that are significantl y worse than the average baseline for other engines. In proposing the standards, the agencies have looked prim arily at the ty pical performance levels of the majority of the engines in the fleet , and the increased performance that would be achieved through increased spread of technology . The agencies also r ecogniz e that for the smaller group of products, the same reduction from the industry baseline may

be more costly

than the agencies have assumed or perhaps even not feasible in the timing of these standards . We are therefore proposing a regulatory alternative whereby

a manufacturer w ould have the option to compl y with a unique standard based on a three percent reduction from an individual products own 2011 baseline level. Our assessment is that this three percent reduction is appropriate given the same technology packages and cost we have estimated for the primary program. We do not believe this alternative needs to continue past 2016 since manufacturers will have had ample opportunity to benchmark competitive products and make appropriate changes to bring their product performance into line with the rest of the industry . However, we are requesting comment on the potential to extend this regulatory alternative for one additional y ear for a single engine family with performance measured in that year as six percent beyond the engine’s own 2011 baseline level. We also request comment on the level of reduction beyond the baseline that is appropriate in this alternative. The three percent level reflects the aggregate improvement beyond the baseline we are requiring of the entire industry . As this provision is inten ded to address potential issues for legacy products that we would expect to be replaced or significantl y improved at the manufacturer’s next product change, we request comment if a two percent reduction would be more appropriate. We would consider two percent rather than three percent if we were convinced that making all of the changes we have outlined in our assessment of the technical feasibility of the standards was not possible for some engines due to legacy design issues that will change in the future . We are proposing that manufacturers making use of these provisions would not be able to generate emissions credits from other engines in the same regulatory category as the engines complying using this alternate approach. EPA and NHTSA considered settin g even more stringent engine standards for the 2017 model year based on the use of more sophisticated waste heat recovery technologies such as bottoming cycle engine designs. We are not today proposing more stringent standards because we do not believe th is technology can be broadl y available by 2017 model year. We request comment on the technological feasibility and cost

- effectiveness of more stringent standards in the timeframe of the proposed standards. (c) In

- use Standards Section 202(a)(1) of the Clean A ir Act specifies that EPA is to adopt emissions standards that are applicable for the useful life of the vehicle. The in

- use standards that EPA is proposing would apply to individual vehicles and engines. NHTSA is not proposing to a dopt in

- use. EPA is proposing that the in

- use standards for heavy dut y engines installed in tractors be established b y adding an adjustment factor to the full useful life emissions andDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

57 of 54 1 fuel consumption results projected in the EPA c ertification process. EPA and NHTSA are proposing a 2 percent adjustment factor for the in

- use standard to provide a reasonable margin for production and test

- to
- test variability that could result in differences between the initial emission test results a nd emission results obtained during subsequent in

- use testing. EPA is also proposing that the useful life for these engine and vehicles with respect to GHG emissions be set equal to the respective useful life periods for criteria pollutants. The agencie s propose that the existing engine useful life periods 44 , as included in Table II
- 3 , be broadened to include CO 2 emissions and fuel consumption for both engines and tractors. Table II - 3 Tractor and Engine Useful Life Periods

Years Miles Medium Heav y Dut y Diesel Engines and Class 7 Tractors 10 185,000 Heav y Heav y Dut y Diesel Engines and Class 8 Tractors 10 435,000 EPA and NHTSA request comments on the magnitude and need for an in

- use adjustment factor for the engine standard and the compliance model (TEST) based tractor standard. (2) Test Procedures and Related Issues The agencies are proposing a complete set of test procedures to evaluate fuel consumption and CO 2 emis sions from Class 7/8 tractors and the engines installed in them. The test procedures related to the tractors are all new, while the engine test procedures build substantially on EPA’s current non

- GHG emissions test procedures, except as noted. This secti on discusses the proposed simulation model developed for demonstrating compliance with the tractor standard and the proposed engine test procedures. (a ) Truck Simulation Model We are proposing to set separate engine and vehicle

- based emission standards to ach ieve the goal of reducing emissions and fuel consumption for both trucks and engines. For the Class 7 and 8 tractors, engine manufacturers would be subject to the engine standards, and Class 7 and 8 tractor manufacturers would be required to install engin es in their tractors certified for use in the tractor. The tractor manufacturer would be subject to a separate vehicle

- based standard that would use a proposed truck simulation model to evaluate the impact of the tractor cab design to determine compliance with the tractor standard.

44 40 CFR § 86.004

- 258 of 54 1 A simulation model, in general, uses various inputs to characterize a vehicle’s properties (such as weight, aerodynamics, and rolling resistance) and predicts how the vehicle would behave on the road when it follows a driving c ycle (vehicle speed versus time). On a second

- by

- second basis, the model determines how much engine power needs to be generated for the vehicle to follow the driving cycle as closely as possible. The engine power is then transmitted to the wheels through transmission, driveline, and axles to move the vehicle according to the driving cycle. The second

- by

- second fuel consumption of the vehicle, which corresponds to the engine power demand to move the vehicle, is then calculated according to a fuel consumpt ion map of the model. Similar to a chassis d ynamometer test, the second

- by

- second fuel consumption is aggregated over the complete drive cycle to determine a fuel consumption of the vehicle. NHTSA and EPA are proposing to evaluate fuel consumption and CO 2 emissions respectivel y through a simulation of whole

- vehicle operation, consistent with the NAS recommendation to use a truck model to evaluate truck performance. The agencies developed the Truck Efficiency Simulation Tool [TEST] for the specific purpose of this proposal to evaluate truck performance. The [TEST] model is similar in concept to a number of vehicle simulation tools developed by commercial and government entities. The model developed b y the agencies and proposed here was designed for the express purpose of vehicle compliance demonstration and is therefore simpler and less configurable than similar commercial products. This approach gives a compact and quicker tool for vehicle compliance without the overhead and costs of a more sophisticated model. Details of the model are included in Chapter 4 of the DRIA. [TEST] is designed to focus on the inputs most closely associated with fuel consumption and CO 2 emissions

- i.e . on those which have the largest impacts such as aerod ynamics, rolling res istance, weight, and others. EPA has validated [TEST] based on the chassis test results from three SmartWay certified tractors tested at Southwest Research Institute. The validation work conducted on these three vehicles is representative of the other C lass 7 and 8 tractors. Many aspects of one tractor configuration (such as the engine, transmission, axle configuration, tire sizes, and control sy stems) are similar to those used on the manufacturer’s sister models. For example, the powertrain configurat ion of a sleeper cab with any roof height is similar to the one used on a day

cab with any

roof height. Details are included in DRIA Chapter 4. Overall, the [TEST] model predicted the fuel consumption and CO 2 emissions within 4% of the chassis test proc edure results for three test cycles

– the ARB Transient cycle, ARB High Speed Cruise cycle, and the Low Speed Cruise cycle. These cycles are very similar to the ones the agencies are proposing to utilize in compliance testing. Test to test variation for heavy

- dut y vehicle chassis testing can be higher than 4 percent based on driver variation. The proposed simulation model is described in greater detail in Chapter 4 of the DRIA and is available for download b y interested parties at ( www.epa.gov/xxxxx ). We request comment on all aspects of this approach to compliance determination in general and to the use of the [TEST] model in particular. The agencies are proposing that for demonstrating compliance, a Class 7 a nd 8 tractor manufacturer would measure the performance of specified tractor sy stems (suchDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

59 of 54 1 as aerod yn amics and tire rolling resistance), input the values into [TEST], and compare the model’s output to the standard. The agencies propose that a tractor manu facturer would provide the inputs for each of following factors for each of the tractors it wished to certify under CO 2 standards and for establishing fuel consumption values: Coefficient of Drag, Tire Rolling Resistance Coefficient, Weight Reduction, Veh icle Speed L imiter, and Extended I dle Reduction Technology . These are the technologies on which the agencies’ own feasibility

anal ys is for these vehicles is predicated. An example of the [TEST] input screen is included in Figure II
- 1 . The input values for the simulation model would be derived b y the manufacturer from test procedures proposed b y the agencies in this proposal. The agencies are proposing several testing alternatives for aerody namic assessment, a single procedure f or tire rolling resistance coefficient determination, and a prescribed method to determine tractor weight reduction. The agencies are proposing defined model inputs for determining vehicle speed limiter and extended idle reduction technology

benefits. Th e other aspects of vehicle performance are fixed within the model as defined b y the agencies and are not varied for the purpose of compliance.

Figure II - 1 : Example [TEST] Input Screen (b ) Metric Test metrics whi ch are quantifiable and meaningful are critical for a regulatory program. The CO 2 and fuel consumption metric should reflect what we wish to control (CO 2 or fuel consumption) relative to the clearest value of its use: in this case, carrying60 of 54 1

freight. It sh ould encourage efficiency improvements that will lead to reductions in emissions and fuel consumption during real world operation. The agencies are proposing standards for Class 7 and 8 combination tractors that would be expressed in terms of moving a ton (2000 pounds) of freight over one mile. Thus, NHTSA's proposed fuel consumption standards for these trucks would be represented as gallons of fuel used to move one ton of freight 1000 miles, or gal/1000 ton

- mile. EPA's proposed CO 2 vehicle standards wou ld be represented as grams of CO 2 per ton
- mile. The NAS panel reached the same conclusion in their report. The panel spent considerable time explaining the advantages of and recommending a load

- specific fuel consumption approach to regulating the fuel ef ficiency of heav y dut y trucks. See NAS Report Chapter 2 pages 2

- 14 through 2

- 21 of the report. The panel first points out that the nonlinear relationship between fuel econom y and fuel consumption has led consumers of light

- duty

vehicles to have difficulty in judging the benefits of replacing the most inefficient vehicles. The panel describes an example where a light

- duty vehicle can save the same 107 gallons per year (assuming 12,000 miles travelled per year) b y improving one vehicle’s fuel efficiency fr om 14 to 16 mpg or improving another vehicle’s fuel efficiency

from 35 to 50.8 mpg. The use of miles per gallon leads consumers to undervalue the importance of small mpg improvements in vehicles with lower fuel econom y. Therefore, the NAS panel recommend s the use of a fuel consumption metric over a fuel economy metric. The panel also describes the primary purpose of most heav y duty vehicles as moving freight or passengers (the payload). Therefore, they

concluded that the most appropriate way to represent an attribute

- based fuel consumption metric is to normalize the fuel consumption to the payload. With the approach to compliance NHTSA and EPA are proposing today , a default payload is specified for each of the tractor categories suggesting that a gram pe r mile metric with a specified payload and a gram per ton

- mile metric would be effectivel y equivalent. The primary

difference between the metrics and approaches relates to our treatment of mass reductions as a means to reduce fuel consumption and greenhou se gas emissions. In the case of a gram per mile metric, mass reductions are reflected only in the calculation of the work necessary to move the vehicle mass through the drive cycle. As such it directly

reduces the gram emissions in the numerator since a vehicle with less mass will require less energy to move through the drive cycle leading to lower CO 2 emissions. In the case of Class 7 and 8 tractors and our proposed gram/ton

- mile metric, reductions in mass are reflected both in less mass moved through the drive cycle (the numerator) and greater payload (the denominator). We adjust the payload based on vehicle mass reductions because we estimate that approximately one third of the time the amount of freight loaded in a trailer is limited not by volume i n the trailer but by the total gross vehicle weight rating of the tractor. By reducing the mass of the tractor the mass of the freight loaded in the tractor can go up. Based on this general approach, it can be estimated that for every

1200 pounds in mass reduction total truck vehicle miles traveled and therefore trucks on the road could be reduced by one percent. Without the use of a per ton
- mile metric it would not be clear or straightforward for the agencies to reflect the benefits of mass reduction fr om large freight carrying vehicles that are often limited in the freight they

carry by the gross vehicle weight rating of the truck. The agencies seekDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

61 of 54 1 comment on the use of a per ton

- mile metric and also whether other metrics such as per cube

- mile should be considered instead. (c) Truck Aerodynamic Assessment The aerod ynamic drag of a vehicle is determined by the vehicle’s coefficient of drag (Cd), frontal area, air density and speed. The agencies are proposing to establish and use pre

- defined values for the input parameters to [TEST] which represent the frontal area and air density , while the speed of the vehicle would be determined in [TEST] through the proposed drive cycles. The agencies are proposing that the manufacturer would determine a truck’s Cd, a d imensionless measure of a vehicle’s aerody namics, for input into the model through a combination of vehicle testing and vehicle design characteristics. Quantifying truck aerodyn amics as an input to the [TEST] presents technical challenges because of the p roliferation of truck configurations, the lack of a clearl y preferable standardized test method, and subtle variations in measured Cd values among various test procedures. Class 7/8 tractor aerodynamics are currently developed by manufacturers using a ran ge of techniques, including vehicle coast down testing, wind tunnel testing, and computational fluid dy namics, as further discussed below. Reflecting that each of these approaches has limitations and no one approach appears to be superior to others, the a gencies are proposing to allow all three aerodyn amic evaluation methods to be used in demonstrating a vehicle’s aerodyn amic performance. The agencies welcome comments on each of these methods. The agencies are proposing that the coefficient of drag assess ment be a product of test data and vehicle characteristics using good engineering judgment. The primary tool the agencies expect to use in our own evaluation of aerodyn amic performance is the coast down procedure described in SAE J2263. Allowing manufact urers to use multiple test procedures and modeling coupled with good engineering judgment to determine aerod ynamic performance is consistent with the current approach used in determining representative road load forces for light

- dut y vehicle testing. 45 The agencies anticipate that as we and the industry gain experience with assessing aerodynamic performance of HD vehicles for purposes of compliance a test

- only approach may

have advantages. We believe this broad approach allowing manufacturers to use multiple different test procedures to demonstrate aerodynamic performance is appropriate given that no single test procedure is superior in all aspects to other approaches. However, we also recognize the need for consistency and a level playingfield in evaluatin g aerod ynamic performance. To accomplish this, the agencies propose to use a two

- part approach that evaluates aerodyn amic performance not onl y through testing but through the application of good engineering judgment and a technical description of the vehi cles aerody namic characteristics. The first part of the proposed evaluation approach uses a bin structure characterizing the expected aerodyn amic performance of tractors based on definable vehicle attributes. This bin approach is described further below. The second proposed

45 See CFR T itle 40, Part 86, Section.129

- 00 (e)(1).62 of 54 1

evaluation element uses aerodynamic testing to measure the vehicles aerodynamic performance under standardized conditions. The agencies expect that the SAE J2263 coast down procedures or a constant speed vehicle test will be the primary aerod ynamic testing tool but are interested in working with the regulated industry and other interested stakeholders to develop a primary test approach. Additionally , the agencies propose to have a process that would allow manufacturers to demonstrate that another aerody namic test procedure should also be permitted for purposes of compliance with the aerodyn amic requirements of today ’s proposed rules. We are requesting comment on methods that should form the primary

aerod ynamic testing tool, methods th at may be appropriate as alternatives, and the mechanism (including standards, practices, and unique criteria) for the agencies to consider allowing alternative aerody namic test methods. NHTSA and EPA are proposing that manufacturers use a two part screeni ng approach for determining the aerodyn amic inputs to the TEST model. The first part would require the manufacturers to assign each vehicle aerodyn amic configuration to one of five aerod ynamics bins created b y EPA and NHTSA as described below. The assignment by

bin reflects the aerodyn amic characteristics of the vehicle. For each bin, EPA and NHTSA have already defined a nominal Cd that will be used in the TEST model and a range of Cd values that would be expected from testing of vehicles meeting this bi n description. The second part would require the manufacturer to then compare its own test results of aerody namic performance (as conducted in accordance with the agencies’requirements) for the vehicle to confirm the actual aerodynamic performance was con sistent with the agencies’ expectations for vehicles within this bin. If the predicted performance and actual observed performance match, the Cd value as an input for the TEST model is the nominal Cd value defined for the bin. If however, a manufacturer’ s test data demonstrates performance that is better than projected for the assigned bin a manufacturer may use the test data and good engineering judgment to demonstrate to the agencies that this particular vehicle’s performance is in keeping with the perf ormance level of a more aerody namic bin and with the agencies’ permission may use the Cd value of the more aerodynamic bin. Conversel y, if the test data demonstrates that the performance is worse than the projected bin, then the manufacturer would use the Cd value from the less aerody namic bin. Using this approach, the bin structure can be seen as the agencies’ first effort to create a common measure of aerody namic performance to benchmark the various test methods manufacturers may use to demonstrate aero dy

namic performance. For example, if a manufacturers test methods consistently

produce Cd values that are better than projected by the agencies, EPA and NHTSA can use this information to further scrutinize the manufacturer’s test procedure, helping to ens ure that all manufacturers are competing on a level playing field. The agencies are proposing aerodynamic technology bins which divide the wide spectrum of tractor aerody namics into five categories. The first category , “Classic,” represents tractor bo dies which prioritize appearance or special dut y capabilities over aerod ynamics. The Classic trucks incorporate few, if an y, aerod ynamic features and may have several features which detract from aerodynamics, such as bug deflectors, custom sunshades, b

- pi llar exhaust stacks, and others. The second category for aerody

namics is the “Conventional” tractor body . The agencies consider Conventional tractors to be the average new tractor today which capitalizes on a generall y aerod yn amic shape and avoidsDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

63 of 54 1 classic features which increase drag. Tractors within the “SmartWay” category build on Conventional tractors with added components to reduce drag in the most significant areas on the tractor, such as fully enclosed roof fairings, side extending gap reducers, fue l tank fairings, and streamlined grill/hood/mirrors/bumpers. The “Advanced SmartWay” aerod ynamic category

builds upon the SmartWay tractor body

with additional aerod ynamic treatments such as underbody airflow treatment, down exhaust, and lowered ride height. And finall y, “Advanced SmartWay I I” tractors incorporate advanced technologies which are currentl y in the prototype stage of development, such as advanced gap reduction, rearview cameras to replace mirrors, wheel s ys tem streamlining, and advanced body designs. The agencies recognize that these proposed aerodynamic bins are static and referential and that there may be other technologies that may provide similar aerodynamic benefit. In addition, it is expected that aerodynamic equipment will advance ov er time and the agencies may find it appropriate and necessary to revise the bin descriptions. Under this proposal, the manufacturer would then input into [TEST] the Cd value specified for each bin as also defined in Table II
- 4 Error! Reference source not found. Error! Reference source not found. . For example, if a manufacturer tests a Class 8 sleeper cab high roof tractor with features which are similar to a SmartWay tractor and the test produces a Cd value of 0.59, then the manufacturer wo uld assign this tractor to the Class 8 Sleeper Cab High Roof SmartWay bin. The manufacturer would then use the Cd value of 0.60 as the input to [TEST]. Table II - 4 : Aerodynamic Input Definitions to [TEST] C lass 7 Class 8 Day Cab Day

Cab Sleeper Cab Low Roof High

Roof Low

Roof High

Roof Low

Roof Mid

Roof High Roof Aerod ynamics Test Results (Cd) Classic ≥0.83 ≥0.73 ≥0.83 ≥0.73 ≥0.83 ≥0.78 ≥0.73 Conventional 0.78

-

0.82 0.63

-

0.72 0.78

-

0.82 0.63

-

0.72 0.78

-

0 .82 0.73

-

0.77 0.63

- 0.72 SmartWay 0.73

-

0.77 0.58

-

0.62 0.73

-

0.77 0.58

-

0.62 0.73

-

0.77 0.68

-

0.72 0.58

- 0.62 Advanced SmartWay 0.68

-

0.72 0.53

-

0.57 0.68

-

0.72 0.53

-

0.57 0.68

-

0.72 0.63

-

0.67 0.53

- 0.57 Advanced SmartWay II ≤0.67 ≤0.52 ≤0.67 ≤0.52 ≤0.67 ≤0.62 ≤0.52 Aerod ynamic Input to [TEST] (Cd) Frontal Area (m 2 ) 6.0 9.8 6.0 9.8 6.0 6.6 9.8 Classic 0.85 0.75 0.85 0.75 0.85 0.80 0.75 Conventional 0.80 0.68 0.80 0.68 0.80 0.75 0.68 SmartWay 0.75 0.60 0.75 0.60 0.75 0.70 0.60 Advanced SmartWay 0.70 0.55 0.70 0. 55 0.70 0.65 0.5564 of 54 1

Advanced SmartWay II 0.65 0.50 0.65 0.50 0.65 0.60 0.50

Coefficient of drag ( Cd) and frontal area of the tractor

- trailer combination go hand

- in

- hand to determine the force required to overcome aerodyn amic drag. As explained above, the agencies are proposing that the Cd value is one of the [TEST] inputs which will be derived b y the manufacturer. However, the agencies are proposing to specify the truck’s frontal area for each regulatory category ( i.e. each of the seven subcategories whic h are proposed and listed in Table II
- 4 Error! Reference source not found. Error! Reference source not found. under the Aerod ynamic Input to [TEST]). The frontal area of a high roof tractor pulling a box trailer will be determined primaril y by the box trailer’s dimensions and the ground clearance of the tractor. The frontal area of low and mid roof tractors will be determined b y the tractor itself. An alternate approach to the proposed frontal area specification is to create the aerodyn ami c input table (as shown in Table II
- 4 Error! Reference source not found. Error! Reference source not found. ) with values that represent the Cd multiplied by the frontal area. This approach will provide the same aerodynamic load, but it will not allow the comparison of aerod ynamic efficiency across regulatory categories that can be done with the Cd values alone. The agencies are interested in comments regarding the frontal area of trucks, specificall y whether the specified frontal areas are a ppropriate and whether the use of standard frontal areas may have unanticipated consequences. EPA and NHTSA recognize that wind conditions, most notably wind direction, have a greater impact on real world CO 2 emissions and fuel consumption of heav y dut y tr ucks than of light

- duty

vehicles. As noted in the NAS report 46 , the wind average drag coefficient is about 15 percent higher than the zero degree coefficient of drag (Cd). The agencies considered proposing the use of a wind averaged drag coefficient in th is regulatory

program, but ultimately

decided to propose using coefficient of drag values which represent zero yaw ( i.e., representing wind from directl y in front of the vehicle, not from the side) instead. We are taking this approach recognizing that win d tunnels are currentl y the onl y tool to accuratel y assess the influence of wind speed and direction on a truck’s aerodynamic performance. The agencies recognize, as NAS did, that the results of using the zero yaw approach may result in fuel consumption p redictions that are offset slightly from real world performance levels, not unlike the offset we see today between fuel econom y test results in the CAFE program and actual fuel econom y performance observed in

- use. We believe this approach will not impact t echnology effectiveness or change the kinds of technology decisions made by

the tractor manufacturers in developing equipment to meet our proposed standards. However, the agencies are interested in receiving comment on approaches to develop wind averaged coefficient of drag values including CFD, coast down, and constant speed test procedures. The methodologies the agencies are considering for aerodyn amic assessment include coast down testing, wind tunnel testing, and computational fluid dynamics. The

46 See 2010 NAS Report, Finding 2

- 4 on page 2

- 40.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

65 of 54 1 agen cies welcome information on a constant speed test procedure and how it could be applied to determine aerody namic drag. (i ) Coast Down Testing The coast down test procedure has been used extensively in the light

- duty industry to capture the road load force b y c oasting a vehicle along a flat straightaway under a set of prescribed conditions. Coast down testing has been used less extensively to obtain road load forces for medium

- and heav y - duty vehicles. EPA has conducted a significant amount of test work to dem onstrate that coast down testing per SAE J2263 produces reasonabl y repeatable test results for Class 7 and 8 tractor / trailer pairings, as described in DRIA Chapter 3. The agencies propose that a manufacturer which chooses this method would determine a tractor’s Cd value through anal ys is of the road load force equation derived from SAE J2263 Revised 2008

- 12 test results, as proposed in 40 CFR 1066.210

. (ii) Wind Tunnel Testing A wind tunnel provides a stable environment yi elding a more repeatable test than coast down. This allows the manufacturer to run multiple baseline vehicle tests and explore configuration modifications for nearl y the same effort (e.g., time and cost) as conducting the coast down procedure. In addition, wind tunnels provide testers with the ability to yaw the vehicle at positive and negative angles relative to the original centerline of the vehicle to accurately capture the influence of non

- uniform wind direction on the Cd (e.g., wind averaged Cd). The agencies propose to allow the us e of existing SAE wind tunnel procedures with some minor modifications as discussed in Section V of this proposal. The agencies seek comments on the appropriateness of using the existing SAE wind tunnel procedures, and the modifications to these procedure s, for this regulatory purpose. (iii) Computational Fluid Dynamics Computational Fluid Dynamics, or CFD, capitalizes on today ’s computing power by modeling a full size vehicle and simulating the flows around this model to examine the fluid dy

namic properties, in a virtual environment. CFD tools are used to solve the Navier

- Stokes equations that follow phy sical law of conservation of momentum and govern fluid d ynamics and flow relationship around a body in motion or a static body with fluid in motion around it. CFD anal ys is involves several steps: defining the model structure or geometry

based on provided specifications to define the basic model shape, applying a closed surface around the structure to define the external model shape (wrapping or surface meshing) , dividing the control volume, including the model and the surrounding environment, up into smaller, discreet shapes (gridding), defining the flow conditions in and out of the control volume and the flow relationships within the grid (including eddies and turbulence), and solving the flow equations based on the prescribed flow conditions and relationships.66 of 54 1 This approach can be beneficial to manufacturers since they can rapidl y prototy

pe ( e.g ., design, research, and model) an entire vehicle without investing in material costs; they can modify

and investigate changes easily ; and the data files can be re

- used and shared within the company or with corporate partners. The accuracy

of the outputs from CFD anal ys is is highl y dependent on the inputs. The CFD mode ler decides what method to use for wrapping, how fine the mesh cell and grid size should be, and the phy sical and flow relationships within the environment. A balance must be achieved between the number of cells, which defines how fine the mesh is, and th e computational times for a result ( i.e ., solution

- time

- efficiency). All of these decisions affect the results of the CFD aerodynamic assessment. Because CFD modeling is dependent on the quality of the data input and the design of the model, the agencies seek comment on a minimum set of criteria applicable to using CFD for aerodynamic assessment in Section V. Further, we are proposing a requirement to correlate CFD aerodynamic assessments with experimental results from either or both the coast down proced ure and wind tunnel testing. This will allow the use of CFD and the design freedom that it offers while ensuring that, regardless of the decisions made during the process, the CFD aerody namic assessment accurately simulates real

- world aerody namics. (d ) Tire R olling Resistance Assessment NHTSA and EPA are proposing that the tractor’s tire rolling resistance input to the [TEST] model be determined using the I SO 28580:2009 test method. 47 The agencies believe the ISO test procedure is appropriate to propose for this program because the procedure is the same one used b y NHTSA in its fuel efficiency tire labeling program 48 and is consistent with the direction being taken b y the tire industry both in the United States and Europe. The rolling resistance from this test would be used to specify the rolling resistance of each tire on the steer and drive axle of the vehicle. The results would be expressed as a rolling resistance coefficient and measured as kilogram per metric ton (kg/metric ton). The agencies are proposi ng that three tire samples within each tire model be tested to account for some of the production variability and the average of the three tests would be the rolling resistance coefficient for the tire. The [TEST] model would use a combined tire rolling r esistance, where 15 percent of the gross weight of the truck and trailer would be distributed to the steer axle, 42.5 percent to the drive axles, and 42.5 percent to the trailer axles. 49 The trailer tires’ rolling resistance would be prescribed by the agen cies as part of the standardized trailer used for demonstrating compliance at 6

47 ISO, 2009, Passenger Car, Truck, and Bus Tyres

– Methods of Measuring Rolling Resistance

– Single Point Test and Correlation of Measurement Results: ISO 28580:2009 (E), First Edition, 2009

- 07

- 01 48 NHTSA, 2009. “NHTSA Tire Fuel Efficiency Consumer Information Program Development: Phase 1

– Evaluation of Laboratory Test Protocols.” DOT HS 811 119. June. (www.regulations.gov, Docket ID: NHTSA

- 2008

- 0121

- 0019). 49 This dis tribution is equivalent to the federal over

- axle weight limits for an 80,000 GVWR 5

- axle tractor

trailer: 12,000 pounds over the steer axle, 34,000 pounds over the tandem drive axles (17,000 pounds per axle) and 34,000 pounds over the tandem trailer axles (17,000 pounds per axle).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

67 of 54 1 kg/metric ton, which was the average trailer tire rolling resistance measured during the SmartWay

tire testing. 50 We acknowledge that the useful life of original equipment tir es used on tractors is shorter than the tractor’s useful life. In this proposal, we are treating the tires as if the owner replaces the tire with tires that match the original equipment. Some owners opt for the original tires under the assumption that th is is the best product. However, tractor tires are often retreaded or replaced. Steer tires on a highway tractor might need replacement after 75,000 to 150,000 miles. Drive tires might need retreading or replacement after 150,000 to 300,000 miles. Of course, tire removal miles can be much higher or lower, depending upon a number of factors that affect tire removal miles. These include the original tread depth; desired tread depth at removal to maintain casing integrity ; tire material and construction; ty pical load; tire “scrub” due to urban driving and set back axles; and, tire underinflation. Since it is common for both medium and heavy dut y truck tires to be replaced and retreaded, we welcome comments in this area. We are specificall y seeking data for the rolling resistance of retread and replacement heavy duty tires and the t ypical useful life of tractor tires. (e) Weight Reduction Assessment EPA and NHTSA are seeking to account for the emissions and fuel consumption benefits of weight reduction as a control technology in heavy duty trucks. Weight reduction impacts the emissions and fuel consumption performance of tractors in different way s depending on the truck’s operation. For trucks that cube

- out, the weight reduction will show a small reduction in grams of CO 2 emitted or fuel consumed per mile travelled. The benefit is small because the weight reduction is minor compared to the overall weight of the combination truck and payload. However, a weight reduction in tractors which operate at maximum gro ss vehicle weight rating would result in an increase in payload capacity . Increased vehicle payload without increased GVWR significantl y reduces fuel consumption and CO 2 emissions per ton mile of freight delivered. It also leads to fewer vehicle miles driven with a proportional reduction in traffic accidents. The empty

curb weight of tractors varies significantly today . Items as common as fuel tanks can vary

between 50 and 300 gallons each for a given truck model. In formation provided b y truck manufac turers indicates that there may be as much as a 5,000 to 17,000 pound difference in curb weight between the lightest and heaviest tractors within a regulatory subcategory

(such as Class 8 sleeper cab with a high roof). Because there is such a large variat ion in the baseline weight among trucks that perform roughl y similar functions with roughl y similar configurations, there is not an effective way to quantify

the exact CO 2 and fuel consumption benefit of mass reduction using [TEST] because of the difficulty in establishing a baseline. However, if the weight reduction is limited to tires and wheels, then both the baseline and weight differentials for

50 US E nvironmental Protection Agency. SmartWay Transport Partnership July 2010 e

- update accessed July 16, 2010, from http://www.epa.gov/smartwaylogistics/newsroom/documents/e

- update

- july

- 10.pdf68 of 54 1

these are readily

quantifiable and well

- understood. Therefore, the agencies are proposing that the mass red

uction that would be simulated be limited only to reductions in wheel and tire weight. The agencies of course still encourage each OEM to reduce tractor curb weight generally in as many other way s as possible, which would reduce fuel consumption and GHG e missions independent of the degree to which such improvements are recognized for fuel consumption and CO 2 compliance purposes. In the context of this heav y dut y vehicle program with only changes to tires and wheels, the agencies do not foresee an y related impact on safet y. 51 The agencies welcome comments regarding this approach and detailed data to further improve the robustness of the agencies’ assumed baseline truck curb weights for each regulatory category used within the model, as outlined in DRIA Chap ter 3. EPA and NHTSA are proposing to specify the baseline vehicle weight for each regulatory

category (including the tires and wheels), but allow manufacturers to quantify weight reductions based on the wheel material selection and single wide versus du al tires per Table II
- 5 . The agencies assume the baseline wheel and tire configuration contains dual tires with steel wheels because these represent the vast majority of new vehicle configurations today . The proposed weight redu ction due to the wheels and tires would be reflected in the payload tons by increasing the specified payload by the weight reduction amount discounted by two thirds to recognize that approximately one third of the truck miles are travelled at maximum paylo ad, as discussed above in the payload discussion. Table II - 5 : Proposed Weight Reduction Values Weight Reduction Technology Weight Reduction (kg per tire/wheel) Single Wide Drive Tire with ..

. Steel Wheel 38 Aluminum Wheel 63 Li ght Weight Aluminum Wheel 67 Steer Tire or Dual Wide Drive Tire with

... High Strength Steel Wheel 4 Aluminum Wheel 10 Li ght Weight Aluminum Wheel 14 (f ) Extended Idle Reduction Technology Assessment Extended idling from Class 8 heav y duty line haul trucks contributes to significant CO 2 emissions and fuel consumption in the United States. The Federal Motor Carrier Safety Administration regulations require a certain amount of driver rest for a

51 For more information on the estimated safety effects of this proposed rule, see Chapter 9 of the draft RIA.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

69 of 54 1 corresponding period of driving hours

. 52 Extended idle occurs when Class 8 long haul drivers rest in the sleeper cab compartment during rest periods as drivers find it both convenient and less expensive to rest in the truck cab itself than to pull off the road and find accommodations. During this rest period a driver will idle the truck in order to provide heating or cooling or run on

- board appliances. In some cases the engine can idle in excess of 10 hours. During this period, the truck will consume approximately 0.8 gallons of fuel and emi t over 8,000 grams of CO 2 per hour. An average truck can consume 8 gallons of fuel and emit over 80,000 grams of CO 2 during overnight idling in such a case. Idling reduction technologies are available to allow for driver comfort while reducing fuel consumptions and CO 2 emissions. Auxiliary power units, fuel operated heaters, battery

supplied air conditioning, and thermal storage s ys tems are among the technologies available today . The agencies are proposing to include extended idle reduction technology

as an input to the [TEST] model for Class 8 sleeper cabs. The manufacturer would input the value based on the idle reduction technology installed on the truck. As discussed further in Section III, if a manufacturer chooses to use idle reduction technology to meet the standard, then it would require an automatic main engine shutoff after 5 minutes to help ensure the idle reductions are realized in

- use. As with all of the technology inputs discussed in this section, the agencies are not mandating the use of idle reductions or idle shutdown, but rather allowing their use as one part of a suite of technologies feasible for reducing fuel consumption and meeting the proposed standards. The proposed value (5 g CO 2 /ton

- mile or 0.5 gal/1000 ton

- mile) for the idle r eduction technologies was determined using an assumption of 1,800 idling hours per ye ar, 125,000 miles travelled, and a baseline idle fuel consumption of 0.8 gallons per hour. Additional detail on the emission and fuel consumption reduction values are inc luded in DRIA Chapter 2. (g ) Vehicle Speed Limiters Fuel consumption and CO 2 emissions increase proportional to the square of vehicle speed. 53 Therefore, lowering vehicle speeds can significantl y reduce fuel consumption and GHG emissions. A vehicle speed limi ter, which limits the vehicle's maximum speed, is a simple technology that is utilized today . The feature is electronically

programmed and controlled. Manufacturers today sell trucks with vehicle speed limiters and allow the customers to set the limit. However, as proposed the [TEST] model will not provide a fuel consumption reduction for a limiter that can be overridden. In order to obtain a benefit for the program, the manufacturer must preset the limiter in such a way

that the setting will not be cap able of being easily overridden by the fleet or the owner. As with other engine calibration aspects of emission controls, tampering with a calibration would be considered unlawful by EPA. If the manufacturer installs a

52 Federal Motor Carrier Safety Administration. Hours of Service Regulations. Last ac cessed on August 2, 2010 at http://www.fmcsa.dot.gov/rules

- regulations/topics/hos/ 53 NAS Report. Page 2

- 22. Road Load Force Equation defines the aerodynamic portion of the road load as 1⁄2 * Coefficient of Drag * Frontal Area * air density * vehicle speed squared.7 0 of 54 1

vehicle speed limiter into a truck that is not easil y overridden, then the manufacturer would input the vehicle speed limit setpoint into [TEST] model. (h ) Defined Vehicle Configurations in the [TEST ] model As discussed above, the agencies are proposing methodologies that manufacturers would use to quantify

the values to be input into the [TEST] for these factors affecting truck efficiency : Coefficient of Drag, Tire Rolling Resistance Coefficient, Weight Reduction, Vehicle Speed L imiter, and Extended Idle Reduction Technology . The other asp ects of vehicle performance are fixed within the model and are not varied for the purpose of compliance. The defined inputs being proposed include the drive cycle, tractor
- trailer combination curb weight, payload, engine characteristics, and drivetrain fo r each vehicle t ype, and others. We are seeking comments accompanied with data on the defined model inputs as described in draft RIA Chapter 3. (i ) Vehicle Drive Cycles As noted by

the March 2010 NAS Report, 54 the choice of a drive cycle used in compliance tes ting has significant consequences on the technology that will be employed to achieve a standard as well as the ability of the technology

to achieve real world reductions in emissions and improvements in fuel consumption. Manufacturers naturally will design vehicles to ensure they satisfy regulatory

standards. If the agencies propose an ill

- suited drive cycle for a regulatory category , it may

encourage GHG emissions and fuel consumption technologies which satisfy the test but do not achieve the same benefi ts in use. For example, requiring all trucks to use a constant speed highway drive cycle will drive significant aerodyn amic improvements. However, in the real world a combination tractor used for local delivery may spend little time on the highway , reduc ing the benefits that would be achieved by this technology . In addition, the extra weight of the aerod ynamic fairings will actually penalize the GHG and fuel consumption performance in urban driving and may reduce the freight carrying capability . The unique nature of the kinds of CO 2 emissions control and fuel consumption technology means that the same technology

can be of benefit during some operation but cause a reduced benefit under other operation. 55 To maximize the GHG emissions and fuel consumption b enefits and avoid unintended reductions in benefits, the drive cycle should focus on promoting technology

that produces benefits during the primary operation modes of the application. Consequently , drive cycles used in GHG emissions and fuel consumption c ompliance testing should reasonabl y represent the primary actual use, notwithstanding that every truck has a different drive cycle in

- use.

54 March 2010 NAS Report, Chapters 4 and 8. 55 This situation does not typically occur for heavy

- duty emission control technology designed to control criteria pollutants such as PM and NOx.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

71 of 54 1 The agencies are proposing a modified version of the California Air Resource Board (ARB) Heav y Heavy Dut y Truck 5 Mode Cycle 56 , using the basis of three of the cycles which best mirror Class 7 and 8 combination truck driving patterns, based on information from MOVES. 57 The key advantage of ARB 5 mode cycle is that it provides the flexibility

to use several different mo des and weight the modes to fit specific truck application usage patterns. EPA analyzed the five cycles and found that some modifications to the modes appear to be needed to allow sufficient flexibility in weightings. The agencies are proposing the use o f the Transient mode, as defined b y ARB, because it broadl y covers urban driving. The agencies are also proposing altered versions of the High Speed Cruise and Low Speed Cruise modes which would reflect only constant speed cycles at 65 mph and 55 mph resp ectivel y. EPA and NHTSA relied on the EPA MOVES analy sis of Federal Highway Administration data to develop the proposed mode weightings to characterize ty pical operations of heavy duty trucks, per Table II
- 6 below. 58 A detailed d iscussion of drive cycles is included in DRIA Chapter 4. 59 Table II - 6 : Drive Cycle Mode Weightings

Transient 55 mph Cruise 65 mph Cruise Day Cabs 19% 17% 64% Sleeper Cabs 5% 9% 86%
(ii) Empty Weight and Payload The total weight of the tractor

- trailer combination is the sum of the tractor curb weight, the trailer curb weight, and the payload. The total weight of a truck is important because it in part determines the impact of technologies, such as rolling resist ance, on GHG emissions and fuel consumption. The agencies are proposing to specify each of these aspects of the vehicle. The agencies developed the proposed tractor curb weight inputs from actual tractors weights measured in two of EPA’s test programs an d based on

56 California Air Resources Board. Heavy Heavy Duty Diese l Truck chassis dynamometer schedule, Transient Mode. Last accessed on August 2, 2010 at http://www.dieselnet.com/standards/cycles/hhddt.html 57 EPA’s MOVES (Motor Vehicle Emission Simulator). See http://www.epa.gov/otaq/models/moves/index.htm for additional information. 58 The Environmental Protection Agency. Draft MOVES2009 Highway Vehicle Population and Activity Data. EPA

- 420

- P
- 09

- 001, August 2009 http://www.epa.gov/otaq/models/moves/tech docs/420p09001.pdf 59 In the light

- duty

vehicle rule, EPA and NHTSA based compliance with tailpipe standards on use of the FTP and HFET, and declined to use alternative tests. See 75 FR at 25407. NHTSA is mandated to use the FTP and HFET tests for CAFE st andards, and all relevant data was obtained by FTP and HFET testing in any case. Id. Neither of these constraints exist for class 7

- 8 tractors. The little data which exist on current performance are principally measured by the ARB Heavy Heavy Duty Truc k 5 Mode Cycle testing, and NHTSA is not mandated to use the FTP to establish heavy duty fuel economy standards. See 49 USC section 32902 (k)(2) authorizing NHTSA, among other things, to adopt and implement appropriate “test methods, measurement metrics, ... and compliance , protocols”.72 of 54 1

information from the manufacturers. The proposed trailer curb weight inputs were derived from actual trailer weight measurements conducted b y EPA and weight data provided to I CF by

the trailer manufacturers. 60 The proposed payloads, as describe d above, are 25,000 pound for a Class 7 tractor and 38,000 pounds for a Class 8 tractor. Details of the individual weight inputs b y regulatory category are included in DRIA Chapter 4. There are several methods that the agencies have considered for evaluating the GHG emissions and fuel consumption of tractors used to carry freight. A key

factor in these methods is the weight of the truck that is assumed for purposes of the evaluation. In use, trucks operate at different weights at different times during their operations. The greatest freight transport efficiency (the amount of fuel required to move a ton of payload) would be achieved by operating trucks at the maximum load for which they are designed all of the time. However, logistics such as delivery demands which require that trucks travel without full loads, the density of payload, and the availability of full loads of freight limit the ability

of trucks to operate at their highest efficiency all the time. M.J. Bradley anal yz ed the Truck Inventory and Use Survey

and found that approximately 9 percent of combination truck miles travelled empty , 61 percent are “cubed

- out” (the trailer is full before the weight limit is reached), and 30 percent are “weighed out” (operating weight equal 80,000 pounds whi ch is the gross vehicle weight limit on the Federal Interstate Highway S ys tem or greater than 80,000 pounds for vehicles traveling on roads outside of the interstate s ys tem). 61 The Federal Highway Administration developed Truck Payload Equivalent Factors t o inform the development of highway sy stem strategies using Vehicle Inventory and Use Survey

(VIUS) and Vehicle Travel In formation Sy stem (VTRI S) data. Their results found that the average payload of a Class 8 truck ranged from 36,247 to 40,089 pounds, de pending on the average distance travelled per day

. 62 The same results found that Class 7 trucks carried between 18,674 and 34,210 pounds of payload also depending on average distance travelled per day

. As described above, the amount of payload that a trac tor can carry depends on the category (or GVWR) of the vehicle. For example, a ty pical Class 7 tractor can carry less payload than a Class 8 tractor. The agencies are proposing to prescribe a fixed payload of 25,000 pounds for Class 7 tractors and 38,000 pounds for Class 8 tractors for their respective test procedures. The agencies are proposing a common payload for Class 8 day cabs and sleeper cabs because the data available does not distinguish based on ty pe of Class 8 tractor. These payload values rep resent a heavily loaded trailer, but not

60 ICF International. Investigation of Costs for Strategies to Reduce Greenhouse Gas Emissions for Heavy

Duty On

- road Vehicles. July 2010. Pages 4

- 15. 61 M.J. Bradley & Associates. Setting the Stage for Regulation of Heavy

- Duty Vehicle Fuel Economy and GHG Emissions: Issues and Opportunities. February 2009. Page 35. Analysis based on 1992 Truck Inventory and Use Survey data, where the survey data allowed developing the distribution of loads instead of merely the average l oads. 62 The U.S. Federal Highway Administration. Development of Truck Payload Equivalent Factor. Table 11. Last viewed on March 9, 2010 at http://ops.fhwa.dot.gov/freight/freight_analysis/faf/faf2_reports/reports9/s510_11_12_tables.htmDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

73 of 54 1 maximum GVWR, since as described above the majority of tractors "cube

- out" rather than "weigh

- out.” The proposed payloads are based on the average payload developed by the Federal Highway

Administration Truck Paylo ad Equivalent Factor for Class 7 and Class 8 trucks. 63 Additional details on proposed payloads are included in DRIA Chapter 3. (iii) Standardized Trailers NHTSA and EPA are proposing that the tractor performance in the [TEST] model will be judged b y assuming it is pulling a standardized trailer. The agencies believe that an assessment of the tractor aerodyn amics should be conducted using a tractor

- trailer combination to reflect the impact of aerodynamic technologies in actual use, where tractors are designed and used with a trailer. Assessing the tractor aerodyn amics using only the tractor would not be a reasonable way to assess in

- use impacts. For example, the in

- use aerod yn amic drag while pulling a trailer is different than without the trailer and the full impact of an aerodyn amic technology on reducing emissions and fuel consumption would not be reflected if the assessment is performed on a tractor without a trailer. In addition to assessing the tractor with a trailer, it is appropriate to adopt a standardize d trailer used for testing, and to vary the standardized trailer b y the regulatory category . This is similar to the standardization of payload discussed above, as a way to reasonabl y reflect in

- use operating conditions. High roof tractors are optimally d esigned to pull box trailers. The roof fairing on a tractor is the feature designed to minimize the height differential between the tractor and t ypical trailer to reduce the air flow disruption. Low roof tractors are designed to carry flat bed or low

- boy trailers. Mid roof tractors are designed to carry

tanker and bulk carrier trailers. The agencies conducted a survey of tractor
- trailer pairing in

- use to evaluate the representativeness of this premise. The survey of over 3,000 tractor

- trailer combinati ons found that in 95 percent of the combination trucks the tractor’s roof height was paired appropriatel y for the type of trailer that it was pulling. 64 The agencies also have evaluated the impact of pairing a low roof tractor with a box trailer in coast down testing and found that the aerody namic force increases by

50 percent over a high roof tractor pulling the same box trailer. 65 Therefore, drivers have a large incentive to use the appropriate matching to reduce their fuel costs. However, the agencies recognize that in operation tractors sometimes pull trailers other than the ty

pe that it was designed to carry . The agencies are proposing the matching of trailers to roof height for the test procedure. To do otherwise would necessarily result in a standard reflecting substandard aerodynamic performance, and thereb y result in standards which are less stringent than would be appropriate based on the reasonable assumption that tractors will generally pair with trailer of appropriate roof height. The other a spects

63 The U.S. Feder al Highway Administration. Development of Truck Payload Equivalent Factor. Table 11. Last viewed on March 9, 2010 at http://ops.fhwa.dot.gov/freight/freight_analysis/faf/faf2_reports/reports9/s510_11_12_tables.htm 64 U.S. EPA. Truck and Trailer Roof He ight Match Analysis Memo to Docket. Docket # 65 See DRIA Chapter 2 for additional detail.74 of 54 1

of the test procedure such as empty trailer weight, location of payload, and tractor

- trailer gap are being proposed for each regulatory category to provide consistent test procedures. (iv) Standardized Drivetrain The agencies’ assessment of the current v ehicle configuration process at the truck dealer’s level is that the truck companies provide tools to specify the proper drivetrain matched to the bu yer’s specific circumstances. These dealer tools allow a significant amount of customization for drive cyc le and payload to provide the best specification for the customer. The agencies are not seeking to disrupt this process. Optimal drivetrain selection is dependent on the engine, drive cycle (including vehicle speed and road grade), and payload. Each combination of engine, drive cycle, and payload has a single optimal transmission and final drive ratio. The agencies are proposing to specify the engine’s fuel consumption map, drive cycle, and payload; therefore, it makes sense to also specify

the drivetra in that matches. (v) Engine Input to [TEST ] As the agencies are proposing separate engine and tractor standards, the [TEST] model will be used to assess the compliance of the tractor with the tractor standard. To maintain the separate assessments, the age ncies are proposing to define the engine characteristics used in [TEST], including the fuel consumption map which provides the fuel consumption at hundreds of engine speed and torque points. If the agencies did not standardize the fuel map, then a tractor that uses an engine with emissions and fuel consumption better than the standards would require fewer vehicle reductions than those technicall y feasible reductions being proposed. The agencies are proposing two distinct fuel consumption maps for use in [ TEST]. EPA proposes the first fuel consumption map would be used in [TEST] for the 2014 through 2016 model y ears and represent an average engine which meets the 2014 model year engine CO 2 emissions standards. NHTSA proposes to use the same fuel map for i ts voluntary opt
- in in the 2014 and 2015 model years, as well as its mandatory program in the 2016 model y ear. The agencies are proposing two distinct fuel consumption maps for use in [TEST]. The first fuel consumption map would be used in [TEST] for the 2014 through 2016 model y ears and represent an engine which meets the 2014 model year engine CO 2 emissions standards. A second fuel consumption map would be used beginning in 2017 model year and represents an engine which meets the 2017 model year CO 2 em issions and fuel consumption standards and accounts for the increased stringency in the proposed MY 2017 standard. Effectively there is no change in stringency of the tractor vehicle (not including the engine) and there is stability in the tractor vehicle (not including engine) standards for the full rulemaking period. 66 These inputs are appropriate given the separate proposed regulatory requirement that Class 7/8 combination tractor manufacturers use onl y certified engines.

66 As noted earlier, use of the 2017 model year fuel consumption map as a [TEST] input results in numerically more stringent proposed vehicle standards for MY 2017.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

75 of 54 1 (i ) Engine Test Procedure The NAS p anel did not specificall y discuss or recommend a metric to evaluate the fuel consumption of heavy dut y engines. However, as noted above they did recommend the use of a load specific fuel consumption metric for the evaluation of vehicles. 67 An analogous me tric for engines would be the amount of fuel consumed per unit of work. Thus, EPA is proposing that GHG emission standards for engines under the CAA would be expressed as grams of emissions per brake horsepower

- hour (g/bhp

- hr); NHTSA's proposed fuel consumption standards under EI SA, in turn, would be represented as gallons of fuel per 100 horsepower

- hour (gal/100 bhp

- hr). This metric is also consistent with EPA’s current standards for non

- GHG emissions for these engines. EPA’s criteria pollutant standards for engines require that manufacturers demonstrate compliance over a transient test cycle, the FTP; a steady - state test cycle, the SET or supplemental emissions test; and the not

- to
- exceed, or NTE test. EPA created this multi

- layered approach to criteria emissions control in response to engine designs that optimized operation for lowest fuel consumption at the expense of very high criteria emissions when operated off the regulatory cycle. EPA’s use of multiple test procedures for criteria pollutants help s to ensure that manufacturers calibrate engine s ystems for compliance under all operating conditions. With regard to GHG and fuel consumption control, the agencies believe it is more appropriate to set standards based on a single test procedure, either the FTP or SET, depending on the primary expected use of the engine. For engines used primarily in line

- haul combination tractor trailer operations, we believe the stead y - state SET procedure more appropriately reflects in

- use engine operation. By setting standards based on the most representative test cycle, we can have confidence that OEMs will design engines for the best GHG and fuel consumption performance relative to the most common ty

pe of expected engine operation. There is no incentive to design th e engines to give worse fuel consumption under other ty pes of operation, relative to the most common ty

pe of operation, and we are not concerned if manufacturers further calibrate these designs to give better in

- use fuel consumption during other operation, while maintaining compliance with the criteria emissions standards as such calibration is entirely consistent with the goals of our joint program. Further, we are concerned that setting standards based on both transient and steady

- state operating conditio ns for all engines could lead to undesirable outcomes. For example, turbocompounding is one technology that the agencies have identified as a likely approach for compliance against our proposed HHD SET standard described below. Turbocompounding is a very effective approach to lower fuel consumption under steady driving conditions ty

pified b y combination tractor trailer operation and is well reflected in testing over the SET test procedure. However, when used in driving typified by transient operation as we expect for vocational trucks and as is represented by the FTP, turbocompounding shows very little benefit. Setting an FTP

- based standard onl y for engines intended for use in combination tractor trailers could lead manufacturers to

67 See NAS Report, Note (#), at page 2

- 40.76 of 54 1

not apply turbocompounding because the full benefits are not demonstrated on the FTP even though it can be a highl y cost
- effective means to reduce GHG emissions and lower fuel consumption in more steady state applications. The current non

- GHG emissions engine test procedures also require the development of regeneration emission rates and frequency factors to account for the emission changes during a regeneration event. 68 EPA and NHTSA are proposing to exclude the CO 2 emissions and fuel consumption increases due to regeneration from the calculation of the compliance levels over the defined test procedures. We considered including regeneration in the estimate of fuel consumption and GHG emissions and have decided not to do so for two reasons. First, EPA’s existing criteria emission regulations alread y provide a strong motivation to engine manufacturers to reduce the frequency and duration of infrequent regeneration events. The very stringent 2010 NOx emission standards cannot be met by engine designs that lead to frequent and extend regeneration events. Hence, we believe engine manufacturers are already reducing regeneration emissions to the greatest degree possible. In addition to believing that regenerations are already controlled to the extent technologicall y possible, we believe that attempting to include regeneration emissions in the standard setting could lead to an inadvertently lax emissions standard. In order to include regeneration and set appropriate standards, EPA and NHTSA would have needed to project the reg eneration frequency and duration of future engine designs in the timeframe of this proposal. Such a projection would be inherentl y difficult to make and quite likely

would underestimate the progress engine manufacturers will make in reducing infrequent re generations. If we underestimated that progress, we would effectivel y be setting a more lax set of standards than otherwise would be expected. Hence in setting a standard including regeneration emissions we faced the real possibility that we would achiev e less effective CO 2 emissions control and fuel consumption reductions than we will achieve b y not including regeneration emissions. We are seeking comments regarding regeneration emissions and what approach if an y the agencies should use in reflecting re generation emissions in this program. In conclusion, for Class 7 or 8 tractors, compliance with the vehicle standard would be determined b y establishing values for the variable inputs and using the prescribed inputs in [TEST] and compliance against the e ngine standard using the SET engine cycle. The model would produce CO 2 and fuel consumption results that would be compared against EPA's and NHTSA's respective standards. (j ) Chassis

- based Test Procedure The agencies also considered proposing a chassis

- bas ed vehicle test to evaluate Class 7/8 tractors based on a laboratory test of the engine and vehicle together. A "chassis dy

namometer test" for heavy dut y vehicles would be similar to the Federal Test Procedure used today

for light

- duty

vehicles.

68 40 CFR § 86.004

- 28Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

77 of 54 1 However , the agencies decided not to propose the use of a chassis test procedure to demonstrate compliance for tractor standards due to the significant technical hurdles to implementing such a program by the 2014 model year. The agencies recognize that such test ing requires expensive, specialized equipment that is not yet widespread within the industry . The agencies have onl y identified approximately 11 heavy dut y chassis sites in the United States today

and rapid installation of new facilities to comply with mo del year 2014 is not possible. 69 In addition, and of equal if not greater importance, because of the enormous numbers of truck configurations that have an impact on fuel consumption, we do not believe that it would be reasonable to require testing of man y combinations of tractor model configurations on a chassis dynamometer. The agencies evaluated the options available for one tractor model (provided as confidential business information from a truck manufacturer) and found that the compan y offered three cab configurations, six axle configurations, five front axles, 12 rear axles, 19 axle ratios, eight engines, 17 transmissions, and six tire sizes

– where each of these options could impact the fuel consumption and CO 2 emissions of the tractor. Even using representative grouping of tractors for purposes of certification, this presents the potential for many different combinations that would need to be tested if a standard was adopted based on a chassis test procedure. While the agencies are not today pro posing the use of a complete chassis based test procedure for Class 7/8 tractors, we believe such an approach could be appropriate in the future, if more testing facilities become available and if the agencies are able to address the complexity

of tractor configurations issue described above. We request comments on the potential use of chassis based test procedures in the future whether to augment or replace the model based approach we are proposing today

. (3) Summary of proposed flexibility and credit provisi ons EPA and NHTSA are proposing two flexibility provisions specifically

for heavy duty tractor and engine manufacturers, as discussed in Section IV below. These are an averaging, banking and trading program for emissions and fuel consumption credits, as w ell as provision for credits for innovative vehicle or engine technologies which are not included as inputs to the [TEST] model or are not demonstrated on the engine SET test cycle. The agencies are proposing that credits earned b y manufacturers under th is ABT program be restricted for use to only within the same regulatory subcategory . First, relating credits between categories is tenuous because of the differences in regulatory useful lives. We want to avoid having credits from longer useful life cate gories flooding shorter useful life categories, adversel y impacting compliance with CO 2 or fuel consumption standards in the shorter useful life category , and we have not based the level

69 For comparison, engine manufacturers typically own a large number of engine dynamometer test cells for engine development and durability (up to 100 engine dynamometers per manufacturer).78 of 54 1

of the standard on such impact on compliance. Inaddition, extending the use of credits beyond these designated categories could inadvertently have major impacts on the competitive market place, and we want to avoid such results. For example, a manufacturer which has multiple engine offerings over several regulatory categ ories could mix credits across engine categories and shift the burden between them, possibly impacting the competitive market place. Similarly, integrated manufacturers which produce both engines and trucks could shift credits between engines and trucks and have a similar effect. We would like to ensure that this proposal reduces the CO2 emissions and fuel consumption but does not inadvertentl y have such impacts on the market place. However, we welcome comments on the extension of credits beyond the limit ations we are proposing. The agencies are also proposing to provide credit provisions to manufacturers for the use of innovative technologies. These would include technologies resulting in demonstrable reductions in CO 2 emissions and fuel consumption which are not accounted for in the [TEST] model or the engine test procedure. Innovative technology credits are being proposed but would be limited for use in averaging within the category in which it was generated. (4) Deferral of standards for tractor and en gine manufacturing companies that are small businesses EPA and NHTSA are proposing to defer greenhouse gas emissions and fuel consumption standards for small tractor or engine manufacturers meeting the Small Business Administration (SBA) size criteria of a small business as described in 13 CFR 121.201. 70 The agencies will instead consider appropriate GHG and fuel consumption standards for these entities as part of a future regulatory action. This includes both U.S.

- based and foreign small volume heav y dut y tractor or engine manufacturers. The agencies have identified two entities that fit the Small Business Administration (SBA) size criterion of a small business. 71 The agencies estimate that these small entities comprise less than 0.5 percent of the total he av y - dut y combination tractors in the U.S. based on Polk Registration Data from 2003 through 2007, 72 and therefore that the exemption will have a negligible impact on the GHG emissions and fuel consumption improvements from the proposed standards. To ensur e that the agencies are aware of which companies would be exempt, we propose to require that such entities submit a declaration to EPA and NHTSA containing a detailed written description of how that manufacturer qualifies as a small entity under the provis ions of 13 CFR 121.201.

70 See § 1036.150 and § 1037.150 71 The agencies have identified Ottawa Truck, Inc. and Kalmar Industries USA as two potential small tractor manufacturers. 72 M.J. Bradley. Heavy Duty Vehicle Market Analysis. May 2009.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

79 of 54 1 

### C. Heavy - Duty Pickup Trucks and Vans The primary

elements of the EPA and NHTSA programs being proposed for complete HD pickups and vans are presented in this section. These provisions also cover incomplete HD pickups and vans that ar e sold b y OEMs as cab

- chassis (chassis

- cab, box

delete, bed

- delete, cut

- away van) vehicles, and complete Class 4 pickups trucks and vans that are very

similar to complete Class 3 vehicles, as discussed in detail in Section V.E. Section II.C(1) explains th e proposed form of the CO 2 and fuel consumption standards, the proposed numerical levels for those standards, and the proposed approach to phasing in the standards over time. The proposed measurement procedure for determining compliance is discussed in Se ction II.C(2), and the proposed EPA and NHTSA compliance programs are discussed in Section II.C(3). Sections II.C(4) discusses proposed implementation flexibility provisions. Sections II.xx and II.xx. discuss additional standards and provisions for N 2 O and CH 4 emissions and for impacts from vehicle air conditioning. (1) What are the proposed levels and timing of HD pickup and van standards ? (a ) Vehicle

-Based Standards About 90 percent of Class 2b and 3 vehicles are pick

- up trucks, passenger vans, and work vans th at are sold by the original equipment manufacturers (OEMs) as complete vehicles, ready for use on the road. In addition, most of these complete HD pickups and vans are covered b y Clean Air Act vehicle emissions standards for criteria pollutants today

(i.e ., they

are chassis tested similar to light

- dut y), expressed in grams per mile. This distinguishes this category from other, larger heavy

- dut y vehicles that ty picall y have onl y the engines covered b y Clean Air Act engine emission standards, expressed in grams per brake horsepower

- hour. 73 As a result, Class 2b/3 complete vehicles share much more in common with light

- duty trucks than with other heav y - dut y vehicles. Three of these commonalities are especiall y significant: (1) over 95 percent of the HD pickups and vans sold in the U.S. are produced by Ford, General Motors, and Chry sler

– three companies with large light

- duty vehicle (LDV) and light

- duty truck (LDT) sales in the United States, (2) these companies ty pically base their HD pickup and van designs o n higher sales volume LDT platforms and technologies, often incorporating new LDT design features into HD pickups and vans at their next design cycle, and (3) at this time most complete HD pickups and vans are certified to vehicle

- based rather than engine

- based EPA standards. There is also the potential for substantial GHG and fuel consumption reductions from vehicle design improvements beyond engine changes (such as through optimizing aerody namics, weight, tires, and brakes), and the OEM is generall y responsible for both engine and vehicle design. All of these factors together suggest that it is appropriate and reasonable to set standards for the vehicle as a whole, rather than to

73 As discussed briefly in Section I and in mo re detail in Section V, this regulatory category also covers som e incomplete Class 2b/3 vehicles and some complete Class 4 vehicles.80 of 54 1

establish separate engine and vehicle GHG and fuel co nsumption standards , as is proposed for the other heavy

- duty categories. This approach for complete vehicles is consistent with Recommendation 8

- 1 of the March 2010 NAS Report, which encourages the regulation of “the final stage vehi cle manufacturers since they have the greatest control over the design of the vehicle and its major subsy stems that affect fuel consumption.” (b ) Weight

-Based Attributes In setting heav y - dut y vehicle standards it is important to take into account the great di versit y of vehicle sizes, applications, and features. That diversity reflects the variet y of functions performed by heav y - duty vehicles, and this in turn can affect the kind of technology

that is available to control emissions and re duce fuel consumption, and its effectiveness. EPA has dealt with this diversity in the past by

making weight

- based distinctions where necessary , for example in setting HDV standards that are different for vehicles above and below 10,000 lb GVWR, and in d efining different standards and useful life requirements for light

- , medium

- , and heav y - heavy dut y engines. Where appropriate, distinctions based on fuel type have also been made, though with an overall goal of remaining fuel

- neutral. The joint EPA GHG and NHTSA fuel economy rules for light

- dut y vehicles accounted for vehicle diversity in that segment by

basing standards on vehicle footprint (the wheelbase times the average track width). Passenger cars and light trucks with larger footprints are assigned numericall y higher target levels for GHGs and numericall y lower target levels for fuel econom y in acknowledgement of the differences in technology

as footprint gets larger, such that vehicles with larger footprints have an inherent t endency

to burn more fuel and emit more GHGs per mile of travel. Using a footprint

- based attribute to assign targets also avoids interfering with the ability of the market to offer a variet y of products to maintain consumer choice. In developing this pr oposal, the agencies emphasized creating a program structure that would achieve reductions in fuel consumption and GHGs based on how vehicles are used and on the work they perform in the real world, consistent with the March 2010 NAS report recommendations to be mindful of HD vehicles’ unique purposes. Despite the HD pickup and van similarities to light

- duty vehicles, we believe that the past practice in EPA’s heav y - duty program of using weight

- based distinctions in dealing with the diversity

of HD pickup and van products is more appropriate than using vehicle footprint. Weight

- based measures such as payload and towing capabilit y are key among the things that characterize differences in the design of vehicles, as well as differences in how the vehicles will be used. Vehicles in this category have a wide range of payload and towing capacities. These weight

- based differences in design and in

- use operation are the key factors in evaluating technological improvements for reducing CO 2 emis sions and fuel consumption. Payload has a particularl y important impact on the test results for HD pickup and van emissions and fuel consumption, because testing under existing EPADraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

81 of 54 1 procedures for criteria pollutants is conducted with the vehicle loaded to half of its payload capacit y (rather than to a flat 300 lb as in the light

- dut y program), and the correlation between test weight and fuel use is strong. 74 Towing, on the other hand, does not directl y factor into test weight as nothing is towed during the test. Hence onl y the higher curb weight caused b y heavier truck components would play

a role in affecting measured test results. However towing capacity can be a significant factor to consider because HD pickup truck towing capacities can be quite large, with a correspondingly large effect on design. We note too that, from a purchaser perspective, p ayload and towing capability ty picall y pla y a greater role than phy sical dimensions in influencing purchaser decisions on which heav y - duty

vehicle to buy . For passenger vans, seating capacit y i s of course a major consideration, but this correlates closely with payload weight. Although heav y - dut y vehicles are traditionally classified by their GVWR, we do not believe that GVWR is the bes t weight

- based attribute on which to base GHG and fuel consumption standards for this group of vehicles. GVWR is a function of not only payload capacit y but of vehicle curb weight as well; in fact, it is the simple sum of the two. Allowing more GHG emiss ions from vehicles with higher curb weight tends to penalize lightweighted vehicles with comparable payload capabilities by making them meet more stringent standards than they would have had to meet without the weight reduction. The same would be true for another common weight

- based measure, the gross vehicle combined weight (GCWR), which adds the maximum combined towing and payload weight to the curb weight. Similar concerns about using weight

- based attributes that include vehicle curb weight were raised in the EPA/NHTSA proposal for light

- dut y GHG and fuel econom y standards: “footprint

- based standards provide an incentive to use advanced lightweight materials and structures that would be discouraged by weight

- based standards”, and “there is less risk of ‘gaming’ (artificial manipulation of the attribute(s) to achieve a more favorable target) b y increasing footprint under footprint

- based standards than by increasing vehicle mass under weight

- based standards

—it is relativel y eas y for a manufacturer to add enough weight to a vehicle to decrease its applicable fuel econom y target a significant amount, as compared to increasing vehicle footprint.” 75 The agencies believe that using payload and towing capacities as the weight

- based attributes would avoid the above

- mentioned disincentive for the use of lightweighting technology by taking vehicle curb weight out of the standards determination. After taking these considerations into account, EPA and NHTSA have decided to propose standards fo r HD pickups and vans based on a “work factor” attribute that combines vehicle payload capacity and vehicle towing capacity , in pounds, with an

74 Section II.C(2) discusses our decision to propose that GHGs and fuel consumption for HD pickups and vans be measured u sing the same test conditions as in the existing EPA program for criteria pollutants. 75 74 FR 49685, September 28, 2009.82 of 54 1

additional fixed adjustment for four

- wheel drive (4wd) vehicles. This adjustment would account for the fact that 4wd, critical to enabling the many off

- road heav y - duty

work applications, adds roughly 500 lb to the vehicle weight. Under our proposal, target GHG and fuel consumption standards would be determined for each vehicle with a unique work factor. These tar gets would then be production weighted and summed to derive a manufacturer’s annual fleet average standards. To ensure consistency

and help preclude gaming, we are proposing that payload capacity be defined as GVWR minus curb weight, and towing capacity a s GCWR minus GVWR. We are proposing that, for purposes of determining the work factor, GCWR be defined according to SAE Recommended Practice J2807 APR2008, GVWR be defined consistent with EPA’s criteria pollutants program, and curb weight be defined as in 40 CFR § 86.1803

- 01. We request comment on the need to establish additional regulations or guidance to ensure that these terms are determined and applied consistently across the HD pickup and van industry for the purpose of determining standards. Based on anal ys is of how CO 2 emissions and fuel consumption correlate to work factor (see memorandum to the docket, xx), we believe that a straight line correlation is appropriate across the spectrum of possible HD pickups and vans, and that vehicle distinction s such as Class 2b vs. Class 3 need not be made in setting standards levels for these vehicles. We request comment on this proposed approach. We note that payload/towing

- dependent gram per mile and gallon per 100 mile standards for HD pickups and vans par allel the gram per ton

- mile and gallon per 1000 ton
- mile standards being proposed for Class 7/8 combination tractors and for vocational trucks. Both approaches account for the fact that more work is done, more fuel is burned, and more CO 2 is emitted in mo ving heavier loads than in moving lighter loads. Both of these load

- based approaches avoid penalizing truck designers wishing to reduce GHG emissions and fuel consumption by reducing the weight of their trucks. However, the sizeable diversity

in HD work truck and van applications, which go well beyond simply transporting freight, and the fact that the curb weights of these vehicles are on the order of their payload capacities, suggest that setting simple gram/ton

- mile and gallon/ton

- mile standards for the m are not appropriate. Even so, we believe that our proposal of payload

based standards for HD pickups and vans is consistent with the NAS Report’s recommendation in favor of load

- specific fuel consumption standards. These attribute

- based CO 2 and fuel co nsumption standards are meant to be relativel y consistent from a stringency perspective. Vehicles across the entire range of the HD pickup and van segment have their respective target values for CO 2 emissions and fuel consumption, and therefore all HD pic kups and vans would be affected by the standard. With the proposed attribute

- based standards approach, EPA and NHTSA believe there should be no significant effect on the relative distribution of vehicles with differing capabilities in the fleet, which means that buy ers should still be able to purchase the vehicle that meets their needs.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

83 of 54 1 (c) Proposed Standards The agencies are proposing standards based on a technology anal ys is performed by EPA to determine the appropriate HD pickup and van standards. This ana ly sis, described in detail in Draft RIA Chapter 2, considered:

 the level of technology that is incorporated in current new HD pickups and vans,  the available data on corresponding CO 2 emissions and fuel consumption for these vehicles,  technologies that w ould reduce CO 2 emissions and fuel consumption and that are judged to be feasible and appropriate for these vehicles through the 2018 model y ear,  the effectiveness and cost of these technologies for HD pickup and vans,  projections of future U.S. sales fo r HD pickup and vans, and  forecasts of manufacturers’ product redesign schedules. Based on this analy sis, EPA is proposing the CO 2 attribute

- based target standards shown in Figure II
- 2 and II

- 3, and NHTSA is proposing the equival ent attribute

- based fuel consumption target standards, also shown in Figure II
- 2 , applicable in model year 2018

. Th ese figures also shows phase

- in standards for model y ears before 2018, and their derivation is explained below, al ong with alternative implementation schedules to ensure equivalency

between the EPA and NHTSA programs while meeting statutory obligations. Also , f

or reasons discussed below, separate targets are being established for gasoline

- fueled (and any other Otto

- cycle) vehicles and diesel

- fueled (and an y other Diesel

- cycle) vehicles. The targets would be used to determine the production

- weighted standards that appl y to the combined diesel and gasoline fleet of HD pickups and vans produced b y a manufacturer in ea ch model ye ar.84 of 54 1 300 350 400 450 500 550 600 650 700 750 800

0 1000 2000 3000 4000 5000 6000 7000 8000 9000 10000 Work Factor (pounds)CO2 (grams per mile)

2.95 3.95 4.95 5.95 6.95Fuel Consumption (gallons per 100 miles)
Diesel Vehicles 2015 2014

2018 2016

2017

Figure II - 2 : Proposed EPA CO2 Target Standards and NHTSA Fuel Consumption Ta rget Standard s for Diesel HD Pickups and Vans 76

76 The NHTSA proposal provides a voluntary opt

- in for model years 2014 and 2015. Target line functions for 2016

- 2018 are for the second NHTSA alternative described in Section II.C(d)(ii).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

85 of 54 1 300 350 400 450 500 550 600 650 700 750 800

0 1000 2000 3000 4000 5000 6000 7000 8000 9000 10000 Work Factor (pounds)CO2 (grams per mile)

3.38 4.38 5.38 6.38 7.38 8.38Fuel Consumption (gallons per 100 miles)

Gasoline Vehicles

2018 2017 2015 2014

2016

Figure II - 3 : Pr oposed EPA CO2 Target Standards and NHTSA Fuel Consumption Ta rget Standard s for Gasoline HD Pickups and Vans 77 Described mathematically , EPA’s and NHTSA’s proposed functions are defined by the following formulae: EPA CO 2 Target (g/mile) = [a x WF ] + b NHTSA Fuel Consumpti on Target (gallons/100 miles) = [c x WF] + d Where: WF = Work Factor = [0.75 x (Payload Capacity + xwd)] + [0.25 x Towing Capacity] Payload Capacit y = GVWR (lbs)

– Curb Weight (lbs ) xwd = 500 lbs if the vehicle is equip ped with 4wd, o therwise equals 0 lbs Towing Capacit y = GCWR (lbs)

– GVWR (lbs )

77 The NHTSA proposal provides a voluntary opt

- in for model years 2014 and 2015. Target line functions for 2016

- 2018 are for the second NHTSA alternative described in Section II.C(d)(ii).86 of 54 1 Coefficients a, b, c, and d are taken from Table II
- 7 or Table II

- 8. Table II - 7 : Coef

ficients for Proposed HD Pickup and Van Target Standards 78 Diesel Vehicles model yr a b c d 2014 0.

0478 36

8 0.00047

0 3.6

2 2015 0.

0474 36

6 0.00046

6 3.5

9 2016 0.

0460 35

4 0.00045

2 3.4

8 2017 0.

0445 34

3 0.00043

7 3.3

7 2018 0.

0416 32

0 0.00040

8 3.1

5 Gasoline Vehicles model yr a b c d 20 14 0.

0482 37

1 0.00047

3 3.6

5 2015 0.

0479 36

9 0.00047

1 3.6

3 2016 0.

0469 36

2 0.00046

1 3.5

5 2017 0.

0460 35

4 0.00045

2 3.4

8 2018 0.

0440 33

9 0.00043

2 3.3

3

Table II
- 8: Coef

ficients Proposed for NHTSA’s First Alternative and EPA’s Alternativ e HD Pickup and Van Target Standards

78 The NHTSA pr oposal provides a voluntary opt

- in for model years 2014 and 2015. Target line functions for 2016

- 2018 are for the second NHTSA alternative described in Section II.C(d)(ii).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

87 of 54 1 Diesel Vehicles model yr a b c d 2014(a) 0.047

8 36

8 0.00047

0 3.6

2 2015(a) 0.047

4 36

6 0.00046

6 3.5

9 2016
- 2018 0.044 0 33

9 0.00043

2 3.3

3 2019 (b) 0.041

6 32

0 -- -- Gasoline Vehicles model yr a b c d 2014(a) 0.048

2 3 7

1 0.00047

3 3.6

5 2015(a) 0.047

9 36

9 0.00047

1 3.6

3 2016
- 2018 0.045 6 35

2 0.00044

8 3.4

5 2019 (b) 0.044

0 33

9 -- -- (a) NHTSA standards would be voluntary in 2014 and 2015 (b) There are no proposed NHTSA standards in 2019
These targets are based on a set of vehicl e, engine, and transmission technologies assessed b y the agencies and determined to be feasible and appropriate for HD pickups and vans in the 2014

- 2018 timeframe. Much of the information used to make this technology

assessment was developed for the recent 2012

- 2016 light

- dut y GHG and fuel econom y rulemaking. See Section III.A for a detailed anal ys is of these vehicle, engine and transmission technologies, including their feasibility , costs, and effectiveness in HD pickups and vans

. To calculate a manufact

urer’s HD pickup and van fleet average standard, the agencies are proposing that separate target curves be used for gasoline and diesel vehicles. The agencies estimate that in 2018 the target curves will achieve 15 and 10 percent reductions in CO 2 and fuel consumption for diesel and gasoline vehicles, respectivel y, relative to a common baseline for current (model ye ar 2010) vehicles. An additional two percent reduction in GHGs would be achieved b y the EPA program from a proposed direct air conditioning leakage standard. These reductions are based on the agencies’ assessment of the feasibility of incorporating technologies (which differ significantl y for gasoline and diesel powertrains) in the 2014

- 2018 model years, and on the differences in relative effici ency in the current gasoline and diesel vehicles. The resulting reductions represent roughl y equivalent stringency levels for gasoline and diesel88 of 54 1

vehicles, which is important in ensuring our proposed program maintains product choices available to vehicle buyers. The NHTSA fuel consumption target curves and the EPA GHG target curves are equivalent. The agencies established the target curves using the direct relationship between fuel consumption and CO 2 using conversion factors of 8887 g CO 2 /gallon for gaso line and 10,180 g CO 2 /gallon for diesel fuel. It is expected that measured performance values for CO 2 would generall y be equivalent to fuel consumption. However, as explained in section II.xx ,EPA is proposing an alternative for manufacturers to demonstrate compliance with N 2 O and CH 4 emissions standards through the calculation of a CO 2 - equivalent emissions level that would be compared to the CO 2 - based standards, similar to the recentl y promulgated light

duty GHG standards for model y ears 2012

- 2016. For t est families that do not use this compliance alternative, the measured performance values for CO 2 and fuel consumption would be equivalent because the same test runs and measurement data would be used to determine both values, and calculated fuel consumpti on would be based on the same conversion factors that are used to establish the relationship between the CO 2 and fuel consumption target curves (8887 g CO 2 /gallon for gasoline and 10,180 g CO 2 /gallon for diesel fuel). In this case, for example, if a manuf acturer’s fleet average measured compliance value exactly meets the fleet average CO 2 standard, it will also exactly meet the fuel consumption standard. The proposed NHTSA fuel consumption program will not use a CO 2 - equivalent metric. Measured performan ce to standards would be based on the measurement of CO 2 with no adjustment for N 2 O and CH 4 . For manufacturers that choose to use the EPA CO 2 - equivalent approach, compliance with the CO 2 standard would not be directl y equivalent to compliance with the NHT SA fuel consumption standard. (d ) Proposed Implementation Plan (i ) EPA Program Phase

- in 2014

- 2018 EPA is proposing that the GHG standards be phased in graduall y over the 2014

- 2018 model years, with full implementation effective in the 2018 model year. Therefore, 100 percent of a manufacturer’s vehicle fleet would need to meet a fleet

- average standard that would become increasingl y more stringent each year of the phase

- in period. For both gasoline and diesel vehicles, this phase

- in would be 15

- 20

- 40

- 60

- 100 percent in model years 2014

- 2015

- 2016

- 2017

- 2018, respectively

. These percentages reflect stringency

increases from a baseline performance level for model year 2010, determined by the agencies based on EPA and manufacturer data. Because these vehicles are not c urrentl y regulated for GHG emission s, this phase

- in takes the form of target line functions for gasoline and diesel vehicles that become increasingl y stringent over the phase

- in model years. These y ear - by

- ye ar functions have been derived in the same way a s the 2018 function, b y t aking a percent reduction in CO 2 from a common unregulated baseline. For example, in 2014 the reduction for both diesel and gasoline vehicles would be 15% of the fully

- phased

- in reductions (15% of 10%). Figures II

- 2 and II

- 3, and Table II
- 7, reflect this phase

- in approach.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

89 of 54 1 EPA is also proposing to provide manufacturers with an optional alternative implementation schedule in model years 2016 through 2018, equivalent to NHTSA’s proposed first alternative for standards that do not ch ange over these model years, described below. Under this option the phase

- in would be 15

- 20

- 67

- 67

- 67

- 100 percent in model years 2014

- 2015

- 2016

- 2017

- 2018

- 2019, respectivel y. Table II

- 8 provides the coefficients, a and b, for this manufacturer’s alternativ e. As explained below, the stringency

of this alternative was established b y NHTSA such that a manufacturer with a stable production volume and mix over the model y ear 2016

- 2018 period could use Averaging, Banking and Trading to comply with either alternative and have a similar credit balance at the end of model year 2018. Under the above

- described alternatives, each manufacturer would need to demonstrate compliance with the applicable fleet average standard using that year’s target function over all of it s HD pickups and vans starting in 2014. EPA also request comment on different regulatory approach to the phase

- in, intended to reduce the testing and certification burden on manufacturers during the 2014

- 2017 phase

- in years , while achieving GHG reductions on the same schedule as the proposed phase

- in. In this alternative approach, each manufacturer would be required to demonstrate compliance with the final 2018 targets , but only over a predefined percentage of its HD pickup and van production. The remain ing vehicles produced each ye ar would not be regulated for GHGs. Thus th is approach would have the effect of setting final standards in 2014 that do not vary

over time, but with an annually increasing set of regulated vehicles. The percentage of regulate d vehicles would increase each year, to 100 percent in 2018. We think it likely

that manufacturers would leave the highest emitting vehicles unregulated for as long as possible under this approach, because these vehicles would tend to be the costliest to redesign or may simpl y be phasing out of production. We therefore expect that, to be equivalent, the percentage penetration each ye ar would be higher than the 15

- 20

- 40

- 60 percent penetrations required under the proposed approach. EPA requests comment on this regulatory alternative, and on what percentage penetrations are appropriate to achieve equivalent program benefits. (ii) NHTSA Program Phase

- in 2016

- 2018 NHTSA is proposing to allow manufacturers to select one of two fuel consumption standard alternatives fuel consumption standards for model years 2016

- 2018 , as well as a manufacturer’s phase

- in alternative, involving voluntary standards in 2014

- 2015 . Manufacturers would select an alternative at the same time they submit the model year 2016 Pre

- Certificatio n Compliance Report; and, once selected, the alternative would apply

for model years 2016

– 2018, and could not be reversed. To meet the EISA statutory requirement for three years of regulatory stability , the first alternative would define a fuel consumpt ion target line function for gasoline vehicles and a target line function for diesel vehicles that would not change over model years 2016 and 2018. The proposed target line function coefficients are provided in Table II

- 7. The second alternative would b e equivalent to the EPA target line functions in each model ye ar 2016 to 2018. Stringency of fuel consumption standards would increase graduall y over the 201 6

- 2018 model years . Relative to a model year 2010 unregulated90 of 54 1

baseline, f

or both gasoline and die sel vehicles, stringency would be 40

- 60

- 100 percent of the 2018 target line function in model years 2016

- 2017

- 2018, respectively

. The stringency

of the target line functions in the first alternative is 67 percent of the 2018 stringency

in the second alte rnative. The stringency of the first alternative was established so that a manufacturer with a stable production volume and mix over the model year 2016

- 2018 period, could use Averaging, Banking and Trading to comply with either alternative and have a sim ilar credit balance at the end of model ye ar 2018. NHTSA also requests comment on a different regulatory approach that would parallel the above

- described EPA regulatory alternative involving certification of a pre

defined percentage of a manufacturer’s HD pickup and van production. (iii) NHTSA Voluntary Standards Period NHTSA is proposing that manufacturers may voluntarily

opt into the NHTSA HD pickup and van program in model y ears 2014 or 2015. If a manufacturer elects to opt into the program, the program would become mandatory and the manufacturer would not be allowed to reverse this decision. To opt into the program, a manufacturer must declare its intent to opt in to the program at the same time it submits the Pre

- Certification Compliance Report. See propos ed regulatory text for 49 CFR Part 535.8 for information related to the Pre

- Certification Compliance Report. If a manufacturer elects to opt into the program in 2014, the program would be mandatory for 2014 and 2015. A manufacturer would begin tracking c redits and debits beginning in the model y ear in which they

opt into the program. The handling of credits and debits would be the same as fort the mandatory

program and would continue through 2018. For manufacturers that opt into NHTSA’s HD pickup and van fuel consumption program in 2014 or 2015, the stringency would increase gradually each model year. Relative to a model y ear 2010 unregulated baseline, f or both gasoline and diesel vehicles, stringency would be 15

- 2 0 percent of the model y ear 2018 target line function (under the NHTSA second alternative) in model years 201 4

- 201 5, respectivel y. The corresponding absolute standards targets levels are provided in Figure II
- 2 , and the accompanying equations. NHTSA also requests comment on a different regulatory approach that would parallel the above

- described EPA regulatory alternative involving certification of a pre

defined percentage of a manufacturer’s HD pickup and van production. (2) What are the proposed HD pickup and van test cy cles and procedures? EPA and NHTSA are proposing that HD pickup and van testing be conducted using the same heav y - duty chassis test procedures currentl y used b y EPA for measuring criteria pollutant emissions from these vehicles, but with the addition of th e highway fuel econom y test cycle (HFET) currently required only for light

- dut y vehicle GHG emissions and fuel economy

testing. Although the highway cycle driving pattern would be identical to that of the light

- dut y test, other test parameters for running the HFET, such as testDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

91 of 54 1 vehicle loaded weight, would be identical to those used in running the current EPA Federal Test Procedure for complete heav y - dut y vehicles. The GHG and fuel consumption results from vehicle testing on the FTP and the HFET would be w eighted by 55 percent and 45 percent, respectively , and then averaged in calculating a combined cycle result. This result corresponds with the data used to develop the proposed work factor

- based CO 2 and fuel consumption standards, since the data on the ba seline and technology efficiency

was also developed in the context of these test procedures. The addition of the HFET and the 55/45 cycle weightings are the same as for the light

- dut y CO 2 and CAFE programs, as we believe the real world driving patterns fo r HD pickups and vans are not too unlike those of light

- dut y trucks, and we are not aware of data specifically on these patterns that would lead to a different choice of cycles and weightings. More importantly , we believe that the 55/45 weightings will pr ovide for effective reductions of GHG emissions and fuel consumption from these vehicles, and that other weightings, even if they were to more precisel y match real world patterns, are not likely

to significantl y improve the program results. Another important parameter in ensuring a robust test program is vehicle test weight. Current EPA testing for HD pickup and van criteria pollutants is conducted with the vehicle loaded to its Adjusted L oaded Vehicle Weight (ALVW), that is, its curb weight plus 1⁄2 of the payload capacit y. This is substantially more challenging than loading to the light

- duty

vehicle test condition of curb weight plus 300 pounds, but we believe that this loading for HD pickups and vans to 1⁄2 payload better fits their usage in the real world and would help ensure that technologies meeting the standards do in fact provide real world reductions. The choice is likewise consistent with use of an attribute based in considerable part on payload for the standard. We see no reason to set test load c onditions differentl y for GHGs and fuel consumption than for criteria pollutants, and we are not aware of an y new information (such as real world load patterns) since the ALVW was originally

set this way

that would support a change in test loading conditio ns. We are therefore proposing to use ALVW for test vehicle loading in GHG and fuel consumption testing. EPA and NHTSA request comment on the proposed test cycles, weighting factors, test loading conditions, and other factors that are important for establ ishing an effective GHG and fuel consumption test program. Additional provisions for our proposed testing and compliance program are provided in Section V.E. (3) How are the HD pickup and van standards structured? EPA and NHTSA are proposing fleet average standards for new HD pickups and vans , based on a manufacturer’s new vehicle fleet makeup. In addition, EPA is proposing in

- use standards that would apply to the individual vehicles in this fleet over their useful lives. The compliance provisions for these proposed fleet average and in

- use standards for HD pickups and vans are largely based on the recentl y promulgated light

duty GHG and fuel economy

program, as described below and in greater detail in Section V.E.92 of 54 1 (a ) Fleet Average Standards In this proposal we outline how each manufacturer would have a GHG standard and a fuel consumption standard unique to its new HD pickup and van fleet in each model year, depending on the load capacities of the vehicle models produced by that manufacturer, and on the U.S.

- dire cted production volume of each of those models in that model year. Vehicle models with larger payload/towing capacities would have individual targets at numerically

higher CO 2 and fuel consumption levels than lower payload/towing vehicles would, as discus sed in Section II.C(1). The fleet average standard for a manufacturer would be a production

- weighted average of the work factor

- based targets assigned to unique vehicle configurations within each each model t ype produced b y the manuf acturer in a model year. The fleet average standard with which the manufacturer must compl y would be based on its final production figures for the model year, and thus a final assessment of compliance would occur after production for the model y ear ended. Because compliance with the fleet average standards depends on actual test group production volumes, it is not possible to determine compliance at the time the manufacturer applies for and receives an EPA certificate of conformit y for a test group. Instea d, at certification the manufacturer would demonstrate a level of performance for vehicles in the test group, and make a good faith demonstration that its fleet, regrouped b y unique vehicle configurations within each model ty pe, is expected to comply with its fleet average standard when the model year is over. EPA would issue a certificate for the vehicles covered b y the test group based on this demonstration, and would include a condition in the certificate that if the manufacturer does not comply with th e fleet average, then production vehicles from that test group will be treated as not covered b y the certificate to the extent needed to bring the manufacturer’s fleet average into compliance. As in the light

- duty program, additional “model ty pe” testing would be conducted b y the manufacturer over the course of the model ye ar to supplement the initial test group data

. T he emissions and fuel consumption level s of the test vehicles would be us ed to calculate the production

- weighted fleet average s for the manufacturer , after application of the appropriate deterioration factor to each result to obtain a full useful life value. See generall y 75 FR at 25470

- 72. EPA and NHTSA do not currentl y anticipate notable deterioration of CO 2 emissions and fuel consumption performance, and are therefore proposing that an assigned deterioration factor be applied at the time of certification: an additive assigned deterioration factor of zero, or a multiplicative factor of one would be used. EPA and NHTSA anticipate that the deterioration factor would be updated from time to time, as new data regarding emissions deterioration for CO 2 are obtained and anal yz ed. Additionally , EPA and NHTSA may consider technology

- specific deterioration factors, should data indicate that certain control technologies deteriorate differentl y than others. See also 75 FR at 25474.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

93 of 54 1 (b ) In

- Use Standards Section 202(a)(1) of the Clean Air Act specifies that EPA set emissions standards that are applicable for the useful life of the vehicle. The in

- use standards that EPA is proposing would appl y t o individual vehicles. NHTSA is not proposing to adopt in

- use standards because it is not required under EISA, and because it is not currently anticipated that there will be an y notable deteri oration of fuel consumption. For the EPA proposal, compliance with the in

- use standard for individual vehicles and vehicle models will not impact compliance with the fleet average standard, which will be based on the production weighted average of the new vehicles. EPA is proposing that the in

- use standards for HD pickups and vans be established by

adding an adjustment factor to the full useful life emissions and fuel consumption results used to calculate the fleet average. EPA is al so proposing that the useful life for these vehicles with respect to GHG emissions be set equal to their useful life for criteria pollutants: 11 y ears or 120,000 miles, whichever occurs first (40 CFR 86.1805

- 04(a)). As discussed above, we are proposing th at certification test results obtained before and during the model year be used directly to calculate the fleet average emissions for assessing compliance with the fleet average standard. Therefore this assessment and the fleet average standard itself do n ot take into account test

- to
- test variability and production variability

that can affect measured in

- use levels. For this reason is proposing an adjustment factor for the in

- use standard to provide some margin for production and test
- to
- test variability

that could result in differences between the initial emission test results used to calculate the fleet average and emission results obtained during subsequent in

- use testing. EPA is proposing that each model’s in

- use CO 2 standard would be the model

- specifi c level used in calculating the fleet average, plus 10 percent. This is the same as the approach taken for light

- duty vehicle GHG in

- use standards. 79 NHTSA is proposing that the same 10 percent margin be applied to the model

- specific fuel consumption leve ls used in calculating the fleet average fuel consumption. As it does now for heav y - duty vehicle criteria pollutants, EPA would use a variet y of mechanisms to conduct assessments of compliance with the proposed in

- use standards, including pre

- production ce rtification and in

- use monitoring once vehicles enter customer service. The full useful life in

- use standards would apply to vehicles that had entered customer service. The same standards would apply to vehicles used in pre

- producti on and production line testing, except that deterioration factors would not be applied. (4) What HD pickup and van flexibility provisions are being proposed? This proposal contains substantial flexibility in how manufacturers can choose to implement the EPA an d NHTSA standards while preserving their timel y benefits for the environment and energy

securit y. Primary among these flexibilities are the gradual

79 75 FR at 25473

- 74.94 of 54 1

phase

- in schedule, alternative compliance paths, and corporate fleet average approach described above. Add itional flexibility provisions are described briefl y here and in more detail in Section IV. As explained in Section II.C(3), we are proposing that at the end of each model ye ar, when production for the model year is complete, a manufacturer calculate its production

- weighted fleet average CO 2 and fuel consumption. Under this proposed approach, a manufacturer’s HD pickup and van fleet that achieves a fleet average CO 2 or fuel consumption level better than its standard would be allowed to generate credits. Conversel y, if the fleet average CO 2 or fuel consumption level does not meet its standard, the fleet would incur debits (also referred to as a shortfall). A manufacturer whose fleet generates credits in a given model ye ar would have several options for usi ng those credits to offset emissions from other HD pickups and vans. These options include credit carry

- back, credit carry

- forward, and credit trading. These provisions exist in the 2012

- 2016 light

- dut y vehicle National Program, and similar provisions are part of EPA’s Tier 2 program for light

- dut y vehicle criteria pollutant emissions, as well as many other mobile source standards issued by EPA under the Clean Air Act. The manufacturer would be able to carry back credits to offset a deficit that had accru ed in a prior model year and was subsequently carried over to the current model ye ar, with a limitation on the carry

- back of credits to three years, consistent with the light

- duty program. We are proposing that, after satisfying an y need to offset pre

exi sting deficits, a manufacturer may bank remaining credits for use in future years. This averaging, banking, and trading program for HD pickups and vans is discussed in more detail in Section IV.D. We are not proposing any credit transferabilit y to or fro m other credit programs, such as the light

- dut y GHG and fuel consumption programs or the proposed heav y - dut y engine ABT program. Consistent with the President’s May 21, 2010 directive to promote advanced technology

vehicles, we are also proposing two other flexibility provisions that parallel similar provisions adopted in the light

- duty program. (1) Advanced technology credits (detailed in Section IV.D) for electric vehicles, plug

- in electric vehicles, and fuel cell vehicles would be made available in the 2014 through 2018 model y ears. (2) Off

- cycle technology

credits (also detailed in Section IV.D) would be provided starting in the 2014 model year for innovative technologies shown b y the manufacturer to provide GHG and fuel consumption reductions in real world driving, but not on the test. Our proposed approach to recognizing the benefits of flexible

- fueled vehicles (FFVs) and dedicated alternative

- fueled vehicles is also based on the approach taken by EPA in the light

- duty

vehicle rule for later models ye ars, but, unlike in that rule, we are not referring to it as a credits provision because it does not include the incentives mandated in EISA for light

- duty vehicles only . In fact, since heavy dut y vehicles were not included in the EI SA incentives for FFVs , manufacturers did not produce FFV heavy duty vehicles. These provisions are discussed in detail in Section V.E. We are also not referring to our proposed treatment of air conditioning improvements as credits provisions for reasons explained in Section I I.xx.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

95 of 54 1 

### D. Class 2b - 8 Vocational Trucks Class 2b

- 8 vocational trucks (i.e. vehicles) consist of a very wide variety

of configurations including delivery , refuse, utility , dump, cement, transit bus, shuttle bus, school bus, emergency

vehicle, motor homes, 80 and tow trucks, among others. The agencies are defining that Class 2b

- 8 vocational vehicles are all heav y - duty vehicles which are not included in the Heav y Dut y Pickup Truck and Van or the Class 7/8 Tractor segments, with the exception of vehicles for which the agencies are deferring setting of standards, such as small business manufacturers. In addition, recreational vehicles are included under EPA’s proposed standards but are not included under NHTSA’s proposed standards. As mentioned in Section I, vocatio nal trucks undergo a complex build process. Often an incomplete chassis is built by a chassis manufacturer with an engine purchased from an engine manufacturer and a transmission purchased from another manufacturer. A body manufacturer purchases an incomplete chassis which is then completed by attaching the appropriate features to the chassis. The agencies face difficulties in establishing the baseline CO 2 and fuel consumption performance for the wide variety of vocational trucks which makes it difficul t to try

and set different standards for a large number of potential regulatory categories. The diversit y in the vocational vehicle segment can be primarily attributed to the variet y of vehicle bodies rather than the chassis. For example, a body builder can build either a Class 6 bucket truck or a Class 6 delivery truck from the same Class 6 chassis. The aerodynamic difference between these two vehicles due to their bodies will lead to different baseline fuel consumption and GHG emissions. However, the baseline fuel consumption and emissions due to the components included in the common chassis (such as the engine, drivetrain, frame, and tires) will be the same between these two types of complete vehicles. Furthermore, the agencies evaluated the aerodynamic improvement opportunities for vocational vehicles. For example, the aerodynamics of a fire truck are impacted significantly

by the equipment such as ladders located on the exterior of the truck. The agencies found little opportunity to improve the ae rod ynamics of the equipment on the truck. The agencies also evaluated the aerodyn amic opportunities discussed in the NAS report. The panel found that there was no fuel consumption reduction opportunity

through aerod yn amic technologies for bucket trucks, transit buses, and refuse trucks 81 primarily due to the low vehicle speed in normal operation. The panel did report that there are opportunities to reduce the fuel consumption of straight trucks b y approximately

1 percent for trucks which operate at the av erage speed t ypi cal of a pickup and delivery

truck (30 mph), although the opportunity is greater for trucks which operate at higher speeds. 82 To overcome the lack of baseline information from the different vehicle applications without sacrificing much fuel consumption or GHG emission

80 See above for discussion of applicability of NHTSA’s sta ndards to non

- commercial vehicles. 81 NAS Report. Page 6

- 3. 82 NAS Report, Page 5

- 29.96 of 54 1

reduction potential, the agencies propose to set standards for the chassis manufacturers of vocational vehicles (instead of the body builders) and the engine manufacturers. EPA is proposing CO 2 standards and NHTSA is proposi ng fuel consumption standards for manufacturers of chassis for new vocational vehicles and for manufacturers of heav y dut y engines installed in these vehicles. The proposed heav y dut y engine standards for CO 2 emissions and fuel consumption would focus on potential technological improvements in fuel combustion and overall engine efficiency and those proposed controls would achieve most of the emission reductions. Further reductions from the class 2b

- 8 vocational vehicle itself are possible within the timefr ame of these proposed regulations. Therefore, the agencies are also proposing separate standards for vocational vehicles that will focus on additional reductions that can be achieved through improvements in vehicle tires. The agencies' analy ses, as discus sed briefly below and in more detail later in this preamble and in the Draft RIA Chapter 2 , show that these standards are appropriate under each agency ’s respective statutory authoritie s. Together these standards are estimated to achieve reductions up to 1 1 percent from vocational trucks. EPA is also proposing standards to control N 2 O and CH 4 emissions from Class 2b

- 8 vocational trucks. The proposed heav y dut y engine standards for both N 2 O and CH 4 and details of the standard are included in the discussion in II. E. EPA is not proposing air conditioning leakage standards appl yi ng to chassis manufacturers to address HFC emissions. As discussed further below, the agencies propose to set CO 2 and fuel consumption standards for these chassis based on tire rolling resistance improvements and for the engines based on engine technologies. The fuel consumption and GHG emissions impact of tire rolling resistance is impacted by the mass of the vehicle. However the impact of mass on rolling resistance is relativel y small so the agencies propose to aggregate several vehicle weight categories under a single category for setting the standards. The agencies propose to divide the vocational vehicle segment into three broad regulatory categories

- Li ght Heav y (Class 2b through 5), Medium Heav y (Class 6 and 7), and Heavy Heav y (Class 8) which is consistent with the nomenclature used in the diesel engine classification. The agencies are interested in comment on this segmentation strategy (subcatego rization). As the agencies move towards future heavy duty fuel consumption and GHG regulations for post

- 2017 model years, we intend to gather GHG and fuel consumption data for specific vocational applications which could be used to establish application

- s pecific standards in the future. (1) What are the proposed CO 2 and Fuel Consumption standards and their timing? In developing the proposed standards, the agencies have evaluated the current levels of emissions and fuel consumption, the kinds of technologies th at could be utilized by manufacturers to reduce emissions and fuel consumption and the associated lead time, the associated costs for the industry , fuel savings for the consumer, and the magnitude of the CO 2 and fuel economy savings that may be achieved. The technologies that theDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

97 of 54 1 agencies considered while setting the proposed vehicle

- level standards include improvements in lower rolling resistance tires. The technologies that the agencies considered while setting the engine standards include engine fricti on reduction, aftertreatment optimization, among others. The agencies’ evaluation indicates that these technologies are available today in the heav y dut y tractor and light

- dut y vehicle markets, but have very

low application rates in the vocational market. The agencies have anal yz ed the technical feasibility of achieving the proposed CO 2 and fuel consumption standards, based on projections of what actions manufacturers would be expected to take to reduce emissions and fuel consumption to achieve the standards, and believe that the proposed standards are appropriate, cost

- effective, and technologicall y feasible within the rulemaking time frame. EPA and NHTSA also present the estimated costs and benefits of the proposed vocational truck standards in Section III. (a ) Proposed Chassis Standards EPA is proposing the following CO 2 standards for the 2014 model y ear for the Class 2b through Class 8 vocational truck chassis. Similarly , NHTSA is proposing the following fuel consumption standards for the 2016 model year, with a voluntary opt
- in program offered beginning in the 2014 model ye ar. For the EPA GHG program, the proposed standard applies throughout the useful life of the vehicle. EPA and NHTSA proposing more stringent vehicle standards for the 2017 model ye ar which reflect the CO 2 emissions reductions required through the 2017 model year engine standards. (As explained in Section B. (2) (h)(v) above, engine performance is one of the inputs into the compliance model, and that inp ut will change in 2017 to reflect the 2017 MY engine standards.) The 2017 MY vehicle standards are not premised on manufacturers installing additional vehicle technologies.98 of 54 1 Table II - 8 : Proposed Class 2b - 8 Vo cational Truck CO 2 and Fuel Consumption Standards EPA CO 2 (gram/ton

- mile) Standard Effective 2014 Model Year

Li ght Heav y Class 3

- 5 Medium Heav y

Class 6

- 7 Heav y Heav y

Class 8 CO 2 Emissions 420 249 101 NHTSA Fuel Consumption (gallon per 1000 ton

- mile) Standard Effective 2016 Model Year 83 Li ght Heav y

Class 3

- 5 Medium Heav y

Class 6

- 7 Heav y Heav y

Class 8 Fuel Consumption 41.3 24.5 9.9 EPA CO 2 (gram/ton

- mile) Standard Effective 2017 Model Year

Li ght Heav y Class 3

- 5 Medium Heav y

Class 6

- 7 Heav y Heav y

Class 8 CO 2 Emissions 404 240 100 NHTSA Fuel Consumption (gallon per ton

- mile) Standard Effective 2017

- 18 Model Year

Li ght Heav y Class 3

- 5 Medium Heav y

Class 6

- 7 Heav y Heav y

Class 8 Fuel Consumption 39.7 23.6 9.8 (i ) Off

-Road Vo cational Truck Standards In developing the proposal EPA and NHSTA received comment from manufacturers and owners that trucks sometimes have very limited on

- road usage. These trucks by definition of Title 40, Part 85.1703 are motor vehicles, but will spend the majority of their operations off

- road. Trucks, such as those used in oil fields, will experience little benefit from low rolling resistance tires. The agencies are therefore proposing to allow a narrow range of these de facto off

- road trucks to be exc luded from the proposed vocational truck standards because the trucks require special off

- road tires such as lug tires. The trucks must still use a certified engine, which will provide fuel consumption and CO 2 emission reductions to the truck in all appli cations. To insure the limited use of these trucks, the agencies are proposing requirements that the vehicles have off

- road tires, have limited high speed operation, and are designed for specific off

- road applications. The agencies are proposing that a truck must meet the following requirements to qualify

for an exemption from the vehicle standards for vocational trucks:

 Installed tires which are lug tires or contain a speed rating of less than or

equal to 60 mph; and

 In clude a vehicle speed limiter gover ned to 55 mph.

83 Manufacturers may voluntarily opt

- in to the NHTSA fuel consumption program in 2014 or 2015. If a manufacturer opts

- in, the program becomes mandatory.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

99 of 54 1 EPA and NHTSA have concluded that the onroad performance losses and additional costs to develop a truck which meets these specifications will limit the exemption to trucks built for the desired purposes. The agencies welcome comment on the proposed requirements and exemptions. (b ) Proposed Heavy Duty Engine Standard s EPA is proposing GHG standards 84 and NHTSA is proposing fuel consumption standards for new heav y duty engines installed in vocational trucks. The standards will vary depending on wh ether the engines are diesel or gasoline powered. The agencies' anal ys es, as discussed briefly below and in more detail later in this preamble and in the Draft RIA Chapter 2 , show that these standards are appropriate and feasible under each agency ’s respe ctive statutory authorities. The agencies have anal yzed the feasibility of achieving the GHG and fuel consumption standards, based on projections of what actions manufacturers are expected to take to reduce emissions and fuel consumption. EPA and NHTSA also present the estimated costs and benefits of the heav y dut y engine standards in Section III. In developing the proposed rules, the agencies have evaluated the kinds of technologies that could be utilized by

engine manufacturers compared to a baseline engine, as well as the associated costs for the industry and fuel savings for the consumer and the magnitude of the GHG and fuel consumption savings that may be achieved. With respect to the lead time and cost of incorporating technology improvements that reduce GHG emissions and fuel consumption, the agencies place important weight on the fact that during MYs 2014

- 2017 engine manufacturers are expected to redesign and upgrade their products only once. Over these four model years there will be an opportun ity

for manufacturers to evaluate almost every one of their engine models and add technology

in a cost

- effective way

to control GHG emissions and reduce fuel consumption. The time

- frame and levels for the standards, as well as the ability to average, bank and trade credits and carry a deficit forward for a limited time, are expected to provide manufacturers the time needed to incorporate technology that will achieve the proposed GHG and fuel consumption reductions, and to do this as part of the normal engin e redesign process. This is an important aspect of the proposed rules, as it will avoid the much higher costs that would occur if manufacturers needed to add or change technology

at times other than these scheduled redesigns. This time period will also pro vide manufacturers the opportunity to plan for compliance using a multi

- year time frame, again in accord with their normal business practice. Further details on lead time, redesigns and technical feasibility can be found in Section III. EPA’s existing non

- GHG emissions regulations for heav y dut y on highway engines establish four regulatory categories (three for compression

- ignition or diesel engines and one for spark ignition or gasoline engines) that represent the engine’s

84 Specifically, EP A is proposing CO 2 , N 2 O, and CH 4 emissions standards for new heavy duty engines over an EPA specified useful life period (see Section II. II. E. for the N 2 O, and CH 4 standards ).100 of 54 1

intended and primary

truck applic ation, as shown in Table II
- 9

. 85 All heav y duty engines are covered either under the heav y dut y pickup truck and van category or under the heav y duty engine standards. Table II - 9 : E ngine Regulatory Subcategories Engine Category Intended Application Li ght Heav y Dut y Diesel (LHDD) Class 2b through Class 5 trucks (8,501 through 19,500 pounds GVWR) Medium Heav y Dut y Diesel (MHDD) Class 6 and Class 7 trucks (19,501 through 33,000 pounds GVWR) Heav y Heav y Dut y Diesel (HHDD) Class 8 trucks (33,001 pounds and greater GVWR Gasoline In complete vehicles less than 14,000 pounds GVWR and all vehicles (complete or incomplete) greater than 14,000 pounds GVWR For the purposes of the GHG engine emissions and engine fuel consumption standards that EPA and NHTSA are proposing today , the agencies intend to maintain these same four regulatory subcategories for GHG engine emissions standards and fuel consumption standards. This category structure wou ld enable the agencies to set standards that appropriately reflect the technology available for engines for use in each ty pe of vehicle. (i ) Diesel Engine Standards EPA's proposed heav y duty diesel engine CO 2 emission standards are presented in Table II
- 10 . Similar to EPA’s non

- GHG standards approach, manufacturers may generate and use credits to show compliance with the standards. The EPA standards become effective in 2014, with more stringent standards becoming effective in model ye ar 2017. Recentl y, EPA’s non

- GHG heav y duty engine program provided new emissions standards for the industry in three year increments. Largel y, the heav y dut y engine and truck manufacturer product plans have fallen into three ye ar cycles to reflect thi s environment. The proposed two

- step CO 2 emission standards recognize the opportunity

for technology

improvements over this timeframe while reflecting the t ypical diesel truck manufacturer product plan cycles. NHTSA’s fuel consumption standards, also pres ented in Table II
- 10 , would contain a voluntary

opt
- in to the engine program starting in 2014 model year, with mandatory

engine standards starting in 2017 model y ear, s ynchronizing with EPA’s 2017 model year standards. A manufacturer may opt
- in to NHTSA’s voluntary standards in 2014, 2015 or 2016. Once a manufacturer opts

- in the standards become mandatory for the opt

- in and subsequent model years, and the manufacturer may not reverse its

85 See § 1036.140 LHDD, MHDD, HHDD intended categoriesDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

101 of 54 1 decision. To opt into the program, a manuf acture must declare its intent to opt in to the program with documented communication of the intent, at the same time it submits the Pre
- Certification Compliance Report. See draft regulatory text for 49 CFR 535.8 for information related to the Pre

- Certifi cation Compliance Report. A manufacturer opting into the program would begin tracking credits and debits beginning in the model y ear in which they

opt into the program. The agencies are proposing the same standard level for the Light Heavy and Medium Heav y diesel engine categories. The agencies found that there is an overlap in the displacement of engines which are currentl y certified as LHDD or MHDD. The agencies developed the baseline 2010 model year CO 2 emissions from data provided to EPA by the manuf

acturers during the non

- GHG certification process. Analy sis of CO 2 emissions from 2010 model y ear LHDD and MHDDD engines showed little difference between LHDD and MHDD baseline CO 2 performance, which overall averaged 630 g CO 2 /bhp

- hr (6.19 gal/100 bhp

- hr) , 86 in the 2010 model year. Furthermore, the technologies available to reduce fuel consumption and CO 2 emissions from these two categories of engines are similar. The agencies are proposing to maintain these two separate engine categories with the same st andard level (instead of combining into a single category) to respect the different useful life periods associated with each category

. The agencies are proposing to evaluate compliance with the LHD/MHD standards based on the heav y dut y FTP engine cycle. The agencies found a difference in the baseline 2010 model y ear CO 2 and fuel consumption performance between the LHDD/MHDD engines, which averaged 630 g CO 2 /bhp

- hr (6.19 gal/100 bhp

- hr) 87 , and the HHDD engines, which averaged 584 g CO 2 /bhp

- hr (5.74 gal/100 bhp

- hr). The HHDD data is also based on manufacturer submitted CO 2 data for non

- GHG emissions certification process. In addition, the agencies believe that there may be some technologies available to reduce fuel consumption and CO 2 emissions that may not be appropriate for both the LHDD/MHDD and the HHDD engines, such as turbocompounding. Therefore, the agencies are proposing a standard level for HHDD engines which differs from the LHDD/MHDD standard level. We are proposing standards based on the FTP pro cedure for vocational truck engines reflecting their primary use in transient operating conditions ty pified by both frequent accelerations and decelerations as well as some steady cruise conditions as represented on the FTP. The primary reason the agencie s are proposing to set two separate HHDD engine standards is to encourage engine manufacturers to install technologies appropriate to the intended use of the engine with the vehicle. Tractors spend the majority

of their operation at steady state condition s, and will obtain in

- use benefit of technologies such as turbocompounding and other waste heat recovery

86 Calculated using the conversion 8887 g CO2/gallon for gasoline and 10,180 g CO2/gallon for diesel fuel. [site source] 87 Calculated using the conversion 8887 g CO2/gallon for gasoline and 10,180 g CO2/gallon for diesel fuel. [site sour ce ]102 of 54 1

technologies during this kind of ty pical engine operation. Therefore, the engines installed in line haul tractors would be required to meet the standard based on the SET, which is a steady state test cycle. On the other hand, vocational vehicles such as urban delivery trucks spend more time operating in transient conditions and may not realize the benefit of this ty pe of technology

in

- use. The use of an FTP test procedure for these engines will focus engine design on technologies that realize in

- use benefits during the kind of operation ty

pical for these engines. Therefore, we are proposing that engines installed in vocational vehicles be required to meet the standard and demonstrate compliance over the engine FTP cycle, which uses a transient test cycle. The levels of the standards reflect the difference in baseline emissions for the different test procedures. The engine standards that EPA is propo sing and the voluntary opt
- in standards being proposed b y NHTSA for the 2014 model year would require diesel engine manufacturers to achieve on average a three percent reduction in fuel consumption and CO 2 emissions over the baseline 2010 model year perfor mance for the HHDD engines and a five percent reduction for the LHDD and MHDD engines. The agencies’ assessment of the NAS report and other literature sources indicates that there are technologies available to reduce fuel consumption by this level in the proposed timeframe in a cost

- effective manner. These technologies include improved turbochargers, aftertreatment optimization, low temperature exhaust gas recirculation, and engine friction reductions. Additional discussion on technical feasibility is in cluded in Section III below and in DRIA Chapter 2. Additionally , the agencies are proposing that diesel engines further reduce fuel consumption and CO 2 emissions from the 2010 model y ear baseline in 2017 model year. The proposed 2017 model y ear standards for the LHDD and MHDD engines represent a 9 percent reduction from the 2010 model y ear. The proposed reductions represent on average a five percent decrease over the 2010 baseline for HHDD engines required to use the FTP standard. The additional reductio ns may be achieved through the increased development of the technologies evaluated for 2014 model year. The agencies’ anal ys is indicates that this ty

pe of advanced engine development will require a longer development time than the 2014 model year and ther efore are proposing to provide additional lead time to allow for its introduction. Similar to EPA’s non

- GHG standards approach, manufacturers may generate and use credits b y the same engine category to show compliance with both agencies’ standards.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

103 of 54 1 Table II - 10 : Proposed Diesel Engine Standards Effective 2014 Model Year

Li ght Heav y Diesel

- FTP Medium Heav y

Diesel

- FTP Heav y Heav y

Diesel

- FTP CO 2 Standard (g/bhp

- hr) 600 600 567 Optional Fuel Consumption S tandard (gallon/100 bhp

hr) 5.89 5.89 5.57

Effective 2017 Model Year

Li ght Heav y Diesel

- FTP Medium Heav y

Diesel

- FTP Heav y Heav y

Diesel

- FTP CO 2 Standard (g/bhp

- hr) 576 576 555 Fuel Consumption (gallon/100 bhp

hr) 5.57 5.57 5.45

In proposi ng thes e standards for diesel engines used in vocational trucks , the agencies have looked primarily at the t ypical performance levels of the majority of engines in the fleet. We recognize however that when regulating a category of products for the first time, th ere will be individual products that may deviate from this baseline level of performance. Recognizing that for these products a reduction from the industry baseline may

be more costly

than the agencies have assumed or perhaps even not feasible in the timi ng of these standards, EPA and NHTSA are proposing a regulatory alternative whereb y a manufacturer could comply with a unique standard based on a five percent reduction from the products own 2011 baseline level. Our assessment is that this five percent re duction is appropriate and technologically feasible given the same technology packages and cost we have estimated for the primary program. We do not believe this alternative needs to continue past 2016 since manufacturers will have had ample opportunity

t o benchmark competitive products and make appropriate changes to bring their product performance into line with the rest of the industry . However, we are requesting comment on the potential to extend this regulatory alternative for one additional year for a single engine famil y with performance measured in that year as nine percent beyond the engine’s own 2011 baseline level. We also request comment on the level of reduction beyond the baseline that is appropriat e in this alternative. The five percent le vel reflects the aggregate improvement beyond the baseline we are requiring of the entire industry . As this provision is intended to address potential issues for legacy products that we would expect to be replaced or significantly improved at the manufacturer’s next product change, we request comment if a two percent reduction would be more appropriate. We would consid er two percent rather than five percent if we were convinced that making all of the changes we have outlined in our assessment of the techn ical feasibility

of the standards was not possible for some engines due to legacy104 of 54 1

design issues that will change in the future. We are proposing that manufacturers making use of these provisions would not be able to generate emissions credits from other e ngines in the same regulatory category as the engines complying using this alternate approach. (ii) Gasoline Engine Standard Heav y dut y gasoline engines are t ypically used in vocational truck applications. The number of engines certified in the past for this s egment of vehicles is very limited and has ranged between three and five engine models. Unlike the purpose built heavy

duty diesel engines ty

pical of this segment, these gasoline engines are developed for heav y dut y pickup trucks and vans primaril y, but are also sold as loose engines to vocational truck manufacturers. Therefore, the agencies evaluated these engines in parallel with the heav y duty pickup truck and van standard development. As with the pickup truck and van segment, the agencies anticipate that the manufacturers will have only one engine re

- design within the 2014

- 18 model y ears under consideration within this proposal. In our meetings with all three of the major manufacturers in this segment, confidential future product plans were shared w ith the agencies. Reflecting those plans and our estimates for when engine changes will be made in alignment with those product plans, we have concluded that the 2016 model year reflects the most logical model year start date for the heav y - duty gasoline e ngine standards. In order to meet the standards we are proposing for heav y - duty pickups and vans, we project that all of the OEMs will have redesigned their gasoline engine offerings b y the start of the 2016 model ye ar. Given the small volume of loose ga soline engine sales relative to complete heav y - duty pickup sales, we think it is appropriate to set the timing for the heav y - dut y gasoline engine standard inline with our projections for engine redesigns to meet the heav y - duty pickup truck standards. Ther efore, NHTSA’s proposed fuel consumption standard and EPA’s proposed CO 2 standard for heav y dut y gasoline engines are first effective in the 2016 model year. The baseline 2010 model year CO 2 performance of these heavy duty gasoline engines over the FTP c yc le is 660 g CO 2 /bhp

- hr (6.48 gal/100 bhp

- hr) in 2010 based on non - GHG certification data provided to EPA b y the manufacturers. The agencies propose that manufacturers achieve a 5 percent reduction in CO 2 in the 2016 model year over the 2010 MY baseline through technologies such as coupled cam phasing, engine friction reduction, and stoichiometric direct injection. Additional detail on technology feasibility is included in Section III and in the DRIA Chapter 2. NHTSA is proposing a 7.05 gallon/100 bhp

- hr standard for fuel consumption while EPA is proposing a 627 g CO 2 /bhp

- hr standard tested over the FTP effective in 2016 model year. Similar to EPA’s non

- GHG standards approach, manufacturers may generate and use credits by the same engine category to show compliance with both agencies' standards. In the preceding section on diesel engines, we describe an alternative compliance approach for diesel engines based on improvements from an engine’s own baseline of performance. We are not making a similar propos al for gasoline engines, but we requestDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

105 of 54 1 comment on the need for and appropriateness of such an approach. Comments suggesting the need for a similar approach should include specific recommendations on how the approach would work and the technical reasons why such an approach would be necessary in order to make the gasoline engine standards feasible. (c) In

- Use Standards Section 202(a)(1) of the Clean Air Act specifies that emissions standards are to be applicable for the useful life of the vehicle. The in

- use standards that EPA is proposing would apply

to individual vehicles and engines. NHTSA is not proposing to adopt in

- use standards that would apply to the vehicles and engines in a similar fashion. EPA is propos ing that the in

- use standards for heavy dut y engines installed in vocational trucks be established by adding an adjustment factor to the full useful life emissions and fuel consumption results. EPA is proposing a 2 percent adjustment factor for the in

- use standard to provide some margin for production and test

- to
- test variability that could result in differences between the initial emission test results and emission results obtained during subsequent in

- use testing. EPA is proposing that the useful life for these engine and vehicles with respect to GHG emissions be set equal to the respective useful life periods for criteria pollutants. EPA proposes that the existing engine useful life periods 88 , as included in Table II
- 11 , be br oadened to include CO 2 emissions and fuel consumption for both engines and tractors. While NHTSA proposes to use useful life considerations for establishing fuel consumption performance for initial compliance and for ABT, NHTSA does not intend to implement an in

- use compliance program for fuel consumption, because it is not required under EISA and because it is not currently anticipated there will be notable deterioration of fuel consumption over the engines’ useful life.

Table II - 11 : Proposed Useful Life Periods

Years Miles Class 2b

- 5 Trucks, Spark Ignited (SI), and L ight Heavy

Dut y Diesel Engines 10 110,000 Class 6

- 7 Trucks and Medium Heav y Duty Diesel Engines 10 185,000 Class 8 Trucks and Heavy Heavy Duty Diesel Engines 10 435,000 EPA requests comments on the magnitude and need for an in

- use adjustment factor for the engine standard and the compliance model [TEST] based chassis standard.

88 40 CFR § 86.004

- 2106 of 54 1 (2) Test Procedures and Related Issues The agencies are proposing te st procedures to evaluate fuel consumption and CO 2 emissions of vocational trucks in a manner very similar to Class 7 and Class 8 combination tractors. This section describes a simulation model for demonstrating compliance, engine test procedures, and a t est procedure for evaluating h yb rid powertrains (a potential means of generating credits, although not part of the technology on which the proposed standard is premised). (a ) Computer Simulation Model As previously

mentioned, to achieve the goal of reducing em issions and fuel consumption for both trucks and engines, we are proposing to set separate engine and vehicle

- based emission standards. For the vocational trucks, engine manufacturers would be subject to the engine standards, and chassis manufacturers wou ld be required to install certified engines in their chassis. The chassis manufacturer would be subject to a separate vehicle

- based standard that would use the proposed truck simulation model to evaluate the impact of the tire design to determine complian ce with the truck standard. A simulation model, in general, uses various inputs to characterize a vehicle’s properties (such as weight, aerodynamics, and rolling resistance) and predicts how the vehicle would behave on the road when it follows a driving c ycle (vehicle speed versus time). On a second

- by

- second basis, the model determines how much engine power needs to be generated for the vehicle to follow the driving cycle as closely as possible. The engine power is then transmitted to the wheels through transmission, driveline, and axles to move the vehicle according to the driving cycle. The second

- by

- second fuel consumption of the vehicle, which corresponds to the engine power demand to move the vehicle, is then calculated according to the fuel consumption map embedded in the compliance model. Similar to a chassis dynamometer test, the second

- by

- second fuel consumption is aggregated over the complete drive cycle to determine a fuel consumption of the vehicle. NHTSA and EPA are proposing to evaluate fu el consumption and CO 2 emissions respectivel y through a simulation of whole

- vehicle operation, consistent with NAS recommendation to use a truck model to evaluate truck performance. The agencies developed the Truck Efficiency Simulation Tool [TEST] for th e specific purpose of this proposal to evaluate truck performance. The [TEST] model is similar in concept to a number of vehicle simulation tools developed by commercial and government entities. The model developed b y the agencies and proposed here was d esigned for the express purpose of vehicle compliance demonstration and is therefore simpler and less configurable than similar commercial products. This approach gives a compact and quicker tool for vehicle compliance without the overhead and costs of a more sophisticated model. Details of the model are included in Chapter 4 of the DRIA. [TEST] is designed to focus on the inputs most closely associated with fuel consumption and CO 2 emissions

- i.e . on those which have the largest impacts such as aerod yn amics, rolling resistance, weight, and others.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

107 of 54 1 EPA and NHTSA have validated [TEST] based on the chassis test results from three SmartWay

certified tractors tested at Southwest Research Institute. The validation work conducted on these three vehicles is representative of the other Class 7 and 8 tractors. Man y aspects of one tractor configuration (such as the engine, transmission, axle configuration, tire sizes, and control sy stems) are similar to those used on the manufacturer’s sister models. For examp le, the powertrain configuration of a sleeper cab is similar to the one used on a straight truck. Details are included in DRIA Chapter 4. Overall, the [TEST] model predicted the fuel consumption and CO 2 emissions within 4% of the chassis test procedure results for three test cycles

– the ARB Transient cycle, ARB High Speed Cruise cycle, and the Low Speed Cruise cycle. These cycles are very similar to the ones the agencies are proposing to utilize in compliance testing. Test to test variation for heav y - dut y vehicle chassis testing can be higher than 4 percent based on driver variation. The proposed simulation model is described in greater detail in DRIA Chapter 4 and is available for download b y interested parts at ( www.epa.gov/xxxxx ). We request comment on all aspects of this approach to compliance determination in general and to the use of the [TEST] model in particular. The agencies are proposing that for demonstrating compliance, a chassis manufacturer wou ld measure the performance of tires, input the values into [TEST], and compare the model’s output to the standard. Tires are the onl y technology on which the agencies’ own feasibility anal ys is for these vehicles is predicated. An example of the [TEST] input screen is included in Figure II
- 4 . The input values for the simulation model would be derived by the manufacturer from tire test procedure proposed by the agencies in this proposal. The agencies are proposing that the remai ning model inputs would be fixed values that are pre

- defined by the agencies and are detailed in the draft RIA Chapter 3, including the engine fuel consumption map to be used in the simulation.108 of 54 1 Figure II - 4 : Example [TEST] Input Screen (b ) Tire Rolling Resistance Assessment As with the Class 7/8 combination tractors, NHTSA and EPA are proposing that the vocational truck’s tire rolling resistance input to the [TEST] model be determined using the ISO 28580:2009 tes t method. 89 The agencies believe the IS O test procedure is appropriate to propose for this program because the procedure is the same one used by the NHTSA tire fuel efficiency labeling program 90 and is consistent with the direction being taken b y the tire industry both in the United States and Europe, and with the EPA SmartWay

program. The rolling resistance from this test would be used to specify the rolling resistance of each tire on the steer and drive axle of the vehicle. The results would be expressed as a rolling resistance coefficient and measured as kilogram per ton (kg/metric ton). The agencies are proposing that three tire samples within each tire model be tested to account for some of the production variability and the average of the three tests would be the rolling resistance coefficient for the tire. (c) Defined Vehicle Configurations in the [TEST ] model As discussed above, the agencies are proposing a methodology that chassis manufacturers would use to quantify the tire rolling resistance values to be input into the [TEST]. Moreover, the agencies are proposing to define the remaining [TEST] model inputs ( i.e . specify

them by rule), which may

differ by the regulatory

category (for reasons described in the DRIA). The defined inputs being proposed include the drive cycle, aerody

namics, truck curb weight, payload, engine characteristics, and drivetrain for each vehicle ty

pe, among others. (i ) Metric Based on NAS’s recommendation and feedback from the heav y dut y truck industry , NHTSA and EPA are proposin g standards for vocational trucks that would be expressed in terms of moving a ton of payload over one mile. Thus, NHTSA's proposed fuel consumption standards for these trucks would be represented as gallons of fuel used to move one ton of payload thousan d miles, or gal/1000 ton

- mile. EPA's proposed CO 2 vehicle standards would be represented as grams of CO 2 per ton
- mile. (ii) Drive cycle The drive cycle being proposed for the vocational trucks consists of the same three modes proposed for the Class 7

- 8 combin ation tractors. The agencies are thus proposing the use of the Transient mode, as defined by ARB in the HHDDT cycle, a

89 ISO, 2009, Passenger Car, Truck, and Bus Tyres

– Methods of Measuring Rolling Resistance

– Single Point Test and Correlation of Measurement Results: ISO 28580:2009(E), First Edition, 2009

- 07

- 01 90 NHTSA, 2009. “NHTSA Tire Fuel Eff iciency Consumer Information Program Development: Phase 1

– Evaluation of Laboratory Test Protocols.” DOT HS 811 119. June. (www.regulations.gov, Docket ID: NHTSA

- 2008

- 0121

- 0019).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

109 of 54 1 constant speed cycle at 65 mph and a 55 mph constant speed mode. However, we are proposing different weightings for each mode than prop osed for Class 7/8 combination tractors, given the known difference in driving patterns between these two categories of vehicles. The variet y of vocational vehicle applications makes it challenging to establish a single cycle which is representative of a ll such trucks. However, in aggregate, the vocational vehicles t ypically operate over shorter distances and spend less time cruising at highway

speeds than combination tractors. The agencies evaluated two sources for mode weightings, as detailed in DRIA Chapter 3. The agencies are proposing the mode weightings based on the vehicle speed characteristics of single unit trucks used in EPA’s MOVES model which were developed using Federal Highway Administration data to distribute vehicle miles traveled b y roa d ty pe. 91 The proposed weighted CO 2 and fuel consumption value consists of 37 percent of 65 mph Cruise, 21 percent of 55 mph Cruise, and 42 percent of Transient performance, which are reflected in the [TEST] model. (iii) Empty Weight and Payload The total weight of the truck is the sum of the tractor curb weight and the payload. The agencies are proposing to specify each of these aspects of the vehicle. The agencies developed the truck curb weight inputs based on industry information developed by IC F. 92 The pro posed curb weights are 10,300 pounds for the LH trucks, 13,950 pounds for the MH trucks, and 29,000 pounds for the HH trucks. NHTSA and EPA are also proposing the following payload requirement for each regulatory

category . The payloads were developed from Federal Highway statistics based on averaging the payloads for the weight categories represented within each vehicle category

. 93 The proposed payload requirement is 5,700 pounds for the L ight Heav y trucks, 11,200 pounds for Medium Heav y trucks, and 3 8,000 pounds for Heavy Heav y trucks. Additional information is available in DRIA Chapter 3. (iv) Engine As the agencies are proposing separate engine and truck standards, the [TEST] model will be used to assess the compliance of the chassis with the truck stan dard. To maintain the separate assessments, the agencies are proposing to use fixed values that are pre - defined by

the agencies for the engine characteristics used in [TEST], including the fuel consumption map which provides the fuel consumption at hundre ds of engine speed and torque points. If the agencies did not standardize the fuel map, then a truck that uses an engine with emissions and fuel consumption better than the standards would require

91 The Environmental Protection Agency. Draft MOVES2009 Highway Vehicle Popul ation and Activity Data. EPA

- 420

- P
- 09

- 001, August 2009 http://www.epa.gov/otaq/models/moves/techdocs/420p09001.pdf 92 ICF Cost Report. Need cite and docket #. 93 The U.S. Federal Highway Administration. Development of Truck Payload Equivalent Factor. Tab le 11. Last viewed on March 9, 2010 at http://ops.fhwa.dot.gov/freight/freight_analysis/faf/faf2_reports/reports9/s510_11_12_tables.htm110 of 54 1

fewer vehicle reductions than that being proposed. The ag encies are proposing that the engine characteristics used in [TEST] be representative of a diesel engine, because it represents the largest fraction of engines in this market. The agencies are proposing two distinct sets fuel consumption maps for use in [TEST]. The first fuel consumption map would be used in [TEST] for the 2014 through 2016 model years and represent a diesel engine which meets the 2014 model year engine CO 2 emissions standards. A second fuel consumption map would be used beginning in th e 2017 model year and represents a diesel engine which meets the 2017 model year CO 2 emissions and fuel consumption standards and accounts for the increased stringency in the proposed MY 2017 standard). Effectively there is no change in stringency of the vocational vehicle (not including the engine) and there is stability in the vocational vehicle (not including engine) standards for the full rulemaking period. These inputs are reasonable given the separate proposed regulatory requirement that vocational truck chassis manufacturers use only certified engines. (v) Drivetrain The agencies’ assessment of the current vehicle configuration process at the truck dealer’s level is that the truck companies provide software tools to specify the proper drivetrain mat ched to the buy er’s specific circumstances. These dealer tools allow a significant amount of customization for drive cycle and payload to provide the best specification for the customer. The agencies are not seeking to disrupt this process. Optimal driv etrain selection is dependent on the engine, drive cycle (including vehicle speed and road grade), and payload. Each combination of engine, drive cycle, and payload has a single optimal transmission and final drive ratio. The agencies are proposing to sp ecify

the engine’s fuel consumption map, drive cycle, and payload; therefore, it makes sense to specify the drivetrain that matches. In conclusion, for vocational trucks, compliance would be determined by establishing values for the tire rolling resist ance and using the prescribed inputs in [TEST]. The model would produce CO 2 and fuel consumption results that would be compared against EPA's and NHTSA's respective standards. (d ) Engine Test Procedures The NAS panel did not specificall y discuss or recommend a metric to evaluate the fuel consumption of heavy dut y engines. However, as noted above they did recommend the use of a load specific fuel consumption metric for the evaluation of vehicles. 94 An analogous metric for engines would be the amount of fuel c onsumed per unit of work. Thus, EPA is proposing that GHG emission standards for engines under the CAA would be expressed as grams of emissions per brake horsepower

- hour (g/bhp

- hr): similarly , NHTSA's proposed fuel consumption standards under EISA would b e represented as

94 March 2010 NAS Report. Page 2

- 40.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

111 of 54 1 gallons of fuel per 100 horsepower

- hour (gal/100 bhp

- hr). EPA’s metric is also consistent with EPA’s current standards for non

- GHG emissions for these engines. EPA’s criteria pollutant standards for engines currently require that manufacturers demonstrate compliance over a transient test cycle, the FTP; a steady - state test cycle, the SET or supplemental emissions test; and the not

- to
- exceed, or NTE test. EPA created this multi

- layered approach to criteria emissions control in response to engine designs that optimized operation for lowest fuel consumption at the expense of very high criteria emissions when operated off the regulatory cycle. EPA’s use of multiple test procedures for criteria pollutants helps to ensure that manufacturers cal ibrate engine s ystems for compliance under all operating conditions. With regard to GHG and fuel consumption control, the agencies believe it is more appropriate to set standards based on a single test procedure, either the FTP or SET, depending on the primary expected use of the engine. For engines used primarily in combination tractor trailer operations, we believe the stead y - state SET procedure more appropriately reflects in

- use engine operation. By setting standards based on the most representative test cycle, we can have confidence OEMs will design engines for best GHG and fuel consumption performance relative to the most common ty

pe of expected engine operation. We are not concerned if off

- cycle, manufacturers further calibrate these designs to gi ve better in

- use fuel consumption while maintaining compliance with the criteria emissions standards as such calibration is entirely consistent with the goals of our joint program. Further, we believe that setting standards based on both transient and ste ad y - state operating conditions for all engines could lead to undesirable outcomes. For example, turbocompounding is one technology that the agencies have identified as a likel y approach for compliance against our proposed HHD SET standard described below. Turbocompounding is a very effective approach to lower fuel consumption under steady driving conditions ty pified b y combination tractor trailer operation and is well reflected in testing over the SET test procedure. However, when used in driving ty

pifie d by transient operation as we expect for vocational trucks and as is represented b y the FTP, turbocompounding shows very little benefit. Setting an FTP based standard for engines intended for use in combination tractor trailers could lead manufacturers t o not apply turbocompounding even though it can be a highly cost effective means to reduce GHG emissions and lower fuel consumption. The current non

- GHG emissions engine test procedures also require the development of regeneration emission rates and f requency factors to account for the emission changes during a regeneration event. 95 EPA and NHTSA are proposing to exclude the CO 2 emissions and fuel consumption increases due to regeneration from the calculation of the compliance levels over the defined t est procedures. We considered including regeneration in the estimate of fuel consumption and GHG emissions and have decided not to do so for two reasons. First, EPA’s existing criteria emission regulations alread y provide a strong motivation to engine manufacturers to reduce the frequency and duration of infrequent regeneration events. The very stringent 2010 NOx emission

95 40 CFR § 86.004

- 28112 of 54 1

standards cannot be met by engine designs that lead to frequent and extend regeneration events. Hence, we believe engine manufacturer s are already reducing regeneration emissions to the greatest degree possible. In addition to believing that regenerations are alread y controlled to the extent technologicall y possible, we believe that attempting to include regeneration emissions in the s tandard setting could lead to an inadvertently lax emissions standard. In order to include regeneration and set appropriate standards, EPA and NHTSA would have needed to project the regeneration frequency and duration of future engine designs in the timef rame of this proposal. Such a projection would be inherently

difficult to make and quite likel y would underestimate the progress engine manufacturers will make in reducing infrequent regenerations. If we underestimated that progress, we would effectively be setting a more lax set of standards than otherwise would be expected. Hence in setting a standard including regeneration emissions we faced the real possibility

that we would achieve less effective CO 2 emissions control and fuel consumption reductions than we will achieve by not including regeneration emissions. We are seeking comments regarding regeneration emissions and what approach if an y the agencies should use in reflecting regeneration emissions in this program. (e) Hybrid Powertrain Technology A lthough the proposed vocational vehicle standards are not premised on use of hy brid powertrains, certain vocational truck applications may be suitable candidates for use of h ybrids due to the greater frequency of stop

- and

- go urban operation and their use o f power take

- off sy stems. Examples are vocational vehicles used predominantly in stop

start urban driving (e.g. delivery trucks). As an incentive, the agencies are proposing to provide credits for the use of h ybrid powertrain technology as described in S ection IV. The agencies are proposing that an y credits generated using such technologies could be applied to an y heav y duty vehicle or engine, and not be limited to the vehicle category generating the credit. Section IV below also details the proposed ap proach to account for the use of a h yb rid powertrain when evaluating compliance with the truck standard. In general, manufacturers can derive the fuel consumption and CO 2 emissions reductions based on comparative test results using the proposed chassis te sting procedures. We are proposing the same three drive cycles and cycle weightings discussed for the vocational vehicles to evaluate trucks that use hy brid powertrains to power the vehicle during motive operation (such as pickup and delivery trucks and transit buses). However, we are proposing an additional power take

- off (PTO) test cycle for trucks which use a PTO to power equipment while the vehicle is either idling or moving (such as bucket or refuse trucks). The reductions due to the hy brid technolo gy

would be calculated relative to the same ty pe of vehicle with a conventional powertrain tested using the same protocol. (3) Summary of proposed flexibility and credit provisions EPA and NHTSA are proposing a number of flexibility provisions for vocational truck chassis manufacturers and engine manufacturers, as discussed in Section IV below. These provisions are all based on an averaging, banking and trading program for emissions and fuel consumption credits. They include provisions to encourage the introd uction of advanced technologies such as h yb rid drivetrains, provisions toDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

113 of 54 1 incentivize earl y compliance with the proposed standards, and provisions to allow compliance using innovative technologies unanticipated by the agencies in developing this proposal. (4) Deferral of standards for sm all chassis manufacturing and small engine companies EPA and NHTSA are proposing to defer greenhouse gas emissions and fuel consumption standards from small truck chassis manufacturers meeting the Small Business Administration (SBA) size criteria of a small business as described in 13 CFR 121.201. 96 The agencies will instead consider appropriate GHG and fuel consumption standards for these entities as part of a future regulatory action. This includes both U.S.

- based and foreign small volume heavy dut y tractor manufacturers. The agencies have identified ten chassis entities that appear to fit the Small Business Administration (SBA) size criterion of a small business. 97 The agencies estimate that these small entities comprise less than 0.5 percent of the total heav y - duty vocational truck market in the U.S. based on Polk Registration Data from 2003 through 2007, 98 and therefore that the exemption will have a negligible impact on the GHG emissions and fuel consumption improvements from the proposed standards. EPA and NHTSA have also identified three entities that appear to fit the Small Business Administration (SBA) size criteria of a small business based on company information included in Hoover’s. 99 Based on 2008 and 2009 model year engine certification data submitted to EPA for non

- GHG emissions standards, the agencies estimate that these small entities comprise less than 0.1 percent of the total heavy

- dut y engine sales in the U.S. The proposed exemption from the standards establis hed under this proposal would have a negligible impact on the GHG emissions and fuel consumption reductions otherwise due to the standards. 

### E. EPA’s Proposed N 2 

### 0 and CH 4 

### Standards In addition to proposing CO 2 emission standards for heav y dut y vehicles and e ngines, EPA is also proposing separate standards for nitrous oxide (N 2 O) and methane (CH 4 ) emissions. 100 NHTSA is not proposing comparable separate standards for these GHGs because they

are not directly

related to fuel consumption in the same way that CO2 i s, and NHTSA’s authority under E IS A relates to fuel efficiency . N 2 O and CH 4 are

96 40 CFR §§ 1036.150 and 10367.150 97 The agencies have identi fied Lodal, Indiana Phoenix, Autocar LLC, HME, Giradin, Azure Dynamics, DesignLine International, Ebus, Krystal Koach, and Millenium Transit Services LLC as potential small business chassis manufacturers. 98 M.J. Bradley. Heavy Duty Vehicle Market Analysis . May 2009. 99 The agencies have identified Baytech Corporation, Clean Fuels USA, and BAF Technologies, Inc. as three potential small businesses. 100 NHTSA's statutory responsibilities relating to reducing fuel consumption are directly related to reducing CO 2 emissions, but not to the control of other GHGs.114 of 54 1

important GHGs that contribute to global warming, more so than CO 2 for the same amount of emissions due to their high Global Warming Potential (GWP). 101 EPA is proposing N 2 O an d CH 4 standards which apply to HD pickup trucks and vans as well as all heav y dut y engines. EPA is not proposing N 2 O and CH 4 standards for the Class 7/8 tractor or Class 2b

- 8 chassis manufacturers because they are being controlled through the engine progr am. Almost universally

across current engine designs, both gasoline

- and diesel

fueled, N 2 O and CH 4 emissions are relativel y low today and EPA does not believe it would be appropriate or feasible to require reductions from the levels of current gasoline an d diesel engines because current heav y dut y criteria pollutant emission standards indirectly result in control of N 2 O and CH 4 . Additionally , unlike criteria pollutants, specific technologies beyond those presentl y implemented in heav y dut y vehicles to mee t existing emission requirements have not surfaced that target reductions in N 2 O or CH 4 . Because of this, reductions in N 2 O or CH 4 beyond current levels would likely result in an increase in the overall stringency of the criteria emission standards. Neve rtheless, it is important that future engine technologies or fuels not currentl y researched do not result in increases in these emissions, and this is the intent of the proposed “cap” standards. The proposed standards would act to cap emissions at today ’s levels to ensure that manufacturers do not allow the N 2 O and CH 4 emissions of their future engines to rise above current levels if they choose a different technology path from currently

used and largel y successful methods for controlling N 2 O and CH 4 . As d iscussed below, some technologies that manufacturers may adopt for reasons other than reducing fuel consumption or GHG emissions could increase N 2 O and CH 4 emissions if manufacturers do not address these emissions in their overall engine and aftertreatment design and development plans. Manufacturers will be able to design and develop the engines and aftertreatment to avoid such emissions increases through appropriate emission control technology

selections like those already used and available today . Becau se EPA believes that these standards can be capped at the same level, regardless of ty pe of HD engine involved, the following discussion relates to all types of HD engines regardless of the vehicles in which such engines are ultimatel y used. In addition, since these standards are designed to cap current emissions, EPA is proposing the same standards for all of the model years to which the rules appl y. EPA believes that the proposed N 2 O and CH 4 cap standards would accomplish the primary goal of preventing i ncreases in these emissions as engine and aftertreatment technologies evolve because manufacturers will continue to target current or lower N 2 O and CH 4 levels in order to maintain ty pical compliance margins. However, we also believe that an alternative co mpliance approach that allows manufacturers to convert these emissions to CO 2 - equivalent emission values and combine them with CO 2 into a single compliance value would also be appropriate, so long as it did not undermine the stringency

of the CO 2 standard. As described below, EPA is proposing that such an

101 N 2 O has a GWP of 298 and CH 4 has a GWP of 25 according to the IPCC Fourth Assessment Report (AR4).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

115 of 54 1 alternative compliance approach be available to manufacturers to provide certain flexibilities for different technologies

. EPA requests comments on the approach to regulating N 2 O and CH 4 emissions includi ng the appropriateness of “cap” standards, the technical bases for the levels of the proposed N 2 O and CH 4 standards, the proposed test procedures, and the proposed timing for the standards. In addition, EPA seeks an y additional emissions data on N 2 O and C H 4 from current technology

engines. (1) What is EPA’s proposed approach to controlling N 2 O? N 2 O is a global warming gas with a global warming potential (GWP) of 310. It accounts for about 0.3% of the current greenhouse gas emissions from heavy duty trucks. 102 N 2 O is emitted from gasoline and diesel vehicles mainly during specific cataly st temperature conditions conducive to N 2 O formation. Specificall y, N 2 O can be generated during periods of emission hardware warm

- up when rising catal ys t temperatures pass thr ough the temperature window when N 2 O formation potential is possible. For current heav y dut y gasoline engines with conventional three

- way cataly st technology , N 2 O is not generall y produced in significant amounts because the time the catal ys t spends at the critical temperatures during warm

- up is short. This is largel y due to the need to quickly reach the higher temperatures necessary for high cataly st efficiency to achieve emission compliance of criteria pollutants. N 2 O is a more significant concern with diesel vehicles, and potentially

with future gasoline lean

- burn engines, equipped with advanced catal yt ic NOx emissions control systems. These s ys tems can but need not be designed in a way that emphasizes efficient NOx control while allowing the formation of significant quantities of N 2 O. Excess oxygen present in the exhaust during lean

- burn conditions in diesel or lean

- burn gasoline engines equipped with these advanced s ys tems can favor N 2 O formation if catal ys t temperatures are not carefully controlled. To prevent this trade

- off, future designs and controls at reducing criteria emissions would need to take into account the balance of reducing these emissions while also preventing N 2 O formation much like the path taken in current heavy dut y compliant eng ines and vehicles. Without specific attention to controlling N 2 O emissions in the development of such new NOx control sy stems, vehicles could have N 2 O emissions many times greater than are emitted by

current gasoline vehicles. EPA is proposing an N 2 O emi ssion standard that we believe would be met by current
- technology

gasoline and diesel vehicles at essentially no cost. EPA believes that heav y dut y emission standards since 2008 model year, specificall y the very stringent NOX standards for both engine and chassis certified engines, directly result in stringent N 2 O control. It is believed that the current emission control technologies used to meet the stringent NOX standards achieve the maximum feasible reductions and that no additional technologies are rec ognized that would result in additional N 2 O reductions. As noted,

102 Value adapted from “Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990

- 2007. April 2009.116 of 54 1

N 2 O formation in current catal ys t sy stems occurs, but their emission levels are inherentl y low, because the time the catal ys t spends at the critical temperatures during warm

- up when N 2 O can form is short. At the same time, we believe that the proposed standard would ensure that the design of advanced NOx control sy stems for future diesel and lean

burn gasoline vehicles would control N 2 O emission levels. While current NOx control approaches u sed on current heavy duty diesel vehicles do not compromise N 2 O emissions and actuall y result in N 2 O control, we believe that the proposed standards would discourage an y new emission control designs for diesels or lean

- burn gasoline vehicles that achieve c riteria emissions compliance at the cost of increased N 2 O emissions. Thus, the proposed standard would cap N 2 O emission levels, with the expectation that current gasoline and diesel vehicle control approaches that comply with heav y dut y vehicle emission st andards for NOx would not increase their emission levels, and that the cap would ensure that future diesel and lean

- burn gasoline vehicles with advanced NOx controls would appropriately control their emissions of N 2 O. (a ) Heavy

-Duty Pickup Truck and Van Nitrous Oxide (N 2 O) Exhaust Emission Standard EPA is proposing a per

- vehicle N 2 O emission standard of 0. 03 g/mi, measured over the combined

- cycle FTP vehicle laboratory test. Similar to the CO 2 standard approach, the N 2 O emission level of a vehicle would be a composite of the FTP city and highway cycles with the same 55% cit y weighting and 45% highway weighting. The standard would become effective in model ye ar 20 14 for all HD pickups and vans that are subject to the proposed CO 2 emission requirements. Averag ing between vehicles would not be allowed. The standard is designed to prevent increases in N 2 O emissions from current levels, i.e . a no - backsliding standard. The proposed N 2 O level is approximately two times the average N 2 O level of current gasoline and diesel heavy dut y trucks that meet the NOx standards effective since 2008 model year. 103 Manufacturers ty pically use design targets for NOx emission levels at approximately

50% of the standard, to account for in

- use emissions deterioration and normal testing and production variability , and we expect manufacturers to utilize a similar approach for N 2 O emission compliance. We are not proposing a more stringent standard for current gasoline and diesel vehicles because the stringent heavy duty NOx standards alrea dy

result in significant N 2 O control, and we do not expect current N 2 O levels to rise for these vehicles particularl y with expected manufacturer compliance margins

. Diesel heav y dut y pickup trucks and vans with advanced emission control technology

are in the early

stages of development and commercialization. As this segment of the vehicle market develops, the proposed N 2 O standard would require manufacturers to incorporate control strategies that minimize N 2 O formation. Available approaches include usin g electronic controls to limit cataly st conditions that might favor

103 Ne ed to get this from MOVES and other test data.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

117 of 54 1 N 2 O formation and considering different cataly st formulations. While some of these approaches may

have associated costs, EPA believes that they will be small compared to the overall costs of the advanced NOx control technologies already required to meet heav y dut y standards. The light

- dut y GHG rule requires that manufacturers begin testing for N 2 O by 2015 model year . The manufacturers of complete pickup trucks and vans (Ford, General Moto rs, and Chry sler) are already impacted b y the light

- dut y GHG rule and will therefore have this equipment and capability in place for the timing of this proposal. Overall, we believe that manufacturers of HD pickups and vans (both gasoline and diesel) woul d meet the proposed standard without implementing any significantly new technologies, onl y further refinement of their existing controls, and we do not expect there to be an y significant costs associated with this standard. (b ) Heavy Duty Engine Nitrous Oxide (N 2 O) Exhaust Emission Standard EPA is also proposing a per engine N 2 O emissions standard of 0.05 g/bhp

- hr for heav y dut y engines which become effective in 2014 model year. These standards remain the same over the useful life of the engine. The N 2 O emis sions would be measured over the heav y dut y engine FTP cycle because it is believed that this cycle poses the highest risk for N 2 O formation versus the additional heavy duty compliance cycles. Averaging between vehicles would not be allowed. The standard is designed to prevent increases in N 2 O emissions from current levels, i.e . a no - backsliding standard. The proposed N 2 O level is twice the average N 2 O level of current diesel engines as demonstrated in the ACES Study and in EPA’s testing of two additional engines with SCR aftertreatement s ys tems. 104 Manufacturers t ypically use design targets for NOX emission levels of about 50% of the standard, to account for in

- use emissions deterioration and normal testing and production variability , and manufacturers are e xpected to utilize a similar approach for N 2 O emission compliance. EPA requests comment on the agency 's technical assessment of current and potential future N 2 O formation in heav y dut y engines, as presented here. Engine emissions regulations do not curre ntly require testing for N 2 O. The Mandatory

GHG Reporting final rule (MRR) 105 requires reporting of N 2 O and requires that manufacturers either measure N 2 O or use a compliance statement based on good engineering judgment in lieu of direct N 2 O measurement. Th e light

- dut y GHG final rule 106 allows manufacturers to provide a compliance statement based on good engineering judgment through the 2014 model ye ar, but requires measurement beginning

104 CRC Report: ACES Phase 1 of the Advanced Collaborative Emissions Study, 2009.(This study included detailed chemical characterization of exhaust species emitted from four 2007 model year heavy heavy diesel en gines) 105 74 FR 56260, October 30, 2009 106 75 FR 25324 (May 7, 2010).118 of 54 1

in 2015 model y ear. EPA is proposing a consistent approach for heavy duty engine manufacturers which allows them to start direct measurement of N 2 O in the 2015 model ye ar. EPA welcomes comments on whether there are differences in the heavy dut y market which would warrant a different approach. Manufacturers without the capabil ity to measure N 2 O by

the 2015 model ye ar would need to acquire and install appropriate measurement equipment in response to this proposed program. EPA has established four separate N 2 O measurement methods, all of which are commercially

available today

. EPA expects that most manufacturers would use photo

- acoustic measurement equipment, which EPA estimates would result in a one

time cost of about $50,000 for each test cell that would need to be upgraded. Overall, EPA believes that manufacturers of heavy dut y engines, both gasoline and diesel, would meet the proposed standard without implementing any new technologies, and beyond relativel y small facilities costs for an y companies that still need to acquire and install N 2 O measurement equipment, EPA does not project that manufacturers would incur significant costs associated with this proposed N 2 O standard. EPA is not proposing any vehicle

- level N 2 O standards for heav y dut y trucks (combination and vocational) in this proposal. The N 2 O emissions would b e controlled through the heav y dut y engine portion of the program. The onl y requirement of those truck manufacturers to comply with the N 2 O requirements is to install a certified engine. (2) What is EPA’s proposed approach to controlling Methane (CH 4 )? CH 4 (or methane) is greenhouse gas with a GWP of 23. It accounts for about 0.03% of the greenhouse gases from heav y - dut y trucks. 107 EPA is proposing a standard that would cap CH 4 emission levels, with the expectation that current heav y dut y vehicles and engines me eting the heav y duty emission standards would not increase their levels, and that it would ensure that emissions would be addressed if in the future there are increases in the use of natural gas or an y other alternative fuel. EPA believes that current heav y duty emission standards, specificall y the NMHC standards for both engine and chassis certified engines directl y result in stringent CH 4 control. It is believed that the current emission control technologies used to meet the stringent NMHC standards achie ve the maximum feasible reductions and that no additional technologies are recognized that would result in additional CH 4 reductions. The level of the standard would generally be achievable through normal emission control methods already required to meet h eav y duty emission standards for h ydrocarbons and EPA is therefore not attributing any cost to this part of today ’s proposal. Since CH 4 is produced in gasoline and diesel engines similar to other hydrocarbon components, controls targeted at reducing overal l NMOG levels generall y also work at reducing CH 4 emissions. Therefore, for gasoline and diesel vehicles, the heav y dut y h ydrocarbon standards will generally prevent increases in CH 4 emissions

107 Value adapted from “Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990

- 2007. April 2009.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

119 of 54 1 levels from today . CH 4 from heav y dut y vehicles is relatively low compared to other GHGs largel y due to the high effectiveness of the current heav y dut y standards in controlling overall HC emissions. Since CH 4 is produced in gasoline and diesel engines similar to other hydrocarbon components, CH 4 emission levels are already low due to controls targeted at reducing overall NMHC levels. Therefore, for gasoline and diesel vehicles, the 2008 NMHC standards will generally

prevent increases in CH 4 emissions levels from today

. EPA believes that this level for the standard would be met by current gasoline and diesel trucks and vans, and would prevent increases in future CH 4 emissions in the event that alternative fueled vehicles with high methane emissions, like some past dedicated compressed natural gas (CNG) vehicles, be come a significant part of the vehicle fleet. Currently EPA does not have separate CH 4 standards because, unlike other hydrocarbons, CH 4 does not contribute significantl y to ozone formation. 108 However, CH 4 emissions levels in the gasoline and diesel heav y dut y truck fleet have nevertheless generall y been controlled by

the heavy

duty hydrocarbon (HC) emission standards. Even so, without an emission standard for CH 4 , future emission levels of CH 4 cannot be guaranteed to remain at current levels as vehicle technologies and fuels evolve. In recent model years, a small number of heav y duty trucks and engines were sold that were designed for dedicated use of compressed natural gas (CNG). While emission control designs on these recent dedicated CNG

- fueled vehic les demonstrate CH 4 control as effective as gasoline or diesel equivalent vehicles, CNG

- fueled vehicles have historically

produced significantly

higher CH 4 emissions than gasoline or diesel vehicles. This is because their CNG fuel is essentiall y methane, and any unburned fuel that escapes combustion and is not oxidized by the catal ys t is emitted as methane. However, even if these vehicles meet the heav y dut y h ydrocarbon standard and appear to have effective CH 4 control by

nature of the hydrocarbon controls , heav y dut y standards do not require CH 4 control. While the proposed CH 4 cap standard should not require an y different emission control designs (i.e., feedback controlled 3

- way catal ys t) beyond what is already required to meet heav y duty hydrocarbon stand ards on a dedicated CNG vehicle, the cap will ensure that sy stems maintain the current level of CH 4 control. We are not proposing more stringent CH 4 standards because we believe that the same controls that are used to meet current heav y dut y hydrocarbon st andards should result in effective CH 4 control. Since CH 4 is already

measured under the current heavy dut y emissions regulations (so that it may

be subtracted to calculate non

- methane hydrocarbons), the proposed standard would not result in additional test ing costs. EPA requests comment on whether the proposed cap standard would result in any significant technological challenges for makers of CNG vehicles.

108 But see Ford Motor Co. v. EPA , 604 F. 2d 685 (D.C. Cir. 1979) (permissible for EPA to regulate CH4 under CAA section 202 (b)).120 of 54 1 (a ) Heavy

- duty Pickup Truck and Van CH 4 Standard EPA is proposing a CH 4 emission standard of 0. 05 g/mi a s measured on the combined cycle FTP, to apply beginning with model year 20 14 for HD pickups and vans subject to the proposed CO 2 standards. Similar to the CO 2 standard approach, the CH 4 emission level of a vehicle would be a composite of the FTP cit y and highway cycles with the same 55% cit y weighting and 45% highway weighting. The level of the proposed standard is approximately two times the average heav y duty gasoline and diesel truck and van levels. 109 As with N 2 O, this proposed level recognizes that manufacturers t ypicall y set emissions design targets with a compliance margin of approximately

50% of the standard. Thus, we believe that the proposed standard should be met by current gasoline vehicles with no increase from today ’s CH 4 levels. Similarly , since current diesel vehicles generall y have even lower CH 4 emissions than gasoline vehicles, we believe that diesels would also meet the proposed standard with a larger compliance margin resulting in no change in today ’s CH 4 levels. (b ) Heavy Duty Engine Me thane (CH 4 ) Exhaust Emission Standard EPA is proposing a heavy duty engine CH 4 emission standard of 0.02 g/hp

- hr as measured on the heav y duty engine FTP, to appl y beginning in model ye ar 2014. The proposed standard would cap CH 4 emissions at a level curr entl y achieved by diesel and gasoline heav y dut y engines. The level of the standard would generall y be achievable through normal emission control methods already required to meet 2007 emission standards for NMHC 110 and EPA is therefore not attributing any c ost to this part of this proposal. The level of the proposed CH 4 standard is twice the average CH 4 emissions from the four diesel engines in the ACES study

. 111 As with N 2 O, this proposed level recognizes that manufacturers t ypicall y set emission design targets at about 50% of the standard. Thus, EPA believes the proposed standard would be met b y current diesel and gasoline engines with little if an y technological improvements. The agency believes a more stringent CH 4 standard would not be timely , sinc e, as discussed above for N 2 O, EPA believes that the challenge of compl yi ng with the CO 2 standards should be the primary focus of the manufacturers CH 4 is measured under the current 2007 regulations so that it may be subtracted to calculate non

- methane hydrocarbons. Therefore EPA expects that the proposed standard would not result in additional testing costs.

109 Need to get this number from MOVES and test data. 110 40 CFR § 86.007

- 11 111 CRC Report: ACES Phase 1 of the Advanced Collaborative Emissions Study, 2009.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

121 of 54 1 EPA is not proposing any vehicle

- level CH 4 standards for heav y dut y trucks (combination or vocational) in this proposal. The CH 4 emissions would b e controlled through the heav y dut y engine portion of the program. The onl y requirement of these truck manufacturers to comply with the CH 4 requirements is to install a certified engine. (3) Alternative CO 2 Equivalent Standard In lieu of compl yi ng with the s eparate N 2 O and CH 4 cap standards, EPA is proposing that a manufacturer could choose to comply with a single CO 2 - equivalent standard. Under this option, a manufacturer would convert its N 2 O and CH 4 test results into CO 2 - equivalent values and add this sum to its CO 2 emissions. This CO 2 - equivalent value as well as straight CO 2 value would both still need to comply with the applicable CO 2 standard. In other words, a manufacturer could offset any N 2 O emissions or an y CH 4 emissions by

taking steps to further reduce CO 2 . A manufacturer choosing this option for an engine would need to appl y this approach to all of the engines in that engine family . If a manufacturer chose this option, the result would be more environmentally protective overall than the cap standard approach, since the manufacturer would need to reduce its CO 2 emissions to offset an y N 2 O or CH 4 levels, but would not be allowed to increase CO 2 above the standard b y reducing N 2 O or CH 4 . EPA proposes that the compliance level for the optional CO 2 - e quivalent approach be calculated using the Global Warming Potential of each GHG, such that the CO 2 - equivalent equals CO 2 + (298 x N 2 O) + (25 x CH 4 ). The N 2 O and CH 4 values would be the measured emission values for these GHGs. Finally , for manufacturers u sing this option, the CO 2 - equivalent emission level would also become the basis for any engine emission debits or credits that the manufacturer might generate. The proposed NHTSA fuel consumption program will not use CO 2 - equivalent, as suggested above. Me asured performance to the NHTSA fuel consumption standards will be based on the measurement of CO 2 with no adjustment for N 2 O and/or CH 4 . For manufacturers that use the EPA alternative and a CO 2 - equivalent performance value, compliance to the EPA CO 2 stan dard will not be directly equivalent to compliance to the NHTSA fuel consumption standard. (4) EPA’s proposed standards for direct emissions from air conditioning Air conditioning (A/C) systems contribute to GHG emissions in two way s
– direct emissions through refrigerant leakage and indirect exhaust emissions due to the extra load on the vehicle’s engine to provide power to the air conditioning s ys tem. Hydrofluorocarbon (HFC) refrigerants, which are powerful GHG pollutants, can leak from the A/C sy stem. This includes the direct leakage of refrigerant as well as the subsequent leakage associate with maintenance and servicing, and with disposal at the end of the vehicle’s life. The most commonly used refrigerant in automotive applications122 of 54 1

– R134a, has a high gl obal warming potential (GWP) of 1430. 112 Due to the high GWP of R134a , a small leakage of the refrigerant has a much greater global warming impact than a similar amount of emissions of CO 2 or other mobile source GHGs. Heav y dut y air conditioning s ys t ems today are similar to those used in light

- duty applications. However, differences may exist in terms of cooling capacit y (such that sleeper cabs have larger cabin volumes than day cabs), s ys tem layout (such as the number of evaporators), and the durabi lity requirements due to longer truck life. However, the component technologies and costs to reduce direct HFC emissions are similar between the two ty pes of vehicles. The quantity

of GHG emissions from heavy duty trucks relative to the CO 2 emissions fr om driving the vehicle and moving freight is very small. Therefore, a credit approach is not appropriate for this segment of vehicles because the value of the credit is too small to provide sufficient incentive to utilize feasible and cost

- effective air c onditioning leakage improvements. For the same reason, including air conditioning leakage improvements within the main standard would in many instances result in lost control opportunities. Therefore, EPA is proposing that truck manufacturers be required to meet a low leakage requirement for all air conditioning sy stems installed in 2014 model year and later trucks, with one exception. The agency is not proposing leakage standards for Class 2b

- 8 Vocational Vehicles at this time due to the complexity in the build process and the potential for different entities besides the chassis manufacturer to be involved in the air conditioning sy stem production and installation, with consequent difficulties in developing a regulatory s ys tem. EPA is proposing a leaka ge standard which is a “percent refrigerant leakage per ye ar” to assure that high

- quality , low

- leakage components are used in each air conditioning sy stem design. The agency believes that a single “gram of refrigerant leakage per ye ar” would not fairly ad dress the variety

of air conditioning system designs and layouts found in the heavy dut y truck sector. EPA is proposing a standard of 1.50 percent leakage per ye ar for Heav y Dut y Pickup Trucks and Vans and Class 7/8 Tractors. The proposed standard was de rived from the vehicles with the largest s ys tem refrigerant capacity based on the Minnesota GHG Reporting database. 113 The average percent leakage per ye ar of the 2010 model y ear vehicles is 2.7 percent. This proposed level of reduction is roughly

comparab le to that necessary to generate credits under the light

- dut y vehicle program. See 75 FR at 25426

- 247. Since refrigerant leakage past the compressor shaft seal is the dominant source of leakage in belt

- driven air conditioning sy stems, the

112 The global warming potentials (GWP) used in the NPRM analys is 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 addressi ng climate change. The IPCC SAR GWP values are used in the official U.S. greenhouse gas inventory submission to the climate change framework. When inventories are recalculated for the final rule, changes in GWP used may lead to adjustments. 113 The Minne sota refrigerant leakage data can be found at http://www.pca.state.mn.us/climatechange/mobileair.html#leakdata.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

123 of 54 1 agency is seeki ng comment on whether the stringency of a single “percent refrigerant leakage per ye ar” standard fairl y addresses the range of s ys tem refrigerant capacities likely to be used in heavy

duty trucks. 114 Since sy stems with less refrigerant may have a larger per centage of their annual leakage from the compressor shaft seal than sy stems 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 need ed to meet the standard). EPA welcomes comments relative to the stringency of the standard. Manufacturers can choose to reduce A/C leakage emissions in two way s. First, they can utilize leak

- tight components. Second, manufacturers can largel y eliminate the global warming impact of leakage emissions by adopting sy stems that use an alternative, low

- GWP refrigerant. EPA believes that reducing A/C s ys tem leakage is both highly cost
- effective and technologicall y feasible. The availability of low leakage components is being driven b y the air conditioning program in the light

- dut y GHG rule which appl y to 2012 model y ear and later vehicles. The cooperative industry and government Improved Mobile Air Conditioning (IMAC) program has demonstrated that new

- vehicle leakage emissions can be reduced b y 50% b y reducing the number and improving the quality of the components, fittings, seals, and hoses of the A/C sy stem. 115 All of these technologies are already in commercial use and exist on some of today ’s s ystems, and E PA does not anticipate any significant improvements in sealing technologies for model ye ars beyond 2014. However, EPA does anticipate that updates to the SAE J2727 standard will be forthcoming (to address new materials and components which perform better than those originally used in the SAE anal ysis), and that it will be appropriate to include these updates in the regulations concerning refrigerant leakage. C onsistent with the 2012

- 2016 light

- dut y GHG rule, we are estimating costs for leakage control at $18 (2008$) in direct manufacturing costs. Including a low complexity ICM of 1.14 results in costs of $21 in the 2014 model y ear. Time based learning is considered appropriate for A/C leakage control , so costs in the 2017 model year would be $19. Thes e costs are applied to all heav y duty pickups and vans, and to all combination tractors. EPA proposes that manufacturers demonstrate improvements in their A/C sy stem designs and components through a design

- based method. The proposed method for calculating A/C leakage is based closel y 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 available A/C components. Under the proposed 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 s ys tem leakage performance and calculate the percent leakage per ye ar as this score divided b y the sy stem refrigerant capacity

.

114 Society of Automotive Engineers Surface Vehicle Standard J2727, issued August 2008, http://www.sae.org 115 Team 1

- Refrigerant Leakage Reduction: Final Report to Sponsors, SAE, 2007.124 of 54 1 Consistent with the light

- duty GHG rule, EPA is proposing that a manufacturer would compare the components of its A/C sy stem with a set of leakage

- reduction technologies and actions that is b ased closel y 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 s ystem generall y 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 sy stem leakage. However, in the heavy dut y truck program, the total A/C leakage score would then be di vided by the value by

the total refrigerant s ystem capacit y to develop a percent leakage per ye ar. EPA believes that the design

- based approach would result in estimates of likely leakage emissions reductions that would be comparable to those that would eventuall y result from performance

- based testing. 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. CO 2 emissions are also associated wi th air conditioner efficiency , since air conditioners create load on the engine. See 74 FR at 49529. However, EPA is not proposing to set air conditioning efficiency standards for vocational and combination trucks. The CO 2 emissions due to air condition ing sy stems in these heavy duty trucks are minimal compared to their overall emissions of CO 2 . For example, EPA conducted modeling of a Class 8 sleeper cab using [TEST] to evaluate the impact of air conditioning and found that it leads to approximately 1 gram of CO 2 /ton

- mile. Therefore, a projected 24% improvement of the air conditioning s ys tem (the level projected in the light

- duty GHG rulemaking), would only reduce CO 2 emissions by less than 0.3 g CO 2 /ton

- mile, or approximately

0.3 percent of the basel ine Class 8 sleeper cab CO 2 emissions. EPA is not specifying a specific in

- use standard for leakage, as neither test procedures nor facilities exist to measure refrigerant leakage from a vehicle’s air conditioning sy stem. However, consistent with the light

- dut y GHG rule, where we require that manufacturers attest to the durability of components and s ys tems used to meet the CO2 standards (see 75 FR at 25689), we will require that manufacturers of heav y - dut y vehicles attest to the durability of these sy stems, and provide an engineering anal ys is which demonstrates component and s ys tem durability

. (5) EPA’s proposed credits for in direct emissions from air conditioning As described above, in addition to direct emissions from refrigerant leakage, air conditioning sy s tems also create indirect exhaust emissions due to the extra load on the vehicle’s engine to provide power to the air conditioning sy stem. These indirect emissions are in the form of the additional CO2 emitted from the engine when A/C is being used due to the added loads. Unlike direct emissions which tend to be a set annual leak rate not directl y tied to usage, indirect emissions are full y a function of A/C usage.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards (8/11/2010)

125 of 54 1 Due to the complexity

of the heav y dut y market, it is difficult to estimate with any degr ee of precision what the actual impact of indirect emissions are across the vastly different applications and duty cycles of heavy

duty trucks. Depending on application, geographic location and even seasonal usage relationships, A/C sy stems usage will vary differentl y across the heavy dut y fleet and therefore efficiency improvements will also result in different indirect emission reductions . For this reason, EPA is not proposing an indirect emission standard like we have proposed for direct emissions in heavy dut y vehicles. Instead, EPA is seeking comment on the applicability of an indirect emissions credit for A/C s ys tem efficiency improvements specificall y in the heav y duty pickup trucks and vans (i.e., 2b/3). These vehicles are most closely related to their light duty counterparts that have an indirect emissions credit program established under the light duty GHG rule. It is likely

that the light duty

and heav y dut y vehicles can share components used to improve the A/C sy stem efficiency and reduce ind irect emissions. EPA also seeks comment on the level of the credit and if the fleet CO2 target standards should be adjusted accordingl y to reflect expected A/C efficiency improvements similar to approach used in the light dut y rule, 

## III. Feasibility Assessments and Conclusions In this section, NHTSA and EPA discuss several aspects of our joint technical anal ys es. These anal ys es are common to the development of each agency ’s proposed standards. Specifically

we discuss: the development of the basel ine used by each agency for assessing costs, benefits, and other impacts of the standards, the technologies the agencies evaluated and their costs and effectiveness, and the development of the proposed standards based on application of technology in light of the attribute based distinctions and related compliance measurement procedures. We also discuss consideration of standards that are either more or less stringent than those proposed. This proposal is based on the need to obtain significant oil savings and GHG emissions reductions from the transportation sector, and the recognition that there are appropriate and cost

- effective technologies to achieve such reductions feasibly . The decision on what standard to set is guided b y each agency’s statutory requirements, and is largel y based on the need for reductions, the effectiveness of the emissions control technology , the cost and other impacts of implementing the technology , and the lead time needed for manufacturers to employ the control technology

. The availability of technology

to achieve reductions and the cost and other aspects of this technology are therefore a central focus of this proposed rulemaking. Here, the focus of the standards is on appl yi ng fuel efficiency and emissions control technol ogy

to reduce fuel consumption, CO 2 and other greenhouse gases. Vehicles combust fuel to generate power that is used to perform two basic functions: 1) transport the truck and its payload, and 2) operate various accessories during the operation of the tru ck such as the power take

- off units. Engine

- based technology can reduce fuel consumption and CO 2 emissions by improving engine efficiency , which increases the amount of power produced per unit of fuel consumed. Vehicle

- based126 of 54 1

technology

can reduce fuel co nsumption and CO 2 emissions by increasing the vehicle efficiency , which reduces the amount of power demanded from the engine to perform the truck’s primary

functions. Our technical work has therefore focused on both engine efficiency improvements and vehic le efficiency

improvements. In addition to fuel delivery , combustion, and aftertreatment technology, an y aspect of the truck that affects the need for the engine to produce power must also be considered. For example, the drag due to aerody namics and the resistance of the tires to rolling both have major impacts on the amount of power demanded of the engine while operating the vehicle. The large number of possible technologies to consider and the breadth of vehicle sy stems that are affected mean that c onsideration of the manufacturer’s design and production process play s a major role in developing the proposed standards. Engine and vehicle manufacturers t ypically develop man y different models based on a limited number of platforms. The platform typica lly consists of a common engine or truck model architecture. For example, a common engine platform may contain the same configuration (such as inline), number of cylinders, valvetrain architecture (such as overhead valve), cylinder head design, piston desi gn, among other attributes. An engine platform may

have different calibrations (such as different power ratings) and different aftertreatment control strategies (such as EGR or SCR). On the other hand, a common vehicle platform has different meanings dep ending on the market. In the heav y dut y pickup truck market, each truck manufacturer usually has onl y a single pickup truck platform (for example the F series b y Ford) with common chassis designs and shared body panels, but with variations on load capacit y of the axles, the cab configuration, tire offerings, and powertrain options. L astly , the combination tractor market has several different platforms and the trucks within each platform (such as LoneStar by Navistar) have less commonalit y. Tractor manufa cturers will offer several different options for bumpers, mirrors, aerodynamic fairing, wheels, and tires, among others. However, some areas such as the overall basic aerodynamic design (such as the grill, hood, windshield, and doors) of the tractor are t ied to tractor platform. The platform approach allows for efficient use of design and manufacturing resources. Given the very large investment put into designing and producing each truck model, manufacturers of heav y - dut y pickup trucks and vans t ypicall y plan on a major redesign for the models every 5 years or more. Recently , EPA’s non

- GHG heav y dut y engine program provided new emissions standards every three model years. Heavy dut y engine and truck manufacturer product plans typically have fallen into three year cycles to reflect this environment. While the recent non

- GHG emissions standards can be handled generall y with redesigns of engines and trucks, a complete redesign of a new heav y - dut y engine or truck ty pically occurs on a slower cycle and often does not align in time due to the fact that the manufacturer of engines differs from the truck manufacturer. At the redesign stage, the manufacturer will upgrade or add all of the technology and make most other changes supporting the manufacturer’s plans for the next several ye ars, including plans related to emissions, fuel econom y, and safet y regulations.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

127 of 54 1 A redesign of either engines or truck platforms often involves a package of changes designed to work together to meet the various requirements and plans for the model for several model y ears after the redesign. This often involves significant engineering, development, manufacturing, and marketing resources to create a new product with multiple new features. In order to leverage this significant upfront investment, manufacturers plan vehicle redesigns with several model ye ars of production in mind. Vehicle models are not completel y static between redesigns as limited changes are often incorporated for each model year. This interim process is called a ref resh of the vehicle and it generall y does not allow for major technology changes although more minor ones can be done ( e.g. , small aerodyn amic improvements, etc). More major technology

upgrades that affect multiple sy stems of the vehicle thus occur at the vehicle redesign stage and not in the time period between redesigns. As discussed below, there are a wide variet y of CO 2 and fuel consumption reducing technologies involving several different sy stems in the engine and vehicle that are available for consid eration. Many can involve major changes to the engine or vehicle, such as changes to the engine block and cylinder heads or changes in vehicle shape to improve aerodynamic efficiency. Incorporation of such technologies during the periodic engine, transmi ssion or vehicle redesign process would allow manufacturers to develop appropriate packages of technology upgrades that combine technologies in way s that work together and fit with the overall goals of the redesign. By s ynchronizing with their multi

- ye ar planning process, manufacturers can avoid the large increase in resources and costs that would occur if technology had to be added outside of the redesign process. We considered redesign cycles both in our costing and in assessing the lead time required. As described below, the vast majority of technology

required b y this proposal is commerciall y available and already being employed to a limited extent across the fleet. Therefore the majority

of the emission and fuel consumption reductions which would res ult from these proposed rules would result from the increased use of these technologies. EPA and NHTSA also believe that these proposed rules would encourage the development and limited use of more advanced technologies, such as advanced aerod ynamics and hy

brid powertrains in some vocational truck applications. In evaluating truck efficiency , NHTSA and EPA have excluded fundamental changes in the engine or trucks’ performance. For example, the agencies did not consider approaches that would require redu ctions in engine power or otherwise limit truck performance. The agencies have limited the assessment of technical feasibility and resultant vehicle cost to technologies which maintain freight utility

. The agencies worked together to determine compone nt costs for each of the technologies and build up the costs accordingl y. For costs, the agencies considered both the direct or ‘‘ piece ’’ costs and indirect costs of individual components of technologies. For the direct costs, the agencies followed a bill of materials (BOM) approach utilized by the agencies in the light

- duty fuel econom y and GHG final rule. A bill of materials, in a general sense, is a list of components or sub

- sy stems that make up a s ys tem

— in this case, an item of technology which reduce s GHG emissions and fuel consumption. In128 of 54 1

order to determine what a sy stem costs, one of the first steps is to determine its components and what they cost. NHTSA and EPA estimated these components and their costs based on a number of sources for cost

- relate d information. In general, the direct costs of fuel consumption

- improving technologies for heav y - duty pickups and vans are consistent with those used in the 2012

- 2016 light

- duty rule, except that the agencies have scaled up certain costs where appropriate to accommodate the larger size and/or loads placed on parts and s ys tems in the heavy

- dut y classes relative to the light

- duty classes. For loose heav y - dut y engines, the agencies have consulted various studies and have exercised engineering judgment when es timating direct costs. For technologies expected to be added to vocational and combination trucks, the agencies have again consulted various studies and have used engineering judgment to arrive at direct cost estimates. Once costs were determined, they w ere adjusted to ensure that they were all expressed in 2008 dollars using a ratio of GDP deflators for the associated calendar years. Indirect costs were accounted for using the ICM (indirect cost multiplier) approach explained in Chapter 2 of the DRIA, rather than using the traditional Retail Price Equivalent (RPE) multiplier approach. For the heav y dut y pickup truck and van cost projections in this proposal, the agencies have used I CMs developed for light

- dut y vehicles (with the exception that here ret urn on capital has been incorporated into the ICMs, where it had not been in the light

- dut y rule) primarily because the manufacturers involved in this segment of the heav y dut y market are the same manufacturers that build light duty trucks. For the Class 7/8 tractor, vocational truck, and heav y duty engine cost projections in this proposal, EPA contracted with RTIInternational to update EPA’s methodology

for accounting for indirect costs associated with changes in direct manufacturing costs for heav y dut y engine and truck manufacturers. 116 Inaddition to the indirect cost multipliers varying by complexity

and time frame, there is no reason to expect that the multipliers would be the same for engine manufacturers as for truck manufacturers. The report from RTI provides a description of the methodology , as well as calculations of new indirect cost multipliers. The multipliers used here include a factor of 5% of direct costs representing the return on capital for heav y dut y engines and truck manufacturers. T hese indirect cost multipliers are intended to be used, along with calculations of direct manufacturing costs, to provide improved estimates of the full additional costs associated with new technologies. Details of the direct and indirect costs, and all applicable ICMs, are presented in Section VIII of this preamble and Chapter 2 of the draft DRIA. In addition, for details on the I CMs, please refer to the RTIreport that has been placed in the docket. The agencies request comment on all aspects of the c ost anal ys is, including the adjustment factors used in the RTIanal ys is

-- the levels associated with R&D, warranty , etc.
-- and whether those are appropriate or should be revised. If commenters suggest revisions, the agencies request supporting arguments and/or documentation.

116 RTI International. Heavy Duty Truck Retail Price Equivalent and Indirect Cost Multipliers. July 2010.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

129 of 54 1 EPA and NHTSA believe that the emissions reductions called for b y the proposed standards are technologically feasible at reasonable costs, reflecting our projections of widespread use of commerciall y available technology. Manufact urers may also find additional means to reduce emissions and lower fuel consumption beyond the technical approaches we describe here. We encourage such innovation through provisions in our flexibility program as discussed in Section IV. The remainder of this section describes the technical feasibility and cost analy sis in greater detail. Further detail on all of these issues can be found in the joint DRIA Chapter 2. 

### A. Class 7 - 8 Combination Tractors Class 7 and 8 tractors are used in combination with trailer s to transport freight. The variation in the design of these tractors and their ty pical uses drive different technology

solutions for each regulatory class. EPA and NHTSA collected information on the cost and effectiveness of fuel consumption and CO 2 emis sion reducing technologies from several sources. The primary sources of information were the recent National Academ y of Sciences report of Technologies and Approaches to Reducing the Fuel Consumption of Medium

- and Heav y - Duty

Vehicles (NAS) 117 , TIAX’s asses sment of technologies to support the NAS panel report (TIAX) 118 , EPA’s Heav y - dut y Lumped Parameter Model 119 , the analy sis conducted b y NESCCAF, I CCT, Southwest Research Institute and TIAX for reducing fuel consumption of heavy

- dut y long haul combination trucks (NESCCAF/ICCT) 120 , and the technology

cost anal ysis conducted b y ICF for EPA (I CF). 121 Following on the Energy Independence and Security Act of 2007, the National Research Council appointed a NAS committee to assess technologies for improving fuel efficiency of heavy

- duty vehicles to support NHTSA’s rulemaking. The NAS report assessed current and future technologies for reducing fuel consumption, how the technologies could be implemented, and identified the potential cost of such technologies. The NAS panel contracted TIAX to perform an assessment of technologies and their associated capital costs which provide potential fuel consumption reductions in heav y - duty trucks and engines. Similar to the Lumped Parameter model which EPA developed to assess the impa ct and interactions of GHG and fuel consumption reducing technologies for light

- dut y vehicles, EPA developed a new version to specificall y address the effectiveness and interactions of the proposed pickup truck and light heav y - dut y engine technologies. Th e NESCAFF/ICCT

117 National Academy of Science. Technologies and Approaches to Reducing the Fuel Consumption of Medium

- and Heavy - Duty Vehicles. March 31, 2010. 118 TIAX, LLC. Assessment of Fuel Economy Technologies for Medium

- and Heavy

- Duty Vehicles. November 2009. 119 U.S. EPA. Heavy
- duty Lumped Parameter Model. NEED DOCKET #. 120 NESCCAF, ICCT, Southwest Research Institute, and TIAX. Reducing Heavy

- Duty Long Haul Com bination Truck Fuel Consumption and CO2 Emissions. October 2009. 121 ICF International. Investigation of Costs for Strategies to Reduce Greenhouse Gas Emissions for Heavy
- Duty On

- Road Vehicles. June 2010.130 of 54 1

study assessed technologies available in the 2012 through 2017 to reduce CO 2 emissions and fuel consumption of line haul combination tractors and trailers. Lastly , the I CF report focused on the capital, maintenance, and operating costs of t echnologies currentl y available to reduce CO 2 emissions and fuel consumption in heavy

- dut y engines, combination tractors, and vocational vehicles. (1) What technologies did the agencies consider to reduce the CO 2 emissions and fuel consumption of tractors? Manufacturers can reduce CO 2 emissions and fuel consumption of combination tractors through engine, aerodynamic, tire, extended idle, and weight reduction technologies. The agencies note that SmartWay trucks are available today which incorporate the technolo gies that the agencies are considering as the basis for the standards in this proposal. . The standards are premised on use of these technologies. We will also discuss other technologies that could potentially be used, such as vehicle speed limiters, although we are not basing the proposed standards on their use for the model years covered b y this proposal, for various reasons discussed below. In this section we discuss the baseline tractor and engine technologies for the 2010 model year, and then disc uss the kinds of technologies that could be used to improve performance relative to this baseline. (a ) Baseline Tractor &Tractor Technologies Baseline tractor: The agencies developed the baseline tractor to represent the average 2010 model ye ar tractor. To day there is a large spread in aerody namics in the new tractor fleet. Trucks sold may reflect classic styling, or may be sold with conventional or SmartWay aerod yn amic packages. Based on our review of current truck model configurations and Polk data prov ided through MJ Bradley , 122 we believe the baseline new truck fleet aerodynamics represent approximately 25 percent classic, 70 percent conventional, and 5 percent SmartWay . The baseline Class 7/8 day cab tractor consists of an aerodynam ic package which clo sely resembles the “conventional” package described in Section II, baseline tire rolling resistance of 7.8 kg/metric ton for the steer tire and 8.2 kg/ metric ton, dual tires with steel wheels on the drive axles, and no vehicle speed limiter. The baselin e tractor for the Class 8 sleeper cabs contains the same aerod ynamic and tire rolling resistance technologies as the baseline day cab, does not include vehicle speed limiters, and does not include an idle reduction technology . The agencies assume the base line transmission is a 10 speed manual. Aerod ynamic technologies: There are opportunities to reduce aerodynamic drag from the tractor, but it is difficult to assess the benefit of individual aerodyn amic features. Therefore, it requires optimizing it as a sy stem. The potential areas to reduce drag include all sides of the truck

– front, sides, top, rear and bottom. The grill, bumper, and hood can be designed to minimize the pressure created b y the front of the truck.

122 MJ Bra dley. Heavy Duty Market Analysis. May 2009. Page 10.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

131 of 54 1 Technologies such as aerody namic mirrors and fuel tank fairings can reduce the surface area perpendicular to the wind and provide a smooth surface to minimize disruptions of the air flow. Roof fairings provide a transition to move the air smoothly over the tractor and trailer. Side extende rs can minimize the air entrapped in the gap between the tractor and trailer. Lastly , underbelly treatments can manage the flow of air underneath the tractor. As discussed in the TIAX report, the coefficient of drag (Cd) of a SmartWay sleeper cab high ro of tractor is approximately 0.60, which is a significant improvement over a truck with no aerody namic features which has a Cd value of approximately 0.80. The [TEST] model demonstrates that an aerodynamic improvement of a Class 8 high roof sleeper cab with a Cd value from 0.60 (which represents a SmartWay tractor) provides a 5% reduction in fuel consumption and CO 2 emissions over a truck with a Cd of 0.68. Lower Rolling Resistance Tires: A tire’s rolling resistance results from the tread compound material , the architecture and materials of the casing, tread design, the tire manufacturing process, and its operating conditions (surface, inflation pressure, speed, temperature, etc.). Differences in rolling resistance of up to 50% have been identified for tir es designed to equip the same vehicle. The baseline rolling resistance coefficient for today ’s fleet is 7.8 kg/metric ton for the steer tire and 8.2 kg/metric ton for the drive tire, based on sales weighting of the top three manufacturers based on market share. Since 2007 SmartWay

has steer tires with rolling resistance coefficients of less than 6.6 kg/metric ton for the steer tire and less than 7.0 kg/metric ton for the drive tire. Low rolling resistance drive tires are currentl y offered in both dual as sembly and single wide

base configurations. Single wide tires can offer both the rolling resistance reduction along with improved aerody namics and weight reduction. The [TEST] model demonstrates that replacing baseline tractor tires with tires which meet the SmartWay level provides a 4% reduction in fuel consumption and CO 2 emissions over the prescribed test cycle. Weight Reduction: The agencies’ baseline tire and wheel package consists of dual tires with steel wheels. A tractor’s empty curb weight can b e reduced from the replacement of dual tires with single wide tires and with the replacement of steel wheels with high strength steel or aluminum. Analy sis of literature indicates that there is opportunity

to reduce t yp ical tractor curb weights by 80 to 6 70 pounds, or up to roughl y 3 percent, through the use of lighter weight wheels and single wide tires. 123 High strength steel, aluminum, and light weight aluminum alloy s provide opportunities to reduce the truck’s mass relative to steel wheels. In addition , single wide tires (a single wide

- based tire which replaces two standard tires in each wheel position) provide the opportunity to reduce the overall mass of wheels and tires due to the replacement of dual tires with singles. On average, these technologie s together can reduce weight by over 400 pounds. A weight reduction of this magnitude applied to a truck which travels at 70,000 pounds will have a minimal impact on fuel consumption. However, for trucks which operate at the maximum GVWR which occurs approximately for one third of truck miles travelled, a reduced tare weight will allow for additional payload to be carried. The [TEST] model

123 NEED CITATION132 of 54 1

demonstrates that a weight reduction of 400 pounds applied to the payload tons for one third of the trips provides a 0.3% reduction in fuel consumption and CO 2 emissions over the prescribed test cycle. Extended I dle Reduction: Auxiliary power units, fuel operated heaters, battery supplied air conditioning, and thermal storage s ys tems are among the technologies available today

to reduce main engine extended idling from sleeper cabs. Each of these technologies reduces the baseline fuel consumption during idling from a truck without this equipment (the baseline) from approximately 0.8 gallons per hour (main engine idling f uel consumption rate) to approximately 0.2 gallons per hour for an APU. EPA and NHTSA agree with the NAS assessment of a 6 percent reduction in overall fuel consumption reduction. Vehicle Speed Limiters: Fuel consumption and GHG emissions increase propo rtional to the square of vehicle speed. Therefore, lowering vehicle speeds can significantl y reduce fuel consumption and GHG emissions. A vehicle speed limiter, which limits the vehicle's maximum speed, is a simple technology that is utilized today by so me fleets (though the ty pical maximum speed setting is often higher than 65 mph). The [TEST] model shows that using a vehicle speed limiter set at 62 mph will provide a 4% reduction in fuel consumption and CO 2 emissions over the prescribed test cycles ove r a baseline vehicle without a VSLor one set above 65 mph. Transmission: As discussed in the NAS report, automatic and automated manual transmissions may

offer the ability

to improve vehicle fuel consumption by optimizing gear selection compared to an av erage driver. However, as also noted in the report the improvement is very

dependent on the driver of the truck, such that reductions ranged from 0 to 8 percent. Well

- trained drivers would be expected to perform as well or even better than an automatic transmission since the driver can see the road ahead and anticipate a changing stoplight or other road condition that an automatic transmission can not anticipate. However, poorly

- trained drivers that shift too frequentl y or not frequentl y enough to mainta in optimum engine operating conditions could be expected to realize improved in

- use fuel consumption by switching from a manual transmission to an automatic or automated manual transmission. While we believe there may be real benefits in reduced fuel cons umption and GHG emissions through the application of automatic transmission technology , we are not proposing to reflect that potential improvement in our standard setting nor in our compliance model. We have taken this approach because we cannot say with confidence what level of performance improvement to expect. However, we welcome comments on this decision supported where possible with data. If a clear measure of performance improvement can be defined for the use of automatic transmission technologies, we will consider reflecting the technology

in setting the stringency

of the standards and in determining compliance with the standards. Low Friction Transmission, Axle, and Wheel Bearing Lubricants: The NAS report assessed low friction lubricants for the drivetrain as a 1 percent improvement in fuel consumption based on fleet testing. The light

- duty fuel econom y and GHG final rule and the pickup truck portion of this program estimate that low friction lubricants can haveDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

133 of 54 1 an effectiveness value between 0 and 1 percent compared to traditional lubricants. However, it is not clear if in many heavy dut y applications these low friction lubricants could have competing requirements like component durability issues requiring specific lubricants with different prop erties than low friction. The agencies are interested in comments on whether low friction lubricants should be included in the technologies available in [TEST] to set the fuel consumption and CO 2 emissions standards and how manufacturers could ensure the use of these lubricants for the full useful life of the truck. Hy brid: Hy brid powertrain development in Class 7/8 tractors has been limited to a few manufacturer demonstration vehicles to date. One of the key benefit opportunities for fuel consumption re duction with hy brids is less fuel consumption when a vehicle is idling, which are already included as a separate technology in the agencies’ technology assessment. NAS estimated that hy brid s ys tems would cost approximately $25,000 per truck in the 2015 through 2020 timeframe and provide a potential fuel consumption reduction of 10 percent, of which 6 percent is idle reduction which can be achieved through other idle reduction technologies. 124 The limited reduction potential outside of idle reduction for Cla ss 8 sleeper cab tractors is due to the mostly highway operation and limited start

- stop operation. Due to the high cost and limited benefit during the model ye ars at issue in this proposal, the agencies are not including hy brids in assessing standard stri ngency

(or as an input to [TEST]). However as discussed in Section IV, the agencies are providing incentives to encourage the introduction of advanced technologies including h ybrid powertrains in appropriate applications. Management: The NAS report noted man y operational opportunities to reduce fuel consumption, such as driver training and route optimization. The agencies have included discussion of several of these strategies in the DRIA, but are not using these approaches or technologies in the standard setting process. The agencies are looking to other resources, such as EPA’s SmartWay Transport Partnership and regulations that could potentially

be promulgated by

the Federal Highway

Administration and the Federal Motor Carrier Safet y Administration, t o continue to encourage the development and utilization of these approaches. (b ) Baseline Engine & Engine Technologies The baseline engine for the Class 8 tractors is a Heav y Heavy
- D ut y Diesel engine with 15 liters of displacement which produces 455 horsepow er. The agencies are using a smaller baseline engine for the Class 7 tractors because of the lower combined weights of this class of vehicles require less power, thus the baseline is an 11L engine with 350 horsepower. The agencies developed the baseline diesel engine as a 2010 model year engine with an aftertreatment sy stem which meets EPA’s 0.2 grams of NOx/bhp

- hr standard with a selective catal yt ic reduction (SCR) sy stem along with EGR and meets the PM emissions standard with a diesel particulate filter (DPF) with active regeneration. The baseline engine is turbocharged with a variable geometry turbocharger. The

124 See page 6

- 28 of NAS report.134 of 54 1

following discussion of technologies describes improvements over the 2010 model y ear baseline engine performance, unless otherwise noted. Fur ther discussion of the baseline engine and its performance can be found in section III.A.2.6 below. Turbochargers: Improved efficiency of a turbocharger compressor or turbine could reduce fuel consumption by approximately 1 to 2 percent over variable ge ometry turbochargers in the market today . The NAS report identified technologies such as higher pressure ratio radial compressors, axial compressors, and dual stage turbochargers as design paths to improve turbocharger efficiency. Low Temperature Exhaust Gas Recirculation: Most medium

- and heav y - duty vehicle diesel engines sold in the U.S. market today use cooled EGR, in which part of the exhaust gas is routed through a cooler (rejecting energy to the engine coolant) before being returned to the engine int ake manifold. EGR is a technology employed to reduce peak combustion temperatures and thus NOx . Low
- temperature EGR uses a larger or secondary EGR cooler to achieve lower intake charge temperatures, which tend to further reduce NOx formation. If the NOx re quirement is unchanged, low

- temperature EGR can allow changes such as more advanced injection timing that will increase engine efficiency slightl y more than 1 percent. Because low

- temperature EGR reduces the engine’s exhaust temperature, it may not be compatible with exhaust energy recovery sy stems such as turbocompound or a bottoming cycle. Engine Friction Reduction: Reduced friction in bearings, valve trains, and the piston

- to
- liner interface will improve efficiency . Any friction reduction must be caref ully developed to avoid issues with durability or performance capabilit y. Estimates of fuel consumption improvements due to reduced friction range from 0.5% to 1.5%. 125 Selective catal yt ic reduction (SCR): This technology is common on 2010 the medium

- and heav y - duty diesel engines used in Class 7/8 tractors. Because SCR is a highl y effective NOx aftertreatment approach, it enables engines to be optimized to maximize fuel efficiency, rather than minimize engine

- out NO x . 2010 SCR sy stems are estimated to r esult in improved engine efficiency of approximately

4 to 5 percent compared to a 2007 in

- cy linder EGR

- based emissions sy stem and b y an even greater percentage compared to 2010 in

- cylinder approaches. 126 As more effective low

temperature catal ys ts are devel oped, the NO x conversion efficiency of the SCR sy stem will increase. Next

- generation SCR sy stems could then enable additional efficiency improvements; alternatively , these advances could be used to maintain efficiency while down

- sizing the aftertreatment. We estimate that continued optimization of the catal ys t

125 TIAX, Assessment of Fuel Economy Technologies for Medium

- and Heavy

- Duty Vehicles, Final Report, Nov. 19, 2009, pg 4

- 15 126 Stanton, D. “Advanced Diese l Engine Technology Development for High Efficiency, Clean Com bustion.” Cummins, Inc. Annual Progress Report 2008 Vehicle Technologies Program: Advanced Com bustion Engine Technologies, US Department of Energy. Pp 113

- 116. December 2008.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

135 of 54 1 could offer 1 to 2 percent additional reduction in fuel use over 2010 model year sy stems. 127 Improved Combustion Process: Fuel consumption reductions in the range of 1 to 3 percent over the baseline d iesel engine are identified in the NAS report through improved combustion chamber design, higher fuel injection pressure, improved injection shaping and timing, and higher peak cylinder pressures. Reduced Parasitic L oads: Accessories that are traditionall y gear or belt driven by a vehicle’s engine can be optimized and/or converted to electric power. Examples include the engine water pump, oil pump, fuel injection pump, air compressor, power

- steering pump, cooling fans, and the vehicle’s air

- conditioning s y stem. Optimization and improved pressure regulation may significantl y reduce the parasitic load of the water, air and fuel pumps. Electrification may result in a reduction in power demand, because electrically

powered accessories (such as the air compress or or power steering) operate only when needed if they are electrically powered, but they

impose a parasitic demand all the time if they

are engine driven. In other cases, such as cooling fans or an engine’s water pump, electric power allows the accessory to run at speeds independent of engine speed, which can reduce power consumption. The TIAX [2009, pg. 3

- 5] study used 2 to 4 percent fuel consumption improvement for accessory electrification, with the understanding that electrification of accessories will have more effect in short

- haul/urban applications and less benefit in line

- haul applications. Mechanical Turbocompounding: Mechanical turbocompounding adds a low pressure power turbine to the exhaust stream in order to extract additional energy , which is then delivered to the crankshaft. Published information on the fuel consumption reduction from mechanical turbocompounding varies between 2.5 and 5 percent. 128 Some of these differences may

depend on the operating condition or duty cycle that was considere d by

the different researchers. The performance of a turbocompounding s ys tem tends to be highest at full load and much less or even zero at light load. Electric Turbocompounding: This approach is similar in concept to mechanical turbocompounding, except that the power turbine drives an electrical generator. The electricit y produced can be used to power an electrical motor supplementing the engine output, to power electrified accessories, or to charge a h ybrid s ys tem battery . None of these sy stems have b een demonstrated commercially , but modeled results by industry and DOE have shown improvements of 3 to 5 percent. 129 Bottoming C ycle: An engine with bottoming cycle uses exhaust or other heat energy from the engine to create power without the use of additio nal fuel. The sources of

127 TIAX Assessment o f Fuel Economy Technologies for Medium and Heavy
- duty Vehicles, Report to National Academy of Sciences, Nov 19, 2009, pg. 4

- 9 128 NESCCAF/ICCT study (p. 54) and TIAX (2009, pp. 3

- 5) 129 K. G. Duleep of Energy and Environmental Analysis, R. Kruiswyk, 2008, pp. 212

- 214, NESCCAF/ICCT, 2009, p. 54136 of 54 1

energy include the exhaust, EGR, charge air, and coolant. The estimates for fuel consumption reduction range up to 10 percent as documented in the NAS report. (2) Projected Technology Package Effectiveness and Cost (a ) Class 7/8 Combination Tractors EPA and NHTSA project that CO 2 emissions and fuel consumption reductions can be achieved through the increased application of aerodyn amic technologies, low rolling resistance tires, weight reduction, extended idle reduction technologies, vehi cle speed limiters, and engine improvements. As discussed above, the agencies believe that hy brid powertrains in tractors will not be cost

- effective in the time frame of the rules. The agencies also are not proposing to include drivetrain technologies in the standard setting process, as discussed in Section II. The agencies evaluated each technology and estimated the most appropriate application rate of technology into each tractor regulatory class based on our understanding of the industry sectors into which the trucks would be applied. The next sections describe the effectiveness of the individual technologies, the costs of the technologies, the projected application rates of the technologies into the regulatory classes, and finally

the derivation of the proposed standards. (i ) Baseline Tractor Performance The agencies developed the baseline tractor for each subcategory to represent an average 2010 model ye ar tractor configured as noted earlier. The approach taken by the agencies was to define the individ ual inputs to [TEST]. For example, the agencies evaluated the industry ’s tractor offerings and concluded that the average tractor contains a generally

aerody namic shape (such as roof fairings) and avoids classic features such as exhaust stacks at the b

- pi llar which increase drag. The agencies consider a baseline truck as having “conventional” aerodynamic package, though today there is a large spread in aerod ynamics in the new tractor fleet. As noted earlier, our assessment of the baseline new truck fleet aerod ynamics represents approximately 25 percent classic, 65 percent conventional, and 10 percent SmartWay . This mix of vehicle aerody namics provides a Cd performance level slightl y greater than the “conventional aerodyn amic package” Cd value (for exampl e the baseline high roof tractor has a Cd of 0.69 while the same tractor category with a conventional aerody namic package has a Cd of 0.68). The baseline rolling resistance coefficient for today ’s fleet is 7.8 kg/metric ton for the steer tire and 8.2 kg/m etric ton for the drive tire, based on sales weighting of the top three manufacturers based on market share. 130

130 US Environmental Protection Agency. SmartWay Transport Partnership July 2010 e

- update accessed July 16, 2010, from http://www. epa.gov/smartwaylogistics/newsroom/documents/e

- update

- july

- 10.pdf

.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

137 of 54 1 Table III - 1 : Baseline Tractor Definitions Class 7 Class 8 Day Cab Day Cab Sleeper Cab Low/Mi d Roof High Roof Low/Mid Roof High Roof Low Roof Mid

Roof High Roof Aerodynamics (Cd) Frontal Area (m 2 ) 6.0 9.8 6.0 9.8 6.0 6.6 9.8 Baseline 0.81 0.69 0.81 0.69 0.81 0.76 0.69 Steer Tires (Crr kg/metric ton) Baseline 7.8 7.8 7.8 7.8 7.8 7.8 7.8 Drive Tires (Crr kg/metric ton) Baseline 8.2 8.2 8.2 8.2 8.2 8.2 8.2 Weight Reduction (lbs.) Baseline 0 0 0 0 0 0 0

Extended Idle Reduction (gram CO 2 /ton - mile reduction) Baseline N/A N/A N/A N/A 0 0 0 Vehicle Speed Limiter Baseline
-- -- -- -- -- -- -- Engine Baseline 2010 MY

11 L Engine 2010 MY

11 L Engine 2010 MY

15 L Engine 2010 MY

15 L Engine 2010 MY

15 L Engine 2010 MY

15 L Engine 2010 MY

15 L Engine The agencies use the inputs described in Table III
- 1 in [TEST] to deri ve the baseline CO 2 emissions and fuel consumption of Class 7/8 tractors. The results are included in Table III
- 2

.

Table III - 2 : Class 7/8 Tractor Baseline CO 2 Emissions and Fuel Cons um ption

Class 7 Class 8 Day Cab Day Cab Sleeper Cab Low Roof High Roof Low Roof High Roof Low Roof Mid Roof High Roof CO 2 (grams CO2/ton
- mi le) 115 135 86 98 76 77 89 Fuel Consumption (gal/1000 ton
mi le) 11.3 13.3 8.4 9.6 7.5 7.6 8.7

(ii) Tractor Tech nology Package Effectiveness The agencies’ assessment of the proposed technology effectiveness was developed through the use of the [TEST] Model in coordination with chassis testing of three SmartWay

certified Class 8 sleeper cabs. The agencies developed technology138 of 54 1

performance characteristics for each subcategory , described below. Each technology consists of an input parameter which is in turn modeled in [TEST]. Table III
- 3 describes our proposed model inputs for the range of Cl ass 7 and 8 tractor aerodyn amic packages and vehicle technologies. This was combined with a projected technology application rate to determine the stringency of the proposed standard. The aerod ynamic packages are categorized as Classic, Conventional, SmartWay , Advanced SmartWay , and Advanced SmartWay II. The Classic aerody

namic package refers to traditional styling such as a flat front, exposed air cleaners and exhaust stacks, among others. The conventional package refers to an overall aerodyn amic appearance and best represents the aerody namics of the majority

of new tractor sales. The SmartWay aerod ynamic package includes technologies such as roof fairings, aerodyn amic hoods, aerod ynamic mirrors, chassis fairings, and cab extenders. The Advanced SmartWay and Advanced SmartWay

II packages reflect different degrees of new aerodyn amic technology

development such as active air management. A more complete description of these aerod ynamic packages is included in Chapter 2 of the draft RIA. In general, the c oefficient of drag values for each package and tractor subcategory were developed from EPA’s coast down testing of tractor

- trailer combinations, the NAS report, and SAE papers. The rolling resistance coefficient for the tires was developed from SmartWay ’ s tire testing to develop the SmartWay certification. The benefits for the extended idle reductions were developed from literature, SmartWay work, and the NAS report. The weight reductions were developed from manufacturer information.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

139 of 54 1 Table III - 3 Class 7 - 8 Tractor Technology Values Class 7 Class 8 Day Cab Day Cab Sleeper Cab Low Roof High

Roof Low

Roof High

Roof Low

Roof Mid

Roof High

Roof Aerodynamics (Cd) Frontal Area (m 2 ) 6.0 9.8 6.0 9.8 6.0 6.6 9.8 Classic 0.85 0.75 0.85 0.75 0.85 0.80 0.75 Conventional 0.80 0.68 0.80 0.68 0.80 0.75 0.68 Sm art Wa y 0.75 0.60 0.75 0.60 0.75 0.70 0.60 Advanced Smart

Wa y 0.70 0.55 0.70 0.55 0.70 0.65 0.55 Advanced Smart

Wa y II 0.65 0.50 0.65 0.50 0.65 0.60 0.50 S teer Tires (Crr kg/metric ton) Baseline 7.8 7.8 7.8 7.8 7.8 7.8 7.8 Sm art Wa y 6.6 6.6 6.6 6.6 6.6 6.6 6.6 Advanced Smart

Wa y 5.7 5.7 5.7 5.7 5.7 5.7 5.7

Drive Tires (Crr kg/metric ton) Baseline 8.2 8.2 8.2 8.2 8.2 8.2 8.2 Sm art Wa y 7.0 7.0 7.0 7.0 7.0 7 .0 7.0 Advanced Smart

Wa y 6.0 6.0 6.0 6.0 6.0 6.0 6.0

Weight Reduction (lbs.) Baseline 0 0 0 0 0 0 0 Control 400 400 400 400 400 400 400

Extended Idle Reduction (gram CO 2 /ton - mile reduction) Baseline N/A N/A N/A N/A 0 0 0 Control N/A N/A N/A N/A 5 5 5 Vehicle Speed Limiter 131 Baseline N/A N/A N/A N/A N/A N/A N/A Control N/A N/A N/A N/A N/A N/A N/A
(iii) Tractor Technology Application Rates Vehicle manufacturers often introduce major product changes together, as a package. In this manner the manufacturers can optimize their available resources, including engineering, development, manufacturing and marketing activities to create a product with multiple new features. In addition, manufacturers recognize that a truck design will need to remain competitiv e over the intended life of the design and meet future regulatory

requirements. In some limited cases, manufacturers may implement an individual technology

outside of a vehicle’s redesign cycle. In keeping with these

131 Vehicle speed limiters are an applicable technology for all Class 7/8 tractors, however the standards are not premised on the use of this technology.140 of 54 1

industry practices, the agencies have created a set of vehicle technology packages for each regulatory

class of Class 7/8 combination tractors. With respect to the levels of technology application used to develop the proposed standards, NHTSA and EPA established technology application constra ints. The first ty pe of constraint was established based on the application of fuel consumption and CO 2 emission reduction technologies into the different ty pes of tractors. For example, idle reduction technologies are limited to Class 8 sleeper cabs usin g the assumption that day cabs are not used for overnight hoteling. A second ty pe of constraint was applied to most other technologies and limited their application based on factors reflecting the real world operating conditions that some combination trac tors encounter. This second ty pe of constraint was applied to the aerodyn amic, tire, and vehicle speed limiter technologies. Table III
- 4 specifies the application rates that EPA and NHTSA used to develop the proposed standards. The impact of aerodynamics on a truck’s efficiency increases with vehicle speed. Therefore, the usage pattern of the truck will determine the benefit of various aerod ynamic technologies. Sleeper cabs are often used in line haul applications and drive the majority

of their miles on the highway travelling at speeds greater than 55 mph. The industry has focused aerody

namic technology

development, including SmartWay tractors, on these t yp es of trucks. Therefore the agencies are proposing the most aggressive aerod yn amic technology application to this regulatory class. All of the major manufacturers today

offer at least one SmartWay truck model. The NAS Report on heav y - dut y truck found that manufacturers indicated that aerodyn amic improvements which yield 3 to 4 percent fuel consumption reduction or 6 to 8 percent reduction in Cd values, beyond technologies used in today ’s SmartWay trucks are achievable. 132 EPA and NHTSA are proposing that the aerodyn amic application rate for Class 8 sleeper cab high roof cabs to consist of 20 percent of Advanced SmartWay , 70 percent SmartWay , and 10 percent conventional reflecting our assessment of the fraction of tractors in this segment that can successfully appl y these aerodyn amic packages. The small percentage of conventi onal truck aerody namics reflects applications including tractors serving as refuse haulers which spend a portion of their time off

- road at the land fill and generall y operate at lower speeds with frequent stops further reducing the benefit of aggressive ae rod ynamic technologies. Features such as chassis skirts are prone to damage in off

road applications; therefore we are not proposing to require that all trucks have chassis skirts or achieve GHG reductions premised on use of such technology . The 90 perce nt of tractors that we project can either be SmartWay or Advanced SmartWay

equipped reflect the bulk of Class 8 high roof sleeper cab applications. We are not projecting a higher fraction of Advanced SmartWay aerod yn amic s ys tems because of the limited lea d time for the program and the need for these more advanced technologies to be developed and demonstrated before being carried across a wider fraction of the fleet. Our averaging, banking and trading provisions provide manufacturers with the flexibility t o implement

132 TIAX. Assessment of Fuel Economy Technologies for Medium

- and Heavy

- Duty Vehicles. November 2009. Page 4

- 40.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

141 of 54 1 these technologies over time even though the standard changes in a single step. We request comment on our assessment of the potential for use of Advanced SmartWay technologies and the need for a fraction of these vehicles to continue to remain configured as conventional cabs due to their occasional use off

- road. The proposed aerod yn amic application for the other tractor regulatory categories is less aggressive than for the Class 8 sleeper cab high roof. The agencies recognize that there are tr

uck applications which require on/off

- road capability

and other truck functions which restrict the t ype of aerod ynamic equipment applicable. We also recognize that these ty pes of trucks spend less time at highway speeds where aerody

namic technologies have the greatest benefit. The 2002 VIUS data ranks trucks by major use. 133 The heav y trucks usage indicates that up to 35 percent of the trucks may be used in on/off

- road applications or heavier applications. The uses include construction (16%), agriculture (12%), waste management (5%), and mining (2%). Therefore, the agencies analyzed the technologies to evaluate the potential restrictions that would prevent 100 percent application of SmartWay technologies for all of the tractor regulatory classes. Trucks d esigned for on/off

- road application may

be restricted in the ability to improve the aerodynamic design of the bumper, chassis skirts, air cleaners, and other aspects of the truck which would ty picall y be needed to move a conventional truck into the SmartWay bin. First, off

- road applications may

require the use of steel bumpers which tend to be less aerody namic than plastic designs. Second, ground clearance may be an issue for some off road applications due to poor road surface quality . This may pose a gr eater likelihood that those items such as chassis skirts would incur damage in use and therefore would not be a technology desirable in these applications. Third, the trucks used in off

- road applications may

also experience dust which requires an addition al air cleaner to manage the dirt. Fourth, some trucks are used in applications which require heavier load capacity , such as those with gross combined weights of greater than 80,000 pounds, which is today ’s federal highway limit. Often these trucks are c onfigured with different axle combinations than those traditionally used on

- road. These trucks may

contain either a lift axle or spread axle which allows for greater carryi ng capabilit y. Both of these configurations limit the design and effectiveness of chassis skirts. Lastly , some work trucks require the use of power take off (PTO) operation or access to equipment which may limit the application of side extenders and chassis skirts. The agencies considered the on/off

- road restriction to aerody namic te chnology application, used VIUS estimate of approximately 35 percent of tractors may be used in this ty pe of application, and used confidential data provided by truck manufacturers regarding the fraction of their current sales which go into the various app lications, to project the aerodynamic application rates for each tractor category. For example, the agencies project that day

cabs with low roofs will be used more often in these on/off

- road applications than day

cabs with high roof. Therefore, the agenc ies project technology

133 U.S. Department of Energy. Transportation Energy Data Book, Edition 28

- 2009. Table 5.7.142 of 54 1

application rate for conventional aerodyn amics in day cab low roof as 40 percent while it would be 30 percent in day cab high roofs tractors. The agencies have also estimated that the development of advanced aerodynamic technologies would be applied first to high roof sleeper cabs and then follow with the other tractor categories. Therefore, the agencies propose a 10 percent application rate of the Advanced SmartWay aerod ynamic technology

package to the other tractor categories. Th e agencies welcome comment on our assessment of application rates and are interested in data which provides estimates on truck sales to the various applications where aerody namics are less effective or restricted. At least one low rolling resistance tire m odel is available today which meet the rolling resistance requirements of the SmartWay and Advanced SmartWay tire packages, therefore EPA believes the 2014 model year provides sufficient lead time for tractor manufacturers for purposes of the proposed CO 2 regulations. However, tire rolling resistance is onl y one of several performance criteria that affect tire selection. The characteristics of a tire also influence durability , traction control, vehicle handling, comfort, and retreadability. A single perf ormance parameter can easil y be enhanced, but an optimal balance of all the criteria must be maintained. Tire design requires balancing performance, since changes in design may change different performance characteristics in opposing directions. Similar to the discussion regarding lesser aerodynamic technology

application in tractor segments other than sleeper cab high roof, the agencies believe that low rolling resistance tires should not be applied to 100% of all tractor segments. The agencies are prop osing application rates that vary by category and match the application rates used for the aerodynamic packages to reflect the on/off

- road application of some tractors which require a different balancing of traction versus rolling resistance. We are seeki ng comment on our assessment. Weight reductions can be achieved through single wide tires replacing dual tires and lighter weight wheel material. Single wide tires can reduce weight b y over 160 pounds per axle. Aluminum wheels used in lieu of steel wheel s will reduce weight b y over 80 pounds for a dual wheel axle. L ight weight aluminum steer wheels and aluminum single wide drive wheels and tires package available today would provide a 670 pound weight reduction over the baseline steel steer and dual driv e wheels. The agencies are proposing 100% application of a technology package which reduces vehicle weight b y 400 pounds which takes into account that not all tractors can or will use single wide tires. The agencies are unaware of reasons why a combinati on of lower weight wheels or tires cannot be applied to all trucks, but welcome comments. Idle reduction technologies provide significant reductions in fuel consumption and CO 2 emissions for Class 8 sleeper cabs and are available on the market today, an d therefore will be available in the 2014 model y ear. There are several different technologies available to reduce idling. These include auxiliary power units, diesel fired heaters, and battery

powered units. Our discussions with manufacturers indicate that idle technologies are sometimes installed in the factory, but it is also a common practice to have the units installed after the sale of the truck. We would like to continue to incentivize this practice while providing certainty that the overnight id le operations will be eliminated. Therefore, we are allowing the installation of only an automatic engine shutoff, without override capability , to qualify for idle emission reductions in [TEST] toDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

143 of 54 1 allow for aftermarket installations of idle reduction technology . We are proposing a 100 percent application rate for this technology for Class 8 sleeper cabs. The agencies are unaware of reasons wh y extended idle reduction technologies could not be applied to all tractors with a sleeper cab, but welcome comments. Vehicle speed limiters may be used as a technology

to meet the standard, but in setting the standard we assumed a 0 percent application rate of vehicles speed limiters. While we believe vehicles speed limiters are a simple, eas y to implement, and inexpensive technology , we want to leave the use of vehicles speed limiters to the truck purchaser. Since truck fleets purchase trucks today with owner set vehicle speed limiters, we considered not including VSLs in our compliance model. However, we have concluded that we should allow the use of VSLs that cannot be overridden by the operator as a means of compliance for truck OEMs that wish to offer it and truck purchasers that wish to purchase the technology . In doing so, we are providing another means o f meeting that standard that can lower compliance cost and provide a more optimal vehicle solution for some truck fleets. For example, a local beverage distributor may operate trucks in a distribution network of primarily local roads. Under those conditi ons, aerod ynamic fairings used to reduce aerodynamic drag provide little benefit due to the low vehicle speed while adding additional mass to the vehicle. An OEM could choose to install a VSLset a 55 mph for this customer. The resulting truck modeled in [TEST] could meet our proposed emission standard without the use of an y specialized aerod ynamic fairings. The resulting truck would be optimized for its intended application and would be fully compliant with our program all at a lower cost to the ultimat e truck purchaser. We are seeking comment on the use of VSL s that cannot be overridden b y the end

- user as a means of compliance with our proposed standards. We have chosen not to assume the use of a mandatory vehicle speed limiter in our proposal becaus e of concerns about how to set a realistic application rate that avoids unintended adverse impacts. While we expect there will be some use of VSL , currentl y it is used when the fleet involved decides it is feasible and practicable and increases the overal l efficiency

of the freight s ys tem for that fleet operator. However at this point in time the agencies are not in a position to determine how many additional situations would be able to use a VSLwith similar benefits to overall efficiency . Setting a man datory expected use of such VSL carries the risk of requiring VSL in situations that are not appropriate from an efficiency perspective. To avoid such error, the agencies are not using a specified application rate for VSL, and instead will rel y on the ind ustry to select VSLwhen circumstances are appropriate for its use. Implementation of this program may provide greater information for using this technology in standard setting in the future. Man y stakeholders including the American Trucking Association have advocated for more widespread use of vehicle speed limits to address fuel efficiency and greenhouse gas emissions. We welcome comments on our decision not to premise the emission standards on the use of VSL s. Table III
- 4 pr ovides the proposed application rates of each technology broken down by weight class, cab configuration, and roof height.144 of 54 1 Table III - 4

– Proposed Technology Application Rates for Class 7 and 8 Tractors

Class 7 Class 8 Day Cab Day Cab Sleeper Cab Low Roof High Roof Low Roof High Roof Low Roof Mid Roof High

Roof Aerodynamics (Cd) Classic 0% 0% 0% 0% 0% 10% 0% Conventional 40% 30% 40% 30% 30% 20% 10% Sm art Wa y 50% 60% 50% 60% 60% 60% 70% Advanced Smart

Wa y 10% 10% 10% 10% 10% 10% 20% Advanced Smart

Wa y II 0% 0% 0% 0% 0% 0% 0% Steer Tires (Crr kg/metric ton) Baseline 40% 30% 40% 30% 30% 30% 10% Sm art Wa y 50% 60% 50% 60% 60% 60% 70% Advanced Smart

Wa y 10% 10% 10% 10% 10% 10% 20%

Drive Tires (Crr kg/metric t on) Baseline 40% 30% 40% 30% 30% 30% 10% Sm art Wa y 50% 60% 50% 60% 60% 60% 70% Advanced Smart

Wa y 10% 10% 10% 10% 10% 10% 20% Weight Reduction (lbs.) Baseline 0% 0% 0% 0% 0% 0% 0% Control 100% 100% 100% 100% 100% 100% 100%

Extended Idle Reduction (gra m CO 2 /ton - mile reduction) Baseline Not Applicabl e Not Applicable Not

Applicabl e Not Applicabl e 0% 0% 0%
Control Not Applicabl e Not Applicable Not

Applicabl e Not Applicabl e 100% 100% 100% Vehicle Speed Limiter Baseline 0% 0% 0% 0% 0% 0% 0% Control 0% 0 % 0% 0% 0% 0% 0%

(iv) Derivation of the Proposed Tractor Standards The agencies used the technology inputs and proposed technology application rates in [TEST] to develop the fuel consumption and CO 2 emissions standards for each subcategory

of Class 7/8 combination tractors. The agencies derived a scenario truck for each subcategory

by weighting the individual [TEST] input parameters included in Table III
- 3 by the application rates in Table III
- 4 . For example, the Cd value for a Class 8 Sleeper Cab High Roof scenario case was derived as 10 percent times 0.68 plus 70Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

145 of 54 1 percent times 0.60 plus 20 percent times 0.55, which is equal to a Cd of 0.60. Similar calculations were done for tire rolling resistance, we ight reduction, idle reduction, and vehicle speed limiters. To account for the two proposed engine standards, EPA is proposing the use of a 2014 model year fuel consumption map in [TEST] to derive the 2014 model year tractor standard and a 2017 model y ear fuel consumption map to derive the 2017 model y ear tractor standard. The agencies then ran [TEST] with a single set of vehicle inputs, as shown in Table III
- 5 , to derive the standards for each subcategory

. Additional detail is provided in the draft RIA Chapter 2.

Table III - 5 : [TEST] Inputs for the Class 7/8 Tractor Standard Setting

Class 7 Class 8 Day Cab Day Cab Sleeper Cab Low Roof High Roof Low Roof High Roof Low Roof Mid Roof High Roof Aerodynamics (Cd) 0.77 0.62 0.77 0.62 0.76 0.69 0.620 Steer Tire CRR (k g/ me tric ton) 6.99 6.87 6.99 6.87 6.87 6.87 6.54 Drive Tire CRR (k g/m etric ton) 7.38 7.26 7.38 7.26 7.26 7.26 6.92 We ight Reduction (lbs.) 400 400 400 400 400 400 400 Extended Idle Reduction (g/ton
- mi le) -- -- -- -- 5 5 5 Vehicle Speed Limiter
-- -- -- -- -- -- -- 2014 MY Standard Engine 2014 MY 11L 2014 MY

11L 2014 MY

15L 2014 MY

15L 2014 MY

15L 2014 MY

15L 2014 MY

15L 2017 MY Standard Engine 2017 MY 11L 2017 MY

11L 2017 MY

15L 2017 MY

15L 2017 MY

15L 2017 MY

15L 2017 MY

15L The level of the 2017 model year standard and percent reduction over the baseline for each class is included in Table III
- 6

.

Table III - 6 : Proposed 2017 Model Year Tractor Reductions

Class 7 Class 8 Day Cab Day Cab Sleeper Cab Low Roof High Roof Low Roof High Roof Low Roof Mid Roof High Roof Fuel Consumption Standard (gallon/1000 ton
mi le) 10.4 11.8 7.9 8.6 6. 4 6.4 7.1 CO2 Standard (grams CO2/ton
- mi le) 106 120 80 88 65 65 72 Percent Reduction 9% 12% 7% 10% 15% 16% 19%

A summary

of the proposed technology package costs is included in Table III
- 7 with additional details available in the draft RIA Chapter 2.146 of 54 1 Table III - 7 : Class 7 - 8 Tractor Technology Costs inclusive of Indirect Cost Markups in the 2014 Model Year a (2008$) Class 7 Class 8 Day Cab Day

Cab Sleeper Cab Low Roof High

Roo f Low

Roof High

Roof Low

Roof Mid

Roof High

Roof Aerodynamics $975 $1,216 $647 $1,215 $1,025 $1,152 $1,527 Steer Tires $65 $65 $65 $65 $65 $65 $65 Drive Tires $60 $60 $121 $121 $121 $121 $121 Weight Reduction $1,472 $1,472 $2,421 $2,421 $2,421 $2,421 $2,421 Auxiliary Power Unit N/A N/A N/A N/A $5,228 $5,228 $5,228 Air Conditioning $21 $21 $21 $21 $21 $21 $21 Total $2,593 $2,835 $3,275 $3,842 $8,881 $9.007 $9,382

a Costs shown are for the 2014 model year so do not reflec t learning impacts which would result in lower costs for later model years. For a description of the learning impacts considered in this analysis and how it impacts technology costs for other years, refer to Chapter 2 of the draft RIA. b Note that values in this table include penetration rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated classes. To see the actual estimated technology costs exclusive of penetration rates, refer to Chapter 2 of the dra ft RIA.
(v) Alternative Tractor Standards Considered The agencies are not proposing tractor standards less stringent than the proposed standards because the agencies believe these standards are appropriate, highly cost effective, and technologically feasible within the rulemaking time frame. The agencies considered proposing tractor standards which are more stringent than the proposed reflecting either the increased application rates of the technologies discussed or the inclusion of hy brid powertrains in trac tors. The agencies have proposed the maximum application rates feasible for the various tractor categories and their associated use. However, the agencies welcome comment on the application rates for each t ype of technology and for each tractor category.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

147 of 54 1 The agencies are not proposing a level of stringency premised on the use of hy brid technologies because our assessment is that the high cost of hy brids 134 with the relativel y low improvement is not cost effective for inclusion the 2017 model year. The ag encies welcome comments on whether h yb rid technologies are appropriate to consider for the 2017 model ye ar standard, or if not, then when would they be appropriate. (b ) Tractor Engines (i ) Baseline Engine Performance EPA and NHTSA developed the reference medium an d heav y heavy

- dut y diesel engine to represent a 2010 model year engine compliant with the 0.2 g/bhp

- hr NOx standard for on

- highway

heavy dut y engines. The agencies developed baseline SET values for medium and heavy heavy

- dut y diesel engines based on 2009 model year confidential manufacturer data and from testing conducted b y EPA. The agencies adjusted the pre - 2010 data to represent 2010 model ye ar engine maps by

using predefined technologies includ ing SCR and other sy stem s that are being used in current 2010 model year production . I f an engine utilized did not meet the 0.2 g/bhp

- hr NOx level, then the individual engine’s CO 2 result was adjusted to accommodate aftertreatment strategies that would result in a 0.2 g/bhp

- hr NOx emission level as described in DRIA Chapter 2. The engine CO 2 results were then sales weighted within each regulatory

class to develop an industry average 2010 model year reference engine. While most of the engines fell within a few percent of this baseline at least one engine was mo re than six percent above this average baseline.

Table III - 8 : 2010 Model Year Baseline Diesel Engine Perform ance CO 2 Emissions (g/bhp

- hr) Fuel Consumption

(gallon/100 bhp

- hr) Medium Heav y Diesel

- SET 518 5. 09 Heav y Heav y Diesel

- SET 490 4.81

(ii) Engine Technology Package Effectiveness The MHDD and HHDD engine technology package for the 2014 model ye ar includes engine friction reduction, improved aftertreatment effectiveness, improved combustion processes, and low temperature EGR sy stem optimization. The agencies

134 The NAS Report estimated that hybrid powertrains for tractors would cost $25,000 and provide a 10 percent reduction, though 6 percent of that reduction is already achievable through the extended idle reduction technologies included in the proposal (NAS Report, page 6

- 28).148 of 54 1

considered improvements in parasitic and friction losses through piston designs to reduce friction, improved lubrication, and improved water pump and oil pump designs to reduce parasitic losses. T he aftertreatment improvements are available through lower backpressure of the sy stems and optimization of the engine

- out NOx levels. Improvements to the EGR sy stem and air flow through the intake and exhaust sy stems, along with turbochargers can also pro duce engine efficiency improvements. We note that individual technology

improvements are not additive to each other due to the interaction of technologies. The agencies assessed the impact of each technology over each of the 13 SET modes to project an ove rall weighted SET cycle improvement in the 2014 model ye ar of 3 percent, as detailed in DRIA Chapter 2. The agencies proposal reflects a 100 percent application rate of this technology package. Recently , EPA’s non

- GHG heav y dut y engine program provided new criteria pollutant emissions standards for the industry in three year increments. The heavy dut y engine manufacturer product plans have fallen into three ye ar cycles to reflect these requirements. The agencies are proposing set fuel consumption and CO 2 emission standards recognizing the opportunity for technology

improvements over this timeframe while reflecting the ty

pical heav y dut y engine manufacturer product plan cycles. Thus, the agencies are proposing to set a more stringent standard for heav y d ut y engines beginning in the 2017 model y ear. The MHDD and HHDD engine technology package for the 2017 model ye ar includes the continued development of the 2014 model year technology package plus turbocompounding. A similar approach to evaluating the impa ct of individual technologies as taken to develop the overall reduction of the 2014 model year package was taken with the 2017 model year package. The weighted SET cycle improvements lead to a 6 percent reduction on the SET cycle, as detailed in DRIA Chap ter 2. The agencies proposal is premised on a 100 percent application rate of this technology package. The agencies believe that bottom cycling technologies are still in the development phase and will not be ready for production by the 2017 model year. 135 Therefore, these technologies were not included in determining the stringency of the proposed standards. However, we do believe the bottoming cycle approach represents a significant opportunit y to reduce fuel consumption and GHG emissions in the future. EPA and NHTSA are therefore both proposing provisions described in Section IV to create incentives for manufacturers to continue to invest to develop this technology

. (iii) Derivation of Engine Standards EPA developed the proposed 2014 model year CO 2 emissions standards for diesel engines b y appl yi ng the three percent reduction from the technology package to the 2010 model year baseline values. EPA developed the 2017 model year CO 2 emissions standards for diesel engines while NHTSA similarly developed the 2017 model year

135 TIAX noted in their report to the NAS commitee that the engine imp rovements beyond 2015 model year included in their report are highly uncertain, though they include waste heat recovery in the engine package for 2016 through 2020 (page 4

- 29).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

149 of 54 1 diesel engine fuel consumption standards by applyingthe 6 percent reduction from the 2017 model year technology package (reflecting performance of turbocompounding) to the 2010 model y ear baseline values. The proposed standards are included i n Table III
- 9

. Table III - 9 : Proposed Diesel Engine Standards Effective 2014 Model Year MHDD
- SET HHDD
- SET CO 2 Standard (g/bhp

- hr) 502 475 Optional Fuel Consumption Standard (ga llon/100 bhp

- hr) 4.93 4.67 Effective 2017 Model Year MHDD
- SET HHDD
- SET CO 2 Standard (g/bhp

- hr) 487 460 Fuel Consumption (gallon/100 bhp

- hr) 4.78 4.52

(iv) Engine Technology Package Costs EPA has historically

used two different approaches to estimate the indirect costs (sometimes called fixed costs) of regulations including costs for product development, machine tooling, new capital investments and other general forms of overhead that do not change with incremental changes in manufacturing volumes. Wh ere the Agency could reasonabl y make a specific estimate of individual components of these indirect costs, EPA has done so. Where EPA could not readil y make such an estimate, EPA has instead relied on the use of markup factors referred to as Indirect Cost Multipliers (ICMs) to estimate these indirect costs as a ratio of direct manufacturing costs. In general, EPA has used whichever approach it believed could provide the most accurate assessment of cost on a case b y case basis. The agencies’ general appro ach used elsewhere in this proposal (for HD pickup trucks, gasoline engines, Class 7/8 tractors, and Class 2b

- 8 vocational trucks) estimates indirect costs based on the use of I CMS. See also 75 FR at 25376. We have used this approach generall y because th ese standards are based on installing new parts and s ys tems purchased from a supplier. In such a case, the supplier is conducting the bulk of the research and development on the new parts and s ys tems and including those costs in the purchase price paid by the original equipment manufacturer. In this situation, we believe that the I CM approach provides an accurate and clear estimate of the additional indirect costs borne by the manufacturer. For the heav y - dut y diesel engine segment, however, the agencies do not consider this model to be the most appropriate because the primary cost is not expected to be the purchase of parts or s ys tems from suppliers or even the production of the parts and sy stems, but rather the development of the new technology by the o riginal equipment manufacturer itself. Most of the technologies the agencies are projecting the heav y - dut y engine manufacturers will use for compliance reflect modifications to existing engine sy stems rather than wholesale addition of technology ( e.g. , improved turbochargers rather150 of 54 1

than adding a turbocharger where it did not exist before as was done in our light

- duty joint rulemaking in the case of turbo

- downsizing). When the bulk of the costs come from refining an existing technology rather than a wholes ale addition of technology , a specific estimate of indirect costs may be more appropriate. For example, combustion optimization may

significantly

reduce emissions and cost a manufacturer millions of dollars to develop but will lead to an engine that is no more expensive to produce. Using a bill of materials approach would suggest that the cost of the emissions control was zero reflecting no new hardware and ignoring the millions of dollars spent to develop the improved combustion system. Details of the c ost anal ys is are included in the DRIA Chapter 2. The agencies developed the engineering costs for the research and development of diesel engines with lower fuel consumption and CO 2 emissions. The aggregate costs for engineering hours, technician support, dy namometer cell time, and fabrication of prototy pe parts are estimated at $6,750,000 per manufacturer per ye ar over the five y ears covering 2012 through 2016. In aggregate, this average out to $530 per engine during 2012 through 2016 using an annual sale s value of 280,000 medium

- HD and heav y - HD engines. The agencies also are estimating costs of $100,000 per engine manufacturer per engine class (medium

- HD and heav y - HD) to cover the cost of purchasing photo

- acoustic measurement equipment for two engine tes t cells. This would be a one

- time cost incurred in the y ear prior to implementation of the standard (i.e., the cost would be incurred in 2013). In aggregate, this averages out to $4 per engine in 2013 using an annual sales value of 280,000 medium

- HD and h eavy - HD engines. Where we projected that additional new hardware was needed to the meet the proposed standards, we developed the incremental costs for those technologies and marked them up using the I CM approach. Table III
- 10 belo w summarizes those estimates of cost on a per item basis. All costs shown in Table III
- 18 include a low complexity ICM of 1.11 and time based learning is considered applicable to each technology

.

Table III - 10 : Heavy - duty Diesel Engine Component Costs for Tractors (2008$)Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

151 of 54 1

2014 Model Year 2017 Model

Year Cy linder Head (flow optimized, increased firing pressure, improved thermal management) $6 $6 Exhaust Manifold (flow optimized, impr oved thermal management) $0 $0 Turbocharger (improved efficienc y) $17 $16 EGR Cooler (improved efficienc y) $3 $3 Wa ter Pump (optimized, variable vane, variable speed) $87 $79 Oil Pump (optimized) $4 $4 Fuel Pump (higher working pressure, increased eff iciency, improved pressure regulation) $4 $4 Fuel Rail (higher working pressure) $10 $9 Fuel Injector (optimized, improved multiple event control, higher working pressure) $10 $9 Piston (reduced friction skirt, ring and pin) $3 $2 Aftertreatment system (im proved effectiveness SCR, dosing, dpf) a $0 $0 Valve Train (reduced friction, roller tappet) $78 $71 Mechanical Turbocompounding $0 $823
a Note that costs for aftertreatment improvements for MH and HH diesel engines are covered via the engineering c osts (see text). For LH diesel engines, we have included the cost of aftertreatment im provements as a technology cost. The overall diesel engine technology package cost for a medium HD engine is $223 in the 2014 model year and $203 in the 2017 model y ear ; for a heavy HD engine these costs are $145 and $132, respectivel y; and for a heav y HD engine placed in a Class 8 sleeper cab these costs are $145 and $955, respectively . The differences for the medium HD engines are the valve train friction reduction cos ts of $78 in 2014 ($71 in 2017) that are not applied to heav y HD engines, and for Class 8 sleeper cab engines the difference is the turbocompounding cost of $823 in 2017 which is not applied to other engines. (v) Alternative Engine Standards Considered The ag encies are not proposing engine standards less stringent than the proposed standards because the agencies believe these proposed standards are appropriate, highl y cost effective, and technologicall y feasible, as described in Section VIII. The agencies con sidered proposing engine standards which are more stringent reflecting the inclusion of advanced heat recovery sy stems, such as Rankine or bottoming cycles. However, the agencies are not proposing this level of stringency because our assessment is that th ese technologies would not be available for production by the 2017 model year. The agencies welcome comments on whether waste heat recovery technologies are appropriate to consider for the 2017 model y ear standard, or if not, then when would they

be appro priate.152 of 54 1



### B. Class 2b and 3 Complete Pickup Trucks and Vans The process used to determine the standards the agencies are proposing for HD pickups and vans is described here. We started by gathering available information about the fuel consumption and CO 2 emiss ions from recent model year vehicles. The core portion of this information comes primaril y from EPA’s certification databases, CFEIS and VERIFY, which maintain the publicly available data 136 regarding emission and fuel econom y results. This information is not extensive because manufacturers have not been required to chassis test HD diesel vehicles for EPA’s criteria pollutant emissions standards, nor have they

been required to conduct any testing of heavy

- dut y vehicles on the highway

cycle. Nevertheless, e nough certification activity has occurred for diesels under EPA’s optional chassis

- based program, and due to a California NOx requirement for the highway

test cycle, enough test results have been voluntaril y reported for both diesel and gasoline vehicles u sing the highway test cycle, to yield a reasonably robust data set. To supplement this data set, for purposes of this rulemaking EPA initiated its own testing program using in

- use vehicles. This program and the results from it thus far are described in a memorandum to the docket for this rulemaking. 137 Heav y - dut y pickup trucks and vans are sold in a variety of configurations to meet market demands. Among the differences in these configurations that affect CO 2 emissions and fuel consumption are curb weight, GVWR, axle ratio, and drive wheels (2wd or 4wd). Because the currently

- available test data set does not capture all of these configurations, it is necessary to extend that data set across the product mix using adjustment factors. In this way a test resu lt from, say

a truck with 2wd, 3.73:1 axle ratio, and 8000 lb test weight, can be used to model emissions and fuel consumption from a truck of the same basic body design, but with 4wd, a 4.10:1 axle ratio, and 8500 lb test weight. The adjustment factors are based on data from testing in which only that parameter is varied. These parameterized adjustments and their basis are also described in a memorandum to the docket for this rulemaking. 138 The agencies requested and received from each of the three major m anufacturers confidential information for each model and configuration, indicating the values of each of these key

parameters as well as the annual production (for the U.S. market). Production figures are useful because, under our proposed standards for H D pickups and vans, compliance is judged on the basis of production

- weighted (corporate average) emissions or fuel consumption level, not individual vehicle levels. For consistency and to avoid confounding the anal ys is with data from unusual market condit ions in 2009, the production and vehicle specification data is from the 2008 model y ear. We made the simplifying assumption that these sales figures reasonably approximate future sales for purposes of this anal ys is.

136 http ://www.epa.gov/otaq/certdata.htm 137 Xx CJ memo cite 138 (xx cite TF memo to docket)Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

153 of 54 1 One additional assessment was needed to make the data set useful as a baseline for the standards selection. Because the appropriate standards are determined by applying efficiency

- improving technologies to the baseline fleet, it is necessary to know the level of penetration of these technologi es in the latest model year (2010) already

. This information was also provided confidentiall y by the manufacturers. Generall y, the agencies found that the HD pickup and van fleet was at a roughl y consistent level of technology

application, with (1) the transition from 4

- speed to 5

- or 6

- speed automatic transmissions mostly

accomplished, (2) coupled cam phasing to achieve variable valve control on gasoline engines likewise mostly in place, and (3) substantial remaining potential for optimizing cataly tic di esel NOx after treatment to improve fuel econom y (the new heav y dut y NOx standards having taken effect in the 2010 model year). Taking this 2010 baseline fleet, and appl yi ng the technologies determined to be feasible and appropriate by the 2018 model ye ar, along with their effectiveness levels, the agencies could then make a determination of appropriate standards. The assessment of feasibility , described in Section III.xx, took into account the projected costs of these technologies. The derivation of thes e costs, largely based on analy ses developed in the light

- duty GHG and fuel econom y rulemaking, are described at the beginning of Section II and in Section III.xx. Our assessment concluded that the technologies that the agencies considered feasible and app ropriate for HD pickups and vans could be consistently applied to all vehicles across this sector by the 2018 model year. Therefore we did not apply varying penetration rates across vehicle types and models in developing and evaluating the standards. The reader should remember, as explained in Section II.xx, that our decision to set standards that vary

linearly according to a weight

- based attribute (work factor) was appropriate, not to limitations in the application of technologies across the HD pickup an d van fleet, but rather to the impact that increasing test weight driven b y the work factor attribute has on CO2 emissions and fuel consumption, and on the correlation of HD vehicle utility

to the work factor. Since the manufacturers of HD pickups and vans generall y onl y have one basic pick

- up truck and van with different versions (( i.e. , different wheel bases, cab sizes, 2wd, 4wd, etc.) and do not have the flexibility of the light

- duty

like fleet to coordinate model improvements over several y ears, chang es to the HD pickups and vans to meet new standards must be carefully planned with the redesign cycle taken into account. The opportunities for large

- scale changes ( e.g. , new engines, transmission, vehicle body and mass) occur less frequently than in the light duty

fleet, ty pically at spans of 8 or more ye ars. However, opportunities for gradual improvements not necessarily linked to large scale changes can occur between the redesign cycles like upgrades to existing vehicle’s engine, transmission and after treatment s ys tems. Given this long redesign cycle and our understanding with respect to where the different manufactures are in that cycle, the agencies determined that the full implementation of the new standards would be feasible and appropriate b y the 2018 model year. Although we did not determine that it was necessarily for feasibility

to apply varying technology

levels to different vehicles, we did decide that a phased154 of 54 1

implementation schedule would be appropriate to accommodate manufacturers’ redesi gn workload and product schedules, especially in light of this sector’s relatively low sales volumes and long product cycles. We did not determine a specific cost of implementing the final standards immediately in 2014 without a phase

- in, but we assessed it to be much higher than the cost of the phase

- in we are proposing, due to the workload and product cycle disruptions it would cause, and also due to manufacturers’ resulting need it would entail to develop some of these technologies for heavy

- duty applic ations sooner than or simultaneously

with light

- duty

development efforts. On the other hand, waiting until 2018 before appl yi ng any new standards could miss the opportunity to achieve meaningful and cost

- effective earl y reductions not requiring a major pr oduct redesign cycle when the largest changes and reductions are expected to occur. The proposed phase

- in schedule, 15

- 20

- 40

- 60

- 100 percent in 2014

- 2015

- 2016

- 2017

- 2018, respectively , was chosen to strike a balance between meaningful reductions in the earl y ye ars (15 and 20 percent) and providing manufacturers with needed time via a graduall y accelerating ramp

- up. 139 By expressing the proposed phase

- in in terms of increasing fleet wide stringency for each manufacturer, while also providing for credit generat ion and use (including averaging, carry

- forward, and carry

- back), we believe we have afforded manufacturers substantial flexibility to satisfy the phase

- in through a variet y of pathways: the gradual application of technologies across the fleet, greater ap plication levels on only a portion of the fleet, or a mix of the two. We considered setting more stringent standards that would require the application of additional technologies by 2018. We expect, in fact, that some of these technologies may well prove feasible and cost

- effective in this timeframe, and may even become technologies of choice for individual manufacturers. This dy namic has played out in EPA programs before and highlights the value of setting performance

- based standards that leave engineer s the freedom to find the most cost

- effective solutions. However, the agencies do believe that at this stage there is not enough information to conclude that the additional technologies provide an appropriate basis for standard

- setting. For example, we believe that 42V stop

- start sy stems can be applied to gasoline vehicles with significant GHG and fuel consumption benefits, but we recognize that there is uncertainty

at this time over the cost

- effectiveness of these s ys tems in heavy

duty applications, and over customer acceptance of vehicles towing large loads that would routinely

stop running at idle. Hy

brid electric technology

too could be applied to heav y - dut y vehicles, and in fact has already been so applied on a limited basis. However, the developme nt, design, and tooling effort needed to apply this technology

to a vehicle model is quite large, and seems less likely to prove cost
- effective in this timeframe, due to the small sales volumes relative to the light

- duty sector. Here again, potential cust omer acceptance would need to be better understood because the smaller engines that facilitate much of a h ybrid’s benefit are t ypicall y at odds with the importance pickup

139 The NHTSA proposal,provides a voluntary opt

- in for model years 2014 and 2015. NHTSA also provides an alternative standard that meets EISA’s requirement for three years of regulatory stability. See Section II.C.d.ii for a more detailed discussi on.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

155 of 54 1 trucks buyers place on engine horsepower and torque, whatever the vehicle’s real perf ormance. We also considered setting less stringent standards calling for a more limited set of applied technologies. However, our assessment concluded with a high degree of confidence that the technologies chosen as the basis for our proposal are clearl y feasible in the 2014

- 2018 timeframe, and that the phase

- in and other flexibility provisions allow for their application in a very cost
- effective manner. More difficult to characterize is the degree to which more or less stringent standards might be appropriate because of under

- or over - estimating effectiveness for technologies we are applying. Our basis for these estimates is described in Section III.xx. Because for the most part these technologies have not y et been applied to HD pickups and vans, even on a limited basis, we are rel yi ng to some degree on engineering judgment. Even so, we believe that we have applied this judgment using the best information available, primarily from our recent rulemaking on light

- dut y vehicle GHGs and fuel economy , and hav e generated a robust set of effectiveness values. We solicit comment and new information that would aid the agencies in establishing the appropriate level of stringency for the HD pickup and van standards, and on all facets of the assessment described ab ove and elsewhere in these rulemaking proposals. (1) What technologies did the agencies consider? The agencies considered over 35 vehicle technologies that manufacturers could use to improve the fuel consumption and reduce CO 2 emissions of their vehicles durin g MYs 2014

- 2018. The majority of the technologies described in this section are readil y available, well known, and could be incorporated into vehicles once production decisions are made. Other technologies considered may not currentl y be in production, b ut are beyond the research phase and under development, and are expected to be in production in the next few years. These are technologies which are capable of achieving significant improvements in fuel economy and reductions in CO 2 emissions, at reasonab le costs. The agencies did not consider technologies in the research stage because the lead time available for this proposal is not sufficient to move such technologies from research to production. The technologies considered in the agencies’ anal ysis ar e briefl y described below. They fall into five broad categories: e ngine technologies, transmission technologies, vehicle technologies, electrification/accessory technologies, and hy

brid technologies

. In this class of trucks and vans, diesel engines are installed in about half of all vehicles. The ratio between gasoline and diesel engine purchases b y consumers has tended to track changes in the overall cost of oil and the relative cost of gasoline and diesel fuels. When oil prices are higher, diesel sal es tend to increase. This trend has reversed when oil prices fall or when diesel fuel prices are significantl y higher than gasoline. In the context of our technology discussion for heav y - dut y pickups and vans,156 of 54 1

we are treating gasoline and diesel engines separately so each has a set of baseline technology . We discuss performance improvements in terms of changes to those baseline engines. Our cost and inventory estimates contained elsewhere reflect the current fleet baseline with an appropriate mix of gas oline and diesel engines. Ty pes of engine technologies that improve fuel efficiency and reduce CO 2 emissions include the following:

 Low

- friction lubricants

– low viscosity and advanced low friction lubricants oils are now available with improved performa nce and better lubrication. If manufacturers choose to make use of these lubricants, they would need to make engine changes and possibly conduct durability

testing to accommodate the low

friction lubricants.

 Reduction of engine friction losses

– can be achieved through low

- tension piston rings, roller cam followers, improved material coatings, more optimal thermal management, piston surface treatments, and other improvements in the design of engine components and subsy stems that improve engine operation.

 Cylinder deactivation

– deactivates the intake and exhaust valves and prevents fuel injection into some cylinders during light

- load operation. The engine runs temporaril y as though it were a smaller engine which substantially reduces pumping losses.

 Variable valve timing

– alters the timing of the intake valve, exhaust valve, or both, primarily

to reduce pumping losses, increase specific power, and control residual gases.

 Stoichiometric gasoline direct

- injection technology

– injects fuel at high pre ssure directly into the combustion chamber to improve cooling of the air/fuel charge within the cylinder, which allows for higher compression ratios and increased thermody namic efficiency

.

 Diesel engine improvements and diesel aftertreatment improvement s
– improved EGR sy stems and advanced timing can provide more efficient combustion and, hence, lower fuel consumption. Aftertreatment sy stems are a relativel y new technology

on diesel vehicles and, as such, improvements are expected in coming ye ars that a llow the effectiveness of these s ys tems to improve while reducing the fuel and reductant demands of current sy stems. Ty pes of transmission technologies considered include:

 Improved automatic transmission controls

– optimizes shift schedule to maximize f uel efficiency

under wide ranging conditions, and minimizes losses associated with torque converter slip through lock

- up or modulation.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

157 of 54 1  Six

-, seven -, and eight

- speed automatic transmissions

– the gear ratio spacing and transmission ratio are optimized for a broader range of engine operating conditions. Ty pes of vehicle technologies considered include:

 Low

- rolling

- resistance tires

– have characteristics that reduce frictional losses associated with the energy dissipated in the deformation of the tires under load, therefore improving fuel efficiency and reducing CO 2 emissions.

 Aerodynamic drag reduction

– is achieved b y changing vehicle shape or reducing frontal area, including skirts, air dams, underbody covers, and more aerodynamic side view mirrors.

 Mass reduction and material substitution

– Mass reduction encompasses a variet y of techniques ranging from improved design and better component integration to application of lighter and higher

- strength materials. Mass reduction is further compounded b y re ductions in engine power and ancillary s ys tems (transmission, steering, brakes, suspension, etc.). The agencies recognize there is a range of diversity and complexity

for mass reduction and material substitution technologies and there are man y techniques that automotive suppliers and manufacturers are using to achieve the levels of this technology that the agencies have modeled in our analy sis for this proposal. Ty pes of electrification/accessory and hy brid technologies considered include:

 Electric pow er steering (EPS) and Electro

-Hydraulic power steering (EHPS)

– are electrically

- assisted steering s ys tems that have advantages over traditional hydraulic power steering because it replaces a continuously operated h ydraulic pump, thereb y reducing parasitic losses from the accessory drive.

 Improved accessories (IACC)

– may include high efficiency

alternators, electrically

driven (i.e., on

- demand) water pumps and cooling fans. This excludes other electrical accessories such as electric oil pumps and electri cally driven air conditioner compressors.

 Air Conditioner Systems

– These technologies include improved hoses, connectors and seals for leakage control. They also include improved compressors, expansion valves, heat exchangers and the control of these co mponents for the purposes of improving tailpipe CO 2 emissions as a result of A/C use.158 of 54 1 (2) How did the agencies determine the costs and effectiveness of each of these technologies? Building on the technical anal ys is underl yi ng the 2012

- 2016 light

- dut y final rule, the agencies took a fresh look at technology cost and effectiveness values for purposes of this proposal. For costs, the agencies reconsidered both the direct or “piece” costs and indirect costs of individual components of technologies. For the dir ect costs, the agencies followed a bill of materials (BOM) approach employ ed b y NHTSA and EPA in the 2012

- 2016 light

- duty

rule. For two technologies (stoichiometric gasoline direct injection and turbocharging with engine downsizing), the agencies relied, to the extent possible, on the tear down data available and scaling methodologies used in EPA’s ongoing study with FEV. This study consists of complete sy stem tear
- down to evaluate technologies down to the nuts and bolts to arrive at very

detailed estimates of the costs associated with manufacturing them. 140 For the other technologies, considering all sources of information and using the BOM approach, the agencies worked together intensively to determine component costs for each of the technologies and b uild up the costs accordingl y. Where estimates differ between sources, we have used engineering judgment to arrive at what we believe to be the best cost estimate available today , and explained the basis for that exercise of judgment. Once costs were det ermined, they were adjusted to ensure that they were all expressed in 2008 dollars using a ratio of GDP values for the associated calendar ye ars, 141 and indirect costs were accounted for using the new approach developed by EPA and used in the 2012

- 2016 light

- duty rule. NHTSA and EPA also reconsidered how costs should be adjusted by

modifying or scaling content assumptions to account for differences across the range of vehicle sizes and functional requirements, and adjusted the associated material cost impact s to account for the revised content, although some of these adjustments may

be different for each agency due to the different vehicle subclasses used in their respective models. Regarding estimates for technology effectiveness, NHTSA and EPA used the e stimates from the 2012

- 2016 light

- duty rule as a baseline but adjusted them as appropriate, taking into account the unique requirement of the heav y dut y test cycles to test at curb weight plus half payload versus the light

- duty requirement of curb plus 300 lbs. The adjustments were made on an individual technology basis by assessing the specific impact of the added load on each technology when compared to the use of the

140 U.S. Environmental Protection Agency, “Draft Report

– Light

- Duty Technology Cost Analysis Pilot Study,” Contract No. EP

- C

- 07

- 069, Work Assignment 1

- 3, Septem ber 3, 2009. 141 NHTSA examined the use of the CPI multiplier instead of GDP for adjusting thes e dollar values, but found the difference to be exceedingly small

– only $0.14 over $100.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

159 of 54 1 technology

on a light

- duty

vehicle. The agencies also considered other sources such as the March 2010 NAS Report, recent CAFE compliance data, and confidential manufacturer estimates of technology effectiveness. NHTSA and EPA engineers reviewed effectiveness information from the multiple sources for each technology and ensured that such ef

fectiveness estimates were based on technology hardware consistent with the BOM components used to estimate costs. Together, the agencies compared the multiple estimates and assessed their validity , taking care to ensure that common BOM definitions and other vehicle attributes such as performance and drivability were taken into account. The agencies note that the effectiveness values estimated for the technologies may represent average values applied to the baseline fleet described earlier, and do not reflect the potentially

- limitless spectrum of possible values that could result from adding the technology

to different vehicles. For example, while the agencies have estimated an effectiveness of 0.5 percent for low friction lubricants, each vehicle could have a unique effectiveness estimate depending on the baseline vehicle’s oil viscosity rating. Similarly , the reduction in rolling resistance (and thus the improvement in fuel economy and the reduction in CO 2 emissions) due to the application of low roll ing resistance tires depends not only on the unique characteristics of the tires originall y on the vehicle, but on the unique characteristics of the tires being applied, characteristics which must be balanced between fuel efficiency , safet y, and performanc e. Aerod ynamic drag reduction is much the same

—it can improve fuel economy and reduce CO 2 emissions, but it is also highl y dependent on vehicle

- specific functional objectives. For purposes of this NPRM, NHTSA and EPA believe that employing average values for technology effectiveness estimates is an appropriate way of recognizing the potential variation in the specific benefits that individual manufacturers (and individual vehicles) might obtain from adding a fuel

- saving technology . However, the agencies seek comment on whether additional levels of specificity

beyond that already provided would improve the anal ysis for the final rules, and if so, how those levels of specificity should be anal yz ed. The following section contains a detailed description of o ur assessment of vehicle technology

cost and effectiveness estimates. The agencies note that the technology costs included in this NPRM take into account onl y those associated with the initial build of the vehicle. The agencies seek comment on the additi onal lifetime costs, if an y, associated with the implementation of advanced technologies including maintenance and replacement costs. Based on comments, the agencies may decide to conduct additional anal ys is for the final rules regarding operating, mainten ance and replacement costs. (a ) Engine Technologies NHTSA and EPA have reviewed the engine technology estimates used in the 2012

- 2016 light

- dut y rule. In doing so NHTSA and EPA reconsidered all available sources and updated the estimates as appropriate. The s ection below describes both diesel and gasoline engine technologies considered for this proposal.160 of 54 1 (i ) Low Friction Lubricants (LUB) One of the most basic methods of reducing fuel consumption in both gasoline and diesel engines is the use of lower viscosit y eng ine lubricants. More advanced multi

viscosity engine oils are available today with improved performance in a wider temperature band and with better lubricating properties. This can be accomplished by changes to the oil base stock ( e.g. , switching engine lubricants from a Group Ibase oils to lower

- friction, lower viscosity Group III s ynthetic) and through changes to lubricant additive packages ( e.g. , friction modifiers and viscosity improvers). The use of 5W

- 30 motor oil is now widespread and auto manufa cturers are introducing the use of even lower viscosity

oils, such as 5W

- 20 and 0W

- 20, to improve cold

- flow properties and reduce cold start friction. However, in some cases, changes to the crankshaft, rod and main bearings and changes to the mechanical t olerances of engine components may be required. In all cases, durability testing would be required to ensure that durability is not compromised. The shift to lower viscosity and lower friction lubricants will also improve the effectiveness of valvetrain technologies such as cylinder deactivation, which rel y on a minimum oil temperature (viscosity) for operation. Based on the 2012

- 2016 light

- duty final rule, and previously

- received confidential manufacturer data, NHTSA and EPA estimated the effectiveness o f low friction lubricants to be between 0 to 1 percent. In the 2012

- 2016 light

- duty final rule, the agencies estimated the cost of moving to low friction lubricants at $3 per vehicle (2007$). That estimate included a markup of 1.11 for a low complexity technology . For class 2b and 3, we are using the same base estimate but have marked it up to 2008 dollars using the GDP price deflator and have used a markup of 1.17 for a low complexity technology

to arrive at a value of $4 per vehicle. As in the light

- duty rule, learning effects are not applied to costs for this technology

and, as such, this estimate applies to all model y ears. 142 , 143 (ii) Engine Friction Reduction (EFR) In addition to low friction lubricants, manufacturers can also reduce friction and improve f uel consumption by

improving the design of both diesel and gasoline engine components and subs ys tems. Approximately 10 percent of the energy

consumed by

a vehicle is lost to friction, and just over half is due to frictional losses within the engine. 144

142 Note that throughout the cost estimates for this HD analysis, the agencies have used slightly higher markups than those used in the 2010

- 2016 light

- duty FRM. The n ew , slightly higher ICMs include return on capital of roughly 6%, a factor that was not included in the light

- duty analysis. 143 Note that the costs developed for low friction lubes for this analysis reflect the costs associated with any engine changes that would be required as w ell as any durability testing that may be required. 144 “I mp act of Friction Reduction Technologies on Fuel Economy,” Fenske, G. Presented at the March 2009 Chicago Chapter Meeting of the ‘Society of Tribologists and Lubricated Engine ers’ Meeting, March 18th, 2009. Available at: http://www.chicagostle.org/program/2008

- 2009/Impact%20of%20Friction%20Reduction%20Technologies%20on%20Fuel%20Economy%20

- %20with%20VGs%20removed.pdf (last accessed July 9, 2009).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

161 of 54 1 Examples include improvements in low

- tension piston rings, piston skirt design, roller cam followers, improved crankshaft design and bearings, material coatings, material substitution, more optimal thermal management, and piston and cylinder surface treatment s. Additionally , as computer
- aided modeling software continues to improve, more opportunities for evolutionary friction reductions may

become available. All reciprocating and rotating components in the engine are potential candidates for friction reductio n, and minute improvements in several components can add up to a measurable fuel economy improvement. The 2012

- light

- dut y final rule, the March 2010 NAS Report, and, NESCCAF and EEA reports as well as confidential manufacturer data suggested a range of e ffectiveness for engine friction reduction to be between 1 to 3 percent. NHTSA and EPA continue to believe that this range is accurate. Consistent with the 2012

- 2016 light

- dut y final rule, the agencies estimate the cost of this technology

at $14 per cylin der compliance cost (2008$), including the low complexity

I CM markup value of 1.17. Learning impacts are not applied to the costs of this technology

and, as such, this estimate applies to all model years. This cost is multiplied by

the number of engine cylinders. (iii) Coupled Cam Phasing (CCP) Valvetrains with coupled (or coordinated) cam phasing can modify the timing of both the inlet valves and the exhaust valves an equal amount by phasing the camshaft of an overhead valve (OHV) engine. 145 For overhead valve ( OHV) engines, which have only one camshaft to actuate both inlet and exhaust valves, CCP is the only VVT implementation option available and requires only one cam phaser. 146 Based on the 2012

- 2016 light

- duty final rule, previously

- received confidential manuf acturer data, and the NESCCAF report, NHTSA and EPA estimated the effectiveness of CCP to be between 1 to 4 percent. NHTSA and EPA reviewed this estimate for purposes of the NPRM, and continue to find it accurate. In the 2012

- 2016 Light

- duty final rule, the agencies estimated a $41 cost per cam phaser not including an y markup (2007$). NHTSA and EPA believe that this estimate remains accurate. Using the new indirect cost multiplier of 1.17, for a low complexity technology , the compliance cost per cam phas er would be $46 (2008$) in the 2014 model ye ar. Time

- based learning is applied to this technology . This technology was considered for gasoline engines onl y.

145 Although CCP appears only in the SOHC and OHV branches of the decision tree, it is noted that a single phaser with a secondary chain drive would allow CCP to be applied to DOHC engines. Since this wo uld potentially be adopted on a limited number of DOHC engines NHTSA did not include it in that branch of the decision tree. 146 It is also noted that coaxial camshaft developments would allow other VVT options to be applied to OHV engines. However, since they would potentially be adopted on a limited number of OHV engines NHTSA did not inc lude them in the decision tree.162 of 54 1 (iv) Cylinder Deactivation (DEAC) In conventional spark

- ignited engines throttling the a irflow controls engine torque output. At partial loads, efficiency can be improved by

using cylinder deactivation instead of throttling. C yl inder deactivation (DEAC) can improve engine efficiency by disabling or deactivating (usually) half of the cylinde rs when the load is less than half of the engine’s total torque capability

– the valves are kept closed, and no fuel is injected

– as a result, the trapped air within the deactivated cylinders is simply compressed and expanded as an air spring, with reduce d friction and heat losses. The active cylinders combust at almost double the load required if all of the cylinders were operating. Pumping losses are significantly reduced as long as the engine is operated in this “part

cylinder” mode. Cylinder deactiv ation control strategy relies on setting maximum manifold absolute pressures or predicted torque within which it can deactivate the cylinders. Noise and vibration issues reduce the operating range to which cylinder deactivation is allowed, although manufa cturers are exploring vehicle changes that enable increasing the amount of time that cylinder deactivation might be suitable. Some manufacturers may choose to adopt active engine mounts and/or active noise cancellations sy stems to address NVH concerns and to allow a greater operating range of activation. Cylinder deactivation has seen a recent resurgence thanks to better valvetrain designs and engine controls. General Motors and Chry sler Group have incorporated cylinder deactivation across a substantial portion of their V8

- powered lineups. Effectiveness improvements scale roughl y with engine displacement

- to
- vehicle weight ratio: the higher displacement

- to
- weight vehicles, operating at lower relative loads for normal driving, have the potential to operate in part

- cylinder mode more frequentl y. NHTSA and EPA adjusted the 2012

- 2016 light

- duty final rule estimates using updated power to weight ratings of heav y - duty trucks and confidential business information and confirmed a range of 3 to 4 percent for these vehicles. NHTSA and EPA consider the costs for this technology to be identical to that for V8 engines on light

- dut y trucks. As such, the agencies have used the cost used in the 2012

- 2016 light

- dut y final rule. Using the new markup of 1.17 for a low compl exity technology

results in an estimate of $193 (2008$) in the 2014 model y ear Time based learning is applied to this technology . This technology was considered for gasoline engines only

. (v) Stoichiometric Gasoline Direct Injection (SGDI) Stoichiometric gas oline direct injection (SGDI) engines inject fuel at high pressure directl y into the combustion chamber (rather than the intake port in port fuel injection). SGDI requires changes to the injector design, an additional high pressure fuel pump, new fuel rai ls to handle the higher fuel pressures and changes to the cylinder head and piston crown design. Direct injection of the fuel into the cylinder improves cooling of the air/fuel charge within the cylinder, which allows for higher compression ratios andDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

163 of 54 1 inc reased thermodynamic efficiency without the onset of combustion knock. Recent injector design advances, improved electronic engine management s ys tems and the introduction of multiple injection events per cylinder firing cycle promote better mixing of the air and fuel, enhance combustion rates, increase residual exhaust gas tolerance and improve cold start emissions. SGDIengines achieve higher power densit y and match well with other technologies, such as boosting and variable valvetrain designs. Several m anufacturers have recently introduced vehicles with SGDIengines, including GM and Ford and have announced their plans to increase dramatically the number of SGDI engines in their portfolios. The 2012

- 2016 light

- duty final rule estimated the range of 1 to 2 percent for SGDI . NHTSA and EPA reviewed this estimate for purposes of the NPRM, and continue to find it accurate. Consistent with the 2012

- 2016 light

- dut y final rule, NHTSA and EPA cost estimates for SGDI take into account the changes required to the engine hardware, engine electronic controls, ancillary and Noise Vibration and Harshness (NVH) mitigation sy stems. Through contacts with industry NVH suppliers, and manufacturer press releases, the agencies believe that the NVH treatments will be limited t o the mitigation of fuel sy stem noise, specifically from the injectors and the fuel lines. For this analy sis, the agencies have estimated the costs at $395 (2008$) in the 2014 model y ear. Time based learning is applied to this technology . This technolog y was considered for gasoline engines only , as diesel engines already employ direct injection. (b ) Diesel Engine Technologies Diesel engines have several characteristics that give them superior fuel efficiency compared to conventional gasoline, spark

- ignited engines. Pumping losses are much lower due to lack of (or greatl y reduced) throttling. The diesel combustion cycle operates at a higher compression ratio, with a very lean air/fuel mixture, and turbocharged light

duty diesels t ypicall y achieve much highe r torque levels at lower engine speeds than equivalent

- displacement naturally

- aspirated gasoline engines. Additionally, diesel fuel has a higher energy

content per gallon. 147 However, diesel fuel also has a higher carbon to hydrogen ratio, which increases the amount of CO 2 emitted per gallon of fuel used b y approximately

15 percent over a gallon of gasoline. Based on confidential business information and the March 2010 NAS Report, two major areas of Diesel engine design will be improved during the 2014

- 201 8 timeframe. These areas include aftertreatment improvements and a broad range of engine improvements.

147 Burning one gallon of diesel fuel produces about 15 percent more carbon dioxide than gasoline due to the higher density and carbon to hydrogen ratio.164 of 54 1 (i ) Aftertreatment Improvements Based on confidential product plans and published information, all vehicles in the class 2b and 3 class will be moving (or h ave already moved) to the SCR ty

pe of aftertreatment s ys tem. As the experience base for SCR expands over the next few y ears, many improvements in this aftertreatment sy stem such as construction of the catal ys t, thermal management, and reductant optimizati on will result in a significant reduction in the amount of fuel used in the process. This technology was not considered in the 2012

- 2016 L ight

- dut y final rule. Based on confidential business information, EPA and NHTSA estimate the reduction in CO 2 as a r esult of these improvements at 4%. T he agencies have estimated the cost of this technology at $25 for each percentage improvement in fuel consumption. This estimate is based on the agencies’ belief that this technology is, in fact, a very cost effective a pproach to improving fuel consumption. As such, $25 per percent improvement is considered a reasonable cost. This cost would cover the engineering and test cell related costs necessary to develop and implement the improved control strategies that would a llow for the improvements in fuel consumption. Importantly , the engineering work involved would be expected to result in cost savings to the aftertreatment and control hardware (lower platinum group metal (PGM) loadings, lower reductant dosing rates, etc. ). Those savings are considered to be included in the $25 per percent estimate described here. Given the 4% expected improvement in fuel consumption results in an estimated cost of $1 10 (2008$) for a 201 4 model year truck or van . This estimate includes a low complexity I CM of 1.17 and time based learning from 2012 forward. (ii) Engine Improvements Diesel engines in the Class 2b and 3 segment are expected to have several improvements in their base design in the 2014

– 2018 timeframe. These improvements includ e items such as improved combustion management, optimal turbocharger design, and improved thermal management. This technology was not considered in the 2012

- 2016 light

- duty

final rule. Based on confidential business information, EPA and NHTSA estimate the reduction in CO 2 as a result of these improvements at 5%. The cost for this technology includes costs associated with low temperature exhaust gas recirculation and improved turbochargers

. These costs are considered collectively

in our costing anal ys is an d termed “diesel engine improvements.” The agencies have estimated the cost of diesel engine improvements based on the TIAX report which estimated the retail price equivalent at $500 using a 2 times multiplier. Dividing that value gives a direct manufact uring cost of $250. Applying a low complexity

I CM and time based learning from 2012 forward results in the agencies’ estimate of $2 75 (2008$) in the 2014 model year . (c) Transmission Technologies NHTSA and EPA have also reviewed the transmission technology e stimates used in the 2012

- 2016 light

- duty final rule. In doing so, NHTSA and EPA considered orDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

16 5 of 54 1 reconsidered all available sources and updated the estimates as appropriate. The section below describes each of the transmission technologies considered for this proposal. (i ) Improved Automatic Transmission Control (IATC) (Aggressive Shift Logic and Early Torque Converter Lockup) Calibrating the transmission shift schedule to upshift earlier and quicker, and to lock

- up or partiall y lock

- up the torque converter und er a broader range of operating conditions can reduce fuel consumption and CO 2 emissions. However, this operation can result in a perceptible degradation in NVH. The degree to which NVH can be degraded before it becomes noticeable to the driver is strong ly influenced by

characteristics of the vehicle, and although it is somewhat subjective, it alway s places a limit on how much fuel consumption can be improved by transmission control changes. Given that the Aggressive Shift Logic and Earl y Torque Converte r Lockup are best optimized simultaneously

due to the fact that adding both of them primarily requires only

minor modifications to the transmission or calibration software, these two technologies are combined in the modeling. We consider these technologie s to be present in the baseline, 6

- speed automatic transmissions in the majority of class 2b and 3 trucks in the 2010 model year timeframe. (ii) Automatic 6

- and 8

- Speed Transmissions (NAUTO) Manufacturers can also choose to replace 4

- 5
- and 6

- speed automatic transmissions with 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 planet ary 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 already, and 7

- and 8

- speed automatics have entered production in light

- dut y vehicles, albeit in lower

- volume a pplications in luxury

and performance oriented cars. As discussed in the 2010 light

- duty final rule, confidential manufacturer data projected that 6

- speed transmissions could incrementally reduce fuel consumption by 0 to 5 percent from a 4

- speed automatic transmission, while an 8

- speed transmission could incrementall y reduce fuel consumption by up to 6 percent from a 4

- speed automatic transmission. GM has publicly claimed a fuel economy

improvement of up to 4 percent for its new 6

- speed automatic transmiss ions. 148

148 General Motors, news release, “From Hybrids to Six

- Speeds, Direct Inje ction And More, GM’s 2008 Global Pow ertrain 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)

.166 of 54 1 NHTSA and EPA reviewed and revised these effectiveness estimates based on actual usage statistics and testing methods for these vehicles along with confidential business information. When combined with IATC, the agencies estimate the effectivenes s for a conversion from a 4 to a 6

- speed transmission to be 5.3% and a conversion from a 6 to 8

- speed transmission to be 1.7%. While 8

- speed transmissions were not considered in the 2012

- 2016 Light

- duty final rule, they

are considered as a technology

of c hoice for this analy sis in that manufacturers are expected to upgrade the 6

- speed automatic transmissions being implemented today with 8

- speed automatic transmissions in the 2014

- 2018 timeframe. For this proposal, we are estimating the cost of an 8

- speed automatic transmission at $231 (2008$) relative to a 6

- speed automatic transmission in the 2014 model y ear. This estimate is based from the March 2010 NAS Report and we have applied a low complexity I CM of 1.17 and time based learning. This technology

ap plies to both gasoline and diesel trucks and vans. (d ) Electrification/Accessory Technologies (i ) Electrical Power Steering (EPS) or Electrohydraulic Power Steering (EHPS) Electric power steering (EPS) or Electroh ydraulic power steering (EHPS) provides a potential reduction in CO 2 emissions and fuel consumption over hydraulic power steering because of reduced overall accessory loads. This eliminates the parasitic losses associated with belt

- driven power steering pumps which consistently draw load from the engine t o pump hydraulic fluid through the steering actuation sy stems even when the wheels are not being turned. EPS is an enabler for all vehicle h ybridization technologies since it provides power steering when the engine is off. EPS may be implemented on most vehicles with a standard 12V sy stem. Some heavier vehicles may require a higher voltage system which may add cost and complexity

. The 2012012

- 2016 light

- duty final rule estimated a 1 to 2 percent effectiveness based on the 2002 NAS report for light

- dut y v ehicle technologies, a Sierra Research report, and confidential manufacturer data. NHTSA and EPA reviewed these effectiveness estimates and found them to be accurate, thus they have been retained for purposes of this NPRM. NHTSA and EPA adjusted the EPS c ost for the current rulemaking based on a review of the specification of the sy stem. Adjustments were made to include potentially higher voltage or heavier duty s ys tem operation for class 2b and 3. Accordingl y, higher costs were estimated for sy stems with higher capability . After accounting for the differences in s ys tem capability and appl yi ng the ICM markup of low complexity technology

of 1.17, the estimated costs for this proposal are $108 for a MY 2014 truck or van (2008$). As EPS sy stems are in wide spread usage today , time

- based learning is deemed applicable. EHPS sy stems are considered to be of equal cost and both are considered applicable to gasoline and diesel engines.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

167 of 54 1 (ii) Improved Accessories (IACC) The accessories on an engine, including the altern ator, coolant and oil pumps are traditionally

mechanically

- driven. A reduction in CO 2 emissions and fuel consumption can be realized b y driving them electrically, and only when needed (“on

- demand”). Electric water pumps and electric fans can provide better control of engine cooling. For example, coolant flow from an electric water pump can be reduced and the radiator fan can be shut off during engine warm

- up or cold ambient temperature conditions which will reduce warm

- up time, reduce warm

- up fuel enric hment, and reduce parasitic losses. Indirect benefit may

be obtained by

reducing the flow from the water pump electrically

during the engine warm

- up period, allowing the engine to heat more rapidl y and thereb y reducing the fuel enrichment needed during col d starting of the engine. Further benefit may

be obtained when electrification is combined with an improved, higher efficiency

engine alternator. Intelligent cooling can more easily be applied to vehicles that do not ty

pically carry heavy payloads, so larger vehicles with towing capacity present a challenge, as these vehicles have high cooling fan loads. 149 The agencies considered whether to include electric oil pump technology for the rulemaking. Because it is necessary to operate the oil pump any time th e engine is running, electric oil pump technology has insignificant effect on efficiency . Therefore, the agencies decided to not include electric oil pump technology for this proposal. NHTSA and EPA jointly reviewed the estimates of 1 to 2 percent effecti veness estimates used in the 2012

- 2016 light

- dut y final rule and found them to be accurate for Improved Electrical Accessories. Consistent with the 2012

- 2016 light

- duty final rule, the agencies have estimated the cost of this technology at $88 (2008$) inc luding a low complexity

I CM of 1.17. This cost is applicable in the 2014 model y ear. Improved accessory s ys tems are in production currently and thus time

- based learning is applied. This technology

was considered for diesel trucks and vans onl y. (e) Vehicle Technologies (i ) Mass Reduction Reducing a vehicle’s mass, or down

- weighting the vehicle, decreases fuel consumption by

reducing the energy

demand needed to overcome forces resisting motion, and rolling resistance. Manufacturers employ a systematic approach t o mass reduction, where the net mass reduction is the addition of a direct component or s ys tem mass reduction plus the additional mass reduction taken from indirect ancillary s ystems and components, as a result of full vehicle optimization, effectivel y compounding or

149 In the CAFE model, IACC refers solely to improved engine cooling. How ever, EPA has included a high efficiency alternator in this category, as well as improvements to the cooling system.168 of 54 1

obtaining a secondary

mass reduction from a primary mass reduction. For example, use of a smaller, lighter engine with lower torque

- output subsequently allows the use of a smaller, lighter

- weight transmission and drive line components. L ikewi se, the compounded weight reductions of the body , engine and drivetrain reduce stresses on the suspension components, steering components, wheels, tires and brakes, allowing further reductions in the mass of these subsy stems. The reductions in unsprung ma sses such as brakes, control arms, wheels and tires further reduce stresses in the suspension mounting points. This produces a compounding effect of mass reductions. Estimates of the sy

nergistic effects of mass reduction and the compounding effect that occ urs along with it can vary significantly

from one report to another. For example, in discussing its estimate, an Auto

- Steel Partnership report states that “These secondary mass changes can be considerable

— estimated at an additional 0.7 to 1.8 times the in itial mass change.” 150 This means for each one pound reduction in a primary component, up to 1.8 pounds can be reduced from other structures in the vehicle ( i.e. , a 180 percent factor). The report also discusses that a primary variable in the realized secon dary weight reduction is whether or not the powertrain components can be included in the mass reduction effort, with the lower end estimates being applicable when powertrain elements are unavailable for mass reduction. However, another report b y the Alumi num Association, which primarily focuses on the use of aluminum as an alternative material for steel, estimated a factor of 64 percent for secondary mass reduction even though some powertrain elements were considered in the anal ysis. 151 That report also not es that ty pical values for this factor vary from 50 to 100 percent. Although there is a wide variation in stated estimates, sy nergistic mass reductions do exist, and the effects result in tangible mass reductions. Mass reductions in a single vehicle comp onent, for example a door side impact/intrusion sy stem, may actuall y result in a significantl y higher weight savings in the total vehicle, depending on how well the manufacturer integrates the modification into the overall vehicle design. Accordingl y, car e must be taken when reviewing reports on weight reduction methods and practices to ascertain if compounding effects have been considered or not. Mass reduction is broadly applicable across all vehicle subsy stems including the engine, exhaust sy stem, trans mission, chassis, suspension, brakes, bod y, closure panels, glazing, seats and other interior components, engine cooling s ys tems and HVAC sy stems. It is estimated that up to 1.25 kilograms of secondary weight savings can be achieved for

150 “Preliminary Vehicle Mass Estimation Using Empirical Subsystem Influence Coefficients,” Malen, D.E., Reddy, K. Auto

- Steel Partnership Report, May 2007, Docket EPA

- HQ

- OAR

- 2009

- 0472

- 0169. Accessed on the Internet on May 30, 2009 at: http://www.a

sp.org/database/custom/Mass%20Compounding%20

- %20Final%20Report.pdf 151 “Be nefit Analysis: Use of Aluminum Structures in Conjunction with Alternative Pow ertrain Technologies in Automobiles,” Bull, M. Chavali, R., Mascarin, A., Aluminum Association Research Report, May 2008, Docket EPA

- HQ

- OAR

- 2009

- 0472

- 0168. Accessed on the Inte rnet on April 30, 2009 at: http://www.autoaluminum.org/dow nloads/IBIS

- Pow ertrain

- Study.pdfDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

169 of 54 1 every kilogram of weight saved on a vehicle when all subsy stems are redesigned to take into account the initial primary weight savings. 152 , 153 Mass reduction can be accomplished by proven methods such as:

 Smart Design: Computer aided engineering (CAE) tools can be used to be tter optimize load paths within structures b y reducing stresses and bending moments applied to structures. This allows better optimization of the sectional thicknesses of structural components to reduce mass while maintaining or improving the function of the component. Smart designs also integrate separate parts in a manner that reduces mass by combining functions or the reduced use of separate fasteners. In addition, some “body on frame” vehicles are redesigned with a lighter “unibody” construction.

 Mat erial Substitution: Substitution of lower density and/or higher strength materials into a design in a manner that preserves or improves the function of the component. This includes substitution of high

- strength steels, aluminum, magnesium or composite materials for components currentl y fabricated from mild steel.

 Reduced Powertrain Requirements: Reducing vehicle weight sufficientl y al lows for the use of a smaller, lighter and more efficient engine while maintaining or increasing performance. Approximat ely half of the reduction is due to these reduced powertrain output requirements from reduced engine power output and/or displacement, changes to transmission and final drive gear ratios. The subsequent reduced rotating mass ( e.g. , transmission, driveshaft s/halfshafts, wheels and tires) via weight and/or size reduction of components are made possible b y reduced torque output requirements.

 Automotive companies have largely used weight savings in some vehicle subsy stems to offset or mitigate weight gains in o ther subs ys tems from increased feature content (sound insulation, entertainment systems, improved climate control, panoramic roof, etc.).

 Li ghtweight designs have also been used to improve vehicle performance parameters b y increased acceleration performan ce or superior vehicle handling and braking.

152 “Future Generation Passenger Compartment

- Validation (ASP 241)” Villano, P.J., Shaw , J.R., Polewarczyk, J., Morgans, S., Carpenter, J.A., Yocum, A.D., in “Lightwei ghting Materials

– FY 2008 Progress Report,” U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Vehicle Technologies Program, May 2009, Docket EPA

- HQ

- OAR

- 2009

- 0472

- 0190. 153 “Preliminary Vehicle Mass Estimation Using Empirical Subsy stem Influence Coefficients,” Malen, D.E., Reddy, K. Auto

- Steel Partnership Report, May 2007, Docket EPA

- HQ

- OAR

- 2009

- 0472

- 0169. Accessed on the Internet on May 30, 2009 at: http://www.a

sp.org/database/custom/Mass%20Compounding%20

- %20Final%20Report.pdf170 of 54 1 Many manufacturers have already announced proposed future products plans reducing the weight of a vehicle body through the use of high strength steel body

- in

white, composite body

panels, magnesium alloy front and rear energy

absorbing structures reducing vehicle weight sufficientl y to allow a smaller, lighter and more efficient engine. Nissan will be reducing average vehicle curb weight by 15% by 2015. 154 Ford has identified weight reductions of 250 to 750 lbs per vehicle as part of its implementation of known technology within its sustainability

strategy between 2011 and 2020. 155 Mazda plans to reduce vehicle weight b y 220 pounds per vehicle or more as models are redesigned. 156 , 157 Ducker International estimates that the average curb weight of light

- dut y vehicle fleet will decrease approximately 2.8% from 2009 to 2015 and approximately

6.5% from 2009 to 2020 via changes in automotive materials and increased change

- over from previously used bod y - on - frame automobile an d light

- truck designs to newer unibody designs. 154 While the opportunity for mass reductions available to the light

- duty

fleet may not in all cases be applied directl y to the heav y - duty fleet due to the differe nt designs for the expected dut y c ycl es of a “work” vehicle, mass reductions are still available particularly to areas unrelated to the components necessary for the work vehicle aspects. Due to the payload and towing requirements of these heav y - dut y v ehicles, engine downsizing was not considered in the estimates for CO 2 reduction in the area of mass reduction/material substitution. NHTSA and EPA estimate that a 3 percent mass reduction with no engine downsizing results in a 1 percent reduction in fuel consumption. In addition, a 5 and 10 percent mass reduction with no engine downsizing result in an estimated CO 2 reduction of 1.6 and 3.2 percent respectivel y. These effectiveness values are 50% of the 2012

- 2016 L ight

- dut y final rule values due to the e limination of engine downsizing for this class of vehicle. Consistent with the 2012

- 2016 light

- dut y final rule, the agencies have estimated the cost of mass reduction at $1.32 per pound (2008$). For this analy sis, the agencies are estimating a 5% mass reduction or, given the baseline weight of current trucks and vans, are estimating costs of $462, $544, $513, and $576 for Class 2b gasoline, 2b diesel, 3 gasoline, 3 diesel trucks and vans, respectivel y. All values are in 2008 dollars, are applicable in the 2014 model year and include a low complexity I CM of 1.17. Time based learning is considered applicable to mass reduction technologies.

154 “Lighten Up!,” Brooke, L., Evans, H. Automive Engineering International, Vol. 117, No. 3, March 2009. 155 “2008/9 Blueprint for Sustainability,” Ford Motor Company. Available at: http:// www.ford.com/go/su stainability (last accessed February 8, 2010). 156 “Mazda to cut vehicle fuel consumption 30 percent by 2015,” Mazda press release, June 23, 2009. Available at: http://www.mazda.c om /publicity/release/2008/200806/080623.html (last accessed February 8, 2010). 157 “Mazda: Don’t believe hot air being emitted by hybrid hype,” Greimel, H. Automotive News, March 30, 2009.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

171 of 54 1 (ii) Low Rolling Resistance Tires (ROLL) Tire rolling resistance is the frictional loss associated mainly with the ene rgy dissipated in the deformation of the tires under load and thus influences fuel economy and CO 2 emissions. Other tire design characteristics ( e.g. , materials, construction, and tread design) influence durability , traction (both wet and dry grip), vehic le handling, and ride comfort in addition to rolling resistance. A t ypical low rolling resistance tire’s attributes would include: increased tire inflation pressure, material changes, and tire construction with less hysteresis, geometry changes ( e.g. , red

uced aspect ratios), and reduction in sidewall and tread deflection. These changes would generally be accompanied with additional changes to suspension tuning and/or suspension design. EPA and NHTSA estimated a 1 to 2 percent increase in effectiveness with a 10 percent reduction in rolling resistance, which was based on the March 2010 NAS Report findings and consistent with the 2012

- 2016 L ight

- duty final rule. Based on the 2012

- 2016 light

- duty final rule and the March 2010 NAS Report, the agencies have e stimated the cost for low rolling resistance tires to be $6 per Class 2b truck or van, and $9 per Class 3 truck or van. 158 The higher cost for the Class 3 trucks and vans is due to the predominant use of dual rear tires and, thus, 6 tires per truck. Due to the commodity

- based nature of this technology , cost learning is not applied. This technology

is consider applicable to both gasoline and diesel. (iii) Aerodynamic Drag Reduction (AERO) Many factors affect a vehicle’s aerody namic drag and the resulting power re quired to move it through the air. While these factors change with air density and the square and cube of vehicle speed, respectivel y, the overall drag effect is determined b y the product of its frontal area and drag coefficient. Reductions in these quantities can therefore reduce fuel consumption and CO 2 emissions. Although frontal areas tend to be relativel y similar within a vehicle class (mostly due to market

- competitive size requirements), significant variations in drag coefficient can be observed. Significant changes to a vehicle’s aerody namic performance may

need to be implemented during a redesign ( e.g. , changes in vehicle shape). However, shorter

- term aerody namic reductions, with a somewhat lower effectiveness, may be achieved through the use of revised exterior components (ty picall y at a model refresh in mid

- cycle) and add

- on devices that currentl y being applied. The latter list would include revised front and rear fascias, modified front air dams and rear valances, addition of rear deck lips and underbod y panels, and lower aerodynamic drag exterior mirrors. The 2012

- 2016 light

- duty final rule estimated that a fleet average of 10 to 20 percent total aerodynamic drag reduction is attainable which equates to incremental reductions in fuel consumpt ion and CO 2 emissions of 2 to 3 percent for both cars and

158 “T ires and Passenger Vehicle Fuel Economy,” Transportation Researc h Board Special Report 286, National Research Council of the National Academies, 2006, Docket EPA

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- 0146.172 of 54 1

trucks. These numbers are generall y supported b y confidential manufacturer data and public technical literature

. For the heav y - dut y truck category , a 5 to 10 percent total aerod ynamic drag reducti on was considered due to the different structure and use of these vehicles equating to incremental reductions in fuel consumption and CO 2 emissions of 1 to 2 percent. Consistent with the 2012

- 2016 light

- dut y final rule, the agencies have estimated the cost for this technology at $54 (2008$) including a low complexity I CM of 1.17. This cost is applicable in the 2014 model year to both gasoline and diesel trucks and vans.
(3) What are the projected technology package effectiveness and cost? The assessment of th e proposed technology effectiveness was developed through the use of the EPA Lumped Parameter model developed for the light duty rule. Many

of the technologies were common with the light duty assessment but the effectiveness of individual technologies was appropriatel y adjusted to match the expected effectiveness when implemented in a heav y dut y application. The model then uses the individual technology

effectiveness levels but then takes into account technology s yn ergies. The model is also designed to pre vent double counting from technologies that may directl y or indirectly impact the same phy sical attribute (e.g., pumping loss reductions). To achieve the levels of the proposed standards for gasoline and diesel powered heav y dut y vehicles, the technol ogies packages were determined to generally require the full list of feasible technologies previously discussed respective to unique gasoline and diesel technologies. Some of the technologies may already be implemented in select heav y dut y vehicles howeve r none of the technologies discussed are considered ubiquitous in the heavy

duty fleet. Further, man y technologies can be further improved (e.g., aerod ynamic improvements) from today’s levels.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

173 of 54 1 Table III - 11 : Technology Costs Inclusive of Indirect Costs Markups for the 2014 MY (2008$) Technology Class 2b Gasoline Class 2b

Diesel Class 3

Gasoline Class 3

Diesel Low friction lubes $4 $4 $4 $4 Engine friction reduction $108 N/A $108 N/A Coupled cam phasing $ 46 N/A $46 N/A Cylinder deactivation $193 N/A $193 N/A Stoichiometric gasoline direct injection $395 N/A $395 N/A Engine improvements N/A $275 N/A $275 8s automatic transmission (increment to 6s automatic transmission) $ 231 $ 231 $ 231 $ 231 Improved acc essories N/A $88 N/A $88 Low rolling resistance tires $6 $6 $9 $9 Aerod ynamic improvements $54 $54 $54 $54 Electric (or electro/hydraulic) power steering $108 $108 $108 $108 Aftertreatment improvements N/A $110 N/A $110 Mass reduction (5%) $462 $544 $ 513 $576 Air conditioning $21 $21 $21 $21 Total $1,628 $1,441 $1,679 $1,473 At 15% phase

- in in 2014 $244 $216 $252 $221 

### C. Class 2b - 8 Vocational Vehicles Vocational vehicles cover a wide variet y of applications which influence both the body st yl e and usag e patterns. They also are built using a complex process, which includes additional parties such as body builders. These factors have led the agencies to propose a vehicle standard for vocational trucks for the first phase of the program that relies on le ss extensive addition of technology as well as focusing on the chassis manufacturer as the manufacturer subject to the standard. We believe that future rulemakings will consider increased stringency and possibly

more application

- specific standards. The ag encies are proposing standards for the diesel and gasoline engines used in vocational vehicles, similar to those discussed above for class 7/8 tractors. (1) What technologies did the agencies consider to reduce the CO 2 emissions and fuel consumption of vocat ional trucks? Similar to the approach taken with tractors, the agencies evaluated aerodyn amic, tire, idle reduction, weight reduction, hy brid powertrain, and engine technologies and their impact on reducing fuel consumption and GHG emissions. The engines used in vocational trucks include both gasoline and diesel engines, thus, each typ e is discussed separately below. As explained in section II.D.1.b, the proposed regulatory structure for heav y - dut y engines separates the compression ignition (or “diesel”) engines into three regulatory

classes

- light heav y, medium heav y, and heav y heav y diesel engines

-- while174 of 54 1

spark ignition (or “gasoline”) engines are a single regulatory class. Therefore, the subsequent discussion will assess each t ype of engine separat el y. (a ) Truck Technologies Vocational trucks t ypically travel fewer miles than combination tractors. They also tend to be used in more urban locations (with consequent stop and start drive cycles). Therefore the average speed of vocational trucks is signifi cantl y lower than tractors. . This has a significant effect on the t ypes of technologies that are appropriate to consider for reducing CO 2 emissions and fuel consumption. The agencies considered the ty pe of technologies for vocational trucks based on the energy

losses of a t yp ical vocational vehicle. The technologies are similar to the ones considered for tractors. Argonne National Lab conducted an energy audit using simulation tools to evaluate the energy losses of vocational trucks, such as a Clas s 6 pick up and delivery

truck. Argonne found that 74 percent of the energy losses are attributed to the engine, 13 percent to tires, 9 percent to aerody namics, 2 percent to transmission losses, and the remaining 4 percent of losses to axles and accessori es for a medium duty truck traveling at 30 mph. 159 Low Rolling Resistance Tires: Tires are the second largest contributor to energy losses of vocational vehicles, as found in the energy audit conducted by

Argonne National Lab. The range of rolling resist ance of tires used on vocational trucks today is large. This is in part due to the fact that the competitive pressure to improve rolling resistance of vocational truck tires has been less than that found in the line haul tire market. In addition, the dri ve cycles t ypical for these applications often lead truck buyers to value tire traction and durability more heavil y than rolling resistance. Therefore, the agencies concluded that a regulatory program that seeks to optimize tire rolling resistance in addi tion to traction and durability can bring about fuel consumption and CO 2 emission reductions from this segment. The NAS report states that rolling resistance impact on fuel consumption reduces with mass of the vehicle and with drive cycles with more frequ ent starts and stops. The report found that the fuel consumption reduction opportunity

for reduced rolling resistance ranged between 1 and 3 percent in the 2010 through 2020 timeframe. The agencies estimate that average rolling resistance from tires in 2 010 model year can be reduced by 10 percent by

2014 model year based on the tire development achievements over the last several ye ars in the line haul truck market which would lead to a 2 percent reduction in fuel consumption based on [TEST]. Aerod ynamics: As shown above, aerodynamics have less of an impact on vocational truck energy

losses than engines or tires. In addition, the aerodynamic performance of a complete vehicle is significantl y influenced b y the bod y of the truck. The agencies are not propo sing to regulate body builders in this phase of regulations for the reasons discussed in Section II. Therefore, we are not basing an y of the proposed

159 Argonne National Lab. Evaluation of Fuel Consumption Potential of Medium and Heavy
- duty Vehicles through Modeling and Simulation. O ctober 2009. Page 89.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

175 of 54 1 standards for vocational trucks on aerodynamic improvements. Nor would aerodynamic performance be input into the TEST model to demonstrate compliance. Weight Reduction: NHTSA and EPA are also not basing an y of the proposed standards on use of vehicle weight reduction. Thus, vehicle mass reductions would not be input into the [TEST] model. The vocationa l truck models are not designed to be application

- specific. Therefore weight reductions are difficult to quantify

. Drivetrain: The agencies recognize that approximately 6 percent of the total vehicle losses are attributed to the axles, accessories, and transmission. The NAS report found that the opportunities to reduce fuel consumption in vocational vehicles due to transmission and driveline technologies in the 2015 timeframe ranged between 1.2 and 2 percent. The agencies welcome comment on transmissi on and driveline technologies specific to the vocational vehicle market that can achieve fuel consumption and GHG emissions reductions. Idle Reduction: Episodic idling by vocational trucks occurs during the workday , unlike the overnight idling of line hau l combination trucks. Vocational truck idling can be divided into two ty

pical ty pes. The first t ype is idling while waiting

– such as during a pickup or delivery . This ty pe of idling can be reduced through automatic engine shut

offs. The second t ype of idling is to accomplish power take off operation (PTO), such as compacting garbage or operating a bucket. The agencies have found onl y one study that quantifies the emissions due to idling conducted by Argonne National Lab based on 2002 VIUS data. 160 EPA conducted a work assignment to assist in characterizing PTO operations. The study of a utility truck used in two different environments (rural and urban) and a refuse hauler found that the PTO operated on average 28 percent of time relative to the total t ime spent driving and idling. The use of h ybrid powertrains to reduce idling is discussed below. Hy brid Powertrains: Several t ypes of vocational vehicles are well suited for hy brid powertrains. Vehicles such as utility or bucket trucks, delivery vehicle s, refuse haulers, and buses have operational usage patterns with either a significant amount of stop
- and

- go activity

or spend a large portion of their operating hours idling the main engine to operate a PTO unit. The industry is currently

developing thre e t ypes of h ybrid powertrain s ys tems

– hy draulic, electric, and plug

- in electric. The h ybrids developed to date have seen fuel consumption and CO 2 emissions reductions between 20 and 50 percent in the field. However, there are still some key issues that are restricting the penetration of h ybrids, including overall s ys tem cost, battery technology , and lack of cost
- effective electrified accessories. The agencies are proposing to include hy brid powertrains as a technology to meet the vocational truck standard, as described in Section IV . However, the agencies are not proposing a vocational truck standard predicated on using a specific penetration of hy brids. We have not predicated the standards based on the use of h ybrids reflecting the still nascent level of technology development and the

160 Gaines, Linda, A. Vyas, J. Anderson (Argonne National Laboratory). Estimation of Fuel Use by Idling Commercial Trucks . January 2006.176 of 54 1

very small fraction of vehicle sales they would be expected to account for in this timeframe on the order of only a percent or two. Where we to overestimate the number of hy brids that could be produced, we would set a st andard that is not feasible. We believe that it is more appropriate given the status of technology development and our high hopes for future advancements in h ybrid technologies to encourage their production through incentives. The agencies welcome comments on this approach. (b ) Gasoline engine technologies The gasoline (or spark ignited) engines certified and sold as loose engines into the heav y - dut y truck market are t ypicall y large V8 and V10 engines produced by General Motors and Ford. The basic engine architecture of these engines is the same as the versions used in the heavy

- dut y pickup trucks and vans. Therefore, the technologies anal yz ed b y the agencies mirror the gasoline engine technologies used in the heav y - dut y pickup truck anal ys is. Building o n the technical anal ys is underl yi ng the 2010 light

- duty FRM, the agencies took a fresh look at technology effectiveness values for purposes of this proposal. NHTSA and EPA used the estimates from the 2012

- 2016 LD rule as a baseline. The agencies then con sidered the impact of test procedures (such as higher test weight of HD pickup trucks and vans) on the effectiveness estimates. The agencies also considered other sources such as the 2010 NAS Report, recent CAFE compliance data, and confidential manufacturer estimates of technology effectiveness. NHTSA and EPA engineers reviewed effectiveness information from the multiple sources for each technology

and ensured that such effectiveness estimates were based on technology hardware consistent with the BOM components used to estimate costs. The agencies note that the effectiveness values estimated for the technologies may represent average values, and do not reflect the potentially

- limitless spectrum of possible values that could result from adding the techn ology to different vehicles. For example, while the agencies have estimated an effectiveness of 0.5 percent for low friction lubricants, each vehicle could have a unique effectiveness estimate depending on the baseline vehicle’s oil viscosity rating. For purposes of this NPRM, NHTSA and EPA believe that emplo yi ng average values for technology effectiveness estimates is an appropriate way

of recognizing the potential variation in the specific benefits that individual manufacturers (and individual engines) might obtain from adding a fuel

- saving technology . However, the agencies seek comment on whether additional levels of specificit y be yond that already provided would improve the analysis for the final rules, and if so, how those levels of specificity shoul d be anal yz ed. Baseline Engine: Similar to the gasoline engine used as the baseline in the Light

duty GHG rule, the agencies assumed the baseline engine in this segment to be a naturally aspirated, overhead valve V8 engine. The following discussion of ef fectiveness is generall y in comparison to 2010 baseline engine performance. The technologies the agencies considered include the following:Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

177 of 54 1 Engine Friction Reduction: Inaddition to low friction lubricants, manufacturers can also reduce friction and impro ve fuel consumption by improving the design of engine components and subs ys tems. Examples include improvements in low

- tension piston rings, piston skirt design, roller cam followers, improved crankshaft design and bearings, material coatings, material subs titution, more optimal thermal management, and piston and cylinder surface treatments. The 2010 NAS, NESCCAF and EEA reports as well as confidential manufacturer data used in the Light

- duty GHG rulemaking suggested a range of effectiveness for engine frict ion reduction to be between 1 to 3 percent. NHTSA and EPA continue to believe that this range is accurate. Coupled Cam Phasing: Valvetrains with coupled (or coordinated) cam phasing can modify

the timing of both the inlet valves and the exhaust valves an equal amount by phasing the camshaft of a single overhead cam (SOHC) engine or an overhead valve (OHV) engine. Based on 2010 L ight

- dut y final rule, previousl y - received confidential manufacturer data, and the NESCCAF report, NHTSA and EPA estimated the ef fectiveness of CCP to be between 1 to 4 percent. NHTSA and EPA reviewed this estimate for purposes of the NPRM, and continue to find it accurate. Cylinder Deactivation: In conventional spark

- ignited engines throttling the airflow controls engine torque output. At partial loads, efficiency can be improved by using cylinder deactivation instead of throttling. Cylinder deactivation can improve engine efficiency

by disabling or deactivating (usually) half of the cylinders when the load is less than half of the engine’s total torque capability

– the valves are kept closed, and no fuel is injected

– as a result, the trapped air within the deactivated cylinders is simply compressed and expanded as an air spring, with reduced friction and heat losses. The active cylinders combust at almost double the load required if all of the cylinders were operating. Pumping losses are significantl y reduced as long as the engine is operated in this “part cylinder” mode. Effectiveness improvements scale roughl y with engine disp lacement

- to
- vehicle weight ratio

- the higher displacement

- to
- weight vehicles, operating at lower relative loads for normal driving, have the potential to operate in part

cylinder mode more frequently . Therefore, the agencies reduced the effectiveness ass umed from this technology for trucks because of the lower displacement

- to
- weight ratio relative to light

- duty vehicles. NHTSA and EPA adjusted the 2010 Light

- dut y final rule estimates using updated power to weight ratings of heavy

- dut y trucks and confidential business information and confirmed a range of 3 to 4 percent for these vehicles. Stoichiometric gasoline direct injection (SGDI): Stoichiometric gasoline direct injection or Spark Ignition Direct injection engines inject fuel at high pressure directl y into the combustion chamber (rather than the intake port in port fuel injection). Direct injection of the fuel into the cylinder improves cooling of the air/fuel charge within the cylinder, which allows for higher compression ratios and increased thermodyn amic efficiency without the onset of combustion knock. Recent injector design advances, improved electronic engine management sy stems and the introduction of multiple injection events per cylinder firing cycle promote better mixing of the air and fuel, e nhance combustion rates, increase residual exhaust gas tolerance and improve cold start emissions. SGDIengines achieve higher power density and match well with other178 of 54 1

technologies, such as boosting and variable valvetrain designs. The 2010 light

- dut y fina l rule estimated the effectiveness of SGDI to be between 2 and 3 percent. NHTSA and EPA revised these estimated accounting for the use and testing methods for these vehicles along with confidential business information estimates received from manufacturer s while developing the proposal. Based on these revisions, NHTSA and EPA estimate the range of 1 to 2 percent for SGDI. (c) Diesel engine technologies Different ty

pes of diesel engines are used in vocational trucks, depending on the application. They

fall i nto the categories of Light, Medium, and Heav y Heavy
- duty Diesel engines. The Li ght Heav y - dut y Diesel engines t ypicall y range between 4.7 and 6.7 liters displacement. The Medium Heav y - duty Diesel engines t ypicall y have some overlap in displacement with the L ight Heavy
- duty Diesel engines and range between 6.7 and 9.3 liters. The Heavy Heavy
- dut y Diesel engines ty picall y are represented by engines between 10.8 and 16 liters. Baseline Engine: There are three baseline diesel engines, a Light, Medium, and a Heav y Heav y - dut y Diesel engine. The agencies developed the baseline diesel engine as a 2010 model year engine with an aftertreatment s ystem which meets EPA’s 0.2 grams of NOx/bhp

- hr standard with a selective catal yt ic reduction (SCR) sy stem along with EGR and meets the PM emissions standard with a diesel particulate filter (DPF) with active regeneration. The engine is turbocharged with a variable geometry turbocharger. The following discussion of technologies describes improvements over the 2010 model ye ar baseline engine performance, unless otherwise noted. Further discussion of the baseline engine and its performance can be found in section III.C.2.6 below. The following discussion of effectiveness is generall y in comparison to 2010 baseline engine performance, and is in reference to performance in terms of the FTP test procedure that would be used for compliance for these engine standards. This is in comparison to the steady state SET test procedure that would be used for compliance purposes for the engines used in Class 7/8 tractors. Turbochargers: Improved efficiency of a turbocharger compressor or turbine could reduce fuel consumption by approximately 1 to 2 percent over today’s variable geometry turbochargers in the market today . The NAS repo rt identified technologies such as higher pressure ratio radial compressors, axial compressors, and dual stage turbochargers as design paths to improve turbocharger efficiency

. Low Temperature Exhaust Gas Recirculation: Most LHDD, MHDD, and HHDD engines so ld in the U.S. market today use cooled EGR, in which part of the exhaust gas is routed through a cooler (rejecting energy to the engine coolant) before being returned to the engine intake manifold. EGR is a technology employed to reduce peak combustion temperatures and thus NOx . L ow - temperature EGR uses a larger or secondary EGR cooler to achieve lower intake charge temperatures, which tend to further reduce NOx formation. If the NOx requirement is unchanged, low

- temperature EGR can allow changes such as mo re advanced injection timing that will increase engine efficiency slightly more than 1 percent. Because low

- temperature EGR reduces the engine’sDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

179 of 54 1 exhaust temperature, it may not be compatible with exhaust energy recovery sy stems such as turbocompound or a bottoming cycle. Engine Friction Reduction: Reduced friction in bearings, valve trains, and the piston

- to
- liner interface will improve efficiency . Any friction reduction must be carefully developed to avoid issues with durability or performance capabilit y . Estimates of fuel consumption improvements due to reduced friction range from 0.5% to 1.5%. 161 Selective catal yt ic reduction (SCR): This technology is common on 2010 heav y duty diesel engines. Because SCR is a highly effective NOx aftertreatment approa ch, it enables engines to be optimized to maximize fuel efficiency , rather than minimize engine

- out NO x . 2010 SCR sy stems are estimated to result in improved engine efficiency of approximately

4 to 5 percent compared to a 2007 in

- cylinder EGR

- based emiss ions sy stem and by

an even greater percentage compared to 2010 in

- cylinder approaches. 162 As more effective low

- temperature cataly sts are developed, the NO x conversion efficiency

of the SCR sy stem will increase. Next

- generation SCR sy stems could then enable still further efficiency improvements; alternativel y, these advances could be used to maintain efficiency while down

- sizing the aftertreatment. We estimate that continued optimization of the catal ys t could offer 1 to 2 percent additional reduction in fuel use over 2010 model y ear s ys tems. 163 Improved Combustion Process: Fuel consumption reductions in the range of 1 to 3 percent are identified in the NAS report through improved combustion chamber design, higher fuel injection pressure, improved injection sh aping and timing, and higher peak cylinder pressures. Reduced Parasitic L oads: Accessories that are traditionally gear or belt driven by a vehicle’s engine can be optimized and/or converted to electric power. Examples include the engine water pump, oil pump, fuel injection pump, air compressor, power

- steering pump, cooling fans, and the vehicle’s air

- conditioning s ys tem. Optimization and improved pressure regulation may significantl y reduce the parasitic load of the water, air and fuel pumps. Electrificat ion may result in a reduction in power demand, because electrically

powered accessories (such as the air compressor or power steering) operate only when needed if they are electrically powered, but they

impose a parasitic demand all the time if they

are en gine driven. In other cases, such as cooling fans or an engine’s water pump, electric power allows the accessory to run at speeds independent of engine speed, which can reduce power consumption. The TIAX [2009, pg. 3

- 5] study used 2 to 4 percent fuel consumption improvement for accessory electrification, with the

161 TIAX, Assessment of Fuel Economy Technologies for Medium

- and Heavy

- Duty Vehicles, Final Repo rt, Nov. 19, 2009, pg 4

- 15 162 Stanton, D. “Advanced Diesel Engine Technology Development for High Efficiency, Clean Com bustion.” Cummins, Inc. Annual Progress Report 2008 Vehicle Technologies Program: Advanced Com bustion Engine Technologies, US Department of Energy. Pp 113

- 116. December 2008. 163 TIAX Assessment of Fuel Economy Technologies for Medium and Heavy
- duty Vehicles, Report to National Academy of Sciences, Nov 19, 2009, pg. 4

- 9180 of 54 1

understanding that electrification of accessories will have more effect in short

- haul/urban applications and less benefit in line

- haul applications. (2) What are the projected technology package effect iveness and cost? (a ) Vocational Trucks (i ) Baseline Vocational Truck Performance The baseline vocational truck model is defined in [TEST], as described in DRIA Chapter 4. The agencies used a baseline rolling resistance coefficient for today ’s vocational truck fl eet of 9 kg/metric ton. 164 Further truck technology is not included, as discussed below in the discussion of the baseline vocational truck. The baseline engine fuel consumption represents a 2010 model year diesel engine, as described in DRIA Chapter 4. Us ing these values, the baseline performance of these vehicles is included in Table III
- 12

. Table III - 12 : Baseline Vocational Truck Perform ance Vocational Truck Light Heavy Medium

H eavy Heavy

Heavy Fuel Consumption Baseline (gallon/1000 ton
- mi le) 44.6 26.7 10.3
CO 2 Baseline (grams CO 2 /ton
- mi le) 454 272 105
(ii) Vocational Truck Technology Package The proposed program for vocational trucks for this phase of regulatory standards is limited to tire and engine technologies. Aerodynamics technology , weight reduction, drive train improvement, and hy brid power trains are not included for the reasons discussed above. The agencies are seeking comment on the appropriateness of this approa ch. The assessment of the proposed technology effectiveness was developed through the use of the [TEST] model. To account for the two proposed engine standards, EPA is proposing the use of a 2014 model year fuel consumption map in [TEST] to derive the 201 4 model year truck standard and a 2017 model y ear fuel consumption map to derive the 2017 model y ear truck standard. EPA estimates that the rolling resistance of tires

164 The baseline tire rolling resistance for this segment of vehicles was d erived for the proposal based on the current baseline tractor and passenger car tires. The baseline tractor drive tire has a rolling resistance of 8.2 kg/metric ton based on SmartWay testing. The average passenger car has a tire rolling resistance of 9.7 5 kg/metric ton based on a presentation made to CARB by the Rubber Manufacturer’s Association. Additional details are available in the DRIA Chapter 2.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

181 of 54 1 can be reduced b y 10 percent in the 2014 model year. The vocational truck standards f or all three regulatory

classes were determined using a tire rolling resistance coefficient of 8.1 kg/metric ton with a 100 percent application rate b y 2014 model year. The set of input parameters which are modeled in [TEST] are described in Table III
- 13

.

Table III - 13 : TEST Inputs for Vocational Truck Standards Vocational Truck 2014 MY 2017 MY Fuel Map 2014 MY 7L for LH/MH and 15L for HH Trucks 2017 MY 7L for

LH/MH and 15L for HH Trucks Tire Rolling Resistance (kg/metric ton) 8.1 8.1 The agencies developed the proposed standards by using the engine and tire rolling resistance inputs in the [TEST] model, as shown in Table III
- 13 . The percent reduction s shown in Table III
- 14 reflect improvements over the 2010 model year baseline truck with a 2010 model y ear baseline engine.

Table III - 14 : Proposed Vocational Truck Standards and Perc ent Reductions Vocational Truck Light Heavy Medium

Heavy Heavy

Heavy 2016 Fuel Consumption Standard (gallon/1000 ton
- mi le) 41.3 24.5 9.9 2017 Fuel Consumption Standard (gallon/1000 ton
- mi le) 39.7 23.6 9.8
2014 CO 2 Standard (grams CO 2 /ton
- mi le) 4 20 249 101 2017 CO 2 Standard (grams CO 2 /ton
- mi le) 404 240 100 Percent Reduction in 2014 8% 8% 4% Percent Reduction in 2017 11% 12% 5% (iii) Technology Package Cost EPA and NHTSA developed the costs of low rolling resistance tires based on the IC F report. The estimated cost per truck is $155 (2008$) for LHD and MHD trucks and $186 (2008$) for HHD trucks. These costs include a low complexity I CM of 1.14 and are applicable in the 2014 model year (iv) Alternative Truck Standards Considered The agencies are not proposing truck standards less stringent than the proposed standards because the agencies believe these standards are highl y cost effective, as described in Section VIII.182 of 54 1 The agencies considered proposing truck standards which are more stringent reflectin g the inclusion of hy brid powertrains in vocational trucks. However, the agencies are not proposing this level of stringency because our assessment is that these technologies would not be broadl y available for production by the 2017 model year. The agenc ies welcome comments on whether h yb rid powertrain technologies are appropriate to consider for the 2017 model y ear standard, or if not, then when would they be appropriate. (b ) Gasoline Engines (i ) Baseline Gasoline Engine Performance EPA and NHTSA developed the r eference heavy

- duty gasoline engines to represent a 2010 model year engine compliant with the 0.2 g/bhp

- hr NOx standard for on - highway

heavy duty engines. NHTSA and EPA developed the baseline fuel consumption and CO 2 emissions for the gasoline engines fr om manufacturer reported CO 2 values used in the certification of non

- GHG pollutants. The baseline engine for the anal ys is was developed to represent a 2011 model year engine, because this is the most current information available. The average CO 2 perform ance of the heav y duty gasoline engines was 660 g/bhp

- hour, which will be used as a baseline. The baseline gasoline engines are all stoichiometric port fuel injected V

- 8 engines without cam phasers or other variable valve timing technologies. While they may

reflect some degree of static valve timing optimization for fuel econom y they do not reflect the potential to adjust timing with engine speed. (ii) Gasoline Engine Technology Package Effectiveness The gasoline engine technology package includes engine frict ion reduction, coupled cam phasing, and stoichiometric gasoline direct injection to produce an overall 5 percent reduction from the reference engine based on the Heav y - duty Lumped Parameter model. The agencies are projecting a 100% application rate of thi s technology package to the heav y dut y gasoline engines, which results in a CO 2 standard of 627 g/bhp

- hr and a fuel consumption standard of 7.05 gallon/100 bhp

- hr. As discussed in Section II.D.b.ii, the agencies propose the gasoline engine standards begin in the 2016 model y ear based on the agencies’ projection of the engine redesign schedules of the small number of engines in this category

. (iii) Gasoline Engine Technology Package Cost For costs, the agencies reconsidered both the direct or “piece” costs and in direct costs of individual components of technologies. For the direct costs, the agencies followed a bill of materials (BOM) approach employ ed b y NHTSA and EPA in the 2012

- 2016 LD rule. NHTSA and EPA are proposing to use the marked up gasoline engine technology

costs developed for the HD Pickup Truck and Van segment because they are made b y the same manufacturers (primaril y b y Ford and GM) and, therefore, the indirect cost markups used there are more appropriate here. The costs are summarized in Table III
- 15 . The costs shown in Table III
- 15 include a low complexity I CM of 1.17 and areDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

183 of 54 1 applicable in the 2016 model y ear. No learning effects are applied to engine friction reduction costs, while time based learning is considered applicable to both coupled cam phasing and stoichiometric GDI.

Table III - 15 : Heavy Duty Gasoline Engine Technology Costs (2008$) 2016MY Engine Friction Reduction $88 Coupled Cam Phasi ng $43 Stoichiometric Gas Direct Injection $372 Total $504 (iv) Alternative Gasoline Engine Standards Considered The agencies are not proposing gasoline standards less stringent than the proposed standards because the agencies believe these standards are hi ghl y cost effective. The agencies considered proposing gasoline standards which are more stringent reflecting the inclusion of cylinder deactivation and other advanced technologies. However, the agencies are not proposing this level of stringency because our assessment is that these technologies would not be available for production b y the 2017 model year. The agencies welcome comments on whether other gasoline technologies are appropriate to consider for the 2017 model y ear standard, or if not, then when would they be appropriate. (c) Diesel Engines (i ) Baseline Diesel Engine Performance EPA and NHTSA developed the baseline heavy

- duty diesel engines to represent a 2010 model year engine compliant with the 0.2 g/bhp

- hr NOx standard for on

- highway heav y dut y engine s. The agencies utilized 2007 through 2011 model year CO 2 certification levels from the FTP cycle as the basis for the reference engine CO 2 performance. The pre - 2010 data are subsequently

adjusted to represent 2010 model year engine maps by using predef

ined technologies includ ing SCR and other sy stem s that are being used in current 2010 production . . The engine CO 2 results were then sales weighted within each regulatory class to develop an industry average 2010 model year reference engine, as shown in Table III
- 16 . The level of CO 2 emissions and fuel consumption of these engines varies significantl y, where the engine with the highest CO 2 emissions is estimated to be 20 percent greater than the sales weighted average. Details of this anal ys is are included in DRIA Chapter 2.184 of 54 1 Table III - 16 : 2010 Model Year Reference Diesel Engine Perform ance CO 2 Emissions (g/bhp

- hr) Fuel Consumption

(gallon/100 bhp

- hr) Li ght Heav y Diesel

- FTP 630 6 .19 Medium Heav y Diesel

- FTP 630 6.19 Heav y Heav y Diesel

- FTP 584 5.74 (ii) Diesel Engine Packages The diesel engine technology packages for the 2014 model y ear include engine friction reduction, improved aftertreatment effectiveness, improved combustion p rocesses, and low temperature EGR s ys tem optimization. The improvements in parasitic and friction losses come through piston designs to reduce friction, improved lubrication, and improved water pump and oil pump designs to reduce parasitic losses. The af tertreatment improvements are available through lower backpressure of the sy stems and optimization of the engine

- out NOx levels. Improvements to the EGR sy stem and air flow through the intake and exhaust sy stems, along with turbochargers can also produce engine efficiency improvements. It should be pointed out that individual technology

improvements are not additive to each other due to the interaction of technologies. The agencies assessed the impact of each technology over the FTP and project an overall cycle improvement in the 2014 model year of 3 percent for HHDD and 5 percent for LHDD and MHDD engines, as detailed in DRIA Chapter 2. EPA used a 100 percent application rate of this technology package to determine the proposed 2014 MY standards Recently , EPA’s non

- GHG heav y dut y engine program provided new emissions standards for the industry in three year increments. The heav y dut y engine manufacturer product plans have fallen into three y ear cycles to reflect this environment. EPA is proposing set CO 2 emission standards recognizing the opportunity for technology improvements over this timeframe while reflecting the typical heav y dut y engine manufacturer product plan cycles. Thus, the agency is setting initial standards for the 2014 model year and a m ore stringent standard for heav y dut y engines beginning in the 2017 model year. The 2017 model year technology package for LHDD and MHDD engine includes continued development and refinement of the 2014 model year technology package. This package leads to a projected 9 percent reduction for LHDD and MHDD engines in the 2017 model year. The HHDD engine technology packages for the 2017 model y ear include the continued development of the 2014 model year technology package plus turbocompounding. A similar app roach to evaluating the impact of individual technologies as taken to develop the overall reduction of the 2014 model year package was taken with the 2017 model year package. The FTP cycle improvements lead to a 5 percent reduction on the cycle for HHDD, as detailed in DRIA Chapter 2. The agenciesDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

185 of 54 1 used a 100 percent application rate of the technology package to determine the proposed 2017 MY standards. The agencies believe that bottom cycling technologies are still in the development phase and will not b e read y for production by the 2017 model year. 165 Therefore, these technologies were not included in determining the stringency of the proposed standards. However, we do believe the bottoming cycle approach represents a significant opportunit y to reduce fu el consumption and GHG emissions in the future. EPA and NHTSA are therefore both proposing provisions described in Section IV to create incentives for manufacturers to continue to invest to develop this technology

. The overall projected improvements in CO 2 emissions and fuel consumption over the baseline are included in Table III
- 17

Table III - 17 : Percent Fuel Consumption and CO 2 Emission Reductions 2014 2017 Li ght Heav y Diesel

- FT P 5% 9% Medium Heav y Diesel

- FTP 5% 9% Heav y Heav y Diesel

- FTP 3% 5% (iii) Technology Package Costs NHTSA and EPA jointly developed costs associated with the engine technologies to assess an overall package cost for each regulatory class. The agencies are taking a slightly different approach to assess the overall costs of the MHD and HHD diesel engine program than the BOM approach used for the other regulatory groups. The engine costs in this analy sis are proposed to include separate analy sis of the increm ental part costs, research and development activities, and additional equipment, such as emissions equipment to measure N 2 O emissions. The agencies are taking a different approach to cost estimation in this case because we estimate that the indirect costs including those related to research and development are the primary determinant in the cost to the manufacturers. Our general approach used elsewhere in this proposal (for HD pickup trucks, gasoline engines, Class 7/8 tractors, and Class 2b

- 8 vocational trucks) estimates a direct manufacturing cost for a part and marks it up based on a factor to account for indirect costs. See also 75 FR at 25376. We believe that approach is appropriate when compliance with proposed standards is achieved generall y b y in stalling new parts and sy stems purchased from a supplier. In such a case, the supplier is conducting the bulk of the research and development on the new parts and sy stems and including those costs in

165 TIAX noted in their report to the NAS panel that the engine improvements beyond 2015 model year incl uded in their report are highly uncertain, though they include waste heat recovery in the engine package for 2016 through 2020 (page 4

- 29).186 of 54 1

the purchase price paid by the original equipment manuf acturer. The indirect costs incurred b y the original equipment manufacturer need not include much cost to cover research and development since the bulk of that effort is already done. For the MHD and HHD diesel engine segment, however, the agencies do not consider this model to be the most appropriate because the primary cost is not expected to be the purchase of parts or sy stems from suppliers or even the production of the parts and s ys tems, but rather the development of the new technology by the origi nal equipment manufacturer itself. Therefore, the agencies believe it more accurate to directly estimate the indirect costs. EPA commonly

uses this approach in cases where significant investments in research and development can lead to an emission contro l approach that requires no new hardware. For example, combustion optimization may significantly

reduce emissions and cost a manufacturer millions of dollars to develop but will lead to an engine that is no more expensive to produce. Using a bill of mate rials approach would suggest that the cost of the emissions control was zero reflecting no new hardware and ignoring the millions of dollars spent to develop the improved combustion sy stem. Details of the cost analy sis are included in the DRIA Chapter 2. To reiterate, we have used this different approach because the MHD and HHD diesel engines are expected to compl y in large part via technology

changes that are not reflected in new hardware but rather knowledge gained through laboratory

and real world test ing that allows for improvements in control sy stem calibrations

– changes that cannot be reflected well through direct costs with indirect cost multipliers. The agencies developed the engineering costs for the research and development of diesel engines with lower fuel consumption and CO 2 emissions. The aggregate costs for engineering hours, technician support, dynamometer cell time, and fabrication of prototy pe parts are estimated at $6,750,000 per manufacturer per ye ar over the five y ears covering 2012 through 2016. In aggregate, this average out to $530 per engine during 2012 through 2016 using a very rough annual sales value of 280,000 medium

- HD and heav y - HD engines. The agencies also are estimating costs of $100,000 per engine manufacturer per engine class (medium

- HD and heavy

- HD) to cover the cost of purchasing photo

- acoustic measurement equipment for two engine test cells. This would be a one

- time cost incurred in the year prior to implementation of the standard (i.e., the cost would be incurred in 2 013). In aggregate, this averages out to $4 per engine in 2013 using a very

rough annual sales value of 280,000 medium

- HD and heav y - HD engines. EPA also developed the incremental piece cost for the components to meet each the 2014 and 2017 standards. Ind irect Cost Multipliers and learning are applied to each technology

to develop the piece costs included in Table III
- 18 . All costs shown in Table III
- 18 include a low complexity I CM of 1.11 and time based learning is considered applicable to each technology

.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

187 of 54 1 Table III - 18 : Heavy - duty Diesel Engine Component Costs (2008$) 2014 Model Year 2017 Model

Year Cy linder Head (flow optimized, increased firing pressure, im proved thermal management) $6 $6 Exhaust Manifold (flow optimized, improved thermal management) $0 $0 Turbocharger (improved efficienc y) $17 $16 EGR Cooler (improved efficienc y) $3 $3 Wa ter Pump (optimized, variable vane, variable speed) $87 $79 Oi l Pump (optimized) $4 $4 Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) $4 $4 Fuel Rail (higher working pressure) $10 $9 Fuel Injector (optimized, improved multiple event control, higher working pressure) $10 $9 Piston (reduced friction skirt, ring and pin) $3 $2 Aftertreatment system (i mp roved effectiveness SCR, dosing, dpf) a $0 (MH & HH) $111 (LH) $0 (MH & HH)

$101 (LH) Valve Train (reduced friction, roller tappet) $78 $71
a Note that costs for aftertreatment improvements for MH and HH diesel engines are covered via the engineering costs (see text). For LH diesel engines, we have included the cost of aftertreatment im provements as a technology cost. The overall costs for each diesel engine regulatory class are included in Table III
- 19

. Table III - 19 : Diesel Engine Technology Costs per Engine (2008$) 2014 2017 LHD Diesel $328 $299 MHD Diesel $223 $203 HHD Diesel $145 $132
(iv) Alternativ e Diesel Engine Standards Considered The agencies are not proposing diesel engine standards less stringent than the proposed standards because the agencies believe these standards are highl y cost effective.188 of 54 1 The agencies considered proposing diesel engine s tandards which are more stringent reflecting the inclusion of other advanced technologies. However, the agencies are not proposing this level of stringency because our assessment is that these technologies would not be available for production by the 2017 model year. The agencies welcome comments on whether other diesel engine technologies are appropriate to consider for the 2017 model y ear standard, or if not, then when would they be appropriate. 

## IV. Proposed Regulatory Flexibility Provisions This section d iscusses proposed flexibility provisions intended to achieve the goals of the overall GHG program while providing alternate pathway s to achieve those goals. The primary

flexibility

provisions the agencies are proposing for combination tractors and vocatio nal trucks relate to a program of Averaging, Banking, and Trading of credits (ABT) that EPA and NHTSA are proposing in association with each agency’s respective standards (see Section II above). For HD pickups and vans, the primary flexibility provision i s the fleet averaging program patterned after the LD GHG and CAFE rule. In addition, this section also describes proposed flexibility provisions that would apply

in specific circumstances. 

### A. Averaging , Bank

ing, and Trading (ABT) Program Averaging, Banking, and Trading (ABT) of emissions credits have been an important part of man y EPA mobile source programs under CAA Title II, including engine and vehicle programs. ABT programs can be important because they can help to address man y issues of technological fea sibility and lead

- time, as well as considerations of cost. ABT programs are not just add

- on provisions included to help reduce costs, but are usuall y an integral part of the standard setting itself. An ABT program is important because it provides manufac turers flexibilities that assist the development and implementation of new technologies efficientl y, and therefore enables new technologies to be implemented more quickly than without ABT. A well

- designed ABT programs can provide important environmental b enefits and at the same time increase flexibility and reduce costs for the regulated industry

. Section II above describes EPA’s proposed GHG emission standards and NHTSA’s proposed fuel consumption standards. For each of these respective sets of standar ds, the agencies are also proposing ABT provisions consistent with each agency ’s statutory authorit y. The agencies have worked closely together to design these proposed provisions to be essentially identical to each other in form and function. Because of this fundamental similarity , the remainder of this section refers to these provisions collectively

as “the ABT program” except where agency

- specific distinctions are requi red. As discussed in detail below, the structure of th is proposed GHG ABT program fo r HD engines is based closely on earlier ABT programs for HD engines; the proposed program for HD pickups and vans is built on the existing light

- dut y GHG program flexibility provisions; and we propose first

- time ABT provisions for combination tractorsDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

189 o f 402 and vocational trucks that are as consistent as possible with our other HD vehicle regulations . The flexibility provisions associated with this new regulatory category are intended to sy stematically build upon the structure of the existing programs. As an overview, “averaging ” means the exchange of emission credits between engine families or truck families within a given manufacturer’s regulatory class

. For example within each regulatory class, e ngine manufacturers divide their product line into ‘‘engine f amilies’’ that are comprised of engines expected to have similar emission characteristics throughout their useful life. Averaging allows a manufacturer to certify one or more engine families within the same regulatory class at levels above the applicable emission standard. T he increased emissions over the standard must be offset by one or more engine families within that manufacturer’s regulatory class that are certified below the same emission standard, such that the average emissions from all the manufa cturer’s engine families, weighted by engine power, regulatory useful life, and production volume, are at or below the level of the emission standard. (The inclusion of engine power, useful life, and production volume in the averaging calculations allows the emissions credits or debits to be expressed in total emissions over the useful life of the credit

- using or generating engine sales .) Total credits for each regulatory class within each model ye ar are determined by summing together the credits calculat ed for every engine famil y within that specific regulatory class. “Banking” means the retention of emission credits by the manufacturer for use in future model ye ar averaging or trading. “Trading” means the exchange of emission credits between manufacturers , which can then be used for averaging purposes, banked for future use, or traded to another manufacturer. In the current program, m anufacturers are restricted to onl y averaging, banking and trading credits generated within a regulatory class. In the past, w e have followed this practice of allowing trading between like products for two primary reasons. First by onl y allowing credit averaging, banking and trading between similar products we can help ensure that the regulations do not create an unlevel playing field for the regulated industry . Engine and truck manufacturers have commonly

expressed to us a concern that some manufacturers with a wide range of product offerings spanning a number of regulatory categories would be able to use the ABT program provisions to generate credits in regulatory class markets where they face less competition and then use those credits to compete unfairl y in other regulatory categories where they

face greater competition. Second, we have recognized that the estimation of emission credits is not an absolutely precise process and actual emission reductions or increases “in

- use” will vary due to differences in vehicle dut y cycles, maintenance practices and any number of other factors. By restricting credit trading betwee n like products, the agencies gain some degree of assurance that the operation and use of the vehicles generating credits and consuming credits will be similar. Emission credits in the current EPA engine ABT program and NHTSA fuel consumption credits repre sent the amount of emission s and fuel consumption of an engine or truck family that fall below or above the applicable CO 2 emission and fuel consumption standard s . Calculated or selected emissions and fuel consumption levels below the standard create “posi tive credits,” while calculated or selected emissions and fuel consumption levels above the standard create “negative credits.” In addition,190 of 542

“projected credits” refer to emission and fuel consumption credits based on the (future or estimated) projected app licable production volume of the engine or truck family

. “Reserved credits” are emission and fuel consumption credits generated within a model ye ar waiting to be reported to the agencies at the end of the model ye ar. “Actual credits” refer to emission cred its based on actual applicable production volume as contained in the end

- of

- ye ar reports (or final reports as applicable) submitted to the agencies . Some or all of these credits may

be revoked if the agencies review of the end

- of

- ye ar reports or an y subsequent audit action(s) reveals problems or errors with credit computations. For this proposal, the agencies are adopting the framework of EPA’s existing engine ABT program, including how averaging, banking, and trading would work in the proposed GHG and fuel consumption ABT program. (1) Heavy - duty Engines For the heav y - dut y engine ABT program, th e EPA and NHTSA are proposing to use EPA’s existing regulatory engine classification categories as the category designations under this engine ABT program. The existing diesel engine categories are light

- heav y dut y (LHD), medium

- heav y dut y (MHD), and heav y - heavy duty (HHD). LHD diesel engines are primarily used in vehicles with a gross vehicle weight rating (GVWR) of less than 19,500 lbs . These engines typically have a rated horsepower ranging from 70 to 170 hp . Vehicle body t ypes in this group might include any heav y duty vehicle built for a light

- dut y truck chassis, van trucks , multi

- stop van s , recreational vehicle s , and some single axle straight trucks. Vehicles conta ining these engines would normally include personal transportation, light

- load commercial hauling and delivery , passenger service, agriculture, and construction applications

. MHD diesel e ngines are normally used in vehicles whose GVWR varies from 19,500

– 33 ,000 lbs. These diesel engines r ated horsepower generally ranges from 170 to 250 hp . Vehicle s containing these engines t ypically include school buses, tandem axle straight trucks, city

tractors, and a variet y of special purpose vehicles such as small dump trucks, and trash compactor trucks. Normall y the applications for these vehicles would include commercial short haul and intra

- city delivery and pickup. HHD diesel engines are intended for use in vehicles which exceed 33,000 lbs. GVWR. These diesel engine s rated horsepower generall y exceeds 250 hp. Vehicles containing engines of this ty pe are normally

tractors, trucks, and buses used in inter

- city , long

- haul applications. HHD engines are generall y regarded as designed for rebuild and have a long useful lif

e period. LHD and MHD engines are t ypically not intended for rebuild, though some MHD engines are designed for rebuild, and have a shorter useful life. Gasoline or spark ignited engines for heav y - dut y vehicles fall into one separate regulatory

class. T hese engines are t ypically installed in trucks with a GVWR ranging from 8,500 pounds to 19,500 pounds although they can be installed into trucks of an y size.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

191 o f 402 The compliance program we are proposing would adopt a slightl y different method for generating a m anufacturer’s CO 2 emission and fuel consumption credit or deficit. The manufacturer’s certification test result would serve as the basis for the generation of the manufacturer’s family certification level (FCL). The FCL is a new term we propose for this program to differentiate the purpose of this credit generation technique from the family emission limit (FEL) previously used in a similar context in other EPA rules. A manufacturer could define its FCLat any level at or above the certification test resu lt. Credits for the ABT program would be generated when the FCL is compared to the CO 2 and fuel consumption standard, as discussed in section II. The credits earned in this section will be restricted to the engine classification and not tradable with other engine classifications consistent with EPA’s past practice for ABT programs as described previousl y. Credit calculation for the proposed Engine ABT and fuel consumption programs would be generated, either positive or negative, according to Equation IV
- 1 and Equation IV
- 2 :

Equation IV - 1 Proposed HD Engine CO 2 credit (deficit) HD Engine CO 2 credit (deficit) (metric tons) = (Std

- FCL) x (CF) x (Volume) x ( UL) x (10 - 6 ) where Std = the standard associated with the specific engine regulatory class (g/hp

- hr) FCL= Family

Certification L evel for the engine family CF = a transient cycle conversion factor in bhp

- hr/mile which is the integrated total cycle brake ho rsepower - hour divided by the equivalent mileage of the applicable test cycle. For gasoline heavy dut y engines, the equivalent mileage is 6.3 miles. For diesel heav y dut y engines, the equivalent mileage is 6.5 miles. Volume = (projected or actual) product ion volume of the engine family UL= useful life of the engine (miles) 10 - 6 converts the grams of CO 2 to metric tons Equation IV - 2 : Proposed HD Engine Fuel Consumption credit (deficit) in gallons HD Diesel Engine Fuel Consumption credit for (deficit) (gallons) = (HD Engine CO 2 Credit in metric tons) x (10 6 ) / (PG) Where PG=the number of grams of CO 2 per gallon of fuel: 10,180 for diesel, 8,871 for gasoline HD Gasoline Engine Fuel Consumption credit for (def icit) (gallons) = (HD Engine CO 2 Credit in metric tons) x (10 6 ) / (8,871)192 of 542 10 6 converts the metric tons to grams To calculate credits, manufacturers would determine a famil y certification l imit (FCL) for each engine family category they have designated for the ABT program. That FCLmay be above (negative) or below (positive) the standard and would be used to establish the CO 2 credits earned (or used) in Equation IV
- 1. The proposed CO 2 and fuel consumption standards are associated with specific regulatory classes as described in §II.C (light heav y - dut y, medium heav y - dut y, and heav y heav y - dut y). In the ABT program, engines certified with an FCL below the standard in each of the three regulatory classes in Table IV
- 1 could generate positive credits ( g/bhp

- hr and gal/100 bhp

- hr)

. The volume used in Equation IV

- 1 refers to the total number of eligible engines sold per family to participate in the ABT program during that model year. An engine family is described in draft regulation 40 CFR 1036.230. In equation IV

- 1, a manufacturer would also need to average its Power Rating across their engine family configurations and weight this figure b y sales volume per engine famil y class. As an example, a manufacturer with three engine famil ies in their fleet engine family average subject to the ABT program with power rating classes of 300, 325 and 350 horsepower would average the power rating of these classes according to intended volume of sales, L et’s assume the manufacturer sells (100, 1 50 and 200) engines respectivel y. The resulting average power rating would be [(300 hp x 100) + (325 hp x 150) + (350 hp x 200)] ÷ 450, so the average would be 330.56 hp. The useful life values in Equation IV

- 1 are proposed to be the same as the regulato ry

classifications previously used for the LHD, MHD and HHD engine groups. Thus, the agencies propose that for LHD diesel engines and gasoline engines, the useful life values would be 110,000; for MHD engines, 185,000 miles; and for HHD engines, 435,000 m iles. Once CO 2 credits are calculate using Equation IV

- 1, a manufacturer would simply

convert the tons of CO 2 to gallons to calculate fuel consumption credits, using Equations IV

- 2. The same equation would be used to compute credits needed to reconcile deficits when the manufacturer seeks to settle shortfalls within a particular model year that still meets EPA’s GHG standards and NHTSA’s fuel consumption standards under the ABT program. We have defined engine families in 40 CFR § 1036.230 and manufactur ers may designate how to group their engines for certification and compliance purposes.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

193 o f 402 Table IV - 1 : Engine Service Classes Engine Category Intended service class description LHD light

- duty truck ch assis van multi

- stop van single axle straight trucks MHD school buses

tandem axle straight trucks C ity tractors Dump and Refuse Utility vehicles HHD Multi

- axle trucks used long

- haul applications

Large inter

- cit y busses Credits generated b y engine manufacturers un der this ABT program would be restricted for use onl y within their engine class based on performance against the standard as defined in Table II. 1 . For example, LHD engine manufacturers could only use their LHD engine credits for averaging, banking and tr ading with LHD engines, not with MHD or HHD engines. This limitation is consistent with today ’s criteria pollutant program for engines and would help ensure that credits earned to reduce GHG emissions and fuel consumption would be used to limit their growth and not circumvent the intent of the regulations. EPA and NHTSA are concerned that extending the use of credits beyond these designated classes could also create an advantage for large or integrated manufacturers that currently does not exist in the market . A manufacturer that produces both engines and equipment for heav y - dut y highway vehicles could mix credits across engine and equipment sectors, shifting the burden between the sectors, not equally shared in either sector, to gain an advantage over co mpetitors that are not integrated. Similarly , large volume manufacturers of engines can shift credits between heav y - heavy dut y engines and light

- heav y duty engines to gain an advantage in one sector over other manufacturers that may

not have multiple engi ne offerings over several regulatory engine sectors. Finally , relating credits between categories of engines could be problematic because of the differences in regulatory useful lives. The agencies want to avoid having credits from longer useful life cat egories flooding shorter useful life categories, adversel y impacting compliance with CO 2 standards in the shorter useful life category. The agencies would like to ensure that this regulation reduces CO 2 emissions and fuel consumption in each engine catego ry but does not interfere with the ability of manufacturers to engage in free trade and competition. Li miting credit ABT to the regulatory

category and not between engines and equipment would help due solely to the regulatory

structure to insure that we o ffer no new advantage to an y competitor in the market place. However, the agencies welcome comments on the extension of credits beyond the limitations we are proposing. Under previous ABT programs for other rulemakings, EPA has allowed manufacturers to carry

forward deficits from engines for a set period of time. The agencies are proposing to allow manufacturers of engines to carry forward deficits for up to three years before reconciling the short

- fall. However, manufacturers must use credits,194 of 542

once cr edits are generated, to offset a shortfall before credits may be banked or traded for additional model y ears. This restriction reduces the chance of manufacturers passing forward deficits before reconciling shortfalls and exhausting those credits before r econciling past deficits. We will accept comments on alternative approaches for reconciling deficit shortfalls in the engine category

. As described in section II above, EPA is proposing that engine manufacturers have the added option of combining their CH 4 and N 2 O emissions with their CO 2 emissions for a CO 2 equivalence value that recognizes the inter

- correlation of these elements in impacting global warming. This option does not apply to the NHTSA fuel consumption program. To take account of the differe nt global warming potential of these GHG s, EPA proposes to use Equation IV
- 3 :

Equation IV - 3 : CO 2 Eq = CO 2 + (25*CH 4 ) + (298 *N 2 O)
The CO 2 equivalen cy equation can be used to combi ne CH 4 and N 2 O with CO 2 where the result would need to meet the CO 2 standard rather than report numbers for the CO 2 standard and separate numbers for the N 2 O and CH 4 caps. In general, we do not expect manufacturers to use this provision. However, we are providing this alternative as a flexibility

in the event an engine OEM has trouble meeting the CH 4 and/or the N 2 O emissions caps. (As specified above, there are no ABT credits for performance that falls below N 2 O and CH 4 caps). Manufacturers would need t o meet the FEL limit when they use the CO 2 equivalent standard, not the FCLimposed for CO 2 alone. Additional flexibilities for engines are discussed later in Section IV(B). Engine manufacturers will not need to adopt new testing provisions or new equipm ent to assess engine performance to meet the requirements for CO 2 emissions or fuel consumption reduction, though manufacturers may need to purchase new equipment to measure N 2 O. In fact, the onl y additional testing cost that is anticipated to meet the GH G standards set forth above will likel y be N 2 O measurement equipment. We have not generated new classifications for manufacturers outside the existing ones previousl y chosen for this industry so we do not anticipate an y additional difficulties presented i n this regulation for manufacturers to understand and utilize our ABT program. We welcome comments on additional arguments related to needed flexibility within this program. (2) Class 7/8 Combination Tractors In addition to the engine ABT program described above, the agencies are also proposing a vehicle ABT program to facilitate reductions in GHG emissions and fuel consumption based on combination tractor design changes and improvements. For this category , the structure of the proposed ABT program should create incentives for tractor manufacturers to advance new, clean technologies, or existing technologies earlier than they would otherwise. As explained above, combination tractor manufacturers are divided into the following nine regulatory classes under these proposed rules:Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

195 o f 402 Class 7 Day

Cab Class 8 Day Cab Class 8 Sleeper Cab Low Roof Low Roof Low Roof Mid Roof Mid Roof Mid Roof High Roof High Roof High Roof Vehicle c redits for tractors in these classifications will be earned on a g/ton

- mile or gallo n/1000 ton

- mile basis for tractors which are below the standard

. C redits generated within regulatory classes will be tradable between truck manufacturers in that specific regulatory

class only . Credits will not be fungible between engine and vehicle regu latory

classes. This is similar to the restrictions we have described above for engine manufacturers. This limitation will help ensure that credits earned to reduce GHG emissions and fuel consumption will be used to limit their growth and not circumvent the intent of our regulation. We are concerned that extending the use of credits to be transferred or traded to other classes may

create an advantage for large or integrated manufacturers that currentl y does not exist in the market. We would like to ens ure that this regulation reduces the emission of CO 2 and fuel consumption but does not interfere with the ability of manufacturers to engage in free trade and competition. This a ddresses competitive concerns expressed b y non - integrated manufacturers and those with limited participation in the market. This structure a llows for a straightforward compliance program for each sector independently

with aspects that are also independentl y quantifiable and verifiable

. Credit calculation for the Proposed Class 7 /8 Tractor CO 2 and fuel consumption credits will be generated, either positive or negative, according to Equation IV

- 4 and Equation IV
- 5: Equation IV - 4 : The proposed Class 7/8 Tractor CO 2 credit (deficit) Class 7/8 Tractor CO 2 credit (deficit)( metric tons ) = (Std

- FCL) x (Payload Tons) x (Volume) x (UL) x (10 - 6 )

where Std = the standard associated with the specific tractor regulatory class (g/ton

- mile) Payload tons = the prescribed payload for each class in tons (12.5 tons for Class 7 and 19 tons for Class 8) FCL= Family

Certification L evel for the tractor family Volume = (projected or actual) production volume of the tractor famil y UL= useful life of the tractor (435,000 miles for Class 8 and 185,000 mile s for Class 7) 10 - 6 converts the grams of CO 2 to metric tons Equation IV - 5 : Proposed Class 7/8 Tractor Fuel Consumption credit (deficit) in gallons =196 of 542

Class 7/8 Tractor Fuel Consumption credit for (deficit) (gallons) = (Class 7/8 Tractor CO 2 credit in metric tons) x (10 6 ) / (10,180) where 10,180 is the number of grams of CO 2 per gallon of diesel fuel 10 6 converts the metric tons to grams
Similar to the proposed Heav y - dut y Engine ABT program described in the previous section, tractor manufacturers would be able to carry forward credit deficits from their regulatory

classes for three years before reconciling the shortfall. However, just as in the engine category , manufacturers must use credits once those cred its have been generated to offset a shortfall before those credits can be banked or traded for additional model y ears. This restriction reduces the chance of tractor manufacturers passing forward deficits before reconciling their shortfalls and exhausting those credits before reconciling past deficits. Manufacturers of vehicles that generate a deficit at the end of the model ye ar, i.e. their fleet average exceeds the fleet standard for their vehicle classification, that manufacturer could carry that defic it forward for three years following the model year for which that deficit was generated. Deficits must be reconciled at the reporting dates for year three. We will accept comments on alternative approaches of reconciling deficit shortfalls. Additional f

lexibilities for class 7/8 combination tractors are discussed later in Section IV(B). (3) Class 2b - 8 Vocational Vehicles Similar to the Class 7 and 8 combination tractor manufacturers, we are offering a limited ABT program for Class 2b

- 8 vocational chassis manufacturers. As the certification of the chassis will be based on the use of low rolling resistance tires, those manufacturers that introduce products into the market with performance improvements, which are better than required to meet the vehicle standards, vehicle credits will be generated. Credit calculation for the Proposed Class 2b

- 8 vocational vehicle CO 2 and fuel consumption credits (deficits) will be generated, either positive or negative, according to Equation IV

- 6 and Equation IV

- 7:

Equation IV - 6 : The proposed HD HWY CO 2 vehicle credit (deficit) Vocational Vehicle CO 2 credit (deficit) (metric tons) = (Std

- FCL) x (Payload Tons) x (Sales Volume) x (UL) x (10 - 6 ) where Std = the standard associated with the specific tractor regulatory class (g/ton

- mile)Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

197 o f 402 Payload tons = the prescribed payload for each class in tons (2.85 tons for LHD, 5.6 tons for MHD, and 19 tons for HHD) FCL= Family

Certification L evel for the vehicle family Volume = (projected or actual) production volume of the vehicle family UL= useful life of the vehicle (110,000 miles for LHD, 185,000 miles for MHD, or 435,000 miles for HHD) 10 - 6 converts the grams of CO 2 to metric tons Equation IV - 7 : Proposed Vocational Vehicle Fuel Consumption credit (deficit) in gallons Vocational Vehicle Fuel Consumption credit for (deficit) (gallons) = (Vocational Vehicle CO 2 credit in metric tons) x (10 6 ) / (10,180) where 10,180 is the number of grams of CO 2 per gallon of diesel fuel 10 6 converts the metric tons to grams Also similar to the proposed heav y - dut y engine and tractor ABT programs, the vehicle credits generated within each regulatory class will be allowed to be averaged, banked, or traded betwee n chassis manufacturers within their existing categories. For vocational vehicles the categories are based on the vehicles GVWR rating. We are proposing vehicles with a GVWR <14,000 lbs, vehicles between 14,000 and 26,000 lbs, and vehicles with a GVWR >2 6,000 lbs. These three weight categories will form the restrictive classifications for vocational vehicles and are discussed in 40 CFR § 1037.230. Similar to the proposed Heav y - dut y Engine ABT program above, vocational chassis manufacturers will be ab le to carry forward deficits from their fleet

- wide average for three ye ars before reconciling the shortfall. However, just as in the engine category , manufacturers must use credits earned once those credits have been generated to offset a shortfall before those credits can be banked or traded for additional model y ears. This restriction reduces the chance of chassis manufacturers passing forward deficits before reconciling their shortfalls and exhausting those credits before reconciling past deficits. Manufacturers of vocational vehicles that generate a deficit at the end of the model y ear, could carry

that deficit forward for three years following the model ye ar for which that deficit was generated. Deficits must be reconciled at the reporting dates for ye ar three. We will accept comments on alternative approaches of reconciling deficit shortfalls. 

### B. Class 2b/3 Heavy - duty Pickup Trucks and Vans Flexibility Provisions As explained above, EPA and NHTSA are proposing specific flexibility provisions for manufa cturers of HD pickups and vans similar to the fleet

- averaging198 of 542

program that currentl y exists for light

- duty cars and trucks. An flexibility program is important because it provides manufacturers flexibilities that assist the development and implementation of new technologies efficientl y, and therefore enables new technologies to be implemented faster than without a flexibility program. A flexibility

program also provides incentives to manufacturers if there are unexpected shifts in sales. A manufacturer’ s credit or debit balance will be determined by calculating their fleet average performance and comparing it to the manufacturer’s CO 2 and fuel consumption standards, as determined b y their fleet mix, for a given model year. A target standard is determine d for each vehicle with a unique payload, load capacity and drive configuration. These unique targets along with their associated production volumes are summed to derive the production volume

- weighted manufacturer annual fleet average standard. The attri bute basis for Class 2b/3 differs from our light

- dut y approach. The attribute basis for this flexibility will be the payload, 4

- wheel drive (4WD) and towing capacity as discussed in Section II. A manufacturer will generate credits if its vehicle achieves a fleet average CO 2 or fuel consumption level lower than its standard and will generate debits if its fleet average CO 2 or fuel consumption level is above that standard. At the end of the model year, each manufacturer will calculate a production

- weighted fleet average. If a manufacturer’s fleet achieves a fleet average CO 2 and fuel consumption level lower than its standard, it will generate credits, and if its fleet average CO 2 and fuel consumption level is above that standard, it will generate debits. Th e end

- of

- year reports will provide appropriate data to assess pre

- compliance estimates with final model year figures. Similar to Tier 2 and LD GHG programs, the agencies would address any ultimate deficits by

a possible void of certificates on a sufficient number of vehicles to address shortfall. Enforcement action would fall to penalty or other relief as appropriate or applicable. The credit calculation for the Proposed Class 2b and 3 Heav y Dut y Pickup and Van GHG and fuel consumption regulations will be generated, either positive or negative, according to Equation IV
- 1 8 and Equation IV

- 9: Equation IV - 8 The proposed class 2b - 3 Heavy Duty Pickup and Vans CO2 credit (deficit) Class 2b

- 3 HD PU and Van CO 2 credit (d eficit) (metric tons) = (Manufacturer’s Production Weighted Fleet Emission Standard

- Manufacturer’s Production Weighed Fleet Average Emission Performance) x (Sales Volume) x (UL ) x (10 - 6 ) where Std = the standard associated with the specific 2b/3 pickup an d van regulatory

class (g/ton

- mile) Manufacturers Fleet Performance = [EPA needs to clarify that performance is determined using the unique configurations within each model ty pe] Sales Volume = (projected or actual) production volume of the vehicle familyDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

199 o f 402 UL= useful life of the vehicle (xxxxx miles) 10 - 6 converts the grams of CO 2 to metric tons Equation IV - 7 Proposed Vocational Vehicle Fuel Consumption credit (deficit) in gallons = Vocational Vehicle Fuel Consumption credit for (defici t) (gallons) = (Class 2b

- 3 HD PU and Van CO 2 fleet credit s in metric tons) x (10 6 ) / (10,180) where 10,180 is the number of grams of CO 2 per gallon of diesel fuel 10 6 converts the metric tons to grams
We propose to prohibit trading between Class 2b/3 comp lete vehicles and any other category

including light

- duty

passenger cars and light trucks, engines, Class 7/8 tractors, and Class 2b

- 8 Vocational Vehicles. We propose to allow trading onl y within the Class 2b/3 complete vehicle category . This restriction is intended to promote improvements in GHG emissions and fuel consumption in all vehicle and engine categories, and to avoid shifting the burden or cost of reduction to other categories. It is expected these restrictions will maximize improvements across all regulated categories. Similar to the proposed Heav y - dut y Engine ABT program above, class 2b/3 heav y dut y pickup and van manufacturers under this flexibility program would be able to carry forward deficits from their fleet

- wide average for three years before reconciling the shortfall. Manufacturers will be required to provide a plan in their pre

- model year reports showing how they

will resolve projected credit deficits. However, just as in the engine category , manufacturers must use credits earned on ce those credits have been generated to offset a shortfall before those credits can be banked or traded for additional model ye ars. This restriction reduces the chance of vehicle manufacturers passing forward deficits before reconciling their shortfalls and exhausting those credits before reconciling past deficits. We will accept comments on alternative approaches of reconciling deficit shortfalls. 

### C. A dditional Proposed F lexibil ity Provisions In the proposed GHG program we have developed provisions to faci litate reductions in GHG emissions and fuel consumptions beginning in the 2014 model y ear. We have specifically

focused on reducing CO 2 emissions and fuel consumption. While we view our proposed ABT and flexibility structure as sufficient to encourage re duction efforts b y heav y - dut y highway engine and vehicle manufacturers, we understand that other efforts may

enhance the overall GHG reduction we anticipate achieving. Therefore we propose the following flexibilities to address additional opportunities fo r manufacturers to reduce their GHG emissions and fuel consumption. These opportunities200 of 542

will help provide additional incentives for manufacturers to innovate and to develop new strategies and cleaner technologies. (1) Early Credit Option The agencies are pr oposing that manufacturers of HD engines, combination tractors, and vocational trucks be eligible to generate earl y credits if they demonstrate improvements in excess of the standards prior to model y ear 2014 (for EPA CO 2 emission standards) or prior to mo del year 2016 (for NHTSA fuel consumption standards). Specificall y, manufacturers would need to certify their engines or vehicles to the standards at least six months before the start of the 2014 model y ear. The limitations on the use of credits in the A BT programs

– i.e., limiting averaging to within each the regulatory

category and vehicle or engine subcategory

– would appl y for the proposed earl y credits as well. We propose that manufacturers of HD pickups and vans that demonstrate improvements in ex cess of the standards [...] be eligible for early credits against their fleet average CO 2 and fuel consumption standards The agencies consider the proposed availabilit y of early credits to be a valuable complement to the overall ABT program b y encouraging ac hievement of the standards earlier than would likely otherwise occur. NHTSA and EPA request comment on whether a credit multiplier, specifically a multiplier of 1.5, would be appropriate to appl y t o earl y credits, as a greater incentive for earl y complianc e. Additionally , the agencies seek comment on whether or not a requirement that HD engines, combination tractors, and vocational trucks that are eligible to generate early

credits, be allowed to do so only if they certify prior to June 1, 2013 should a mu ltiplier of 1.5 be applied to early credits. (2) Advanced Technology Credits As discussed in earlier sections, EPA and NHTSA are proposing targeted provisions that we expect would promote the implementation of certain advanced technologies. Specifically, m anufacturers that show improvements in CO 2 emissions and fuel consumptions and incorporate the following technologies would be eligible for special credits that could be applied to an y heav y duty vehicle or engine, and not be limited to the vehicle category generating the credit:

 Hy brid powertrain designs that incorporate regeneration of the energy storage components

 Rankine Cycle engines

 Electric Vehicles (EVs) For Rankine C ycle engines, we propose that advanced technology credits be determined using the s ame HD engine test procedure used for diesel and gasoline engines. For EVs, we propose that advanced technology credits be established based on zero vehicle emissions, so that the credit would numericall y equal the standard. NHTSADraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

201 o f 402 and EPA request comment on whether a credit multiplier, specificall y a multiplier of 1.5, would be appropriate to apply to advanced technology

credits, as a greater incentive for their introduction. NHTSA and EPA request comment on the list of technologies identified as advance d technologies and whether additional technologies should be added to the list. NHTSA and EPA also request comment on whether credits generated from vehicles compl yi ng prior to 2014 and using Advanced SmartWay or Advanced SmartWay

II aerod yn amic technolog ies should be designated as Advanced Technology Credits that could be applied to any heavy dut y vehicle or engine. For vocational trucks incorporating h ybrid powertrains, we propose two methods for establishing the number of credits generated, each of whic h is discussed next: (a ) Chassis Dynamometer Evaluation For h ybrid certification to generate credits we propose to utilize chassis testing as an effective way

to compare the CO 2 emissions and fuel consumption performance of conventional and h ybrid vehicles. We are proposing that heavy

- dut y h ybrid vehicles be certified using “A to B” vehicle chassis dy namometer testing. This concept allows a hy brid vocational truck manufacturer to directly quantify the benefit associated with use of its hy brid s ys tem on an ap plication

- specific basis. The concept would entail testing the conventional vehicle, identified as “A”, using the cycles as defined in Section V. The “B” vehicle would be the hy brid version of vehicle “A”. The “B” vehicle would need to be the same exact vehicle model as the “A” vehicle. As an alternative, if no specific “A” vehicle existed for the h ybrid vehicle that is the exact vehicle model, the most similar vehicle model would need to be used for testing. We propose to define the “most similar vehi cle” as a vehicle with the same footprint, same payload, same testing capacit y, the same engine power s ys tem, the same intended service class, and the same coefficient of drag. To determine the benefit associated with the h ybrid system for greenhouse gas (GHG) performance, the weighted CO 2 emissions results from the chassis test of each vehicle would define the benefit as described below:

1. (CO 2 _A

– CO 2 _B ) / (CO 2_A ) = ______ (Improvement Factor) 2. Improvement Factor x [TEST] CO 2 Result_B = ___ (g/ton mile bene fit) Similarly , the benefit associated with the hy brid sy stem for fuel consumption would be determined from the weighted fuel consumption results from the chassis tests of each vehicle as described below:

3. (Fuel Consumption_

A

– Fuel Consumption_B )/ (Fuel Co nsumption_ A )= ______ (Improvement Factor) 4. Improvement Factor x [TEST] Fuel Consumption Result_B = ___ (gallon/ton mile benefit)202 of 542 The agencies are proposing two sets of dut y cycles to evaluate the benefit depending on the vehicle application (such as delive ry truck, bucket truck, or refuse truck) to assess h ybrid vehicle performance. The key difference between these two sets of vehicles is that one set (e.g. delivery trucks) does not operate a power take

- off (PTO) unit while the other set (e.g. bucket and r efuse applications) does. The first set of duty cycles would appl y to the hy brid powertrains used to improve the motive performance of the vehicle (such as pickup and delivery trucks) and to assess improvements associated with hy brid technology . The ty

pi cal operation of these vehicles is very similar to the overall drive cycles proposed in Section II. Therefore, the agencies are proposing to use the vocational vehicle weightings for these vehicles, as shown in Table IV
- 2 . We ar e proposing the same regulatory vocational vehicle classifications as for the ABT vocational vehicle classification. Should an OEM want to use h ybrid or innovative vehicles for other sectors, improvements associated with hy brid technology will be assessed using traditional duty cycle and test procedures for conventional vehicles. Hy brid vehicles used in applications such as utility and refuse trucks tend to have additional benefit associated with use of stored energy , which avoids main engine operation an d related CO 2 emissions and fuel consumption. To appropriately address these alternative sources for benefits, exercising the conventional and h yb rid vehicles using their PTO would help to quantify the benefit to GHG emissions and fuel consumption reducti ons. Focus on PTO is specifically for vehicles that use PTO and this adequatel y expresses the inherent function of the vehicle. The dut y c yc le proposed to quantify the h yb rid CO 2 and fuel consumption impact over this broader set of operation would be the three primary cycles plus a PTO duty

cycle. Our proposed PTO cycle is based on consideration of using alternate, appropriate duty cycles with Administrator approval in a public process. The PTO duty cycle as proposed takes into account the sales impact and population of utility trucks and refuse haulers. As described below, the agencies are proposing to add an additional PTO cycle to measure the improvement achieved for this ty

pe of hy brid powertrain application. The proposed weightings for the hy brids with PTO are included in Table IV
- 2

.

Table IV - 2 : Proposed Drive Cycle Weightings for Hybrid Vehicles Transient 55 mph 65 mph PTO Vocational Vehicles without PTO 42% 21% 37% 0% Voc ational Vehicles with PTO 30% 15% 27% 28%
(i ) Power Take Off (PTO) Cycle In most PTO equipped trucks, it is necessary to run the primary

drive engine at all times when the PTO might be needed. Ty pical PTO sy stems require no more than 19 kW at an y time, whic h is far below the optimal operation range of the primary drive engine of most trucks. Furthermore, in intermittent operations, the primary drive engine is kept running at all times in order to ensure that the PTO can operate instantaneously . This results in excess idle time. It would be possible to hy bridize or change the operation of a conventional PTO equipped truck to lower the GHG emissions in the real world.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

203 o f 402 However, there is currently no method for an engine, vehicle or equipment manufacturer to demo nstrate GHG emissions reductions due to the application of advanced PTO technology . The current and proposed test procedures do not allow for PTO operation to be included in the test protocol. The agencies are proposing to add a new optional PTO test to th e standard set of tests in order for manufacturers of advanced PTO sy stems to demonstrate in the laboratory environment GHG reductions that will be realized from their sy stems in the real world. EPA commissioned Southwest Research Institute (SwRI ) to revie w the heavy duty truck market to determine what ty pes of trucks used PTO’s and if the manufacturers thought that there was any possibility of commercial hy

brid PTO applications. In some segments, manufacturers did not think a hy brid PTO was feasible. On th e other hand, there are already utility

and refuse trucks in existence that feature hy brid PTO units. We chose to study

the behavior of conventional versions of these trucks in order to understand their t ypical operation. The agencies are proposing a labor atory test where the vehicle or vehicle powertrain, including the PTO, would be put into a laboratory environment. The PTO sy stem would then be disconnected from the vehicle apparatus that it normally powers and the h ydraulic lines would be attached to a t est rig. The vehicle or powertrain would be started and the PTO would be actuated over cycle, seen in Table IV
- 3 . During the cycle, the engine emissions would be measured. In order to determine the GHG emissions improvement, the c ertifying party would need to run a conventional version of the PTO sy stem over the cycle and then run the advanced PTO technology package over the same cycle. The difference in GHG emissions would be the improvement. EPA commissioned SwRI to design a tes t rig that will be used to run the PTO cycle. The test rig is designed to be portable, durable, and eas y to replicate. It will have two hydraulic circuits so that it can handle two stage PTO pumps t ypicall y found on refuse trucks with side load arms. In th e event a truck had a single stage PTO sy stem, the second circuit would not be used. We are proposing that the testing take place on a full y warmed up vehicle and PTO sy stem in “standard” laboratory conditions. The test cycle will be approximately

ten minutes long.204 of 542 Table IV - 3 : Proposed PTO Cycle Cycle Simulation Mode Time Normalized Pressure, Circuit 1 (%) Normalized Pressure, Circuit 2 (%) Utility 0 0 0.0 0.0 Utility 1 33 80.5 0.0 Utility 2 40 0.0 0.0 Util ity 3 145 83.5 0.0 Utility 4 289 0.0 0.0 Refuse 5 361 0.0 13.0 Refuse 6 363 0.0 38.0 Refuse 7 373 0.0 53.0 Refuse 8 384 0.0 73.0 Refuse 9 388 0.0 0.0 Refuse 10 401 0.0 13.0 Refuse 11 403 0.0 38.0 Refuse 12 413 0.0 53.0 Refuse 13 424 0.0 73.0 Ref use 14 442 11.2 0.0 Refuse 15 468 29.3 0.0 Refuse 16 473 0.0 0.0 Refuse 17 486 11.2 0.0 Refuse 18 512 29.3 0.0 Refuse 19 517 0.0 0.0 Refuse 20 530 12.8 11.1 Refuse 21 532 12.8 38.2 Refuse 22 541 12.8 53.4 Refuse 23 550 12.8 73.5 Refuse 24 553 0.0 0.0 Refuse 25 566 12.8 11.1 Refuse 26 568 12.8 38.2 Refuse 27 577 12.8 53.4 Refuse 28 586 12.8 73.5 Refuse 29 589 0.0 0.0 Refuse 30 600 0.0 0.0 (b ) Engine Dynamometer Evaluation The engine test procedure we are proposing for hybrid evaluation involves exercising the conventional engine and h ybrid

- engine s ys tem based on an engine testing strategy . The basis for the sy stem control volume, which serves to determine the valid test article, will need to be the most accurate representation of real world func tionality

.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

205 o f 402 An engine test methodology would be considered valid to the extent the test is performed on a test article that does not mischaracterize criteria pollutant performance or actual sy stem performance. Energy inputs should not be based on simulati on data which is not an accurate reflection of actual real world operation . It is clearl y important to be sure credits are generated based on known ph ys ical s ystems. This includes testing using recovered vehicle kinetic energy . Additionall y, the duty cycle over which this engine

hy brid s ys tem will be exercised must reflect the use of the application, while not promoting a proliferation of duty cycles which prevent a standardized basis for comparing h ybrid s ys tem performance. The agencies are proposing the use of the Heav y Duty Engine FTP cycle for evaluation of hy brid vehicles, which is the same test cycle proposed for engines used in vocational vehicles. For powerpack testing, which includes the engine and h ybrid s ys tems in a pre

- transmission format, the engine based testing is applicable for determination of brake

- specific emissions benefit versus the engine standard. For post

- transmission powertrain sy stems and vehicles, the comparison evaluation based on the Improvement Factor and the T.E.S.T. resul t based on a vehicle drive trace in a powertrain test cell or chassis dynamometer test cell seem to accuratel y reflect the performance improvements associated with these test configurations. It is important that introduction of clean technology be incent ivized without compromising the program intent of real world improvements in GHG and fuel consumption performance. The agencies seek comments on the most appropriate test procedures to accuratel y reflect the performance improvement associated with hybrid sy stems tested using these or other protocols. (3) Innovative Technology Credits NHTSA and EPA are proposing an optional credit opportunity intended to apply to new and innovative technologies that reduce fuel consumption and CO 2 emissions, but for which the reduction benefits are not captured over the test procedure used to determine compliance with the standards (i.e., the benefits are “off

- cycle”). Eligible innovative technologies would be those that are relatively newl y introduced in one or more vehicle models, but that are not yet implemented in widespread use in the heav y duty fleet. EPA and NHTSA would not approve credits for technologies that are not innovative or novel approaches to reducing greenhouse gas emissions and fuel consumption. Further, any credits for these off

- cycle technologies would need to be based on real

- world fuel consumption and GHG reductions that can be measured with verifiable test methods, and representing driving conditions ty pical of the vehicle application. We would not con sider technologies to be eligible for these credits if the technology

has a significant impact on CO2 emissions over the primary test cycles. Rather, we are focused for purposes of Innovative Technology credits on technologies that are not nearl y so well d eveloped and understood, and that we are not prepared to require their utilization to meet the CO2 standards. However, EPA and NHTSA are aware of some emerging and innovative technologies and concepts in various stages of development with CO2 reduction po tential that might not be adequatel y captured on the proposed certification test cycles, and we believe that some of these technologies might merit some additional CO2 and fuel consumption credit for the manufacturer. Examples206 of 542

include adaptive cruise control, electric engine battery , and active aerody namics. We believe it would be appropriate to provide an incentive to encourage the introduction of these ty pes of technologies and that a credit mechanism is an effective way to do so. This optional credit opportunity would be available through the 2018 model y ear. We are proposing that manufacturers quantify CO2 and fuel consumption reductions associated with the use of the off

- cycle technologies such that the credits could be applied based on the propose d metrics (such as g/mile and gal/100 mile for pickup trucks, g/ton

- mile and gal/1000 ton

- mile for tractors and vocational trucks, and g/bhp

- hr and gal/100 bhp

- hr for engines). EPA and NHTSA request comments whether credits generated using innovative technologies should be fungible across vehicle and engine categories or restricted to within the category where the credit was generated. Credits would have to be based on real additional reductions of CO 2 emissions and fuel consumption and would need to be qu antifiable and verifiable with a repeatable methodology . Such submissions of data should be submitted to EPA and NHTSA , and will be subject to public scrutiny . We propose that the technologies upon which the credits are based would be subject to full use ful life compliance provisions, as with other emissions controls. Unless the manufacturer can demonstrate that the technology would not be subject to in

- use deterioration over the useful life of the vehicle, the manufacturer would have to account for dete rioration in the estimation of the credits in order to ensure that the credits are based on real in

- use emissions reductions over the life of the vehicle. As discussed below, we are proposing a two

- tiered process for demonstrating the CO2 and fuel consumpt ion reductions of an innovative and novel technology with benefits not captured b y the proposed test procedures. First, a manufacturer of heav y duty pickup trucks and vans would determine whether the benefit of the technology could be captured using the 5

- cycle methodology currently used to determine light duty vehicle fuel econom y label values. EPA established the 5

- cycle test methods to better represent real

- world factors impacting fuel econom y, including higher speeds and more aggressive driving, colde r temperature operation, and the use of air conditioning. If this determination is affirmative, the manufacture would follow the protocol laid out below and in the proposed regulations. I f the heav y dut y pickup truck and van manufacturer found that the technology was such that the benefit was not adequatel y captured using the 5
- cycle approach, then the manufacturer would have to develop a robust methodology , subject to EPA and NHTSA approval, to demonstrate the benefit and determine the appropriate CO2 and fuel consumption credit. The heav y - dut y engine, combination tractor, and vocational truck manufacturers would automatically opt for the second tier process and would develop a robust methodology to demonstrate the reductions. (a ) Technology Demonstration U sing EPA 5

- Cycle Methodology for Heavy Duty Pickup Truck and Van Manufacturers As noted above, the CO2 and fuel consumption reduction benefit of some innovative technologies could be demonstrated using the 5

- cycle approach currentl y usedDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

207 o f 402 for EPA’s fuel ec onom y labeling program for light duty vehicles. The 5

- cy cle methodology

was finalized in EPA’s 2006 fuel economy labeling rule, 166 which provides a more accurate fuel economy label estimate to consumers starting with 2008 model year vehicles. In addition to the FTP and HFET test procedures, the 5

- cycle approach folds in the test results from three additional test procedures to determine fuel economy . The additional test cycles include cold temperature operation, high temperature, high humidity and solar loadi ng, and aggressive and high

- speed driving; thus these tests could be used to demonstrate the benefit of a technology that reduces CO 2 and fuel consumption over these ty pes of driving and environmental conditions. Using the test results from these additiona l test cycles collectively with the 2

- cycle data provides a more precise estimate of the average fuel consumption and CO 2 emissions of a vehicle for both the city and highway

independentl y. A significant benefit of using the 5

- cy cle methodology

to measure and quantify

the CO 2 and fuel consumption reductions is that the test cycles are properl y weighted for the expected average U.S. operation, meaning that the test results could be used without further adjustments. The use of these supplemental cycles may pr ovide a method by

which technologies not demonstrated on the baseline 2

- cycles can be quantified. The cold temperature FTP can capture new technologies that improve the CO 2 and fuel consumption performance of vehicles during colder weather operation. The se improvements may

be related to warm

- up of the engine or other operation during the colder temperature. An example of such a new, innovative technology is a waste heat capture device that provides heat to the cabin interior, enabling additional engine

- of f operation during colder weather not previously enabled due to heating and defrosting requirements. The additional engine

- off time would result in additional CO 2 and fuel consumption reductions that otherwise would not have been realized without the heat capture technology

. Certain new technologies may be able to use the high temperatures, humidity , and solar load of the SC03 test cycle to accuratel y measure their impact. An example of a new technology

may be a refrigerant storage device that accumulates pressurized refrigerant during driving operation or uses recovered vehicle kinetic energy during deceleration to pressurize the refrigerant. Much like the waste heat capture device used in cold weather, this device would also allow additional engine

- off operation while maintaining appropriate vehicle interior occupant comfort levels. Another example is glazed windows. This reflects sunlight away from the cabin so that the energy required to stabilize the cabin air to a comfortable level is decreased. Th e impact of these windows may

be measureable on an SC03 test (with and without the window option). The US06 cycle may

be used to capture innovative technologies designed to reduce CO2 emissions and fuel consumption during higher speed and more aggressive acceleration conditions, but not reflected on the 2

- cycle tests. . An example of this is an

166 Fuel Economy Labeling of Motor Vehicles: Revisions to Improve Calculation of Fuel Economy Estimates; Final Rule (7 1 FR 77872, December 27, 2006)208 of 542

active aerodynamic technology . This technology recognizes the benefits of reduced aerod ynamic drag at higher speeds and makes changes to the vehicle at those spee ds. The changes may

include active front or grill air deflection devices designed to redirect frontal airflow. Certain active suspension devices designed primaril y to reduce aerod ynamic drag b y lowering the vehicle at higher speeds may also be measured o n the US06 cycle. To properl y measure these technologies on the US06, the vehicle would require unique load coefficients with and without the technologies. The different load coefficient (properl y weighted for the US06 cycle) could effectivel y result in reduced vehicle loads at the higher speeds when the technologies are active. Similar to the previously

discussed cycles, the results from the US06 test with and without the technology

could then use the 5

- cycle methodology to quantify

CO2 reductions. If the 5

- cycle procedures can be used to demonstrate the innovative technology , then the process would be relativel y simple. The manufacturer would simply test vehicles with and without the technology installed or operating and compare results. All 5
- cycles would be tested with the technology enabled and disabled, and the test results would be used to calculate a combined city /highway CO2 and fuel consumption value with the technology

and without the technology . These values would be compared to determine the amount of the credit; the combined city /highway CO2 or fuel consumption value with the technology operating would be subtracted from the combined city /highway CO2 or fuel consumption value without the technology operating to determine the gram per mile CO2 credit or gallon per mile fuel consumption credit. It is likely that multiple tests of each of the five test procedures would need to be performed in order to achieve the necessary strong degree of statistical significance of the credit determination results. This would have to be done for each model t ype for which a credit was being sought, unless the manufacturer could demonstrate that the impact of the technology

was independent of the vehicle configuration on which it was installed. In this case, the agencies may consider allowing the test to be performed on an engine family basis or other grouping. At the end of the model year, the manufacturer would determine the number of vehicles produced subject to each credit amount and report that to the a gencies in the final model year report. The gram per mile credit value determined with the 5

- cycle comparison testing would be multiplied by the total production of vehicles subject to that value to determine the total number of credits. (b ) Alternat ive Off

- Cycle Credit Methodologies In cases where the benefit of a technological approach to reducing CO 2 emissions and fuel consumption cannot be adequately represented using existing test cycles, EPA and NHTSA would review and approve as appropriate tes t procedures and anal yt ical approaches to estimate the effectiveness of the technology for the purpose of generating credits. An alternative approach may be developed and submitted to EPA and NHSTA for approval. The demonstration program should be robust, verifiable, and capable of demonstrating the real

- world emissions benefit of the technology with strong statistical significance. The CO 2 and fuel consumption benefit of some technologies may be able to be demonstrated with a modeling approach, using eng ineering principles. The amount ofDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

209 o f 402 potential electrical power that the panel could supply could be modeled for average U.S. conditions and the units of electrical power translated to equivalent fuel energy or annualized CO 2 emission rate reduction from th e captured solar energy . The CO 2 reductions from other technologies may be more challenging to quantify , especiall y if they are interactive with the driver, geographic location, environmental condition, or other aspect related to operation on actual roads . In these cases, manufacturers might have to design extensive on

- road test programs. Any such on

- road testing programs would need to be statistically robust and based on average U.S. driving conditions, factoring in differences in geograph y, climate, an d driving behavior across the U.S. Whether the approach involves on

- road testing, modeling, or some other anal yt ical approach, the manufacturer would be required to present a proposed methodology

to EPA and NHTSA. EPA and NHTSA would approve the methodo logy and credits onl y if certain criteria were met. Baseline emissions and control emissions would need to be clearl y demonstrated over a wide range of real world driving conditions and over a sufficient number of vehicles to address issues of uncertainty with the data. Data would need to be on a vehicle model

- specific basis unless a manufacturer demonstrated model specific data was not necessary. Approval of the approach to determining a CO 2 and fuel consumption benefit would not imply approval of the r esults of the program or methodology ; when the testing, modeling, or anal ys es are complete the results would likewise be subject to EPA and NHTSA review and approval. The agencies believe that manufacturers could work together to develop testing, modelin g, or anal yt ical methods for certain technologies, similar to the SAE approach used for A/C refrigerant leakage scores. The agencies request comments on the proposed approach for off

- cycle emissions credits, including comments on how best to structure the program. EPA and NHTSA particularl y request comments on how the case

- by

- case approach to assessing off

- cycle innovative technology

credits could best be designed, including way s to ensure the verification of real

- world emissions benefits and to ensure transparency in the process of reviewing manufacturer’s proposed test methods. (4) A ir Conditioning Credit Option for Complete Pickup Truck and Van Manufacturers EPA has previously

offered GHG ABT credits for light

- duty cars and trucks recognizing both direct and indirect emissions in the air conditioning s ys tem and its operation. The A/C s ys tems in the large pickups and vans are very similar to the light

duty s ys tems for which we have offered GHG ABT programs. They share sy stems and components for A/C operation that are used in Light

- Duty cars and trucks. Class 2b/3 Li ght

- Heavy
- dut y vehicles are similar in make and payload capacit y that makes it reasonable to extend GHG ABT credits for that category. The indirect effect of A/C emissions of CO 2 and fuel cons umption resulting from increased emissions due to running the vehicle with the A/C operating are expected to be equivalent to what is generated for light

- duty vehicles; 46 g/mile (HFET) and 86 g/mile (FTP). The A/C reduction technologies currently used in light

- dut y can also be used for210 of 542

light

- heav y dut y vehicles. L ight

- dut y vehicles taking part in the light

- dut y A/C GHG ABT program experienced a 24% reduction in GHG emissions and we would expect to see a similar improvement in light

- heav y dut y vehicles. Some of the technological improvements used in the light

- dut y context and available to light

- heavy

- duty manufacturers include, but are not limited to; e fficient compressors and other components, forced recirculation, reduced reheat, and improved blower and fan controls

. We believe these direct and indirect A/C improvements will require minimal additional cost for light

- heavy

dut y manufacturers and have been shown to reduce the GHG emissions and fuel consumption from light

- duty vehicles. (5) Alternative Fuel Ve hicle Adjustment for Class 2b/3 Complete Vehicles The agencies currently do not propose a program for flex fuel vehicles (FFV) or alternative fuel vehicles. However, we are accepting comment on whether to provide a flexibility program similar to the progr am we currently offer for light

- duty FFV vehicles. ] 

## V. NHTSA

and EP A Proposed Compliance, Certification, and Enfor cement Pr ovisions A. Overview (1) Proposed Compliance Approach This section describes EPA’s and NHTSA’s proposed program to ensure compli ance with EPA’s proposed emission standards for carbon dioxide (CO 2 ), nitrous oxide (N 2 O), and methane (CH 4 ) and NHTSA’s proposed fuel consumption standards, as described in s ection II. To achieve the goals projected in this proposal, it is important for the agencies to have an effective and coordinated compliance program for our respective standards. As is the case with the L ight

- Dut y GHG and CAFE program, the proposed compliance program for heav y - dut y vehicles and engines has two central priorities. (1 ) to address the agencies’ respective statutory requirements; and (2) to streamline the compliance process for both manufacturers and the ageneies b y building on existing practice wherever possible, and b y structuring the program such that manufacturers can use a single data set to satisfy the requirements of both agencies. It is also important to consider the provisions of EPA’s existing criteria pollutant program in the development of the approach used for heav y - dut y certification and compliance. The ex isting EPA heav y - dut y highway engine emissions program has an established infrastructure and methodology

that would allow effective integration with this proposed GHG and fuel consumption program, without needing to create new unique processes in many inst ances. The compliance program would also need to address the importance of the impact of new control methods for heav y - dut y vehicles as well as other control systems and strategies that may

extend beyond the traditional purview of the criteria pollutant p rogram. The proposed heav y - dut y compliance program would use a variet y of mechanisms to conduct compliance assessments, including preproduction certificationDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

211 of 54 1 and postproduction, in

- use monitoring once vehicles enter customer service. Specificall y, the agencies are establishing a compliance program that utilizes existing EPA testing protocols and certification procedures. Under the provisions of this program, manufacturers would have significant opportunity to exercise implementation flexibility , based on the program schedule and design, as well as the credit provisions that exist in the program for conventional and h ybrid power s ystems. Today’s action also discusses a process to foster the use of innovative technologies, not yet contemplated in the current certification process. EPA would continue to conduct compliance preview meetings which provide the Agency an opportunity to review a manufacturer’s new product plans and ABT projections. Given the nature of the proposed compliance program which wo uld involve both engine and vehicle compliance for some categories, it would be necessary for manufacturers to begin pre

- certification meetings with EPA early enough to address issues of certification and compliance for both integrated and non

- integrated p roduct offerings. Based on feedback EPA received during the Light

- Duty GHG comment period, EPA would seek to ensure transparency in the compliance process. In addition to providing information in published reports annually regarding the status of cr edit balances and compliance on an industry basis, EPA and NHTSA seek comment on additional strategies for providing information useful to the public regarding industry ’s progress toward reducing GHG emissions and fuel consumption from this sector while pr otecting sensitive business information. (a ) Heavy

-Duty Pickup Trucks and Vans The proposed compliance regulations (for certification, testing, reporting, and associated compliance activities) for heav y - dut y pickup trucks and vans closely track both current practices and the recently adopted greenhouse gas regulations for light

- dut y vehicles and trucks. Thus they would be familiar to manufacturers. EPA already oversees testing, collects and processes test data, and performs calculations to determine complian ce with both CAFE and CAA standards for L ight

- Dut y. For Heavy
- Duty products that closel y parallel light

- dut y pick

- ups and vans, under a coordinated approach, the compliance mechanisms for both programs for NHTSA and EPA would be consistent and non

- duplicat ive for GHG pollutant standards and fuel consumption requirements. Vehicle emission standards established under the CAA apply throughout a vehicle’s full useful life. Under EPA existing criteria pollutant emission standard program for heav y - duty pickup trucks and vans, vehicle manufacturers certify a group of vehicles called a test group. A test group t ypically includes multiple vehicle lines and model types that share critical emissions

- related features. The manufacturer generall y selects and tests a sin gle vehicle to represent the entire test group for certification purposes. The test vehicle is the one expected to be the worst case for the emission standard at issue. Emissions from the test group are assigned as the value for the entire test group. Ho wever, the compliance program in the recent GHG regulations for light

- duty vehicles requires that manufacturers perform addition testing. This same approach would be applied to the category of heav y - duty

vehicles known as complete pickups and vans.212 of 54 1 (b ) Heavy

- duty Engines Heav y - dut y engine certification and compliance for traditional criteria pollutants has been established by

EPA since 1988. In developing a program to address GHG pollutants, it is important to build upon the infrastructure for certification and compliance that exists today , while developing additional tools to address GHG pollutants which has control strategies which extend beyond those of traditional criteria pollutants. In so doing, the Agency

is proposing to continue its current engine ba sed strategy to effect control of GHG pollutants, as well as adding new strategies to address vehicle design which impact GHG emissions. The traditional engine approach would largely match the existing gaseous pollutant control strategy . This would allow the basic tools for certification and compliance, which have already been developed and implemented, to be expanded for carbon dioxide, methane, and nitrous oxide. Engines with similar emissions control technology may be certified in engine families, as with criteria pollutants. The proposed approach for certification would follow the current process which would require manufacturer submission of certification applications, approval of the application, and receipt of the certificate of conformity prior to introduction into commerce of an y engines. EPA proposes the certificate of conformit y be a single document that would be applicable for both criteria pollutants and greenhouse gas pollutants. (c) Class 7/8 Combination Tractors and Class 2b

- 8 Vocational Vehicles Currently , EPA does not directly regulate exhaust emissions from most heavy

duty vehicles. Instead, a compliance assessment of the engine is undertaken as described above. Vehicle manufacturers installing certified engines are required to do so in a manner that maintains all functionality of the emission control sy stem. While no process exists for certifying heavy

- dut y vehicles other than light

- heav y dut y pickups and vans, a process similar to the one used for heav y - dut y engines can be applied to the vehicles. We are proposing a standard certification program for heav y - duty vehicles. Manufacturers would divide their vehicles into families and submit an application for certification for each family . However, the demonstration of compliance would not require emission testing, but would instead involve a computer simulation model, [TEST]. This modeling tool uses a combination of manufacturer

- specified and EPA

provided vehicle parameters to develop a vehicle model. This model is then exercised over certain drive cycles. With today ’s action, EPA is proposing the dut y cycles over which Class 7 and 8 combination tractors will be exercised to are: 65 mile per hour steady state cruise cycle, the 55 mile per hour steady state cruise cycle, and the ARB transient cycle. Additional details regarding these duty cycles will be addressed in section D(1)(b) of this chapter. Over each dut y c ycle, the simulation tool will return the expected CO 2 emissions, in g/ton

- mile and gal/1000 ton

- mile, which can then be compared to the emission standard.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

213 of 54 1 

### B. Heavy - duty Pickup Trucks and Vans (1) Proposed Compliance Approach EPA and NHTSA are proposing new emission standards to control greenhouse gases (GHGs) from heavy

- dut y trucks between a 8,500 and 14,000 gross vehicle weight rati ng that are not already covered under the light

- duty truck and medium duty

passenger vehicle GHG standards already set forth in the “Light

- Dut y Vehicle Greenhouse Has Emissions Standards and Corporate Average Fuel Economy Standard; Final Rule” as published in the Federal Register on Friday May 7, 2010 . In this section “trucks” now refers to heav y - dut y pickup trucks and vans between 8,500 and 14,000 pounds not alread y covered under the above light

- dut y rule. First, EPA is proposing fleet average emission standards for carbon dioxide ( CO 2 ) on a gram per mile (g/mile) basis and NHTSA is proposing fuel consumption standards on a gallon per mile (gal/mile) basis that would apply separatel y to a manufacturer’s fleet of trucks from both the manufacturer’s fleet of light

- dut y vehicles and heavy

- duty vehicles with a GVWR above 14,000 pounds. CO 2 is the primary pollutant resulting from the combustion of vehicular fuels , and the amount of CO 2 emitted is highl y correlated to the amount of fuel consumed. EPA and NHTS A are providing auto manufacturers with the opportunity to earn credits toward the fleet

- wide average CO 2 and fuel consumption standards for improvements to air conditioning s ys tem efficiency that reduce the load on the engine and thereb y reduce CO 2 emissi ons and fuel consumption. Separatel y, EPA is setting standards to control the leakage of HFCs from air conditioning sy stems. In addition, the EPA is proposing separate emissions standards for two other GHG pollutants: methane (CH 4 ) and nitrous oxide (N 2 0 )

. CH 4 and N 2 O emissions relate closely to the design and efficient use of emission control hardware (i.e., cataly tic converter s ). The standards for CH 4 and N 2 O would be set as a cap that would limit emissions increases and prevent backsliding from curre nt emission levels. Previously , complete vehicles with a Gross Vehicle Weight Rating of 8,500

- 14,000 pounds could be certified according to 40 CFR part 86, section S. These heav y duty chassis certified vehicles were required to pass emissions on both th e FTP and HFET, also known as the Federal Test Procedure and the Highway Fuel Economy

Test, for most 50 state certificates of compliance 167 . These proposed rules would use the same testing procedures already required for certification, namely the FTP and the HFET. Using the data from these two tests, the EPA could apply attribute based standards for CO 2 emissions. The attribute upon which the CO 2 standard would be based will be a function of vehicle payload, vehicle towing capacity and two

- wheel vs four

- wheel drive configuration as discussed in chapter 2 C (1)(c) of this notice. This attribute based standard would be a manufacturer fleet standard and would be subject to an average banking and trading scheme similar to the light

- duty GHG rule. This propo sal would require nearl y all heavy

- duty trucks between 8,500 and 14,000 gross vehicle weight rating that are not already covered under the light

- duty truck and medium duty

passenger

167 50

- state as opposed to ???? California? 49

- state?214 of 54 1

vehicle GHG standards be tested on a chassis dy namometer. This requirement would apply based on whether the vehicle manufacturer sold the vehicle as a complete or nearl y complete vehicle. 168 Manufacturers would be allowed to exclude vehicles they sell to secondary manufacturers without cabs (often known as rolling chassis), as w ell as a very small number of vehicles sold with cabs. Specifically , a manufacturer could engine certify up to two percent of its vehicles with complete cabs, or up to 2,000 vehicles if its total sales in this category was less than 100,000.To the extent manufacturers are allowed to engine certify

for criteria pollutant (non GHG) requirements today , they would also be allowed to do so under the proposed regulations. (a ) Certification Process CAA section 203(a)(1) prohibits manufacturers from introducing a new motor vehicle into commerce unless the vehicle is covered by an EPA

- issued certificate of conformity . Section 206(a)(1) of the CAA describe s the requirements for EPA issuance of a certificate of conformity , based on a demonstration of compliance with the emission stan dards established b y EPA under s ection 202 of the Act. The c ertification demonstration requires emission testing , and must be done for each model year. 169 Under Tier 2 heavy

dut y chassis certification and other EPA emission standard programs , vehicle manufacturers certify a group of vehicles called a test group. A test group ty pically includes multiple vehicle car lines and model ty pes that share critical emissions

- related features. 170 Th e manufacturer generall y selects and tests one vehicle t o represent the entire test group for certification purposes. The test vehicle is the one expected to be the worst case for the emission standard at issue. EPA requires the manufacturer to make a good faith demonstration in the certification application that vehicles in the test group will both 1) comply throughout their useful life with in the e missions bin assigned, and 2) contribute to fleetwide compliance with the applicable emissions standards when the ye ar is over. EPA issues a certificate for the vehicles included in the test group based on this demonstration, and include s a condition in the certificate that if the manufacturer does not comply with the fleet average , then production vehicles from that test group will be treated as not covered by th e certificate to the extent needed to bring the manufacturer’s fleet average into compliance with the applicable standards

. Th e certification process often occurs sev eral months prior to production and manufacturer testing may occur months before the cer tificate is issued. The certification process for the Tier 2 heavy dut y chassis program is an efficient way for manufacturers to conduct the needed testing well in advance of certification, and to receive the needed

168 The proposed regulations would use the term “cab

- com plete vehicle” to refer to incomplete vehicles sold with complete cabs, but lacking a cargo carrying container. 169 CAA section 206(a)(1). 170 The specific test group criteria are described in 40 CFR § 86.1827

- 01, car lines and model types have the meaning given in 40 CFR § 86.1803

- 01.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

215 of 54 1 certificates in a time frame which allo w s for the orderl y production of vehicles. The use of condi tions on the certificate has been an effective way to ensure that manufacturers comply throughout their useful life and meet fleet standards

. EPA has also adopted this approach as part of its LD GHG compliance program. EPA is proposing to similarly condition each certificate of conformit y for the GHG program upon a manufacturer's good faith demonstration of compliance with the manufacturer’s fleetwide average CO 2 standard. The following discussio n explains how EPA proposes to integrate the proposed vehicle certification program into the existing certification program. (b ) Certification Test Groups and Test Vehicle Selection For heav y dut y chassis certification to the criteria emission standards, manuf acturers currentl y as mentioned above divide their fleet into "test groups" for certification purposes. The test group is EPA's unit of certification; one certificate is issued per test group. These groupings cover vehicles with similar emission control sy stem designs expected to have similar emissions performance. 171 The factors considered for determining test groups include Gross Vehicle Weight, combustion cycle, engine ty pe, engine displacement, number of cylinders and cylinder arrangement, fuel ty pe, f uel metering s ys tem, catal ys t construction and precious metal composition, among others. Vehicles having these features in common are generally placed in the same test group. 172 EPA is pr oposing to retain the current test group structure for 2b and 3 chas sis certified trucks in the certification requirements for CO 2 . At the time of certification, manufacturers would use the CO 2 emission level from the Emission Data Vehicle as a surrogate to represent all of the models in the test group. However, followin g certification further testing would generally be allowed for compliance with the fleet average CO 2 standard as described below. EPA's issuance of a certificate would be conditioned upon the manufacturer's subsequent model level testing and attainment of the actual fleet average. Under the current Tier 2 program, complete heav y duty Otto

- cycle vehicles under 14000 pounds Gross Vehicle Weight Rating are required to chassis certify

. 173 The current Tier 2 program allows complete heav y dut y diesel vehicles un der 140000 pounds GVWR to optionally chassis certify

. 174 These proposed rules will now require all HD vehicles under 14000 pounds GVWR to chassis certify except as noted in section xx. EPA recognizes that the Tier 2 heav y dut y chassis test group criteria d o not necessarily

relate to CO 2 emission levels. For instance, while some of the criteria, such

171 40 CFR § 86.1827

- 01. 172 EPA provides for other groupings in certain circumstances, and c an establish its own test groups in cases where the criteria do not apply. 40 CFR § 86.1827

- 01(b), (c) and (d). 173 40 CFR § 86.1801

- 01(a) 174 40 CFR § 86.1863

- 07(a)216 of 54 1

as combustion cycle, engine ty pe and displacement, and fuel metering, may have a relationship to CO 2 emissions, others, such as those pertaining to the catalys t, may not. In fact, there are man y vehicle design factors that impact CO 2 generation and emission but are not major factors includ ed in EPA's test group criteria. 175 Most important among these may

be vehicle weight, horsepower, aerod yn amics, vehicle size, and performance features. To remed y this, EPA is considering allowing manufacturers provisions similar to the LD GHG rule that would yield more accurate CO 2 estimates than only using the test group emission data vehicle CO 2 emissions. EPA believes that the current test group concept is appropriate for N 2 0 and CH 4 because the technologies that would be employed to control N 2 O and CH 4 emissions would generall y be the same as those used to co ntrol the criteria pollutants. As just discussed, the “worst case ” vehicle a manufacturer selects as the Emissions Data Vehicle to represent a test group under Tier 2 (40 CFR § 86.1828

- 01) may not have the highest levels of CO 2 in that group. For instance, there may be a heavier, more powerful configuration that would have higher CO 2 , but may , due to the way the catal yt ic converter has been matched to the engine, actually have lower NO X , CO, PM or HC. Therefore, EPA is proposing to require a single Emission Data Vehicle that would represent the test group for both Tier 2 heavy dut y chassis and CO 2 certification. The manufacturer would be allowed to initially apply the Emission Data Vehicle’s CO 2 emissions value to all models in the test group, even if other models in the test group are expected to have higher CO 2 emissi ons. However, as a condition of the certificate, this surrogate CO 2 emissions value would generall y be replaced with actual, model

- level CO 2 values based on results from CAFE testing that occurs later in the model ye ar or through the use of ADFEs. This mod el level data would become the official certification test results (as per the conditioned certificate) and would be used to determine compliance with the fleet average. Only if the test vehicle is in fact the worst case CO 2 vehicle for the test group cou ld the manufacturer elect to appl y the Emission Data Vehicle emission levels to all models in the test group for purposes of calculating fleet average emissions. Manufacturers would be unlikely to make this choice, because doing so would ignore the emissio ns performance of vehicle models in their fleet with lower CO 2 emissions and would unnecessarily inflate their CO 2 fleet average. Testing at the model level would necessaril y increase testing burden beyond the minimum Emission Data Vehicle testing. EPA requests comment regarding whether the Tier 2 heav y dut y chassis test group can adequatel y represent CO 2 emissions for certification purposes, and whether the Emission Data Vehicle's CO 2 emission level is an appropriate surrogate for all vehicles in a tes t group at the time of certification, given that the certificate would be conditioned upon additional model level testing occurring during the ye ar and that the surrogate CO 2 emission values would be replaced with model

- level emissions data from those tes ts.

175 EPA noted this potential lack of connection between fuel economy testing and testing for emissions standard purposes when it first adopted fuel economy test procedures. See 41 FR at 38677 (Sept. 10, 1976).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

217 of 54 1 Comments should also address EPA's desire to minimize the up

- front pre

- production testing burden and whether the proposed efficiencies would be balanced b y the requirement to test all model ty pes in the fleet by

the conclusion of the model y ear in ord er to establish the fleet average CO 2 levels. There are two standards that the manufacturer would be subject to, the fleet average standard and the in

- use standard for the useful life of the vehicle. Compliance with the fleet average standard is based o n production weighted averaging of the test data that applies for each model, For each model, the in

- use standard is set at 10% higher than the level used for that model in calculating the fleet average. The certificate covers both of these standards, an d the manufacturer has to demonstrate compliance with both of these standards for purposes of receiving a certificate of conformity . The certification process for the in

- use standard is discussed above. (c) Pre

- Model Year (or Compliance Plan) Reporting EPA and NHTSA are proposing that manufacturers submit a compliance plan for their entire fleet no later than two months prior to the certification of any test group in a given model ye ar. Preferably , this compliance plan would be submitted at the manufacturer ’s annual certification preview meeting, This preview meeting is t ypicall y held before the earliest date that the model year can begin. The earliest a model year can begin is January

2 nd of the calendar ye ar prior to the model year. This plan would incl ude the manufacturer's estimate of its attribute

- based standard, along with a demonstration of compliance with the standard based on projected model

- level CO 2 emissions and fuel consumption, and production estimates. This information would be similar to the information submitted to NHTSA and EPA in the pre

- model year report required for CAFE compliance for light duty vehicles. Included in the compliance plan, manufacturers seeking to take advantage of air conditioning or other credit flexibilities would i nclude these in their compliance demonstration. Similarly , the compliance demonstration would need to include a credible plan for addressing deficits accrued in prior model years. EPA and NHTSA would review the compliance plan for technical viability and conduct a certification preview discussion with the manufacturer. The agencies would view the compliance plan as part of the manufacturer's good faith demonstration, but understands that initial projections can vary considerably

from the reality of final production and emission results. In addition, the compliance plan must be approved b y the EPA Administrator prior to any certificate of compliance being issued. The agencies request comment on the proposal to evaluate manufacturer compliance plans prior to the beginning of model y ear certification. (d ) Demonstrating compliance with the proposed standards (i ) CO2 and Fuel Consumption Fleet Standards As noted, attribute

- based CO 2 standards result in each manufacturer having a fleet average CO 2 standard unique to its heav y - duty truck fleet of GVWR 8500

- 14000 pounds and that standard would be separate from the stand ard for passenger cars, light

trucks , and other heav y - duty trucks. The standards depend on th ose attributes corresponding to the relative capability , o r “work factor”, of the vehicle models produced218 of 54 1

by that manufacturer. The proposed attributes used to determine the stringency of the CO 2 standard are payload and towing capacity as described in chapter 2 C of this notice. Generally , fleets with a mix of vehicles with increased payloads or greater towing capacity (or utilizing four wheel drive configurations ) would face numerically less stringent standards (i.e., higher CO 2 grams/mile standards) than fleets consisting of less powerful vehicles. (However, the standards would be expected to equall y challenging and achieve similar percent reductions.) Although a manufacturer’s fleet average standard could be estimated throughout the model year based on projected production volume of its vehicle fleet, the f inal compliance values would be based on the final model ye ar production figures. A manufacturer’s calculation of fleet average emissions at the end of the model ye ar would be based on the production

- weighted average emissions of each model in its fleet. The payload and towing capacity inputs used to determine manufacturer compliance with these proposed rules would be the advertised values. The agencies propose to use the same general vehicle category definitions that are used in the current EPA HD chassi s certification. 176 The new vehicle category definitions differ slightly

from the EPA definitions for Heavy

- duty Vehicle definitions for the Tier 2 program, as well as other EPA vehicle programs. Mainly , manufactures would be able to test, and possibly

mod el, more configurations of vehicles that were historically in a given test group. Tier 2 requires the worst case configuration be tested for emissions certification. For HD chassis certification, this usually meant only

testing the vehicle with the highe st ALVW, roadload, and engine displacement within a given test group. This worst case configuration may onl y represent a small fraction of the test group production volume. By

testing the worst case, albeit possibly small volume, vehicle configuration, the EPA had a reasonable expectation that all represented vehicles would pass the given emissions standards. Since CO 2 standards are a fleet standard based on volume and payload , it may be in a manufacturer’s best interest to test multiple configurations within a given test group. The agencies are requesting comment on allowing the manufacturer to test as many configurations within a test group as the manufacturer requires in order to best represent the volumes of each configuration within that said test group. The agencies are proposing the use of Anal yt ically Derived Fuel Econom y similar to the ADFE provisions allowed for light dut y with 40 CFR § 600.006

- 89 (e). This provision would allow EPA and NNTSA to accept analy tical expressions to generate CO 2 and fuel economy

that have been approved in advance by the agencies. F or model ye ars 201 4 through 201 7 , or earlier if early credits are sought, EPA is proposing the equation and parameter values below for assigning a CO 2 level to an individual vehicle’s relevant attributes

. These CO 2 values would be production weighted to determine each manufacturer’s fleet average. Each parameter would change on an annual basis, resulting in the annual increase in stringency

. For the function used to describe the prop osed standard, see section II C of this notice

176 40 CFR § 86.1816

- 05Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

219 of 54 1 (ii) CO2 In

- Use Standards Section 20 2(a)(1) of the CAA requires emission standards to appl y to vehicles throughout their statutory useful life , see Section II.B. The useful life requirement for this proposal is 10 years or 120,000 miles. Currently , EPA regulations require manufacturers to conduct in

- use testing as a condition of certification for heav y - dut y trucks between a 8,500 and 14,000 gross vehicle weight tht are chassis certified. The vehicles are tested to determine the in

- use levels of criteria pollutants when they are in their first and third years of service. This testing is referred to as the In

- Use Verification Program ( IU VP ) testing, which was first implemented as part of EPA’s CAP 2000 certificat ion program. 177 EPA is requesting comment on applying the same In
- Use program already set forth in the “Light

- Dut y Vehicle Greenhouse Has Emissions Standards and Corporate Average Fuel Econom y Standard; Final Rule” as published in the Federal Register on Friday May 7, 2010 to Heavy

Dut y Pick Ups and Vans

. The In

- Use Verification Program for Heav y Dut y Pick Ups and Vans would follow the same general provisions of the light duty program in regard to testing, vehicle selection, and reporting.

(e) Cab

- Chassis Ve hicles and Complete Class 4 Vehicles As discussed in Section I.C(2)(a), we are proposing to include most cab

- chassis Class 2b/3 vehicles in the complete Class 2b/3 program. Because their numbers are relativel y small, and to reduce the testing and complian ce tracking burden to manufacturers, we would treat these vehicles as equivalent to the complete van or truck product they

are derived from. The manufacturer would determine which complete vehicle configuration it produces most closel y matches the cab

- cha ssis product leaving its facility , and would include each of these cab

- chassis vehicles in the fleet averaging calculations as though it were identical to the corresponding complete vehicle. Any in

- use testing of these vehicles would do likewise, with load ing of the tested vehicle to a total weight equal to the ALVW of the corresponding complete vehicle configuration. If the secondary manufacturer had altered or replaced an y vehicle components in a way

that would substantially

affect CO 2 emissions from the tested vehicle, the OEM could request that EPA not test the vehicle or invalidate a test result. Secondary

(finisher) manufacturers would not be subject to requirements under this provision, other than to comply with anti

- tampering regulations. However, if they modify vehicle components in such a way that GHG emissions and fuel consumption are

177 64 FR 23906, May 4, 1999

.220 of 54 1

substantially

affected, they

become manufacturers subject to the standards under this proposal. We realize that this approach does not capture the likely loss of a erody

namic efficiency involved in converting these vehicles from standard pickup trucks or vans to ambulances and the like, and thus it could assign them lower GHG emissions and fuel consumption than they

deserve. However, we feel that this approach strik es a fair balance between the alternatives

—grouping these vehicles with vocational trucks subject only to engine standards and tire requirements, or creating a complex and burdensome program that forces OEMs to track, and perhaps control, a plethora of veh icle configurations they

currently do not manage. We request comment on this proposed provision and an y suggestions for way s to improve it. (2) Proposed Labeling Provisions Vehicles in the 2B & 3 categories currentl y have vehicle emission control information labels (VECI) showing compliance with criteria pollutant standards, similar to ECI s for engines. As with engines, we believe this label is sufficient, assuming minor modifications may

be needed for CO 2 FELs if ABT is used. (3) Other Certification Issues (a ) Carryo ver/Carry Across Certification Test Data EPA’s proposed certification program for vehicles allows manufacturers to carry certification test data over and across certification testing from one model year to the next, when no significant changes to models ar e made. EPA will also appl y this policy to CO 2 , N 2 O and CH 4 certification test data. (b ) Compliance Fees The CAA allows EPA to collect fees to cover the costs of issuing certificates of conformity

for the classes of vehicles and engines covered by this propos al. On May

11, 2004, EPA updated its fees regulation based on a study of the costs associated with its motor vehicle and engine compliance program (69 FR 51402). At the time that cost study was conducted the current rulemaking was not considered. At this time the extent of any added costs to EPA as a result of this proposal is not known. EPA will assess its compliance testing and other activities associated with the rule and may

amend its fees regulations in the future to include an y warranted new costs. 

### C. H eavy - Duty Engines (1) Proposed Compliance Approach Section 203 of the Clean Air Act requires that all motor vehicles and engines sold in the United States to carry a certificate of conformity issued by the US EPA. For heav y - dut y engines, this certifies that the engine meets all requirements as set forth in theDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

221 of 54 1 regulations (40 CFR Part 86, Subpart N, for criteria pollutants) including the requirement that the engine be compliant with emission standards. This demonstration is completed through emission testing as well as durability testing to determine the level of deterioration throughout the useful life of the engine. In addition to compliance with emission standards, manufacturers are also required to warrant their products against emission defects, and demon strate that a service network is in place to correct an y such conditions. The engine manufacturer also bears responsibility in the event that an emission

- related recall is necessary . Finally , the engine manufacturer is responsible for tracking and ensuri ng correct installation of an y emission related components installed by a second part y (i.e. vehicle manufacturer). We believe this compliance structure is also valid for administering these proposed GHG regulations for heav y - duty engines. (a ) Certification Process In order to obtain a certificate of conformity , engine manufacturers must complete a compliance demonstration, normally consisting of test data from relatively new (low

hour) engines as well as supporting documentation, showing that their product mee ts emission standards and other requirements in the CFR. To account for aging effects, low

- hour test results are coupled with testing

- based deterioration factors (DFs), which provide a ratio (or offset) of end

- of

- life emissions to low

- hour emissions for e ach pollutant being measured. These factors are then applied to all subsequent low

- hour test data points to predict the emissions behavior at the end of the useful life. For purposes of this compliance demonstration and certification, engines with simil ar engine hardware and emission characteristics throughout their useful life may be grouped together in engine families, consistent with current criteria

- pollutant certification procedures. Examples of such characteristics are the combustion cycle, aspiration method, and aftertreatment sy stem. Under this system, the worst

- case engine (“parent rating”) is selected based on having the highest fuel feed per engine stroke, and all emissions testing is completed on this model. All other models within the fami ly (“child ratings”) are expected to have emissions at or below the parent model and therefore in compliance with emission standards. An y engine within the family can be subject to selective enforcement audits (SEAs), in

- use, confirmatory , or other compli ance testing. We are proposing to continue to use this approach for the selection of the worst

case engine (“parent rating”) for fuel consumption and GHG emissions as well. We believe this is appropriate because this worst case engine configuration would be expected to have the highest in

- use fuel consumption and GHG emissions within the family . We note that lower engine ratings contained within this family would be expected to have a higher fuel consumption rate when measured over the Federal Test Proced ures and expressed in terms of fuel consumption per brake horsepower hour. This higher fuel consumption rate is misleading in the context of comparing engines within a single engine famil y. This seeming contradiction can be most easil y understood in term s of an example. For a t yp ical engine family a top rating could be 500 horsepower with a number of lower engine ratings down to 400 horsepower or lower included within the family . When installed in identical trucks the 400 and 500 horsepower engines woul d be expected to operate identically when the demanded power from the engines is 400222 of 54 1

horsepower or less. So in the case where in

- use driving never included acceleration rates leading to horsepower demand greater than 400 horsepower, the two trucks with th e 400 and 500 horsepower engines would give identical fuel consumption and GHG performance. When the desired vehicle acceleration rates were high enough to require more than 400 horsepower, the 500 horsepower truck would accelerate faster than the 400 hor sepower truck resulting in higher average speeds and higher fuel consumption and GHG emissions measured on a per mile or per ton

- mile basis. Hence, the higher rated engine famil y would be expected to have the highest in

- use fuel consumption and CO 2 emissi ons. The reason that the lower engine ratings appear to have worse fuel consumption relates to our use of a brake specific work metric. The brake specific metric measures power produced from the engine and delivered to the vehicle ignoring the parasitic work internal to the engine to overcome friction and air pumping work within the engine. The fuel consumed and GHG emissions produced to overcome this internal work and to produce useful (brake) work are both measured in the test cycle but onl y the brake work is reflected in the calculation of the fuel consumption rate. This is desirable in the context of reducing fuel consumption as this approach rewards engine designs that minimize this internal work through better engine designs. The less work that i s needed internal to the engine, the lower the fuel consumption will be. If we included the parasitic work in the calculation of the rate, we would provide no incentive to reduce internal friction and pumping losses. However, when comparing two engines w ithin the very same family

with identical internal work characteristics, this approach gives a misleading comparison between two engines as described above. This is the case because both engines have an identical fuel consumption rate to overcome internal work but different rates of brake work with the higher horsepower rating having more brake work because the test cycle is normalized to 100 percent of the engine’s rated power. The fuel consumed for internal work can be thought of as a fixed offset ident ical between both engines. When this fixed offset is added to the fuel consumed for useful (brake) work over the cycle, it increases the overall fuel consumption (the numerator in the rate) without adding an y work to the denominator. This fixed offset id entical between the two engines has a bigger impact on the lower engine rating. In the extreme this can be seen easily . As the engine ratings decrease and approach zero, the brake work approaches zero and the calculated brake specific fuel consumption ap proaches infinity . For these reasons, we are proposing that the same selection criteria, as outlined in 40 CFR Part 86, Subpart N, be used to define a single engine family designation for both criteria pollutant and GHG emissions. Further, we are proposin g that for fuel consumption and CO 2 emissions only any

selective enforcement audits (SEAs), in

- use, confirmatory , or other compliance testing will be limited to the parent rating for the famil y. This approach is being contemplated for administrative conven ience at this time and we seek comments on alternatives to address compliance testing. Consistent with the current regulations, manufacturers may

electively

subdivide a grouping of engines which would otherwise meet the criteria for a single family if the y have evidence that the emissions are different over the useful life. The Agency

utilizes a 12

- digit naming convention for all mobile

- source engine families (and test groups for vehicles). This convention is also shared by the CaliforniaDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

223 of 54 1 Air Resources Board which allows manufacturers to potentially use a single family

name for both EPA and CARB certification. Of the 12 digits, 9 are EPA

- defined and provide identifying characteristics of the engine family . The first digit represents the model y ear, thro ugh use of a predefined code. For example, “A” corresponds to the 2010 model y ear and “B” corresponds to the 2011 model year. The 5 th position corresponds to the industry sector code, which includes such examples as light

- duty vehicle (V) and heavy

- dut y d iesel engines (H). The next three digits are a unique alphanumeric code assigned to each manufacturer b y EPA. The next four digits describe the displacement of the engine; the units of which are dependent on the industry segment and a decimal may be used when the displacement is in liters. For engine families with multiple displacements, the largest displacement is used for the family name. For on
- highway

vehicles and engines, the tenth character is reserved for use b y CARB. The final characters (includi ng the 10 th character in absence of CARB guidance) left to the manufacturer to determine, such that the family

name forms a unique identifying characteristic of the engine family

. This convention is well understood by the regulated industries, provides suf ficient detail, and is flexible enough to be used across a wide spectrum of vehicle and engine categories. In addition, the current harmonization with other regulatory bodies reduces complications for affected manufacturers. For these reasons, we are not proposing an y major changes to this naming convention for this proposal. There may be additional categories defined for the 5 th character to address heav y - dut y vehicle test groups, however that will be discussed later. As with criteria pollutant standards , the heavy

- duty diesel regulatory

category is subdivided into three regulatory subcategories, depending on the GVW of the vehicle in which the engine will be used. These regulatory subcategories are defined as light

heav y - dut y diesel (LHDD), medium heav y - dut y diesel (MHDD), and heavy heavy

- dut y diesel (HHDD). All heavy

- dut y gasoline engines (HDG) are grouped into a single subcategory . Each of these regulatory subcategories are expected to be in service for varying amounts of time, so they each carry

diffe rent regulatory

useful lives. For this reason, expectations for demonstrating useful life compliance differ b y subcategory, particularl y as related to deterioration factors. Li ght heav y - dut y diesel engines (and all gasoline heav y - dut y engines) have the same regulatory

useful life as a light

- dut y vehicle (110,000 miles), which is significantl y shorter than the other heavy

- dut y regulatory subcategories. Therefore, we believe it is appropriate to maintain commonality with the light

- duty

GHG rule. During the light

duty GHG rulemaking, the conclusion was reached that no significant deterioration would occur over the useful life. Therefore, EPA is proposing to specify that manufacturers would use assigned DFs for CO 2 and the values would be zero (for additive DF s) and one (for multiplicative DFs). EPA is interested in data that addresses this issue. For the medium heav y - duty and heav y heav y - duty

diesel engine segments, the regulatory

useful lives are significantly longer (185,000 and 435,000 miles, respectivel y)

. For this reason, the Agency is not convinced that engine/aftertreatment wear will not have a negative impact on GHG emissions. To address useful life compliance for MHDD224 of 54 1

and HHDD engines certified to GHG standards, we believe the criteria pollutant appr oach for developing DFs is appropriate. Using CO 2 as an example, many of the engine deterioration concerns previousl y identified will affect CO 2 emissions. Reduced compression, as a result of wear, will cause higher fuel consumption and increase CO 2 produc tion. In addition, as aftertreatment devices (ATDs) age (primarily particulate traps), regeneration events may become more frequent and take longer to complete. Since regeneration commonl y requires an increase in fuel rate, CO 2 emissions would likely incr ease as well. Finally , any changes in EGR levels will affect heat release rates, peak combustion temperatures, and completeness of combustion. Since these factors could reasonabl y be expected to change fuel consumption, CO 2 emissions would be expected to change accordingl y. HHDD engines may

also require some degree of aftertreatment maintenance throughout their useful life. For example, one major heav y - dut y engine manufacturer specifies that their diesel particulate filters be removed and cleaned at int ervals between 200,000 and 400,000 miles, depending on the severity of service. Another major engine manufacturer requires DPF service at 300,000 miles. This maintenance or lack thereof if service is neglected, could have serious negative implications to C O 2 emissions. In addition, there may

be emissions

- related warranty implications for manufacturers to ensure that if rebuilding or specific emissions related maintenance is necessary , it will occur at the prescribed intervals. Therefore, it is impetrative that manufacturers are detailed in their maintenance instructions. The Agency currentl y seeks public comment on how to properl y address this issue. Lean
- NO X aftertreatment devices may also facilitate GHG reductions by allowing engines to run with higher engine

- out NO X levels in exchange for more efficient calibrations. In most cases, these aftertreatment devices require a consumable reductant, such as diesel exhaust fluid (DEF), which requires periodic maintenance b y the vehicle operator. Without such m aintenance, the emission control sy stem may be compromised and compliance with emission standards may be jeopardized. Such maintenance is considered to be critical emission related maintenance and manufacturers must therefore demonstrate that it is likely to be completed at the required intervals. One example of such a demonstration are engine power derate strategies that will limit engine power or vehicle speed in absence of this required maintenance. If the manufacturer determines that maintenance is ne cessary on critical emission

related components within the useful life period, they must have a reasonable basis for ensuring that this maintenance will be completed as scheduled. This includes any adjustment, cleaning, repair, or replacement of critical e mission

- related components. Ty pically , the Agency

has only allowed manufacturers to schedule such maintenance if the manufacturer can demonstrate that the maintenance is reasonabl y likely to be done at the recommended intervals. This demonstration may be in the form of survey data showing at least 80% of in

- use engines get the prescribed maintenance at the correct intervals. Another possibility is to provide the maintenance free of charge. We see no reason to depart from this approach for GHG

- related crit ical emission

- related components; however the Agency welcomes commentary

on this approach.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

225 of 54 1 (b ) Demonstrating compliance with the proposed standards (i ) CO2 Standards As mentioned previously, demonstrating compliance over the useful life generall y consists of low

- h our testing over specified duty cy cles. Deterioration factors (DFs) are applied to these low

- hour tests to project end

- of

- life emission levels. These final adjusted test results form the basis for the Famil y Certification Limit (FCL), which the manufacturer must specify to be at or above the certification test results. This FCLbecomes the emission standard for the famil y and an y certification or confirmatory

testing must show compliance with this limit. In addition, manufactures may choose an FCL at any level above their certification test results to provide a larger compliance margin. If subsequent certification or confirmatory testing reveals emissions above the FCL , the new, higher result becomes the FCL. The FCL is also used to determine the Famil y Emissions L imit (FEL), which serves as the emission limit for any subsequent field testing conducted after the time of certification. This would primarily include selective enforcement audits (SEAs), but also may include in

- use testing and/or production line testing for GHGs. The FELdiffers from the FCL in that it includes an EPA

- defined compliance margin; currently proposed to be 2%. Under this scenario the FEL will always be 2% higher than the FCL . If field testing activities reveal emission levels to be above this FEL, then the new test result becomes the FCLfor the family , similar to certification testing. Engine Emission Testing Under current non

- GHG engine emissions regulations, manufacturers are required to demonstrate compliance using two tes t methods: the heav y - dut y transient cycle and the heav y - dut y stead y state test. Each test is an engine speed versus engine torque schedule intended to be run on an engine dynamometer. Over each test, emissions are sampled using the equipment and procedure s outlined in 40 CFR Part 1065, which includes provisions for measuring CO 2 , N 2 O, and CH 4 . Emissions may be sampled continuously or in a batch configuration (commonly known as “bag sampling”) and the total mass of emissions over each cycle are normalized b y the engine power required to complete the cycle. Following each test, a validation check is made comparing actual engine speed and torque over the cycle to the commanded values. If these values do not align well, the test is deemed invalid. The transient test, also known as the Federal Test Procedure (FTP), is characteristic of t ypical urban stop

- and

- go driving. Also included is a period of more steady state operation that would be ty pical of short cruise intervals at 45 to 55 miles per hour. Each trans ient test consists of two 20 minute tests separated b y a “soak” period of 20 minutes. The first test is run with the engine in a “cold” state, which involves letting the engine cool to ambient conditions either by sitting overnight or by

forced cooling pr ovisions outlined in §86.1335

- 90 (or 40 CFR Part 1036)

. This portion of the test is meant to assess the ability of the engine to control emissions during the period prior to226 of 54 1

reaching normal operating temperature. This is commonly a challenging area in cri teria pollutant emission control, as cold combustion chamber surfaces tend to inhibit mixing and vaporization of fuel and aftertreatment devices do not tend to function well at low temperatures. Following the first test, the engine is shut off for a peri od of 20 minutes, during which emission anal yz er checks are performed and preparations are made for the second test (also known as the “hot” test). After completion of the second test, the results from the cold and hot tests are weighted and a single comp osite result is calculated for each pollutant. Based on t ypi cal in

- use dut y c ycl es, the cold test results are given a 1/7 weighting and the hot test results are given a 6/7 weighting. Deterioration factors are applied to the final weighted results and th e results are then compared to the emission standards. Prior to 2007, compliance only needed to be demonstrated over the FTP. However, a number of events brought to light the fact that this transient cycle may not be as well suited for engines which spend much of their duty cycle at steady cruise conditions, such as those used in line

- haul semi

- trucks. As a result, the steady

- state test was added, which was known as the supplemental emission test (or SET), consisting of 13 steady

- state modes. During each m ode, emissions were sampled for a period of five minutes. Weighting factors were then applied to each mode and the final weighted results were compared to the emission standards (including deterioration factors). In addition, emissions at each mode could not exceed the NTE emission limits. Alternativel y, manufacturers could run the test as a ramped

- modal cycle (RMC). In this case, the cycle still consists of the same speed/torque modes, however linear progressions between points are added and instead of w eighting factors, each mode is sampled for various amounts of time. The result is a continuous cycle lasting approximately 40 minutes. With the implementation of Part 1065 test procedures in 2010, manufacturers are now required to run the modal test as a ramped

- modal cycle. In addition, the order of the speed/torque modes in the RMC have changed for 2010 and later engines. It is well known that fuel consumption, and therefore CO 2 emissions, are highl y dependent on the drive cycle over which they are measur ed. Stead y cruise conditions, such as highway

driving, tend to be more efficient, having lower fuel consumption and CO 2 emissions. In contrast, highl y transient operation, such as cit y driving, tends to lead to lower efficiency

and therefore higher fuel consumption and CO 2 emissions. One example of this is the difference between EPA

- measured cit y and highway fuel econom y ratings assigned to all new light

- dut y passenger vehicles. For these heav y - duty

engine and vehicle rules, we believe it is important to assess CO 2 emissions and fuel consumption over both transient and steady state test cycles, as all vehicles will operate in conditions ty pical of each cycle at some point in their useful life. However, due to the drive cycle dependence of CO 2 emissions, we do not believe it is reasonable to have a single CO 2 standard which must be met for both cycles. A single CO 2 standard would likely prove to be too lax for steady

- state conditions while being too strict for transient conditions. Therefore, we are reco mmending that all heavy

- duty engines be tested over both transient and steady - state tests. However, onl y the resultsDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

227 of 54 1 from either the transient or steady - state test cycles will be used to assess compliance with GHG standards, depending on they t ype of vehi cle the engine will be used in. Engines that will be used in class 7/8 tractors will use the RMC for GHG certification, and vocational truck engines will use the FTP transient test. In both cases, results from the other test cycle will be reported but no t used for a compliance decision. Engines will continue to be required to show criteria pollutant compliance over both cycles, in addition to NTE requirements. Durability testing Another element of the current certification process is the requirement to c omplete durability

testing to establish deterioration factors (DFs). As previously mentioned, manufacturers are required to demonstrate that their engines comply with emission standards throughout the regulatory compliance period of the engine. This demon stration is commonly made through the combination of low

- hour test results and testing based deterioration factors. For engines without aftertreatment devices (ATDs), deterioration factors primarily account for engine wear as service is accumulated. Commo nly this includes valve/valve seat wear and piston ring wear, which both serve to reduce in

- cylinder pressure. Oil control seals and gaskets also deteriorate with age, leading to higher lubricating oil consumption. Additionally , flow properties of EGR s ys tems may change as deposits accumulate and therefore alter the mass of EGR inducted into the combustion chamber. These factors, amongst others, may serve to reduce power, increase fuel consumption, and change combustion properties; all of which affect pol lutant emissions. For engines equipped with ATDs, DFs take into account engine deterioration, as described above, in addition to aging affects on the ATDs. Oxidation cataly sts and other catal yt ic devices rel y on active precious metals to effectivel y conve rt and reduce harmful pollutants. These metals may become less active with age and therefore pollutant conversion efficiencies may decrease. Particulate filters may also experience reduced trapping efficiency

with age due to ash accumulation and/or degrad ation of the filter substrate, which may

lead to higher tailpipe PM measurements and/or increased regeneration frequency . With ATD equipped engines, the DFs for pollutants managed b y ATDs are primaril y a function of the aftertreatment device(s) rather than deterioration of the engine, since conversion/reduction efficiencies of the ATDs are generally quite high in a nominal state. At this time, we anticipate that most engine component wear will not have a significant negative impact on CO 2 emissions. However , wear and aging of aftertreatment devices may

or may not have a significant negative impact on CO 2 emissions. In addition, future engine or aftertreatment technologies may experience significant deterioration in CO 2 emissions performance over the useful life of the engine. For these reasons, we believe that the use of DFs for CO 2 emissions is both appropriate and necessary . As with criteria pollutant emissions, these DFs are preferabl y developed through testing the engine over a representative duty cycle for an extended period of time. This is ty

pically either half or full useful life, depending on the regulatory class.228 of 54 1

The DFs are then calculated by comparing the high

- hour to low

- hour emission levels, either b y division or subtraction (for multiplicative & additive DFs, respectively). This testing process may

be a significant cost to an engine manufacturer, mainly due to the amount of time and resources required to run the engine out to half or full useful life. For this reason, durability testing for the determination of DFs is not commonly

repeated from model year to model year. In addition, some DFs may be allowed to carry

over between families sharing a common architecture and aftertreatment sy stem. EPA prefers to have manufacturers develop testing

- based DFs for their products, and we are proposing that this be the case for the final rule. However, we do understand that for the reasons stated above , it may be impractical to expect manufacturers to have testing

- based deterioration factors available for this proposal. Therefore, we are willing to consider requiring the use of assigned DFs for CO 2 . Under this possibility , we suggest that manufacturers would be required to submit any CO 2 data from durability testing to aid in developing more accurate a ssigned DFs. IRAFs/Regeneration impacts on CO 2 Heav y - dut y engines may be equipped with exhaust aftertreatment devices which require periodic “regeneration” to return the device to a nominal state. A common example is a diesel particulate filter (DPF), whic h accumulates particulate matter (PM) as the engine is operated. When the PM accumulation reaches a threshold such that exhaust backpressure is significantly increased, exhaust temperature is activel y increased to oxidize the stored PM. The increase in e xhaust temperature is commonl y facilitated through late combustion phasing and/or raw fuel injection into the exhaust sy stem upstream of the DPF. Both methods impact emissions and therefore must be accounted for at the time of certification. In accordance with §86.004

- 28(i), this ty pe of event would be considered infrequent because in most cases they only occur once every

30 to 50 hours of engine operation (rather than once per transient test cycle), and therefore adjustment factors must be applied at cert ification to account for these effects. Similar to DFs, these adjustment factors are based off of manufacturer testing; however this testing is far less time consuming. Emission results are measured from two test cycles: with and without regeneration occurring. The differences in emission results are used, along with the frequency at which regeneration is expected to occur, to develop upward (UAFs) and downward adjustment factors (DAFs). UAFs are added to all emission results derived from a test cycle in which regeneration did not occur. Similarly , DAFs are applied to results based on a cycle which did experience a regeneration event. Each pollutant will have a unique set of adjustment factors and additionally , separate factors are commonly

developed for transient and steady

- state test cycles. The impact of regeneration events on criteria pollutants varies b y pollutant and the aftertreatment device(s) used. In general, the adjustment factor can have a very significant impact on compliance with the NO X stan dard. For this reason, heav y - dut y truck and engine OEMs are already very well motivated to extend the regeneration frequency to as long an interval as possible and to reduce the during of the regeneration as much as possible. Both of these actions signif icantly reduce the impact ofDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

229 of 54 1 regeneration on CO 2 emissions and fuel consumption. We do not believe that adding an adjustment factor for infrequent regeneration to the CO 2 or fuel efficiency standards would provide a significant additional motivation to OE Ms to reduce regenerations. However, doing so would add significant uncertainty to our projections of CO 2 and fuel consumption performance in 2014 and beyond. In addressing that uncertainty , the Agencies would have to set less stringent fuel efficiency and CO 2 standards for heav y duty trucks and engines. In practice, we believe adding an adjustment factor for infrequent regeneration would provide no significant improvement in infrequent regeneration beyond what will be achieved through the NO X standards, but would force the Agencies to set less effective standards for CO 2 and fuel efficiency . Therefore, we are not proposing to include an infrequent regeneration adjustment factor for CO 2 or fuel efficiency in this program. The Agencies are seeking public commentary on this approach. AECDs As part of the engine control strategy , there may be devices or algorithms which reduce the effectiveness of emission control sy stems under certain limited circumstances. These strategies are referred to as Auxiliary Emis sion Control Devices (AECDs). One example would be the reduced use of EGR during cold engine operation. In this case, low coolant temperatures may cause the electronic control unit to reduce EGR flow to improve combustion stability . Once the engine warms up, normal EGR rates are resumed and full NO X control is achieved. At the time of certification, manufacturers are required to disclose all AECDs and provide a full explanation of when the AECD is active, which sensor inputs effect AECD activation, and what aspect of the emission control sy stem is affected b y the AECD. Manufacturers are further required to attest that their AECDs are not “defeat

- devices,” which are intentionall y targeted at reducing emission control effectiveness. Several common AECDs disclosed for criteria pollutant certification will have a similarly negative influence on GHG emissions as well. One such example is cold

- start enrichment, with provides additional fueling to stabilize combustion shortly after initially starting the engi ne. From a criteria pollutant perspective, HC emissions can reasonabl y be expected to increase as a result. From a GHG perspective, the extra fuel does not result in a similar increase in power output and therefore the efficiency of the engine is reduced, which has a negative impact on CO 2 emissions. In addition, there may be AECDs that uniquely reduce GHG emission control effectiveness. Therefore, consistent with today ’s certification procedures, we are proposing that a comprehensive list of AECDs coveri ng both criteria pollutant, as well as GHG emissions is required at the time of certification. (ii) EPA’s N

2 O and CH

4 Standards In 2009, a rule was established requiring manufacturers of mobile

- source engines to report the emissions of CO 2 , N 2 O, and CH 4 . Whil e CO 2 is commonly measured during certification testing, CH 4 and N 2 O are not. CH 4 has traditionally not been included in criteria pollutant regulations because it is a relatively stable molecule and does not230 of 54 1

contribute significantly

to ground

- level ozone formation. In addition, N 2 O is commonly a by product of lean

- NO X aftertreatment s ys tems. Until recentl y, these t ypes of systems were not widel y used on heav y - dut y engines and therefore N 2 O emissions were insignificant. Both species, while emitted in small quantities relative to CO 2 , have much higher global warming potential (GWP) than CO 2 and therefore must be considered as part of a comprehensive GHG regulation. EPA is proposing that CH 4 and N 2 O be reported at the time of certification. We are proposing to allow manufacturers to use a compliance statement based on good engineering judgment for the first year of the program in lieu of direct measurement of N 2 O. However, beginning in 2015 model ye ar, the agency is proposing to require the direct measurement of N 2 O for certification. The intent of the CH 4 and N 2 O standards are more focused on prevention of future increases in these compounds, rather than forcing technologies that reduce these pollutants. As one example, we envision manufacturers satisfying this requirement b y using catal ys t formulations that do not promote increases in N 2 O rather than pursuing a catal ys t that may increase N 2 O. In many way s this becomes a design

- based criterion in that the decision of one cataly st over another will effectiv el y determine compliance with N 2 O standards over the useful life of the engine. For this reason, we believe low

- hour test results are adequate to demonstrate compliance with CH 4 and N 2 O standards and we are proposing to accept DF values provided b y manufac turers of zero (additive) or one (multiplicative). EPA is also proposing an option which allows manufacturers to calculate a CO 2 - equivalent value which is subject to the CO 2 standards in lieu of compl yi ng with the separate N 2 O and CH 4 caps. (c) Additional Comp liance Provisions (i ) Warranty & Defect Reporting Under section 207 of the Clean Air Act, engine manufacturers are required to warrant their product such that it is free from defects that would cause the engine to not comply with emission standards. This warr ant y must be applicable from when the engine is introduced into commerce through a period generally defined as half of the regulatory useful life (specified in hours and years, whichever comes first). The exact time of this warranty is dependent on the re gulatory class of the engine. In addition, components that are considered “high cost” are required to have an extended warranty . Examples of such components would be exhaust aftertreatment devices and electronic control units. Current warrant y provisions in 40 CFR Part 86 define the warrant y periods and covered components for heav y - duty engines. The current list of components is comprised of any device or s ys tem whose failure would result in an increase in criteria pollutant emissions. At this point, we be lieve this list to be adequate for addressing GHG emissions as well. However, there may

be instances where the failure of a component or s ys tem may reduce the efficiency

of the engine while not increasing criteria pollutant emissions. In this case, the c omponent or s ys tem may be inappropriatel y left off the list of covered components. Therefore we are seeking public comment on what devices and/or s ys tems may need toDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

231 of 54 1 be added to the warranted component list to adequately address GHG emissions. The followi ng list identifies items commonly defined as critical emission

- related components:

 Electronic control units

 Aftertreatment devices

 Fuel metering components

 EGR

- Sy stem components

 Crankcase

- ventilation valves

 All components related to charge

- air compression and cooling

 All sensors and actuators associated with an y of these components When a manufacturer experiences an elevated rate of failure of an emission control device, they

are required to submit defect reports to the EPA. These reports will generall y hav e an explanation of what is failing, the rate of failure, and any possible corrections taken b y the manufacturer. Based on how successful EPA believes the manufacturer to be in addressing these failures, the manufacturer may need to conduct a product recal l. In such an instance, the manufacturer is responsible for contacting all customers with affected units and repairing the defect at no cost to them. We believe this structure for the reporting of criteria pollutant defects, and recalls, is appropriate f or components related to complying with GHG emissions as well. (2) Proposed Enforcement Provisions (a ) ECI Labeling Current provisions for engine certification require manufacturers to equip their product with permanent emission control information (ECI) labels. These labels list important characteristics, parameters, and specifications related to the emissions performance of the engine. These include, but are not limited to, the manufacturer, model, displacement, emission control sy stems, and tune

- up specifications. In addition, this label also provides a means for identifying the engine famil y name, which can then be referenced back to certification documents. This label provides essential information for field inspectors to determine that an engine is in fac t in the certified configuration. We do not anticipate an y major changes needing to be made to ECI labels as a result of new GHG standards and a single label is appropriate for both criteria pollutant and GHG emissions purposes. Perhaps the most significant addition would be the inclusion of family

certification levels (FCLs) or family emission limits (FEL s) for GHG pollutants, if the manufacturer is participating in averaging, banking, and trading. In most cases, this would be a CO 2 FEL . However, a manuf acturer may

also specify

a CO 2 - equivalent FEL (CO 2e ), which considers N 2 O and CH 4 emissions in addition to CO 2 .232 of 54 1 (b ) In

- Use Standards In
- use testing of engines provides a number of benefits for ensuring useful life compliance. In addition to verifying complian ce with emission standards at an y given point in the useful life, it can be used along with manufacturer defect reporting, to indentify components failing at a higher than normal rate. In this case, a product recall or other service campaign can be initiat ed and the problem can be rectified. Another key benefit of in

- use testing is the discouragement of control strategies catered to the certification test cycles. In the past, engine manufacturers were found to be producing engines that performed acceptabl y over the certification test cycle, while changing to alternate operating strategies “off

- cycle” which caused increases in criteria pollutant emissions. While these strategies are clearl y considered defeat devices, in

- use testing provides a meaningful way of ensuring that such strategies are not active under normal engine operation. Currently , manufacturers of certified heav y - duty engines are required to conduct in

- use testing programs. The intent of these programs is to ensure that their products are cont inuing to meet criteria pollutant emission standards at various points within the useful life of the engine. Since initial certification is based on engine dy namometer testing, and removing in

- use engines from their respective vehicles is often impractical, a unique testing procedure was developed. This includes using portable emission measurement s ys tems (PEMS) and testing the engine over t ypical in

- situ drive routes rather than a prescribed test cycle. To assess compliance, emission results from a well d efined area of the speed/torque map of the engine, known as the not

- to
- exceed (NTE) zone, are compared to the emission standards. To account for potential increases in measurement and operational variability , certain allowances are applied to the standard which results in the standard for NTE measurements (NTE limit) to be at or above the duty cycle emission standards. In addition, EPA also conducts an annual in

- use testing program of heavy

- duty engines. Testing procured vehicles with specific engines ove r well

- defined drive routes using a constant trailer load allows for a consistent comparison of in

- use emissions performance. If potential problems are identified in

- situ, the engine may be removed from the vehicle and tested using an engine dynamometer o ver the certification test cycles. If deficiencies are confirmed the Agency will either work with the manufacturer to take corrective action or proceed with enforcement action against the manufacturer. The GHG reporting rule requires manufacturers to submi t CO 2 data from all engine testing (beginning in the 2011 model year), which we believe is equally applicable to in

- use measurements. Methods of CO 2 in

- situ measurement are well established and most, if not all, PEMS devices measure and record CO 2 along wi th criteria pollutants. CH 4 and N 2 O present in

- situ measurement challenges that may be impractical to overcome for this testing, and therefore it is not recommended that they be included in in

use testing requirements at this time. While measurement of C O 2 may be practical and important, implementing an NTE emission standard for CO 2 is challenging. As previously

discussed, CO 2 emissions are highl y dependent on the drive cycle of the vehicle, which does not lend itself well to the NTE

- based test procedure . Therefore, weDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

233 of 54 1 propose that manufacturers be required to submit CO 2 data from in

- use testing, in both g/bhp

- hr and g/ton

- mile, but these data will be used for reference purposes only (there would be no NTE limit/standard for CO 2 ). (3) Other Certification Prov isions (a ) Carryover/Carry Across Certification Test Data EPA’s current certification program for heavy

- duty engine s allows manufacturers to carry certification test data over and across certification testing from one model year to the next, when no significant changes to models are made. EPA is proposing to also apply this policy

to CO 2 , N 2 O and CH 4 certification test data. (b ) Certification Fees The CAA allows EPA to collect fees to cover the costs of issuing certificates o f conformity

for the classes of engine s covered b y this proposal . On May 11, 2004, EPA updated its fees regulation based on a study of the costs associated with its motor vehicle and engine compliance program (69 FR 51402). At the time that cost study was conducted , the current rulemaking was not considered. At this time the extent of any added costs to EPA as a result of this proposal is not known. EPA will assess its compliance testing and other activities associated with the rule and may amend its fees regulations in the future to include an y warranted new costs. (c) OBD Beginning in the 2013 model y ear, manufacturers will be required to equip heavy

duty engines with on

- board diagnostic s ys tems. These s ys tems monitor the activity of the emission control sy stem and issue alerts when faults are de tected. These diagnostic sy stems are currentl y being developed based around components and s ys tems that influence criteria pollutant emissions. Consistent with the light

- duty vehicle GHG rule, we believe that monitoring of these components and sy stems for criteria pollutant emissions will have and equally beneficial affect on CO 2 emissions. Therefore, we do not anticipate the necessity of having any

unique OBD provisions for heavy

- dut y GHG emissions. We are open to comment on this topic, however. (d ) Applicabi lity of Current High Altitude Provisions to Greenhouse Gases EPA is proposing that engines covered b y this proposal must meet CO 2 , N 2 O and CH 4 standards at elevated altitudes. The CAA requires emission standards under section 202 for heav y - dut y engines to apply at all altitudes. EPA does not expect engine CO 2 , CH 4 , or N 2 O emissions to be significantly different at high altitudes based on engine calibrations commonly

used at all altitudes. Therefore, EPA proposes that it retain its current high altitude regulations so manufacturers will not normally be required to submit engine CO 2 test data for high altitude. Instead, they will be required to submit an engineering evaluation indicating that common calibration approaches will be utilized at high altitude. An y deviation in emission control practices emplo yed onl y at altitude will234 of 54 1

need to be included in the auxiliary emission control device (AECD) descriptions submitted by

manufacturers at certification. In addition, any AECD specific to high altitude will be r equired to include emissions data to allow EPA evaluate and quantify any emission impact and validity of the AECD. 

### D. Class 7/8 Combination Trucks (1) Proposed Compliance Approach In addition to requiring engine manufacturers to certify their engines, manufacture rs of class 7 and 8 combination trucks must also certify that their vehicles meet CO 2 emission and fuel consumption standards. This vehicle certification will ensure that efforts beyond just engine efficiency improvements are undertaken to reduce GHG emis sions. Some examples include aerodyn amic improvements, rolling resistance reduction, idle reduction technologies, and vehicle speed limiting sy stems. Unlike engine certification however, this certification will be based on a load

specific basis (g/ton

- m ile as opposed to work

- based, or g/bhp

- hr). This will take into account the anticipated vehicle loading that would be experienced in use and the associated affects on fuel consumption and CO 2 emissions. Vehicle manufacturers will also be required to warrant their products against emission defects, and demonstrate that a service network is in place to correct an y such conditions. The vehicle manufacturer also bears responsibility

in the event that an emission

- related recall is necessary. (a ) Certification Pro cess In order to obtain a certificate of conformity for the truck, vehicle manufacturers must complete a compliance demonstration, showing that their product meets emission standards as well as other requirements in the CFR. For purposes of this demonstration, vehicles with similar emission characteristics throughout their useful life are grouped together in test groups, similar to EPA’s light

- duty emissions certification program. Examples of characteristics that would define a test group for heav y - dut y v ehicles are wheel and tire package, aerodynamic profile, number and rolling resistance of tires, and engine model. Under this sy stem, the worst

- case vehicle would be selected based on having the highest fuel consumption, and all other models within the family are assumed to have emissions at or below the parent model and therefore in compliance with emission standards. An y vehicle within the family can be subject to selective enforcement auditing in addition to confirmatory or other administrator testing. The worst
- case vehicle is then tested using either the optional chassis test or attribute

- based model. We anticipate test groups for class 7/8 combination tractors to utilize the standardized 12

- digit naming convention, as outlined in the engine certific ation section of this chapter. As with engines, each certifying vehicle manufacturer will have a unique three digit code assigned to them. Currently , there is no 5 th digit (industry sector) code for this class of vehicles, for which we propose to use the next available character, “2.” Since we are proposing that the engine is one of several test

- group defining features, we still believe it is appropriate to include engine displacement in the family name. If theDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

235 of 54 1 test
- group consists includes multiple engine models with varying displacements, the largest would be specified in the test

- group name, consistent with current practices. The remaining characters would remain available for CARB and/or manufacturer use, such that the result is a unique test

- group name. Class 7 and 8 trucks share several common traits, such as the trailer attachment provisions, number of wheels, and general construction. However, further inspection reveals key

differences related to GHG emissions. Payloads hauled by class 7 vehicles are significantl y less than class 8 vehicles. In addition, class 8 vehicles may have provisions for hotelling (“sleeper cabs”), which results in an increase in size as well as the addition of comfort features like power and climate control for use while th e truck is parked. Both segments may have various degrees of roof fairing to provide better aerod ynamic matching to the trailer being pulled. This is a feature which can help reduce CO 2 emissions significantly when properl y matched to the trailer, but can also increase CO 2 emissions if improperly matched. Based on these differences, it is reasonable to expect differences in CO 2 emissions, and therefore these properties form the basis for combination tractor regulatory subcategories. The various combinati ons of payload, cab size, and roof profile result in nine regulatory

subcategories for class 7 and 8 trucks. These include class 7 (day cabs), class 8 (day cabs), and class 8 (sleeper cabs), each with high, mid, and low roof profiles. These vehicles all h ave a regulatory useful life of 435,000 miles and therefore must meet CO 2 emission standards throughout this period, as required in the CAA. (b ) Demonstrating compliance with the proposed standards (i ) CO2 and Fuel Consumption Standards Consistent with existing c ertification processes for light

- dut y vehicles and heav y duty pickups and vans, emissions testing of the complete vehicle would be the preferred method for demonstrating compliance with vehicle emission standards. However, vehicle

- level certification is n ew to the heav y - duty vehicle segment above 14,000 lbs. Therefore, most vehicle manufacturers are not adequatel y equipped to conduct vehicle

level emission testing for class 7/8 combination tractors. Chassis dynamometers, emission sampling equipment, and staff engineering support are a few of the factors that would add significant cost to vehicle development in a relativel y short amount of time, which may

make the prospect of vehicle testing quite onerous. In addition to the infrastructure and testing fac ilities the industry would need to add, the Agencies have not completed the extensive work ultimately desirable for us to propose new test procedures and standards based on the use of a chassis test procedure. Recognizing these constraints related to time, staffing, and capitol, we are proposing onl y a vehicle simulation model option for demonstrating compliance at the time of certification. However, we do believe that a chassis based test procedure as currentl y utilized for vehicles below 14,000lbs could be a better long

- term approach to regulate all heav y - dut y vehicles and we are seeking comment on a chassis based approach. Model236 of 54 1 Vehicle modeling will be conducted using EPA’s [TEST] simulation model, which is described in detail in Chapter 4 of the draft RIA. Basicall y, this model functions by defining a vehicle model then exercises this model over various drive cycles. Several initialization files are needed to define a vehicle, which include mechanical attributes, control algorithms, and driver inputs. The majority of these inputs will be predetermined by EPA and NHTSA for the purposes of vehicle certification. The net results from the [TEST] model are CO 2 emissions and fuel consumption values over the drive cycle that the user selects. The CO 2 emiss ion result will be used for demonstrating compliance with vehicle GHG standards. The vehicle manufacturer will be responsible for entering aerodynamic properties of the vehicle, the weight reduction, tire properties, idle reduction s ys tems, and vehicle spe ed limiting sy stems. For [TEST] inputs relating to weight reduction, rolling resistance, and aerodynamics, EPA is proposing the use of lookup tables based on typical performance levels across the industry . These lookup tables do not have data directl y rel ated to CO 2 , but rather provide the appropriate coefficients for the model to assess CO 2 - related performance. Examples are ty pical drag coefficients for conventional and Smart

- Way

class 8 sleeper cabs or coefficients of rolling resistance for standard and low

rolling resistance tires. The exception is for idle reduction technologies, which will have a CO 2 reduction specified in the lookup tables. We believe this approach reduces the testing burden placed upon manufacturers, yet adequatel y assesses improvem ents associated with select technologies. The model will be publicly available and will be found on EPA’s website. The Agency reserves the right to independently evaluate the inputs to model via Administrator testing to validate those model inputs. The A gency also reserves the right to evaluate vehicle performance using the inputs to the model provided b y the manufacturer to confirm the performance of the s ystem using [TEST]. In the event of such testing or evaluation, the Administrator’s results become the official certification results. The exception being that the manufacturer may continue to use their data, provided it represents a worst

- case condition over the Administrator’s results. To better facilitate the entry of onl y the appropriate parameters, EPA will provide a spreadsheet

- ty

pe template for entering data specific to each vehicle. This template can then be fed directl y to the model, which allows the end user to avoid interacting directly with the model and an y associated coding. It is expected that this template will be submitted to EPA as part of the certification process for each certified vehicle configuration. For certification, the model will exercise the vehicle over three test cycles; one transient and two steady - state. For the transient test, we are proposing to use the heav y heav y - dut y diesel truck (HHDDT) transient test cycle, which was developed by the California Air Resources Board and West Virginia Universit y to evaluate heav y - dut y vehicles. The transient mode simulates urban, start

- stop driving, featuring 1.8 stops per mile over the 2.9 mile duration. The two steady state test points are reflective of the tendency for some of these vehicles to operate for extended periods at highway speeds.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

237 of 54 1 Based on data from the EPA’s MOVES databas e, and common highway speed limits, we are expecting these two points to be 55 and 65 mph. The model will predict the total emissions results from each segment using the unique properties entered for each vehicle. These results are then normalized to the payload and distance covered, so as to yield a gram/ton

- mile result, as well as a fuel consumption (gal/ton

- mile) result for each test cycle. As with engine and vehicle testing, certification will be based on a parent rating for the test group, represent ing the worst

case fuel consumption and CO 2 emissions. However, vehicle manufacturers will also have the opportunit y to model sub

- configurations to determine an y benefits that are available on onl y a select number of vehicles within a test group. The resu lts from all three tests are then combined using weighting factors, which reflect ty pical usage patterns. The t ypical usage characteristics of class 7 and 8 trucks with day cabs differ significantly

from class 8 vehicles with sleeper cabs. The trucks with day cabs tend to operate in more urban areas, have a limited travel range, and tend to return to a common depot at the end of each shift. Class 8 sleeper cabs, however, are ty picall y used for long distance trips which consist of mostly highway driving i n an effort to cover the highest mileage in the shortest time. For these reasons, we propose that the cycles are weighted differently for these two groups of vehicles. For class 7 and 8 trucks with day cabs, we recommend weights of 64%, 17%, and 19% (65 mph, 55 mph, and transient, resp.). For class 8 with sleeper cabs, the high speed cruise tendency results in weights of 86%, 9%, and 5% (65 mph, 55 mph, and transient, resp.). These final, weighted emission results are compared to the emission standard t o assess compliance. Durability Testing As with engine certification, a manufacturer must provide evidence of compliance through the regulatory

useful life of the vehicle. Factors influencing vehicle

- level GHG performance over the life of the vehicle fall into two basic categories: vehicle attributes and maintenance items. Each category merits different treatment from the perspective of assessing useful life compliance, as each has varying degrees of manufacturer versus owner/operator responsibility

. The category

of vehicle attributes generall y refers to aerodynamic features, such as fairings, side

- skirts, air dams, air foils, etc, which are installed b y the manufacturer to reduce aerodynamic drag on the vehicle. These features have a significant impact on G HG emissions and their emission reduction properties are assessed early in the useful life (at the time of certification). These features are expected to last the full life of the vehicle without becoming detached, cracked/broken, misaligned, or otherwise not in the original state. In the absence of the aforementioned failure modes, the performance of these features is not expected to degrade over time and the benefit to reducing GHG emissions is expected to last for the life of the vehicle with no specia l maintenance requirements. To assess useful life compliance, we recommend a design

- based approach which would ensure that the manufacturer has robustly designed these features so they can reasonabl y be expected to last the useful life of the vehicle.238 of 54 1 The category

of maintenance items refers to items that are replaced, renewed, cleaned, inspected, or otherwise addressed in the preventative maintenance schedule specified b y the vehicle manufacturer. Items that have a direct influence on GHG emissions are pri maril y l ubricants and tire pressure. Sy nthetic engine oil may

be used by vehicle manufacturers to reduce the GHG emissions of their vehicles. Manufacturers may specify that these fluids be changed throughout the useful life of the vehicle. If this is the case, the manufacturer should have a reasonable basis that the owner/operator will use fluids having the same properties. This may be accomplished by

requiring (in service documentation, labeling, etc) that onl y these fluids can be used as replacements. Similarly , tire pressure has a profound affect on GHG emissions and fuel consumption. It is preferred that vehicle manufacturers equip their vehicles with tire pressure monitoring sy stems (TPMS) to ensure that drivers are immediately notified of tires with low pressure. Aside from TPMS, there is unfortunately little that a manufacturer can do to ensure proper tire inflation. Fortunatel y, the effect of tire inflation on fuel consumption is well known and therefore we believe that most owner/operators will k eep tires properl y inflated if only

for economic reasons. Currently , EPA seeks public comment on the merits and feasibility

of requiring TPMS on all new heavy

- dut y vehicles as part of this proposal. If the vehicle remains in its original certified conditi on throughout its useful life, it is not believed that GHG emissions would increase as a result of service accumulation. This is based on the assumption that as components wear, the rolling resistance due to friction is likely

to stay the same or decrease . With all other components remaining equal (tires, aerod ynamics, etc), the overall drag force would stay the same or decrease, thus not significantl y changing GHG emissions at the end of useful life. Itis important to remember however, that this vehicle assessment does not take into account any engine

related wear affects, which may in fact increase GHG emissions over time. For the reasons explained above, we believe that for the first phase of this program, it is most important to ensure that the vehicl e remain in its certified configuration throughout the useful life. This can most effectivel y be accomplished through engineering analy sis and specific maintenance instructions provided by the vehicle manufacturer. The vehicle manufacturer would be primarily responsible for providing engineering analy sis demonstrating that vehicle attributes will last for the full life of the vehicle. In addition they will be required to submit the recommended maintenance schedule (and other service related documentation), showing that fluids meeting original equipment properties are required as replacements. (ii) EPA’s Air Conditioning Leakage Standards Heav y - dut y vehicle air conditioning (A/C) systems contribute to GHG emissions in two way s. First, operation of the air condit ioning unit places an accessory load on the engine, which increases fuel consumption. Second, most modern refrigerants are Hydrofluorocarbon (HFC) based, which have significant global warming potential (GWP=1430). For heav y - duty vehicles, the load added by the air conditioning s ys tem is comparativel y small compared to other power requirements of the vehicle. Therefore, we are not targeting an y GHG reduction due to decreased air conditioning usage or higherDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

239 of 54 1 efficiency A/C units for this proposal. However, re frigerant leakage, even in very small quantities, can have significant adverse effects on GHG emissions. Refrigerant leakage is a concern for heav y - dut y vehicles, similar to light

- duty vehicles. To address this, EPA is proposing a design

- based standard for reducing refrigerant leakage from heav y - dut y vehicles. This standard is based off using the best practices for material selection and interface sealing, as outlined in SAE publication J2 727. Based on design criteria in this publication, a leakage “sc ore” can be assessed and an estimated annual leak rate can be made for the A/C sy stem. At the time of certification, manufacturers will be required to outline the design of their sy stem, including specifying materials and construction methods. They will a lso need to supply

the leakage score developed using SAE J2727 and the refrigerant volume of their s ys tem to determine the leakage rate per year. If the certifying manufacturer does not complete installation of the air conditioning unit, detailed instruct ions must be provided to the final installer which ensures that the A/C sy stem is assembled to meet the low

- leakage standards. These instructions will also need to be provided at the time of certification, and manufacturers must retain all records relatin g to auditing of the final assembler. (c) In

- Use Standards As previously

addressed, the drive

- cycle dependence of CO 2 emissions makes NTE
- based in

- use testing impractical. In addition, we believe the reporting of CO 2 data from the criteria pollutant in

- use te sting program will be helpful in future rulemaking efforts. For these reasons, we are not proposing an NTE

- based in

- use testing program for class 7/8 combination tractors during this proposal. In the absence of NTE

- based in

- use testing, provisions are nec essary for verifying that production vehicles are in the certified configuration, and remain so throughout the useful life. Perhaps the easiest method for doing this is to verify the presence of installed emission

- related components. This would basically consist of a vehicle audit against what is claimed in the certification application. This includes verifying the presence of aerod ynamic components, such as fairings, side

- skirts, and gap

- reducers. In addition, the presence of idle

- reduction and speed lim iting devices would be verified. The presence of low rolling resistance tires could be verified at the point of initial sale; however verification at other points throughout the useful life would be non

- enforceable for the reasons mentioned previously

. Th e category

of wear items primarily

relates to tires. It is expected that vehicle manufacturers will equip their trucks with low rolling resistance (LRR) tires, as they may provide a substantial reduction in GHG emissions. The tire replacement intervals f or this class of vehicle is normally in the range of 50,000 to 100,000 miles, which means the owner/operator will be replacing the tires at several points within the useful life of the vehicle. We believe that as LRR tires become more common on new equipm ent, the aftermarket prices of these tires will also decrease. Along with decreasing tire prices, the fuel savings realized through use of LRR tires will ideally provide enough incentive for240 of 54 1

owner/operators to continue purchasing these tires. The inventory modeling in today's proposal reflects the continued use of low rolling resistance tires through the life of the vehicle. We seek comment on this and all aspects of our inventory modeling. (2) Proposed Enforcement Provisions As identified above, a significant amount of vehicle

- level GHG reduction is anticipated to come from the use of components specificall y designed to reduce GHG emissions. Examples of such components include low rolling resistance tires, aerod ynamic fairings, idle reduction s ys tems, and ve hicle speed limiters. At the time of certification, vehicle manufacturers will specify which components will be on their vehicle when introduced into commerce. Based on this list of components reported to EPA the GHG performance of the vehicle will be ass essed either through modeling or testing and a certificate of conformit y ma y be issued. As described in the in

- use testing section, it is important to have the ability to determine if the vehicle is in the certified configuration both at the time of sale, as well as at any point within the useful life. Perhaps the most practical and basic method of verifying a vehicle is in its certified configuration is through a vehicle emissions control information label, similar to that used for engines and light

- duty vehicles. This label would list identifying features of the vehicle, including model year, vehicle model, certified engine family, vehicle manufacturer, test group, and GHG emissions category . In addition, this label would list emission

- related component s that an inspector could reference in the event of a field inspection. Possible examples may include LRR (for low rolling resistance tires), ARF (aerod yn amic roof fairing), and ARM (aerodynamic rearview mirrors). With this information, inspectors could v erify the presence and condition of attributes listed as part of the certified configuration. Similarly , on current ECI labels, manufacturers list abbreviations, which are defined in SAE J1930, for each emission control device. Examples include three

- way c atal ys t (TWC), electronic control (EC), and heated oxygen sensor (HO2S). Unfortunately we are not aware of a similar, existing list of vehicle emission control devices and features likely to be used on heav y - duty vehicles. At this point, it is also difficu lt to develop such a list due to the wide array

of devices and features vehicle manufacturers may used in the future. Therefore, we are currentl y seeking comment on how to best define a list of emission control devices and features for use in this vehicle GHG certification label. (3) Other Certification Provisions (a ) Warranty Section 207 of the Clean Air Act requires manufacturers to warrant their products to be free from defects that would otherwise cause non

- compliance with emission standards. In addition, thi s warranty must ensure that the vehicle remains in this configuration throughout its useful life. For purposes of this regulation, vehicle manufacturers must warrant all components installed which act to reduce CO 2 emissions at the time of initial sale. This includes all aerodynamic features, tires, idle reductionDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

241 of 54 1 sy stems, speed limiting sy stem, and other equipment added to reduce CO 2 emissions. In addition, the manufacturer must ensure these components and sy stems remain functional for the useful life of the vehicle. The exception being tires, which are only required to be warranted for the first life of the tires (vehicle manufacturers are not expected to cover replacement tires). For aerodynamic features, such as fairings or side

- skirts, the manufactur er must warrant against failures which are not the result operator damage. However, these components should be designed to withstand possible damage from normal driving, which may include stone impingement and other minor impact with small debris. The vehi cle manufacturer is also required to warrant the A/C sy stem for the useful life of the vehicle against design or manufacturing defects causing refrigerant leakage in excess of the standard. At the time of certification, manufacturers must supply a copy of the warranty statement that will be supplied to the end customer. This document should outline what is covered under the GHG emissions related warranty as well as the length of coverage. Customers must also have clear access to the terms of the warranty, the repair network, and the process for obtaining warrant y s ervice. (b ) Certification Fees Similar to engine certification, the Agency will assess certification fees for heavy

duty vehicles. The proceeds from these fees are used to fund the compliance and ce rtification activities related to GHG regulation for this regulatory category . In addition to the certification process, other activities funded by certification fees include EPA

administered in

- use testing, selective enforcement audits, and confirmatory testing. At this point, the exact costs associated with the heavy

- dut y vehicle GHG compliance are not well known. EPA will assess its compliance program associated with this proposal and assess the appropriate level of fees. We anticipate that fees will b e applied based on test groups, following the light

- duty vehicle approach. (c) Requirements for conducting aerodynamic assessment using allowed methods The requirements for conducting aerodynamic assessment using allowed methods includes three key

components : 1) adherence to a minimum set of standardized criteria for each allowed method; 2) accuracy demonstration for a given aerodyn amic assessment methodology

and correlation demonstration between methodologies if a manufacturer is using an alternative method to determine aerodynamic values; and 3) submittal of aerod ynamic values and supporting information on annual basis for the purposes of certifying vehicles to a particular aerody namic bin as discussed in the section II. First, we are proposing requirements for conducting each of the allowed aerod ynamic assessment methods. We will cite approved and published standards and practices, where feasible, but will attempt to propose criteria where none exists or where more current research indicates otherwise. We are requesting comment on the proposed requirements for each allowed method, standards and practices that should be used, and242 of 54 1

any unique criteria that we are proposing. A description of the requirements for each method is discussed later in this section. The manufacturer would be required to provide information showing that the meet these requirements and attest to the accuracy of the information provided. Second, a manufacturer would be required to demonstrate a) the accuracy of aerod ynamic assessment m ethodology and b) correlation demonstration between methodologies if a manufacturer is using an alternative method to determine aerodyn amic values. The accuracy

of aerod yn amic assessment would be demonstrated using multiple tests on multiple vehicles with some statistical confidence applied as discussed later in this section. This ensures the accuracy of method solely

on the merits of the chosen method. Further, if a manufacturer chooses to use a method other than the coastdown procedure (e.g., wind tunnel or CFD) for aerodynamic assessment, the manufacturer would be required to correlate that method using multiple tests on multiple vehicles. For wind tunnel testing, either full or reduced scale, a correlation would need to occur with coastdown procedure only to ensure that the wind tunnel is accuratel y modeling the aerod ynamic value in the real world. For CFD, a correlation would occur with the coastdown procedure and a wind tunnel since CFD is a calculated value and, therefore, requires some empirica l measurement to ensure accuracy

. This demonstration must occur before a manufacturer can use their method and any testing for demonstration purposes must adhere to the requirements for conducting aerod ynamic assessment mentioned above. Third, to ensure continued compliance, manufactures would be required to provide a minimum set of information on an annual basis at certification time to 1) support continued use of an aerodyn amic assessment method and 2) to assign an aerod ynamic values based on the appli cable aerodynamic bins. The information supplied to the agencies should be based on an approved aerody namic assessment method and adhere to the requirements for conducting aerodynamic assessment mentioned above. Regardless of the method, all testing shoul d be performed with a tractor

- trailer combination to mimic real world usage. Accordingl y, it is important to match the t ype of tractor with the correct trailer. Although, as discussed elsewhere in this proposal, the correct tractor
- trailer combination is not alway s present or tractor
- onl y operation may occur, the majority

of operation in the real world involves correctly matched tractor

trailer combinations and we will attempt to reflect that here. Therefore, the following guidelines should be used when performing aerody namic assessment:

• For a Class 7/8 tractor truck with a low roof, a flatbed trailer loaded to capacity must be used;

• For a Class 7/8 tractor truck with a mid roof, a tanker trailer loaded to capacity must be used;Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

243 of 54 1 • For a Class 7/8 tra ctor truck with a high roof, a box trailer consistent with the specifications described in this proposal for the reference truck must be used. This ensures consistency

and continuity

in the aerody

namic assessments, and maintains the overlap with real world operation. Standardized Criteria for Aerodynamic Assessment Methods (i ) Coastdown Procedure Requirements For coast down testing, the test runs should be conducted in a manner consistent with SAE J2263 with additional modifications as described in the Regulato ry Impact Analy sis using the mixed model anal ys is method. The Agency seeks comment on the use of these protocols and the modifications the Agency has described. Since the coastdown procedure is the primary aerody namic assessment method, the manufacturer would be required to conduct the coastdown procedure according to the requirements in this proposal and supply the following to the agency for approval:

 Facilit y information: name and location, description and/or background/history , equipment and cap ability , track and facility elevation, and track size/length;

 Test conditions for each test result including date and time, wind speed and direction, ambient temperature and humidity , vehicle speed, driving distance, manufacturer name, test vehicle/model typ e, model year, applicable model engine family , tire t yp e and rolling resistance, test weight and driver name(s) and/or ID(s);

 Cd results from valid tests including, at a minimum, eight (8) valid test results, with no maximum number, standard deviation, calculated error and error bands, and total number of tests, including number of voided or invalid tests. (ii) Wind Tunnel Testing Requirements Wind tunnel testing must conform to the following procedures and modifications, where applicable, including:

 SAE J 1252, “ SAE WI ND TUNNEL TEST PROCEDURE FOR TRUCKS AND BUSES ” (July

1981) except that article 5.2 that specifies a minimum Rey nolds number of 0.7 x 10 6 is not included and is superseded, for the purposes of this rulemaking, b y a minimum Reynolds number of 1. 0 x 10 6 and, for reduced

- scale wind tunnel testing, a one

- eighth (1/8 th ) or larger scale model of a heav y - duty tractor and trailer must be used and of sufficient design to simulate airflow through the radiator inlet grill;.244 of 54 1  J1594, “ VEHI CL E AERODYNAMICS TE RMINOLOGY ” (December 1994); and

 J2071, “ AERODYNAMIC TESTI NG OF ROAD VEHICLES

- OPEN THROAT WI

ND TUNNELADJUSTMENT ” (June 1994). In addition, the wind tunnel used for aerodyn amic assessment must be a recognized facility

by the Subsonic Aerody

namic Testing A ssociation (SATA). The Agency

seeks comment on the use of these protocols and the modifications the Agency

has described and the need for membership in SATA. For wind tunnel testing, we are proposing that manufacturers perform wind tunnel testing and the coastdown procedure, according the requirements proposed in this proposal, on the same tractor model and provide the results for both methods. The wind tunnel tests should be conducted at a zero yaw angle and, if so equipped, utilizing the moving/rolli ng floor (i.e., the moving/rolling floor should be on during the test as opposed to static) for comparison to the coastdown procedure, which assumes zero y aw angle for the oncoming wind. The manufacturer would be required to supply the following:

 Facilit y information: name and location, description and

background/history , layout, wind tunnel ty pe, diagram of wind tunnel layout, structural and material construction;

 Wind tunnel design details: corner turning vane type and material, air settling, mesh scre en specification, air straightening method, tunnel volume, surface area, average duct area, and circuit length;

 Wind tunnel flow quality : temperature control and uniformity , airflow quality , minimum airflow velocity , flow uniformity , angularit y and stabil ity , static pressure variation, turbulence intensity , airflow acceleration and deceleration times, test duration flow quality , and overall airflow qualit y achievement;

 Test/Working section information: test section ty pe (e.g., open, closed, adaptive wall) and shape (e.g., circular, square, oval), length, contraction ratio, maximum air velocity , maximum dy namic pressure, nozzle width and height, plenum dimensions and net volume, maximum allowed model scale, maximum model height above road, strut movement rat e (if applicable), model support, primary boundary

layer slot, boundary

layer elimination method and photos and diagrams of the test section;

 Fan section description: fan ty pe, diameter, power, maximum rotational speed, maximum tip speed, support ty pe, me chanical drive, sectional total weightDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

245 of 54 1  Data acquisition and control (where applicable): acquisition ty pe, motor control, tunnel control, model balance, model pressure measurement, wheel drag balances, wing/body panel balances, and model exhaust simulation

 Moving ground plane or Rolling Road (if applicable): construction and material, yaw table and range, moving ground length and width, belt type, maximum belt speed, belt suction mechanism, platen instrumentation, temperature control, and steering; and

 Fac ility

correction factors and purpose. (iii) CFD Requirements Currently , there is no existing standard, protocol or methodology governing the use of CFD. Therefore, we are coupling the use of CFD with empirical measurements from coastdown and wind tunnel proc edures. However, we think it is important to require a minimum set of criteria that all CFD analysis should for the purpose of these rules. Therefore, the agencies propose that an unstructured, time

- accurate, 5 million cell, Navier

- Stokes computational fl uid dy namics code which uses turbulence models with boundary layer resolution of +/

- 95% be used to perform aerody namic assessment and calculate the drag coefficient. In addition, CFD runs should be conducted with the assumption zero yaw angle to match wi nd tunnel and coast down results. The agencies seek comment on the use of commercial or open source code and the criteria set forth above for conducting the analysis. Finally , in general for each of the allowed aerodynamic assessment methods, we are requ esting comment on the list of information that must be provided for facilities and test conditions. Acceptance Demonstration for Aerodynamic Assessment Methods The manufacturer would have to demonstrate that the methodology used for aerod ynamic assessment is acceptable prior to its use. This demonstration would be performed prior to certification in the initial year, model year 2014, of the rules’ implementation and would require agency approval to proceed with use of the method for aerod ynamic assessment thereafter. The demonstration testing would occur on up to three of the manufacturer’s models including: the top selling model, the worst

- case aerod yn amic model, and another randomly chosen model in the manufacturer’s fleet depending on the size of the manufacturer. If there is overlap in the models (e.g., the top selling model is also the worst
- case), the agencies will choose the model used for demonstration. For smaller manufacturers, a reduction in the number of vehicles for demonstration should be requested from and must be approved b y the agencies.246 of 54 1 The manufacturer would be required to perform three to five tests on the production

- intent version of the tractor model and three to five tests of the modified version of the tractor model that would pro duce a significant difference in Cd. This demonstrates that the method used can capture differences in Cd produced by vehicle/model configuration changes. For each aerodyn amic assessment method, the manufacturer would be required to provide information on the test conditions for each test result including but not limited to: test date and time, wind speed (if applicable), temperature, humidity , manufacturer and model, model year, applicable model engine family , tire t ype and rolling resistance for actual model, model test weight, equivalent vehicle test weight, actual and simulated or equivalent vehicle speed, Rey nolds number (if applicable), yaw angle (if applicable), blockage ratio (if applicable), model mounting (if applicable), model geometry, body ax is force and moments (if applicable), total test duration, test vehicle and type and operator name(s) and/or ID(s). In addition, the manufacturer must provide the Cd results from valid tests including: at a minimum, three to five (3

- 5) valid test results for each configuration (e.g., base and modified) with no maximum number, standard deviation for valid test results, calculated error and error bands for valid test results, and total number of tests, including number of voided or invalid tests. In additio n to the testing for each aerodynamic assessment method, alternative methods will also require correlation testing to the coastdown procedure. This will provide confidence in the use of the alternative method once these proposed regulations are implemente d. For an aerod yn amic assessment method to be deemed acceptable, the results from the multiple test runs should be within plus or minus five percent (+/

- 5%) of each other with a 95% confidence interval. In addition, for alternative aerody namic assessme nt methods, the results must also correlate with the coastdown procedure or wind tunnel test results, depending on the alternative aerodynamic assessment method used, within plus or minus ten percent (+/

- 10%) with a 95% confidence interval. We may also c onsider other factors to determine if an aerodynamic assessment method is acceptable. We are requesting comment on the correlation factors within and between aerodyn amic assessment methods For CFD, the manufacturer would be required to perform the coastdo wn procedure and wind tunnel testing on the model being simulated and compare the predicted Cd results to the experimental results. The simulations should be conducted assuming zero degrees of y aw angle and all simulated conditions should be consistent wi th the experimental test conditions. The manufacturer may

use the data from the aerody namic assessment correlation to satisfy the acceptance demonstration for that methodology

. Once the demonstration and correlation is performed, the manufacturer would n ot have to perform a demonstration test unless they make a fundamental change in their aerod ynamic assessment method (e.g., switch to wind tunnel testing from coastdown,Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

247 of 54 1 change wind tunnel testing facilities or CFD software code). In addition, the agencie s reserve the right to evaluate the manufacturer’s information and to request a re

demonstration on a specific model if the manufacturer introduces a model used for demonstration and correlation with much different characteristics than the current model in their fleet. We are requesting comment on the number of vehicles that a manufacturer is required to test for demonstration purpose and the requirement for the method

- to
- method correlation of 5%. Annual Testing and Data Submittal for Aerodynamic Assessme nt Once the manufacturer has performed acceptance demonstration, the aerodynamic assessment can be used to generate Cd values for all models the manufacturer plans to certify and introduce into commerce. For each model, the manufacturer would supply a pre dicted Cd based on the frontal area for each of the other models in the manufacturer’s fleet and the other conditions used to determine the base Cd. This reduces burden on the manufacturer to perform aerodynamic assessment but provides data for all the mo dels in a manufacturer’s fleet. If a manufacturer has previously performed aerodyn amic assessment on the other models, the manufacturer may submit an experimental Cd in lieu of a predicted Cd. The aerod ynamic assessment data will be used in one of two way s: 1) the manufacturer will input the values and data, including the Cd from the aerody namic assessment, into the agency ’s model and determine a GHG value/score or 2) the agency will use the manufacturer’s input data into the model and assign a GHG value/ score. Since the agency

may input the data into the model, manufacturers must provide the information described above for acceptance demonstration for the purposes of annual certification. In addition, the manufacturer must supply manufacturer fleet infor

mation to the agency

for annual certification purposes along with the acceptance demonstration parameters: manufacturer name, model ye ar, model line (if different than manufacturer name), model name, engine family , engine displacement, transmission name and t ype, number of axles, axle ratio, vehicle dimensions, including frontal area, predicted or measured coefficient of Drag (Cd), assumptions used in developing the predicted or measured Cd. justification for carry

- across of aerody namic assessment data, ph otos of the model line

- up, if available, and model applications and usage options. We are requesting comment on the annual testing requirements and the burden on manufacturers to satisfy

the requirements. (d ) Aerodynamic Assessment In

- Use Compliance Although the procedures above ensure accuracy in the aerody

namic assessment, it is alway s beneficial to have the ability to perform confirmation or validation post

certification. Therefore, we reserve the right and have the authorit y under the Clean Air Act (CAA) to perform in

- use compliance checks of aerodyn amic assessment and the underlying methods to confirm and validate the generated aerody namic results.248 of 54 1 Therefore, we are proposing a in

- use compliance program for aerody namic assessment that consists of two par ts: 1) an in

- use vehicle confirmatory evaluation using a vehicle recruited from the in

- use fleet and performing the aerodynamic assessment discussed in this proposal, either using the manufacturer’s facilit y and tools or using the agency ’s facilit y and to ols; and/or 2) validation of the manufacturer source data by performing an audit of the manufacturer’s aerodyn amic assessment methods and tools using a reference truck as described in this proposal. (i ) In

- Use Vehicle Aerodynamic Confirmation The agencies will confirm the aerodynamic values, in particular Cd, of the manufacturer’s vehicle by: 1) recruiting the truck from the in

- use fleet, 2) returning the truck to specification, if necessary , and 3) evaluating the in

- use truck using the coastdown procedure. T he manufacturer must provide the agencies with supporting information to perform the confirmation including: identifying a candidate vehicle, providing specifications for that particular model and for that particular vehicle, if possible, based on VIN, an d other information as requested by the agencies. Alternativel y, if the manufacturer has chosen to use an alternative method to determine and provide aerody namic assessment, the agencies may use the manufacturer’s model example for evaluation at some alter native site. For reduced

- scale wind tunnel testing, this would include providing the scale model that the manufacturer used for aerod ynamic assessment to the agencies for evaluation in a different reduced

- scale wind tunnel of the agencies’ choosing. For CFD, the manufacturer would supply the agencies with the CFD software files (e.g., computer aided design and engineering files or CAD/CAE files) of the model to the agencies for anal ys is using some other CFD code of the agencies choosing. In addition, the manufacturers must supply other information as requested b y the agencies to support evaluation of the alternative methods (e.g., test conditions if different than the acceptance demonstration and correlation testing above). (ii) Manufacturer Aerodynamic Assess ment Source Audit/Crosscheck In addition to the aerodynamic assessment confirmation, the agencies reserve the right to also perform an audit of the aerodyn amic assessment method used by the manufacturer. For this audit, the agencies will select a standard reference truck for use in evaluating the manufacturer’s aerodyn amic source. The reference truck will include an actual full size tractor

- trailer combination from the in

- use fleet (vehicle reference truck), a reduced

- scale model of the tractor

- trailer combination (reduced

- scale reference truck), and CFD files of the tractor

- trailer combination (CFD reference truck). The vehicle, reduced

- scale and CFD reference truck would be used by the agencies at the manufacturer’s facility

to evaluate the aerodyn ami c assessment method including: coastdown procedures at the manufacturer’s owned/operated or contracted track , wind tunnel evaluation at manufacturer’s owned/operated or contracted facility , and/or CFDDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

249 of 54 1 software anal ys is at the manufacturer’s facility or us ing the manufacturer’s CFD software program. The manufacturer would be required to allow or arrange access for the agencies to the facility

and/or CFD software for the audit and provide information to support the audit as requested b y the agencies. We are seeking comment on the information the manufacturer must supply to the agencies to support aerodynamic confirmation and source audits, and the use of a reference truck for aerodynamic assessment audits.



### E. Class 2b - 8 Vocational Trucks (1) Proposed Compliance App roach Similar to class 7 and 8 combination tractors, heavy

- dut y vocational vehicles will be required to have both engine and complete vehicle certificates of conformity . As discussed in the engine certification section, engines that will be used in vocati onal vehicles will need to be certified using the FTP cycle for GHG pollutants and show compliance through the useful life of the engine. This certification is in addition to the current requirements for obtaining a certificate of conformity for criteria p ollutant emissions. For this proposal, the majority of the GHG reduction for vocational trucks is expected come from the use of low rolling resistance tires as well as increased utilization of hy brid powertrain s ys tems. Other technologies such as aerody nam ic improvements and vehicle speed limiting s ys tems are not as relevant for this class of vehicles, since the ty pical dut y c yc le is much more urban, consisting of lower speeds and frequent stopping. Idle reduction strategies are expected to be encompassed b y h ybrid technology, which we anticipate will handle power

- take

- off (PTO) operation. Therefore, for these initial rules, certification of heav y - duty vocational vehicles with conventional powertrains will focus on quantifying GHG benefits due to the use of low rolling resistance tires. (a ) Certification Process Vehicles will be divided into test groups for purposes of certification. As with class 7/8 combination tractors, these are groups of vehicles within a given regulatory class that are expected to share c ommon emission characteristics. Vocational truck regulatory

classes share the same structure as those used for heav y - dut y engine criteria pollutant certification and are based on gross vehicle weight ratings (GVWR). For review, this includes light

- heav y (LHD) with a GVWR less than 14,000 lbs, medium

heav y (MHD) with a GVWR greater than (or equal to) 14,000 lbs and less than 26,000 lbs, and heav y - heavy

(HHD) with a GVWR greater than (or equal to) 26,000 lbs. Other test group features may

include the t ype o f tires used, intended application, and number of wheels.250 of 54 1 As with class 7/8 combination tractors, we anticipate using the standardized 12

- digit naming convention to identify vocational truck test groups. As with engines and class 7/8 combination tractors, each certifying vehicle manufacturer will have a unique three digit code assigned to them. Currently , there is no 5 th digit (industry sector) code for this class of vehicles, for which we propose to use the next available character, “3.” Since we are pro posing that the engine is one of several test

- group defining features, we still believe it is appropriate to include engine displacement in the family name. If the test
- group consists includes multiple engine models with varying displacements, the largest would be specified in the test

- group name, consistent with current practices. The remaining characters would remain available for CARB and/or manufacturer use, such that the result is a unique test

- group name. Each test group will need to demonstrate compliance with emission standards using the [TEST] vehicle model approach. Additional provisions are available for certification of hy

brid vehicles or vehicles using unique technologies, which was detailed in Chapter IV. If the test group consists of multi ple models, only result from the worst

case model is necessary

for certification. However, manufacturers will need to submit an engineering evaluation demonstrating that the test group has been assembled appropriatel y and that the test model indeed reflect s the worst

- case model. Also, manufacturers should plan on submitting tire rolling resistance properties to EPA at the time of certification. Finally the data from each of the certification cycles described below will need to be submitted at the time of c ertification. (b ) Demonstrating compliance with the proposed standards (i ) CO2 and Fuel Consumption Standards Model For this stage of the rules, demonstrating compliance with GHG standards primarily involves demonstrating the use of LRR tires and quantifying the a ssociated CO 2 benefit. Similar to class 7/8 combination tractors, this will be done using [TEST]. However, the input parameters entered b y the vehicle manufacturer will be limited to the properties of the tires. [TEST] will use the tire data, along with a baseline truck and engine, to generate a complete vehicle model. The test weight used in the model will be based on the vehicle class, as identified above. Light

- heavy dut y vehicles will have a test weight of 16,000 lbs, 25,150 lbs for medium

- heavy dut y vehicles, and heavy

- heavy dut y vocational vehicles will use a test weight of 67,000 lbs. The model will then be exercised over the HHDDT transient cycle as well as 55 and 65 mph steady

- state cruise conditions. The results of each of the three tests will be weighted at 37%, 21%, and 42% for 65 mph, 55 mph, and transient tests, respectivel y. It may seem more expedient and just as accurate to require manufacturers use tires meeting certain industry standards for qualifying tires as having low rolling resist ance. In addition, CO 2 benefits could be quantified for different ranges of coefficients of rolling resistance to provide a means for comparison to the standard. However, we believe that as technology advances, other aspects of vocational trucks mayDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

251 of 54 1 warrant inclusion in future rulemakings. For this reason, we believe it is important to have the certification framework in place to accommodate such additions. While the modeling approach may

seem to be overl y complicated for this phase of the rules, it also serves to create a certification pathway for future rulemakings and therefore we believe this is the best approach. In
- use Standards The category

of wear items primarily

relates to tires. It is expected that vehicle manufacturers will equip their trucks with low rolling resistance (LRR) tires, as they may provide a substantial reduction in GHG emissions. The tire replacement intervals for this class of vehicle is normally in the range of 50,000 to 100,000 miles, which means the owner/operator will be rep lacing the tires at several points within the useful life of the vehicle. We believe that as LRR tires become more common on new equipment, the aftermarket prices of these tires will also decrease. Along with decreasing tire prices, the fuel savings reali zed through use of LRR tires will ideally provide enough incentive for owner/operators to continue purchasing these tires. The inventory modeling in today 's proposal reflects the continued use of low rolling resistance tires through the life of the vehicl e. We seek comment on this and all aspects of our inventory modeling. (ii) Evaporative Emission Standards Evaporative and refueling emissions from heavy

- duty highway engines and vehicles are currentl y regulated under 40 CFR part 86. Even though these emission standards appl y to the same engines and vehicles that must meet exhaust emission standards, we require a separate certificate for complying with evaporative and refueling emission standards. An important related point to note is that the evaporative and refueling emission standards alway s appl y to the vehicle, while the exhaust emission standards may

appl y to either the engine or the vehicle. For vehicles other than pickups and vans, the standards proposed in this notice to address greenhouse gas emissio ns apply separately to engines and to vehicles. Since we plan to apply both greenhouse gas standards and evaporative/refueling emission standards to vehicle manufacturers, we believe it would be advantageous to have the regulations related to their certif ication requirements written together as much as possible. EPA regards these proposed changes as discrete, minimal, and for the most part clarifications to the existing standards. Except as specifically

proposed here, EPA is not soliciting comment on, or otherwise considering whether to make changes to those standards. Accordingl y, EPA will not consider an y comments directed to any aspect of these standards other than those specifically proposed here. We are generall y not proposing to change the evaporative or refueling emission standards, but we have come across several provisions that warrant clarification or correction:

 When adopting the most recent evaporative emission change we did not carry through the changes to the regulatory text applying evap orative emission standards for methanol

- fueled compression

- ignition engine. The proposed252 of 54 1 regulations correct this by appl yi ng the new standards to all fuels that are subject to standards.  We are proposing provisions to address which standards appl y when an auxiliary (nonroad) engine is installed in a motor vehicle, which is currentl y not directly addressed in the highway regulation. The proposed approach would require testing complete vehicles with any auxiliary engines (and the corresponding fuel

sy stem components). Incomplete vehicles would be tested without the auxiliary engines, but an y such engines and the corresponding fuel

- sy stem components would need to meet the standards that appl y under our nonroad program as specified in 40 CFR part 1060.  We ar e proposing to remove the option for secondary vehicle manufacturers to use a larger fuel tank capacity than is specified by

the certifying manufacturer without re

- certifying the vehicle. Secondary vehicle manufacturers needing a greater fuel tank capacity would need to either work with the certifying manufacturer to include the larger tank, or go through the effort to re

- certify the vehicle itself. Our understanding is that this provision has not been used and would be better handled as part of certification rather than managing a separate process. We are proposing corresponding changes to the emission control information label.  Rewriting the regulations in a new part in conjunction with the greenhouse gas standards allows for some occasions of improved organization and clarit y, as well as updating various provisions. For example, we are proposing a leaner description of evaporative emission families that does not reference sealing methods for carburetors or air cleaners. We are also clarifying how evap orative emission standards affect engine manufacturers and proposing more descriptive provisions related to certifying vehicles above 26,000 pounds GVWR using engineering anal ys is.  Since we adopted evaporative emission standards for gaseous

- fuel vehicles, we have developed new approaches for design

- based certification (see, for example, 40 CFR 1060.240). We request comment on changing the requirements related to certifying gaseous

- fuel vehicles to design

- based certification. This would allow for a simpler assessment for certifying these vehicles without changing the standards that appl y.
(2) Proposed Labeling Provisions It is crucial that a means exist for allowing field inspectors to identify whether a vehicle is certified, and if so, whether it is in the ce rtified configuration. As with engines and tractor trailers, we believe an emission control information (ECI) label is a logical first step in facilitating this identification. For vocational trucks, the engine will have an ECIlabel that is permanently affixed to the engine and identify the engine as certified for use in a certain regulatory subcategory

of vehicle (i.e. MHD, etc). If this label is obscured during installation, a duplicate label will need to be added in a conspicuous location.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

253 of 54 1 The vehi cle will also have an ECI label listing the test group, engine famil y, and range of tire rolling resistances that the vehicle is certified to use. In addition, if any other emission related components are present, such as hy brid powertrains, key component s will also need to be specified on the label. L ike the engine label, this will need to be permanentl y affixed to the vehicle in an area that is clearl y accessible to the owner/operator. (3) Other Certification Issues Warranty As with other heav y - duty engine and vehicle regulatory categories, manufacturers of vocational trucks are required to warrant their product to be free from defects that would adversel y affect emissions. This warranty also covers the failure of emission related components for the useful li fe of the vehicle. For vocational trucks, the two key emission related components addressed in this proposal are the tires and A/C sy stem. Manufacturers of vocational trucks are required to warrant both tires and A/C sy stems to be free from defects at the time of initial sale. As with class 7/8 combination tractors, we expect the vehicle manufacturer to only warrant tires the original tires against manufacturing or design

- related defects. This tire warranty would not cover replacement tires or damage f

rom road hazards or improper inflation. In addition, the vehicle manufacturer is required to warrant the A/C sy stem for the useful life of the vehicle against design or manufacturing defects causing refrigerant leakage in excess of the standard. As with cl ass 7/8 combination tractors, all warranty documentation must be submitted to EPA at the time of certification. This should include the warranty statement provided to the owner/operator, description of the service repair network, list of covered components (both conventional and high

- cost), and length of coverage. Certification Fees Similar to engine and tractor

- trailer vehicle certification, the Agency will assess certification fees for vocational trucks . The proceeds from these fees are used to fund the compliance and certification activities related to GHG regulation for this industry segment. In addition to the certification process, other activities funded b y certification fees include EPA

- administered in

- use testing, selective enforcement audits, and confirmatory

testing. At this point, the exact costs associated with the heavy

- dut y vehicle GHG compliance are not well known. EPA will assess its compliance program associated with this proposal and assess the appropriate level of fees. We anticipate th at fees will be applied based on test groups, following the light

- duty vehicle approach.254 of 54 1



### F. Statutory Prohibited Acts (1) Heavy - Duty Vehicles & Engines Section 203 of the Clean Air Act describes acts that are prohibited by law. This section and associated regul ations appl y equally to the greenhouse gas standards as to an y other regulated emission. Acts that are prohibited by section 203 of the Clean Air Act include the introduction into commerce or the sale of an engine or vehicle without a certificate of confor

mity , removing or otherwise defeating emission control equipment, the sale or installation of devices designed to defeat emission controls, and other actions. In addition, vehicle manufacturers, or an y other party , may not make changes to the certified eng ine that would result in it not being in the certified configuration. EPA proposes to include in the regulations a new section that details these prohibited acts. Prior regulations, such as the NLEV program, had included such a section, and although there is no burden associated with the regulations or any specific need to repeat what is in the Clean Air Act, EPA believes that including this language in the regulations provides clarity and improves the ease of use and completeness of the regulations. (see 40 CFR § 86.1854

– 12). 

### G. NHTSA Enforcement Penalties As part of the fuel efficiency improvement program to be created through this rulemaking, NHTSA is proposing civil penalties for non

- compliance with fuel consumption standards. NHTSA’s authorit y under EI S A, as codified at 49 U.S.C. 32902(k), requires the agency to determine appropriate measurement metrics, test procedures, standards, and compliance and enforcement protocols for HD vehicles. NHTSA interprets its authority to develop an enforcement program to include the authority to determine and assess civil penalties for non

- compliance, that would impose penalties determined based on the discussion that follows. NHTSA proposes that in cases of non

- compliance, the agency would establish civil penalties ba sed on consideration of the following factors:

 Actual fuel consumption performance related to the applicable standard  Estimated cost to comply with the regulation and applicable standard  Quantity

of vehicles or engines not compl yi ng  Manufacturer’s history of non

- compliance  The civil penalt y should act as a deterrent  The financial condition of the manufacturer  Civil penalties paid for non

- compliance of the same vehicles under the EPA GHG programDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

255 of 54 1 NHTSA recognizes that EPA also has authority to impose civil p enalties for non

compliance with GHG regulations. In the case of non

- compliance with fuel consumption regulations, NHTSA intends to give consideration to civil penalties imposed by EPA for GHG non

- compliance. 178 The proposed civil penalty amount NHTSA cou ld impose would not exceed the limit that EPA is authorized to impose under the CAA. The potential maximum civil penalty for a manufacturer would be calculated as follows: Equation V
- 1 : Aggregate Maximum C ivil Penalty Aggregate Maximum Civil Penalty for a Non

- Com pliant Regulatory Class = (CAA Limit) x (production volume within the regulatory class) NHTSA seeks comments related to this proposal for a civil penalty program under EI SA.

178 EPA discussed a similar situation concerning consideration of civil penalties imposed by NHTSA for CAFE violations for light

- duty vehicles, in the final rule establishing the 2012

- 2016 MY standards. See 75 FR 25324, 25482 (May 7, 2010).256 of 54 1



## VI. How Wo uld This Pr oposed Program Impact Fuel Consum ption, GHG

Emissions, and Climate Change? A. What methodologies did the agencies use to project GHG emissions and fuel consumption impacts? EPA and NHTSA used EPA's official mobile source emissions inventory model named Motor Vehicl e Emissions Simulator (MOVES2010) 179 , to estimate emission and fuel consumption impacts of these proposed rules. MOVES has capability to take in user inputs to modify

default data to better estimate emissions for different scenarios, such as different regul atory

alternatives, state implementation plans (SIPs), geographic locations, vehicle activity , and microscale projects. The agencies performed multiple MOVES runs to establish reference case and control case emission inventories and fuel consumption valu es. The agencies ran MOVES with user input databases that reflected characteristics of the proposed rules, such as emissions improvements and recent sales projections. Some post

- processing of the model output was required to ensure proper results. The ag encies ran MOVES for non - GHGs, CO 2 , CH 4 , and N 2 O for calendar ye ars 2005 and 2030. Additional runs were performed for just the three greenhouse gases and for fuel consumption for every calendar year from 2014 to 2050, inclusive, which fed the economy

- wid e modeling, monetized benefits estimation, and climate impacts analy sis. The agencies also used MOVES to estimate emissions and fuel consumption impacts for the other alternatives considered and described in Section IX. 

### B. MOVES Analysis (1) Inputs and assumption s (a ) Reference run updates Since MOVES2010 vehicle sales and activity data were developed from AEO2006, EPA first updated these data using sales and activity estimates from AEO2010. EPA also updated the fuel suppl y information in MOVES to reflect a 100% E10 “gasoline” fuel supply to reflect the Renewable Fuels Standard 180 . MOVES2010 defaults were used for all other parameters to estimate the reference case emissions inventories. (b ) Control run updates EPA developed more user input data for MOVES runs to estimat e control case inventories. The fuel supply update used in the reference case was also used in the

179 MOVES homepage: http://www.epa.gov/otaq/models/moves/index.htm 180 http://www.epa.gov/otaq/fuels/renewab lefuels/index.htmDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

257 of 54 1 control case. To account for improvements of engine and vehicle efficiency, EPA developed several user inputs to run the control case in MOVES. Since MOVE S does not operate based on engine FTP cycle results, EPA used the percent reduction in engine CO 2 emissions expected due to the proposed rules to develop energy inputs for the control case runs. Also, EPA used the percent reduction in aerodynamic drag co efficient and tire rolling resistance coefficient expected from the proposed rules to develop road load input for the control case. Table VI
- 1 and Table VI
- 2 describe the estimated expected reductions fro m these proposed rules, which were input into MOVES for estimating control case emissions inventories. Table VI - 1 : Estim ated reductions in engine CO 2 emission rates fromthese proposed rules GVWR class Fuel M odel y ears CO 2 Reduction from 2010 MY HHD (8a

- 8b) Diesel 2014

- 2016 3% 2017+ 6% MHD (6

- 7) and LHD 4

- 5 Diesel 2014

- 2016 5 % 2017+ 9 % Gasoline 2016+ 5%

Table VI - 2 : Estim ated reductions in rolling resis tance and aerodynamic drag coefficients fromthese proposed rules Truck t ype Reduction in tire rolling resistance coefficient from 2010 MY Reduction in aerodynamic drag coefficient from 2010 MY Combination long

- haul 8.4% 7.2% Combination short

- haul 7.0% 5.3% Straight trucks, refuse trucks, motor homes, transit buses, and other vocational trucks 10.0% 0%

Since nearl y all 2b/3 pickup trucks and vans will be certified on a chassis dy namometer, the CO 2 reductions for these vehicles will not be represented a s engine and road load reduction components , but total vehicle CO 2 reductions . These estimated reductions are described in Table VI
- 3

.258 of 54 1 Table VI - 3 : Estim ated total vehicle CO 2 reducti ons for 2b/3 pickup trucks and vans GVWR class Fuel Model year CO 2 Reduction from reference case LHD 2b

- 3 Gasoline 2014 1.5 % 2015 2 % 2016 4 % 2017 6 % 2018+ 10% Diesel 2014 2.3 %

2015 3 % 2016 6 % 2017 9 % 2018+ 15%



### C. What are the pr ojected reductions in fuel consumption and GHG emissions? EPA and NHTSA expect significant reductions in GHG emissions and fuel consumption from these proposed rules

– emission reductions from both downstream (tailpipe) and upstream (fuel production and distribution) sources, and fuel consumption reductions from more efficient vehicles. Increased vehicle efficiency and reduced vehicle fuel consumption would also reduce GHG emissions from upstream sources. The following subsections summarize the GHG e missions and fuel consumption reductions expected from these proposed rules. (1) Downstream (tailpipe) EPA used MOVES to estimate downstream GHG inventories from these proposed rules. We expect reductions in CO 2 from all heavy

- dut y vehicle classes. The reduc tions come from engine improvements and road load improvements. EPA expects CH 4 and N 2 O emissions to increase very slightly because of VMT rebound and because significant vehicle reductions are not expected from these proposed rules. Overall, downstream GHG emissions (CO 2 eq) will be reduced significantly , and is described in the following subsections. For CO 2 and fuel consumption, the total energy consumption “pollutant” was run in MOVES rather than CO 2 itself. The energy was converted to fuel consumption basedDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

259 of 54 1 on fuel heating values used in the development of MOVES emission and energy rates 181

. These values are 122,893 kJ/gallon for gasoline and 138,451 kJ/gallon for diesel. To calculate CO 2 , the agencies assumed a CO 2 content of 8,887 g/gallon for gasoline and 10,180 g/gallon for diesel. (a ) Model year lifetime Table VI - 4 : Reference case and control case GHG (CO 2 , CH 4 , and N 2 O) reductions and fuel savings

by truck type (2b/3, vocational, and combination) for MY 2014 through 2018 Downstream GHG Reductions (MMT CO 2 eq) 2b3 pickups/vans 21 Vocational 35 Combination short

- haul 45 Combination long

- haul 106 (b ) Calendar year Table VI - 5 : Annual DownstreamGHG Emi ssions Reductions and Fuel Savings in 2018, 2030, and 2050 Downstream GHG Reductions (MMT CO 2 eq) Diesel Savings (million gallons) Gasoline Savings

(million gallons) 2018 20 1,861 71 2030 58 5,412 352 2050 91 8,453 570
(2) Upstream (fuel production and di stribution) Upstream GHG emission reductions associated with the production and distribution of fuel were projected using emission factors from DOE’s “Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation” ( GREET1.8 ) model, with some modi fications consistent with the L ight Duty Greenhouse Gas rulemaking

. More information regarding these modifications can be found in the RIA Chapter 5. These estimates include both international and domestic emission reductions, since reductions in foreign e xports of finished gasoline and/or crude would make up a significant share of the fuel savings resulting from the GHG standards. Thus, significant portions of the upstream GHG emission reductions will occur outside of the U.S.; a breakdown and discussion of projected international versus domestic reductions is

181 MOVES2004 Energy and Emission Inputs. EPA420

- P
- 05

- 003, March 2005. http://www.epa.gov/otaq/models/ngm/420p05003.pdf260 of 54 1

included in the RIA. GHG emission reductions from upstream sources can be found in Table VI
- 6

.

Table VI - 6 : Annual Upstream GHG Em issions Reductions in 2018, 2030, and 2050

CO 2 (MMT) CH 4 (MMT

CO 2 eq) N 2 O (MMT

CO 2 eq) Total GHG (MMT

CO 2 eq) 2018 4.5 0.8 0.02 5.3 2030 12.7 2.0 0.06 14.7 2050 19.8 3.1 0.10 22.9
(3) Total (upstream + downstream)

Table VI - 7 : Annual Total GHG Emissions Reductions and Oil Savings in 2018, 2030, and 2050 GHG Reductions (MMT CO 2 eq) 2018 25 2030 73 2050 114



### D. Overview of Climate Change Impacts from GHG Emissions Once emitted, GHGs that are the subject of thi s regulation can remain in the atmosphere for decades to centuries, meaning that 1) their concentrations become well

mixed throughout the global atmosphere regardless of emission origin, and 2) their effects on climate are long lasting. GHG emissions come mainly from the combustion of fossil fuels (coal, oil, and gas), with additional contributions from the clearing of forests and agricultural activities. T he transportation sector represents a significant portion, 28%, of U

. S

. GHG emissions

. 182 This section p rovides a summary of observed and projected changes in GHG emissions and associated climate change impacts

. The source document for the section below is the Technical Support Document (TSD) 183 for EPA’s Endangerment and Cause or Contribute Findings Under the Clean Air Act. 184 Below is the Executive Summary of

182 U.S. EPA (2009) Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990

–2007. EPA

- 430

- R
- 09

- 004, Washington, DC. 183 “ Technical Support Document for Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act ” Docket: EPA

- HQ

- OAR

- 2009

- 0472

- 11292 184 See 74 FR 66496 (Dec. 15, 2009)

- 8Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

261 of 54 1 the TSD which provides technical support for the endangerment and cause or contribute anal ys es concerning GHG emissions under section 202(a) of the Clean Air Act . The TSD reviews observed and projected ch anges in climate based on current and projected atmospheric GHG concentrations and emissions, as well as the related impacts and risks from climate change that are projected in the absence of GHG mitigation actions, including this proposal and other U.S. and global actions. The TSD was updated and revised based on expert technical review and public comment as part of EPA’s rulemaking process for the final Endangerment Findings

. The key findings sy

nthesized here and the information throughout the TSD are primarily drawn from the assessment reports of the Intergovernmental Panel on Climate Change (IPCC), the U.S. Climate Change Science Program (CCSP), the U.S. Global Change Research Program (USGCRP), and the National Research Council (NRC). 185 In May 2010, the National Research Council (NRC) of the U.S. National Academ y of Sciences published its comprehensive assessment, “Advancing the Science of Climate Change 186 ” (NRC, 2010). It concluded that “climate change is occurring, is caused largel y b y human activities, and poses significant risks for

— and in many

cases is alread y affecting

— a broad range of human and natural sy stems.” Furthermore, the NRC stated that this conclusion is based on findings that are “consistent with the conclusions of recent assessments b y the U.S. Global Change Research Program, the Intergovernmental Panel on Climate Change’s Fourth Assessment Report, and other assessments of the state of scientific knowledge on climate change.” These are the same assessments that served as the primary scie ntific references underl yi ng the Administrator’s Endangerment Finding. Importantly , this recent NRC assessment represents another independent and critical inquiry of the state of climate change science, separate and apart from the previous IPCC and U.S. G lobal Change Research Program (USGCRP) assessments. The NRC assessment is a clear affirmation that the scientific underpinnings of the Administrator’s Endangerment Finding are robust, credible, and appropriatel y characterized by EPA. (1) Observed Trends in Gr eenhouse Gas Emissions and Concentrations The primary

long

- lived GHGs directl y emitted by human activities include carbon dioxide (CO 2 ), methane (CH 4 ), nitrous oxide (N 2 O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF 6 ). Greenhouse gases have a warming effect b y trapping heat in the atmosphere that would otherwise escape to space. In 2007, U.S. GHG emissions were 7,150 teragrams 187 of CO 2 equivalent 188 (TgCO 2 eq).

185 For a complete list of core references from IPCC, USGCRP/CCSP, NRC and others relied upon for development of the TSD for EPA’s Endangerment and Cause or Contribute Findings see section 1(b), specifically, Table 1.1 of the TSD. 186 National Research Council (NRC) (2010). Advancing the Science of Climate Change. National Academy Press

. Washington, DC. 187 One teragram (Tg) = 1 million metric tons. 1 metric ton = 1,000 kilograms = 1.102 short tons = 2,205 pounds. 188 Long
- lived GHGs are compared and summed together on a CO 2 - equivalent basis by multi plying each gas by its global warming potential (GWP), as estimated by IPCC. In accordance with United Nations262 of 54 1

The dominant gas emitted is CO 2 , mostly from fossil fuel combu stion. Methane is the second largest component of U.S. emissions, followed b y N 2 O and the fluorinated gases (HFCs, PFCs, and SF 6 ). Electricity generation is the largest emitting sector (34% of total U.S. GHG emissions), followed by transportation (28%) and industry (19%). Transportation sources under Section 202 (a) 189 of the Clean Air Act (passenger cars, light duty

trucks, other trucks and buses, motorcycles, and passenger cooling) emitted 1,649 TgCO 2 eq in 2007, representing 23% of total U.S. GHG emissio ns. U.S. transportation sources under Section 202 (a) made up 4.3% of total global GHG emissions in 2005, 190 which, in addition to the United States as a whole, ranked onl y behind total GHG emissions from China, Russia, and India but ahead of Japan, Brazil, G erman y, and the rest of the world’s countries. In 2005, total U.S. GHG emissions were responsible for 18% of global emissions, ranking only behind China, which was responsible for 19% of global GHG emissions. Th e scope of this proposal focuses on GHG emis sions under Section 202(a) from heavy

- dut y source categories (see Section VI.C)

. The global atmospheric CO 2 concentration has increased about 38% from pre

industrial levels to 2009, and almost all of the increase is due to anthropogenic emissions. The g lobal atmospheric concentration of CH 4 has increased by 149% since pre

- industrial levels (through 2007); and the N 2 O concentration has increased b y 23% (through 2007). The observed concentration increase in these gases can also be attributed primarily to anthropogenic emissions. The industrial fluorinated gases, HFCs, PFCs, and SF 6 , have relativel y low atmospheric concentrations but the total radiative forcing due to these gases is increasing rapidly ; these gases are almost entirely anthropogenic in origin

. Historic data show that current atmospheric concentrations of the two most important directly

emitted, long

- lived GHGs (CO 2 and CH 4 ) are well above the natural range of atmospheric concentrations compared to at least the last 650,000 years. Atmospheri c GHG concentrations have been increasing because anthropogenic emissions have been outpacing the rate at which GHGs are removed from the atmosphere b y natural processes over timescales of decades to centuries. (2) Observed Effects Associated With Global Eleva ted Concentrations of GHGs Current ambient air concentrations of CO 2 and other GHGs remain well below published exposure thresholds for an y direct adverse health effects, such as respiratory or toxic effects.

Fram ew ork Convention on Climate Change (UNFCCC) reporting procedures, the U.S. quantifies GHG emissions using the 100

- year timeframe values for GWPs established in the IPCC Second Assessment Report. 189 Source categories under Section 202(a) of the Clean Air Act are a subset of source categories considered in the transportation sector and do not include emissions from non

- highway sources such as boats, rail, aircraft, agricultural equipment, construction/mining equipment, and other off

- road equipment. 190 More recent emission data are available for the United States and other individual countries, but 2005 is the most recent year for which data for all countries and all gases are available.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

263 of 54 1 The global average net effect of the increase i n atmospheric GHG concentrations, plus other human activities (e.g., land

- use change and aerosol emissions), on the global energy balance since 1750 has been one of warming. This total net heating effect, referred to as forcing, is estimated to be +1.6 (+ 0.6 to +2.4) watts per square meter (W/m 2 ), with much of the range surrounding this estimate due to uncertainties about the cooling and warming effects of aerosols. However, as aerosol forcing has more regional variability

than the well

- mixed, long

- lived GHGs, the global average might not capture some regional effects. The combined radiative forcing due to the cumulative (i.e., 1750 to 2005) increase in atmospheric concentrations of CO 2 , CH 4 , and N 2 O is estimated to be +2.30 (+2.07 to +2.53) W/m2 . The rat e of increase in positive radiative forcing due to these three GHGs during the industrial era is very likely to have been unprecedented in more than 10,000 years. Warming of the climate system is unequivocal, as is now evident from observations of increase s in global average air and ocean temperatures, widespread melting of snow and ice, and rising global average sea level. Global mean surface temperatures have risen by 1.3 ± 0.32  F (0.74°C ± 0.18  C) over the last 100 years. Eight of the 10 warmest y ears on record have occurred since 2001. Global mean surface temperature was higher during the last few decades of the 20th century than during any comparable period during the preceding four centuries. Most of the observed increase in global average temperatures since the mid

- 20th century is very likel y due to the observed increase in anthropogenic GHG concentrations. Climate model simulations suggest natural forcing alone (i.e., changes in solar irradiance) cannot explain the observed warming. U.S. tempe ratures also warmed during the 20 th and into the 21 st century ; temperatures are now approximately 1.3°F (0.7°C) warmer than at the start of the 20 th century , with an increased rate of warming over the past 30 years. Both the IP CC 191 and the CCSP reports attributed recent North American warming to elevated GHG concentrations. In the CCSP (2008) report, 192 the authors find that for North America, “more than half of this warming [for the period 1951

- 2006] is likely the result of human

caused greenhouse gas forci ng of climate change.” Observations show that changes are occurring in the amount, intensity , frequency and ty pe of precipitation. Over the contiguous United States, total annual precipitation increased b y 6.1% from 1901 to 2008. It is likely that ther e have been increases in the

191 Hegerl, G.C. et al. (2007) Understanding and Attributing Climate Change. In: Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor, and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. 192 CCSP (2008) Reanalysis of Historical Climate Data for Key Atmospheric Features: Implications for Attribution of Causes of Observed Change . A Report by the U.S. Climate Change Science Program and the Subcommittee on Global Change Research [Randall Dole, Martin Hoerling, and Siegfried Schubert (eds.)]. National Oceanic and Atmospheric Administration, National Climatic Data Center, Asheville, NC, 156 pp.264 of 54 1

number of heav y precipitation events within many land regions, even in those where there has been a reduction in total precipitation amount, consistent with a warming climate. There is strong evidence that global sea level gradually rose in the 20 th century and is currentl y rising at an increased rate. It is not clear whether the increasing rate of sea level rise is a reflection of short

- term variability or an increase in the longer

- term trend. Nearl y all of the Atlantic Ocean shows sea level rise during the last 50 years with the rate of rise reaching a maximum (over 2 millimeters [mm] per year) in a band along the U.S. east coast running east

- northeast

. Satellite data since 1979 show that annual average Arctic sea ice extent has shrunk by 4.1% per decade. The size and speed of recent Arctic summer sea ice loss is highl y anomalous relative to the previous few thousands of years. Widespread changes in extreme temperatures have been observed in the last 50 ye ars across all world regions, including the United States. Cold day s, cold nights, and frost have become less frequent, while hot day s, hot nights, and heat waves have become more frequent. Observational evidence from all continents and most oceans shows that many natural s y stems are being affected by regional climate changes, particularly temperature increases. However, directly attributing specific regional changes in climate to emissions of GHGs from human activities is difficult, especially for precipitation. Ocean CO 2 uptake has lowered the average ocean pH (increased acidity) level by approximately

0.1 since 1750. Consequences for marine ecos ys tems can include reduced calcification by

shell

- forming organisms, and in the longer term, the dissolution of carbonate sedime nts. Observations show that climate change is currently affecting U.S. phy sical and biological s ys tems in significant way s. The consistency of these observed changes in phy sical and biological sy stems and the observed significant warming likely cannot be e xplained entirely

due to natural variability or other confounding non

- climate factors. (3) Projections of Future Climate Change w ith Continued Increases in Elevated GHG Concentrations Most future scenarios that assume no explicit GHG mitigation actions (beyond those already enacted) project increasing global GHG emissions over the century , with climbing GHG concentrations. Carbon dioxide is expected to remain the dominant anthropogenic GHG over the course of the 21 st century . The radiative forcing associated with the non

- CO 2 GHGs is still significant and increasing over time.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

265 of 54 1 Future warming over the course of the 21 st century, even under scenarios of low

emission growth, is very

likely to be greater than observed warming over the past century
. According to c limate model simulations summarized by the IPCC , 193 through about 2030, the global warming rate is affected little by the choice of different future emissions scenarios. By

the end of the 21 st century , projected average global warming (compared to average t emperature around 1990) varies significantl y depending on the emission scenario and climate sensitivity assumptions, ranging from 3.2 to 7.2  F (1.8 to 4.0  C), with an uncertainty range of 2.0 to 11.5  F (1.1 to 6.4  C). All of the United States is very likel y to warm during this century, and most areas of the United States are expected to warm by more than the global average. The largest warming is projected to occur in winter over northern parts of Alaska. In western, central and eastern regions of North America, the projected warming has less seasonal variation and is not as large, especially near the coast, consistent with less warming over the oceans. It is very likel y that heat waves will become more intense, more frequent, and longer lasting in a future warm climate, whereas cold episodes are projected to decrease significantl y. In creases i n the amount of precipitation are very likely in higher latitudes, while decreases are likel y in most subtropical latitudes and the southwestern United States, cont inuing observed patterns. The mid

- continental area is expected to experience drying during summer, indicating a greater risk of drought. Intensit y of precipitation events is projected to increase in the United States and other regions of the world. More intense precipitation is expected to increase the risk of flooding and result in greater runoff and erosion that has the potential for adverse water quality effects. It is likel y that hurricanes will become more intense, with stronger peak winds and more heavy

precipitation associated with ongoing increases of tropical sea surface temperatures. Frequency changes in hurricanes are currently too uncertain for confident projections. By the end of the century, global average sea level is projected b y IPCC 194 t o rise between 7.1 and 23 inches (18 and 59 centimeter [cm]), relative to around 1990, in the absence of increased dyn amic ice sheet loss. Recent rapid changes at the edges of the

193 Meehl, G.A. et al. (2007) Global Climate Projections. In: Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. 194 IPCC (2 007) Summary for Policymakers. In: Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.266 of 54 1

Greenland and West Antarctic ice sheets show acceleration of flow and thinni ng. While an understanding of these ice sheet processes is incomplete, their inclusion in models would likely

lead to increased sea level projections for the end of the 21 st century
. Sea ice extent is projected to shrink in the Arctic under all IPCC emis sions scenarios. (4) Projected Risks and Impacts Associated With Future Climate Change Risk to society , ecos ys tems, and many natural Earth processes increase with increases in both the rate and magnitude of climate change. Climate warming may increase the p ossibility

of large, abrupt regional or global climatic events (e.g., disintegration of the Greenland Ice Sheet or collapse of the West Antarctic Ice Sheet). The partial deglaciation of Greenland (and possibly West Antarctica) could be triggered by a sust ained temperature increase of 2 to 7  F (1 to 4oC) above 1990 levels. Such warming would cause a 13 to 20 feet (4 to 6 meter) rise in sea level, which would occur over a time period of centuries to millennia. The CCSP 195 reports that climate change has the p otential to accentuate the disparities already evident in the American health care s ys tem, as many of the expected health effects are likel y to fall disproportionatel y on the poor, the elderly , the disabled, and the uninsured. The IPCC 196 states with very h igh confidence that climate change impacts on human health in U.S. cities will be compounded by population growth and an aging population. Severe heat waves are projected to intensify in magnitude and duration over the portions of the United States where these events already occur, with potential increases in mortality and morbidity , especiall y among the elderly, young, and frail. Some reduction in the risk of death related to extreme cold is expected. It is not clear whether reduced mortality from col d will be greater or less than increased heat

related mortalit y in the United States due to climate change. I ncreases in regional ozone pollution relative to ozone levels without climate change are expected due to higher temperatures and weaker circulat ion in the United States and other world cities relative to air quality levels without climate change. Climate change is expected to increase regional ozone pollution, with associated risks in

195 Ebi, K.L., J. Balbus, P.L. Kinney, E. Lipp, D. Mills, M.S. O’Neill, and M. Wilson (2008) Effects of Global Change on Human Health. In : Analyses of the effects of global change on human health and welfare and human systems . A Report by the U.S. Climate Change Science Program and the Subcommittee on Global Change Research. [Gamble, J.L. (ed.), K.L. Ebi, F.G. Sussman, T.J. Wilbanks, (Autho rs)]. U.S. Environmental Protection Agency, Washington, DC, USA, pp. 2

- 1 to 2

- 78. 196 Field, C.B. et al. (2007) North America. In: Climate Change 2007: Impacts, Adaptation and Vulnerability. Contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E. Hanson (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

267 of 54 1 respiratory

illnesses and premature death. In addition to hum an health effects, tropospheric ozone has significant adverse effects on crop yi elds, pasture and forest growth, and species composition. The directional effect of climate change on ambient particulate matter levels remains uncertain. Within settlements experiencing climate change, certain parts of the population may be especially

vulnerable; these include the poor, the elderl y, those already in poor health, the disabled, those living alone, and/or indigenous populations dependent on one or a few resource s. Thus, the potential impacts of climate change raise environmental justice issues. The CCSP 197 concludes that, with increased CO 2 and temperature, the life cycle of grain and oilseed crops will likely progress more rapidly . But, as temperature rises, the se crops will increasingl y begin to experience failure, especiall y if climate variability increases and precipitation lessens or becomes more variable. Furthermore, the marketable yi eld of many horticultural crops (e.g., tomatoes, onions, fruits) is very likel y to be more sensitive to climate change than grain and oilseed crops. Higher temperatures will very likely reduce livestock production during the summer season in some areas, but these losses will very likely be partially

offset by warmer temperature s during the winter season. Cold

- water fisheries will likely be negativel y affected; warm

- water fisheries will generall y benefit; and the results for cool

- water fisheries will be mixed, with gains in the northern and losses in the southern portions of ran ges. Climate change has very

likely increased the size and number of forest fires, insect outbreaks, and tree mortality in the interior West, the Southwest, and Alaska, and will continue to do so. Over North America, forest growth and productivity have bee n observed to increase since the middle of the 20 th century , in part due to observed climate change. Rising CO 2 will very likely increase photosy

nthesis for forests, but the increased photosy nthesis will likely

only increase wood production in young fores ts on fertile soils. The combined effects of expected increased temperature, CO 2 , nitrogen deposition, ozone, and forest disturbance on soil processes and soil carbon storage remain unclear. Coastal communities and habitats will be increasingl y stressed b y climate change impacts interacting with development and pollution. Sea level is rising along much of the U.S. coast, and the rate of change will very likel y increase in the future, exacerbating the impacts of progressive inundation, storm

- surge flooding , and shoreline erosion. Storm impacts are likel y to be more severe, especiall y along the Gulf and Atlantic coasts. Salt marshes, other coastal habitats, and dependent species are threatened b y sea level rise,

197 Backlund, P., A. Janetos, D.S. Schimel, J . Hatfield, M.G. Ryan, S.R. Archer, and D. Lettenmaier (2008) Executive Summary. In: The Effects of Climate Change on Agriculture, Land Resources, Water Resources, and Biodiversity in the United States. A Report by the U.S. Climate Change Science Program and the Subcommittee on Global Change Research. Washington, DC., USA, 362 pp.268 of 54 1

fixed structures blocking landward migration , and changes in vegetation. Population growth and rising value of infrastructure in coastal areas increases vulnerability to climate variability

and future climate change. Climate change will likely further constrain already overallocated water resources in some regions of the United States, increasing competition among agricultural, municipal, industrial, and ecological uses. Although water management practices in the United States are generally advanced, particularl y in the West, the reliance on past c onditions as the basis for current and future planning may no longer be appropriate, as climate change increasingl y creates conditions well outside of historical observations. Rising temperatures will diminish snowpack and increase evaporation, affecting s easonal availability

of water. In the Great Lakes and major river s ys tems, lower water levels are likely to exacerbate challenges relating to water quality , navigation, recreation, hydropower generation, water transfers, and binational relationships. Dec reased water supply and lower water levels are likely to exacerbate challenges relating to aquatic navigation in the United States. Higher water temperatures, increased precipitation intensity , and longer periods of low flows will exacerbate man y forms o f water pollution, potentially making attainment of water quality

goals more difficult. As waters become warmer, the aquatic life they now support will be replaced b y other species better adapted to warmer water. In the long term, warmer water and changi ng flow may result in deterioration of aquatic ecos ys tems. Ocean acidification is projected to continue, resulting in the reduced biological production of marine calcifiers, including corals. Climate change is likely

to affect U.S. energy

use and energy production and phy sical and institutional infrastructures. It will also likely interact with and possibly exacerbate ongoing environmental change and environmental pressures in settlements, particularl y in Alaska where indigenous communities are facing m ajor environmental and cultural impacts. The U.S. energy sector, which relies heavil y on water for hydropower and cooling capacit y, may be adversel y impacted by changes to water supply and quality in reservoirs and other water bodies. Water infrastructure, including drinking water and wastewater treatment plants, and sewer and stormwater management s ys tems, will be at greater risk of flooding, sea level rise and storm surge, low flows, and other factors that could impair performance. Disturbances such as wi ldfires and insect outbreaks are increasing in the United States and are likel y to intensify in a warmer future with warmer winters, drier soils, and longer growing seasons. Although recent climate trends have increased vegetation growth, continuing incre ases in disturbances are likely to limit carbon storage, facilitate invasive species, and disrupt ecosystem services. Over the 21 st century , changes in climate will cause species to shift north and to higher elevations and fundamentally rearrange U.S. ec osy stems. Differential capacities for range shifts and constraints from development, habitat fragmentation, invasiveDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

269 of 54 1 species, and broken ecological connections will alter ecos ys tem structure, function, and services. Climate change impacts will vary in nature and magnitude across different regions of the United States. Sustained high summer temperatures, heat waves, and declining air quality are projected in the Northeast, 198 Southeast, 199 Southwest, 200 and Midwest. 201 Projected climate change would continue to cause loss of sea ice, glacier retreat, permafrost thawing, and coastal erosion in Alaska. Reduced snowpack, earlier spring snowmelt, and increased likelihood of seasonal summer droughts are projected in the Northeast, Northwest, 202 and Alaska. More sever e, sustained droughts and water scarcit y are projected in the Southeast, Great Plains, 203 and Southwest. The Southeast, Midwest, and Northwest in particular are expected to be impacted by an increased frequency

of heavy downpours and greater flood risk. E cosy stems of the Southeast, Midwest, Great Plains, Southwest, Northwest, and Alaska are expected to experience altered distribution of native species (including local extinctions), more frequent and intense wildfires, and an increase in insect pest outbreaks and invasive species. Sea level rise is expected to increase storm surge height and strength, flooding, erosion, and wetland loss along the coasts, particularly in the Northeast, Southeast, and islands. Warmer water temperatures and ocean acidificat ion are expected to degrade important aquatic resources of islands and coasts such as coral reefs and fisheries. A longer growing season, low levels of warming, and fertilization effects of carbon dioxide may

benefit certain crop species and forests, part icularl y in the Northeast and Alaska

. Projected summer rainfall increases in the Pacific islands may augment limited freshwater supplies. Cold

- related mortality is projected to decrease, especiall y in

198 Northeast includes West Virginia, Maryland, Delaware, Pennsylvania, New Jersey, Ne w York, Connecticut, Rhode Island, Massachusetts, Vermont, New Hampshire, and Maine. 199 Southeas t includes Kentucky, Virginia, Arkansas, Tennessee, North Carolina, South Carolina, southeast Texas, Louisiana, Mississippi, Alabama, Georgia, and Florida. 200 Southwest includes California, Nevada, Utah, western Colorado, Arizona, New Mexico (except the extreme eastern section), and southwest Texas. 201 The Midwest includes Minnesota, Wisconsin, Michigan, Iowa, Illinois, Indiana, Ohio, and Missouri. 202 The Northwest includes Washington, Idaho, w estern Montana, and Oregon. 203 The Great Plains includes central and eastern Montana, North Dakota, South Dakota, Wyoming, Nebraska, eastern Colorado, Nebraska, Kansas, extreme eastern New Mexico, central Texas, and Oklahoma270 of 54 1

the Southeast . In the Midwest in particular, heating oil demand and snow

- related traffic accidents are expected to decrease. Climate change impacts in certain regions of the world may exacerbate problems that raise humanitarian, trade, and national security issues for the United States. The IPCC 204 identifie s the most vulnerable world regions as the Arctic, because of the effects of high rates of projected warming on natural s ys tems; Africa, especially the sub

- Saharan region, because of current low adaptive capacit y as well as climate change; small islands, d ue to high exposure of population and infrastructure to risk of sea level rise and increased storm surge; and Asian mega

- deltas, such as the Ganges

- Brahmaputra and the Zhujiang, due to large populations and high exposure to sea level rise, storm surge and river flooding. Climate change has been described as a potential threat multiplier with regard to national security issues. 

### E. Changes in Atmospheric CO2 Concentrations, Global Mean Temperature, Sea Level Rise , and Ocean pH Associated with the Proposal’s GHG Emissions Reductions EPA examined205 the reductions in CO 2 and other GHGs associated with th is proposal and analyzed the projected effects on atmospheric CO2 concentrations, global mean surface temperature , sea level rise , and ocean pH which are common vari ables used as indicators of climate change. The anal ys is projects that th is proposal will reduce atmospheric concentrations of CO2, global climate warming and sea level rise. Although the projected reductions are small in overall magnitude by themselves, they are quantifiable and would contribute to reducing the risks associated with climate change. EPA therefore determines that the projected reductions in atmospheric CO 2 , global mean temperature and sea level rise are meaningful in the context of this proposal. For this proposal, EPA has provided an anal ys is for projected changes in ocean pH in the context of the changes in emissions from this proposal. Based on this anal yses, the results for projected atmospheric CO 2 concentrations are estimated to b e reduced by an average of XXX ppm, global mean temperature is estimated to be reduced by XXX to XXX °C by

2100 and sea

- level rise is projected to be reduced by approximately XXX

– XXX cm by

2100.

204 Parry, M.L. et al. (2007) Technical Summary. In: Climate Change 2007: Impacts, Adaptation and Vul nerability. Contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [ M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden, and C.E. Hanson (eds.)], Cambridge University Press, Cambridge, United Kingdom, pp. 23 S 78. 205 Using the Model for the Assessment of Greenhouse Gas Induced Climate Change (MAGICC, http://www.cgd.ucar.edu/cas/wigley/magicc/), EPA estimated the effects of this proposal’s greenhouse gas emissions reductions on global mean te mperature and sea level. Please refer to Chapter 8.4 of the RIA for additional information.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

271 of 54 1 (1) Estimated Projected Reductions in Atmospheric CO 2 Concent ration, Global Mean Surface Temperatures , Sea Level Rise , and Ocean pH EPA estimated changes in the atmospheric CO 2 concentration, global mean surface temperature , sea level, and ocean pH out to 2100 resulting from the emissions reductions in this proposal using the Model for the Assessment of Greenhouse Gas Induced Climate Change (MAGICC, version 5.3). This widely

- used, peer reviewed modeling tool was also used to project temperature and sea level rise under different emissions scenarios in the Third and F ourth Assessments of the Intergovernmental Panel on Climate Change (IPCC). GHG emissions reductions from Section VI .C were applied as net reductions to a peer reviewed global reference case (or baseline) emissions scenario to generate an emissions scenari o specific to this proposal . For th e scenario related to this proposal , all emissions reductions were assumed to begin in 20 14 , with zero emissions change in 2013 (from the reference case) followed b y emissions linearl y increasing to equal the va lue suppl ied in Section VI .C for 20 18 and then continuing to 2100. Details about the reference case scenario and how the emissions reductions were applied to generate the scenario can be found in the proposal’s RIA , Chapter 8

. Changes in atmospheric CO 2 concentrat ion, temperature , and sea level for both the reference case and the emissions scenarios associated with this proposal were computed using MAGI CC. To c alculate the reductions in the atmospheric CO 2 concentrations as well as in temperature and sea level resu lting from this proposal , the output from the scenario associated with th e s e proposed rule s was subtracted from an existing Global Change Assessment Model (GCAM, formerl y MiniCAM ) reference emission scenario. To capture some key uncertainties in the climat e sy stem with the MAGI CC model, changes in temperature and sea level rise were projected across the most current IPCC range for climate sensitivities which ranges from 1.5°C to 6.0°C (representing the 90% confidence interval)

. 206 This wide range reflects th e uncertaint y in this measure of how much the global mean temperature would rise if the concentration of carbon dioxide in the atmosphere were to double. Details about this modeling anal ys is can be found in the RIA Chapter 8.4

. The results of this modelin g , summarized in Table VI
- 8 , show small, but quantifiable, reduction s in atmospheric CO 2 concentrations, projected global mean surface temperature and sea level resulting from this proposal , across all climate sensitivities. As a result of the emission reductions from this proposal, the atmospheric CO 2 concentration is projected to be reduced b y an average of XXX parts per million

206 In IPCC reports, equilibrium climate sensitivity refers to the equilibrium change in the annual mean global surface temperature following a doubling of the atmos pheric equivalent carbon dioxide concentration. The IPCC states that climate sensitivity is “likely” to be in the range of 2°C to 4.5°C, “very unlikely” to be less than 1.5°C, and “values substantially higher than 4.5°C cannot be excluded.” IPCC WGI, 2007, Climate Change 2007

- The Physical Science Basis, Contribution of Working Group I to the Fourth Assessment Report of the IPCC, http://www.ipcc.ch /272 of 54 1

(ppm) , the global mean temperature is projected to be reduced b y approximately XXX
XXX °C by

2100 , and global mean sea level rise is projected to be reduced by approximately XXX
- XXX cm by 2100. The reductions are small relative to the IPCC’s 2100 “best estimates” for global mean temperature increases (1.8

– 4.0oC) and sea level rise (0.20

- 0.59m) for all gl obal GHG emissions sources for a range of emissions scenarios

. EPA used a peer reviewed model, the MAGI CC model, to do this analy sis. Further discussion of EPA’s modeling anal ys is is found in the draft RIA. Table VI - 8 : Effect of GHG Emissions Reductions On Projected Changes in Global Clim ate for the

Proposal (for clim ate sensitivities ranging from1.5 - 6°C) Measure Units Year Projected Change Atmospheric CO 2 Concentration ppm 2100
Global Mean Surface Temper ature o C 2100
Sea Level Rise cm 2100 Ocean pH pH units 2 100 As a substantial portion of CO 2 emitted into the atmosphere is not removed by natural processes for millennia, each unit of CO 2 not emitted into the atmosphere avoids essentially

permanent climate change on centennial time scales. Though the magnitude of the avoided climate change projected here is small, these reductions would represent a reduction in the adverse risks associated with climate change (though these risks were not formally es timated for this proposal ) across all climate sensitivities. The IPCC 207 has noted that ocean acidification due to the direct effects of elevated CO 2 concentrations will impair a wide range of planktonic and other marine organisms that use aragonite to mak e their shells or skeletons. EPA used the Program CO2SYS, 208 version 1.05 to estimate projected changes in tropical ocean pH based on the atmospheric CO 2 concentration reductions resulting from this proposal. The program performs calculations relating param eters of the carbon dioxide (CO 2 ) sy stem in seawater. EPA used the program to calculate ocean pH as a function of atmospheric CO 2 , among other specified input conditions. Based on the projected atmospheric CO 2 concentration reductions ( average of XX ppm by 2100 ) that would result from this proposal, the program calculates an increase in ocean pH of about 0.00 XX pH units in 2100. Thus, this

207 Fischlin, A. et al. (2007) Ecosystems, their Properties, Goods, and Services. In: Climate Change 2007: Imp acts, Adaptation and Vulnerability . Contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E. Hanson (eds.)]. Cambridge Univers ity Press, Cambridge, United Kingdom and New York, NY, USA. 208 Lewis, E., and D. W. R. Wallace. 1998. Program Developed for CO 2 System Calculations. ORNL/CDIAC

- 105. Carbon Dioxide Information Analysis Center, Oak Ridge National Laboratory, U.S. Department o f Energy, Oak Ridge, Tennessee.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

273 of 54 1 anal ys is indicates the projected decrease in atmospheric CO 2 concentrations from today ’s proposal would result in an in crease in ocean pH. EPA’s anal ys is of the proposed rules ’ effect on global climate conditions is intended to quantify

these potential reductions using the best available science. While EPA’s modeling results of the effect of this proposal alone show smal l differences in climate effects (CO 2 concentration, temperature, sea

- level rise, ocean pH ) , when expressed in terms of global climate endpoints and global GHG emissions, they yield results that are repeatable and consistent within the modeling frameworks us ed.


## VII. How Wo uld This Pr oposal Im pact Non - GHG Emissions and Their

A ssociated Effects? A. Emissions Inventory Impacts (1) Upstream Impacts of the Program In creasing efficiency in heavy

- dut y vehicles would result in reduced fuel demand and therefore reductions in the emissions associated with all processes involved in getting petroleum to the pump. These projected upstream emission impacts on criteria pollutants are summarized in Table VII
- 1 . The upstream reducti ons would grow over time as the fleet turns over to cleaner CO 2 vehicles, so that by 2030 VOC would decrease by 4,272 tons, NO X by 9,856 tons, CO by 3,277 tons and PM 2.5 by 1,348 tons. Table VII
- 2 shows the corresponding projecte d impacts on upstream air toxic emissions in 2030. Formaldeh yd e would decrease b y XX tons, benzene by XX tons, acetaldehyde by XX tons, acrolein b y XX tons, and 1,3

- butadiene b y XX tons.274 of 54 1 Table VII - 1 : Overall estim ated upstream impacts on criteria pollutants for calendar years 2018, 2030, and 2050 (short tons) Calendar Year NO X VOC CO PM2.5 2018

- 5 ,710

- 1 ,639

- 1,954

- 855 2030

- 9 ,856

- 4 ,272

- 3,277

- 1,348 2050

- 15 ,421

- 6 ,778

- 5,127

- 2,108

Table VII - 2 : Overall estim ated upstream impacts on air toxics for calendar years 2018, 2030, and 2050 (short tons) Calendar Year Benzene 1,3

- butadiene Formaldeh yd e Acetaldeh yd e Acrolein 2018 2030 2050 To p roject these impacts, EPA estimated the impact of reduced petroleum volumes on the extraction and transportation of crude oil as well as the production and distribution of finished gasoline and diesel . For the purpose of assessing domestic

- only emission re ductions it was necessary to estimate the fraction of fuel savings attributable to domestic finished gasoline and diesel , and of this fuel what fraction is produced from domestic crude. For this anal ys is EPA estimated that 50 percent of fuel savings is attributable to domestic finished gasoline and diesel and that 90 percent of this gasoline and diesel originated from imported crude. Emission factors for most upstream emission sources are based on the GREET1.8 model, developed by DOE’ s Argonne National Labo ratory but in some cases the GREET values were modified or updated by EPA to be consistent with the National Emission Inventory (NEI)

. These updates are consistent with those used for the upstream analy sis included in the L ight Dut y Greenhouse Gas rulemaki ng. More information on the development of the emission factors used in this anal ys is can be found in draft RIA Chapter XX. (2) Downstream Impacts of the Program While these proposed rules do not regulate non

- GHG pollutants, EPA expects reductions in downstream emissions of most non

- GHG pollutants. These pollutants include NO X , SO 2 , CO, and HC. The primary reason for this is the improvements in road load (aerod ynamics and tire rolling resistance for Class 7 and Class 8 vehicles) proposed in this proposal. Ano ther reason is that emissions from certain pollutants (e.g. SO 2 ) are proportional to fuel consumption. For vehicle t yp es not affected b y road load improvements, non

- GHG emissions may increase very

slightl y due to VMT rebound. EPA also anticipates the u se of auxiliary power units (APUs) in combination long

- haul trucks for GHG reduction purposes during extended idling. These units exhibit different non - GHG emissions characteristics compared to the on

- road engines they would replace during extended idling . EPA used MOVES to determine non

- GHG emissions inventories for reference and control cases. The improvements in road load, use of APUs, and VMT rebound were included in the MOVES runs and post

- processing.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

275 of 54 1 Table VII - 3 : Overall estim ated downstreamimpacts on criteria pollutants for calendar years 2018, 2030, and 2050. Most of the reductions are through projected increased APU use. Calendar Year Downstream

NO X (short tons) Downstream VOC

(short tons) Downstre am

CO (short tons) Downstream

PM2.5 (short tons) 2018

- 96,764

- 22,004

- 23,329 662* 2030

- 231,631

- 52,577

- 53,709 1,568 2050

- 326,491

- 74,157

- 75,083 2,210 *Note: Positive number means an emissions increase from reference case to control case. For PM2. 5, the projected widespread use of APUs leads to higher PM 2.5 , as APUs are required meet much less stringent PM 2.5 standards than on

- road engines.

Table VII - 4 : Overall estim ated downstreamimpacts on air toxi cs for calendar years 2018, 2030, and 2050 (short tons) Calendar Year Benzene 1,3

- butadiene Formaldeh yd e Acetaldeh yd e Acrolein 2018 2030 2050 (3) Total Impacts of the Program As shown in Table VII
- 5 , the agencies es timate that this program would result in reductions of NO X , VOC, CO, and SO X . For NO X , VOC, and CO, much of the net reductions are realized through the use of APUs, which emit these pollutants at a lower rate than on

- road engines during extended idle oper ation. The downstream increase in PM 2.5 due to APU use is mostly negated by

upstream PM 2.5 reductions, though our calculations show a slight net increase in 2030 and 2050. Additional reductions are achieved in all pollutants through reduced road load (improved aerod ynam ics and tire rolling resistance), which reduces the amount of work required to travel a given distance. For SO X , downstream emissions are roughly proportional to fuel consumption; therefore a decrease is seen in both upstream and downstream sources.276 of 54 1

CY NO X VOC CO PM 2.5 short tons % short tons % short tons % short tons % 2018

- 102,474

- 5.0%

- 23,643

- 7.6%

- 25,283

- 0.79%

- 193

- 0.26% 2030

- 241,487

- 19.6%

- 56,849

- 27.0%

- 56,986

- 2.13% 220 0.75% 2050

- 341,912

- 21.6%

- 80,935

- 30.7%

- 80, 210

- 2.47% 102 0.28% Table VII - 5 : Overall estim ated total impacts (upstreamplus downstream) on criteria pollutants for calendar years 2018, 2030, and 2050. Results are shown in both total short tons and pe rcent change fromreference case to control case.

Table VII - 6 : Overall estim ated downstreamimpacts on air toxics for calendar years 2018, 2030, and 2050 (short tons)



### B. Health Effects of Non - GHG Pollutants In this section we discuss health effects associated with exposure to some of the c riteria and air toxic pollutants impacted by the proposed heavy

- dut y vehicle standards. (1) Particulate Matter (a ) Background Particulate matter is a generic term for a broad class of chemicall y and ph ysically diverse substances. It can be principall y characteriz ed as discrete particles that exist in the condensed (liquid or solid) phase spanning several orders of magnitude in size. Since 1987, EPA has delineated that subset of inhalable particles small enough to penetrate to the thoracic region (including the tr acheobronchial and alveolar regions) of the respiratory

tract (referred to as thoracic particles). Current National Ambient Air Quality Standards (NAAQS) use PM 2.5 as the indicator for fine particles (with PM 2.5 referring to particles with a nominal mean a erody namic diameter less than or equal to 2.5 μm), and use PM 10 as the indicator for purposes of regulating the coarse fraction of PM 10 (referred to as thoracic coarse particles or coarse

- fraction particles; generally including particles with a nominal mean aerody namic diameter greater than 2.5 μm and less than or equal to 10 μm, or PM 10

- 2.5 ). Ultrafine particles are a subset of fine particles, generally less than 100 nanometers (0.1 μm) in aerodynamic diameter. Fine particles are produced primaril y b y c ombustion processes and by transformations of gaseous emissions (e.g., SO X , NO X and VOC) in the atmosphere. The chemical and ph ys ical properties of PM 2.5 may vary greatl y with time, region, CY Benzene 1,3

- butadiene Formaldeh yd e Acetaldeh yd e Acrolein short tons % short tons % short tons % short tons % short tons % 2018 2030 2050Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

277 of 54 1 meteorology , and source category . Thus, PM 2.5 may include a comp lex mixture of different pollutants including sulfates, nitrates, organic compounds, elemental carbon and metal compounds. These particles can remain in the atmosphere for day s to weeks and travel hundreds to thousands of kilometers. (b ) Health Effects of PM Scientific studies show ambient PM is associated with a series of adverse health effects. These health effects are discussed in detail in EPA’s Integrated Science Assessment for Particulate Matter (I SA)

. 209 Further discussion of health effects associated w ith PM can also be found in the draft RIA for this proposal

. The I SA summarizes evidence associated with PM 2.5 , PM 10

- 2.5 , and ultrafine particles (UFPs). The I SA concludes that health effects associated with short

- term exposures (hours to day s) to ambient PM 2.5 include mortality , cardiovascular effects, such as altered vasomotor function and hospital admissions and emergency department visits for ischemic heart disease and congestive heart failure, and respiratory effects, such as exacerbation of asthma sy mptoms in children and hospital admissions and emergency department visits for chronic obstructive pulmonary disease (COPD) and respiratory infections

. 210 The ISA notes that l ong - term exposure to PM 2.5 (months to y ears) is associated with the development/pr ogression of cardiovascular disease, premature mortality , and respiratory effects, including reduced lung function growth, increased respiratory

s ymptoms, and asthma development. 211 The I SA concludes that that the currentl y available scientific evidence fro m epidemiologic, controlled human exposure, and toxicological studies supports a causal association between short

- and long

- term exposures to PM 2.5 and cardiovascular effects and mortality . Furthermore, the I SA concludes that the collective evidence supp orts likely causal associations between short

and long

- term PM 2.5 exposures and respiratory effects. The ISA also concludes that the scientific evidence is suggestive of a causal association for reproductive and developmental effects and cancer, mutageni cit y, and genotoxicity and long

- term exposure to PM 2. 5 . 212 For PM 10

- 2.5 , the I SA concludes that the current evidence is suggestive of a causal relationship between short

- term exposures and cardiovascular effects, such as hospitalization for ischemic heart di sease. There is also suggestive evidence of a causal relationship between short

- term PM 10

- 2.5 exposure and mortality and respiratory effects. Data are inadequate to draw conclusions regarding the health effects associated with long

- term exposure to PM 10

- 2.5 . 213

209 U.S. EPA (2009) Integrated Science Assessment for Particulate Matter (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R

- 08/139F, Docket EPA

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- 11295 210 See U.S. EPA, 2009 Final P M ISA at.Note 209 , at Section 2.3.1.1. 211 See U.S. EPA 2009 Final PM ISA at Note 209 , at page 2

- 12, Sections 7.3.1.1 and 7.3.2.1. 212 See U.S. EPA 2009 Final PM ISA at Note 209 , at Section 2.3.2. 213 See U.S. EPA 2009 Final PM ISA at Note 209 , at.Section 2.3.4, Table 2

- 6.278 of 54 1 For UFPs, the I SA concludes that there is suggestive evidence of a causal relationship between short

- term exposures and cardiovascular effects, such as changes in heart rh ythm and blood vessel function. It also concludes that there is suggestive evi dence of association between short

- term exposure to UFPs and respiratory effects. Data are inadequate to draw conclusions regarding the health effects associated with long

- term exposure to UFP’s. 214 (2) Ozone (a ) Background Ground

- level ozone pollution is ty pically formed by

the reaction of VOC and NO X in the lower atmosphere in the presence of sunlight. These pollutants, often referred to as ozone precursors, are emitted by many ty pes of pollution sources, such as highway and nonroad motor vehicles and engines, pow er plants, chemical plants, refineries, makers of consumer and commercial products, industrial facilities, and smaller area sources. 215 The science of ozone formation, transport, and accumulation is complex. Ground

- level ozone is produced and destroyed in a cyclical set of chemical reactions, many of which are sensitive to temperature and sunlight. When ambient temperatures and sunlight levels remain high for several day s and the air is relativel y stagnant, ozone and its precursors can build up and result in more ozone than ty picall y occurs on a single high

- temperature day . Ozone can be transported hundreds of miles downwind from precursor emissions, resulting in elevated ozone levels even in areas with low local VOC or NO X emissions. (b ) Health Effects of Ozo ne The health and welfare effects of ozone are well documented and are assessed in EPA’s 2006 Air Quality

Criteria Document (ozone AQCD) and 2007 Staff Paper. 216 , 217 People who are more susceptible to effects associated with exposure to ozone can include ch ildren, the elderl y, and individuals with respiratory disease such as asthma. Those with greater exposures to ozone, for instance due to time spent outdoors (e.g., children and outdoor workers), are of particular concern. Ozone can irritate the respirato ry s ys tem, causing coughing, throat irritation, and breathing discomfort. Ozone can reduce lung function and cause pulmonary inflammation in healthy

individuals. Ozone can also aggravate asthma, leading to more asthma attacks that require medical attenti on and/or

214 See U.S. EPA 2009 Final PM ISA at Note 209 , at Section 2.3.5, Table 2

- 6. 215 Area sources are defined as sources that emit less than 10 tons per year of a criteria or hazardous air pollutant or less than 25 tons per year of a combination of pollutants. 216 U.S. EPA. (2006 ). Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final). EPA/600/R

- 05/004aF

- cF. Washington, DC: U.S. EPA. 217 U.S. EPA. (2007). Review of the National Ambient Air Quality Standards for Ozone: Policy Assessment of Scientific and Technica l Information, OAQPS Staff Paper. EPA

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279 of 54 1 the use of additional medication. Thus, ambient ozone may cause both healthy

and asthmatic individuals to limit their outdoor activities. In addition, there is suggestive evidence of a contribution of ozone to cardiovascular

- related morbidity and highl y suggestive evidence that short

- term ozone exposure directl y or indirectly contributes to non - accidental and cardiopulmonary

- related mortality , but additional research is needed to clarify the underlying mechanisms causing these effects. In a rec ent report on the estimation of ozone

- related premature mortality published by

the National Research Council (NRC), a panel of experts and reviewers concluded that short

- term exposure to ambient ozone is likely

to contribute to premature deaths and that oz one - related mortality should be included in estimates of the health benefits of reducing ozone exposure. 218 Animal toxicological evidence indicates that with repeated exposure, ozone can inflame and damage the lining of the lungs, which may lead to permane nt changes in lung tissue and irreversible reductions in lung function. The respiratory effects observed in controlled human exposure studies and animal studies are coherent with the evidence from epidemiologic studies supporting a causal relationship between acute ambient ozone exposures and increased respiratory

- related emergency room visits and hospitalizations in the warm season. In addition, there is suggestive evidence of a contribution of ozone to cardiovascular

- related morbidity and non

- accidental and cardiopulmonary mortality

. (3) Nitrogen Oxides and Sulfur Oxides (a ) Background Nitrogen dioxide (NO 2 ) is a member of the NO X family of gases. Most NO 2 is formed in the air through the oxidation of nitric oxide (NO) emitted when fuel is burned at a high temp erature. SO 2 , a member of the sulfur oxide (SO X ) family of gases, is formed from burning fuels containing sulfur (e.g., coal or oil derived), extracting gasoline from oil, or extracting metals from ore. SO 2 and NO 2 can dissolve in water droplets and fur ther oxidize to form sulfuric and nitric acid which react with ammonia to form sulfates and nitrates, both of which are important components of ambient PM. The health effects of ambient PM are discussed in Section VII. B. (1) (b) of this preamble. NO X along with non

- methane hydrocarbon (NMHC) are the two major precursors of ozone. The health effects of ozone are covered in Section VII. B. (2) (b)

. (b ) Health Effects of NO2 In formation on the health ef fects of NO 2 can be found in the EPA Integrated Science Assessment (I SA) for Nitrogen Oxides. 219 The EPA has concluded that the

218 National Research Council (NRC), 2008. Estimating Mortality Risk Reduction and Economic Benefits from Controlling Ozone Air Pollution . The National Academies Press: Washington, D.C. Docket EPA

HQ

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– Health Criteria (Final Report). EPA/600/R

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findings of epidemiologic, controlled human exposure, and animal toxicological studies provide evidence that is sufficient to inf er a likely causal relationship between respiratory effects and short

- term NO 2 exposure. The I SA concludes that the strongest evidence for such a relationship comes from epidemiologic studies of respiratory effects including sy mptoms, emergency

department visits, and hospital admissions. The I SA also draws two broad conclusions regarding airway responsiveness following NO 2 exposure. First, the I SA concludes that NO 2 exposure may enhance the sensitivity

to allergen

- induced decrements in lung function and i ncrease the allergen

- induced airway inflammatory response following 30

- minute exposures of asthmatics to NO 2 concentrations as low as 0.26 ppm . In addition, small but significant increases in non

- specific airway hy perresponsiveness were reported following 1

- hour exposures of asthmatics to 0.1 ppm NO 2 . Second, exposure to NO 2 has been found to enhance the inherent responsiveness of the airway

to subsequent nonspecific challenges in controlled human exposure studies of asthmatic subjects. Enhanced airway responsiveness could have important clinical implications for asthmatics since transient increases in airway responsiveness following NO 2 exposure have the potential to increase s ymptoms and worsen asthma control. Together, the epidemiologic and experimental data sets form a plausible, consistent, and coherent description of a relationship between NO 2 exposures and an array of adverse health effects that range from the onset of respiratory s ymptoms to hospital admission. Although the weight of evidence s upporting a causal relationship is somewhat less certain than that associated with respiratory morbidity , NO 2 has also been linked to other health endpoints. These include all

- cause (nonaccidental) mortality , hospital admissions or emergency department vi sits for cardiovascular disease, and decrements in lung function growth associated with chronic exposure. (c) Health Effects of SO2 In formation on the health effects of SO 2 can be found in the EPA Integrated Science Assessment for Sulfur Oxides. 220 SO 2 has long been known to cause adverse respiratory

health effects, particularl y among individuals with asthma. Other potentially sensitive groups include children and the elderl y. During periods of elevated ventilation, asthmatics may

experience s ymptomatic broncho constriction within minutes of exposure. Following an extensive evaluation of health evidence from epidemiologic and laboratory studies, the EPA has concluded that there is a causal relationship between respiratory health effects and short

- term exposure t o SO 2 . Separatel y, based on an evaluation of the epidemiologic evidence of associations between short

- term exposure to SO 2 and mortality , the EPA has concluded that the overall evidence is suggestive of a causal relationship between short

- term exposure to SO 2 and mortality

.

220 U.S. EPA. (2008). Integrated Science Assessment (ISA) for Sulfur Oxides

– Health Criteria (Final Report) . EPA/600/R

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281 of 54 1 (4) Carbon Monoxide In formation on the health effects of carbon monoxide (C O ) can be found in the EPA Integrated Science Assessment (I SA) for Carbon Monoxide

. 221 The ISA concludes that ambient concentrations of CO are associated with a numbe r of adverse health effects. 222 This section provides a summary of the health effects associated with exposure to ambient concentrations of CO

. 223 Human clinical studies of subjects with coronary artery disease show a decrease in the time to onset of exerci se - induced angina (chest pain) and electrocardiogram changes following CO exposure. In addition, epidemiologic studies show associations between short

- term CO exposure and cardiovascular morbidity , particularl y increased emergency

room visits and hospital admissions for coronary heart disease (including ischemic heart disease, myocardial infarction, and angina). Some epidemiologic evidence is also available for increased hospital admissions and emergency room visits for congestive heart failure and cardio vascular disease as a whole. The ISA concludes that a causal relationship is likely to exist between short

- term exposures to CO and cardiovascular morbidit y. It also concludes that available data are inadequate to conclude that a causal relationship exis ts between long

- term exposures to CO and cardiovascular morbidity

. Animal studies show various neurological effects with in

- utero CO exposure. Controlled human exposure studies report inconsistent neural and behavioral effects following low

- level CO exp osures. The I SA concludes the evidence is suggestive of a causal relationship with both short

- and long

- term exposure to CO and central nervous sy stem effects. A number of epidemiologic and animal toxicological studies cited in the ISA have evaluated ass ociations between CO exposure and birth outcomes such as preterm birth or cardiac birth defects. The epidemiologic studies provide limited evidence of a CO

induced effect on preterm births and birth defects, with weak evidence for a decrease in birth weight. Animal toxicological studies have found associations between perinatal CO exposure and decrements in birth weight, as well as other developmental outcomes. The ISA concludes these studies are suggestive of a causal relationship between long

- term expo sures to CO and developmental effects and birth outcomes.

221 U .S. EPA, 2010. Integrated Science Assessment for Carbon Monoxide (Final Report). U.S. Environmental Protection Agency, Washington, DC, EPA/600/R

- 09/019F, 2010. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=218686 222 The ISA evaluates the health evidence associated with di fferent health effects, assigning one of five “weight of evidence” determinations: causal relationship, likely to be a causal relationship, suggestive of a causal relationship, inadequate to infer a causal relationship, and not likely to be a causal relat ionship. For definitions of these levels of evidence, please refer to Section 1.6 of the ISA. 223 Personal exposure includes contributions from many sources, and in many different environments. Total personal exposure to CO includes both ambient and nona mb ient components; and both components may contribute to adverse health effects.282 of 54 1 Epidemiologic studies provide evidence of effects on respiratory morbidit y such as changes in pulmonary

function, respiratory

s ymptoms, and hospital admissions associated with ambient CO concentrati ons. A limited number of epidemiologic studies considered copollutants such as ozone, SO 2 , and PM in two

- pollutant models and found that CO risk estimates were generally robust, although this limited evidence makes it difficult to disentangle effects attributed to CO itself from those of the larger complex air pollution mixture. Controlled human exposure studies have not extensively evaluated the effect of CO on respiratory morbidit y. Animal studies at levels of 50

- 100 ppm CO show preliminary

evidence of altered pulmonary vascular remodeling and oxidative injury

. The I SA concludes that the evidence is suggestive of a causal relationship between short

term CO exposure and respiratory morbidity , and inadequate to conclude that a causal relationship exists between long

- term exposure and respiratory morbidit y. Finally , the I SA concludes that the epidemiologic evidence is suggestive of a causal relationship between short

- term exposures to CO and mortality

. Epidemiologic studies provide evidence of an associ ation between short

- term exposure to CO and mortality , but limited evidence is available to evaluate cause

- specific mortality outcomes associated with CO exposure. In addition, the attenuation of CO risk estimates which was often observed in copollutant m odels contributes to the uncertaint y as to whether CO is acting alone or as an indicator for other combustion

- related pollutants. The I SA also concludes that there is not likely to be a causal relationship between relevant long

- term exposures to CO and mortality

. (5) Air Toxics Heav y - dut y vehicle emissions contribute to ambient levels of air toxics known or suspected as human or animal carcinogens, or that have noncancer health effects. The population experiences an elevated risk of cancer and other noncancer health effects from exposure to the class of pollutants known collectively as “ air toxics .” 224 These compounds include, but are not limited to, benzene, 1,3

- butadiene, formaldehyde, acetaldeh yde, acrolein, diesel particulate matter and exhaust organic gases , polycyclic organic matter (POM), and naphthalene. These compounds were identified as national or regional risk drivers in past National

- scale Air Toxics Assessment s (NATA) and have significant inventory

contributions from mobile sources. 225 (a ) Diesel Exhaust Heav y - dut y diesel engines emit diesel exhaust (DE), a complex mixture composed of carbon dioxide, oxygen, nitrogen, water vapor, carbon monoxide, nitrogen compounds, sulfur compounds and numerous low

- molecular

- weight h ydrocarbons. A number of these gas eous hydrocarbon components are individually known to be toxic,

224 U. S. EPA. 2002 National

- Scale Air Toxics Assessment. http://www.epa.gov/ttn/atw/nata12002/risksum.html Docket EPA

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283 of 54 1 including aldeh yd es, benzene and 1,3

- butadiene. The diesel particulate matter (DPM) present in DE consists of fine particles (< 2.5 μm), including a subgroup with a large number of ultrafine particles (< 0.1 μm). These particles have a large surface area which makes them an excellent medium for adsorbing organics and their small size makes them highl y respirable. Man y of the organic compounds present in the gases and on the particles, such as pol yc yc lic organic matter (POM), are individually known to have mutagenic and carcinogenic properties. Diesel exhaust varies significantly in chemical composition and particle sizes between different engine ty pes (heav y - duty , light

- duty), engine operati ng conditions (idle, accelerate, decelerate), and fuel formulations (high/low sulfur fuel). Also, there are emissions differences between on

- road and nonroad engines because the nonroad engines are generally

of older technology . After being emitted in th e engine exhaust, diesel exhaust undergoes dilution as well as chemical and phy sical changes in the atmosphere. The lifetime for some of the compounds present in diesel exhaust ranges from hours to day s. 226 (i ) Diesel Exhaust: Potential Cancer Effects In EPA’s 2002 Diesel Health Assessment Document (Diesel HAD), 227 exposure to diesel exhaust was classified as likely to be carcinogenic to humans by inhalation from environmental exposures, in accordance with the revised draft 1996/1999 EPA cancer guidelines. A numbe r of other agencies (National Institute for Occupational Safety and Health, the International Agency for Research on Cancer, the World Health Organization, California EPA, and the U.S. Department of Health and Human Services) have made similar classificati ons. However, EPA also concluded in the Diesel HAD that it is not possible currentl y to calculate a cancer unit risk for diesel exhaust due to a variety of factors that limit the current studies, such as limited quantitative exposure histories in occupati onal groups investigated for lung cancer. For the Diesel HAD, EPA reviewed 22 epidemiologic studies on the subject of the carcinogenicity

of workers exposed to diesel exhaust in various occupations, finding increased lung cancer risk, although not alway s s tatistically significant, in 8 out of 10 cohort studies and 10 out of 12 case

- control studies within several industries. Relative risk for lung cancer associated with exposure ranged from 1.2 to 1.5, although a few studies show relative risks as high as 2 .6. Additionally , the Diesel HAD also relied on two independent meta

- analy ses, which examined 23 and 30 occupational studies respectivel y, which found statistically significant increases in smoking

- adjusted relative lung cancer risk associated with exposure to diesel exhaust of 1.33 to 1.47. These meta

anal ys es demonstrate the effect of pooling many studies and in this case show the

226 U.S. EPA (2002). Health Assessment Document for Diesel Engine Exhaust . EPA/600/8

- 90/057F Office of Research and Development, Washington DC. Retrieved on March 17, 2009 from http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=29060

. 227 See U.S. EPA (2002) Diesel HAD at Note 226 , at p p. 1

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positive relationship between diesel exhaust exposure and lung cancer across a variety of diesel exhaust

- exposed occupations

. 228 , 229 In the absence of a cancer unit risk, the Diesel HAD sought to provide additional insight into the significance of the diesel exhaust

- cancer hazard b y estimating possible ranges of risk that might be present in the population. An exploratory analy sis was used to characterize a possible risk range b y comparing a ty pical environmental exposure level for highway

diesel sources to a selected range of occupational exposure levels. The occupationall y observed risks were then proportionally scaled according to the exposure ratios to obtain an estimate of the possible environmental risk. A number of calculations are needed to accomplish this, and these can be seen in the EPA Diesel HAD. The outcome was that environmental risks from diesel exhaust exposure c ould range from a low of 10 - 4 to 10 - 5 to as high as 10 - 3 , reflecting the range of occupational exposures that could be associated with the relative and absolute risk levels observed in the occupational studies. Because of uncertainties, the anal ys is ackno wledged that the risks could be lower than 10 - 4 or 10 - 5 , and a zero risk from diesel exhaust exposure was not ruled out. (ii) Diesel Exhaust: Other Health Effects Noncancer health effects of acute and chronic exposure to diesel exhaust emissions are also of con cern to the EPA. EPA derived a diesel exhaust reference concentration (RfC) from consideration of four well

- conducted chronic rat inhalation studies showing adverse pulmonary effects. 230 , 231 , 232 , 233 The RfC is 5 μg/m 3 for diesel exhaust as measured b y DPM. This RfC does not consider allergenic effects such as those associated with asthma or immunologic effects. There is growing evidence, discussed in the Diesel HAD, that exposure to diesel exhaust can exacerbate these effects, but the exposure

- response data are presentl y lacking to derive an RfC. The EPA Diesel HAD states, “With DPM [diesel particulate matter] being a ubiquitous component of ambient PM, there is an uncertaint y about the adequacy of the existing DE [diesel exhaust] noncancer database to identify all of the pertinent DE

- caused noncancer health hazards.” (p. 9

- 19). The Diesel HAD concludes “that acute exposure to DE [diesel exhaust] has been associated with irritation of the eye, nose, and throat, respiratory

228 Bhatia, R., Lopipero, P., Smith, A. (1998). Diesel exposure and lung cancer. Epidemiology, 9(1) , 84

- 91. 229 Lipsett, M. Campleman, S. (1999). Occupational exposure to diesel exhaust and lung cancer: a meta

analysis . Am J Public Health, 80(7) , 1009

- 1017. 230 Ishinishi, N. Kuwabara, N. Takaki, Y., et al. (1988). Long

- term inhalation experiments on diesel exhaust. In: Diesel exhaust and health risks. Results of the HERP studies. Ibaraki, Japan: Research Committee for HERP Studies; pp.11

- 84. 231 Heinrich, U., Fuhst, R., Rittinghausen, S., et al. (1995). Chronic inhalation exposure of Wistar rats and two different strains of mice to diesel engine exhaust, carbon black, and titanium dioxide. Inhal Toxicol, 7, 553

- 556. 232 Mauderly, J.L., Jones, R.K., Grif fith, W.C., et al. (1987). Diesel exhaust is a pulmonary carcinogen in rats exposed chronically by inhalation. Fundam. Appl. Toxicol., 9, 208

- 221. 233 Nikula, K.J., Snipes, M.B., Barr, E.B., et al. (1995). Comparative pulmonary toxicities and carcinogeniciti es of chronically inhaled diesel exhaust and carbon black in F344 rats. Fundam. Appl. Toxicol, 25 , 80

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285 of 54 1 sy mptoms (cough and phlegm), and neuro phy siological sy mptoms such as headache, lightheadedness, nausea, vomiting, and numbness or tingling of the extremities.” 234 (iii) Ambient PM 2.5 Levels and Exposure to Diesel Exhaust PM The Diesel HAD also briefly summarizes health effects associated with ambient PM and discusses the EPA’s annual PM 2.5 NAAQS of 15 μg/m 3 . There is a much more extensive body

of human data showing a wide spectrum of adverse health effects associated with exposure to ambient PM, of which diesel exhaust is an important component. The PM 2.5 NAAQS is designed to provide protection from the noncancer and premature mortality

effects of PM 2.5 as a whole. (iv) Diesel Exhaust PM Exposures Exposure of people to diesel exhaust depends on their various activities, the time spent in those activities, the locations where these activities occur, and the levels of diesel exhaust pollutants in those locations. The major difference between ambient levels of diesel particulate and exposure levels for diesel particulate is that exposure accounts for a person moving from location to location, proximity to the emission source, and whether the exposure occurs in an enclosed environment. Occupational Exposures Occupational exposures to diesel exhaust from mobile sources can be several orders of magnitude greater than ty pical exposures in the non

- occupationally exposed population. Over the ye ars, diesel particulate exposures have been measured for a number of occupational groups. A wide range of exposures have been reported, from 2 μg/m 3 to 1,280 μg/m 3 , for a vari ety of occupations. As discussed in the Diesel HAD, the National Institute of Occupational Safety and Health (NIOSH) has estimated a total of 1,400,000 workers are occupationally exposed to diesel exhaust from on

- road and nonroad vehicles. Elevated Concentrations and Ambient Exposures in Mobile Source

- Impacted Areas Regions immediatel y downwind of highway s or truck stops may experience elevated ambient concentrations of directl y - emitted PM 2.5 from diesel engines. Due to the unique nature of highway s and truck stops, emissions from a large number of diesel engines are concentrated in a small area. Studies near roadway s with high truck traffic indicate higher concentrations of components of diesel PM than other locations. 235 , 236 , 237

234 See U.S. EPA (2002), Diesel HAD at Note 226 , at p. 9

- 9. 235 Zhu, Y.; Hinds, W.C.; Kim, S.; Shen, S.; Si outas, C. (2002) Study of ultrafine particles near a major highway with heavy

- duty diesel traffic. Atmospheric Environment 36: 4323

- 4335. 236 Lena, T.S; Ochieng, V.; Holguín

- Veras, J.; Kinney, P.L. (2002) Elemental carbon and PM2.5 levels in an urban community heavily impacted by truck traffic. Environ Health Perspect 110: 1009

- 1015.286 of 54 1

High ambient particle concentrations have also been reported near trucking terminals, truck stops, and bus garages. 238 , 239 , 240 Additional discussion of exposure and health effects associated with traffic is included below in Section VII. B. (5) (j)

. (b ) Benzene T he EPA’s IRIS database lists benzene as a known human carcinogen (causing leukemia) b y all routes of exposure, and concludes that exposure is associated with additional health effects, including genetic changes in both humans and animals and increased prol iferation of bone marrow cells in mice

. 241 , 242 , 243 EPA states in its IRIS database that data indicate a causal relationship between benzene exposure and acute ly mphocy tic leukemia and suggest a relationship between benzene exposure and chronic non - ly mphocy tic l eukemia and chronic l ymphocy tic leukemia. The International Agency for Research on Carcinogens ( IARC ) has determined that benzene is a human carcinogen and the U.S. Department of Health and Human Services ( DHHS ) has characterized benzene as a known human carcinogen. 244 , 245 A number of adverse noncancer health effects including blood disorders, such as preleukemia and aplastic anemia, have also been associated with long

- term exposure to benzene. 246 , 247 The most sensitive noncancer effect observed in humans, based on current

237 Soliman, A.S.M.; Jacko, J.B.; Palmer, G.M. (2006) Development of an empirical model to estimate real

world fine particulate matter emission factors: the Traffic Air Quality mo del. J Air & Waste Manage Assoc 56: 1540

- 1549. 238 Davis, M.E.; Smith, T.J.; Laden, F.; Hart, J.E.; Ryan, L.M.; Garshick, E. (2006) Modeling particle exposure in U.S. trucking terminals. Environ Sci Techol 40: 4226

- 4232. 239 Miller, T.L.; Fu, J.S.; Hromi s, B.; Storey, J.M. (2007) Diesel truck idling emissions

– measurments at a PM 2.5 hot spot. Proceedings of the Annual Conference of the Transportation Research Board, paper no. 07

- 2609. 240 Ramachandran, G.; Paulsen, D.; Watts, W.; Kittelson, D. (2005) Mass , surface area, and number metrics in diesel occupational exposure assessment. J Environ Monit 7: 728

- 735. 241 U.S. EPA. 2000. Integrated Risk Information System File for Benzene. This material is available electronically at http://www.epa.gov/iris/subst/ 0276.htm. Docket EPA

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- 1659. 242 International Agency for Research on Cancer (IARC). 1982. Monographs on the evaluation of carcinogenic risk of chemicals to humans, Volume 29. Some industrial chemicals and dyestuffs, World Health Organization , Lyon, France, p. 345

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- 0366 243 Irons, R.D.; Stillman, W.S.; Colagiovanni, D.B.; Henry, V.A. 1992. Synergistic action of the benzene metabolite hydroquinone on myelopoietic stimulating activity of granulocyte/macrophage colo ny stimulating factor in vitro, Proc. Natl. Acad. Sci. 89:3691

- 3695. Docket EPA

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- 0370. 244 International Agency for Research on Cancer (IARC). 1982. Monographs on the evaluation of carcinogenic risk of chemicals to humans, Volume 29. Some in dustrial chemicals and dyestuffs, World Health Organization, Lyon, France. Docket EPA

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- 0366 245 U.S. Department of Health and Human Services National Toxicology Program 11th Report on Carcinogens available at: http://ntp.niehs.nih.gov/go/1618 3. 246 Aksoy, M. (1989). Hematotoxicity and carcinogenicity of benzene. Environ. Health Perspect. 82: 193

- 197. Docket EPA

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- 0368. 247 Goldstein, B.D. (1988). Benzene toxicity. Occupational medicine. State of the Art Reviews. 3: 541

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287 of 54 1 data, is the depression of the absolute ly mphocy te count in blood. 248 , 249 In addition, recent work, including studies sponsored b y the Health Effects Institute (HEI), provides evidence that biochemical responses are occurring at lower levels of benzene exposure than previously

known. 250 , 251 , 252 , 253 EPA’s IRI S program has not y et evaluated these new data. (c) 1,3

-Butadiene EPA has characterized 1,3

- butadiene as carcinogenic to humans by inhalation. 254 , 255 The IARC has determined that 1,3

- butadiene is a human carc inogen and the U.S. DHHS has characterized 1,3

- butadiene as a known human carcinogen. 256 , 257 There are numerous studies consistently demonstrating that 1,3

- butadiene is metabolized into genotoxic metabolites by experimental animals and humans. The specific me chanisms of 1,3

- butadiene

- induced carcinogenesis are unknown; however, the scientific evidence strongly suggests that the carcinogenic effects are mediated b y

248 Rothman, N., G.L. Li, M. Dosemeci, W.E. Bechtold, G.E. Marti, Y.Z. Wang, M. Linet, L.Q. Xi, W. Lu, M.T. Smith, N. Titenko

- Holland, L.P. Zhang, W. Blot, S.N. Yin, and R.B. Hayes (1996) Hematotoxicity among Chinese workers heavil y exposed to benzene. Am. J. Ind. Med. 29: 236

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- 0326. 249 U.S. EPA (2002) Toxicological Revie w of Benzene (Noncancer Effects). Environmental Protection Agency, Integrated Risk Information System (IRIS), Research and Developme nt, National Center for Environmental Assessment, Washington DC. This material is available electronically at http://www.epa.gov/iris/subst/0276.htm. Docket EPA

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- 0327. 250 Qu, O.; Shore, R.; Li, G.; Jin, X.; Chen, C.L.; Cohen, B.; Melikian, A .; Eastmond, D.; Rappaport, S.; Li, H.; Rupa, D.; Suramaya, R.; Songnian, W.; Huifant, Y.; Meng, M.; Winnik, M.; Kwok, E.; Li, Y.; Mu, R.; Xu, B.; Zhang, X.; Li, K. (2003) HEI Report 115, Validation & Evaluation of Biomarkers in Workers Exposed to Benzene in China. Docket EPA

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- 0328. 251 Qu, Q., R. Shore, G. Li, X. Jin, L.C. Chen, B. Cohen, et al. (2002) Hematological changes among Chinese workers with a broad range of benzene exposures. Am. J. Industr. Med. 42: 275

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- 0329. 252 Lan, Qing, Zhang, L., Li, G., Vermeulen, R., et al. (2004) Hematotoxically in Workers Exposed to Low Levels of Benzene. Science 306: 1774

- 1776. Docket EPA

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- 0330. 253 Turtletaub, K.W. and Mani, C. (2003) Benzene metabolis m in rodents at doses relevant to human exposure from Urban Air. Research Reports Health Effect Inst. Report No.113. Docket EPA

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- 0385. 254 U.S. EPA (2002) Health Assessment of 1,3

- Butadiene. Office of Research and Development, National Cente r for Environmental Assessment, Washington Office, Washington, DC. Report No. EPA600

- P
- 98

- 001F. This document is available electronically at http://www.epa.gov/iris/supdocs/buta

- sup.pdf. Docket EPA

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- 0386. 255 U.S. EPA (2002) Full IRIS Summary for 1,3

- butadiene (CASRN 106

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- 0). Environmental Protection Agency, Integrated Risk Information System (IRIS), Research and Development, National Center for Environmental Assessment, Washington, DC http://www.epa.gov/iris/subst/0139.htm. Docket EPA

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- 1660 256 International Agency for Research on Cancer (IARC) (1999) Monographs on the evaluation of carcinogenic risk of chemicals to humans, Volume 71, Re

- evaluation of some organic chemicals, hydrazine and hydrogen peroxide and Volume 97 (in p reparation), World Health Organization, Lyon, France. Docket EPA

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- 0387 257 U.S. Department of Health and Human Services (2005) National Toxicology Program 11th Report on Carcinogens available at: ntp.niehs.nih.gov/index.cfm?objectid=32BA9724

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genotoxic metabolites. Animal data suggest that females may be more sensitive than males for can cer effects associated with 1,3

- butadiene exposure; there are insufficient data in humans from which to draw conclusions about sensitive subpopulations. 1,3

- b utadiene also causes a variet y of reproductive and developmental effects in mice; no human data o n these effects are available. The most sensitive effect was ovarian atrophy observed in a lifetime bioassay of female mice. 258 (d ) Formaldehyde Since 1987, EPA has classified formaldeh yde as a probable human carcinogen based on evidence in humans and in rats, mice, hamsters, and monkey s. 259 EPA is currentl y reviewing recently published epidemiological data. For instance, research conducted b y the National Cancer Institute (NCI) found an increased risk of nasophary

ngeal cancer and ly

mphohematopoietic malignancie s such as leukemia among workers exposed to formaldeh yde. 260 , 261 In an anal ys is of the ly mphohematopoietic cancer mortality

from an extended follow

- up of these workers, NCI confirmed an association between ly

mphohematopoietic cancer risk and peak exposure s. 262 A recent National Institute of Occupational Safety and Health (NIOSH) study of garment workers also found increased risk of death due to leukemia among workers exposed to formaldeh yde. 263 Extended follow

- up of a cohort of British chemical workers did not find evidence of an increase in na sophary ngeal or ly

mphohematopoie tic cancers, but a continuing statistically

significant excess in lung cancers was reported. 264 Recently , the IARC re

- classified formaldehyde as a human carcinogen (Group 1). 265

258 Bevan, C.; Stadler, J.C.; Elliot, G.S.; et al. (1996) Subchronic toxicity of 4

- vinylcyclohexene in rats and mice by inhalation. Fundam. Appl. Toxicol. 32:1

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- 0388. 259 U.S. EPA (1987) Assessment of Health Risks to Garment Workers and Certain Home Residents from Exposure to Formaldehyde, Office of Pesticides and Toxic Substances, April 1987. Docket EPA

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- 0389. 260 Hauptmann, M..; Lubin, J. H.; Stewart, P. A.; Hayes, R. B.; Blair, A. 200 3. Mortality from lymphohematopoetic malignancies among workers in formaldehyde industries. Journal of the National Cancer Institute 95: 1615

- 1623. Docket EPA

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- 0336. 261 Hauptmann, M..; Lubin, J. H.; Stewart, P. A.; Hayes, R. B.; Blair, A. 2004. Mortality from solid cancers among workers in formaldehyde industries. American Journal of Epidemiology 159: 1117

- 1130. Docket EPA

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- 0337. 262 Beane Freeman, L. E.; Blair, A.; Lubin, J. H.; Stewart, P. A.; Hayes, R. B.; Hoover, R. N.; Hauptmann, M. 2009. Mortality from lymphohematopoietic malignancies among workers in formaldehyde industries: The National Cancer Institute cohort. J. National Cancer Inst. 101: 751

- 761. Docket EPA

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- 0338. 263 Pinkerton, L. E. 2004. Mortali ty among a cohort of garment workers exposed to formaldehyde: an update. Occup. Environ. Med. 61: 193

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- 0339. 264 Coggon, D, EC Harris, J Poole, KT Palmer. 2003. Extended follow

- up of a cohort of British chemical workers expos ed to formaldehyde. J National Cancer Inst. 95:1608

- 1615. Docket EPA

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- 0340. 265 International Agency for Research on Cancer (IARC). 2006. Formaldehyde, 2

- Butoxyethanol and 1

- tert
Butoxypropan
- 2

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289 of 54 1 Formaldeh yd e exposure also causes a range of noncancer health effects, including irritation of the eyes (burning and watering of the ey es), nose and throat. Effects from repeated exposure in humans include respiratory tract irritation, chronic bronchitis and nasal epi thelial lesions such as metaplasia and loss of cilia

. Animal studies suggest that formaldeh yde may

also cause airway

inflammation

– including eosinophil infiltration into the airway s. There are several studies that suggest that formaldehyde may increase the risk of asthma

– particularly in the young. 266 , 267 (e) Acetaldehyde Acetaldeh yd e is classified in EPA’s IRI S database as a probable human carcinogen, based on nasal tumors in rats , and is considered toxic by the inhalation, oral, and intravenous routes

. 268 Acet aldeh yd e is reasonably anticipated to be a human carcinogen b y the U.S. DHHS in the 11 th Report on Carcinogens and is classified as possibly carcinogenic to humans (Group 2B) by the IARC. 269 , 270 EPA is currently conducting a reassessment of cancer risk from i nhal ation exposure to acetaldehyde. The primary

noncancer effects of exposure to acetaldehyde vapors include irritation of the eyes, skin, and respiratory tract. 271 In short

- term (4 week) rat studies, degeneration of olfactory epithelium was observed at various concentration levels of acetaldeh yde exposure

. 272 , 273 Data from these studies were used b y EPA to develop an inhalation reference concentration. Some asthmatics have been shown to be a sensitive subpopulation to decrements in functional expiratory volume (FEV1 test) and

266 Agency for Toxic Substances and Disease Registry (ATSDR). 1999. Toxicological profile for Formaldehyde. Atlanta, GA: U.S. Department of Health and Human Services, Public Health Service. http://www.atsdr.cdc.gov/toxprofiles/tp111.html Docket EPA

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- 1191. 267 WHO (2002) Concise International Chemical Assessment Document 40: Formaldehyde. Published under the joint sponsorship of the United Nations Environment Programme, the Internation al Labour Organization, and the World Health Organization, and produced within the framework of the Inter

Organization Programme for the Sound Management of Chemicals. Geneva. Docket EPA

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- 1199. 268 U.S. EPA. 1991. Integrated Risk Informatio n System File of Acetaldehyde. Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available electronically at http://www.epa.gov/iris/subst/0290.htm. Docket EPA

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- 0390. 269 U.S. Department of

Health and Human Services National Toxicology Program 11th Report on Carcinogens available at: ntp.niehs.nih.gov/index.cfm?objectid=32BA9724

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7FCE50709CB4C932. 270 International Agency for Research on Cancer (IARC). 1999. Re

- evaluation of some or ganic chemicals, hydrazine, and hydrogen peroxide. IARC Monographs on the Evaluation of Carcinogenic Risk of Chemical to Humans, Vol 71. Lyon, France. Docket EPA

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- 0387 271 U.S. EPA. 1991. Integrated Risk Information System File of Acetaldehyde. This material is available electronically at http://www.epa.gov/iris/subst/0290.htm. 272 Appleman, L. M., R. A. Woutersen, V. J. Feron, R. N. Hooftman, and W. R. F. Notten. 1986. Effects of the variable versus fixed exposure levels on the toxicity of acetaldehyde in rats. J. Appl. Toxicol. 6: 331

- 336. 273 Appleman, L.M., R.A. Woutersen, and V.J. Feron. 1982. Inhalation toxicity of acetaldehyde in rats. I. Ac ute and subacute studies. Toxicology. 23: 293

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bronchoconstriction upon acetaldeh yde inhalation. 274 The agency is currently conducting a reassessment of the health hazards from inhalation exposure to acetaldehyde. (f ) Acrolein Acrolein is extremely

acrid and irritating to humans when inhaled, with acute exposure resulting in upper respiratory tract irritation, mucus hy persecretion and congestion. The intense irritancy of this carbonyl has been demonstrated during controlled tests in human subjects, who suffer intolerable eye and nasal mucosal sensory reactions within minutes of exposure. 275 These data and additional studies regarding acute effects of human exposure to acrolein are summarized in EPA’s 2003 IR IS Human Health Assessment for acrolein. 276 Evidence available from studies in humans indicate that levels as low as 0.09 ppm (0.21 mg/m 3 ) for five minutes may elicit subjective complaints of ey e irritation with increasing concentrations leading to more extensive ey e, nose and respiratory

s ymptoms. 277 Lesions to the lungs and upper respir atory tract of rats, rabbits, and hamsters have been observed after subchronic exposure to acrolein. 278 Acute exposure effects in animal studies report bronchial hy per - responsiveness. 279 In a recent stud y, the acute respiratory irritant effects of exposure t o 1.1 ppm acrolein were more pronounced in mice with allergic airway disease by

comparison to non

- diseased mice which also showed decreases in respiratory rate. 280 Based on these animal data and demonstration of similar effects in humans (e.g., reduction in respiratory rate), individuals with compromised respiratory function (e.g., emph ys ema, asthma) are expected to be at increased risk of developing adverse responses to strong respiratory irritants such as acrolein. EPA determined in 2003 that the human carcinogenic potential of acrolein could not be determined because the available data were inadequate. No information was available on the carcinogenic effects of acrolein in humans and the animal data provided

274 Myou, S.; Fujimura, M.; Nishi K.; Ohka, T.; and Matsuda, T. 1993. Aerosolized acetaldehyde induces histamine

- mediated bronchoconstriction in asthmatics. Am. Rev. Respir.Dis. 148(4 Pt 1): 940

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- 0408. 275 U.S. EPA (U.S. Environmental Prote ction Agency). (2003) Toxicological review of acrolein in support of summary information on Integrated Risk Information System (IRIS) National Center for Environmental Assessment, Washington, DC. EPA/635/R

- 03/003. p. 10. Available online at: http://www.epa .gov/ncea/iris/toxreviews/0364tr.pdf. 276 See U.S. EPA 2003 Toxicological revie w of acrolein, Note 275 , above. 277 See U.S. EPA 2003 Toxicological revie w of acrolein, Note 275 , at p. 11. 278 Integrated Risk Information System File of Acrolein. Office of Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available at http://www.epa.gov/iris/subst/0364.htm Docket EPA

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- 0391. 279 See U.S. 2003 Toxicological review of acrolein, Note 275 , at p. 15. 280 Morris JB, Symanowicz PT, Olsen JE, et al. 2003. Immediate sensory nerve

- mediated respiratory responses to irritant s in healthy and allergic airway - diseased mice. J Appl Physiol 94(4):1563

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291 of 54 1 inadequate evidence of carcinogenicity. 281 T he IARC determined in 1995 that acrolein was not classifiable as to its carcinogenicit y in humans

. 282 (g ) Polycyclic Organic Matter (POM) POM is generall y defined as a large class of organic compounds which have multiple benzene rings and a boiling point greater than 100 degrees Celsius. Many of the compounds included in the class of compounds known as POM are classified by EPA as probable human carcinogens based on animal data. One of these compounds, naphthalene, is discussed separately below. Polycyclic aro matic h ydrocarbons (PAHs) are a subset of POM that contain only hydrogen and carbon atoms. A number of PAHs are known or suspected carcinogens. Recent studies have found that maternal exposures to PAHs (a subclass of POM) in a population of pregnant wome n were associated with several adverse birth outcomes, including low birth weight and reduced length at birth, as well as impaired cognitive development at age three. 283 , 284 EPA has not y et evaluated these recent studies. (h ) Naphthalene Naphthalene is found in s mall quantities in gasoline and diesel fuels. Naphthalene emissions have been measured in larger quantities in both gasoline and diesel exhaust compared with evaporative emissions from mobile sources, indicating it is primarily a product of combustion. E PA released an external review draft of a reassessment of the inhalation carcinogenicity of naphthalene based on a number of recent animal carcinogenicity studies. 285 The draft reassessment completed external peer review. 286 Based on external peer review comments received, additional analyses are being undertaken. This external review draft does not represent official agency opinion and was released solely

for the purposes of external peer review and public comment.

281 U.S. EPA. 2003. Integrated Risk Information System File of Acrolein. Research and Development, National Center for Environmental Assessment , Washington, DC. This material is available at http://www.epa.gov/iris/subst/0364.htm 282 International Agency for Research on Cancer (IARC). 1995. Monographs on the evaluation of carcinogenic risk of chemicals to humans, Volume 63. Dry cleaning, some chlo rinated solvents and other industrial chemicals, World Health Organization, Lyon, France. Docket EPA

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- 0393 283 Perera, F.P.; Rauh, V.; Tsai, W

- Y.; et al. (2002) Effect of transplacental exposure to environmental pollutants on birth outcomes i n a multiethnic population. Environ Health Perspect. 111: 201

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- 0372. 284 Perera, F.P.; Rauh, V.; Whyatt, R.M.; Tsai, W.Y.; Tang, D.; Diaz, D.; Hoepner, L.; Barr, D.; Tu, Y.H.; Camann, D.; Kinney, P. (2006) Effect of prenatal exposure to airborne polycyclic aromatic hydrocarbons on neurodevelopment in the first 3 years of life among inner

- city children. Environ Health Perspect 114: 1287

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- 0373. 285 U. S. EPA. 2004. Toxicological Revie w of Naphth alene (Reassessment of the Inhalation Cancer Risk), Environmental Protection Agency, Integrated Risk Information System, Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available electronically at http://www.epa.gov/iris/subst/0436.htm. Docket EPA

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- 0272. 286 Oak Ridge Institute for Science and Education. (2004). External Peer Review for the IRIS Reassessment of the Inhalation Carcinogenicity of Naphthalene. August 2004. http://cfpu

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The National Toxicology Program listed na phthalene as "reasonabl y anticipated to be a human carcinogen" in 2004 on the basis of bioassay s reporting clear evidence of carcinogenicity

in rats and some evidence of carcinogenicity in mice. 287 California EPA has released a new risk assessment for naphthalene, and the IARC has reevaluated naphthalene and re

- classified it as Group 2B: possibly carcinogenic to humans. 288 Naphthalene also causes a number of chronic non

- cancer effects in animals, including abnormal cell changes and growth in respiratory and n asal tissues. 289 (i ) Other Air Toxics In addition to the compounds described above, other compounds in gaseous hydrocarbon and PM emissions from heav y - dut y vehicles will be affected by th e s e proposed rules . Mobile source air toxic compounds that would potential ly be impacted include eth ylbenzene, propionaldehyde, toluene, and xylene. Information regarding the health effects of these compounds can be found in EPA’s IRI S database. 290 (j ) Exposure and Health Effects Associated with Traffic Populations who live, work, or attend school near major roads experience elevated exposure concentrations to a wide range of air pollutants, as well as higher risks for a number of adverse health effects. While the previous sections of this preamble have focused on the health effects associated with individual criteria pollutants or air toxics, this section discusses the mixture of different exposures near major roadways, rather than the effects of an y single pollutant. As such, this section emphasizes traffic

- related air pollution, i n general, as the relevant indicator of exposure rather than an y particular pollutant. Concentrations of man y traffic

- generated air pollutants are elevated for up to 300

- 500 meters downwind of roads with high traffic volumes. 291 Numerous sources on roads co ntribute to elevated roadside concentrations, including exhaust and evaporative emissions, and resuspension of road dust and tire and brake wear. Concentrations of several criteria and hazardous air pollutants are elevated near major roads. Furthermore, different semi

- volatile organic compounds and chemical components of particulate

287 National Toxicology Program (NTP). (2004). 11th Report on Carcinogens. Public Health Service, U.S. Department of Health and Human Services, Research Triangle Park, NC. Ava ilable from: http://ntp

server.niehs.nih.gov. 288 International Agency for Research on Cancer (IARC). (2002). Monographs on the Evaluation of the Carcinogenic Risk of Chemicals for Humans. Vol. 82. Lyon, France. Docket EPA

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- 0274. 289 U. S. EPA. 1998. Toxicological Revie w of Naphthalene, Environmental Protection Agency, Integrated Risk Information System, Research and Development, National Center for Environmental Assessment, Washington, DC. This material is available electronically at http: //www.epa.gov/iris/subst/0436.htm 290 U.S. EPA Integrated Risk Information System (IRIS) database is available at: www.epa.gov/iris 291 Zho u, Y.; Levy, J.I. (2007) Factors influencing the spatial extent of mobile source air pollution impacts: a m eta
- analys is. BMC Public Health 7: 89. doi:10.1186/1471

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293 of 54 1 matter, including elemental carbon, organic material, and trace metals, have been reported at higher concentrations near major roads. Populations near major roads experience greater risk of certain adverse health effects. The Health Effects Institute published a report on the health effects of traffic

related air pollution. 292 Itconcluded that evidence is “sufficient to infer the presence of a causal association” between tra ffic exposure and exacerbation of childhood asthma sy mptoms. The HEI report also concludes that the evidence is either “sufficient” or “suggestive but not sufficient” for a causal association between traffic exposure and new childhood asthma cases. A rev iew of asthma studies by Salam et al. (2008) reaches similar conclusions. 293 The HEI report also concludes that there is “suggestive” evidence for pulmonary

function deficits associated with traffic exposure, but concluded that there is “inadequate and insu fficient” evidence for causal associations with respiratory health care utilization, adult

- onset asthma, chronic obstructive pulmonary disease (COPD) sy mptoms, and allergy . A review b y Holguin (2008) notes that the effects of traffic on asthma may

be modi fied by

nutrition status, medication use, and genetic factors. 294 The HEI report also concludes that evidence is “suggestive” of a causal association between traffic exposure and all

- cause and cardiovascular mortality . There is also evidence of an associati on between traffic

- related air pollutants and cardiovascular effects such as changes in heart rh ythm, heart attack, and cardiovascular disease. The HEI report characterizes this evidence as “suggestive” of a causal association, and an independent epidemio logical literature review b y Adar and Kaufman (2007) concludes that there is “consistent evidence” linking traffic

- related pollution and adverse cardiovascular health outcomes. 295 Some studies have reported associations between traffic exposure and other health effects, such as birth outcomes (e.g., low birth weight) and childhood cancer. The HEI report concludes that there is currentl y “inadequate and insufficient” evidence for a causal association between these effects and traffic exposure. A review by Ra aschou

Nielsen and Rey

nolds (2006) concluded that evidence of an association between childhood cancer and traffic

- related air pollutants is weak, but noted the inability to draw firm conclusions based on limited evidence. 296 There is a large population in th e U.S. living in close proximity of major roads. According to the Census Bureau’s American Housing Survey for 2007, approximately

20

292 HEI Panel on the Health Effects of Air Pollution. (2010) Traffic

- related air pollution: a critical review of the literature on emissions, exposure, and health effects. [Online at www.healtheffe cts.org] 293 Salam, M.T.; Islam, T.; Gilliland, F.D. (2008) Recent evidence for adverse effects of residential proximity to traffic sources on asthma. Current Opin Pulm Med 14: 3

- 8. 294 Holguin, F. (2008) Traffic, outdoor air pollution, and asthma. Immunol Allergy Clinics North Am 28: 577
- 588. 295 Adar, S.D.; Kaufman, J.D. (2007) Cardiovascular disease and air pollutants: evaluating and improving epidemiological data implicating traffic exposure. Inhal Toxicol 19: 135

- 149. 296 Raaschou

-Nielsen, O.; Reynolds, P. (2006) Air pollution and childhood cancer: a review of the epidemiological literature. Int J Cancer 118: 2920

- 2929.294 of 54 1

million residences in the U.S., 15.6% of all homes, are located within 300 feet (91 m) of a highway with 4+ lanes, a railr oad, or an airport. 297 Therefore, at current population of approximately

309 million, assuming that population and housing are similarly distributed, there are over 48 million people in the U.S. living near such sources. The HEI report also notes that in two North American cities, L os Angeles and Toronto, over 40% of each cit y’s population live within 500 meters of a highway or 100 meters of a major road. It also notes that about 33% of each city ’s population resides within 50 meters of major roads. Together, the evidence suggests that a large U.S. population lives in areas with elevated traffic

- related air pollution. People living near roads are often socioeconomically disadvantaged. According to the 2007 American Housing Survey , a renter
- occupied property is over twice as likel y as an owner - occupied property to be located near a highway with 4+ lanes, railroad or airport. In the same survey , the median household income of rental housing occupants was less than half that of owner

- occupants ($28,921/$59,8 86). Numerous studies in individual urban areas report higher levels of traffic

- related air pollutants in areas with high minority

or poor populations. 298 , 299 , 300 Students may

also be exposed in situations where schools are located near major roads. In a stud y of nine metropolitan areas across the U.S., Appatova et al. (2008) found that on average greater than 33% of schools were located within 400 m of an Interstate, U.S., or state highway , while 12% were located within 100 m. 301 The stud y al so found that among the metropolitan areas studied, schools in the Eastern U.S. were more often sited near major roadways than schools in the Western U.S. Demographic studies of students in schools near major roadway s suggest that this population is more likely than the gene ral student population to be of non

- white race or Hispanic ethnicity , and more often live in low socioeconomic status locations. 302 , 303 , 304

297 U.S. Census Bureau (2008) American Housing Survey for the United States in 2007. Series H

- 150 (National Data), Table 1A

- 7. [Acces sed at http://www.census.gov/hhes/www/housing/ahs/ahs07/ahs07.html on January 22, 2009] 298 Lena, T.S.; Ochieng, V.; Carter, M.; Holguín

- Veras, J.; Kinney, P.L. (2002) Elemental carbon and PM2.5 levels in an urban community heavily impacted by truck traffic. Environ Health Perspect 110: 1009

- 1015. 299 Wier, M.; Sciammas, C.; Seto, E.; Bhatia, R.; Rivard, T. (2009) Health, traffic, and environmental justice: collaborative research and community action in San Francisco, California. Am J Public Health 99: S49 9

- S504. 300 Forkenbrock, D.J. and L.A. Schweitzer, Environmental Justice and Transportation Investment Policy

. Iowa City: University of Iowa, 1997. 301 Appatova, A.S.; Ryan, P.H.; LeMasters, G.K.; Grinshpun, S.A. (2008) Proximal exposure of public schools and students to major roadways: a nationwide U.S. survey. J Environ Plan Mgmt 302 Green, R.S.; Smorodinsky, S.; Kim, J.J.; McLaughlin, R.; Ostro, B. (2004) Proximity of California public schools to busy roads. Environ Health Perspect 112: 61

- 66. 303 Houston, D.; Ong, P.; Wu, J.; Winer, A. (2006) Proximity of licensed child care facilities to near

roadway vehicle pollution. Am J Public Health 96: 1611

- 1617. 304 Wu, Y.; Batterman, S. (2006) Proximity of schools in Detroit, Michigan to automobile and truck traffi c. J Exposure Sci Environ Epidemiol 16: 457

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295 of 54 1 There is some inconsistency in the evidence, which may be due to different local development patterns and measures of tr affic and geographic scale used in the studies. 301 

### C. Environmental Effects of Non - GHG Pollutants In this section we discuss some of the environmental effects of PM and its precursors such as visibility impairment, atmospheric deposition, and materials damage and soiling , as well as environmental effects associated with the presence of ozone in the ambient air , such as impacts on plants, including trees, agronomic crops and urban ornamentals , and environmental effects associated with air toxics

. (1) Visibility Visibility can be defined as the degree to which the atmosphere is transparent to visible light. 305 Visibility impairment is caused by light scattering and absorption by suspended particles and gases. Visibility is important be cause it has direct significance to people’s enjoy ment of daily

activities in all parts of the country . Individuals value good visibility for the well

- being it provides them directl y, where they live and work, and in places where they

enjoy recreational o pportunities. Visibility is also highl y valued in significant natural areas , such as national parks and wilderness areas , and special emphasis is given to protecting visibility

in these areas. For more information on visibility see the final 200 9 PM I SA. 306 EPA is pursuing a two

- part strategy to address visibility . First, EPA has concluded that PM 2.5 causes adverse effects on visibility in various locations, depending on PM concentrations and factors such as chemical composition and average relative humidi ty , and has set secondary PM 2.5 standards. 307 The secondary PM 2.5 standards act in conjunction with the regional haze program. EPA’s regional haze rule (64 FR 35714) was put in place in July

1999 to protect the visibility in M andatory C lass I Federal areas . There are 156 national parks, forests and wilderness areas categorized as M andatory Class IF ederal areas (62 FR 38680

- 81, July 18, 1997). 308 Visibility

can be said to be impaired in both PM 2.5 nonattainment areas and M andatory Class I F ederal areas.

305 National Research Council, 1993. Protecting Visibility in National Parks and Wilderness Areas. National Academy of Sciences Committee on Haze in National Parks and Wilderness Areas. National Academy P ress, Washington, DC. Docket EPA

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. This book can be viewed on the National Academy Press Website at http://www.nap.edu/books/0309048443/html/ 306 See U.S. EPA 2009 Final PM ISA at Note 209

.. 307 The existing annual primary and secondary PM2.5 standards have been remanded and are being addressed in the currently ongoing PM NAAQS review. 308 These areas are defined in CAA section 162 as those national parks exceeding 6,000 acres, wilderness areas and me mo rial parks exceeding 5,000 acres, and all international parks which were in existence on August 7, 1977.296 of 54 1 (2) Pla nt and Ecosystem Effects of Ozone Elevated o zone levels contribute to environmental effects, with impacts to plants and ecos ys tems being of most concern. Ozone can produce both acute and chronic injury in sensitive species depending on the concentration l evel and the duration of the exposure. Ozone effects also tend to accumulate over the growing season of the plant, so that even low concentrations experienced for a longer duration have the potential to create chronic stress on vegetation. Ozone damage t o plants includes visible injury to leaves and impaired photosy nthesis, both of which can lead to reduced plant growth and reproduction, resulting in reduced crop yi elds, forestry production, and use of sensitive ornamentals in landscaping. In addition, the impairment of photosy nthesis, the process by which the plant makes carbohydrates (its source of energy and food), can lead to a subsequent reduction in root growth and carboh ydrate storage below ground , result ing in other, more subtle plant and ecos ys te ms impacts. These latter impacts include increased susceptibility of plants to insect attack, disease, harsh weather, interspecies competition and overall decreased plant vigor. The adverse effects of ozone on forest and other natural vegetation can pot entially lead to species shifts and loss from the affected ecos ys tems, resulting in a loss or reduction in associated ecos ys tem goods and services. Last ly , visible ozone injury to leaves can result in a loss of aesthetic value in areas of special scenic s ignificance like national parks and wilderness areas. The final 2006 Ozone Air Quality Criteria Document presents more detailed information on ozone effect s on vegetation and ecos ys tems. (3) Atmospheric Deposition Wet and dry

deposition of ambient particulate matter delivers a complex mixture of metals (e.g., mercury , zinc, lead, nickel, aluminum, cadmium), organic compounds (e.g., POM, dioxins, furans) and inorganic compounds (e.g., nitrate, sulfate) to terrestrial and aquatic ecos ys tems. The chemical form o f the compounds deposited depends on a variet y of factors including ambient conditions (e.g., temperature, humidity, oxidant levels) and the sources of the material. Chemical and phy sical transformations of the compounds occur in the atmosphere as well as the media onto which they deposit. These transformations in turn influence the fate, bioavailability and potential toxicity

of these compounds. Atmospheric deposition has been identified as a key component of the environmental and human health hazard po sed b y several pollutants including mercury , dioxin and PCBs. 309 Adverse impacts on water quality can occur when atmospheric contaminants deposit to the water surface or when material deposited on the land enters a waterbody through runoff. Potential impact s of atmospheric deposition to waterbodies include those related to both nutrient and toxic inputs. Adverse effects to human health and welfare can occur from the addition of excess nitrogen via atmospheric deposition. The nitrogen

-

309 U.S. EPA (2000) Deposition of Air Pollutants to the Great Waters: Third Report to Congress. Office of Air Quality Planning and Standards. EPA

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297 of 54 1 nutrient enrichment co ntributes to toxic algae blooms and zones of depleted oxygen, which can lead to fish kills, frequentl y in coastal waters. Deposition of heavy metals or other toxi c s may

lead to the human ingestion of contaminated fish, impairment of drinking water, damage to the marine ecology , and limit s to recreational uses. Several studies have been conducted in U.S. coastal waters and in the Great Lakes Region in which the role of ambient PM deposition and runoff is investigated. 310 , 311 , 312 , 313 , 314 Atmospheric deposition of n itrogen and sulfur contributes to acidification, altering biogeochemistry

and affecting animal and plant life in terrestrial and aquatic ecos ys tems across the U.S. The sensitivity of terrestrial and aquatic ecos ys tems to acidification from nitrogen and su lfur deposition is predominantly governed by

geology

. Prolonged exposure to excess nitrogen and sulfur deposition in sensitive areas acidifies lakes, rivers and soils. Increased acidity in surface waters creates inhospitable conditions for biota and affe cts the abundance and nutritional value of preferred prey species, threatening biodiversit y and ecos ys tem function. Over time, acidifying deposition also removes essential nutrients from forest soils, depleting the capacit y of soils to neutralize future a cid loadings and negativel y affecting forest sustainability

. Major effects include a decline in sensitive forest tree species, such as red spruce ( Picea rubens ) and sugar maple ( Acer saccharum ), and a loss of biodiversity of fishes, zooplankton, and macro invertebrates

. In addition to the role nitrogen deposition play s in acidification, nitrogen deposition also leads to nutrient enrichment and altered biogeochemical cycling. In aquatic s ys tems increased nitrogen can alter species assemblages and cause eutrophication. In terrestrial sy stems nitrogen loading can lead to loss of nitrogen sensitive lichen species, decreased biodiversit y of grasslands, meadows and other sensitive habitats, and increased potential for invasive species. For a broader explanatio n of the topics treated here, refer to the description in Section 7.1.2 of the draft RIA. Adverse impacts on soil chemistry and plant life have been observed for areas heavily influenc ed b y atmospheric deposition of nutrients, metals and acid species, resu lting in species shifts, loss of biodiversity , forest decline and damage to forest

310 U.S. EPA (2004) National Coastal Condition Report II. Office of Research and Development/ Office of Water. EPA

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- 0089. 311 Gao, Y., E.D. Nelson, M.P. Field, et al. 200 2. Characterization of atmospheric trace elements on PM2.5 particulate matter over the New York

-New Jersey harbor estuary. Atmos. Environ. 36: 1077

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- 11297. 312 Kim , G., N. Hussain, J.R. Scudlark, and T.M. Church. 2000. F actors influencing the atmospheric depositional fluxes of stable Pb, 210Pb, and 7Be into Chesapeake Bay. J. Atmos. Chem. 36: 65

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- 11299. 313 Lu, R., R.P. Turco, K. Stolzenbach, et al. 2003. Dry deposition of airborne trace metals on the Los Angeles Basin and adjacent coastal waters. J. Geophys. Res. 108(D2, 4074): AAC 11

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- 11296. 314 Marvin, C.H., M.N. Charlton, E.J. Reiner, et al. 2002. Surficial sediment contamination in Lakes Erie and Ontario: A comparative analysis. J. Great Lakes Res. 28(3): 437

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productivity . Potential impacts also include adverse effects to human health through ingestion of contaminated vegetation or livestock (as in the case for dioxin deposition ), reduction in crop yi eld, and limited use of land due to contamination. Atmospheric deposition of pollutants can reduce the aesthetic appeal of buildings and culturall y important articles through soiling , and can contribute directly (or in conjunction with other pollutants) to structural damage b y means of corrosion or erosion. Atmospheric deposition may affect materials principally by promoting and accelerating the corrosion of metals, by degrading paints, and by deteriorating building materials such as concrete and limestone. Particles contribute to these effects because of their electrol yt ic, h ygroscopic, and acidic properties , and their ability to ad sorb corrosive gases (principall y sulfur dioxide). (4) Environmental Effects of Air Toxics Emissions f

rom producing, transporting and combusting f uel contribute to ambient levels of pollutants that contribute to adverse effects on vegetation. Volatile organic compounds (VOCs), some of which are considered air toxics, have long been suspected to play

a rol e in vegetation damage. 315 Inlaboratory experiments, a wide range of tolerance to VOCs has been observed. 316 Decreases in harvested seed pod weight have been reported for the more sensitive plants, and some studies have reported effects on seed germination, flowering and fruit ripening. Effects of individual VOCs or their role in conjunction with other stressors (e.g., acidification, drought, temperature extremes) have not been well studied. In a recent study of a mixture of VOCs including ethanol and tolu ene on herbaceous plants, significant effects on seed production, leaf water content and photosy

nthetic efficiency

were reported for some plant species. 317 Research suggests an adverse impact of vehicle exhaust on plants, which has in some cases been attrib uted to aromatic compounds and in other cases to nitrogen oxides. 318 , 319 , 320 The impacts of VOCs on plant reproduction may have long

- term implications for biodiversity and survival of native species near major roadway s. Most of the studies of the impacts of VOCs on vegetation have focused on short

- term exposure

315 U.S. EPA. 1991. Effects of organic chemicals in the atmosphere on terrestrial plants. EPA/600/3

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- 0401. 316 Cap e JN, ID Leith, J Binnie, J Content, M Donkin, M Skewes, DN Price AR Brown, AD Sharpe. 2003. Effects of VOCs on herbaceous plants in an open

- top chamber experiment. Environ. Pollut. 124:341

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- 0357. 317 Cape JN, ID Leith, J B innie, J Content, M Donkin, M Skewes, DN Price AR Brown, AD Sharpe. 2003. Effects of VOCs on herbaceous plants in an open

- top chamber experiment. Environ. Pollut. 124:341

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- 0357. 318 Viskari E

- L. 2000. Epicuticular wax of No rway spruce needles as indicator of traffic pollutant deposition. Water, Air, and Soil Pollut. 121:327

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- 1128. 319 Ugrekhelidze D, F Korte, G Kvesitadze. 1997. Uptake and transformation of benzene and toluene by plant leaves. Ecotox. Environ. Safety 37:24

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- 1142. 320 Kammerbauer H, H Selinger, R Rommelt, A Ziegler

- Jons, D Knoppik, B Hock. 1987. Toxic components of motor vehicle emissions for the spruce Picea abies. Environ. Pollut. 48:235

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299 of 54 1 and few studies have focused on long

- term effects of VOCs on vegetation and the potential for metabolites of these compounds to affect herbivores or insects. 

### D. Air Quality Impacts of Non - GHG Pollutants (1) C urrent Levels of Non - GHG Pollutants This proposal may

have impacts on ambient concentrations of criteria and air toxic pollutant s. Nationally , levels of PM 2.5 , ozone, NO X , SO X , CO and air toxics are declining. 321 However, approximately 127 million people l ived in counties that exceeded any NAAQS in 2008. 322 These numbers do not include the people living in areas where there is a future risk of failing to maintain or attain the NAAQS. It is important to note that these numbers also do not account for the fac t that EPA recentl y finished reviewing the ozone, and SO 2 standards. Also, EPA is currently reviewing the standards for PM and CO, and those standards could be made more protective, which would increase the number of people living in nonattainment areas. Further, the majority

of Americans continue to be exposed to ambient concentrations of air toxics at levels which have the potential to cause adverse health effects. 323 , 324 The levels of air toxics to which people are exposed vary depending on where people live and work and the kinds of activities in which they engage, as discussed in detail in U.S

. EPA’s recent mobile source air toxics rule. 325 (2) Impacts of Proposed Standards on Futur e Am bient Concentrations of PM 2.5 , Ozone and Air Toxics Full

- scale photochemi cal air quality modeling is necessary

to accurately

project levels of criteria pollutants and air toxics

. For the final rule s , a national

- scale air quality modeling analy sis will be performed to anal yz e the impacts of the standards on PM 2.5 , ozone, and se lected air toxics (i.e., benzene, formaldehyde, acetaldehyde, acrolein and 1,3

- butadiene). The length of time needed to prepare the necessary emissions inventories, in addition to the processing time associated with the modeling itself, has precluded us f

rom performing air qualit y modeling for this proposal. Section s VII.A and VII.B of the preamble present projections of the changes in criteria pollutant and air toxics emissions due to the proposed vehicle standards; the basis for those e stimates is set out in Chapter 6 of the draft RIA. The atmospheric chemistry related to ambient concentrations of PM 2.5 , ozone and air toxics is very complex, and

321 U. S. EPA (2010) Our Nation’s Air: Status and Trends through 2008. Office of Air Quality Planning and Standards, Research Triangle Park, NC. Publication No. EPA 454/R

- 09

- 002. http://www.epa.gov/airtrends/2010/. 322 See U. S. EPA Trends, Note 321

. 323 U. S. Environmental Protection Agency (2007). Control of Hazardous Air Pollutants from Mobile Sources; Final Rule. 72 FR 8434, February 26, 2007. 324 See U. S. EPA 2010. Light

- Duty Fin al Rule, Note (#),. 325 See U. S. EPA 2007, Note 323

.300 of 54 1

making predictions based solely on emissions changes is extremel y difficult. However, based on the magnitude of the emissions changes predicted to result from the proposed standards, EPA expects that there will be a relatively small change in ambient air quality , pending a more comprehensive anal ys is for the final rule s . For the final rule s , EPA intends to use a 2005

- based Community Multi

- scale Air Quality (CMAQ) modeling platform as the tool for the air qualit y modeling. The CMAQ modeling s ys tem is a comprehensive three

- dimensional grid

- based Eulerian air quality model designed to estimate the formation and fate of oxidant precursors, primary and secondary PM concentrations and deposition, and air toxics, over regional and urban spatial scales (e.g., over the contiguous U.S.). 326 , 327 , 328 The CMAQ model is a well

known and well

- established tool and is commonly used b y EPA for regulatory anal ys es, for instance the recent ozone NAAQS proposal, and by States in developing attainment demonstrations for their State Implementation Plans. 329 The CMAQ model version 4. 7 was most recently

peer - reviewed in February of 200 9 for th e U.S. EPA. 330 CMAQ includes man y science modules that simulate the emission, production, decay , deposition and transport of organic and inorganic gas

- phase and particle

- phase pollutants in the atmosphere. EPA intends to use th e most recent version of CMAQ which reflects updates to version 4.7 to improve the underl yi ng science. These include aqueous chemistry

mass conservation improvements, improved vertical convective mixing and lowered CB05 mechanism unit yields for acrolein from 1,3

- butadiene tracer reactions which were updated to be consistent with laboratory measurements
. 

## VIII. W hat ar e the Agencies' Estimated Cost, Economic, and Other Impacts of the Pr oposed Pr ogram ? In this section, we present the co sts and impacts of the proposed HD National Program. It is important to note that NHTSA’s proposed fuel consumption standards and EPA’s proposed GHG standards would both be in effect, and each would lead to average

326 U.S. Environmental Protection Agency, Byun, D.W., and Ching, J.K.S., Eds, 1999. Science algorithms of EPA Models

- 3 Community Multiscale Air Quality (CMAQ mo deling system, EPA/600/R

- 99/030, Office of Research and Development). 327 By un, D.W., and Schere, K.L., 2006. Review of the Governing Equations, Computational Algorithms, and Other Components of the Models

- 3 Community Multiscale Air Quality (CMAQ) Modelin g System, J. Applied Mechanics Reviews, 59 (2), 51

- 77. 328 Dennis, R.L., Byun, D.W., Novak, J.H., Galluppi, K.J., Coats, C.J., and Vouk, M.A., 1996. The next generation of integrated air quality modeling: EPA’s Models

- 3, Atmospheric Environment, 30, 1925

- 193 8. 329 U.S. EPA (2007). Regulatory Impact Analysis of the Proposed Revisions to the National Ambient Air Quality Standards for Ground

- Level Ozone. EPA document number 442/R

- 07

- 008, July 2007. 330 Report on the peer

- review is still being finalized. Draft avail able upon request from Director S.T.Rao, Atmospheric Modeling and Analysis Division; rao.st@epa.gov; 919

- 541

- 4541. Allen, D., Burns, D., Chock, D., Kumar, N., Lamb, B., Moran, M. (February 2009 Draft Version). Report on the Peer Review of the Atmospheric Modeling and Analysis Division, NERL/ORD/EPA. U.S. EPA, Research Triangle Park, NC.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

301 of 54 1 fuel econom y increases and GHG emission reductions. The two agencies’ proposed standards would comprise the HD National Program. The net benefits of the proposed HD National Program consist of the effects of the program on:

 the vehicle program costs (costs of compl yi ng with the vehicle CO 2 standards)  fuel savings associated with reduced fuel usage resulting from the program  the economic value of reductions in greenhouse gas emissions,  the reductions in other (non

- GHG) pollutants,  costs associated with increases in noise, congestion, and accid ents resulting from increased vehicle use,  the economic value of improvements in U.S. energy security impacts,  benefits associated with increased vehicle use due to the “rebound” effect. We also present the cost

- effectiveness of the standards, or the co st per ton of emissions reduced. A few effects of the program, such as the effects on other pollutants, are not included here. We plan to add the effects of other pollutants to the anal ys is for the final rule. The program may

have other effects that are not included here. The agencies seek comment on whether an y costs or benefits are omitted from this analysis, so that they can be explicitly

recognized in the Final Rule. The total monetized benefits (excluding fuel savings) under the program are project ed to be $1.5 to $8.0 billion in 2030 , depending on the value used for the social cost of carbon. These benefits are summarized below in Table VIII

- 5 . The costs of the program in 2030 are estimated to be approximately $ 2.0 billion for new engine and tr uck technology

less $18.9 billion in savings realized by trucking operations through fewer fuel expenditures (calculated using pre

- tax fuel prices). These costs are summarized below in Table VIII

- 4

. The present value of the total monetized benefits (excluding fuel savings) under the program are expected to range from $23.7 billion to $152.9 billion with a 3% discount rate; with a 7% discount rate, the total monetized benefits are expected to range from $15.3 billion to $144.5 billion. These values, summarized in Table VIII

- XX , depend on the value used for the social cost of carbon. The present value of costs of the program for new engine and truck technology , in Table VIII

- XX , are expected to be $43.8 billion using a 3% discount rate, and $23.5 billion w ith a 7% discount rate, less fuel savings (calculated using pre

- tax fuel prices) of $351.1 billion with a 3% discount rate, and $152.1 billion with a 7% discount rate. Total present net benefits (in Table VIII

- XX ) are thus expected to range from $331 bill ion to $460.2 billion with a 3% discount rate, and $143.9 billion to $273.1 billion with a 7% discount rate. The estimates developed here are measured against a baseline fuel econom y associated with MY 2010 vehicles . The extent to which fuel economy impro vements may have occurred in the absence of the rule affect the net benefits associated with the rule. If trucks would have ended up installing technologies to achieve the fuel savings302 of 54 1

and reduced GHG emissions in the absence of this proposal, then both t he costs and benefits of these fuel savings could be attributed to market forces, not the rule. At this time, the agencies do not have estimates of the extent of fuel

- saving technologies that might have been adopted in the absence of this proposal. We se ek comment on the degree to which the technologies discussed in this proposal would have been adopted in the absence of this proposal. EPA has undertaken an analy sis of the econom y - wide impacts of the GHG tailpipe standards as an exploratory exercise that EPA believes could provide additional insights into the potential impacts of the program. These economy

- wide impacts do not represent additional benefits of the program over and above those already included in the anal ys is, and were not a factor that was considered in evaluating the stringency of the proposed standards. Itis important to note that the results of this modeling exercise are dependent on the assumptions associated with how manufacturers will make fuel econom y improvements and how trucking operations will respond to increases in higher vehicle costs and improved vehicle fuel econom y as a result of the program. Section VIII.F discusses the underlying implications of these assumptions on economic impacts. Further information on these and oth er aspects of the economic impacts of our rule are summarized in the following sections and are presented in more detail in the RIA for this proposed rulemaking. 

### A. Conceptual Framework for Evaluating Impacts This regulation is motivated primarily by the goal s of reducing emissions of greenhouse gases and promoting energy securit y by

reducing consumption of petroleum

based fuels. These are classic externalities, meaning that private markets do not incorporate the costs associated with these problems; these co sts are not borne b y the households or businesses whose actions are responsible for them. In the absence of some mechanism to “internalize” these costs

– that is, to transfer their burden to individuals or firms whose decisions impose them

– individuals w ill consume more petroleum

- based fuels than is socially

optimal. Externalities are a classic motivation for government intervention in markets. These externalities, as well as effects due to changes in emissions of other pollutants and other impacts, are discussed in Sections VIII.H

– VIII.J. This proposal also identifies technologies that reduce truck operators’ fuel costs enough that they

pay for themselves over short periods of time under the assumptions made for this anal ys is (e.g. AEO 2010 project ed fuel prices). S tandard economic theory suggests that in normall y - functioning competitive markets, interactions between vehicle buyers and producers would lead producers to incorporate all cost

- effective technology into the vehicles that they offer, without government intervention. Unlike in the light

duty vehicle market, the vast majority of vehicles in the medium

- and heavy

- dut y truck market are purchased and operated b y businesses, for most of whom fuel costs represent a substantial operating expense

. Even in the presence of uncertainty and imperfect information

– conditions that hold to some degree in every market

– we generally

expect firms to attempt to minimize their costs in an effort to survive in a competitive marketplace, and therefore to ma keDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

303 of 54 1 decisions that are in the best interest of the company and its owners and/or shareholders. In this case, the benefits of the rule would be due to external benefits. However, as discussed below in in Section VIII.E, the agencies have estimated that the application of fuel

- saving technologies in response to the proposed standards would yi eld private returns of 140% to 420% (see Table VIII

- 21 below). T he agencies have also estimated that the application of these technologies would be significantl y lower in the absence of the proposed standards ( i.e. , under the “no action” regulatory alternative), meaning that truck buy ers and operators ignore opportunities to make investments in higher fuel econom y that appear to offer significant economic retur ns. As the March 2010 NAS Report notes, buy ers of new trucks appear to require very short pay back periods, ranging from 18 months to 2 y ears for fuel

- saving technologies. 331 Such short pay back periods imply

that purchasers and operators of new trucks appl y very high discount rates to future fuel savings. As Helfand and Wolverton note, however, the observation that truck buyers may discount future returns heavily does not by itself explain why

they demand such short pay

back periods. 332 This discussion examines some re asons that may explain why

the market for fuel econom y ma y not operate as efficientl y as theory would suggest. These include imperfect information in the original and resale markets, split incentives, uncertainty about future fuel prices, and adjustment and transactions costs. As the discussion will indicate, some of these explanations suggest failures in the private market for fuel

- saving technology

in addition to the external failures that are the motivation for the rule. Other explanations suggest market

- based behaviors that may impl y additional costs not accounted for in this analy sis. The agencies invite comment on these explanations, and any information to support corresponding estimates of their importance. The agencies also request comment and i nformation regarding any other factors that could explain the appearance of cost

- effective fuel

- saving technologies that have not been incorporated into trucks

. (1) Information Issues in the Original Sale Markets First, there appears to be poor information available about the effectiveness of many fuel

- saving technologies for new vehicles. As the NAS report notes, “Reliable, peer - reviewed data on fuel saving performance is available onl y for a few technologies in a few applications.” If reliable information o n the effectiveness of new technologies is absent, truck bu ye rs will understandabl y be reluctant to spend additional money to purchase vehicles equipped with unproven technologies. However, information about the effectiveness of selected technologies does exist, and some appear to be very cost
effective. The SmartWay Transport Partnership has been effective in getting the word out to its partners about these technologies, and, as a consequence, man y S martWay

331 See NAS 2010, Note (#), at pp. S

- 12, 8

- 16. 332 Helfand, Gloria, and Ann Wolverton. “Evaluating the Consumer Response to Fuel Economy: A Revie w of

the Literature.” U.S . Environmental Protection Agency: National Center for Environmental Economics Working Paper #09

- 04, August 2009.304 of 54 1

Partners have adopted these new technologies. Nevertheless, adoption of newer technologies throughout the trucking industry still lags their widespread availability

. There are several possible explanations for the slow adoption of apparentl y cost
effective technologies. Itmay be difficult for truck drivers and fleet operators to separate the individual effects of various technologies and operating strategies from one another, particularl y when they

tend to be used in conjunction. It may also be difficult for truck operators to assess the applicabili ty of even objective and reliable test results to their own specific vehicle configurations and operating practices; at the same time, the effects of specific technologies or operating practices may vary with geography , season of the y ear, or other factor s. If so, then cost

- effective technological improvements may not be adopted because they

cannot be distinguished from inefficient technologies. In formation provision, such as the efforts of the SmartWay program, can address the problem of the reliability of results, as long as truck purchasers are willing to act on the information. As noted, though, technological diffusion may be a gradual process even when information is widely available. The requirement for the use of new technologies included in this proposal will speed their adoption and thus provide more readily available information about their benefits. To the extent that the benefits of these new technologies are well documented, they are provided to trucks more quickly and more consistently

than in the absence of regulation, although the diversity of truck uses, driving situations, and driver behavior may still lead to variation in the fuel savings that individual trucks or fleets experience. (2) Information Issues in the Resale Market In additio n to issues in the new vehicle market, the resale market does not appear to reward the addition of fuel

- saving technology to vehicles adequatel y to ensure their original purchase b y new truck bu yers. This lack of payback for users beyond the original owne r almost certainly contributes to the short pay back period that new purchasers expect. Some of this unwillingness to pay for fuel

- saving technology may be due to the extension of the information problems in the new vehicle market into resale markets. Bu ye rs in the resale market have no more reason to trust information on fuel

- saving technologies than bu yers in the original market. Because actual fuel economy of trucks on the road depends on many factors, including geography and driving st yles or habits, l ogs of truck performance for used vehicles may not provide reliable information about the fuel econom y that purchasers of used trucks will experience. A related possibility

is that vehicles will be used for different purposes by their second owners than th ose for which they were originall y designed. For instance, a vehicle originall y purchased for long hauls might be used instead for regional or intrastate trips, in which case some of the fuel

- saving measures that proved effective in its original use may

n ot be equall y effective in the new uses. If information were more widely available and reliable, then purchasers in the resale market would seek vehiclesDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

305 of 54 1 with technologies that best suited their purposes, and buy ers would be matched with sellers so that u sed vehicles would be used in purposes for which their fuel

- saving technologies were most valuable. The fuel savings recovered in the secondary market may not match those in the original market if the optimal new use of the vehicle does not earn as man y b enefits from the technologies. In that case, the premium for fuel

- saving technology

in the secondary

market should accurately reflect the value in that market, even if it is lower than its value in the original market, and the market has not failed. Beca use the information necessary to optimize use in the secondary market may

not be readil y available or reliable, however, bu yers in the resale market may have less ability than purchasers of new vehicles to identify and gain the advantages of new fuel

- savin g technologies, and thus even less likely to pay a premium for them. For these reasons, technology diffusion is likely

to be even slower in the resale market than in the original market. Even when fuel

- saving technologies will provide benefits in the resa le markets, purchasers of used vehicles may not be willing to pay

for them. As a result, the purchasers of original equipment cannot expect the resale market to provide appropriate compensation for the new technologies, even when those technologies would reduce costs for the new bu ye rs. This market failure is likely to contribute to the very

short pay back period required for new technologies in the new vehicle market. (3) Split incentives in the medium - and heavy - duty truck industry When markets work effectiv ely , signals provided by transactions in one market are quickl y transmitted to related markets and influence the decisions of buyers and sellers in those related markets. For instance, in a well

- functioning market sy stem, changes in the expected future price of fuel should be transmitted rapidl y to those who purchase trucks, who will then re

- evaluate the amount of fuel

- saving technology to purchase for new vehicles. In the heavy

- duty vehicle market, however, it appears that the transmission of new information and resulting changes in bu ye rs’ and sellers’ incentives is often neither smooth nor complete. If they endure for prolonged periods, such “split incentives” may

contribute to inefficiencies in the market for fuel economy

. One place where such a spli t may occur is between the owners and operators of trucks. Because they

are generall y responsible for purchasing fuel, truck operators have strong incentives to economize on its use,and are thus likely to support the use of fuel

saving technology . Howeve r, the owners of trucks or trailers are often different from their operators, and, when purchasing vehicles, may be more concerned about their longevit y or maintenance costs than about their fuel efficiency. As a result, capital investments by

truck owner s may

be channeled into equipment that improves vehicles’ durability or reduces their maintenance costs, rather than into fuel

- saving technology . If operators can choose freely among the trucks they

drive, competition among truck owners to emplo y operator s would encourage owners to invest in fuel

- saving technology

. However, if truck owners have more ability to choose among operators, then market signals for improved fuel savings that are transmitted to truck owners may be muted.306 of 54 1 Anecdotal information about large truck fleets suggests that, even within a compan y, the office or department responsible for truck purchas es is often different from that responsible for purchasing fuel. Therefore, the employees who purchase trucks may have strong incentives to lo wer the ir initial capital cost, but not equally strong incentives to lower operating costs. Single

- wide tires, which save fuel and allow more payload (increasing revenue) , offer another example of split incentives. They require a different driving style ; those concerned about retaining drivers may resist their purchase, because drivers may not like the slightly

different "feel" of wheel torque needed . Maintenance and repair staff may resist them because the tires may not be as available as they would li ke on the road, or they may need to change road service providers . Finally , those who resell the trucks may believe that the resale market will not value the tires. While financial pressures should strong provide incentives for greater coordination, espe ciall y when fuel costs are a large share of operating costs, it can be difficult institutionally to change budgeting procedures and to coordinate across offices. Thus, even within a company incentives for fuel savings may not be fully

transmitted. In addi tion, the NAS report notes that split incentives can arise between tractor and trailer operators. 333 Trailers affect the fuel efficiency of shipping, but trailer owners do not face strong incentives to coordinate with truck owners. Although some trucking f leets own or lease their own trailers, a significant part of the trucking business is “drop and hook” service, in which trucking fleets pick up and drop off trailers and containers. These trailers and containers can belong to shippers, other trucking comp anies, leasing companies, or ocean

- going vessel lines, in which cases their owners may not face strong incentives to economize on fuel consumption by tractor operators. Though tractor operators should, in principle, have some ability to arrange tractor
- tr ailer combinations that provide increased fuel efficiency , the value of the resulting fuel savings may be small relative to the complexity and cost involved. EPA and NHTSA are not proposing to regulate trailers in this proposal. By itself, information pro vision may be inadequate to address the potential underinvestment in fuel economy resulting from such split incentives, especially in the near term. In this setting, regulation may contribute to fuel savings that otherwise may be difficult to achieve. (4) Unc ertainty about Future Cost Savings Another factor contributing to slow adoption of fuel saving technologies may be uncertaint y about future fuel prices or truck maintenance costs . When purchasers have less than perfect foresight about future operating exp enses , they may implicitly

discount future savings in those costs due to uncertaint y about potential returns from investments that reduce future costs, while the immediate costs of the fuel

- saving or maintenance

reducing technologies are certain and immedi ate, and thus not subject to discounting

. In

333 See NAS 2010, Note (#), at p. 8

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307 of 54 1 this situation, both the expected return on capital investments in higher fuel econom y and potential variance about its expected rate are likel y to play a role in a firm’s calculation of its pay back period on s uch investments. In the context of energy efficiency investments for the home, Metcalf and Rosenthal (1995) and Metcalf and Hassett (1995) point out that households weigh known, up

- front costs that are essentiall y irreversible against an unknown stream of future fuel savings. 334 Uncertainty about the value of future energy savings may

make risk

- averse households reluctant to invest in energy

- saving technologies that appear to offer attractive economic returns. The se authors find that it is possible to repli cate the observed adoption rates for energy efficiency

improvements by

incorporating the effect of uncertainty

about the value of future energy savings into an empirical model. Greene et al (2009) also find support for this explanation in the context of l ight

duty fuel econom y decisions: a loss

- averse consumer's expected net present value of increasing the fuel economy of a passenger car can be very close to zero , even if a risk

neutral expected value calculation shows that its buyer can expect significant net benefits from purchasing a more fuel

- efficient car

. 335 These authors find is worth noting that they find that uncertaint y regarding the future price of gasoline is a less important source of this result than is uncertainty about the lifetime and relia bility of the vehicle. Supporting this hy pothesis is a finding b y Dasgupta et. al (2007) that consumers are more likely to lease than bu y a vehicle with higher maintenance costs because it provides them with the option to return it before those costs beco me too high. 336 However, the agencies know of no studies that have estimated the impact of uncertainty on perceived future savings for medium and heav y - dut y vehicles

. Purchasers' uncertainty

about future fuel prices implies that mandating improvements i n fuel efficiency can reduce the expected utility associated with truck purchases. This is because adopting such regulation requires purchasers to assume a greater level of risk than they would in its absence, even if the future fuel savings predicted b y a risk

- neutral calculation actually materialize. Thus the mere existence of uncertaint y about future savings in fuel costs does not by itself assure that regulations requiring improved fuel efficiency will necessarily

provide economic benefits for truck p urchasers and operators. On the other hand, risk aversion reduces expected returns for

334 Metcalf, G., and D. Rosenthal (1995). “ The ‘New’ View of Investment Decisions and Public Policy Analys is: An Application to Green Lights and Cold Refrigerators, ” Journal of Policy Analysis and Management 14: 517

– 531. Metcalf and Hassett (1995). “ Energy Tax Credits and Residential Conservation Investment: Evidence from Panel Data (with Kevin Hassett) ” Journ al of Public Economics 57 (1995): 201

- 217. Metcalf, G., and K. Hassett (1999). “ Measuring the Energy Savings from Home Improvement Investments: Evidence from Monthly Billing Data. ” The Review of Economics and Statistics 81(3): 516

- 528. 335 Greene, D., J. German, and M. Delucchi (2009). “Fuel Economy: The Case for Market Failure” in Reducing Climate Impacts in the Transportation Sector, Sperling, D., and J. Cannon, eds. Springer Science. 336 Dasgupta, S., S. Siddarth, and J. Silva

- Risso (2007). “To Lease or to B uy? A Structural Model of a Consumer’s Vehicle and Contract Choice Decisions.” Journal of Marketing Research 44: 490

– 502.308 of 54 1

businesses; competitive pressures can reduce risk aversion, because risk

- neutral companies can make higher average profits over time. (5) Adjustment and Transactions Cost s Another possibility

is that transactions costs of changing to new technologies (how easil y drivers will adapt to the changes, e.g.) may slow their adoption. Because of the diversity

in the trucking industry , truck owners and fleets may like to see how a new technology

works in the field, when applied to their specific operations, before they adopt it. I f a conservative approach to new technologies leads truck buyers to adopt new technologies slowly , then successful new technologies are likel y to be adop ted over time without market intervention, but with delay s in achieving fuel saving, environmental, and energy securit y benefits. In addition, there may

be costs associated with training drivers to realize the potential fuel savings enabled by new techno logies, or with accelerating fleet operators’ scheduled fleet turnover and replacement to hasten their acquisition of vehicles equipped with new fuel

- saving technologies. Here, again, there may be no market failure; instead, requiring the widespread use o f these technologies may impose adjustment and transactions costs not included in this analy sis. As in the discussion of the role of risk, these costs are ty

picall y immediate and undiscounted, while their benefits are future and uncertain; risk or loss av ersion may further discourage companies from adopting new technologies. To the extent that there may be transactions costs associated with the new technologies, then regulation gives all new truck purchasers a level playing field: they will all adjust on approximately the same time frame. If experience with the new technologies serves to reduce uncertainty and risk, industry as a whole may become more accepting of new technologies. This could increase demand for future new technologies and induce additio nal benefits in the legacy fleet through complementary efforts like SmartWay

. (6) Summary On the one hand, commercial vehicles are under competitive pressure to reduce operating costs, and thus their purchasers and operators can be expected to pursue cost

effe ctive fuel

- saving technologies. On the other hand, the short pay back period required by buyers of new trucks is a sy mptom that may

suggest some combination of uncertainty about future cost savings, transactions costs, and imperfectly functioning markets. Asy mmetric or missing information can contribute to market failures, as Akerlof (1970) has argued. 337 The market for medium

- and heav y - duty trucks may

face this problem, both in the new vehicle market and in the resale market. In addition, widespread use of

337 Akerlof, George A. “The Market for ‘Lemons’: Quality Uncertainty and the Market Mechanism,” Quarterly Journal of Economics 84(3) (1970): 488

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309 of 54 1 tractor
- trailer combinations introduces the possibility that owners of trailers may have weaker incentives than truck owners or operators to adopt fuel

- saving technology

. Provision of information about fuel

- saving technologies will assist in the adoptio n of new cost

- saving technologies, but diffusion of new technologies can be a slow process. Those who are willing to experiment with new technologies expect to find cost savings, but those may

be difficult to prove. As noted above, because individual res ults of new technologies vary , new truck purchasers may find it difficult to identify or verify the effects of fuel

- saving technologies. Those who are risk

- averse are likel y to avoid new technologies out of concerns over the possibility of spending money for no return, or with other adverse impacts. As the SmartWay program demonstrates, competitive pressures in the freight transport industry can provide a strong incentive to reduce fuel consumption and improve environmental performance. However, not every driver or trucking fleet operating today

has the requisite ability

or interest to access the technical information provided b y SmartWay, nor the resources necessary to evaluate this information within the context of his or her own freight operation. Regu lation in this context will obviously speed adoption of technologies. The faster adoption will increase potential buyers’ understanding of the value of new technologies. To the extent that different technologies are used, greater information will be gain ed on the relative effects of those technologies. This mechanism should reduce the information problem, by easing both identification and adoption of new technologies. Regulation will also complement existing efforts like SmartWay by providing additional and widespread demonstration of the benefits of new technologies. This will reinforce among truck operators of legacy fleet vehicles a desire to adopt similar new fuel

- saving technologies through the SmartWay program.


### B. Costs Associated with the proposed program In this section, EPA presents our estimate of the costs associated with the proposed program. The presentation here summarizes the costs associated with new technology

expected to be added to meet the new GHG and fuel consumption standards. The anal ys is summarized here provides our estimate of incremental costs on a per truck basis and on an annual total basis. The presentation here summarizes the best estimate by EPA and NHTSA staff as to the technology

mix expected to be employed for complianc e. For details behind the cost estimates associated with individual technologies, the reader is directed to Section III of this preamble and to Chapter 2 of the draft RIA. With respect to the cost estimates presented here, the agencies note that, becaus e these estimates relate to technologies which are in most cases already available, these cost estimates are technically robust.310 of 54 1 (1) Costs per Truck For the class 2b and 3 trucks, the agencies have used a methodology consistent with that used for our recent l ight

- dut y joint rulemaking since most of the technologies expected for class 2b and 3 trucks is consistent with that expected for the larger light

- duty trucks. The cost estimates presented in the recent light

- dut y joint rulemaking were then scaled upward to account for the larger weight, towing capacity , and work demands of the trucks in these heavier classes. For details on that scaling process and the resultant costs for individual technologies, the reader is directed to Section III of this preamble and to Chapter 2 of the draft RIA . Note also that all cost estimates have been updated to 2008 dollars for this anal ys is while the recent light

- duty joint rulemaking was presented in 2007 dollars. For the heav y - dut y gasoline and the light heav y - duty diesel engines, we have used engine

- related costs from the class 2b and 3 truck estimates since the light heav y - dut y engines are essentiall y the same engines as those sold into the class 2b and 3 truck market. For medium and heav y heav y - dut y engines, the agenc ies have estimated costs using a different methodology than that emplo yedin the recent light

- dut y joint rulemaking. In the recent light

- duty joint rulemaking, the fixed costs were included in the hardware costs via an indirect cost multiplier. As such, the hardware costs presented in that analy sis, and in the cost estimates for class 2b and 3 trucks and the light HD diesel and HD gasoline engines, included both the actual hardware and the associated fixed costs. For this anal ys is, some of the fixed cost s are estimated separatel y for medium and heav y HD engines and are presented separatel y from the hardware costs. For details, the reader is directed to Chapter 2 of the draft RIA. Importantly , once totaled both methodologies account for all the costs ass ociated with the proposal. As noted above, all costs are presented in 2008 dollars. The estimates of vehicle compliance costs cover the y ears leading up to

– 2012 and 2013

– and including implementation of the program

– 2014 through 2018. Also presented are costs for the y ears following implementation to shed light on the long term (2022 and later) cost impacts of the program. The year 2022 was chosen here consistent with the recent light

- dut y joint rulemaking. That year was considered long term in that anal ys is because the short

- term and long

- term markup factors described shortly below are applied in five year increments with the 2012 through 2016 implementation span and the 2017 through 2021 span both representing the short

- term. Since man y of the co sts used in this analy sis are based on costs in the recent light

- duty joint rulemaking anal ys is, consistency

with that analy sis seems appropriate. That said, comments are requested as to whether 2024 would be a more appropriate long term ye ar. Some of the individual technology cost estimates are presented in brief in Section III , and account for both the direct and indirect costs incurred in the automobile manufacturing and dealer industries (for a complete presentation of technology costs, please refer to Chapter 2 of the draft RIA ). To account for the indirect costs on class 2b and 3 trucks and on light heav y - dut y engines, the agencies have applied an indirect costDraft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

311 of 54 1 markup (ICM) factor to all of the direct costs to arrive at the estimated technology cos t. The I CM factor used was 1.17 in the short

- term (2014 through 2021) to account for differences in the levels of R&D, tooling, and other indirect costs that will be incurred. Once the program has been fully implemented, some of the indirect costs will n o longer be attributable to these standards and, as such, a lower ICM factor is applied to direct costs in 2022 and later. The agencies have also applied I CM factors to class 4 through 8 truck and both medium and heav y heav y - dut y engine technologies. Mar k up factors in these categories range from 1.11 to 1.26 in the short term (2014 through 2021) depending on the complexity

of the given technology . Note that, for the medium and heavy HD engines, the agencies have applied these mark ups to ensure that our estimates are conservative since we have estimated fixed costs separately for technologies applied to these categories effectively making the use of markups a double counting of indirect costs. The agencies request comment on this fact. The agencies als o request comment on the I CMs being used in this analy sis

-- the levels associated with R&D, warranty , etc.

-- and whether those are appropriate or should be revised. If commenters suggest revisions, the agencies request supporting arguments and/or docume ntation. For the details on the I CMs, please refer to the report that has been placed in the docket for this proposal. 338 The agencies have also considered the impacts of manufacturer learning on the technology

cost estimates. Consistent with recent light

- duty joint rulemaking, some costs are estimated to decline by 20 percent with each of the first two doublings of production beginning with the first year of implementation. These volume

- based cost declines, termed “volume” based learning, take place after manufacturers have had the opportunity to find way s to improve upon their manufacturing processes or otherwise manufacture these technologies in a more efficient way . After two 20 percent cost reduction steps, the cost reduction learning curve flattens o ut considerably as only minor improvements in manufacturing techniques and efficiencies remain to be had. By then, costs decline roughl y three percent per year as manufacturers and suppliers continually strive to reduce costs. These time

- based cost decli nes, termed “time” based learning, take place at a rate of three percent per ye ar. L earning impacts have been considered on most but not all of the technologies expected to be used because some of the expected technologies are alread y used rather widely i n the industry and, presumably , learning impacts have already occurred. The agencies have considered volume

- based learning for onl y a handful of technologies considered to be new or emerging technologies such as energy recovery sy stems and thermal storage units which might one day be used on big trucks. For most technologies, EPA has considered them to be more established and, hence, the agencies have applied the lower time based learning. For more discussion of the learning approach and the technologies to which each t yp e of learning has been applied the reader is directed to Chapter 2 of the draft RIA. The technology

cost estimates discussed in Section III and detailed in Chapter 2 of the draft RIA are used to build up technology package cost estimates. For each engine

338 Insert reference to Chi Li's updated ICM report.312 of 54 1

and truck class, a single package for each was developed capable of complying with the proposed standards and the costs for each package was generated. The technology packages and package costs are discussed in more detail in Chapter 2 o f the draft RIA

. The compliance cost estimates take into account all credits and trading programs and include costs associated with air conditioning controls. Table VIII
- 1 presents the average incremental costs per truck for thi s proposal. For Class 2b and 3, costs increase as the standards become more stringent in 2014 through 2018. Following 2018, costss then decrease going forward as learning effects result in decreased costs for individual technologies. By

2022, the long t erm I CMs take effect and costs decrease yet again. For vocational trucks, cost trends are more difficult to discern as diesel engines begin adding technology

in 2014, gasoline engines begin adding technology in 2016, and the trucks themselves begin adding technology in 2014. With learning effects the costs, in general, decrease each ye ar except for the heav y - duty gasoline engine changes in 2016. L ong term I CMs take effect in 2022 to provide more cost reductions. For combination tractors, costs generall y decrease each ye ar due to learning effects with the exception of 2017 when the engines placed in sleeper cab tractors add turbo compounding. Following that, learning impacts result in cost reductions and the long term IC Ms take effect in 2022 for further cost reductions. By 2030 and later, cost per truck estimates remain constant for all classes. Regarding the long term I CMs taking effect in 2022, the agencies consider this the point at which some indirect costs decrease or are no longer considered attributable to the program (e.g., warrant y costs go down). Costs per truck remain essentially

constant thereafter.

Table VIII - 1 : Estimated Cost per Truck (2008 dollars)

Class 2b&3 Vocational Combination 2014 $233 $362 $6,828 2015 $302 $356 $6,638 2016 $587 $389 $6,358 2017 $877 $382 $6,668 2018 $1,458 $349 $6,403 2020 $1,454 $333 $6,144 2030 $1,375 $272 $5,081 2040 $1,375 $267 $5,081 2050 $1,375 $267 $5,081 As noted above, the fixed costs were estimated separatel y from the hardware costs for the medium and heavy HD engines that are placed in Vocational and Combination trucks. Those fixed costs are not included in Table VIII
- 1 . The agencies have estimated the R&D costs at $6 .75 million per manufacturer per y ear for five ye ars and the new test cell costs (to accommodate measurement of N 2 O emissions) at $100,000 per manufacturer. These costs apply individually

for medium and heavy

HD engines. Given the 11 manufacturers impact ed b y the proposed standards, each of which are estimated to sell both medium and heavy HD engines, we have estimated a five ye ar annual R&D cost of $148.5 million dollars (2 x 11 x $6.75 million for each ye ar 2012

- 2016) and a one time test cell cost of $1 .1 million dollars (2 x 11 x $100,000 in 2013). Estimating annual sales of medium and heav y HD engines at roughl y 280,000 units results in roughly $530 perDraft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

313 of 54 1 engine per ye ar for five years beginning in 2012 and ending in 2016. Again, these costs are not re flected in Table VIII
- 1 , but are included in Table VIII
- 2 as “Other Engineering Costs.” (2) Annual Costs of the Proposal The costs presented here represent the incremental costs for newl y added technology

to comply

with the proposal . Together with the projected increases in truck sales, the increases in per

- truck average costs shown in Table VIII
- 1 above result in the total annual costs presented in Table VIII
- 2 below. Note that the costs presented in Table VIII
- 2 do not include the savings that would occur as a result of the improvements to fuel consumption. Those impacts are presented in Section VIII. E.
. Note also that the costs presented here represent costs estimated to occur presuming that EPA’s proposed standards will continue in perpetuity . Any future changes to the proposed standards would be considered at the time they are proposed and/or ma de final. In other words, EPA’s proposed standards do not apply onl y to 2014

- 2018 model year trucks

- they do, in fact, appl y to all 2014 and later model year trucks. We present more detail regarding the 2014

- 2018 model year trucks in Section VIII.K wher e we summarize all monetized costs and benefits. Table VIII - 2 : Annual Costs Associated with the Proposal ($Millions of 2008 dollars) Year Class 2b&3 Vocational Combination Other Engineering Costs Annual

Costs 2012 $0 $0 $0 $149 $149 2013 $0 $0 $0 $151 $151 2014 $183 $202 $834 $149 $1,367 2015 $221 $205 $825 $149 $1,399 2016 $418 $231 $804 $149 $1,602 2017 $622 $234 $859 $0 $1,714 2018 $1,045 $220 $843 $0 $2,108 2020 $1,004 $222 $844 $0 $2,070 2030 $980 $234 $805 $0 $2,019 2040 $1,057 $322 $921 $0 $2,300 2050 $1,140 $423 $1,065 $0 $2,627 NPV, 3% $19,240 $5,561 $18,261 $692 $43,755 NPV, 7% $9,923 $2,891 $10,009 $632 $23,456 

### C. I ndirect Cost Multipliers (1) Markup Factors to Estimate Indirect Costs For mos t of the segments in this analy sis, the indirect costs are estimated by applying indirect cost multipliers (I CM) to direct cost estimates. I CMs were calculated by EPA as a basis for estimating the impact on indirect costs of individual vehicle technology changes that would result from regulatory actions. Separate ICMs were derived for low, medium, and high complexity technologies, thus enabling estimates of314 of 54 1

indirect costs that reflect the variation in research, overhead, and other indirect costs that can occur among different technologies. I CMs were also applied in the MY 2012

- 2016 CAFE rulemaking. Previous CAFE rulemakings applied a retail price equivalent (RPE) factor to estimate indirect costs and mark up direct costs to the retail level. Retail Pri ce Equivalents are estimated by dividing the total revenue of a manufacturer by the direct manufacturing costs. As such, it includes all forms of indirect costs for a manufacturer and assumes that the ratio applies equivalentl y for all technologies. I CMs are based on RPE estimates that are then modified to reflect only those elements of indirect costs that would be expected to change in response to a technology change. For example, warranty costs would be reflected in both RPE and I CM estimates, while marketing costs might only be reflected in an RPE estimate but not an ICM estimate for a particular technology , if the new technology

is not one expected to be marketed to consumers. Because I CMs calculated b y EPA are for individual technologies, many of wh ich are small in scale, they often reflect a subset of RPE costs; as a result, the RPE is ty pically higher than an ICM. This is not alway s the case, as ICM estimates for complex technologies may reflect higher than average indirect costs, with the resulti ng ICM larger than the averaged RPE for the industry

. Precise association of I CM elements with individual technologies based on the varied accounting categories in compan y annual reports is not possible. Hence, there is a degree of uncertaint y in the I C M estimates. If all indirect costs moved in proportion to changes in direct costs the I CM and RPE would be the same. Because most individual technologies are smaller scale than man y of the activities of auto companies (such as designing and developing e ntirely new vehicles), it would be expected that the RPE estimate would reflect an upper bound on the average ICM estimate. The agencies are continuing to study

I CMs and the most appropriate way to appl y them, and it is possible revised ICM values may

be used in our final rulemaking. With this in mind, the agencies are presenting a sensitivity anal ys is reflecting costs measured using the RPE in place of the I CM and indirect costs estimated independently in our primary

anal ys is to examine the potential imp act of these two approaches on estimated costs. (2) Background While this analy sis relies on I CMs to estimate indirect costs, an alternative method of estimating indirect costs is the retail price equivalent factor (RPE). The RPE has been used b y NHTSA, E PA and other agencies to account for cost factors not included in available direct cost estimates, which are derived from cost teardown studies or sometimes provided by manufacturers. The RPE is the basis for these markups in all DOT safety

regulations an d in most previous fuel econom y rules. The RPE includes all variable and fixed elements of overhead costs, as well as selling costs such as vehicle delivery expenses, manufacturer profit, and full dealer markup, and assumes that the ratio of indirect cost s to direct costs is constant for all vehicle changes. Historically , NHTSA has estimated that the RPE has averaged about 1.5 for the light

- dut y motor vehicle industry . The implication of an RPE of 1.5 is that each added $1.00 of variable cost inDraft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

315 of 54 1 material s, labor, and other direct manufacturing costs results in an increase in consumer prices of $1.50 for an y change in vehicles. NHTSA has estimated the RPE from light

- dut y vehicle manufacturers’ financial statements over nearl y 3 decades, and although its estimated value has varied somewhat ye ar - to
- ye ar, it has generally hovered around a level of 1.5 throughout most of this period. The NAS report as well as a study b y RTI International found that other estimates of the RPE varied from 1.26 to over 2. 339 In a recent report, The National Academ y of Sciences (NAS) acknowledged that an I CM approach was preferable but recommended continued use of the RPE over ICMs until such time as empirical data derived from rigorous estimation methods is available. The NAS report recommended using an RPE of 1.5 for outsourced (supplier manufactured) and 2.0 for in

- house (OEM manufactured) technologies and an RPE of 1.33 for advanced h ybrid and electric vehicle technologies. ICMs t ypicall y are significantly lower than RPEs , because they measure changes in only those elements of overhead and selling

- related costs that are directly influenced by specific technology

changes to vehicles. For example, the number of managers might not be directl y proportional to the value of dir ect costs contained in a vehicle, so that if a regulation increases the direct costs of manufacturing vehicles, there might be little or no change in the number of managers. ICMs would thus assume little or no change in that portion of indirect costs asso ciated with the number of managers

– these costs would be allocated onl y to the existing base vehicle. By contrast, the RPE reflects the historical overall relationship between the direct costs to manufacture vehicles and the prices charged for vehicles, which must compensate manufacturers for both their direct and indirect costs for producing and selling vehicles. The assumption behind the RPE is that changes in the long

- term price of the final product that accompan y increases in direct costs of vehicl e manufacturing will continue to reflect this historical relationship. Another difference between the RPE and ICM is that I CMs have been derived separately for different categories of technologies. A relativel y simple technology change, such as switching to a different tire with lower rolling resistance characteristics, would not influence indirect costs in the same proportion as a more complex change, such as development of a full hy brid design. ICMs were developed for 3 broad categories of te chnology

complexities, and are applied separately to fuel economy technologies judged to fit into each of these categories. This requires determining which of these complexity

categories each technology should be assigned. There is some level of uncert aint y surrounding both the I CM and RPE markup factors. The ICM estimates used in this proposal group all technologies into three broad categories and treat them as if individual technologies within each of the three categories (low, medium, and high compl exity ) would have the same ratio of indirect costs to direct

339 Rogozhin, Alex, Michael Gallaher, and Walter McManus. “Automobile Industry Retail Price Equivalent and Indirect Cost Multipliers.” Report prepared for EPA by RTI International. EPA Report EPA

- 420

- R
- 09

- 003, February 2009.316 of 54 1

costs. This simplification means it is likely that the direct cost for some technologies within a category

will be higher and some lower than the estimate for the category in general. More importantly , the ICM estimtes have not been validated through a direct accounting of actual indirect costs for individual technologies. Rather, the ICM estimates were developed using adjustment factors developed in two separate occasions: the first, a cons ensus process, was reported in the RTI report; the second, a modified Delphi method, was conducted separatel y and reported in an EPA memo. 340 Both these panels were composed of EPA staff members with previous background in the automobile industry ; the membe rships of the two panels overlapped but were not the same. 341 The panels evaluated each element of the industry ’s RPE estimates and estimated the degree to which those elements would be expected to change in proportion to changes in direct manufacturing cos ts. The method and estimates in the RTIreport were peer reviewed by three industry

experts and subsequently by reviewers for the International Journal of Production Economics. 342 RPEs themselves are inherentl y difficult to estimate because the accounting statements of manufacturers do not neatly categorize all cost elements as either direct or indirect costs. Hence, each researcher developing an RPE estimate must apply a certain amount of judgment to the allocation of the costs. Moreover, RPEs for heav y and medium dut y trucks and for engine manufacturers are not as well studied as they are for the light

- duty

automobile industry . Since empirical estimates of I CMs are ultimately

derived from the same data used to measure RPEs, this affects both measures. However, the value of RPE has not been measured for specific technologies, or for groups of specific technologies. Thus appl yi ng a single average RPE to any given technology

by definition overstates costs for very simple technologies, or understates them for advanced technologies. To highlight the potential differences between the use of ICMs and RPEs to estimate indirect costs, the agencies conducted an anal ys is based on the use of average RPEs for each industry

in the place of the ICM and direct fixed cost estimates used in our proposal. Since most technologies involved in this proposal are low complexity level technologies, the estimate based on the use of an average RPE likely overstates the costs. The weighted average RPEs for the truck and engine i ndustries are 1.36 and 1.28 respectivel y. These values were substituted for the I CMs and directly estimate indirect costs used in the primary cost anal ys is referenced elsewhere in this document. Using the average RPEs, the five model year cost of $8.2B i n the primary analy sis increases to $9.5B, an increase of 16 percent. The agencies request comment accompanied by supporting data on the use of ICMs and RPE factors to estimate fixed costs.

340 Helfand, Gloria, and Todd Sherwood. “Documentation of the Development of Indirect Cost Multipliers for Three Automotive Technologies.” Memorandum, Assessment and Standards Division, Office of Transportation and A ir Quality, U.S. Environmental Protection Agency, August 2009. 341 NHTSA staff participated in the development of the process for the second, modified Delphi panel, and reviewed the results as they were developed, but did not serve on the panel. 342 The result s of the RTI report were published in Alex Rogozhin, Michael Gallaher, Glo ria Helfand, and Walter McManus, “Using Indirect Cost Multipliers to Estimate the Total Cost of Adding New Technology in the Automobile Industry.” International Journal of Productio n Economics 124 (2010): 360

- 368.Draft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

317 of 54 1 

### D. Cost per Ton of Emissions Reductions The agencies have calculated the cost per ton of GHG (CO 2 - equivalent, or CO 2 e) reductions associated with this proposal using the above costs and the emissions reductions described in Section s VIand VII . The cost per metric ton of GHG emissions reductions has been calculated in the ye ars 2020, 2030, 2040, and 2050 using the annual vehicle compliance costs and emission reductions for each of those ye ars. The value in 2050 represents the long

- term cost per ton of the emissions reduced. The agencies have also calculated the cost per metric ton of GHG emission reductions including the savings associated with reduced fuel consumption (presented below in Section VIII. E. ). This latter calculation does not include the other benefits associated with this prop osal such as those associated with energy securit y benefits as discussed later in S ection VIII .I . By including the fuel savings in the cost estimates, the cost per ton is less than $0 since the estimated value of fuel savings outweighs the program costs. T he results for CO 2 costs per ton under the proposal are shown in Table VIII
- 3

.

Table VIII - 3 : Annual Cost Per Metric Ton of CO 2 Reduced ($2008 dollars) Year Program Cost Fuel

Savings (post
- tax) CO2

Reduced Cost per Ton

(without Fuel Savings) Cost per Ton

(with Fuel Savings) 2020 $2,100 $9,300 36 $60

- $200 2030 $2,000 $21,100 73 $30

- $260 2040 $2,300 $30,700 94 $20

- $300 2050 $2,600 $38,200 114 $20

- $310 

### E. Impacts of Reduction in Fuel Consumption (1) What are the Projected Changes in Fuel Consumption The new CO 2 standards will result in significant improvements in the fuel efficiency of affected trucks. Drivers of those trucks will see corresponding savings associated with reduced fuel expenditures. The agencies have estimated the impacts on fuel consumption for the tailpipe CO 2 standards. To do this, fuel consumption is calculated using both current CO 2 emission levels and the new CO 2 standards. The difference between these estimates represents the net savings from the CO 2 standards. Note that the total number of miles that vehicles are driven each ye ar is different under the control case scenario than in the reference case due to the “rebound effect,” which is discussed in Section (5) VIII. E. (5) . EPA also notes that drivers who drive more than our average estimates for vehicle miles traveled (VMT) will experience more fuel savings; drivers who drive less than our average VMT estimates will experience less fuel savings. The expected impacts on fuel consumption are shown in Table VIII
- 4 . The gallons shown in the tables reflect impacts from the new CO 2 standards and include increased consumption resul ting from the rebound effect.318 of 54 1 Table VIII - 4 : Fuel Consumption Impacts of the Proposal (Million gallons)

Year Gasoline Diesel 2014 1.7 316 2015 4.9 624 2016 19 931 2017 39 1,393 2018 71 1,861 2020 132 2,72 3 2030 352 5,412 2040 468 7,004 2050 569 8,453 (2) Potential Impacts on Global Fuel Use and Emissions EPA’s quantified reductions in fuel consumption focus on the gains from reducing fuel used b y heavy

- duty vehicles within the United States. However, as d iscussed in section VIII. I, EPA also recognizes that this regulation will lower the world price of oil (the “monopsony” effect). Lowering oil prices could lead to an uptick in oil consumption globally , leading to a corresponding increase in GHG emissions in other countries. This global increase in emissions could slightly offset some of the emission reductions achieved domestically as a result of the regulation. EPA does not provide quantitative estimates of the impact of the regulation on global petrole um consumption and GHG emissions but invites comment on whether to consider this impact. (3) What are the Monetized Fuel Savings? Using the fuel consumption estimates presented in Table VIII
- 4 , the agencies can calculate the monetized fuel savings associated with the proposed standards. To do this, reduced fuel consumption is multiplied in each ye ar b y the corresponding estimated average fuel price in that year, using the reference case taken from the AEO 2010. These estimates do no t account for the significant uncertaint y in future fuel prices; the monetized fuel savings will be understated if actual fuel prices are higher ( or overstated if fuel prices are lower) than estimated. AEO is a standard reference used b y NHTSA and EPA and man y other government agencies to estimate the projected price of fuel. This has been done using both the pre

- tax and post

- tax fuel prices. Since the post

- tax fuel prices are the prices paid at fuel pumps , the fuel savings calculated using these prices r epresent the savings consumers would see. The pre

- tax fuel savings are those savings that society would see. These results are shown in Table VIII
- 5 . Note that in Section V III. K , the overall benefit s and cost s of the rule are p resented and, for that reason, onl y the pre

- tax fuel savings are presented there

. The agencies also request comment on the additional information that would be provided b y conducting sensitivity analy sis that considers the effect of uncertaint y in future f uel prices on estimated fuel savings. For instance, the Agencies could conduct sensitivity analy ses b y rel yi ng on the AEO2010 low oil price and high oil price scenarios.Draft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

319 of 54 1 Table VIII - 5 : Estimated Monetized Fuel Savings ($Millions of 2008 dollars) Year Fuel Savings

(pre

- tax) Fuel Savings

(post

- tax) 2014 $700 $800 2015 $1,400 $1,700 2016 $2,200 $2,700 2017 $3,600 $4,200 2018 $5,000 $5,900 2020 $8,000 $9,300 2030 $18,900 $21,100 2040 $28,000 $30,700 2050 $ 35,200 $38,200 NPV, 3% $351,100 $389,900 NPV, 7% $152,100 $170,100 As shown in Table VIII
- 5 , the agencies are projecting that truck consumers would realize very

large fuel savings as a result of the proposed standards

. As discu ssed further in the introductory

paragraphs of Section V III , it is a conundrum from an economic perspective that these large fuel savings have not been provided b y manufacturers and purchased b y consumers of these products

. Unlike in the light

- dut y vehicl e market, the vast majority

of vehicles in the medium

- and heavy

- dut y truck market are purchased and operated b y businesses; for them, fuel costs may represent substantial operating expenses. Even in the presence of uncertainty and imperfect information

– conditions that hold to some degree in every

market

– we generally

expect firms to be cost

- minimizing to survive in a competitive marketplace and to make decisions that are therefore in the best interest of the compan y and its owners and/or shareholders. A number of behavioral and market phenomena may lead to a disconnect between how businesses account for fuel savings in their decisions and the way in which we account for the full stream of fuel savings for this rule, including imperfect information in th e original and resale markets, split incentives, uncertainty in future fuel prices, and adjustment or transactions costs (see Section VIII. A for a more detailed discussion). As discussed below in the context of rebound in Section VIII.E.5, the nature of the explanation for this gap may influence the actual magnitude of the fuel savings. The agencies request comment on this issue as discussed in more detail in Section V IIIA

. The agencies also request comment on the interest in a sensitivity anal ys is that considers the role of fuel price uncertainty by considering lower and higher future fuel prices scenarios. (4) Payback Period and Lifetime Savings on New Truck Purchases Another factor of interest is the pay back period on the purchase of a new truck that comp lies with the new standards. In other words, how long would it take for the expected fuel savings to outweigh the increased cost of a new vehicle? For example, a new 2018 MY 2b/3 truck is estimated to cost $1,458 more, a vocational truck $349 more,320 of 54 1

and a combination truck $6,403 more (all values are on average, and relative to the reference case vehicle, see Table VI II
- 1 ) due to the addition of new GHG reducing technology . This new technology will result in lower fuel consumptio n and, therefore, savings in fuel expenditures. But how many months or y ears would pass before the fuel savings exceed the upfront costs? Table VIII
- 6 shows the pay back period anal ys is for Class 2b and 3 pickup trucks and vans. The table shows fuel consumed under the reference case and fuel consumed by a 2018 model year truck under the proposal, inclusive of fuel consumed due to rebound miles. The decrease in fuel consumed under the proposal is then monetized by multiplying by the fuel price reported b y AEO (reference case) in 2018. This value represents the fuel savings expected under the proposal for a Class 2b and 3 pickup or van. These savings are then discounted each ye ar since future savings are considered to be of less value than current savings. Shown next are estimated increased costs (costs do not necessaril y reflect increased prices which may be higher or lower than costs) for the new truck (refer to Table VIII
- 1 ). The next columns show the period required for the fuel savings to exceed the new truck costs. As seen in the table, in the fifth year of ownership, the discounted fuel savings (at 3%) have begun to outweigh the increased cost of the truck. Using 7% discounting , this pay back oc curs in ye ar 6. As shown in the table, the full life savings using 3% discounting would be $2,460 and at 7% discounting would be $1,500. Table VIII - 6 : Payback Period for a 2018 Model Year Class 2b/3 Pickup o r Van (2008$) Year of Ownersh ip Fuel Use (gallons) Fuel Savings ($) a In creas ed Cost ($) Cumulative Savings

($) Referen ce Case Proposa

l b Discount

ed at 3% Discount

ed at 7% Discount

ed at 3% Discount

ed at 7% 1 921 812 $327 $321

- $1,458

- $1,131

- $1,137 2 9 03 797 $321 $303

- $810

- $833 3 884 779 $315 $286

- $495

- $547 4 857 756 $303 $266

- $192

- $282 5 824 727 $291 $245 $99

- $37 6 786 693 $273 $222 $372 $185 7 742 654 $253 $198 $625 $383 Full L ife 12,103 10,670 $3,913 $2,969

- $1,458 $2,455 $1,512 N ote s : a Fuel savings calculated using the AEO 2010 reference case fuel prices. Gasoline and diesel fuel prices have been weighted by gasoline and diesel fuel reductions estimated for all 2018MY heavy

- duty trucks during their lifetimes. b Gallons under the proposal case include gallons consumed during rebound driving. The story is somewhat different for vocational trucks and combination trucks. These cases are shown in Table Table VIII
- 7 and Table Table VIII
- 8 , respectively . Since these trucks travel more miles in a given ye ar, their pay back periods are much shorter and actuall y are expected to occur within the first ye ar of ownership under both the 3% andDraft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

321 of 54 1 7% discounting cases. As can be seen in Tables Table VIII
- 7 and Table VI II
- 8 , the lifetime fuel savings are estimated to be considerable with savings of $4,000 (3%) and $3,100 (7%) for the vocational trucks and over $73,000 (3%) and $57,000 (7%) for th e combination trucks.

Table VIII - 7 : Payback Period for a 2018 Model Year Vocational Truck (2008$) Year of Ownersh ip Fuel Use (gallons) Fuel Savings ($) a In creas ed Cost ($) Cumulative Savings

($) Referen ce C ase Proposa

l b Discount

ed at 3% Discount

ed at 7% Discount

ed at 3% Discount

ed at 7% 1 2,093 1,928 $495 $486

- $3 49 $147 $138 2 1,917 1,766 $453 $428 $600 $566 3 1,755 1,617 $415 $378 $1,015 $944 4 1,601 1,475 $376 $330 $1,392 $1,273 5 1,448 1,334 $33 9 $286 $1,731 $1,559 6 1,303 1,200 $300 $244 $2,031 $1,803 7 1,177 1,084 $266 $208 $2,297 $2,010 Full L ife 20,030 18,464 $4,345 $3,413

- $3 49 $3,996 $3,065 Notes: a Fuel savings calculated using the AEO 2010 reference case fuel prices. Gasoline and d iesel fuel prices have been weighted by gasoline and diesel fuel reductions estimated for all 2018MY heavy

- duty trucks during their lifetimes. b Gallons under the proposal case include gallons consumed during rebound driving.322 of 54 1 Table VIII - 8 : Payback Period for a 2018 Model Year Combination Truck (2008$) Year of Ownershi p Fuel Use (gallons) Fuel Savings ($) a Increase d Cost ($) Cumulative Savings ($)
Referenc e Case Proposal

b Discounte

d at 3% Discounte

d at 7% D iscounte

d at 3% Discounte

d at 7% 1 30,257 27,011 $9,746 $9,567

- $6,403 $3,343 $3,164 2 27,801 24,814 $8,968 $8,474 $12,311 $11,638 3 25,415 22,681 $8,223 $7,480 $20,535 $19,117 4 23,049 20,566 $7,426 $6,502 $27,961 $25,620 5 20,652 18,425 $6,636 $5 ,593 $34,597 $31,213 6 18,353 16,371 $5,820 $4,722 $40,417 $35,935 7 16,325 14,559 $5,092 $3,977 $45,510 $39,912 Full L ife 261,897 233,569 $79,711 $64,032

- $6,403 $73,308 $57,629 Notes: a Fuel savings calculated using the AEO 2010 reference case fue l prices. Gasoline and diesel fuel prices have been weighted by gasoline and diesel fuel reductions estimated for all 2018MY heavy

- duty trucks during their lifetimes. b Gallons under the proposal case include gallons consumed during rebound driving.

All of these pay

back analy ses include fuel consumed during rebound VMT in the proposal or control case but not in the reference case, consistent with other parts of the anal ys is. Further, this analy sis does not include other societal impacts such as reduced t ime spent refueling or noise, congestion and accidents since the focus is meant to be on those factors consumers think about most while in the showroom considering a new car purchase. (5) Rebound Effect The VMT rebound effect refers to the fraction of fuel sav ings expected to result from an increase in fuel efficiency that is offset by additional vehicle use. If truck shipping costs decrease as a result of lower fuel costs, an increase in truck VMT may occur. Unlike the light

- duty rebound effect, the medium

- d uty and heav y - duty

rebound effect has not been extensively studied. Because the factors influencing the medium

- and heav y - dut y rebound effect are generally different from those affecting the light

- dut y rebound effect, much of the research on the light

- duty rebound effect is not likely to apply to the medium

- and heav y - dut y sectors. O ne of the major differences between the medium

- and heav y - duty rebound effect and the light

- dut y rebound effect is that heav y duty trucks are used primarily for commercial and business purposes. Since these businesses are profit driven, decision makers are highl y likely to be aware of the costs and benefits of different shipping decisions, both in the near term and long term. Therefore, shippers are much more likely to take i nto account changes in the overall operating costs per mile when making shipping decisions that affect VMT.Draft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

323 of 54 1 Another difference from the light

- dut y case is that, as discussed in the recent NAS Report 343 , when calculating the percentage change in trucking co sts to determine the rebound effect, all changes in the operating costs should be considered. The cost of labor and fuel generall y constitute the top two shares of truck operating costs, depending on the price of petroleum,. 344 , distance traveled, t ype of truck, and commodity

. 345 Finally , the equipment costs associated with the purchase or leasing of the truck is also a significant component of total operating costs. Even though vehicle costs are lump

- sum purchases, they can be considered operating costs for trucking firms, and these costs are, in many cases, expected to be passed onto the final consumers of shipping services on a variable basis. This shipping cost increase could help temper the rebound effect relative to the case of light

- dut y vehicles, in which vehicle costs are not considered operating costs. When calculating the net change in operating costs, both the increase in new vehicle costs and the decrease in fuel costs per mile should be taken into consideration. The higher the net cost savings, the higher the expected rebound effect. Conversel y, if the upfront vehicle costs outweighed future cost savings and total costs increased, shipping costs would rise, which would likely result in a decrease in truck VMT. In theory , other changes such as maintenance costs and insurance rates would also be taken into account, although information on these potential cost changes is extremely limited. We invite comment on the most appropriate methodology for factoring new vehicle purchase or leasing costs into the per

- mile operating costs. We also invite comment or data on how these regulations could affect maintenance, insurance, or other operating costs. The following sections describe the factors affecting the rebound effect, different methodologies for e stimating the rebound effect, and examples of different estimates of the rebound effect to date. According to the NAS study , it is “ not possible to provide a confident measure of the rebound effect , ” yet NAS concluded that a rebound effect likely exists and that “estimates of fuel savings from regulatory standards will be somewhat misestimated if the rebound effect is not considered.” While we believe the medium

- and heav y - dut y rebound effect needs to be studied in more detail, we have attempted to capture the potential impact of the rebound effect in our anal ys is. For this proposal, we have used a rebound effect for single unit trucks of 15%, a rebound effect for medium duty (2b and 3) trucks of 10%, and a rebound effect for combination tractors of 5%. These VMT impacts are reflected in the estimates of total GHG and other air pollution reductions presented in Chapter 5 of the draft RIA. We invite comment and the submission of additional data on the medium

- dut y and heav y - dut y rebound effect.

343 National Academy of Sciences (NAS) Report, 2010. Technologies and Approaches to Reducing the Fuel Consumption of Medium

- and Heavy

- Duty Vehicles. See http://www.nap.edu/catalog/12845.html 344 American Transportation Research Institute, An Analysis of the Operational Costs of Trucking , December 2008. 345 Transport Canada, Operating Cost of Trucks, 2005. See http://www.tc.gc.ca/eng/ policy/report

- acg operatingcost2005

- 2005

- e - 2

- 1727.htm , accessed on July 16, 2010. See also ATRI, 2008.324 of 54 1 (a ) Factors Affecting the Magnitude of the Rebound Effect The heav y - duty

vehicle rebound effect is driven by the interaction of several different factors. In the short

- run, decreasing the fuel cost per mile of driving could lead to a decrease in end product prices. Lower prices could stimulate additional demand for those products, which would then result in an increase in VMT. In the long run, shippers could reorganize their logistics and distribution networks to take advantage of lower truck shipping costs. For example, shippers may shift away

from other modes of shipping such as rail, barge, or air. In addition, shippers may also choose to reduce the number of warehouses, reduce load rates, and make smaller, more frequent shipments, all of which could also lead to an increase in heavy

- dut y VMT. Finally, the benefits of the fuel savings could ripple through the econom y and increase GDP, which would in turn increase overall demand for goods and services, and therefore increase truck VMT. Conversel y, if a fuel e conomy regulation leads to net increases in the cost of trucking because fuel savings do not fully offset the increase in upfront vehicle costs, then the price of trucking services could rise, spurring a decrease in heav y - duty VMT and shift to rail shippin g. These effects would also ripple through the econom y. Because these factors have not been well studied to date, the interaction and potential magnitude of these impacts is not well understood. However, the rebound effect is one of the determinant s of th e fuel savings likel y to result from adopting stricter fuel econom y or GHG emissions stan dards, and is thus an important parameter affecting EPA’s evaluation of alternative standards for future model y ears. Therefore, we invite submission of data regardin g the medium

- and heavy

- duty rebound effect. (b ) Options for Quantifying the Rebound Effect As described in the previous section, the fuel economy rebound effect for heavy

duty trucks has not been studied as extensively as the rebound effect for light

- duty ve hicles, and virtuall y no research has been conducted on the medium

- dut y truck rebound effect. In this proposal, we discuss four options for quantifying the rebound effect. We invite comment on these options, and we also welcome comment on other possible methodologies. (i ) Aggregate Estimates The aggregate approximation approach quantifies the overall change in truck VMT as a result of a percentage change in truck shipping prices. This approach relies on estimates of aggregate price elasticity of demand for trucking services, given a percentage change in trucking prices, which is generall y referred to as an “own

- price elasticity .” Estimates of trucking own

- price elasticities vary widel y, and there is no general consensus on the most appropriate values to u se. A 2004 literature survey cited in the recent NAS report 346 found aggregate elasticity estimates in the range of

- 0.5 to

-

346 NAS Report, 2010.Draft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

325 of 54 1 1.5. 347 Inother words, given an own

- price elasticit y of

- 1.5, a 10% decrease in trucking prices leads to a 15% increase in demand fo r truck shipping demand. However, this survey does not differentiate between studies that quantify change in tons shipped or ton

miles. In addition, most of the studies find that these elasticity estimates vary substantially

based on the length of the trip and the ty pe of cargo. For example, one study estimated an own

- price elasticit y of

- 0.1 for the lumber sector and

- 2.3 for the chemical sector. 348 The increase in overall truck VMT resulting from the rebound effect implicitly includes some component o f mode shifting. Since there are differences in GHG emissions per ton of freight moved by rail compared to truck, an y potential shifting of freight from one mode to the other could have GHG impacts. Although the total demand for freight transport is gene rall y determined b y economic activity, there is often the choice of shipping b y either truck or b y rail when freight is transported over land routes. This is because the United States has both an extensive highway network and an extensive rail network; th ese networks closel y parallel each other and are often both viable choices for freight transport for man y origin and destination pairs within the continent. If rates go down for one mode, there will be an increase in demand for that mode and some demand w ill be shifted from other modes. This “cross

- price elasticity” is a measure of the percentage change in demand for shipping by another mode (e.g., rail) given a percentage change in the price of trucking. Aggregate estimates of cross

- price elasticities a lso vary

widely , and there is no general consensus on the most appropriate value to use for anal yt ical purposes. The NAS report cites values ranging from 0.35 to 0.59. 349 Other reports provide significantly different cross

- price elasticities, ranging from 0.1 350 to 2.0. 351 When considering intermodal shift, the most relevant kinds of shipments are those that are competitive between rail and truck modes. These trips include long

- haul shipments greater than 500 miles, which weigh between 50,000 and 80,000 pound s (the legal road limit in many

states). Special kinds of cargo like coal and short

- haul deliveries are of less interest because they are generall y not economically transferable between truck and rail modes, and they would not be expected to shift modes e xcept under an extreme price change. However, the total volume of ton

- miles that could potentially be subject to mode shifting has also not been studied extensively

.

347 Graham and Glaister, “Road Traffic Demand Elasticity Estimates: A Review,” Transport Revie ws Volume 24, 3, pp. 261

- 274, 2004. 348 Winston, C. (1981). The welfare effects of ICC rate regulation revisited. The Bell Journal of Economics, 12, 232

- 244. 349 2010 NAS Report. See also 2009 Cambridge Systematics, Inc., Draft Final Paper commissioned by the NAS in support of the medium

- duty an d heavy

- duty report. Assessment of Fuel Economy Technologies for Medium and Heavy Duty Vehicles: Commissioned Paper on Indirect Costs and Alternative Approaches

. 350 Friedlaender, A. and Spady, R. (1980) A derived demand function for freight transportation , Revie w of Economics and Statistics, 62, pp. 432

–441. 351 Christidis and Leduc, “Longer and Heavier Vehicles for freight transport,” European Commission Joint Research Center’s Institute for Prospective Technology Studies, 2009.326 of 54 1 (ii) Sector

- Specific Estimates Given the limited data available regarding the medium

- and he av y - dut y rebound effect, the aggregate approach greatly simplifies many

of the assumptions associated with calculations of the rebound effect. In reality , however, responses to changes in fuel efficiency and new vehicle costs will vary significantly

base d on the commodities affected. A detailed, sector

- specific approach would be expected to more accurately reflect changes in the trucking market given these standards. For example, input

- output tables could be used to determine the trucking cost share of the total delivered price of a product or sector. Using the change in trucking prices described in the aggregate approach, the product

- specific demand elasticities could be used to calculate the change in sales and shipments for each product. The change in shipment increases could then be weighted b y the share of the trucking industry total, and then summed to get the total increase in trucking output. A simplifying assumption could then be made that the increase in output results in an increase in VMT. This ty pe of detailed data has not y et been collected, so we do not have an y calculations available for the proposal. While we hope to have this data available for the final rulemaking, gathering high quality data may take a longer time frame. We invite the submission of comments or data that could be used as part of this methodology

. (iii) Econometric Estimates Similar to the methodology used to estimate the light

- dut y rebound effect, the heav y - dut y rebound effect could be modeled econometrically b y estimating truck demand as a function of economic activity (e.g., GDP) and different input prices (e.g., vehicle prices, driver wages, and fuel costs per mile). This ty pe of econometric model could be estimated for either truck VMT or ton

- miles as a measure of demand. The resulting elasticity estimates could then be used to determine the change in trucking demand, given the change in fuel cost and truck prices per mile from these standards. (iv) Other Modeling Approaches Regulation of the heav y - duty industry has b een studied in more detail in Europe, as the European Commission (EC) has considered allowing longer and heavier trucks for freight transport. Part of the anal ys is considered by the EC relies on country

- specific modeling of changes in the freight sector that would result from changes in regulations. 352 This approach attempts to explicitly calculate modal shift decisions and impacts on GHG emissions. Although similar ty pes of anal ys is have not been conducted extensively in the U.S., research is currently un derway

that explores the potential for intermodal shifting in the U.S. For example, Winebrake and Corbett have developed the Geospatial Intermodal Freight Transportation (GIFT) model, which evaluates the potential for GHG emissions reductions based on mod e shifting, given existing limitations of infrastructure and other

352 Christidis and Leduc, “L onger and Heavier Vehicles for freight transport,” European Commission Joint Research Center’s Institute for Prospective Technology Studies, 2009.Draft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

327 of 54 1 route characteristics in the U.S. 353 This model connects multiple road, rail, and waterway transportation networks and embeds activity

- based calculations in the model. Within this intermo dal network, the model assigns various economic, time

- of

- delivery , energy , and environmental attributes to real

- world goods movement routes. The model can then calculate different network optimization scenarios, based on changes in prices and policies. 354 However, more work is needed in this area to determine whether this ty pe of methodology

is appropriate for the purposes of capturing the rebound effect. We invite comment on this approach, as well as suggestions on alternative modeling frameworks that cou ld be used to assess mode shifting, fuel consumption, and the GHG emission implications of these proposed regulations. (c) Estimates of the Rebound Effect The aggregate methodology was used by

Cambridge S ys tematics, Inc. (CSI) to show several examples of th e magnitude of the rebound effect. 355 In their paper commissioned by

the NAS in support of the recent medium

- and heav y - duty report, CSI calculated an effective rebound effect for two different technology cost and fuel savings scenarios associated with an example Class 8 truck. Scenario 1 increased average fuel econom y from 5.59 mpg to 6.8 mpg, with an additional cost of $22,930. Scenario 2 increased the average fuel economy to 9.1 mpg, at an incremental cost of $71,630 per vehicle. The CSI examples prov ided estimates using a range of own

- price elasticities (

- 0.5 to

- 1.5) and cross

- price elasticities (0.35 to 0.59) from the literature. Based on these two scenarios and a number of simplifying assumptions to aid the calculations, CSIfound a rebound effec t of 11

- 31% for Scenario 1 and 5

- 16% for Scenario 2 when the fuel savings from rail were not taken into account (“First rebound effect”). When the fuel savings from reduced rail usage were included in the calculations, the overall rebound effect was betwe en 9

- 13% for Scenario 1 and 3

- 15% for Scenario 2 (“Second Rebound Effect”). See Table VI II
- 9

. CSIincluded a number of caveats associated with these calculations. Namely , the elasticity estimates derived from the literature are “heavil y reliant on factors including the ty pe of demand measures anal yz ed (vehicle

- miles of travel, ton

- miles, or tons), anal ys is geograph y, trip lengths, markets served, and commodities transported .” Furthermore, the CSIexample only

focused on Class 8 combination tractors and did not attempt to quantify the potential rebound effect for any other truck classes. Finall y, these scenarios were characterized as “sketches” and were not included in the final NAS report. In fact, the NAS report asserted that it is “not possible to provide a confident measure of the

353 Winebrake, James and James J. Corbet (2010). “Improving the Energy Efficiency and Environmental Performance of Goods Movement,” in Sperling, Daniel and James S. Cannon (2010) Climate and Transportation Solutions: Findings from the 2009 Asilomar Conference on Transportation and Energy Policy. See http://www.its.ucdavis.edu/events/2009book/Chapter13.pdf 354 Winebrake, J. J.; Corbett, J. J.; Falzarano, A.; Ha wker, J. S.; Korfmacher, K.; Ketha, S.; Zilora, S., Assessing Energy, Environmental, and Economic Tradeoffs in Intermodal Freight Transportation, Journal of the Air &W

aste Management Association , 58(8), 2008. 355 Cambridge Systematics, Inc., “ Assessment of Fuel Economy Technologies for Medium and Heavy Duty Vehicles: Commiss ioned Paper on Indirect Costs and Alternative Approaches ,” September 17, 2009 ,328 of 54 1

rebound effect , ” yet concluded that a rebound effect likely exists and that “estimates of fuel savings from regulatory standards will be somewhat misestimated if the rebound effect is not considered .” Table VIII - 9 : Range of Rebound Effect Estimates fromCambridge Systematics Aggregate Assessment Scenario 1 (6.8 mpg, $22,930) Scenario 2

(9.1 mpg, $71,630) “First Rebound Effect” (increase in truck VMT resulting from decrease in operating costs) 11

- 31% 5
- 16% “Second Rebound Effect” (net fuel savings when decreases from rail are taken into account) 9

- 13 % 3

- 15%
As an alternative, using the econometric approach, NHTSA has estimated the rebound effect in the short run and long run for single unit (Class 4

- 7) and (Class 8) combination tractors. As shown in Table VIII
- 10 : , the estimates for the long

- run rebound effect are larger than the estimates in the short run, which is consis tent with the theory that shippers have more flexibility to change their behavior (e.g., restructure contracts or logistics) when they

are given more time. In addition, the estimates derived from the national data also showed larger rebound effects compar ed to the state data. 356 One possible explanation for the difference in the estimates is that the national rebound estimates are capturing some of the impacts of changes in economic activity. Historically , large increases in fuel prices are highly correlat ed with economic downturns, and there may not be enough variation in the national data to differentiate the impact of fuel price changes from changes in economic activity . In contrast, some states may see an increase in output when energy prices increase (e.g., large oil producing states such as Texas and Alaska); therefore, the state data may be more accurately

isolating the individual impact of fuel price changes. Table VIII - 10 : Range of Rebound Effect Estim ates from NHTSA Econometric Analysis Truck T ype National Data State Data

356 NHTSA’s estimates of the rebound effect are derived from econometric analysis of national and state VMT data reported in Federal Highway Administration, Highway Statistics , v arious editions, Tables VM

- 1 and VM

- 4. Specifically, the estimates of the rebound effect reported in Table VI II
- 10 are ranges of the estimated short

- run and long

- run elasticities of annual VMT by single

- unit and combination trucks with respect to fuel cos t per mile driven. (Fuel cost per mile driven during each year is equal to average fuel price per gallon during that year divided by average fuel economy of the truck fleet during that same year.) These estimates are derived from time

- series regression o f annual national aggregate VMT for the period 1970

- 2008 on measures of nationwide economic activity , including aggregate GDP, the value of durable and nondurable goods production, and the volume of U.S. exports and imports of goods , and variables affectin g the price of trucking services (driver wage rates, truck purchase prices, and fuel costs), and from regression of VMT for each individual state over the period 1994

- 2008 on similar variables measured at the state level.Draft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

329 of 54 1 Short Run Long Run Short Run Long Run Single Unit 13

- 22% 28

- 45% 3

- 8% 12

- 21% Combination N/A 12

- 14% N/A 4

- 5% As discussed throughout this section, there are multiple methodologies for quantifying the rebound effect, and these different methodologies produce a large range of potential values of the rebound effect. However, for the purposes of quantifying the rebound effect for this proposal, we have used a rebound effect with respe ct to changes in fuel costs per mile on the lower range of the long

- run estimates. Given the fact that the long

- run state estimates are generall y more consistent with the aggregate estimates, for this proposal we have chosen a rebound effect for single unit trucks of 15% that is within the range of estimates from both methodologies. Similarly , we have chosen a rebound effect for combination tractors of 5%. To date, no estimates of the medium

- duty (2b and 3) rebound effect have been cited in the literature. Since medium

- dut y vehicles are used for very different purposes than heav y - dut y vehicles, it does not necessaril y s eem appropriate to appl y one of the heav y - dut y estimates to the 2b and 3 classes. Class 2b and 3 vehicles are more similar in use to large light

- duty

vehicles, so for the purposes of our anal ys is, we have chosen to apply the light

- dut y rebound effect of 10% to this class of vehicles. For the purposes of this proposal, we have not taken into account an y potential fuel savings or GHG em ission reductions from the rail sector due to mode shifting. However, we have provided CSI ’s example calculations and request comment on these values. Furthermore, we have made a number of simplifying assumptions in our calculations, which are discussed in more detail in the RIA. Specificall y, we have not attempted to capture how current market failures might impact the rebound effect. The direction and magnitude of the rebound effect in the medium

- and heav y - duty truck market are expected to vary depe nding on the existence and t ypes of market failures affecting the fuel economy of the trucking fleet. If firms are already accurately accounting for the costs and benefits of these technologies and fuel savings, then these regulations would increase their net costs, because trucks would already include all the cost
- effective technologies. As a result, the rebound effect would actually be negative and truck VMT would decrease as a result of these proposed regulations. However, if firms are not optimizing their behavior today due to factors such as lack of reliable information (see Section VIII.A. for further discussion), it is more likely that truck VMT would increase. If firms recognize their lower net costs as a result of these regulations and pass thos e costs along to their customers, then the rebound effect would increase truck VMT. This response assumes that trucking rates include both truck purchase costs and fuel costs, and that the truck purchase costs included in the rates spread those costs over the full expected lifetime of the trucks. If those costs are spread over a shorter period, as the expected short pay back period implies, then those purchase costs will inhibit reduction of freight rates, and the rebound effect will be smaller.330 of 54 1 As discus sed in more detail in Section VIII.A, if there are market failures such as split incentives, estimating the rebound effect may depend on the nature of the failures. For example, if the original purchaser cannot fully recoup the higher upfront costs through fuel savings before selling the vehicle nor pass those costs onto the resale buy er, the firm would be expected to raise shipping rates. A firm purchasing the truck second

hand might lower shipping rates if the firm recognizes the cost savings after oper ating the vehicle, leading to an increase in VMT. Similarl y, if there are split incentives and the vehicle bu yer isn’t the same entity that purchases the fuel, than there would theoreticall y be a positive rebound effect. In this scenario, fuel savings wo uld lower the net costs to the fuel purchaser, which would result in a larger increase in truck VMT. If all of these scenarios occur in the marketplace, the net effect will depend on the extent and magnitude of their relative effects, which are also lik el y to vary across truck classes (for instance, split incentives may be a much larger problem for class 7 and 8 tractors than they

are for heavy

dut y pickup trucks). Additional details on the rebound effect are included in the draft RIA. We invite comment on all of the rebound estimates and assumptions. 

### F. Class Shifting and Fleet Turnover Impacts The agencies considered two additional potential indirect costs, benefits, effects, and externalities which may lead to unintended consequences of the proposal to improve the fuel efficiency

and reduce GHG emissions from HD trucks. The next sections cover the agencies’ qualitative discussions on potential class shifting and fleet turnover effects. (1) Class shifting Heav y dut y vehicles are typically configured and purchased to perform a function. For example, a concrete mixer truck is purchased to transport concrete, a combination tractor is purchased to move freight with the use of a trailer, and a Class 3 pickup truck could be purchased b y a landscape compan y to pul l a trailer carrying lawnmowers. The purchaser makes decisions based on man y attributes of the vehicle, including the gross vehicle weight rating of the vehicle which in part determines the amount of freight or equipment that can be carried. If the agenci es propose a regulation that impacts either the performance of the vehicle or the marginal cost of the vehicle relative to the other vehicle classes, then consumers could choose to purchase a different vehicle which may result in an unintended consequence of increased fuel consumption and GHG emissions in

- use. The agencies, along with the NAS panel, found that there is little or no literature which evaluates class shifting between trucks. 357 The agencies welcome comments that would help inform the evaluation of this potential impact. NHTSA and EPA qualitatively evaluated the proposed rule in light of potential class shifting. The agencies looked at four potential cases of shifting

- from light dut y pickup trucks to heav y duty pickup

357 NAS. Page 6

- 38.Draft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

331 of 54 1 trucks, from sleeper cab s to day cabs, from combination tractors to vocational trucks, and within vocational trucks. Li ght duty

pickup trucks, those with a GVWR of less than 8,500 pounds, are currentl y regulated under the existing CAFE program and will meet GHG emissions standard s beginning in 2012. The increased stringency of the 2012

- 2016 light

- dut y GHG and CAFE rule has led some to speculate that vehicle consumers may choose to purchase heav y - dut y pickup trucks that are currentl y unregulated if the cost of the light

- duty regul ation is high relative to the cost to buy the larger heavy

- dut y pickup trucks. Since fuel consumption and GHG emissions rise significantly with vehicle mass, a shift from light

- duty trucks to heavy

- dut y trucks would likely lead to higher fuel consumption and GHG emissions, an untended consequence of the regulations. Given the significant price premium of a heav y - dut y truck (often five to ten thousand dollars more than a light

- dut y pickup), we believe that such a class shift would be unlikely even absent t oday ’s proposed regulations. With today ’s proposed regulation, any incentive for such a class shift is significantly

diminished. The proposed regulations for the HD pickup trucks, and similarly for vans, are based on similar technologies and therefore ref lect a similar expected increase in cost when compared to the light

- duty GHG regulation. Hence, the combination of the two regulations provides little incentive for a shift from light

- duty trucks to HD trucks. To the extent that our proposed regulation o f heav y - duty pickups and vans could conceivably encourage a class shift towards lighter pickups, this unintended consequence would in fact be expected to lead to lower fuel consumption and GHG emissions as the smaller light

- dut y pickups are significantl y m ore efficient than heav y - dut y pickup trucks. The projected cost increases for our proposal differ significantly between class 8 day cabs and class 8 sleeper cabs reflecting our expectation that compliance with the proposed standards will lead truck consume rs to specify sleeper cabs equipped with auxiliary power units (APUs) while day cab consumers will not. Since Class 8 day cab and sleeper cab trucks perform essentiall y the same function when hauling a trailer, this raises the possibility

that the higher cost for an APU equipped sleeper cab could lead to a shift from sleeper cab to day cab trucks. We do not believe that such an intended consequence will occur for the following reasons. The addition of a sleeper berth to a tractor cab is not a consumer

- se lectable attribute in quite the same way as other vehicle features. The sleeper cab provides a utility that long

- distance trucking fleets need to conduct their operations

-- an on - board sleeping berth that lets a driver comply with federally

- mandated rest periods, as required by the Department of Transportation Federal Motor Carrier Safet y Administration's hours

- of

- service regulations. The cost of sleeper trucks is already higher than the cost of day cabs, y et the fleets that need this utility purchase them. 358 A day

cab simply

cannot provide this utility . The need for this utility would not be changed even if the marginal costs to reduce greenhouse gas emissions

358 A baseline tr actor price of a new day cab is $89,500 versus $113,000 for a new sleeper cab based on information gathered by ICF in the “Investigation of Costs for Strategies to Reduce Greenhouse Gas Emissions for Heavy

- Duty On

- Road Vehicles”, July 2010. Page 3.332 of 54 1

from sleeper cabs exceed the marginal costs to reduce greenhouse gas emissions from day cabs. 359 A trucking fleet could decide to put its drivers in hotels in lieu of using sleeper berths, and switch to day cabs. However, this is unlikely to occur in any

great number, since the added cost for the hotel stay s would far overwhelm differences in the marginal cost between day and sleeper cabs. Even if some fleets do opt to buy hotel rooms and switch to day

cabs, they

would be highly

unlikel y to purchase a day cab that was aerod ynamicall y worse than the sleeper cab they replaced, since the need for fea tures optimized for long

- distance hauling would not have changed. So in practice, there would likely be little difference to the environment for any switching that might occur. Further, while our projected costs assume the purchase of an APU for complian ce, in fact our regulatory

structure would allow compliance using a near zero cost software utility that eliminates tractor idling after five minutes. Using this compliance approach, the cost difference between a class 8 sleeper cab and day cab due to our proposed regulations is small. We are providing this alternative compliance approach reflecting that some sleeper cabs are used in team driving situations where one driver sleeps while the other drives. In that situation, an APU is unnecessary since the tractor is continually being driven when occupied. When it is parked, it will automatically eliminate any

additional idling through the shutdown software. If trucking companies choose this option, then costs based on purchase of APUs may overestimate th e costs of this rule to this sector. Class shifting from combination tractors to vocational trucks may occur if a customer deems the additional marginal cost of tractors due to the regulation to be greater than the utility

provided by

the tractor. The age ncies initially considered this issue when deciding whether to include Class 7 tractors with the Class 8 tractors or regulate them as vocational trucks. The agencies’ evaluation of the combined vehicle weight rating of the Class 7 shows that if these vehi cles were treated significantly differently

from the Class 8 tractors, then they

could be easil y substituted for Class 8 tractors. Therefore, the agencies are proposing to include both classes in the tractor category. The agencies believe that a shift fr om tractors to vocational trucks would be limited because of the ability of tractors to pick up and drop off trailers at locations which cannot be done b y vocational trucks. The agencies do not envision that the proposed regulatory program will cause class shifting within the vocational class. The marginal cost difference due to the regulation of vocational trucks is minimal. The cost of low rolling resistance tires on a per tire basis is the same for all vocational trucks so the only difference in margin al cost of the vehicles is due to the number of axles. The agencies believe that the utility gained from the additional load carrying capabilit y of the additional axle will outweigh the additional cost for heavier vehicles. 360 In conclusion, NHTSA and EPA b elieve that the proposed regulatory structure for HD trucks does not significantly change the current competitive and market factors that

359 The average marginal cost difference between sleeper cabs and day cabs in the proposal is nearly $6,000. 360 The proposed rule projects the difference in costs between the HD and MD vocational truck technologies is approximately $30.Draft Joint EPA/NHT SA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

333 of 54 1 determine purchaser preferences among truck t yp es. Furthermore, even if a small amount of shifting does occur, any re sulting GHG impacts are likel y to be negligible because an y vehicle class that sees an uptick in sales is also being regulated for fuel economy

. Therefore, the agencies did not include an impact of class shifting on the vehicle populations used to assess the benefits of the proposal. The agencies welcome comments to inform the benefits assessment of the final rule. (2) Fleet Turnover Effect A regulation that increases the cost to purchase and/or operate trucks could impact whether a consumer decides to purcha se a new truck and the timing of that purchase. The term pre

- buy

refers to the idea that truck purchases may occur earlier than otherwise planned to avoid the additional costs associated with a new regulatory requirement. Slower fleet turnover, or low

- buys , may occur when owners opt to keep their existing truck rather than purchase a new truck due to the incremental cost of the regulation. The NAS panel discusses the topics associated with HD truck fleet turnover. NAS noted that there is some empirical evidence of pre

- buy behavior in response to the 2004 and 2007 heav y - duty engine emission standards, with larger impacts occurring in response to higher costs. 361 However, those regulations increased upfront costs to firms without any

offsetting future cost savings from reduced fuel purchases. In summary , NAS stated that ...during periods of stable or growing demand in the freight sector, pre

buy behavior may

have significant impact on purchase patterns, especially for larger fleets with better access to capit al and financing. Under these same conditions, smaller operators may simpl y elect to keep their current equipment on the road longer, all the more likel y given continued improvements in diesel engine durability over time. On the other hand, to the extent that fuel economy improvements can offset incremental purchase costs, these impacts will be lessened. Nevertheless, when it comes to efficiency

investments, most heavy dut y fleet operators require relativel y quick payback periods, on the order of two to three ye ars. 362 The regulations the agencies are proposing today are projected to return fuel savings to the truck owners that offset the cost of the regulation within a few y ears for vocational trucks and class 7 and 8 tractors, the categories where the potential for prebu y and delayed fleet turnover are concerns. In the case of vocational vehicles, the added cost is small enough that it is unlikely to have a substantial effect on purchasing behavior. In the case of class 7 and 8 trucks, the effects of the regulation on purchasing behavior will depend on the nature of the market failures and the extent to which firms consider the projected future fuel savings in their purchasing decisions.

361 NAS p. 6

- 36

– 6

- 37 362 NAS R eport. Page 6

- 37.334 of 54 1 If trucking firms account for the rapid pay back, they

are unli kel y to strategically accelerate or delay

their purchase plans at additional cost in capital to avoid a regulation that will lower their overall operating costs. As discussed in Section VIII.A., this scenario may

occur if this proposed rule reduces uncert aint y about fuel

- saving technologies. More reliable information about way s to reduce fuel consumption allows truck purchasers to evaluate better the benefits and costs of additional fuel savings, primarily in the original vehicle market, but possibly in the resale market as well. Other market failures may leave open the possibility of some pre

- buy

or delayed purchasing behavior. Firms may not consider the full value of the future fuel savings for several reasons. For instance, truck purchasers may not want to invest in fuel econom y because of uncertaint y about fuel prices. Another explanation is that the resale market may not full y recognize the value of fuel savings, due to lack of trust of new technologies or changes in the uses of the vehicles. La ck of coordination (also called split incentives

— see Section VIII.A) between truck purchasers (who emphasize the up

- front costs of the trucks) and truck operators, who would like the fuel savings, can also lead to pre - buy or delayed purchasing behavior. I f these market failures prevent firms from fully internalizing fuel savings when deciding on vehicle purchases, then pre

- buy and delayed purchase could occur and could result in a slight decrease in the GHG benefits of the regulation. Thus, whether pre

- b uy

or delayed purchase is likely to play a significant role in the truck market depends on the specific behaviors of purchasers in that market. Without additional information about which scenario is more likely to be prevalent, the Agencies are not projec ting a change in fleet turnover characteristics due to this regulation. We welcome comments on all aspects of this assumption, especiall y in the context of our assumed increase in truck freight shipments due to a VMT rebound. 

### G. Benefits of Reducing CO 2 

### Emis sions (1) Social Cost of Carbon EPA has assigned a dollar value to reductions in carbon dioxide ( CO 2 ) emissions using recent estimates of the “social cost of carbon” (SCC). The SCC is an estimate of the monetized damages associated with an incremental increas e in carbon emissions in a given ye ar. Itis intended to include (but is not limited to) changes in net agricultural productivity , human health, propert y damages from increased flood risk, and the value of ecos ys tem services due to climate change. The SC C estimates used in this anal ys is were developed through an interagency process that included EPA, DOT/NHTSA, and other executive branch entities, and concluded in February 2010. We first used these SCC estimates in the benefits anal ys is for the final joi nt EPA/DOT rule to establish l ight

- d uty v ehicle GHG e mission e tandards and CAFE s tandards; see the rule’s preamble for discussion about application of the SCC

. 363 The SCC Technical Support Document (SCC

363 See U.S. EPA 2010 LD Final Rule, Note (#).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

335 of 541 TSD) provides a complete discussion of the methods use d to develop these SCC estimates. 364 The interagency

group selected four SCC values for use in regulatory anal yses, which we have applied in this analy sis: $5, $22, $36, and $67 per metric ton of CO2 emissions in 2010, in 2008 dollars. 365 , 366 The first thre e values are based on the average SCC from three integrated assessment models, at discount rates of 2.5, 3, and 5 percent, respectivel y. SCCs at several discount rates are included because the literature shows that the SCC is quite sensitive to assumption s about the discount rate, and because no consensus exists on the appropriate rate to use in an intergenerational context. The fourth value is the 95th percentile of the SCC from all three models at a 3 percent discount rate. It is included to represent h igher

- than

- expected impacts from temperature change further out in the tails of the SCC distribution. L ow probability , high impact events are incorporated into all of the SCC values through explicit consideration of their effects in two of the three models as well as the use of a probability density function for equilibrium climate sensitivity . Treating climate sensitivity probabilistically

results in more high temperature outcomes, which in turn lead to higher projections of damages. The SCC increases ove r time because future emissions are expected to produce larger incremental damages as ph ys ical and economic sy stems become more stressed in response to greater climatic change. Note that the interagency group estimated the growth rate of the SCC directly using the three integrated assessment models rather than assuming a constant annual growth rate. This helps to ensure that the estimates are internally consistent with other modeling assumptions. Table VIII
- 11 presents the SCC es timates used in this analy sis. When attempting to assess the incremental economic impacts of carbon dioxide emissions, the analy st faces a number of serious challenges. A recent report from the National Academies of Science points out that an y assessment will suffer from uncertaint y, speculation, and lack of information about (1) future emissions of greenhouse gases, (2) the effects of past and future emissions on the climate sy stem, (3)

364 Docket ID EPA

- HQ

- OAR

- 2009

- 0472

- 114577, Technical Support Document: Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866, Interagency Working Group on Social Cost of Carbon , with participation by Council of Economic Advisers, Council on Environmental Quality, Department of Agriculture, Department of Commerce, Department of Energy, Department of Transportation, Environmental Protection Agency, National Economic Counc il, Office of Energy and Climate Change, Office of Management and Budget, Office of Science and Technology Policy, and Department of Treasury (February 2010). Also available at http://epa.gov/ota q/climate/regulations.htm 365 The interagency group decided that these estimates apply only to CO 2 emissions. Given that warming profiles and impacts other than temperature change (e.g. ocean acidification) vary across GHGs, the group concluded “transforming gases into CO 2 - equivalents using GWP, and then multiplying the carbon

equivalents by the SCC, would not result in accurate estimates of the social costs of non

- CO 2 gases” (SCC TSD, pg 13). 366 The SCC estimates were converted from 2007 dollars to 2008 do llars using a GDP price deflator (1.021) obtained from the Bureau of Economic Analysis, National Income and Product Accounts Table 1.1.4, Prices Indexes for Gross Domestic Product

.336 of 54 1

the impact of changes in climate on the phy sical and biological envir onment, and (4) the translation of these environmental impacts into economic damages. 367 As a result, any effort to quantify

and monetize the harms associated with climate change will raise serious questions of science, economics, and ethics and should be v iewed as provisional. The interagency

group noted a number of limitations to the SCC analy sis, including the incomplete way in which the integrated assessment models capture catastrophic and non

- catastrophic impacts, their incomplete treatment of adaptat ion and technological change, uncertaint y in the extrapolation of damages to high temperatures, and assumptions regarding risk aversion. The limited amount of research linking climate impacts to economic damages makes the interagency modeling exercise eve n more difficult. The interagency group hopes that over time researchers and modelers will work to fill these gaps and that the SCC estimates used for regulatory anal ys is by

the Federal government will continue to evolve with improvements in modeling. Add itional details on these limitations are discussed in the SCC TSD. In light of these limitations, the interagency group has committed to updating the current estimates as the science and economic understanding of climate change and its impacts on society

i mproves over time. Specifically , the interagency group has set a preliminary

goal of revisiting the SCC values in the next few y ears or at such time as substantially

updated models become available, and to continue to support research in this area. Applying the global SCC estimates, shown in Table VIII
- 11 , to the estimated domestic reductions in CO 2 emissions under this proposed rule, we estimate the dollar value of the climate related benefits for each analysis year. For intern al consistency , the annual benefits are discounted back to net present value terms using the same discount rate as each SCC estimate (i.e. 5%, 3%, and 2.5%) rather than 3% and 7%. 368 These estimates are provided in Table VIII
- 12

.

367 Cite NRC 2009 368 It is possible that other benefits or costs of proposed regulations unrelated to CO 2 emissions will be discounted at rates that differ from those used to develop the SCC estimates.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

337 of 541 Table VIII - 11 : Social Cost of CO 2 , 2010

– 2050 a (in 2008 dollars) Year Discount Rate and Statistic

5% Average 3% Average 2.5% Average 3% 95th percentile 2010 $4.80 $21.85 $35.84 $66.26 2015 $5 .87 $24.35 $39.21 $74.33 2020 $6.94 $26.85 $42.58 $82.39 2025 $8.45 $30.15 $46.84 $92.25 2030 $9.95 $33.44 $51.10 $102.10 2035 $11.46 $36.73 $55.36 $111.95 2040 $12.97 $40.02 $59.63 $121.81 2045 $14.50 $42.93 $63.00 $130.43 2050 $16.03 $45.84 $66.37 $139.06
a The SCC values are dollar

- year and emissions

- year specific.

Table VIII - 12 : Monetized CO 2 Benefits of Vehicle Program , CO2 Emissions a (Million 2008$) YEAR CO 2

EMI SSI ONS REDUCTION (Million Metric Tons) BENEFITS

Avg SCC at 5% ($5

- $16) a Avg SCC at 3%

($22

- $46) a Avg SCC at

2.5% ($36

- $66) a 95 th percentile

SCC at 3% ($66

- $139) a 2020 33.3 $231 $894 $1,418 $2,744 2030 64.1 $638 $2,144 $3,277 $6,548 2040 82.4 $1,068 $3,297 $4,911 $10,033 2050 97.8 $ 1,568 $4,486 $6,494 $13,606 Net Present Value b 2,310 $8,100 $41,000 $69,700 $125,300

a Except for the last row (net present value), the SCC values are dollar

- year and emissions

- year specific

. b Net present value of reduced CO 2 emissions is calculated dif ferently from other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 2.5 percent) is used to calculate net present value of SCC for internal consistency. Refer to the SCC TSD for more detail. 

### H. Non - GHG Health and Environmental Impacts This section discusses the non

- GHG health and environmental impacts that can be expected to occur as a result of the proposed heavy

- dut y vehicle GHG rule. GHG emissions are predominantly the b yproduct of fossil fuel co mbustion processes that also produce criteria and hazardous air pollutants. The vehicles that are subject to the proposed standards are also significant sources of mobile source air pollution such as direct PM, NO X , VOCs and air toxics. The proposed stan dards would affect exhaust emissions of these pollutants from vehicles. They would also affect emissions from upstream sources related to changes in fuel consumption. Changes in ambient ozone, PM 2.5 , and air toxics that would result from the proposed sta ndards are expected to affect338 of 54 1

human health in the form of premature deaths and other serious human health effects, as well as other important public health and welfare effects. It is important to quantify the health and environmental impacts associated w ith the proposed standard because a failure to adequately consider these ancillary co pollutant impacts could lead to an incorrect assessment of their net costs and benefits. Moreover, co
- pollutant impacts tend to accrue in the near term, while an y effect s from reduced climate change mostly accrue over a time frame of several decades or longer. EPA ty picall y quantifies and monetizes the health and environmental impacts related to both PM and ozone in its regulatory impact anal ys es (RIAs), when possible. However, EPA was unable to do so in time for this proposal. EPA attempts to make emissions and air quality

modeling decisions earl y in the anal yt ical process so that we can complete the photochemical air quality modeling and use that data to inform the h ealth and environmental impacts anal ys is. Resource and time constraints precluded the Agency from completing this work in time for the proposal. Instead, we provide a characterization of the health and environmental impacts that will be quantified and mo netized for the final rulemaking. EPA bases its anal ys es on peer - reviewed studies of air qualit y and health and welfare effects and peer

- reviewed studies of the monetary values of public health and welfare improvements, and is generall y consistent with b enefits anal ys es performed for the anal ys is of the final Ozone National Ambient Air Quality Standard (NAAQS) and the final PM NAAQS anal ys is, as well as the proposed Portland Cement National Emissions Standards for Hazardous Air Pollutants (NESHAP) RIA, an d final NO 2 NAAQS. 369 , 370 , 371 , 372 Though EPA is characterizing the changes in emissions associated with toxic pollutants, we will not be able to quantify or monetize the human health effects associated with air toxic pollutants for either the proposal or the fi nal rule analy ses. Please refer to Section VII for more information about the air toxics emissions impacts associated with the proposed standards.

369 U.S. Environmental Protection Agency. (2008). Final Ozone NAAQS Regulatory Impact Analysis. Prepared by: Office of Air and Rad iation, Office of Air Quality Planning and Standards. March. 370 U.S. Environmental Protection Agency. October 2006. Final Regulatory Impact Analysis (RIA) for the Proposed National Ambient Air Quality Standards for Particulate Matter. Prepared by: Offic e of Air and Radiation. 371 U.S. Environmental Protection Agency (U.S. EPA). 2009. Regulatory Impact Analysis: National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. Office of Air Quality Planning and S tandards, Research Triangle Park, NC. April. Available on the Internet at <http://www.epa.gov/ttn/ecas/regdata/RIAs/portlandcementria_4

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- 09.pdf>. EPA

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- 0241 372 U.S. Environmental Protection Agency (U.S. EPA). 2010. Final NO2 NAAQS Regulatory Im pact Analysis (RIA). Office of Air Quality Planning and Standards, Research Triangle Park, NC. April. Available on the Internet at http://www.epa.gov/ttn/ecas/regdata/RIAs/FinalNO2RIAfulldocument.pdf. Accessed March 15. EPA

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339 of 541 (1) Human Health and Environmental Impacts To model the ozone and PM air quality benefits of the final rule, EPA will use the Community

Multiscale Air Quality

(CMAQ) model (see VI I.C for a description of the CMAQ model). The modeled ambient air quality data will serve as an input to the Environmental Benefits Mapping and Anal ys is Program (BenMAP). 373 BenMAP is a computer program developed by EPA that integrates a number of the modeling elements used in previous RIAs (e.g., interpolation functions, population projections, health impact functions, valuation functions, analy sis and pooling methods) to translate modeled air concentration estimates into health effects incidence estimates and monetized benefits estimates. Chapter 8.3 in the draft RIA that accompanies this proposal lists the co

- pollutant health effect exposure

- response functions EPA will use to quantify th e co - pollutant incidence impacts associated with the final heavy

- duty vehicles standard. These include PM
- and ozone

- related premature mortality , chronic bronchitis, nonfatal heart attacks, hospital admissions (respiratory and cardiovascular), emergency r oom visits, acute bronchitis, minor restricted activity day s, and days of work and school lost. (2) Monetized Impacts To calculate the total monetized impacts associated with quantified health impacts, EPA applies values derived from a number of sources. For premature mortality , EPA applies a value of a statistical life (VSL) derived from the mortality valuation literature. For certain health impacts, such as chronic bronchitis and a number of respiratory

- related ailments, EPA applies willingness

- to
- pay estim ates derived from the valuation literature. For the remaining health impacts, EPA applies values derived from current cost
- of

- illness and/or wage estimates. Chapter 8.3 in the DRIA that accompanies this proposal presents the monetary values EPA will appl y to changes in the incidence of health and welfare effects associated with the final standard. (3) Other Unquantified Health and Environmental Impacts In addition to the co

- pollutant health and environmental impacts EPA will quantify for the anal ys is of the final standard, there are a number of other health and human welfare endpoints that EPA will not be able to quantify or monetize because of current limitations in the methods or available data. These impacts are associated with emissions of air toxics (i ncluding benzene, 1,3

- butadiene, formaldehyde, acetaldehyde, and acrolein), ambient ozone, and ambient PM 2.5 exposures. Chapter 8 .3 of the DRIA lists these unquantified health and environmental impacts. While there will be impacts associated with air toxi c pollutant emission changes that result from the final standard, EPA will not attempt to monetize those impacts. This

373 I nformation on BenMAP, including downloads of the software, can be found at http://www.ep a.gov/ttn/ecas/ benmodels.html

.340 of 54 1

is primarily

because currently

available tools and methods to assess air toxics risk from mobile sources at the national scale are not a dequate for extrapolation to incidence estimations or benefits assessment. The best suite of tools and methods currently available for assessment at the national scale are those used in the National

- Scale Air Toxics Assessment (NATA). The EPA Science Advi sory Board specifically

commented in their review of the 1996 NATA that these tools were not yet read y for use in a national

- scale benefits analy sis, because they did not consider the full distribution of exposure and risk, or address sub

- chronic health ef fects. 374 While EPA has since improved the tools, there remain critical limitations for estimating incidence and assessing benefits of reducing mobile source air toxics. EPA continues to work to address these limitations; however, EPA does not anticipate having methods and tools available for national

- scale application in time for the anal ys is of the final rules. 375



### I. Energy Security Impacts This proposed rule to reduce fuel consumption and GHG emissions in heavy dut y vehicles results in improved fuel effic iency which, in turn, helps to reduce U.S. petroleum imports. A reduction of U.S. petroleum imports reduces both financial and strategic risks caused b y potential sudden disruptions in the supply of imported petroleum to the U.S. This reduction in risk is a measure of improved U.S. energy security . This section summarizes our estimates of U.S. oil import reductions and energy securit y benefits of the proposed heavy dut y fuel consumption and GHG vehicle standards

. Additional discussion of this issue can b e found in Chapter 9.4 of the draft RIA. (1) Implications of Reduced Petroleum Use on U.S. Imports In 2008, U.S. petroleum import expenditures represented 21 percent of total U.S. imports of all goods and services. 376 In2008, the U.S. imported 66 percent of the petroleum it consumed, and the transportation sector accounted for 70 percent of total U.S. petroleum consumption. This compares to approximately 37 percent of petroleum from imports and 55 percent of consumption from petroleum in the transportation sect or

374 Science Advisory Board. 2001. NATA

– Evaluating the National

- Scale Air Toxics Assessment for 1996

– an SAB Advisory. http://www .epa.gov/ttn/atw/sab/sabrev.html. 375 In April, 2009, EPA hosted a workshop on estimating the benefits of reducing hazardous air pollutants. This workshop built upon the work accomplished in the June 2000 Science Advisory Board/EPA Workshop on the Benefits of Reductions in Exposure to Hazardous Air Pollutants, which generated thoughtful discussion on approaches to estimating human health benefits from reductions in air toxics exposure, but no consensus was reached on methods that could be implemented in the near term for a broad selection of air toxics. Please visit http://epa.gov/air/toxicair/2009workshop.html for more information about the workshop and its associated materials. 376 Source: U.S. Bureau of Economic Analysis, U.S. International Transactions Acc ounts Data, as shown on June 24, 2009.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

341 of 541 in 1975. 377 Itis clear that petroleum imports have a significant impact on the U.S. econom y. Requiring lower

- GHG vehicle technology in heavy

- dut y vehicles in the U.S. is expected to lower U.S. oil imports. EPA used the MOVES model to estimate the fuel savings due to this proposal. A detailed explanation of the MOVES model can be found in Chapter 5 of the draft RIA. Based on a detailed anal ysis of differences in fuel consumption, petroleum imports, and imports of refined petroleum products and crude oil among the Reference Case, High Economic Growth, and Low Economic Growth Scenarios presented in the Energy Information Administration’s Annual Energy Outlook (AEO) 2009 , EPA and NHTSA estimate that approximately 50 percent of the reduction in fuel consumption resulting from adopting improved fuel GHG standards and fuel econom y standards is likely to be reflected in reduced U.S. imports of refined fuel, while the remaining 50 percent would be expected to be reflected in reduced domestic fuel refining

. Of this latter figure, 90 percent is anticipated to reduce U.S. imports of crude petroleum for use as a refinery feedstock, while the remaining 10 percent is expected to reduce U.S. domestic production of crude petroleum. Thus , on balance, each gallon of fue l saved as a consequence of the heavy dut y GHG standards and fuel econom y standards is anticipated to reduce total U.S. imports of crude petroleum or refined fuel b y 0.95 gallons. 378 EPA’s estimates that the reduction in U.S. oil imports from this proposal for the years 2020, 2030 and 2040, in millions of barrels per day (MMBD), are presented in Table VIII
- 13 below. Table VIII - 13 : U.S. Oil Import Reductions fromthe Heavy - Duty Vehicle Rule in 2020, 2030 and 2040 (in MMBD) 2020 2030 2040 0.177 0.357 0.463
(2) Energy Security Im plications In order to understand the energy securit y implications of reducing U.S. petroleum imports, EPA worked with Oak Ridge National Laboratory (ORNL), which h as developed approaches for evaluating the economic costs and energy security implications of oil use. The energy security estimates provide d below are based upon a methodology

developed in a peer

- reviewed study entitled " T he Energy Security Benefits

377 Source: U.S. Department of Energy, Annual Energy Revie w 2008, Report No. DOE/EIA

- 0384(2008), Tables 5.1 and 5.13c, June 26, 2009. 378 This figure is calculated as 0.50 + 0.50*0.9 = 0.50 + 0.45 = 0.95.342 of 54 1

of Reduced Oil Use, 2006

- 2015 ," completed in March 2008. This study is included as part of the docket for this proposal

. 379 , 380 When conducting this analy sis, ORNL considered the full economic cost of importing petroleum into the U.S. The e conomic cost of importing petroleum into the U.S. is defined to include two components in addition to the purchase price of petroleum itself. These are: (1) the higher costs for oil imports resulting from the effect of increasing U.S. import demand on the world oil price and on OPEC market power (i.e., the "demand" or "monopsony " costs); and (2) the risk of reductions in U.S. economic output and disruption of the U.S. econom y caused by sudden disruptions in the supply of imported petroleum to the U.S. (i.e ., macroeconomic disruption/adjustment costs). Maintaining a U.S. military presence to help secure stable oil supply from potentially vulnerable regions of the world was not included in this analy sis because its attribution to particular missions or activ ities is hard to quantify. As part of the process for developing the ORNL energy security estimates, EPA sponsored an independent , expert peer review of th e 2008 ORNL study . A report compiling the peer reviewers’ comments is provided in the docket. 381 In addition, EPA has worked with ORNL to address comments raised in the peer review and to develop estimates of the energy

securit y benefits associated with a reduction in U.S. oil imports for this heav y dut y vehicle rule. In response to peer reviewer comm ents, ORNLmodified its model by

changing several key

parameters involving OPEC supply behavior, the responsiveness of oil demand and supply to a change in the world oil price, and the responsiveness of U.S. economic output to a change in the world oil pri ce. For this proposed rule, ORNLestimated energy security premium s by incorpor ating the most recent available AEO 2010 oil price forecasts and market trends. Energy security premiums fo r the years 2020, 2030 and 2040 are presented in Table VIII
- 14 , 382 as well as a breakdown of the components of the energy securit y premium for each of these ye ars. The components of the energy security premium s and their values are discussed in detail in Chapter 9.4 of the RIA.

379 Leiby, Paul N. , " Estimating the Energy Security Benefits of Reduced U.S. Oil Import s " Oak Ridge National Laboratory, ORNL/TM

- 2007/028, Final Report, 2008. (Docket EPA

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- 0162) 380 The ORNL study “ The Energy Security Benefits of Reduced Oil Use, 2006

- 2015 ," comple ted in March 2008 , is an update version of the approach used for estimating the energy security benefits of U.S. oil im port reductions developed in an ORNL 1997 Report by Leiby, Paul N., Donald W. Jones, T. Randall Curlee, and Russell Lee, entitled “ Oil Im ports: An Assessment of Benefits and Costs. " (Docket EPA

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Report Summary: Estimating the Energy Security Benefits of Reduced U.S. Oil Imports, ICF, Inc., September 2007. 382 AEO 2009 forecasts energy market trends and values on ly to 2035. The energy security premium estimates post

- 2035 were assumed to be the 2035 estimate.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

343 of 541 Table VIII - 14 : Energy Security Premium s in 2020, 2030 and 2040 (2008$/Barrel) Year (range) Monopsony Macroeconomic Disruption/Adjustment Costs Total Mid

- Point 2020 $ 12.28

($ 4.16

- $ 23.74 ) $ 7.39 ($ 3.39

– $ 11.92 ) $ 19.66 ($ 10.27

- $ 30.90 ) 2030 $ 12.69

($ 4.43

– 23.80 ) $ 8.54 ($ 4.10

– $ 13.60 ) $ 21.23 ($ 11.30

- $ 32.88 ) 20 40 $ 12.68

($ 4.41

– $ 23.41 ) $ 8.99 ($ 4.48

- $ 14.08 ) $ 21.67 ($ 11.54

- $ 33.11 ) The literature on the energy securit y for the last two decades has routinel y combined the m onopsony and the macroeconomic disruption components when calculating the total value of the energy securit y premium. However, in the context of using a global value for the Social Cost of Carbon (SCC), the question arises: how should the energy

securit y premium be determined when a global perspective is taken? Monopsony

benefits represent avoided pay ments by the U.S. to oil producers in foreign countries that result from a decrease in the world oil price as the U.S. decreases its consumption of imported oil. Although there is clearly

a benefit to the U.S. when considered from a domestic perspective, the decrease in price due to decreased demand in the U.S. also represents a loss to other countries. Given the redistributive nature of this monopsony effec t from a global perspective, it is excluded in the energy security benefits calculations for this proposal. In contrast, the other portion of the energy securit y premium, the U.S. macroeconomic disruption and adjustment costs that arise from U.S. petroleum imports, does not have offsetting impacts outside of the U.S., and, thus, are included in the energy securit y benefits estimated for this proposal. To summarize , the agencies have included only the macroeconomic disruption portion of the energy securit y benefits to monetize the total energy

securit y benefits of this proposal

. The t otal annual energy

securit y benefits for the proposed heav y dut y vehicle rule are reported in Table VIII
- 15 for the ye ars 2020, 2030 and 2040. These estimates include only the macroeconomic disruption/adjustment portion of the energy security premium. Table VIII - 15 : Total Annual Energy Security Benefits fromthe Heavy - Duty Vehicle Rule in 2020, 2030 and 2040 (millions of 2008$) Year Benefits 2020 $ 477 2030 $ 1,113 2040 $ 1,520344 of 54 1



### J. Other Impacts (1) Noise, Congestion and Accidents Increased vehicle use associated with a positive rebound effect also contributes to increased traffic congestion, motor vehicle accidents, and highway noise. Depending on how the additional travel is distributed over the day and on where it takes place, additional vehicle use can contribute to traffic congestion and delay s by increasing traffic volumes on facilities that are alrea dy heavil y traveled during peak periods. These added delay s impose higher costs on drivers and other vehicle occupants in the form of increased travel time and operating expenses, increased costs associated with traffic accidents, and increased traffic no ise. Because drivers do not take these added costs into account in deciding when and where to travel, they must be accounted for separately as a cost of the added driving associated with the rebound effect. EPA and NHTSA rel y on estimates of congestion, a ccident, and noise costs caused b y pickup trucks and vans, single unit trucks, buses, and combination trucks developed b y the Federal Highway Administration to estimate the increased external costs caused b y added driving due to the rebound effect. 383 The F HWA estimates are intended to measure the increases in costs from added congestion, property damages and injuries in traffic accidents, and noise levels caused by automobiles and light trucks that are borne b y persons other than their drivers (or “marginal ” external costs). EPA and NHTSA employ ed estimates from this source previously in the anal ys is accompanying the L ight Dut y GHG final rule. The agencies continue to find them appropriate for this anal ys is after reviewing the procedures used by FHWA to de velop them and considering other available estimates of these values. FHWA’s congestion estimates for trucks alread y consider that trucks account for a lower percent of peak period traffic on congested freeway s because they try to avoid peak periods when possible. The FHWA congestion costs are a weighted average based on the estimated percent of peak and off

peak freeway

travel for each of the classes of trucks. FHWA focused congestion costs on freeway s because non

- freeway effects are less serious becaus e of lower traffic volumes and opportunities to re

- route around the congestion. The agencies, however, applied the congestion cost to the overall VMT increase, though the fraction of VMT on each road ty pe used in MOVES range from 27 to 29 percent of the v ehicle miles on freeway s for vocational trucks and 53 percent for combination trucks. The results of this anal ys is potentially

overestimate the costs and provide a conservative estimate. The agencies welcome comments on whether the cost calculations shou ld be done differently in the final rulemaking. The agencies are proposing to use FHWA’s “Middle” estimates for marginal congestion, accident, and noise costs caused b y increased travel from trucks

. This approach is consistent with the current methodology used in the Light Duty GHG

383 These estimates were developed by FHWA for use in its 1997 Federal Highway Cost Allocation Study ; see http://www.fhwa.dot.gov/policy/hcas/final/index.htm (last accessed July 21, 2010 ).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

345 of 54 1 rulemaking anal ys is. These costs are multiplied by the annual increases in vehicle miles travelled from the positive rebound effect to yield the estimated increases in congestion, accident, and noise externality costs during ea ch future year. The values the agencies used in the calculation of the congestion, noise, and accident costs are included in Table VIII
- 16

. Table VIII - 16 Noise, Accident, and Congest ion Costs per Mile (2008$) External Costs Pickup truck and vans ($/VMT) V ocational trucks

($/VMT) C ombination

trucks ($/VMT) Congestion $ 0.0 49 $ 0. 110 $ 0. 107 Accidents $ 0.0 26 $ 0. 019 $ 0. 022 Noise $ 0.001 $ 0.0 09 $ 0.0 20

In aggregate, the external costs due to noise, accidents, and congestion from the additional truck driving are presented in Table VIII
- 17

.

Table VIII - 17 Acci dent, Noise, and Congestion Costs (Millions, 2008$) Year Class 2b&3 Vocational Combination EXTERNAL COSTS 2012 $0 $0 $0 $0 2013 $0 $0 $0 $0 2014 $8 $10 $18 $36 2015 $16 $19 $35 $70 2016 $23 $30 $52 $104 2017 $30 $39 $68 $137 2018 $37 $48 $83 $168 2 020 $50 $64 $111 $225 2030 $89 $122 $193 $404 2040 $112 $182 $233 $527 2050 $133 $245 $271 $648 NPV, 3% $1,606 $2,407 $3,439 $7,452 NPV, 7% $746 $1,070 $1,614 $3,429

(2) S avings due to reduced refueling time Reducing the fuel consumption of heavy dut y trucks may either increase their driving range before they require refueling , or motivate truck purchasers to buy , and manufacturers to offer, smaller fuel tanks

. Keeping the fuel tank the same size allows truck operators to reduc e the frequency with whic h drivers ty

picall y refuel their vehicles; it thus extend s the upper limit of the range they can travel before requiring refueling. Alternativel y, if purchasers and manufacturers respond to improved fuel economy by346 of 54 1

reducing the size of fuel tanks to maint ain a constant driving range, the smaller tank will require less time in actual refueling

. Because refueling time represents a time cost of truck operation, these time savings should be incorporated into truck purchasers’ decisions over how much fuel

sav ing technology

they want in their vehicles. The savings calculated here thus raise the same questions discussed in Preamble VIII.A and DRIA Section 9.1: does the apparent existence of these savings reflect failures in the market for fuel econom y, or does it reflect costs not addressed in this analy sis? The response to these questions could vary across truck segment. See those sections for further anal ys is of this question. This analy sis estimates the reduction in the annual time spent filling the fuel t ank; this reduced time could come either from fewer refueling events, if the fuel tank stay s the same size, or less time spent refueling, if the fuel tank is made proportionately smaller. The fuel savings are calculated as the time not spent putting fuel into the vehicle, based on the amount of time that would have been necessary to pump the fuel. The calculation does not include time spent searching for a fuel station or other time spent at the station; it is assumed that the time savings occur when truc k operators would otherwise be refueling. It includes additional mileage associated with the rebound effect. The details of this calculation are discussed in the draft RIA Chapter 9.3.2. The savings per vehicle through its lifetime are listed in Table VIII
- 18

. Table VIII - 18 : Aggregate Refueling Savings (2008$) Pickup trucks and vans vocational trucks tractors 3% Discount Rate $64 $220 $294 7% Discount Rate $50 $176 $235

The aggr egate savings of the vehicles sold in 2014 through 2050 are listed in Error! Reference source not found. Error! Reference source not found.

.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

347 of 54 1 Table VIII - 19 Estimated Savings due to Less Frequent Refueling (Millions of 2 008 dollars) Year Class 2b&3 Vocational Combination Truck/Tractor Total 2012 $0.0 $0.0 $0.0 $0.0 2013 $0.0 $0.0 $0.0 $0.0 2014 $0.3 $1.8 $4.9 $6.9 2015 $0.6 $3.4 $9.6 $13.6 2016 $1.6 $5.2 $14.1 $21.0 2017 $3.2 $8.5 $20.6 $32.3 2018 $6.0 $11.7 $26.8 $44.5 2020 $11.3 $17.3 $38.4 $67.0 2030 $30.3 $37.4 $72.5 $140.2 2040 $41.0 $57.4 $88.7 $187.1 2050 $49.5 $77.5 $103.1 $230.0 NPV, 3% $521 $728 $1,267 $2,516 NPV, 7% $225 $315 $584 $1,123
(3) The Effect of Safety Standards and Voluntary Safety Improve ments on Vehicle Weight Safety regulations developed by NHTSA in previous regulations may make compliance with the proposed standards more difficult or may reduce the projected benefits of the program. The primary way that safety

regulations can impact fu el efficiency and GHG emissions is through increased vehicle weight, which reduces the fuel efficiency

of the vehicle. Using MY 2010 as a baseline, this section discusses the effects of other government regulations on model y ear (MY) 2014

- 2016 medium and heav y dut y vehicle fuel efficiency. At this time, no known safet y standards will affect new models in MY 2017 or 2018. The agency ’s estimates are based on cost and weight tear
- down studies of a few vehicles and cannot possibly cover all the variations in the manufacturers’ fleets. NHTSA requested, and various manufacturers provided, confidential estimates of increases in weight resulting from safety improvements. Those increases are shown in subsequent tables. We have broken down our anal ys is of the impact of safet y standards that might affect the MY 2014

- 16 fleets into three parts: 1) those NHTSA final rules with known effective dates, 2) proposed rules or soon to be proposed rules by NHTSA with or without final effective dates, and 3) currentl y voluntary safet y improvements planned by the manufacturers. (a ) Weight Impacts of Required Safety Standards NHTSA has undertaken several rulemakings in which several standards would become effective for medium and heav y dut y (MD/HD) vehicles between MY 2014 and348 of 54 1

MY 2016. We will examine the potential impact on MD/HD vehicle weights for MY 2014

- 2016 using MY 2010 as a baseline.

 FMVSS 119, Heav y Truck Tires Endurance and High Speed Tests  FMVSS 121, Air Brake Sy stems Stopping Distance  FMVSS 214, Motor Coach Lap/S houlder Belts  MD/HD Vehicle Electronic Stability Control Sy stems (i ) FMVSS 119, Heavy Truck Tires Endurance and High Speed Tests The data in the large truck crash causation study (LTCCS) and the agency ’s test results indicate that J and Lload range tires are more likely to fail the proposed requirements among the targeted F, G, H, J and L load range tires. 384 As such the J and L load range tires specifically need to be addressed to meet the proposed requirements since the other load range tires are likely to p ass the requirements. Rubber material improvements such as improving rubber compounds would be a countermeasure that reduces heat retention and improve the durability of the tires. Using high tensile strength steel chords in tire bead, carcass and belt w ould enable a weight reduction in construction with no strength penalties. The rubber material improvements and using high tensile strength steel would not add an y additional weight to the current production heav y truck tires. Thus there may

not be an in cremental weight per vehicle for the period of MY 2014

- 2016 compared to the MY 2010 baseline. This proposal could become a final rule with an effective date of MY2016. (ii) FMVSS No. 121, Airbrake Systems Stopping Distance The most recent major final rule was published on July 27, 2009 and became effective on November 24, 2009 (MY2009) with different compliance dates. The final rule requires the vast majority of new heavy

truck tractors (approximately 99 percent of the fleet) to achieve a 30 percent reduction in stopping distance compared to currentl y required levels. Three

- axel tractors with a gross vehicle weight rating (GVWR) of 59,600 pounds or less must meet the reduced stopping distance requirements by August 1, 2011 (MY2011). Two

- axle tractors and tra ctors with a GVWR above 59,600 pounds must meet the reduced stopping distance requirements by August 1, 2013 (MY2013). There are several brake systems that can meet the requirements in the final rule. Those sy stems include installation of larger S

- cam dr um brakes or disc brake sy stems at all positions, or hy

brid disc and larger rear S

- cam drum brake s ys tems. According to the data provided by a manufacturer (Bendix), the heaviest drum brakes weigh more than the lightest disc brakes while the heaviest di sc brakes weigh more than the lightest drum brakes. For a three

- axle tractor equipped with all disc brakes, the total weight could increase b y 212 pounds or could decrease b y 134 pounds compared to an all drum braked tractor depending on which disc or drum brakes are used

384 “Preliminary Regulatory Impact Analysis, FMVSS No. 119, New Pneumatic Tires for Motor Vehicles with a GVWR of More Than 4,536 kg (10,000 pounds), June 2010.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

349 of 54 1 for comparison. The improved brakes may add a small amount of weight to the affected vehicle for MY2014

- 2016 resulting in a slight increase in fuel consumption. (iii) FMVSS No. 208, Motor coach Lap/Shoulder Belts Based on preliminary

results from the agency ’s cost/weight teardown studies of motor coach seats, it is estimated that the weight added by 3

- point lap/shoulder belts ranges from 5.96 to 9.95 pounds per 2

- person seat. 385 This is the weight onl y of the seat belt assembly

itself and does not include changing the design of the seat, reinforcing the floor, walls or other areas of the motor coach. Few current production motor coaches have been installed with lap/shoulder belts on their seats, and the number could be negligible. Assuming a 54 passenger motor coach, the added weight for the 3

- point lap/shoulder belt assembly is in the range of 161 to 269 pounds (27 * (5.96 to 9.95)) per vehicle. This proposal could become a final rule with an effective date of MY2016. (iv) Electronic Stability C ontrol Systems (ESC) for Medium and Heavy Duty (MD/HD) Vehicles The ESC is not currently

required in MD/HD vehicles and could be proposed to be required in the vehicles by NHTSA. FMVSS No. 105, Hydraulic and electric brake sy stems, requires multipurpose p assenger vehicles, trucks and buses with a GVWR greater than 4,536 kg (10,000 pounds) to be equipped with an antilock brake sy stem (ABS). All MD/HD vehicles have a GVWR of more than 10,000 pounds, and these vehicles are required to be installed with an AB S by the same standard. The ESC incorporates ya w rate control into the ABS, and yaw is a rotation around the vertical axis. The ESC sy stem uses several sensors in addition to the sensors used in the ABS, which is required in MD/HD vehicles. Those additio nal sensors could include steering wheel angle sensor, yaw rate sensor, lateral acceleration sensor and wheel speed sensor. According to the data provided b y Meritor WABCO, the weight of the ESC for the model 4S4M tractor is estimated to be around 55.494 pounds, and the weight of the ABS only is estimated to be 45.54 pounds. Then the added weight for the ESC for the vehicle is estimated to be 9.954 (55.494

– 45.54) pounds. (b ) Summary

– Overview of Anticipated Weight Increases Table 1 summarizes estimates made b y the agency regarding the weight added by the above discussed standards or likel y rulemakings. The agency estimates that weight additions required b y final rules and likel y NHTSA regulations effective in MY 2016 compared to the MY 2010 fleet will i ncrease motorcoach vehicle weight by 171

- 279 pounds and will increase other heav y dut y truck weights b y a minor 10 pounds.

385 Cost and Weight Analysis of Two Motorcoach Seating Systems: One With and One Without Three

Point Lap/Shoulder Belt Restraints, Ludkes and Associates, July 2010.350 of 54 1 Table VIII - 20 : : Weight Additions Due to Final Rules or Likely NHTSA Regulations Comparing MY 2016 to the MY 2010 Baseline Fleet

Standard Number Added Weight in pounds MD/HD Vehicle Added Weight in kilograms MD/HD Vehicle 119 0 0 121 0 (?) 0 (?) 208 Motorcoaches only 161

- 269 73

- 122
MD/HD Vehicle Electronic Stability Control Sy stem s 10 4.5 Total Motorcoaches 171

- 279 77.5
- 126.5 Total All other MD/HD vehicles 10 4.5 (4) Effects of Vehicle Mass Reduction on Safety NHTSA and EPA have been considering the effect of vehicle weight on vehicle safet y for the past several years in the contex t of our joint rulemaking for light dut y vehicle CAFE and GHG standards, consistent with NHTSA’s long

- standing consideration of safet y effects in setting CAFE standards. Combining all modes of impact, the latest anal ys is by NHTSA for the MYs 2012

- 2016 fin al rule found that reducing the weight of the heavier light trucks (LT > 3,870) had a positive overall effect on safet y, reducing societal fatalities. 386 In the context of the current rulemaking for HD fuel consumption and GHG standards, one would expect that reducing the weight of medium

- dut y trucks similarly would, if an ything, have a positive impact on safety . However, given the large difference in weight between light

- duty vehicles and medium

- duty trucks, and even larger difference between light

- duty v ehicles and heavy

- duty

vehicles with loads, the agencies believe that the impact of weight reductions of medium

- and heav y - dut y trucks would not have a noticeable impact on safet y for an y of these classes of vehicles. However, the agencies recognize that i t is important to conduct further study and research into the interaction of mass, size and safety to assist future rulemakings, and we expect that the collaborative interagency work currently

on - going to address this issue for the light

- dut y vehicle conte xt may also be able to inform our evaluation of safet y effects for the final HD vehicle rule. We seek comment regarding potential safety effects due to

386 “Final Regulatory Impact Analysis, Corporate Average Fuel Economy for MY 2012

- MY 2016 Passenger Cars and Light Trucks”, NHTSA, March 2010, (Docket No. NHTS A

- 2009

- 0059

- 0344.1).Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

351 of 54 1 weight reduction in the HD vehicle context, with particular emphasis on commenters providing supporting data and research for HD vehicle weight reduction.



### K. Summary of Costs and Benefits In this section, EPA presents a summary of costs, benefits, and net benefits of the proposal. Table VIII
- 21 shows the estimated annual monetized costs of the proposed program for the indicated calendar ye ars. The table also shows the net present values of those costs for the calendar ye ars 2012

- 2050 using both a 3 percent and a 7 percent discount rate. 387 In this table, fuel savings are calculate d using pre

- tax fuel prices. Table VIII - 21 : Estimated Monetized Costs of the Proposed Program(Millions of 2008 dollars) a

2020 2030 2040 2050 NPV, Y ears 2012

- 2050, 3% D iscount R ate NPV, Y eaers

2012

- 2050, 7% D iscount R ate E Technology Costs $2,100 $2,000 $2,300 $2,600 $43,800 $23,500 Fuel Savings (pre

- tax) -

$8,000 - $18,900 -

$28,000 -

$35,200 - $351,100

- $152,100 Monetized Annual Costs -

$5,900 - $16,900 -

$25,700 -

$32,600 - $307,300

- $128,600

a Technology costs and fuel savings for separate truck segments can be found in Section 8.3. Table VIII
- 22 presents estimated annual monetized benefits for the indicated calendar years. The table also shows the net present values of those benefits f or the calendar years 2012

- 2050 using both a 3 percent and a 7 percent discount rate. N ote that fuel savings shown here result from fleet

- wide reductions in fuel use. Thus they grow over time, as an increasing fraction of the fleet meet s the 2018 standar ds. The table also shows the benefits of reduced CO 2 emissions

— and consequentl y the annual quantified benefits (i.e., total benefits)

— for each of four SCC values considered b y EPA. As discussed in the RIA Section 8.5, there are some limitations to the SC C analy sis, including the incomplete way in which the integrated assessment models capture catastrophic and non

- catastrophic impacts, their incomplete treatment of adaptation and technological change, uncertaint y in the extrapolation of damages to high tem peratures, and assumptions regarding risk aversion.

387 For the estimation of the stream of costs and benefits, we assume that after implementation of the proposed MY 2014

- 2017 standards, the 2017 standards apply to each year out to 2050

.352 of 54 1 In addition, these monetized GHG benefits exclude the value of net reductions in non - CO 2 GHG emissions (CH 4 , N 2 O) expected under this proposal. Although EPA has not monetized the benefits of reducti ons in non

- CO 2 GHGs, the value of these reductions should not be interpreted as zero. Rather, the net reductions in non

- CO 2 GHGs will contribute to this proposal’s climate benefits, as explained in Section VI .C Table VIII - 22 : Monetized Benefits Associated with the Proposed Program(Millions of 2008 dollars )

2020 2030 2040 2050 NPV, Y ears 2012

- 2050, 3% D iscount R ate a NPV, Y eaers

2012

- 2050, 7% D iscount R ate a E Reduced CO 2 Emissions at each assumed SCC value b 5% (avg SCC) $200 $700 $1,200 $1,800 $8,900 $8,900 3% (avg SCC) $900 $2,400 $3,700 $5,100 $45,300 $45,300 2.5% (avg SCC) $1,500 $3,600 $5,500 $7,400 $76,800 $76,800 3% (95th percentile) $2,900 $7,200 $11,200 $15,400 $138,100 $138,100 Energy Security Impacts (price shock) $500 $1,100 $1,500 $1,800 $19,800 $8,700

Accidents, Congestion, Noise - $200

- $400

- $500

- $600

- $7,500

- $3,400 Refueling Savings $100 $100 $200 $200 $2,500 $1,100 Non
- CO 2 GHG Im pacts and Non
- GHG Im

pacts c,d n/a n/a n/a n/a n/a n/a

Total Annual Benefits at each assumed SCC value b 5% (avg SCC) $600 $1,500 $2,400 $3,200 $23,700 $15,300 3% (avg SCC) $1,300 $3,200 $4,900 $6,500 $60,100 $51,700 2.5% (avg SCC) $1,900 $4,400 $6,700 $8,800 $91,600 $83,200 3% (95th percentile) $3,300 $8 ,000 $12,400 $16,800 $152,900 $144,500
Notes: a Note that net present value of reduced CO 2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 2.5 perce nt) is used to calculate net present value of SCC for internal consistency. Refer to the SCC TSD for more detail. b Section VIII.G notes that SCC increases over time. Corresponding to the years in this table, the SCC estimates range as follows: for Av erage SCC at 5%: $5

- $16; for Average SCC at 3%: $22

- $46 ; f or Average SCC at 2.5%: $36

- $66 ; and for 95 th percentile SCC at 3%: $66

- $139 . Section VIII.F also presents these SCC estimates.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

353 of 54 1 c The monetized GHG benefits presented in this analysis exclude the value of changes in non

- CO 2 GHG emissions expected under this proposal (see RIA Chapter 5) . Although EPA has not monetized changes in non - CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d Non
- GHG

related health an d welfare impacts (related to PM 2.5 and ozone exposure) w ere not estimated for this proposal, but will be included in the analysis of the final rulemaking. Table VIII
- 23 presents estimated annual net benefits for the indicated c alendar ye ars. The table also shows the net present values of those net benefits for the calendar ye ars 2012

- 2050 using both a 3 percent and a 7 percent discount rate. The table includes the benefits of reduced CO 2 emissions (and consequently the annual net benefits) for each of four SCC values considered b y EPA. Table VIII
- 23 : Monetized Net Benefits Associated with the Proposed Program (Millions of 2008 dollars) 2020 2030 2040 2050 NPV, 3% a NPV, 7% a

Total Annual Costs b Total Annual Costs - $5,900

- $16,900

- $25,700

- $32,600

- $307,300

- $128,600

Total Annual Benefits at each assumed SCC value c 5% (avg SCC) $600 $1,500 $2,400 $3,200 $23,700 $15,300 3% (avg SCC) $1,300 $3,200 $4,900 $6,500 $60,100 $51,700 2.5% (avg SCC) $1,900 $4,400 $6,700 $8,800 $91,600 $83,200 3% (95th percentile) $3,300 $8,000 $12,400 $16,800 $152,900 $144,500

Monetized Net Benefits at each assumed SCC value c 5% (avg SCC) $6,500 $18,400 $28,100 $35,800 $331,000 $143,900 3% (avg SCC ) $7,200 $20,100 $30,600 $39,100 $367,400 $180,300 2.5% (avg SCC) $7,800 $21,300 $32,400 $41,400 $398,900 $211,800 3% (95th percentile) $9,200 $24,900 $38,100 $49,400 $460,200 $273,100
Notes:354 of 54 1 a N et present value of reduced CO2 emissions is calculated d ifferently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 2.5 percent) is used to calculate net present value of SCC for internal consistency. Refer to the SCC TSD for more detail. b Negative costs represent savings. c Section VIII. G notes that SCC increases over time. Corresponding to the years in this table, the SCC estimates range as follows: for Average SCC at 5%: $5

- $16; for Average SCC at 3%: $22

- $46; for Average SCC at 2.5% : $36

- $66; and for 95th percentile SCC at 3%: $66

- $139. Section VIII. G also presents these SCC estimates. EPA also conducted a separate anal ys is of the total benefits over the model year lifetimes of the 201 4 through 201 8 model year trucks . In contrast to the calendar ye ar anal ys is presented in Table VIII
- 21 through Table VIII
- 23 , the model year lifetime anal ys is shows the lifetime impacts of the program on each of these MY fleets over the course of their lifetime. Full details of the inputs to this analy sis can be found in RIA Chapter 5 of the RIA . The net societal benefits of the full life of each of the five model years from 201 4 through 201 8 are shown in Table VIII
- 24 an d Table VI II
- 25 at both a 3 percent and a 7 percent discount rate, respectively . Note that Table VI II
- 24 and Table VI II
- 25 include the benefits of reduced CO 2 emissions

— and cons equently the total benefits

— for each of four SCC values considered by EPA. Table VIII - 24 : Monetized Costs, Benefits, and Net Benefits Associated with the Lifetimes of 2014 -

2018 Model Year Trucks (Millions of 2 008 dollars; 3% Discount Rate) 2014MY 2015MY 2016MY 2017MY 2018MY Sum Technology

- $1,400

- $1,400

- $1,600

- $1,700

- $2,100

- $8,200 Fuel Savings (pre

- tax) $6,100 $6,400 $7,200 $10,700 $11,800 $42,200 Energy Security Impacts (price shock) $400 $400 $400 $ 600 $700 $2,500

Accidents, Congestion, Noise - $300

- $300

- $300

- $300

- $300

- $1,400 Refueling Savings $200 $200 $200 $200 $200 $1,100 Non
- CO 2 GHG Impacts and Non
- GHG Impacts c,d n/a n/a n/a n/a n/a n/a

Reduced CO 2 Emissions at each assumed SCC value a, bDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

355 of 54 1 5% (avg SCC) $200 $200 $200 $300 $300 $1,200 3% (avg SCC) $600 $700 $700 $1,100 $1,200 $4,300 2.5% (avg SCC) $1,000 $1,000 $1,100 $1,700 $1,800 $6,600 3% (95th percentile) $1,900 $2,000 $2,200 $3,200 $3,600 $12,900 Monetized Net Benefits at each as sumed SCC value a, b 5% (avg SCC) $5,200 $5,500 $6,100 $9,800 $10,600 $37,400 3% (avg SCC) $5,600 $6,000 $6,600 $10,600 $11,500 $40,500 2.5% (avg SCC) $6,000 $6,300 $7,000 $11,200 $12,100 $42,800 3% (95th percentile) $6,900 $7,300 $8,100 $12,700 $13,90 0 $49,100
Notes: a N et present value of reduced CO2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 2.5 percent) is used to calculate net present v alue of SCC for internal consistency. Refer to the SCC TSD for more detail. b Section VIII. G notes that SCC increases over time. Corresponding to the years in this table, the SCC estimates range as follows: for Average SCC at 5%: $5

- $16; for Average SCC at 3%: $22

- $46; for Average SCC at 2.5%: $36

- $66; and for 95th percentile SCC at 3%: $66

- $139. Section VIII. G also presents these SCC estimates. c The monetized GHG benefits presented in this analysis exclude the value of changes in non

- CO 2 GHG emi ssions expected under this proposal (see RIA Chapter 5) . Although EPA has not monetized changes in non - CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d Non
- GHG

- related health and welfare impacts (related to PM 2.5 and ozone exposure) w ere not estimated for this proposal, but will be included in the analysis of the final rulemaking.356 of 54 1 Table VIII - 25 : Monetized Costs, Benefits, and Net Benefits Associated with the Lifetime s of 2014 -

2018 Model Year Trucks (Millions of 2008 dollars; 7% Discount Rate) 2014MY 2015MY 2016MY 2017MY 2018MY Sum Technology

- $1,400

- $1,400

- $1,600

- $1,700

- $2,100

- $8,200 Fuel Savings (pre

- tax) $4,500 $4,500 $4,900 $7,000 $7,400 $28,300 Energy Sec urity Impacts (price shock) $300 $300 $300 $400 $400 $1,700

Accidents, Congestion, Noise - $200

- $200

- $200

- $200

- $200

- $900 Refueling Savings $200 $200 $200 $200 $200 $900 Non
- CO 2 GHG Impacts and Non
- GHG Impacts c,d n/a n/a n/a n/a n/a n/a

Reduced CO 2 Emissions at each assumed SCC value a, b 5% (avg SCC) $200 $200 $200 $300 $300 $1,200 3% (avg SCC) $600 $700 $700 $1,100 $1,200 $4,300 2.5% (avg SCC) $1,000 $1,000 $1,100 $1,700 $1,800 $6,600 3% (95th percentile) $1,900 $2,000 $2,200 $3,200 $3,600 $1 2,900 Monetized Net Benefits at each assumed SCC value a, b 5% (avg SCC) $3,600 $3,600 $3,800 $6,000 $6,000 $23,000 3% (avg SCC) $4,000 $4,100 $4,300 $6,800 $6,900 $26,100 2.5% (avg SCC) $4,400 $4,400 $4,700 $7,400 $7,500 $28,400 3% (95th percentile) $5,300 $5,400 $5,800 $8,900 $9,300 $34,700
Notes: a N et present value of reduced CO 2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 2.5 percent) i s used to calculate net present value of SCC for internal consistency. Refer to the SCC TSD for more detail.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

357 of 54 1 b Section VIII.G notes that SCC increases over time. Corresponding to the years in this table, the SCC estimates range as follows: for Average SCC at 5%: $5

- $16; for Average SCC at 3%: $22

- $46 ; f or Average SCC at 2.5%: $36

- $66 ; and for 95 th percentile SCC at 3%: $66

- $139 . Section VIII.G also presents these SCC estimates. c The monetized GHG benefits presented in this analysis exclude the va lue of changes in non

- CO 2 GHG emissions expected under this proposal (see RIA Chapter 5) . Although EPA has not monetized changes in non - CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d Non
- GHG

- related health and we lfare impacts (related to PM 2.5 and ozone exposure) w ere not estimated for this proposal, but will be included in the analysis of the final rulemaking. 

### L. Economy - Wide Impacts of the Rule EPA has undertaken an analy sis of the econom y - wide impacts of the me dium

and heav y - dut y truck fuel economy and GHG standards. The results presented in this section were not a factor regarding the appropriateness of the GHG or fuel econom y standards. However, this anal ys is provides more insight into some of the potential impacts of this proposal. It is anticipated that the GHG tailpipe standards would have impacts on the U.S. econom y that extend beyond the transportation sector. The price of medium

- and heav y duty trucks would increase with this proposal

. This proposa l would also lower the demand for transportation fuels, resulting in fuel savings to vehicle users and a lower overall world oil price. This combination of effects

— price increases for trucks and lower demand and world oil prices

— would impact all sectors o f the economy that use medium

and heav y - dut y trucks and fuels as intermediate inputs to produce final goods. Households would also be impacted indirectly as consumers of final goods. Furthermore, as discussed in Chapter 6, truck VMT is largel y driven by changes in economic activity

. To the extent that we have accounted for the increase in VMT due to the rebound effect in our anal ys is, it seems appropriate to also take into account the change in economic activity as a result of the rule. It is important to note, however, that these potential impacts do not represent additional benefits or costs from the regulation. Instead, they represent the effects on the U.S. economy

as its direct benefits and costs are transmitted through changes in prices in the a ffected markets, including those for vehicles and their components, fuel, and the various resources used to supply them. In addition, this analy sis assumes that the fuel savings modeled here would not have taken place in the absence of this rule and that there is no welfare loss associated with mandating higher fuel efficiency . As discussed in Section VIII.A., this assumption is based on the argument that there are imperfections in the market for fuel

- saving technology in the trucking industry

. To estimat e the impacts of this proposal on U.S. Gross Domestic Product (GDP) and personal consumption, EPA has used an economy

- wide, computable general equilibrium (CGE) model. The econom y - wide model used in this analy sis is the358 of 54 1

Intertemporal General Equilibrium M odel (I GEM). 388 IGEM is a model of the U.S. econom y with an emphasis on the economy’s energy and environmental aspects. IGEM is a dy namic model which depicts growth of the economy due to capital accumulation, technical change and population change. The mo del utilizes a unified accounting framework consistent with the National Income and Product Accounts and the Industry Classification Sy stem. It is a detailed multi

- sector model covering thirt y - five industries, consisting of five energy

and thirty

non - ener gy

sectors. The model ensures market balances (supply

equals demand) in value and quantity terms, including limits placed on private investment dictated by domestic and foreign saving behavior and by the fiscal policies of federal, state and local governm ents. Capital accumulation in the model arises from the saving and investment behavior of households and businesses and provides an essential input to production and consumption. Households in the model make choices regarding present and future consumpt ion (i.e., saving) and make choices regarding the allocation of time between labor and leisure. The model covers all aspects of long

- run growth including the suppl y of capital, labor, imported and intermediate inputs to production; the rates and direction s of exogenous and endogenous technical change for each producing sector; and the degrees of substitutability among inputs and commodities in production and final demand (consumption, investment, governments and foreign trade). The substitution possibilit ies for both producers and consumers in IGEM are driven by model parameters that are based on observed market behavior revealed over the past forty to fift y ye ars. In order to model this proposal , the CGE model uses outputs of the transportation sector m odels as inputs to determine the econom y - wide impacts of this proposal

. Specificall y, the model uses information from other models on incremental costs of vehicle technologies, reduction in fuel consumption, and impacts on the world oil price. The increm ental cost of vehicle technologies is used to generate a percentage change in vehicle cost that is applied to the IGEM motor vehicles sector. However, since the cost and fuel savings vary

significantly

across truck classes, we have used a weighted average cost and fuel saving in this analy sis. In addition, medium

- and heav y - duty trucks make up approximately

XXX% of the motor vehicles sector ; therefore the cost increases represented here onl y apply to that portion of the IGEM sector. The data on reduction in fuel consumption are used as inputs to I GEM in order to reduce the amount of refined petroleum sector output required b y the transportation sector and other sectors in the model. Finally , the estimates of reductions in the world oil price are directly used to reduce the oil price in the model. The changes in world oil price are estimated using the Energy Securit y Oil Premium Model maintained by Oak Ridge National Laboratory , which is discussed in more detail in Section VIII. I
.

388 The model is developed and run by Dale W. Jorgen son Associates for EPA. Model Homepage: http://www.dja.insightworks.com/Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

359 of 54 1 (1) Impacts on U.S. GDP In o rder to use IGEM to estimate the real U.S. GDP impacts of this proposal , w e anal yz ed the impact of changes in the costs of medium

- and heav y - dut y trucks, changes in fuel consumption from the shift to a lower GHG

- emitting vehicle stock, and the impacts of c hanges in the demand for motor fuels on fuel prices. See Section VIII.B for additional information on the change in vehicle technology costs, Section VIII.E for details on changes in fuel demand, and Section VIII. I for a discussion on the monopsony effect . It is important to note that the econom y - wide anal ys is does not include a representation of a number of additional benefits (e.g. reducing greenhouse gas and non

GHG emissions), and thus the GDP impacts presented here do not incorporate the results of a complete cost benefit analy sis. Table VIII
- 26 and Figure VIII
- 1 show the Reference Case GDP and GDP with this proposal from 2015 through 2050. Table VIII - 26 : Annual GDP Impacts Associated with This proposal (Billions of 2008 dollars) ye ar reference case

GDP GDP with RULE % change from reference case 201 5 $ XXX $ XXX XXX % 2020 $ XXX $ XXX XXX % 2030 $ XXX $ XXX XXX % 2040 $ XXX $ XXX XXX % 2050 $ XXX $ XXX XXX %

Figure VIII - 1 : Gross Domestic Product In the Reference Case, GDP rises from approximately $XXX trillion in 2015 to $XXX trillion in 2020, $XXX trillion in 2030, $XXX trillion in 20 40, and $XXX trillion in 2050. With this proposal , GDP rises from approximately $XXX trillion in 2015 to $XXX trillion in 2020, $XXX trillion in 2030, $XXX trillion in 2040, and $XXX trillion in 2050. The fuel savings and lower world oil prices that resu lt from this proposal lead to lower prices econom y - wide, even when the impact of higher vehicle costs are factored into this analy sis. Lo wer prices allow for additional purchases of investment goods which, in turn, lead to a larger capital stock. These p rice reductions also allow higher levels of real government spending while improving U.S. competitiveness thus promoting360 of 54 1

increased exports relative to the growth driven increase in imports. As a result, GDP is expected to increase as a result of this prop osal

. (2) Impacts on U.S. Consumption In addition to showing the impacts of the GHG vehicle rule on U.S. GDP, EPA also shows the impacts on real U.S. personal consumption expenditures. Table VIII
- 27 and Figure VIII
- 2 show the Reference Case consumption and consumption with this proposal from 2015 through 2050.

Table VIII - 27 : Consumption Impacts of the Rule (Billions of 2008 dollars) ye ar reference case

consumption consumption with

RULE % change from reference case 201 5 $ XXX $ XXX XXX % 2020 $ XXX $ XXX XXX % 2030 $ XXX $ XXX XXX % 2040 $ XXX $ XXX XXX % 2050 $ XXX $ XXX XXX %

Figure VIII - 2 C onsumption In the Reference Case, consumption rises from approximately $XXX trillion in 2015 to $XXX trillion in 2020, $XXX trillion in 2030, $XXX trillion in 2040, and $XXX trillion in 2050. With this proposal , consumption rises from approximately $XXX trillion in 2015 to $XXX trillion in 2020, $XXX trillion in 2030, $XXX trillion in 2040, and $XXX trillion in 2050. The consumption impacts on a per household basis are presented in Table VIII
- 28 and Figure VIII
- 3 . Higher vehicle costs are projected to reduce household consumption slightly in the first few years of the rule implementation. Over time, fuel savings increase and the price of world oil decreases, which leads to lower prices econom y - wide. As a result, household consumption increases over the long term.

Table VIII - 28 : Consumption Impacts of This proposal per Household (2007$)Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC Standards ( 12/6/2010 )

361 of 54 1 ye ar reference case consumption consumption with RULE % change fro m reference case 01 5 $ XXX $ XXX XXX %
020 $ XXX $ XXX XXX %
030 $ XXX $ XXX XXX %
040 $ XXX $ XXX XXX %
050 $ XXX $ XXX XXX %

Figure VIII - 3 Consumption per Household See the draft RIA Chapter XXX for additional information.


## IX. Analysis of Alternatives The heav y - duty

truck segment is very

complex. The sector consists of a diverse group of impacted parties, including engine manufacturers, chassis manufacturers, truck manufacturers, tr ailer manufacturers, truck fleet owners and the air breathing public. The proposal the Agencies have laid out today is largely shaped to maximize the environmental and fuel savings benefits of the program respecting the unique and varied nature of the regu lated industries. In developing this proposal, we considered a number of alternatives that could have resulted in fewer or potentially greater GHG and fuel consumption reductions that the program we are proposing. This section summarizes the alternatives we considered. We welcome comments on all of these alternatives. 

### A. What are the alternatives that the agencies considered? In developing alternatives, NHTSA must consider EI SA ’ s requirement for the MD/HD fuel efficiency

program noted above. 49 U.S.C. § 329 02(k)(2) and (3) contain362 of 54 1

the following three requirements specific to the MD/HD vehicle fuel efficiency improvement program: (1) The program must be “designed to achieve the maximum feasible improvement”; (2) the various required aspects of the program mus t be appropriate, cost

- effective, and technologically feasible for MD/HD vehicles; and (3) the standards adopted under the program must provide not less than four model y ears of lead time and three model ye ars of regulatory stability . In considering these various requirements, NHTSA will also account for relevant environmental and safety considerations. Each of the alternatives proposed b y NHTSA and EPA represents, in part, a different way the agencies could establish a HD program pursuant to EISA and the C AA

. The agenc ies are proposing Alternative 6

. The alternatives below represent a broad range of approaches under consideration for setting proposed HD vehicle fuel efficiency and GHG emissions standards. The alternatives that the agencies are proposing, in order of increasing fuel efficiency and GHG emissions reductions, are: (1) Alternative 1: No Action A “no action” alternative assumes that the agencies would not issue rule s regarding a MD/HD fuel efficiency improvement program, and is considered to comply with NEPA and to provide an analy tical baseline against which to compare environmental impacts of the other regulatory alternatives. 389 The agencies refer to this as the “No Action Alternative” or as a “ no increase ” or “baseline” alternative. (2) Alternative 2: Engine Only The EPA currently

regulates heavy

- duty

engines, i.e., engine manufacturers, rather than the vehicle as a whole, in order to control criteria emissions. 390 Under Alternative 2, the agencies would similarly set engine performance standards for eac h vehicle class, Class 2b through Class 8, and would specify an engine cell test procedure, as EPA currently

d oes for criteria pollutants. HD engine manufacturers would be responsible for ensuring that each engine could meet the applicable vehicle class en gine performance standard when tested in accordance with the specified engine cell test

389 NEPA re quires agencies to consider a “ no action ” alternative in their NEPA analyses and to compare the e ffects of not taking action with the effects of the reasonable action alte rnatives to demonstrate the different environmental effects of the action alternatives. See 40 CFR § 1502.2(e), 1502.14(d). CEQ has explained that “ [T]he regulations require the analysis of the no action alternative even if the agency is under a court ord er or legislative command to act. This analysis provides a benchmark, enabling decision makers to compare the magnitude of environmental effects of the action alternatives. It is also an example of a reasonable alternative outside the jurisdiction of the a gency which must be analyzed. [See 40 CFR § 1502.14(c).] * * * Inclusion of such an analysis in the EIS is necessary to inform Congress, the public, and the President as intended by NEPA. [See 40 CFR § 1500.1(a).] “ Forty Most Asked Questions Concerning CEQ ’ s National Environmental Policy Act Regulations, ” 46 FR 18026 (1981) (emphasis added). 390 There are several reasons for this approach. In many cases the engine and chassis are produced by different manufacturers and it is more efficient to hold a single entity responsible. Also, testing an engine cell is more accurate and repeatable than testing a whole vehicle.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

363 of 54 1 procedure. Engine manufacturers could improve HD engines b y appl yi ng the combinations of fuel efficiency improvements and GHG emissions reduction technologies to the en gine that they deem best achieve that result. (3) Alternative 3 : Class 8 Combination Tractors Combination tractors consume the largest fraction of fuel within the medium

- and heav y - dut y truck segment. Tractors also offer significant potential for fuel savings due to the high annual mileage and high vehicle speed of ty pical trucks within this segment, as compared to annual mileage and average speeds/duty cycles of other vehicle classes. This alternative would set performance standards for both the engine of Clas s 8 vehicles and the overall vehicle efficiency performance for the Class 8 combination tractor segment. Under Alternative 3, the agencies would set an engine performance standard, as discussed under Alternative 2, for Class 8 tractors . In addition, Class 8 combination tractor manufacturers would be required to meet an overall vehicle performance standard b y making various non

- engine fuel saving technology improvements. These non

- engine fuel efficiency and GHG emissions improvements could be accomplished, f or example, by

a combination of improvements to aerodynamics, lowering tire rolling resistance, decreasing vehicle mass (weight), reducing fuel use at idle, or b y adding intelligent vehicle technologies. 391 Compliance with the overall vehicle standard could be determined using a computer model that would simulate overall vehicle fuel efficiency given a set of vehicle component inputs. Using this compliance approach, the Class 8 vehicle manufacturer would supply certain vehicle characteristics (relating to th e categories of technologies noted immediately above) that would serve as model inputs. The agency

would supply

a standard Class 8 vehicle engine ’ s contribution to overall vehicle efficiency , making the engine component a constant for purposes of complianc e with the overall vehicle performance standard, such that compliance with the overall vehicle standard could only be achieved via efficiency improvements to non

- engine vehicle components. Thus, vehicle manufacturers could make an y combination of improveme nts of the non

- engine technologies that they believe would best achieve the Class 8 overall vehicle performance standard

. (4) Alternative 4: Engines and Class 7 and 8 Tractors This alternative combines Alternative 2 with Alternative 3, and additionally would s et an overall vehicle efficiency performance standard for Class 7 tractors. This alternative would, thus, set standards for all HD engines and would set overall vehicle performance standards for Class 7 and 8 tractors, as described for Class 8 combination tractors under Alternative 3. Class 7 tractors make up a small percent of the tractor market, approximately

9 percent. 392 Though the segment is currentl y small, the agencies

391 See the NAS Report at Note (#), above, for discussions of the potential fuel efficiency improvement technologies that can be applied to each of these vehicle components. ( Chapter 5 )

. 392 MJ Bradley. Heavy Duty Vehicle Market Analysis. May 2009.364 of 54 1

believe the inclusion of this class of vehicles would help prevent a potential cl ass shifting, as noted in the NAS panel report. 393 (5) Alternative 5 : Engines , Class 7 and 8 Tractors, and Class 2b /3 Pickup Trucks and Vans This alternative builds on Alternative 4 through the addition of an overall vehicle efficiency performance standard for Class 2b/3 Pickup Trucks and Vans (or work trucks). Therefore, under this alternative, the agencies would set engine performance standards for each MD/HD vehicle class , and would also set overall vehicle performance standards for Class 7 and 8 tractors, as well as for Class 2b/3 Pickup Trucks and Vans. Compliance for the Class 2b and 3 pickup trucks and vans would be determined through a fleet averaging process similar to determining passenger car and light truck compliance with CAFE standards. (6) Alternative 6 : Engines, Tractors, and Class 2b through 8 Trucks. Alternative 6 represents the agencies’ preferred approach. This alternative would set engine efficiency

standards, engine GHG emissions standards, overall vehicle fuel efficiency standards, and over all vehicle GHG emissions standards for Class 2b and 3 pickup trucks and vans and the remaining Class 2b through Class 8 trucks and the engines installed in them . This alternative essentially sets fuel efficiency

and GHG emissions performance standards for both the engines and the overall vehicles in the entire heav y - dut y truck sector. Compliance with each vehicle class ’ engine performance standard would be determined as discussed in the description of Alternative 2. Compliance with the tractor and vocation al truck classes ’ overall vehicle performance standard (Class 2b through 8 trucks) would be determined as discussed in the description of Alternative 3. Compliance for the Class 2b and 3 pickup trucks and vans as described in Alternative 5. (7) Alternative 7 : Engines, Tractors, Trucks, and Trailers. This alternative builds on Alternative 6 b y add ing a performance standard for fuel efficiency and GHG emissions of commercial trailers . Therefore, this alternative would include fuel efficiency

performance standar ds and GHG emissions standards for Class 2b and 3 work truck and Class 3 through Class 8 vocational truck engines , and the performance standard s for the overall fuel efficiency and GHG emissions of those vehicles, as described above. (8) Alternative 8 : Engin es, Tractors, Trucks, and Trailers with Hybrid Powertrains Alternative 8 includes all elements of Alternative 7, plus applies the maximum application of h ybrids to the pickup trucks, vans, vocational trucks, and tractors by the

393 See NAS at Note (#), above, at page 6

- 38.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

365 of 54 1 2014 and the 2017 MY. The agencies are appl yi ng a 25 percent reduction to CO 2 emissions and fuel consumption, based on the findings of the NAS report. 394 The agencies also project a cost of $30,000 per vehicle for the vocational vehicles and combination tractors, which is the median value described in the NAS report for the vocational vehicles and tractors. The agencies are projecting a cost of $9,000 per vehicle for the HD pickup trucks and vans, again based on the NAS report. 395



### B. How do these alternatives compare in overall GHG emi ssions reductions and fuel efficiency and cost? The agencies analyzed all seven alternatives through MOVES to evaluate the impact of each proposed alternative, as shown in Table IX
- 1

.

Table IX - 1 : Annual CO 2 and Oil Savings in 2030 and 2050

Downstream CO 2 Savings (MMT) Oil Savings (billion gallons) 2030 2050 2030 2050 Alt. 1 0 0 0 0 Alt. 2

- Total 29 46 2.9 4.6 Tractors 19 27 1.8 2.6 HD Pickup Trucks 4 7 0.4 0.7 Vocational Trucks 6 13 0.6 1.2 Alt. 3

- Total 35 50 3.4 4.9 Tractors 35 50 3.4 4.9 HD Pickup Trucks 0 0 0 0 Vocational Trucks 0 0 0 0 Alt. 4

- Total 50 76 5.0 7.5 Tractors 40 57 3.9 5.6 HD Pickup Trucks 4 7 0.4 0.7 Vocational Trucks 6 13 0.6 1.2 Alt. 5

- Total 54 82 5.4 8.2 Tractors 40 57 3.9 5.6 HD Pickup Trucks 8 13 0.8 1.3 Vocational Trucks 6 13 0.6 1.2

394 NAS Report. Page 6

- 28. 395 NAS Report. Page 6

- 28.366 of 54 1 Downstream CO 2 Savings (MMT) Oil Savings (billion gallons) Preferred

- Total 58 91 5.8 9.0 Tractors 40 57 3.9 5.6 HD Pickup Trucks 8 13 0.8 1.3 Vocational Trucks 10 21 1.0 2.1 Alt. 7

- Total 62 96 6.1 9.5 Tractors 40 57 3.9 5.6 HD Pickup Trucks 8 13 0.8 1.3 Vocational Trucks 10 21 1.0 2.1 Trailers 4 5 0.4 0.5 Alt. 8

- Total Tractors HD Pickup Trucks Vocational Trucks Trailers
The aggregate t echnology costs for each alternative in 2030 and 2050 are included in Table IX
- 2

. Table IX - 2 : Technology Cost Projections for the Alternatives Technology

costs (2008$ millions) 203 0 2050 Alt. 1 $0 $0 Alt. 2

- Total $1,226 $1,544 Tractors $78 $103 HD Pickup Trucks $980 $1,140 Vocational Trucks $168 $301 Alt. 3

- Total $773 $1,023 Tractors $773 $1,023 HD Pickup Trucks $0 $0 Vocational Trucks $0 $0 Alt. 4

- Total $1,952 $2,506 Tractors $805 $1,065 HD Pickup Trucks $980 $1,140 Vocational Trucks $168 $301Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

367 of 54 1 Alt. 5

- Total $1,953 $2,506 Tractors $805 $1,065 HD Pickup Trucks $980 $1,140 Vocational Trucks $168 $301 Preferred

- Total $2,016 $2,623 Tractors $805 $1,065 HD Pickup Trucks $980 $1,140 Vocational Trucks $231 $418 Alt. 7

- Total Tractors $805 $1,065 HD Pickup Trucks $980 $1,140 Vocational Trucks $231 $418 Trailers $713 $943 Alt. 8

- Total Tractors HD Pickup Trucks Vocati onal Trucks Trailers



### C. How would the agencies include commercial trailers, as described in Alternative 7? A common theme throughout our proposed HD Program is a recognition of the diversity and complexity

of the heav y - duty

vehicle segment. Trailers are an important part of this segment and are no less diverse in the range of functions and applications they serve. They

are the primary

vehicle for moving freight in the United States. The ty pe of freight varies from retail products to be sold in store s, to bulk goods such as stones, to industrial liquids such as chemicals, to equipment such as bulldozers. Semi

- trailers come in a large variet y of st yl es
– box, refrigerated box, flatbed, tankers, bulk, dump, grain, and many others. The most common ty pe of trailer is the box trailer, but even box trailers come in man y different lengths ranging from 28 feet to 53 feet or greater, and in different widths, heights, depths, materials (wood, composites, and/or aluminum), construction (curtain side or hard sid e), axle configuration (sliding tandem or fixed tandem), and multiple other distinct features. NHTSA and EPA believe trailers impact the fuel consumption and CO 2 emissions from combination trucks and the agencies see opportunities for reductions. Unlike trucks and engines, EPA and NHTSA have very limited experience related to regulating trailers for fuel efficiency or emissions. Likewise, the trailer manufacturing industry has only the most limited experience complying with regulations related to emissio ns and none with regard to EPA or NHTSA368 of 54 1

certification and compliance procedures. We have therefore decided not to propose regulations for trailers in today ’s proposal. However in order to broadl y solicit comments on controlling fuel efficiency and GHG e missions through trailer regulations we are describing in an advanced notice of proposed regulation style a program which could set the foundation of a future rulemaking for trailers. We are soliciting comments on all aspects of the information shared in this section. (1) Why are the agencies considering the regulation of trailers? Trailers impact the aerodynamic drag, rolling resistance, and overall weight of the combination tractor

- trailer. TIAX, LL C performed an evaluation of SmartWay trailer technologies, and found that they provide the opportunity

to reduce fuel consumption and greenhouse gas emissions from tractor trailers b y up to 10 to12 percent for aerodynamics and 3 to 6 percent for lower rolling resistance tires. 396 Reductions of this magnitude are l arger than can be readily accomplished from improvements in engine design and are roughl y of the same magnitude as reductions possible through improvements in truck designs. Not onl y do trailers represent a significant opportunity for reductions as discus sed later in this section, but we have strong reason to believe that these reductions would not occur absent regulation as noted in the recent NAS report. The NAS report notes: A perplexing problem for any option, regarding Class 8 vehicles, is what to d o about the trailer. The trailer market represents a clear barrier with split incentives, where the owner of the trailer often does not incur fuel costs, and thus has no incentive to improve aerodynamics of the trailer itself or to improve the integration of the trailer with the tractor or truck
. 397 In other words, trailers affect the fuel efficiency of shipping, but they

do not face strong uniform incentives to coordinate with truck owners. In principle, if truck owners had the ability

to choose what traile rs they accepted, they

could require trailers with fuel

saving technologies; in practice, though, truck owners have limited practical ability to be selective about what trailers they accept. In this setting, information provision may be inadequate to address the related problems of split incentives and thin markets. Regulation aimed at trailer manufacturers can contribute fuel savings and GHG reductions that otherwise may be difficult to achieve.

396 TIAX. Assessment of Fuel Economy Technologies for Medium

- and Heavy

- Duty Vehicles. November 2009. Pages 4

- 50 and 4

- 57. 397 See NAS at Note (#), above, at ,p. 8

- 8.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

369 of 54 1 (2) What does the trailer industry look like? (a ) Trailer Types The commercial trailer market includes a wide variety of trailer t ypes. The market is dominated b y box (or van) trailers, which made up approximately 63 percent of the new trailers registered between 2003 and 2007. 398 The top ten new trailer registrations are included in by t ype are listed in Table IX
- 3

. Table IX - 3 : Trailer Registrations Trailer T yp e Percentage of Registrations (2003

- 2007) 399 Box 63% Flatbed (Platform) 8% Container C hassis 7% Refrigerated Van 5% Dump 3% Grain 2% Flatbed Drop Deck 2% Tank 1% Lowbed 1% Livestock 1% The remaining 6.5 percent of the trailer registrations consisted of livestock, transfer, hazardous chemical tanks, hoppers, gooseneck livestock, lowb ed drop deck, beverage, special, dry

bulk tanker, logging, wood chip, and other t ypes of trailers. Within each of these main trailer categories there are distinctions among trailer construction, materials, dimension, mass, and functionality , all of which can impact a trailer’s contribution to truck fuel consumption and greenhouse gas emissions. (b ) Trailer Fleet Size Relative to the Tractor Fleet The industry

generally recognizes that the ratio of the number of trailers in the fleet relative to the number of tractors is ty picall y three

- to
- one. 400 Ty picall y at any one time, two trailers are parked while one is being transported. For certain private fleets, this ratio can be greater, as high as six

- to
- one. This characteristic of the fleet impacts the cost effecti veness of trailer technologies because a trailer on average will only travel one third of the miles travelled b y a tractor.

398 See MJ Bradley at Note 392 , above. 399 See MJ Bradley at Note 392 , above. 400 See TIAX at Note 396 above, at page 4

- 49.370 of 54 1 (c) Trailer Owners Trailer ownership is distinct from that of the tractors. Trailers are often owned by shippers or b y leasing compani es, not by the trucking fleets. A special t ype of “trailer” is a shipping container used for intermodal surface movement to transport freight from ocean going liner vessels to inland destinations via truck, rail or barge. When hauled b y a truck, the cont ainer is loaded on a specialty piece of equipment called a “chassis.” This consists of a frame and axle/wheel assemblies on which the container is mounted, so that when the chassis and container are assembled the unit serves the same function as a road tr ailer. 401 Container chassis are sometimes owned b y specialty companies and are leased to ports, fleets, and shippers. Trailers that are purchased b y fleets are t ypically kept much longer than are the tractors, so trucks and trailers have different purchasi ng cycles. Because of the disconnect between owners, the trailer owners may not benefit directly from fuel consumption and GHG emission reductions. (d ) Trailer Builders The top ten builders of with the largest market share of trailer sales in 2009 include Uti lity

Trailer Manufacturing, Great Dane, Wabash National, Hy undai Translead, Timpte, Wilson Trailer, Stoughton Trailers, Heil Trailer, Fontaine Trailer, and MANAC. 402 However, nearly half of all trailer manufacturers are considered small businesses by

the Sm all Business Administration definition. 403 Therefore, the agencies will be required to convene a Small Business Regulatory Enforcement Fairness Act (SBREFA) panel to conduct the proper outreach to all stakeholders impacted by a proposed regulation for trail ers. Although trailer manufacturing is an important sector within the commercial vehicle manufacturing industry , trailers are far less mechanicall y complex than are the trucks that haul them. This means that trailer manufacturing has a low barrier to entry compared to automotive or truck manufacturers. The agencies can envision that proposed regulation would require significant effort to maintain a level playing field within the market to reduce the incentive to work around the regulation. (3) What technologi es are available to reduce fuel consumption and GHG emissions from trailers? There are opportunities to reduce the fuel consumption and GHG emissions impact of the trailer through aerodynamics, tires, and tare weight reductions to some extent in most ty

p es of trailers. In addition, refrigerated trailers have opportunities to both reduce the fuel consumption and CO 2 emissions of the Trailer Refrigeration Unit

401 Per 4 6 CFR § 340.2, 402 Trailer

- Body

Builders.com. 2009 North American Truck Trailer Output. http://trailer

bodybuilders.com/trailer

- output/output /200 9 _trailer_output_table/ 403 Per SBA definition for NAICS 336212, companies with less than 500 employees are considered small businesses.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

371 of 54 1 (TRU) and reduce GHG emissions through reduced refrigerant leakage. There are additional opportunities being developed for improvements in suspension sy stems, trailer structure, dump hoists and other features, depending upon the t ype of trailer and its intended function. (a ) Aerodynamics Trailer aerod yn amic technologies to date have focused on the box, van trailers

– the largest segment of the trailer fleet. This focus on box, van trailers may also be partially attributed to the complexity of the shape of the non

- box, van trailers which, in many cases, transport cargo that is in the windstream (e.g., fl atbeds that carry heavy equipment, car carriers, and loggers). For non

- box, van trailers you could have a different aerodyn amic shape with every load. While some technologies exist to address aerod ynamic drag for non

- box, van trailers, it has been either experimental or not widely commerciall y available. Current trailer aerodyn amic technologies for box trailers are estimated to provide approximately

7 percent GHG emission reductions when used as a package. 404 For box trailers, trailer aerodyn amic technolo gi es have addressed drag at the front of the trailer (i.e., vortex traps, leading edge fairings), underneath the trailer (i.e., side skirts, wheel fairings) and the trailer rear (i.e., afterbodies). These technologies are commerciall y available and have s een moderate adoption rates. More recent trailer aerody namic innovations channel air flow around the sides and under the trailer using underbody air deflectors (“underbell y treatment”). Table IX
- 4 lists technologies that the EP A SmartWay

program has evaluated for use on box, van trailers. In general, the performance of these technologies is dependent upon the smooth transition of airflow from the tractor to the trailer. True for both tractor and trailer aerodynamic drag reducti on, the overall shape can be optimized to minimize aerody namic drag.

404 [Cite]372 of 54 1 Table IX - 4 : Aerodynamic Technologies for Trailers Location on Trailer Technology Ty pe Designed Effect Front Vortex trap Reduce drag induc ed b y cross - flow through gap between tractor and trailer Front Front fairings Smoothly transition air to flow from tractor to the trailer Rear Afterbod y (boat tail

and rear fairings) Reduce pressure drag induced b y the trailer wake Undercarriage Side sk irts Manage flow of air underneath tractor to reduce eddies and wake Undercarriage Underbell y treatment Manage flow of air underneath tractor to reduce eddies and wake Accessories General Reducing surface area perpendicular to travel and minimizing comp lex shapes that may induce drag General Advanced, passive air

management Manage airflow through passive aerod ynamic shapes or devices that keep flow attached to the vehicle (tractor and trailer)
The agencies’ initial assessment of the incremental costs of aerod yn amics is included in Table IX
- 5 . The costs represent a high volume retail price of the components based on information developed for the NAS report405 and the I CF cost contract. 406 Table IX - 5 : Aerodynamic Technology Costs Technology Cost Estimate Trailer Side Skirts $1300

- 1600 Gap Fairing $850 Trailer Aerocone $1000 Boat Tails $1960 Air Tabs $180 Some of these technologies, such as side skirts, may be applicable to oth er trailer ty pes. The agencies are interested in comments regarding the aerody namic improvement opportunities in all ty

pes of trailers.

405 See TIAX, Note 396 above. 406 ICF. Investigation of Costs fo r Strategies to Reduce Greenhouse Gas Emissions fro Heavy

- Duty On

Road Vehicles. June 2010.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

373 of 54 1 (b ) Tires The rolling resistance coefficient ( RR c ) baseline for today ’s fleet is 6.5 kg/ton for the trailer tire, based on sales weighting of the top three manufacturers based on market share. Th is value is based on new trailer tires, since rolling resistance decreases as the tread wears. To achieve the intended emissions benefit, SmartWay established the maximum allowable RRc for the trailer tire 15% below the baseline or 5.5 kg/ton. Similar to combination tractor tires, low rolling resistance tires are available as either dual tires or as single wide

- base tires for trailers. Research indicates the contribution to overa ll vehicle fuel efficiency by tires is approximately

equal to the proportion of the vehicle weight on them. 407 On a fully loaded ty pical class 8 long

- haul tr actor and trailer, 42.5 percent of the total tire energy loss attributed to rolling resistance is fr om the trailer tires

. The T IAX assessment of single wide based tires on the trailer found that they provide approximately

a 3 percent fuel consumption benefit over a standard dual tire package. 408 Based on the ICF report, 409 EPA and NHTSA estimate the increme ntal retail cost for low rolling resistance tires as $78 per tire. The agencies also estimate that the incremental cost to replace a pair of dual tires with a single wide based tire is $216, however, the cost can be reduced when the wheel replacement cost is considered, since half the number of tires and wheels are needed. The inflation pressure of tires also impacts the rolling resistance. Underinflation causes an increase in rolling resistance and fuel consumption. Trailer sy stems, such as tire pressur e monitoring or automatic tire inflation, can help drivers insure that they are traveling with properl y i nflated tires. Estimates vary , but TIAX estimates on average that a trailer automatic tire inflation sy stem could provide a 0.6% benefit to fuel consumption for a cost of approximately $300 to $400. 410 (c) Weight Reduction Reduction in trailer tare (or empty) weight can lead to fuel efficiency reductions in two way s. For applications which are not limited by the weight limit, the overall weight of the trac tor and trailer combination would be reduced and would lead to improved fuel efficiency . For the applications which limit the payload due to the weight restrictions, the lower trailer weight would allow additional payload to be transported during the truc k’s trip. Weight reduction opportunities in trailers exist in both the structural components and in the wheels and tires. Material substitution (replacing steel with aluminum) is feasible for components such as roof posts, bows, side posts, cross

407 Bridgestone Firestone, North American Tire, LLC. “Tires & Truck Fuel Economy,” A New Perspective. Special Edition Four, 2008 408 See TIAX, Note 396 above, at page 4

- 56. 409 See ICF, Note 406 , above. 410 See TIAX, Note 396 above, at page 4

- 58.374 of 54 1

members , floor joists, and floors. Similar material substitution is feasible for wheels. Weight reduction opportunities also exist through the use of single wide based tires replacing two dual tires. The agencies’ assessment of the I CF report 411 indicates that th e expected incremental retail prices of the lightweighted components are as included in Table IX
- 6 : Trailer Lightweighting Costs

. Table IX - 6 : Trailer Lightweighting Costs Component Co st Roof Posts/Bows $120 Side Posts $525 Cross Members/Floor Joists $400 Floor $1,500 Wheels $1,500
(d ) Opportunities in Refrigerated Trailers Refrigeration units are used in van trailers to transport temperature sensitive products. A traditional TRU is powered b y a nonroad diesel engine. There are GHG reduction opportunities in refrigerated trailers through the use of electrical trailer refrigeration units and highl y reflective trailer coatings. Highl y reflective materials, such as reflective paints or translucent white fiberglass roofs, can reflect the solar radiation and decrease the cooling demands on the trailer’s refrigeration unit. A reflective composite roof can cost approximately $800, the addition of reflective tape to a trailer roof would c ost approximately $450. Hy brid trailer refrigeration units utilize a diesel engine which drives a generator which in turn powers the compressor and fans. The cost of this unit is approximately $4,000. (4) What approaches could the agencies propose for evaluat ing fuel efficiency and GHG emissions contributions from trailers? Building from EPA’s SmartWay experience, EPA and NHTSA have considered several options to demonstrate GHG and fuel consumption reductions from trailer technologies. The agencies welcome co mments on the testing approaches describe below or alternative recommendations.

411 See ICF, Note, 406 , above.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

375 of 54 1 (a ) Metric There are several metrics that the agencies envision could be appropriate used to evaluate the fuel consumption and CO 2 emissions due to trailers. The agencies are prop osing the use of a ton

- mile metric with a prescribed payload for each truck regulatory class. A similar approach could be applied to trailer evaluation, which would account for aerod ynamic improvements, tire improvements, and trailer lightweighting. Howe ver, a ton
- mile metric does not necessarily capture the capacit y aspect of trailers. Box trailers provide benefits to freight efficiency through an increase in either cubic volume or pallet

equivalent. Certain box van trailers including drop frame moving van trailers and high cube trailers are speciall y designed to maximize cubic capacity. The agencies welcome comments regarding the appropriate metric for trailer efficiency demonstration. (b ) Potential Approaches to Evaluate GHG Emissions and Fuel Consumpti on Reducing Technologies (i ) Design

-Based Specification Approach The SmartWay

certification for tractors and dry box van trailers began as a design

- based specification, developed on the basis of test results for individual components (tires, wheels, aerodynami c equipment, auxiliary power units, and engines) that have been demonstrated to improve fuel efficiency and reduce emissions. (ii) Modeling Approach As the agencies are proposing for the evaluation of tractors and vocational trucks, a similar simulation mod el approach could also be applied to trailers. A simulation

- based model would require the trailer manufacturer input parameters similar to the ones proposed in the tractor program

– coefficient of drag, tire rolling resistance, and weight. The agencies e nvision that a standardized tractor would be required to fairly assess the tractor
- trailer s ys tem. Both agencies have years of successful experience with vehicle simulation modeling. EPA, DOE, DOT, Commerce and others used vehicle simulation modeling to jumpstart technology scenarios for the Partnership for a New Generation of Vehicles Program, a large public

- private research program aimed at developing advanced fuel

- efficient passenger vehicle designs. Those same agencies used vehicle simulation modelin g for a similar purpose in the 21 st Century Truck Partnership, a sister program to develop advanced fuel

- efficient commercial truck designs. EPA used vehicle simulation modeling to characterize various technology scenarios for its initial design of the SmartWay

program and to conduct anal ys es on its test data, test cycles, and related data. This experience has demonstrated to the technical staff at EPA and DOT that vehicle simulation modeling can be a reliable and feasible tool to assess vehicle performanc e. EPA and NHSTA welcome comments from trailer manufacturers on their ability to run simulation models and evaluate the aerodynamics of the trailers which they produce. (iii) Whole Vehicle Testing

– Chassis, Track or On

-Road Test Complete vehicle testing is commonly conducted on chassis dy

namometers, tracks, or on the road. Light

- dut y vehicles are tested on chassis dynamometers to376 of 54 1

demonstrate compliance with EPA and NHTSA regulations associated with emissions and fuel efficiency , respectively . Heavy dut y truck manufacturers often use paired truck test, such as prescribed in SAE J1321, 412 to evaluate the difference between two trucks. The current SmartWay

verification program allows for a modified SAE J1321 test to be used to evaluate the fuel consumption performa nce of trailers due to improvements in aerod ynamic design. Heavy dut y truck fleets today commonl y use long term on

- road testing to evaluate trucks, trailers, and technologies. A chassis d ynamometer test is a test conducted indoors on a h ydrokinetic chass is dy namometer. The chassis dy namometer option in this test procedure incorporates man y of the methods and requirements established in the federal light

- duty vehicle and ‘light’ heav y - dut y vehicle emissions certification chassis test procedure. Chassis dyn amometers may be found at vehicle test laboratories; t ypicall y, facilities used for emissions and vehicle fuel efficiency

testing. Because the test is conducted on a chassis dy namometer, rolling resistance, aerodynamic drag and inertial road load power requirements must be determined ahead of time, with coastdown tests and calculations to determine the proper horsepower absorption setting for the chassis dy namometer. A track test is a complete vehicle test conducted on an outside test track. Test trac ks may

be found at vehicle proving grounds or other facilities specifically designed for vehicle or tire performance testing. Because the test involves the vehicle being operated on a road surface in a manner similar to that of on

- road driving, rolling re sistance, aerodyn amic drag, and inertial road load power requirements are incorporated in the test measurement, and do not have to be determined beforehand with a coastdown test and calculations. Although the result of a track test reflects real

- world veh icle performance better than a chassis dynamometer test, by directl y evaluating the impacts of road effects such as aerody namic drag of tractors and trailers and rolling resistance effects of tires, variability of ambient conditions may result in greater v ariability of test results. 413 Therefore, an y protocol should include specification of ambient conditions as well as specifications for measurement of fuel consumption. The TMC/SAE Fuel Consumption test is a standardized on

- road test procedure for comparing the in

- service fuel consumption of two conditions of a test vehicle or one test vehicle to another. 414 The procedure uses an unchanging control vehicle run in tandem with the test vehicle. The result of the test is the percent difference in fuel consumpti on between two test vehicles.

412 Society of Automotive Engineers. Joint TMC/SAE Fuel Consumption Test Procedure

– Ty pe II. SAE J1321. October 1986. 413 How ever, it has been demonstrated that even tests conducted in laboratories have differences in repeatability within a given laboratory and differences in reproducibility among laboratories. See “Interlaboratory Crosscheck of Heavy duty Vehicle Chassis Dynamometers” Final Report CRC Project No. E
- 55
- 1, May, 2002. 414 See SAE, Note 412 , above.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

377 of 54 1 The agencies are interested in comments regarding the advantages and disadvantages of each approach, along with any baseline trailer performance. (5) What actions are already being taken to improve the efficiency of trailers? (a ) Sma rtW ay Certified Trailers Beginning in 2007, EPA began designating certain new dry freight box van trailers for on the road use of 53 feet or greater length Certified SmartWay Tra ilers

. Older or pre

- owned trailers could also be certified if properl y retrof itted. Inorder for a tra iler to be designated as Certified SmartWay , the tra iler must be equipped with aerod ynamic devices such as trailer skirts and gap reducers along with verified low rolling resistance trailer tir es (either dual or single

- wide)

. Tra iler manufacturers can also test trailers using a modified J1321 test method to assess the fuel

- saving impact of the aerod ynamic features. Trailers that meet or exceed the minimum threshold for reduction in fuel consumption and that are equipped with Smar tWay
- verified low rolling resistance tires are eligible for SmartWay designation. Information about SmartWay certified trailers, the test methods, and verified trailer equipment is at the US EPA SmartWay web site, http://www.epa.gov/smartway

. (b ) California AB32 The California requirement to reduce GHG emissions from trailers became effective in 2010. 415 Itrequires that all new 2011 model year dry van trailers are SmartWay

certified or demonstrate a 5 percent aerodynamic and a 1.5 percent tire improvement. Compliance is demonstrated through the use of SmartWay certified components or a SAE paired

- truck test to demonstrate improvements. California is also requiring retrofit of existing van trailers phasing in start ing in 2011. Information on the California program can be found at the California Environmental Protection Agency Air Resources Board web site, http://www.arb.ca.gov/cc/hdghg/hdghg.htm

. (6) Why are the Agencies delaying regulation and what are the next steps for trailer regulation? It is the intent of both agencies to take advantage of available and very near - term technologies to achieve early reductions in greenhouse gas emissions and fuel consumption. As noted above, President Obama requested both agencies to coordinate to create a first

- ever National Policy to increase fuel efficiency and decrease greenhouse gas pollution from medium

- and heav y - dut y trucks for Model Years 2014

- 2018. To meet the goal s within the time frame outlined by the President in his directive, EPA and DOT are moving expeditiously

to develop these proposed regulations as outlined in today ’s proposal.

415 California Air Resources Board. http://www.arb.ca.gov/regact/2008/ghghdv08/ghghdv08.htm , accessed (date)378 of 54 1 The expertise of each agency ’s technical and regulatory staff, along with crit ical input from the SmartWay program, industry

and other key

stakeholders, make it feasible to propose regulations covering commercial medium

- duty and heavy

- dut y trucks within this time frame. However, both EPA and NHTSA recognize, along with the NAS, the diversity and complexity

of the trailer industry . There are dozens of trailer ty pes, dozens of trailer manufacturing entities, and several diverse trailer end user groups. In addition to the challenge of addressing these multiple complexities, unlike many other vehicle sectors, this is an industry that has never before been subject to either emissions or fuel econom y regulation. Additionally , since a number of trailer manufacturing entities are small businesses, EPA and NHTSA need to allow sufficient t ime to convene a Small Business Regulatory

Enforcement Fairness Act (SBREFA) panel to conduct the proper outreach to the potentially

impacted stakeholders. Therefore, EPA and NHTSA propose to follow their proposals for medium

- duty and heav y - dut y truck regulations with a proposal for regulating trailers, at a future date to be determined after both agencies conduct a more comprehensive assessment of the topics discussed in this section. EPA and NHTSA welcome comment on delaying proposing trailer regulat ions and on related topics that might affect the timing of such a proposal. 

## X. Recommendations fr omthe Mar ch 2010 NAS Report A. Overview One of the most important resources for the agencies in developing the HD National Program was the report produced b y the National Academ y of Sciences in response to Congress’ mandate in EISA. Section 108 of EI SA states that DOT (by delegation, NHTSA) must execute an agreement with the NAS “to develop a report evaluating MD/HD truck fuel econom y standards, including

— (1) an assessment of technologies and costs to evaluate fuel economy for MD/HD trucks; (2) an anal ys is of existing and potential technologies that may be used practically to improve MD/HD truck fuel econom y; (3) an anal ys is of how such technologies may be practi call y integrated into the MD/HD truck manufacturing process; (4) an assessment of how such technologies may be used to meet fuel economy standards to be prescribed under 49 U.S.C. § 32902(k); and (5) associated costs and other impacts on the operation of M D/HD trucks, including congestion.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

379 of 54 1 EI SA further states that the NAS must submit the report to DOT, the Senate Committee on Commerce, Science, and Transportation, and the House Committee on Energy and Commerce not later than one y ear after the date on which the Secretary executed the agreement with the NAS. NAS requested and was granted an additional six months to complete its report, so based on the date of execution of the ultimate agreement, the deadline for the NAS report was determined to be March 2010

. The National Research Council (NRC) Committee to Assess Fuel Econom y Technologies for Medium

- and Heav y - Dut y Vehicles was formed to fulfill the contract between NHTSA and the NAS. 416 Interpreting the tasks listed in Section 108 of EI SA, NAS directed the committee to:

 Consider approaches to measuring fuel econom y for medium

- and heav y - duty vehicles that would be required for setting standards;  Assess current and potential technologies and estimate improvements in fuel econom y for medium

- duty and heavy

- duty trucks that might be achieved;  Address how the technologies identified in the task above may be used practically

to improve medium

- duty

and heavy

- dut y truck fuel economy;  Address how such technologies may be practically

integrated into the medium

- duty an d heav y - dut y truck manufacturing process;  Assess how such technologies may be used to meet fuel econom y standards;  Discuss the pros and cons of approaches to improving the fuel efficiency of moving goods as opposed to setting vehicle fuel econom y standards ; and  Id entify

the potential costs and other impacts on the operation of medium

- duty and heav y - dut y trucks. 417 The NAS Report “Technologies and Approaches to Reducing the Fuel Consumption of Medium

- and Heav y - Dut y Vehicles” (“March 2010 NAS Report” or “NAS R eport”) was delivered to NHTSA in pre

- publication form in mid

- March 2010, to Congress in late March 2010, and was released to the public on March 31, 2010. 418 Although the NAS Report was developed and written in terms of reducing fuel consumption, its findi ngs and recommendations apply equally to a program that reduces GHG emissions, given the close relationship between the two.

416 National Academy of Science, Committee to Assess Fuel Economy Technologies for Medium

- and Heavy
- Duty Vehicles, “Technologies and Approaches to Reducing the Fuel Consumption of Medium

- and Heavy
- Duty Vehicles,” March 2010 (hereafter, “March 2010 NAS Report” or “NAS Report”), at 1

- 1. Available at http://www.nap.edu/catalog.php?record_id=12845 (last accessed June 20, 2010). 417 See Note 416 above, at 1

- 2. 418 Id

.380 of 54 1



### B. What were the major findings and recommendations of the March 2010 NAS Report, and how is the proposed HD National Program consiste nt with them? The March 2010 NAS Report spanned eight chapters and several hundred pages, with dozens of major findings and recommendations. While this preamble refers frequentl y throughout to the various NAS findings and recommendations as it explains th e HD National Program, this particular section is designed to provide the reader with a quick reference guide to the findings and recommendations and the extent to which the agencies’ proposed program is consistent with them. The significant majority of NAS’ findings and recommendations have been implemented directl y b y the agencies. Generally speaking, to the extent that the proposed HD National Program diverges from the NAS recommendations, it is often due to differences in the agencies’ approach as compared to NAS’ expectations for a HD regulatory program, which the agencies think are necessary

and beneficial in order to obtain the greatest GHG and fuel consumption reductions as rapidly

as possible, and to facilitate the transition for the industry to a more holistic regulatory

s ys tem over a longer timeframe. Instead of discussing the NAS Report findings and recommendations in the order presented in the Report itself, as is done in the NHTSA Study accompanying this NPRM, this section divides the NAS find ings and recommendations into three categories: findings and recommendations with which (1) the HD National Program is consistent; (2) the HD National Program is significantly inconsistent; and (3) the HD National Program is less

- significantl y inconsistent. (1) NAS findings and recommendations with which the proposed HD National Program is consistent (a ) What metrics should be employed for regulating fuel consumption/GHG emissions ? With the light

- duty

fuel economy

and GHG regulations as a backdrop, the NAS committ ee considered the difference between fuel economy (a measure of how far a vehicle will go on a gallon of fuel) and fuel consumption (the inverse measure, of how much fuel is consumed in driving a given distance) as potential metrics for MD/HD regulations. 419 Noting the non

- linear nature of fuel economy

– e.g. , that more fuel can be saved b y increasing fuel econom y from 14 to 16 mpg than from 30 to 32 mpg

– and its potential to confuse consumers, the committee concluded that fuel economy would not be a good m etric for judging the fuel efficiency of a vehicle, and stated that it would use fuel consumption throughout the report instead. 420

419 See Note 416 above,at 2

- 15 through 2

- 17. 420 I d . at 2

- 17.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

381 of 54 1 However, because MD/HD vehicles are designed to carry loads in an efficient and timely manner, as opposed to light

- duty vehicl es which are generally used simply

for carryi ng passengers, the committee suggested that normalizing the fuel consumption to the payload that the vehicle hauls would be the best way to represent an appropriate attribute

- based fuel consumption metric. 421 The committee identified this metric as “L oad

- Specific Fuel Consumption” or “L SFC,” defined as fuel consumption on a given cycle (in gallons/100 miles), divided by payload (in tons). 422 The committee thus recommended that an y HD fuel consumption regulation use LS FC as the metric and be based on using an average (or t ypical) payload based on national data representative of the classes and dut y c yc le of the vehicle. 423 The committee noted that standards might require different values of L SFC due to the various fun ctions of the vehicle classes, e.g. , pickup trucks versus utility trucks versus line

- haul trucks. 424 The committee stated that any data reporting or labeling should state an LSFC at specified tons of payload. 425 The agencies agree that the appropriate metric for regulating HD vehicle GHG emissions and fuel consumption is one tied to the vehicle’s task and reflects the work done by the vehicle. Thus, the agencies have employed different metrics in developing the proposed standards in this NPRM, as follows: The metric for HD engines is grams of CO 2 /brake horsepower

- hour (g/bhp

- hr) and gallons/brake horsepower

- hour (gal/bhp

- hr), which normalizes CO2 emissions and fuel consumption based on work done. The metric for line

- haul Class 7 and 8 trucks is grams of CO 2 /payl oad ton

- mile (g/ton

- mile) and gallons/payload ton

- mile (gal/ton

- mile), which normalizes CO2 emissions and fuel consumption based on the work done in transporting payload. The metric for vocational (Class 4

- 8) trucks is also grams of CO 2 /ton

- mile (g/ton

m ile) and gallons/ton

- mile (gal/ton

- mile), which normalizes CO2 emissions and fuel consumption based on work done. The metric for Class 2b/3 trucks (and cab

- chassis Class 2b/3 trucks and related Class 4 trucks) is grams of CO 2 /mile (g/mi) and gallons/mile (gal/mi)., While these metrics are not normalized by payload, standards are based on the work done by the vehicles in that the standards are vehicle attribute based and a function of payload capacity and towing capacity

(and whether two

- wheel drive or four

- wheel drive). In establishing measurement driving cycles and vehicle load settings, the agencies carefully review reviewed available data and selected cycles and vehicle load settings that are judged to be most representative of national average use.

421 See Note 416 above, at 2

- 18, and at 8

- 18, Recommendation 8

- 3 422 Id. 423 See Note 416 above . at 2

- 40, Recommendation 2

- 1. 424 Id . The committee also state d that regulators should use a common procedure to develop baseline LSFC data for various applications, to determine if separate standards are required for different vehicles that have a common function. 425 Id

.382 of 54 1 Thu s, as NAS recommended, the agencies are proposing separate standards with different metrics

– all based on consideration of the tasks vehicles perform and the work they do, which is consistent with the L SFC concept

– for different classes of vehicles.. The agencies have no plan to require fuel consumption labeling, or to publish values for individual vehicles. Because of the broad range of actual vehicle use, including the range of payloads carried, driving cycles and road terrain, and recognizing that, fo r individual vehicles, engines, transmission ratios, final drive ratios and tire sizes are selected based on intended use, the agencies judge that a label or published fuel consumption value, based on testing under average conditions, would likely not prov ide an accurate assessment of individual vehicle fuel consumption performance, and may be misleading. (b ) Which classes of vehicles should be regulated ? The committee stated that while it may seem expedient to initially focus on those classes of vehicles with the largest fuel consumption ( i.e. , Class 8, Class 6, and Class 2b, which together account for approximately 90 percent of fuel consumption of HD vehicles), the committee believes that selectivel y regulating onl y certain vehicle classes would lead to very serious unintended consequences and would compromise the intent of the regulation. 426 The committee suggested, however, that within vehicle classes, there may be certain subclasses of vehicles ( e.g. , fire trucks) that could be exempt from the regulation w ithout creating market distortions. 427 The agencies agree that it is crucial to avoid unintended consequences such as class shifting, which might occur as a result of regulating onl y certain classes of trucks. Thus, as NAS recommended, the agencies are regu lating all Classes 2b through 8 in this first round of regulations, with different standards tailored to different groups of vehicles to maximize fuel savings and emissions reductions as appropriate for the work that they perform. In addition, the agencie s agree with the NAS recommendation that certain subclasses be exempted from regulation and have provided flexibilities that include Averaging, Banking and Trading, and exemptions for some off

- road vehicles. Related to this recommendation, NAS also noted that large OEMs with significant engineering capability

design and manufacture almost all Class 2b, 3, and 8b vehicles, while small companies with limited engineering resources make a significant percentage of vehicles in Classes 4 through 8a, although in many cases they

buy the complete chassis from larger OEMs. 428 The committee emphasized that regulators will need to take into account the limitations of these smaller companies. 429

426 Id . at 8

- 17, Finding 8

- 1. 427 See Note 416 above. 428 Id ., Finding 8

- 2. 429 Id

.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

383 of 54 1 The agencies agree that the impacts on small manufacturers in Classes 4 through 8a should be considered in developing HD regulations, and have done so through the structure of our standards for those vehicle classes. See Section II in this preamble for a fuller discussion. The agencies are proposing to not set standards at this ti me for engine, chassis, and vehicle manufacturers which meet the small business definitions. (c) What test procedures should be employed for evaluating compliance with standards ? The committee emphasized that a certification test method must be highly accurate , repeatable, and identical to the in

- use compliance tests, as is the case with current regulation of light

- duty vehicles tested on a chassis dy namometer, and for heav y duty engine emission standards tested on engine dy namometers. 430 The committee stated th at using the process and results from existing engine dyn amometer testing for criteria emissions to certify

fuel econom y standards for MD/HD vehicles would build on proven, accurate, and repeatable methods, and put less additional administrative burden on the industry

. 431 However, the committee cautioned that to account for the fuel consumption benefits of h ybrid powertrains and transmission technology , the present engine

- onl y tests for emissions certification will need to be augmented with other powertrain components added to the engine test cell, either as real hardware or as simulated components. 432 Additionally , the vehicle attributes (aero, tires, mass) would need to be accounted for, perhaps b y using vehicle

- specific prescribed loads (via models) in the test cycle, which the committee stated would require close cooperation among component manufacturers and vehicle manufacturers. 433 The committee noted that since there is currentl y no established federal test method for HD vehicle fuel consumption, either empirical testing (whether at the component level or up to the whole vehicle level) or simulation modeling or both could be used for the characterization and certification of regulated equipment. 434 The committee cautioned that each approach involves uncertai nties that can affect certification and compliance, and stressed the need for a pilot regulation program to examine the potential for these effects. 435 The committee also noted that significant segments of the MD/HD vehicle purchasing process are highl y cons umer - driven, with many engine, transmission, and drive axle choice combinations resulting in a wide array of completed vehicles for a given vehicle model. 436 The committee stressed that from a regulatory standpoint, the use of expensive and time

- consuming c hassis testing on each distinct vehicle variation is

430 Id . at 8

- 19, Finding 8

- 8. 431 Id ., Finding 8

- 9. 432 See Note 416 above. 433 Id

. 434 Id ., Finding 8

- 10. 435 Id

. 436 Id ., Finding 8

- 11.384 of 54 1

impractical. 437 However, the committee suggested that by knowing the performance of major subcomponents on fuel consumption, it may be practical to demonstrate compliance certification with vehicle standa rds b y aggregating the subcomponents into a specified virtual vehicle for computers to evaluate fuel consumption of the completed vehicle. 438 The committee stated that further research will be required to underpin the protocol used to measure key input param eters, such as tire rolling resistance and aerod ynamic drag forces, and to ensure the robustness of simulations for evaluating vehicle fuel consumption. 439 However, the committee stated, once determined, these major components may

be assembled through simul ation to represent a whole

- vehicle sy stem, and models benchmarked to reliable data may be used to extend the prediction to a variet y of vehicle t ypes, by changing bodies (aerodynamic measures), tires, and operating weights associated with the powertrains. 440 Thus, the committee recommended that the agency consider the use of simulation modeling with component test data and additional tested inputs from powertrain tests as a way of lowering cost and administrative burdens yet achieving needed accuracy of resul ts. 441 The committee stated that this is similar to the approach taken in Japan, but different in that the program would represent all of the parameters of the vehicle (powertrain, aerodynamics, and tires) and relate fuel consumption to the vehicle task. 442 The committee further recommended that the combined vehicle simulation/component testing approach be supplemented with tests of complete vehicles for audit purposes. 443 The agencies agree that choosing accurate and repeatable test procedures that build on ex isting procedures to the maximum extent will minimize administrative burden and be crucial for the success of the program. Thus, as NAS recommended, the agencies are proposing chassis dynamometer testing for Class 2b/3 and related trucks, building off exi sting criteria pollutant emissions test programs and manufacturers’ experience with light

- duty fuel econom y test procedures; engine dynamometer testing for HD engines, building off existing criteria pollutant emissions test programs; and vehicle simulation testing for Class 4

- 8 vocational trucks and Class 7

- 8 line

- haul trucks, which is new for this program but which, the agencies believe, minimizes burden while maximizing accuracy and repeatability . The agencies have carefully considered measurement protoc ols for key

simulation input parameters and have structured the program to reduce sensitivity

to accuracy

and repeatability

issues. See Section V in this preamble for a fuller discussion. The agencies recognize the importance of continuing work to standar dize and refine measurement methods and intend to work with industry and

437 See Note 416 above. 438 Id

. 439 Id ., Finding 8

- 12. 440 Id

. 441 Id ., Recommendation 8

- 4. 442 See Note 416 above. 443 Id

.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

385 of 54 1 technical organizations to improve those measurement methods. The simulation program includes inputs for all vehicle parameters that affect fuel consumption, but the interface allow s manufacturers to enter a limited number of the inputs for this first program. The majority

of inputs have been preselected by the agencies to represent ty pical vehicle attributes in each regulatory category . The agencies believes this approach and the choice of preselected parameters will reduce the potential for unintended consequences. The simulation program also uses vehicle loads and driving cycles that were selected based on careful consideration of vehicle task, as recommended. And finally , test ing of complete vehicles for audit purposes has occurred and will continue to occur during the comment period, in order to further hone the accuracy of the simulation approach. The agencies are thus consistent with NAS’ recommendations with respect to tes t procedures. The agencies have structured the program to regulate large manufacturers, and as such there are fewer regulated entities than the NAS study envisioned. The agencies agree with the NAS expectation that a program would require close cooperatio n among component manufacturers and vehicle manufacturers. The agencies believe the regulated manufacturers, and their suppliers, have sufficient resources handle this burden, and in most cases are already operating with close cooperation. (d ) How should appropriate technologies be determined ? The committee emphasized that t echnology effectiveness (that is, its fuel consumption/emissions reduction potential) is extremel y dependent on application (for example, a hy

brid powertrain applied to a pickup truck versu s line

- haul tractor) and drive cycle (for example, start

- stop versus stead y - state, variations in load, etc.)

. 444 The committee also stressed that while s ome technologies are economicall y viable now, others may require significantly higher fuel costs or valu ations of environmental/securit y externalities to make them cost

- beneficial. 445 The agencies recognize and agree that not all technologies are applicable in the same way to all HD trucks and all drive cycles, and that not all technologies are cost

beneficial in the timeframe of this rulemaking. The agencies divided the overall HD fleet into unique categories in order to group generally similar vehicle ty

pes that have generall y similar uses. For vocational vehicles, where uses and drive cycles are highl y vari ed, the agencies have structured the program in a way that should provide benefits broadly through the separate regulation of engines and the vehicle (effectively onl y the tires, for this first rulemaking). Measurement of fuel consumption performance in e ach category is based on estimated average drive cycles and vehicle loading for that category

. Section III discusses these issues in considerable detail.

444 Id . at S

- 9, Finding 4/5/6

- 1. 445 Id ., Finding 4/5/6

- 2.386 of 54 1 (2) NAS findings and recommendations with which the proposed HD National Program is not significantly co nsistent, and why the agencies have chosen a different path (a ) Should the agencies conduct a pilot program? In briefings to the agencies following the completion of the NAS Report, the committee repeatedl y stressed its final recommendation over all others: that NHTSA should conduct a pilot program before beginning to regulate HD fuel consumption officiall y, and that the pilot program should have these elements: NHTSA should “Gain experience with certification testing, data gathering, compiling and reporting. There needs to be a concerted effort to determine the accuracy and repeatability

of all the test methods and simulation strategies that will be used with any

proposed regulatory

standards and a willingness to fix issues that are found.” NHTSA should “Gath er data on fuel consumption from several representative fleets of vehicles. This should continue to provide a real

- world check on the effectiveness of the regulatory design on the fuel consumption of trucking fleets in various parts of the marketplace and various regions of the country .” The committee’s fundamental concern was that given that HD fuel consumption had never previousl y been regulated, and given the scope of the regulatory system that the committee had envisioned, serious unintended consequenc es could occur if NHTSA did not build in extra time to conduct a pilot program, with negative effects on the regulated industry

and on fuel savings. With regard to NAS’ first concern, that NHTSA must gain experience with certification testing, data gatheri ng, compiling and reporting before initiating a HD fuel consumption regulatory

sy stem, the agencies believe that the proposed HD National Program may

avoid the risks that NAS identified because it is based in large part on existing test protocols and repor ting sy stems. The agencies’ proposed certification and compliance programs for Classes 2b/3, for example, employ the same testing procedures and reporting s ys tems as for light

- dut y CAFE and GHG regulations, so both the agencies and the manufacturers who are regulated already have much experience with testing, data collection, and reporting. 446 For HD engine standard certification and compliance, similarly , the agencies’ proposed s ys tems rel y on engine testing identical to that already used by EPA and manufa cturers for criteria emissions regulations, and also vehicle modeling. While it is true that the vehicle testing for Class 7

- 8 line

- haul tractors and Class 4

- 8 vocational trucks is new, the agencies believe that the proposed modeling approach will likely avoid NAS’ concerns due to its degree of simplification, relative to what NAS considered. The agencies are not requiring the same level of whole vehicle simulation

446 See Sec tion II of this preamble.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

387 of 54 1 for certification and compliance as envisioned b y NAS

– instead, while manufacturers will take real

- world measurements for each component or sy stem attribute, those measurements will all be placed into “bins,” and the bin value (which will be representative and pre

- defined) will be the value actually employed in the modeling sy stem. The agenci es believe that this approach has considerable merit in the timeframe of this rulemaking to initiate the HD National Program for several reasons. First, since not all test methodologies have been firmly established, pre

- defined bin values help to mitigate measurement uncertaint y that might otherwise allow manufacturers to game the testing protocol. While there may be some loss of accuracy due to use of bin values rather than direct measurement values, and while the agencies will have to track vehicle mode l inputs carefull y to ensure that manufacturers are not gaming the bins themselves, the agencies believe that the proposed levels of stringency should compensate for these risks. And second, waiting for a pilot program to gain additional experience with t esting, data gathering, and reporting would delay our ability

to get fuel efficiency

and emissions improvements as soon as possible. I f a pilot program was initiated as earl y as MY 2014, and it took one year to collect information to inform rulemaking and an additional year for finalizing a rule that, by statute, would provide 4 y ear lead time, the first regulated ye ar would be 2020. The costs of waiting to regulate officiall y, in terms of fuel savings and emissions reductions, would likely outweigh the potential benefits of gaining more experience, especiall y gi ven the structure of the first phase of the proposed HD National Program. With regard to NAS’ second concern, that NHTSA must gather data on fuel consumption from representative fleets as a real

- w orld check on the effectiveness of the regulatory

design, the agencies believe that the proposed HD National Program will be much better able to avoid unintended consequences than the regulatory s ys tem that NAS envisioned because we do not propose to regul ate the entire vehicle as a single s ys tem. The agencies believe that the proposed HD National Program approach has considerable merit for the timeframe of this rulemaking because it does not regulate transmission and final drive ratios and tire sizes, and thus allows manufacturers and customers to continue to specify these attributes in order to optimize them for specific vehicle use. This reduces the need for our regulatory program to define the real

- world drive cycle (in terms of speed, load, grade, and altitude) exactly correctly for every individual vehicle, as compared to NAS’ envisioned approach. Additionally , by expressl y requiring improvements in engine efficiency , the proposed HD National Program will require all vehicles to become more efficient regardless of their intended use. Although the agencies will not document exact real

- world measured improvements in fuel efficiency /emissions reductions, the program will achieve percentage improvements that may be approximately

estimated. Furthermore, while program benefits may be lower than the full potential envisioned by NAS if fleets choose to optimize powertrain specifications for purposes other than fuel efficiency , the agencies believe that achieving improvements sooner outweighs the less

- certain later benefits of undertaking an initial pilot program as suggested b y NAS.388 of 54 1 (b ) Should the agencies regulate trailers in the first phase of the HD National Program? The NAS committee recommended that NHTSA include trailers in its regulatory program to achieve m aximum possible fuel efficiency improvements , and also to provide an incentive to manufacturers to optimize the tractor/trailer interface. 447 The committee noted that commercial trailers are produced b y a separate group of about 12 major manufacturers that are not associated with truck manufacturers. 448 The committee stated that trailers represent an important opportunity for fuel consumption reduction, and can benefit from improvements in aerody namics and tires. 449 For purposes of the proposed HD National Program, the agencies intend to consider regulation of trailers in the next phase of rulemaking and not in this initial phase. As the committee suggested, regulating trailers is very challenging due to the nature of the trailer industry , with many small manufacturers and very long vehicle lifespans. However, since trailer production volume is low, the agencies project that their impact on fuel consumption and emissions reduction will be much smaller than for regulating engines and tractors, as the agencies intend to do in the first phase of the HD National Program. The agencies are thus deferring trailer regulations until a subsequent phase. 450 (c) Should the agencies include in their baseline analysis the effect of the California Air Resources Board SmartW ay man date? The committee found that the legislation passed by California requiring tractor

trailer combinations to be SmartWay certified will have a significant impact on the number of vehicles in the United States that are specified with fuel

- efficient technol ogies beginning in 2010. 451 The agencies are using a 2010 baseline with an estimate of national sales mix that includes the sales of SmartWay tractors. The California trailer mandate is not reflected in either the baseline or the proposal estimates because this proposal does not regulate trailers. Therefore the agencies believe the estimated program for this proposal account for the effects of the California SmartWay mandate (d ) Should the agencies’ aerodynamic drag test method include varying yaw angles? The committee recommended that a HD fuel consumption regulation should require that aerodyn amic features be evaluated on a wind

- averaged basis that takes into account the effects of yaw, and that tractor and trailer manufacturers should be required to certify their drag coefficient results using a common industry standard. 452 The

447 See Note 416 above, at 8

- 18, Recommendation 8

- 2. 448 Id ., Finding 8

- 3. 449 Id

. 450 See Section II of this preamble. 451 See Note 416 above, at 3

- 16, Finding 3

- 4. 452 Id . at 5
- 63, Recommendation 5

- 1.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

389 of 54 1 committee stated that yaw - induced drag can be accuratel y measured onl y i n a wind tunnel. 453 The agencies are not implementing this recommendation in the first phase of the proposed HD National Program. The current lack of common wind tunnel facilities precludes using a single aerodynamic test method at the outset of the program, which will begin with EPA’s GHG regulations in 2014. Instead, the program will allow manufacturers to continu e to use whatever aerodynamic test method they currentl y use. This will ease administrative burden, but the agencies recognize that it will create variability

in measured aerody

namic values. To address this, the agencies are emplo yi ng a bin sy stem for ae rod yn amic drag values, and varying values will be grouped in the same bin. 454 The agencies anticipate investigating varying yaw angles in a subsequent rulemaking for a future phase of the HD National Program. (e) Should the agencies complete an economic/payback analysis prior to beginning to regulate, in order to avoid unintended consequences? The committee recommended that NHTSA’s study (which it expected would precede the NPRM) include a careful economic/pay back an al ys is based on fuel usage b y application and different fuel price scenarios, including operating an d maintenance costs. 455 The committee stated that s tandards that differentiall y affect the capital and operating costs of different vehicle classes can cause purchase of vehicles that are not optimized f

or particular operating conditions, and cautioned that the complexity of truck use and the variability

of duty cycles increase the probability of these unintended consequences. 456 The agencies have included in this NPRM and in the DRIA a draft economic/pay

ba ck anal ysis based on industry average operating cycles and expectations for ongoing maintenance costs. The agencies seek comment on the assumptions and anal ys is presented in Section VIII of the preamble and Chapter 9 of the DRIA. In particular, the agen cies request comment on the ability of these average assumptions to reflect pay

back periods for the industry as a whole and what if any changes the agencies should make in the anal yses for the final rulemaking consistent with the recommendations of the NAS

.

453 Id . at 2

- 40, Finding 2

- 4. 454 See Section II of this preamble. 455 See Note 416 above at 6

- 46, Recommendation 6

- 1. 456 Id . at 6

- 47, Finding 6

- 12.390 of 54 1 (f ) How should the agencies account for indirect effects and unintended consequences as a result of the proposed HD National Program? The committee stressed the need of regulators to consider a number of effects in the development of an y proposals to regul ate HD fuel consumption, 457 specifically fleet turnover impacts and pre

- buy effects; 458 the rebound effect ; 459 vehicle class shifting effects; 460 e nvi ronmental co

- benefits and costs; 461 congestion ; 462 safety ; 463 and incremental weight impacts

. 464 While the committee did not examine any of these effects in depth, it stated that it believed that a rebound effect likely exists, and that estimates of fuel savings from regulatory standards will be somewhat misestimated if the rebound effect is not considered. 465 In response, whi le the agencies have initiated analy ses of these unintended consequences, they

have not all been completed in time to be incorporated into this NPRM. The NAS committee itself noted the lack of available information on these effects, especially

as compared to the wealth of information available for light

- duty fuel econom y and GHG regulatory anal ys is. Much of this work must simply be done from scratch. The agencies have included estimates of the rebound effect in this NPRM and DRIA, 466 but we hope to have an al ys es of other effects available for the final rule. (3) NAS findings and recommendations with which the proposed HD National Program is not entirely consistent, and why the agencies have chosen a different path (a ) Should the agencies regulate final

-stage manu facturers? The committee recommended that NHTSA regulate the final stage manufacturers since they have the greatest control over the design of the vehicle and its major subsy stems that affect fuel consumption. 467 However, this recommendation was predicated on a regulatory sy stem that regulated the whole vehicle as a single unit. The agencies are proposing to regulate final

- stage manufacturers for Class 2b/3 trucks, but not for Class 4

- 8 vocational trucks or for Class 7

- 8 line

- haul tractors. While

457 Id . at 6

- 46 , Finding 6

- 9. 458 Id ., Finding 6

- 10. 459 Id ., Finding 6

- 11. 460 Id . at 6

- 47, Finding 6

- 12. Of particular concern is the potential for fleets to purchase vehicles classified for purposes of our regulations as “vocational” trucks, in order to avoid the significant capital costs associated with the addition of aero improvements, weight reductions, and an APU, and then convert them to a tractor. The agencies believe we have addressed this potential loophole, as discussed in Section [XX]. 461 See Note 416 above, Finding 6

- 13. 462 Id ., Finding 6

- 14. 463 Id ., Findings 6

- 16 and 6

- 17. 464 Id ., Finding 6

- 16. 465 Id ., Finding 6

- 11. 466 See Section VIII of this preamble and Chapter 9 of the draft RIA. 467 See Note 416 above at 8

- 17, Recommendation 8

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391 of 54 1 choosing n ot to regulate the whole vehicle as a single unit for this first phase of the HD National Program means that the agencies’ initial rule will not achieve the maximum potential benefits sought by NAS through its approach, the agencies believe that the benefi ts of implementing regulations more quickly outweigh the drawbacks. Additionally , the proposed HD National Program approach eliminates dealing with thousands of final

- stage manufacturers in the first phase of regulation, many of whom are small businesses and could be unduly affected by

these regulations in this time frame. (b ) What should the agencies do about component testing data? The committee recommended that, in order to ensure consistent data from component manufacturers for certification and compliance modeling, NHTSA establish a standardized test protocol and safeguards for the confidentiality of that component data. 468 To that end, the committee recommended that NHTSA implement as soon as possible a major engineering contract to anal yz e several actual vehicles in several applications and develop an approach to component testing data in conjunction with vehicle simulation modeling to arrive at LSFC data for these vehicles. 469 The agencies believe that these concerns are less of an issue with the proposed H D National Program. As discussed above, test protocols for Class 2b / 3 test protocols are already standardized , and both the agencies and the manufacturers know what to expect in the data. Additionally , for Classes 3 to 8, we know what to expect in the en gine testing and data, and since the vehicle testing uses a simplified bin approach, even though there may be some loss of accuracy and potential for gaming, the agencies believe that this is the fastest way

to get regulations implemented while addressing the problem of a lack of standardized test protocol/safeguards for data. The agencies anticipate addressing this issue on an ongoing basis in subsequent rulemakings for later phases of the HD National Program. (c) How should the agencies validate a combined v ehicle simulation/component testing compliance approach? The committee recommended that a ctual vehicles should also be tested by appropriate full

- scale test procedures to confirm actual L SFC values and reductions measured with fuel consumption reduction te chnologies , as compared to the more cost

effective fleet certification approach. 470 As discussed above, the agencies believe that this is less of a concern for the proposed HD National Program since the agencies are not proposing to regulate the whole vehicl e as a single sy stem . The agencies will continue to conduct tests of complete vehicles for audit purposes as the HD National Program develops and as time and resources allow.

468 Id

. 469 Id . at 8

- 20, Recommendation 8

- 5. 470 Id . at 8

- 19, Recommendation 8

- 4.392 of 54 1 (d ) How should the agencies consider HD regulation in Europe and Japan? The committe e suggested that the HD fuel consumption regulations in Japan, and those under consideration and study by the European Commission, provide valuable input and experience to the U.S. plans. The committee stated that in Japan the complexity of HD vehicle con figurations and duty cycles was determined to lend itself to the use of computer simulation as a cost

- effective means to calculate fuel efficiency , and that the EC studies so far indicate plans to develop and use simulations in their expected regulatory

s y stem. The committee noted that Japan is not using extensive full

- vehicle testing in the certification process, despite the fact that its HD vehicle manufacturing diversity is less than in the U.S., with relativel y few HD vehicle manufacturers and no indep endent engine companies. The agencies have reviewed the Japanese and planned EC HD regulations to the extent possible given the time frame for this rulemaking and considered those approaches. However, the proposed HD National Program differs from the Japanese and planned EC HD programs. The agencies agree that international harmonization in HD fuel consumption/GHG regulations is desirable and expect harmonization may increase over time, given the global presence of man y HD vehicle manufacturers. (e) How much engineering work needs to be done before HD fuel consumption regulations can be implemented? The committee stated that s ignificant engineering work is needed to produce a regulatory

approach that produces cost effective and accurate results, which can pro vide meaningful data to vehicle purchasers. 471 While the agencies emphasize that much engineering work has already been undertaken in support of this proposed HD National Program, we believe, as discussed above, that the need for engineering work perceived b y NAS is reduced somewhat based on the structure of the proposed program. Since the agencies are not regulating transmission ratios, final drive ratio, and tire size; since the agencies are not regulating the complete vehicle as a single unit and instead separating the engine from the vehicle; and since the agencies are building off of existing regulatory programs for light

- dut y vehicles and HD criteria pollutant emissions wherever possible, we believe that we have created a solid basis for the HD National Program that will address NAS’ concerns in this regard. 

## XI . St atutory and Executive Order Reviews (1) Executive Order 12866: Regulatory Planning and Revie w Under section 3(f)(1) of Executive Order (EO) 12866 (58 FR 51735, October 4, 1993), this action is an “economically significant regulatory

action” because it is likely to have an annual effect on the econom y of $100 million or more. Accordingly, the

471 Id . at 8

- 20, Finding 8

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393 of 54 1 agencies submitted this action to the Office of Management and Budge t (OMB) for review under EO 12866 and an y changes made in response to OMB recommendations have been documented in the docket for this action. N HTSA is also subject to the Department of Transportation’s Regulatory Policies and Procedures

. T h e s e proposed ru le s are also significant within the meaning of the DOT Regulatory

Policies and Procedures. E.O. 12866 additionally require s NHTSA to submit this action to OMB for review and document any changes made in response to OMB recommendations

. In addition, the agencies prepared an anal ys is of the potential costs and benefits associated with this action. This analy sis is contained in the Draft Regulatory Impact Analy sis, which is available in the docket for this proposal and at the docket int ernet address listed under ADDRESSES above. (2) National Environmental Policy Act [NHTSA will provide] (3) Paperwork Reduction Act The information collection requirements in this propos al have been submitted for approval to the Office of Management and Budget (OMB ) under the Paperwork Reduction Act , 44 U.S.C. 3501 et seq . The Information Collection Request (I CR) document prepared b y EPA has been assigned EPA I CR number 2394.01

. The Agency

proposes to collect information to ensure compliance with the provisions in this proposal . This includes a variety of testing, reporting and recordkeeping requirements for vehicle manufacturers. Section 208(a) of the Clean Air Act requires that vehicle manufacturers provide information the Administrator may reasonabl y require to determine compliance with the regulations; submission of the information is therefore mandatory . We will consider confidential all information meeting the requirements of section 208(c) of the Clean Air Act. It is estimated that this collection affects approximately 35 engine and vehicle manufacturers. The information that is subject to this collection is collected whenever a manufacturer applies for a certificate of conformity . Under Section 206() of the Clean Air Act (42 USC 7521), a manufacturer mu st have a certificate of conformity before a vehicle or engine can be introduced into commerce. The burden to the manufacturers affected b y this proposal has a range based on the number of engines and vehicles a manufacturer produces. The total estimate d burden associated with this proposal is 23,500 hours annually (see Error! Reference source not found. Error! Reference source not found. ). T h is estimated burden for engine and vehicle manufacturers is a total estimate for new reporting requirement s. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, insta ll, and utilize technology and394 of 54 1

sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicabl e instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. Table XI - 1 Burden for Reporting and Recordkeeping Requirements Number of Affected Vehicle Manufacturers 35 Annual Labor Hours for Each Manufacturer to Prepare and Submit Required Information Varies Total Annual Information Collection Burden 23,500 Hours An agency

may not conduct or sponsor, and a person is not required to respond to a collection of information unless it display s a currently valid OMB control number. The OMB control numbers for EPA's regulations in 40 CFR are listed in 40 CFR part 9. To comment on the Agency ’s need for this information, the accuracy of the provided burden estimates, and an y suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a p ublic docket for this proposal , which includes this I CR, under Docket ID number EPA HQ - OAR- 2010 - 0162 . Submit any comments related to the I CR for this propos al to EPA and OMB. See ‘Addresses’ section at the beginning of this notice for where to submit co mments to EPA. Send comments to OMB at the Office of Information and Regulatory

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Since OMB is required to make a decision concerning the I CR between 30 and 60 day s after [ Insert date of publication in the FEDERAL REGISTER ], a comment to OMB is best assured of having its full effect if OMB receives it b y [ Insert date 30 days after publication in the FEDERAL REGISTER ]. The final rule s will re spond to any OMB or public comments on the information collection requirements contained in this proposal. (4) Regulatory Flexibility Act (a ) Overview The Regulatory

Flexibility

Act (RFA) generall y requires an agency to prepare a regulatory

flexibility

analy sis o f an y rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or an y other statute unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. S mall entities include small businesses, small organizations, and small governmental jurisdictions. For purposes of assessing the impacts of this proposal on small entities, small entity is defined as: (1) a small business as defined by the Small BusinessDraft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

395 of 54 1 A dministration’s (SBA) regulations at 13 CFR 121.201 (see Table XI
- 2 below); (2) a small governmental jurisdiction that is a government of a cit y, count y, town, school district or special district with a population of less than 50, 000; and (3) a small organization that is any

not
- for

- profit enterprise which is independently owned and operated and is not dominant in its field. Table XI
- 2 provides an overview of the primary SBA small business categories included in the heav y - duty engine and vehicle sector: Table XI - 2 : Prim ary SBA Small Business Categories in the Heavy - Duty Engine and Vehicle Sector Industry a Defined as small entity by SBA if less than or equal to: NAICS Codes b
Motor vehicle manufacturers, engine and truck manufacturers 1000 employees 336111 336112 336120 Commercial importers of vehicles and vehicle components $7.0 million annual revenue 811112

811198 541514 Alternative fuel veh icle converters Sec. 42

–Wholesale trade is not applicable to government procurement of supplies 500 employ ees 1000 employees 336111

336112 422720 454312 541514 541690 811198 Truck trailer manufacturers 500 employ ees 336212 Notes: a Heavy
- duty engine and vehicle entities that qualify as small businesses would not be subject to th e s e proposed rule s . We are deferring action on small vehicle entities, and we intend to address these entities in a future rule. b North American Industrial Classification Sys tem (b ) Summary of Potentially Affected Small Entities The agencies have not conducted an Initial Regulatory Flexibility

Anal ys is for the propos al because we are proposing to certify that the se rule s would not have a significant economic impact on a substantia l number of small entities. The agencies are proposing to defer standards for manufacturers meeting SBA’s definition of small business as described in 13 CFR 121.201 due to the short lead time to develop this propos al , the extremely small fuel savings and emissions contribution of these entities, and the potential need to develop a program that would be structured differentl y for them (which would require more time). The agencies would instead consider appropriate fuel396 of 54 1

consumption and GHG standards for th ese entities as part of a future regulatory action. This includes small entities in several distinct categories of businesses for heavy - dut y engines and vehicles: chassis manufacturers, combination tractor manufacturers, and alternative fuel engine converters. Based on preliminary

assessment, the agencies have identified a total of about 17 engine manufacturers, 3 complete pickup truck and van manufacturers, 11 combination tractor manufacturers and 43 heav y dut y chassis manufacturers. Of these, about 15 entities fit the Small Business Administration (SBA) criterion of a small business. There are approximately three engine converters, two tractor manufacturers, and ten heavy

- dut y chassis manufacturers in the heavy

- dut y engine and vehicle market that are small businesses. (No major heavy

- duty engine manufacturer s, heav y duty chassis manufacturers, or tractor manufacturers meet the small

- entity criteria as defined by SBA). The agencies estimate that these small entities comprise less than 0.35 percent of the total heav y - dut y vehicle sales in the U.S., and therefore the proposed deferment will have a negligible impact on the fuel consumption and GHG emissions reductions from the proposed standards. To ensure that the agencies are aware of which companies w ould be deferred, the agencies are proposing that such entities submit a declaration to the agencies containing a detailed written description of how that manufacturer qualifies as a small entity under the provisions of 13 CFR 121.201. Some small entities , such as heav y dut y tractor and chassis manufacturers, are not currently covered under criteria pollutant motor vehicle emissions regulations. Small engine entities are currentl y covered b y a number of EPA motor vehicle emission regulations, and they routinely submit information and data on an annual basis as part of their compliance responsibilities. Because such entities are not automatically

exempted from other EPA regulations for heav y - duty engines and vehicles, absent such a declaration, EPA would a ssume that the entity was subject to the greenhouse gas control requirements in this GHG proposal. The declaration to the agencies would need to be submitted at time of either engine or vehicle emissions certification under the Heavy Dut y Highway Engine p rogram . The agencies expect that the additional paperwork burden associated with completing and submitting a small entity declaration to gain deferral from the proposed GHG and fuel consumption standards would be negligible and easil y done in the context o f other routine submittals to the agencies . However, the agencies have accounted for this cost with a nominal estimate included in the Information Collection Request completed under the Paperwork Reduction Act. Additional information can be found in the Paperwork Reduction Act discussion in Section XI . (3) Paperwork Reduction Act . B ased on this, the agencies are proposing to certify

that the rule s would not have a sign ificant economic impact on a substantial number of small entities. The agencies continue to be interested in the potential impacts of the propos al on small entities and welcome comments on issues related to such impacts. (c) Conclusions We therefore certify

that this propos al will not have a significant economic impact on a substantial number of small entities.Draft Joint EPA/NHTSA NPRM Preamble HD GHG/FC St andards ( 12/6/2010 )

397 of 54 1 (5) Unfunded Mandates Reform Act Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), P.L . 104

- 4, establishes requirements for Federal agencies to assess the effects of their regulatory actions on State, local, and tribal governments and the private sector. Under section 202 of the UMRA, the agencies generally must prepare a written statement, including a cost

benefit anal ys is, for proposed and fina l rules with “Federal mandates” that may result in expenditures to State, local, and tribal governments, in the aggregate, or to the private sector, of $100 million or more in an y one ye ar. Before promulgating a rule for which a written statement is neede d, section 205 of the UMRA generall y requires the agencies to identify and consider a reasonable number of regulatory alternatives and adopt the least costly , most cost
- effective or least burdensome alternative that achieves the objectives of the rule. The provisions of section 205 do not apply when they

are inconsistent with applicable law. Moreover, section 205 allows the agencies to adopt an alternative other than the least costl y, most cost
- effective or least burdensome alternative if the Administrator (of either agency) publishes with the final rule an explanation why that alternative was not adopted. Before the agencies establish any regulatory

requirements that may

significantly or uniquely

affect small governments, including tribal governments, they must have developed under section 203 of the UMRA a small government agency plan. The plan must provide for notifying potentiall y affected small governments, enabling officials of affected small governments to have meaningful and timely input in the devel opment of EPA and NHTSA regulatory proposals with significant Federal intergovernmental mandates, and informing, educating, and advising small governments on compliance with the regulatory

requirements. This proposal contains no Federal mandates (under th e regulatory provisions of Title II of the UMRA) for State, local, or tribal governments. The rule s impose no enforceable dut y on an y State, local or tribal governments. T he agencies have determined that this proposal contains no regulatory requirements that might significantl y or uniquely

affect small governments. T he agencies have determined that this proposal contains a Federal mandate that may result in expenditures of $ 100 or more for the private sector in an y one year . As summarized above in Sectio n I .D, the agencies expect this proposal to cost industry approximately

$8 billion over the lifetime of the vehicles produced in the first five y ears of the program, and in that same time yield approximately $49 billion in benefits

. T he agencies believe that the proposal represents the least costl y, most cost
- effective approach to achieve the statutory requirements of the rule s . Section VIII.L, above, explains why the agencies believe that the fuel savings that would result from this proposal would lead t o lower prices economy

- wide, improving U.S. international competitiveness

. The costs and benefits associated with the proposal are discussed in more detail above in Section VIII and in the Draft Regulatory Impact Analy sis, as required by

the UMRA.398 of 54 1 (6) Executiv e Order 13132 (Federalism) This action does not have federalism implications. It will not have substantial direct effects on the States, on the relationship between the national government and the States, or on the distribution of power and responsibiliti es among the various levels of government, as specified in Executive Order 13132. This proposal would apply to manufacturers of motor vehicles and not to state or local governments. Thus, Executive Order 13132 does not apply to this action

. Although sect ion 6 of Executive Order 13132 does not apply

to this action, the agencies did consult with representatives of state governments in developing this action

. In the spirit of Executive Order 13132, and consistent with EPA and NHTSA policy to promote commun ications between the agencies and State and local governments, the agencies specificall y solicit comment on this proposed action from State and local officials. (7) Executive Order 13175 (Consultation and Coordination with Indian Tribal Governments) Th e s e prop osed rule s do not have tribal implications, as specified in Executive Order 13175 (65 FR 67249, November 9, 2000). This proposal will be implemented at the Federal level and impose compliance costs only on vehicle manufacturers. Tribal governments would be affected onl y to the extent they purchase and use regulated vehicles. Thus, Executive Order 13175 does not apply to this proposal

. T he agencies specificall y solicit additional comment on this propos al from tribal officials. (8) Executive Order 13045: “Pro tection of Children from Environmental Health Risks and Safety Risks” This action is subject to EO 13045 (62 FR 19885, April 23, 1997) because it is an economicall y significant regulatory action as defined by EO 12866, and the agencies believe that the env ironmental health or safet y risk addressed b y this action may have a disproportionate effect on children. A s ynthesis of the science and research regarding how climate change may

affect children and other vulnerable subpopulations is contained in the Technical Support Document for Endangerment or Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act, which can be found in the public docket for this propos al

. 472 A summary of the anal ys is is presented below. With respect to GHG emissions, the effects of climate change observed to date and projected to occur in the future include the increased likelihood of more frequent and intense heat waves. Specifically , EPA’s anal ys is of the scientific assessment literature has determi ned that severe heat waves are projected to intensify in magnitude, frequency , and

472 U.S. EPA. (2009). Technical Support Document for Endangerment or Cause or Contribute Findi ngs for Greenhouse Gases under Section 202(a) of the Clean Air Act. Washington, D.C.: U.S. EPA.. Docket EPA

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399 of 54 1 duration over the portions of the U.S. where these events already occur, with potential increases in mortality

and morbidity , especially among the young, elderl y, and frail. EPA has estimated reductions in projected global mean surface temperatures as a result of reductions in GHG emissions associated with the standards proposed in this action (Section II). Children may receive benefits from reductions in GHG emissions beca use they are included in the segment of the population that is most vulnerable to extreme temperatures. For non
- GHG pollutants , EPA has determined that c limate change is expected to increase regional ozone pollution, with associated risks in respiratory in fection, aggravation of asthma, and premature death. The directional effect of climate change on ambient PM levels remains uncertain. However, d isturbances such as wildfires are increasing in the U.S. and are likel y to intensify in a warmer future with drier soils and longer growing seasons. PM emissions from forest fires can contribute to acute and chronic illnesses of the respiratory s ys tem, particularly

in children, including pneumonia, upper respiratory

diseases, asthma and chronic obstructive pulmonary diseases. The public is invited to submit comments or identify peer - reviewed studies and data that assess effects of earl y life exposure to the pollutants addressed b y this propos al

. (9) Executive Order 13211 (Energy Effects) This proposal is not a “signif icant energy

action” as defined in Executive Order 13211, “Actions Concerning Regulations That Significantly Affect Energy

Supply , Distribution, or Use” (66 FR 28355 (May 22, 2001)) because it is not likely to have a significant adverse effect on the suppl y, distribution, or use of energy. In fact, this proposal has a positive effect on energy suppl y and use. Because the GHG emission standards proposed today result in significant fuel savings, this proposal encourages more efficient use of fuels. Therefo re, we have concluded that this proposal is not likely to have an y adverse energy

effects. Our energy

effects analy sis is described above in Section VIII.H
. (10) National Technology Transfer Advancement Act Section 12(d) of the National Technology Transfer and Advancement Act of 1995 (“NTTAA”), Public Law No. 104

- 113, 12(d) (15 U.S.C. 272 note) directs the agencies to use voluntary

consensus standards in its regulatory activities unless to do so would be inconsistent with applicable law or otherwise impractical . Voluntary consensus standards are technical standards ( e.g. , materials, specifications, test methods, sampling procedures, and business practices) that are developed or adopted by voluntary

consensus standards bodies. NTTAA directs the agencies to provi de Congress, through OMB, explanations when the agencies decide not to use available and applicable voluntary consensus standards. For CO 2 , N 2 O, and CH 4 emissions and fuel consumption from heav y duty engines , the agencies are proposing to collect data over the same tests that are used for400 of 54 1

the Heav y Dut y Highway Engine program. This will minimize the amount of testing done by manufacturers, since manufacturers are already required to run these tests. For CO 2 , N 2 O, and CH 4 emissions and fuel consumption fr om complete pickup trucks and vans , the agencies are proposing to collect data over the same tests that are used for the Heavy

Dut y Highway

Engine program and California Air Resources Board

. This will minimize the amount of testing done b y manufacturers, since manufacturers are alread y required to run these tests. For CO 2 emissions and fuel consumption from heavy dut y combination tractors and vocational trucks , the agencies are proposing to collect data through the use of a simulation model instead of a fu ll

- vehicle chassis dy namometer testing

. This will minimize the amount of testing done b y manufacturers

. EPA's compliance assessment tool is based upon well

- established engineering and phy sics principals that are the basis of general academic understandin g in this area, and the foundation of an y dy namic vehicle simulation model, including the models cited by I CCT in its study473 and cited by the NAS committee in its published report

. 474 Therefore, the EPA's compliance assessment tool satisfies the description of a consensus

. For the evaluation of tire rolling resistance input to the model, EPA is proposing to use the I SO 28580 test, a voluntary consensus methodology . EPA is proposing to allow several alternatives for the evaluation of aerodynamics which allo ws the industry to continue to use their own evaluation tools because EPA does not know of a single consensus standard available for heav y dut y truck aerod yn amic evaluation. For air conditioning standard s, EPA is proposing to use a consensus methodology de veloped b y the Societ y of Automotive Engineers (SAE). (11) Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low - Income Populations Executive Order (EO) 12898 (59 FR 7629 (Feb. 16, 1994)) establishes federal executive policy

on environmental justice. Its main provision directs federal agencies, to the greatest extent practicable and permitted b y law, to make environmental justice part of their mission by

identifying and addressing, as appropriate, disproporti onately high and adverse human health or environmental effects of their programs, policies, and activities on minority

populations and low

- income populations in the United States. With respect to GHG emissions, EPA has determined that th ese proposed rule s will not have disproportionately high and adverse human health or environmental effects on minority

or low

- income populations because it increases the level of environmental protection for all affected populations without having an y disproportionately hi gh and adverse human health or environmental effects on any population, including any minorit y

473 ICCT. ICCT Evaluation of Vehicle Simulation Tools. 2009. Last viewed on August 5, 2010 at http://www.theicct.org/information/reports/icct_evaluation_of_vehicle_simulation_tools 474 NAS Study. Page S

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401 of 54 1 or low

- income population. The reductions in CO 2 and other GHGs associated with the standards will affect climate change projections, and EPA has estimated reduc tions in projected global mean surface temperatures (Section VI ). Within communities experiencing climate change, certain parts of the population may be especially vulnerable; these include the poor, the elderly , those already in poor health, the disabled , those living alone, and/or indigenous populations dependent on one or a few resources. 475 In addition, the U.S. Climate Change Science Program476 stated as one of its conclusions: “The United States is certainly capable of adapting to the collective impact s of climate change. However, there will still be certain individuals and locations where the adaptive capacity is less and these individuals and their communities will be disproportionally impacted b y climate change.” Therefore, these specific sub

- popul ations may receive benefits from reductions in GHGs. For non
- GHG co

- pollutants such as ozone, PM 2.5 , and toxics, EPA has concluded that it is not practicable to determine whether there would be disproportionately high and adverse human health or environm ental effects on minority and/or low income populations from this propos al

. The public is invited to submit comments or identify peer - reviewed studies and data that assess effects of earl y life exposure to the pollutants addressed b y this propos al

. 

## XII. St at utory Pr ovisions and Legal Authority A. EPA Statutory authorit y for the vehicle controls proposed today is found in section 202 (a) (which authorizes standards for emissions of pollutants from new motor vehicles which emissions cause or contribute to air pol lution which may reasonabl y be anticipated to endanger public health or welfare), 202 (d), 203

- 209, 216, and 301 of the Clean Air Act, 42 U.S.C. 7521 (a), 7521 (d), 7522, 7523, 7524, 7525, 7541, 7542, 7543, 7550, and 7601. 

### B. NHTSA Statutory authorit y for the fuel consumption standards proposed today is found in section 103 (which authorizes a fuel efficiency improvement program, designed to achieve the maximum feasible improvement to be created for commercial medium

- and heav y - dut y on - highway

vehicles and wor

k trucks, to include appropriate test methods,

475 U.S. EPA. (2009). Technical Support Document for Endangerment or Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act. Washington, D.C.: U.S. EPA. Docket EPA

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- 11292 476 CCSP (2008 ) Analyses of the effects of global change on human health and welfare and human systems

. A Report by the U.S. Climate Change Science Program and the Subcommittee on Global Change Research. [Gam ble, J.L. (ed.), K.L. Ebi, F.G. Sussman, T.J. Wilbanks, (Authors)]. U.S. Environmental Protection Agency, Washington, DC, USA.402 of 54 1

measurement metrics, standards, and compliance and enforcement protocols that are appropriate, cost

- effective and technologically feasible) of the Energy

Independence and Security Act of 2007, 49 U.S.C. 32902( k).